This letter is in regards to…

This letter is in regards to the Strategic Policy for Bait Management in Ontario, draft for public comment. I feel there are many issues in this proposed policy that have not been addressed properly and could have many economic impacts while having no success in preventing the spread of invasive species, Which is supposed to be the primary intent of the policy. The following contains a list of the issues, impacts, and some possibly more effective solutions I have thought of. With the perspective of a bait harvester, I feel these views could assist in the decisions to help make this draft more effective with less economically impact. 1.Bait Management Zones:

These proposed bait management zones do not prevent the spread of invasive species through the possibility of it spreading through live bait. These boundaries are connected through many lakes and rivers flowing from one proposed BMZ to another BMZ. If invasive species were introduced into one BMZ, they would surely move through the waterways to other BMZs. A better approach may be to utilize watersheds as boundaries. Starting with the Atlantic and Arctic watershed as a boundary. After these are established, look at the higher risk areas where invasive species are present and use smaller watersheds (e.x. Nipigon river watershed, Ottawa river watershed…..) This system would help prevent the spread of invasive species by preventing them from moving through the multiple watersheds.

In the area of economic impacts, there is a huge possibility of lost jobs and decreased sales in many areas because the proposed BMZ boundaries cut off many bait users from the ability to legally buy and utilize their bait with the vast areas between retail shops and wholesale bait shops. For example, in the proposed BMZ A there will be little access to bait in the area due to the remoteness, yet the demand for bait will be high. Traditionally the bait in the proposed BMZ A is mostly purchased in the northern parts of the proposed BMZ B and C then flown into the proposed BMZ A with the angler. Or the bait is picked up in the proposed BMZ B or C and driven to BMZ A on the very few roads in BMZ A but lots of this bait was harvested in BMZ A. With this lack of availability will come the job loss due to lack of sales which will then lead to lay offs. The drop in sales will not just be bait because the alternative to live bait can be purchased and brought from the USA or large urban centers at very low prices. Therefore, these anglers will have little to no reason to stop at those bait shops whose primary business is selling live bait. These businesses will not have the traffic flow that stops and purchases other items that catch their eyes. Such as souvenirs. Tourist outfitters will also be greatly effected because some will have good access to bait while others will not. The outfitters without live bait will loose customers for that reason which result in the lost revenue and lost jobs for guides, pilots, and general maintenance worker, ect…. Bait harvesters will be greatly effected by these boundaries because they will have bait harvest areas/ blocks they will not be able to utilize if their storage facility is in a different BMZ than the harvest area. Replacing these bait blocks through trading among harvesters is unlikely to be affective and the knowledge of the BHA’s are only known by the harvester. Acquiring bait blocks because they become dormant to another harvester is also unlikely because the harvester’s year end report and daily bait log is the MNR’s only way of monitoring this and if a harvester doesn’t want to let a BHA go dormant he or she will just write that it has been harvested even if it wasn’t actually harvested. It will keep other harvesters out and keeping away competition. Loosing BHA’s will reduce the harvesters amount of bait they can catch and sell resulting in lost revenue and lay offs of bait harvester designates. In some areas where harvester’s storage facility is in one BMZ and most of the BHA’s are in a different BMZ it could result in a total loss of the business. Bait harvesters will also be affected by the proposed BMZ’s much like the retail shops, wholesale shops and tourist outfitters simply because they will not be able to move the bait across the proposed boundaries. It will also put much more competition among harvesters in the more southern areas of zones because the lack of ability to distribute bait in the proposed BMZ A. This will result in harvesters in the northern parts of zones who harvest and sell bait traditionally in BMZ A ,but their storage facility are in the next zone south, to move their bait south causing the southern area harvesters a great increase in competition which result in lost jobs. If these BMZs become law a way to solve some of these problems would be to have a system were bait could be certified to go back into BMZ A for example if a harvester traps all of his bait in BMZ A it could be certified or if some of his or her BHAs are in BMZ B but have very low potential of invasive species the bait could be certified. The MNR would have to decide what BHAs are high risk and which ones are low risk but these exceptions would only be for commercial bait harvesters who are held to a higher standard than the private harvesters. I feel the north end of BMZ B has little potential for the spread of invasive species because there are very few there and the water at the North end of BMZ B flows directly into A. The MNR may be able to put these buffer zones on the north end of other BMZs but I don’t know enough about these areas to say whether or not it would be worth it. If a bait retail store buys solely certified bait they would be able to sell there bait to people going to BMZ A.

2.Live bait use in Provincial Parks

In regards to not allowing live bait use or harvest within provincial parks, it will create much of the same problems as the proposed BMZs. These parks have many tourist establishments whose primary target of customers is anglers. The majority of which use live bait. These rules will make some tourist outfitters loose customers because of it. For harvesters, some of these parks cover thousands of Hectares that they have BHA’s and customers in. This will result in loss of many of their BHA’s and customers. With a loss of their BHA’s there will be a huge amount of bait unavailable for harvest. Resulting in a shortage of bait and loss of possible sales. Leading again to possibly lost revenue and jobs. There is no reason for banning use and harvest of live bait in all provincial parks because of the potential risk of invasive species. The park boundaries do not protect the waters going in and out of the parks. The parks all have individual boundaries. It would be best and have less strain on the industry if the parks assessed the pros and cons of allowing harvest and use of bait inside theses parks individually and put individual rules in place as seen appropriate.

3.Sticklebacks

To ban the use of all sticklebacks just for the reason that they look similar to species that are illegal and could cause environmental impacts is ridiculous. The Brooke stickleback and ninespine stickleback are very common in most of the lakes that harvesters harvest. To an uneducated harvester they could be hard to distinguish from some species that are illegal but ignorance is no excuse! A diligent commercial bait harvester knows the difference in these species and if there is even any question to what you have caught you find out. The commercial bait harvesters are well educated and required to have training on acceptable species of bait. To eliminate the use of all sticklebacks even though they are generally an incidental catch will waste a lot of bait because they will now all have to be removed. Where in the past sticklebacks were only removed if large amounts were caught and there was more sticklebacks mixed in with the more desirable species than a customer would be happy with. To remove all sticklebacks will be quite labour intensive and wasteful.

I could see many people who harvest their own bait for personal use having problems distinguishing legal and illegal sticklebacks but yet again ignorance is no excuse. If the MNR is going to allow the private harvest of bait they should consider an educational program tailored to the private bait harvester or at least make the rules and regulations for private harvesters easier to find and well known to the general public. Right now all you need to be allowed to harvest bait for personal use is a fishing license. In the fishing regulations summary there is very little information on the regulations they are suppose to follow or the potential environmental impacts of what they are doing.

In conclusion to this letter, I feel that the potential negative economic impacts that will arise if this policy becomes law will outweigh the benefits because these proposed rules in many ways will be extremely ineffective on preventing invasive species through he live bait pathway. The key to success will be and will always be harvesters, retailers, and anglers are educated and diligent with their live bait.

[Original Comment ID: 209853]