I strongly disagree with…

I strongly disagree with this proposed change.

Many cottagers, vacationers, and other travelling anglers legally harvest bait for personal use when fishing away from their home residence, and do so with minimal ecological risk. 'Visiting' anglers tend to use their bait locally to where they harvest it because (a) it is undesirable to travel an excessive distance from their angling destination to harvest bait, (b) transporting personally-harvested bait over long distances and keeping it alive is difficult without specialized equipment to oxygenate a tank or storage bag, and (c) many anglers are conscious of the ecological risks of transporting baitfish.

The proposed strategy would prohibit visiting anglers from harvesting bait for personal use when fishing outside their home BMZ, instead requiring that they purchase it (or go without). Purchasing bait which could otherwise be harvested adds a considerable cost to a fishing trip, and it removes the opportunity to partake in a satisfying, time-honoured, and ecologically responsible outdoor activity (trapping or harvesting one's own bait). A visiting angler harvesting their own bait poses no greater risk than a local angler doing the same, especially given that the visiting angler is even more likely to use that bait locally, having already arrived at their fishing destination (cottage, camp, or other).

In some locations, the bait supply for purchase is limited or non-existent. The requirement to purchase bait would in some instances result in visiting anglers travelling further to buy bait than they would have travelled to catch their own! Added demand on small bait shops would increase prices, and if/when bait supply runs out, visiting anglers abiding by the law would have no opportunity to obtain bait, even if it is readily available to harvest. Those visiting anglers who camp and fish remotely without means to carry in locally purchased bait (preferring to catch their own on-site or en route) would be similarly restricted.

Adhering to the new regulations would become complicated for anglers living near the boundaries of the BMZ's, who would routinely travel short distances across them for angling opportunities, or perhaps to harvest bait. Carrying bait across these boundaries (even over a distance of metres) would become illegal, while transporting the same bait hundreds of kilometers within the same BMZ would be allowed. Similarly, bait stores located on the "wrong" side of a BMZ boundary might unfortunately find the majority of their customers unable to purchase their bait if their plans are to cross a nearby BMZ boundary to fish.

Lastly, I would request greater clarity on some of the statements under Section 3.0 entitled "Movement of Bait." It is stated that "An estimated 4.2 million angling trips involving live bait take place each year in Ontario, where approximately 25% of these trips occur over distances greater than 400 km. A large portion of Ontario anglers live and purchase bait in the southern part of the province, where invasive species and diseases are most prevalent." Separately, these two statements appear reasonable: many anglers live and purchase bait in southern Ontario, and many anglers take long trips. Putting the statements together is to imply that a "large portion" of anglers making these angling trips are buying their bait in the south, and transporting it far away. Has this implication been established? If so, where are statistics on the actual transport of bait? What does it mean for an angling trip to 'involve' live bait (does this mean the bait is transported over land some long distance as part of the trip, or simply that bait, perhaps locally purchased or caught, was used during the trip)? Given that this summary of the current state of bait transport in Ontario is intended to justify the subsequent proposed regulation changes, it is critical that these statements are transparent and based on valid, representative data.