June 26, 2017…

June 26, 2017

Dear Scott Gibson,

Comment on the Draft Strategic Policy for Bait Management in Ontario, ERB Reference Number 012-9791 Bait is an important pathway of aquatic invasive species (AIS) movement and the draft strategic policy for bait management in Ontario proposes new rules to help mitigate the risk of AIS spread. The Invasive Species Centre welcomes this draft strategic policy for bait management in Ontario and its focus on providing direction for the sustainable use and harvest of bait to reduce ecological risks while maintaining a viable bait industry. The most critical of these bait management proposals rest on industry education and outreach. Education is the key to prevention, and prevention is the best use of limited resources to manage all invasive species. The Invasive Species Centre (ISC) agrees that all bait harvesters and retailers should be educated on the identification of AIS to prevent invasive species in bait supplies.

Invasive species of concern should be listed under the Invasive Species Act, making it illegal for bait harvesters to possess them. Further focus should be put on the proper removal of invasive bycatch by bait harvesters. A study conducted by Drake and Mandrak in 2014 (Ecological Risk of Live Bait Fisheries: A New Angle on Selective Fishing) showed that managing invasive bait fish at the source would result in a greater reduction of AIS release than if it is managed at the angler level. This could also provide a secondary control of AIS by having the bait harvesters cull any AIS caught. Prevention at the source would ensure that enforcement efforts could be put to best use at the baitfish producer level which would reduce the amount of time needed for inspection with the angler.

The ISC feels that more could be done in terms of regulating bait harvesters to ensure they are not spreading AIS between fishing operations. Minnesota has recently suggested updates to their bait harvesting policies to reduce the risk that bait harvesters are transporting AIS in their equipment. This includes assessing the presence of zebra mussel veligers in bait water, determining if altering the time of harvest reduces the risk of capturing veligers, decontamination of equipment between harvests, and allowing bait harvesters to carry several sets of harvesting equipment to reduce spread from one waterbody to another. These steps would reduce the risk of transporting microscopic AIS such as spiny waterflea and zebra mussel veligers. We strongly agree with the enhanced regulations around the movement of personally harvested bait; bait that is harvested by individuals should only be used in the water body that it is caught. This restriction prevents unknown transfer of AIS and non-resident species. Along with this restriction, increased enforcement of dumping excess bait into waterbodies would reduce the spread of AIS. With the enforcement of the Invasive Species Act, anyone transporting invasive fish in their bait can be subject to a fine. This penalty adds another level of protection against the movement of personally harvested invasive species as bait. These enforceable regulations, and extensive outreach and education targeted at anglers, should help to reduce the risk of personally harvested bait as a pathway.

The removal of sculpins, darters, and sticklebacks from the approved bait fish list is a highly effective way to reduce the chance of accidental release of an invasive species such as round goby. This change will make it easier for bait harvesters and retailers to quickly identify if there is a species that shouldn’t be present in their bait. Preventing accidental inclusion of invasive species at the source of the bait industry is the cheapest and most efficient way to mitigate further introductions. The ISC supports the Ministry of Natural Resources and Forestry’s efforts to manage bait as a pathway for AIS introduction.

The Ministry of Natural Resources and Forestry should regularly review bait as a pathway of AIS to ensure that the current and proposed regulations are effective in reducing the spread of invasive species. Regular inspections of bait harvesters and retailers would determine if AIS are being sold as bait, and frequent checks of bait buckets would determine if there is personal harvest and movement of AIS. If this pathway continues to be an access point for AIS into Ontario’s inland lakes and rivers, the ISC recommends that more restrictive solutions should be implemented. Multiple provincial parks in Ontario prohibit the use of live bait to protect native species, and if the live bait industry continues to lead to AIS introductions, the province should look to expand live bait restrictions in threatened areas or province-wide, like the approach in several U.S. states.

In closing, the Invasive Species Centre looks forward to continued discussion on how bait management policies and program can be strengthened in Ontario to protect our lakes and rivers from the threat of invasive species.

Sincerely,

Tracey Cooke

Executive Director

Invasive Species Centre

[Original Comment ID: 209939]