I'll just take a moment to say thank you to the committee members for having me here. I appreciate it. As you can imagine, it's a long drive from northern Canada.
I'm the owner and founder of Lazy Bear Lodge Limited. Lazy Bear is based in Churchill, Manitoba, and has been in operation for over 20 years. It offers a unique lodging experience to its customers, which, along with various other activities, includes beluga whale-watching tours in the summer months. I also operate an organic farm and greenhouse on Hudson Bay.
I am also the chair of the Churchill Beluga Whale Tour Operators Association, the CBWTOA, a group of independent small businesses that operate beluga whale-watching tours in and around Churchill and adjacent areas of the western Hudson Bay coast. The tours operated by members of our association include viewing and interacting with beluga whales from the shore, aboard vessels and in small craft, including but not limited to kayaking and canoeing. I am also president of the Canadian Coast Guard Auxiliary for Churchill.
CBWTOA has created a series of policies and protocols that protect beluga whales and endeavour to educate, inspire and communicate the value of this unique marine mammal throughout the world. A copy of our code of conduct, which governs our whale-watching tours, can be found at CBWTOA.com. This policy was drafted in part in recognition of the marine mammal regulations issued under the Fisheries Act as they existed prior to June 2018.
The town of Churchill is in serious economic distress. Initially, the port of Churchill closed, and then, approximately one year ago, the Hudson Bay rail line washed out. That rail line was Churchill's primary transportation link to the outside world. OmniTRAX, the railway and port owner, was in a legal dispute with the federal government over responsibility for bringing the rail line back into operation.
The tourism industry is Churchill's largest employer, and that industry is keeping the local economy afloat. The members of our association employ approximately 200 persons, including many indigenous persons. The summer tourism industry in Churchill generates approximately $10 million in revenue. Even prior to the commencement of last summer's whale-watching season, our members were accepting guest reservation bookings for next year. We're hiring and training new employees and making new capital equipment purchases. The Province of Manitoba has spent millions of dollars through Travel Manitoba advertising the products provided by our members.
Regarding the beluga whale population, I want to draw to your attention some facts from a Canadian Science Advisory Secretariat study issued in October 2017 and titled “Estimated abundance of the Western Hudson Bay beluga stock from the 2015 visual and photographic aerial survey”. This study illustrates that the beluga whale population in the western Hudson Bay area is thriving. This population is currently estimated at somewhere between 50,000 and 60,000.
The study illustrates that in the western Hudson Bay area, including the Churchill River and Seal River locations, there is a high density of beluga whales, which congregate in these areas during the summer months. There's a high density of beluga whales that travel up the Churchill River right up to the Port of Churchill. It has been estimated that there can be as many as 5,000 beluga whales in the Churchill River at certain times.
I have been involved in beluga whale-watching activities in and around Churchill for roughly 37 years. I can attest that beluga whales are very intelligent, extremely curious and highly social animals. Because of the high density of beluga whales in the areas mentioned above, and because of their natural curious and social behaviour, it is virtually impossible to avoid coming into proximity with beluga whales during our tour operations. As soon as our boats leave the docks, they are approached by beluga whales, which then follow the boats to any destination they choose. Even if we attempted to sail away from the belugas, they would follow us.
In all my years of involvement with whale-watching, I have never seen any beluga whale injured by whale-watching tour operations. Even though our boats use prop guards, these are virtually unnecessary because beluga whales, in my experience, are far too intelligent and agile to be injured by boat propellers. I have never seen any beluga whale bearing scars from a propeller injury.
Further, in all my years of involvement with whale-watching, I have never seen any beluga whale appearing to be distressed by the activities of whale-watching tours. To the contrary, they exhibit playful conduct and curiosity. We do not attempt to lure beluga whales by feeding them or inducing them in any other way. Frankly, there is no need to do so. As noted, beluga whales approach our vessels the minute we leave shore.
You're no doubt aware of the regulations amending the marine mammal regulations, which were registered on June 22, 2018, and published in the Canada Gazette on July 11, 2018. Attached to the amending regulations is a regulatory impact analysis statement.
The statement identifies the matters that were considered by the government when drafting the amending regulations. For instance, the statement refers to the “risk of injury through collisions with boats or being slashed by their propellers”. It also refers to circumstances that exist in other locations, including the St. Lawrence Seaway.
None of these considerations applies to the whale-watching industry in and around Churchill. As noted, to my knowledge, no beluga whale has ever been injured or distressed because of whale-watching tour operations in this location. As further noted, the beluga whale population is thriving in western Hudson Bay. Their numbers are currently estimated at between 50,000 and 60,000. In contrast, it is my understanding that the beluga whale population in the St. Lawrence Seaway numbers approximately only 500 to 600, and there has been notorious publicity regarding the injury or death of many whales in that area because of collisions with large commercial vessels.
The statement refers to Churchill, but says very little about the circumstances that exist in the Churchill area. It states that an “estimated 366 small to medium whale watching businesses were operating in Canada” in 2015. However, it neglects to mention that there are currently only three whale-watching tour businesses with boats in the water operating outside of Churchill. It also fails to mention that the beluga whale population in western Hudson Bay is large and thriving, and that there is no evidence, scientific or otherwise, which suggests that there is any harm or risk of harm to the beluga whale population in western Hudson Bay because of whale-watching operations.
Further, it fails to note that, unlike other parts of Canada or internationally, beluga whales in western Hudson Bay, because of their dense population, natural curiosity and social behaviour, actively approach boats in the water, including whale-watching tour operation vessels. It further fails to have regard to the fact that it is literally impossible to put a boat in the water in the Churchill area without immediately being near beluga whales.
It therefore appears clear to me that by expressly including the Churchill River, Seal River and western Hudson Bay areas as areas where whale-watching tour activities are restricted without any regard to the actual circumstances that exist in these areas, the amending regulations are extraordinarily unfair, arbitrary and discriminatory with respect to the whale-watching industry in Churchill, which is so vitally important to the economy of Churchill.
The members of our association possess over 100 years of combined experience of watching and interacting with beluga whales in and about Churchill. A copy of our association's code of conduct, which I have provided to the clerk, has been drafted to incorporate rules and restrictions that ensure the welfare of beluga whales being watched. I sincerely believe that the whale-watching activities in the Churchill area are beneficial to the whales and enhance their conservation and protection.
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