Mr. Rogers, After…

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Mr. Rogers, After reviewing MR-UGL-2014-01 - A Stocking Plan for Ontario Waters of Lake Superior, I have the following comments, questions, and suggestions. I hope that you will take them into consideration before finalizing this report. As a member of the executive board for the Thunder Bay Salmon Association, I am pleased to see progress towards setting clear objectives and goals related to our stocking efforts, since the absence of a plan has created some controversy for us over the last few years. As a member of the angling community in the Thunder Bay District, I feel that this document lacks the clarity and direction required to be useful when it is eventually called upon at the conclusion of this stocking plan. In the beginning of this document, it states that, it “provides an analysis of the efficacy of the recent activities relative to existing plans and agreements”. The theme of analyzing 'efficacy', the ability to produce a desired result, is repeated throughout the document. From page 6 it is clear that the the desired result of the municipal bodies and angling community which lobbied the governments to introduce the Pacific Salmon Management Policy of 1987, was related specifically to the “potential for tourism revenues” resulting from the introduction of a pacific salmon sport fishing industry. Although I agree that the goal to “increase fish stocking for rehabilitation and to provide angling opportunities” lacks clarity and a measurable objective, I believe the desired result of improving angling opportunities is abundantly clear. On page 11, it says “If there is no evidence that stocked fish are surviving and therefore are not making a contribution to the fishery, the efficacy of the activity is drawn into question”. I agree with the qualitative properties of this statement, however, the way in which this requirement is quantified has a fundamental flaw. In the development of the measurable objectives starting on page 20 of the report, there is no basis for the implied desired result, and corresponding measurement of the ratio between natural and stocked fish. As stated in the report, there are naturally reproducing salmon already present in the Kaministiqua River, however there have been no efforts to date to determine the population size of pacific salmonoids in this, or any other tributary of lake Superior. Without sizing the existing population, how meaningful is a goal of 50% wild to 50% stocked fish? (or any other ratio). It is not clear from this report whether a higher ratio of wild fish to stocked fish implies that the stocking has been successful (ie, stocked fish are now reproducing naturally), or that this same higher ratio means that stocking efforts are not successful (ie, stocked fish are not returning). As both results can be interpreted in both ways, this measurement is meaningless when assessing the efficacy of the stocking effort. From above, the desired result of 'improving angling opportunities', should be the basis for evaluating the efficacy of the chinook stocking program, as it was the basis for its introduction, and continues to be the driving force behind community interest in this effort. Although not idiomatic, I feel that that in the absence of a population study, a 'catch per unit effort' (CPUE) of pacific salmon should be a key factor in evaluating the success of the stocking program. Although some attempt was made in evaluating this during the MNR/TBSA's three year creel survey, to my knowledge, the ministry has not followed through with their side of partnership, in compiling and published the results of the survey. Furthermore, this reports attempt to evaluate CPUE in terms of derby entries, is also fundamentally flawed. Since anglers were only allowed to enter 1 fish per day in the derby, it is not possible to calculate CPUE by derby entries alone. Furthermore, no survey of how many hours of fishing were conducted in order to establish a CPUE. I do not believe it is not possible to calculate CPUE without having a good measurement of either the number of catch, or the unit effort; this should go without saying. If the annual derby is found to be a useful source of data in the future, I would recommend consulting with the TBSA on what data should be collected, and providing information on how it will be used. I am certain that asking the right questions at the right times could be a useful tool. In speaking with other anglers, and comparing trends in recent years, qualitatively I can say that we are currently in a downward slide in terms of CPUE. Quantifying this will certainly be a challenge, but an even greater challenge is explaining why this may be happing, and determining if a change is required. Although I don't feel like there is currently enough information to justify a change in the egg collection permit for the Thunder Bay Salmon Association to reduce the number of stocked fish to 120,000; I don't think this number is a very drastic change when compared to the actual number of stocked fish per year. Regards,