ERO number 019-6067 In…

ERO number
019-6067

In response to the Lake of the Woods Draft Recreational Walleye Plan (the Plan), I would like to submit the following comments:
First, I believe the public consultation process was very poor and bordering on irresponsible. The promised public meeting ‘in early November’ of 2022 (it actually was on November 23) was not widely advertised and very few people were aware of its scheduling (the meeting in Kenora was only posted on MNRF’s Facebook and Twitter accounts).
To address the specific proposals of the Plan, it’s necessary to provide the proper context.
For one, resident anglers account for less than 20% of the recreational anglers on LOW - more than 80% of the anglers on LOW are Americans (source: Ontario Waters of Lake of the Woods Fisheries Management Plan Part 1 – Recreational walleye plan Draft for consultation). Given that the walleye management ‘goal’ is to reduce harvest of walleye by more than 40% from current levels, the proposed change to angling regulations will not, in my opinion, help achieve that goal.
It’s my opinion that the proposed changes will actually result in an increase in walleye mortality from angling.
By reducing the catch limit of resident (Ontario and Canadian anglers) to 2 (which is the current regulation for non-resident angers, so no change to their catch and possession limits in terms of numbers of fish) and introducing a slot size (both options) for all recreational anglers, anglers will try to ensure the fish they catch are as large as permissible; i.e., fish close to 43 cm in total length (both options). Fish greater than 70 cm certainly exist, but are relatively uncommonly caught and many anglers are not as keen on eating large walleye.
This means a lot of smaller fish (e.g., 30 to 40 cm), which under present regs anglers often normally keep, will be released, as will all fish > 40 cm and < 70 cm in total length (TL). However, many of these caught and released fish, regardless of their size, won’t survive.
Why won’t they survive?
Because on LOW, walleye angling is commonly done in water that’s in the 30 foot range (or greater).
A quick Google search refers to many experimental studies that show walleyes caught in 30 ft of water have about an 8% chance of perishing, while fish from 40 ft have 18% mortality; fish from 50 ft 35% mortality. So for each additional 10 ft of depth, walleye mortality from catch and release roughly doubles. Some studies suggest that most fish caught in 30+ feet of water will likely die after release if water temps are at their peak (i.e., mid-summer). Regardless of the exact percentage of mortality, it is well documented that small fish have higher mortality rates than older fish.
Walleye, like most freshwater fish, do not have good pressure equalizing capabilities. Brought up from deep water, the air bladder expands and stays bloated. Capillaries can burst and there are other issues as well.
In other words, LOW is not a good place for extensive use of catch and release for walleye, which will likely increase dramatically with the proposed regulation changes.
There are other likely impacts of the proposed regulation changes as well. Most have not been addressed or considered, at least not in the narrative as presented.
For one, some - perhaps many - anglers (resident and non-resident) that are discouraged by the reduced catch limits on LOW are likely to target other, nearby waters to go fishing, where the daily catch limit remains at 4. Because LOW receives about 60% of the angling pressure in the Kenora District, this is not an inconsequential consideration.
Given that LOW anglers tend to be ‘big water’ walleye anglers, many of these anglers are likely to focus their efforts on the Winnipeg River. The Winnipeg River has a long history of high walleye harvest, which has resulted in shortened seasons (the walleye fishery closes a month earlier towards spring than other nearby waters) and slot size limitations (walleye must be between 35 and 45 cm TL).
The increase in angling pressure from changes on LOW could be substantial (and the slot on the Winnipeg River has been criticized for higher than planned for mortality, again because fishing is generally done at depths that exceed 30 ft, bad news for walleye (especially small fish) that must be released.
Some anglers – again, it seems this was not considered – could be displaced to the smaller, accessible lakes in the Kenora District. On these lakes, the walleye daily catch and possession limit is 4 (sport fish licence) for all anglers and all sizes of fish are legal (however, only 1 fish can be > 46 cm TL). These small lakes (many are only a few hundred ha in surface area) could quickly be over-fished if the number of anglers were to substantially increase.
Although the walleye daily catch limit for non-residents was reduced a couple of years earlier, the larger minimum size limit outside LOW (46 cm vs 43 cm TL) and the ability to keep 1 walleye > 46 cm TL, may also shift non-residents to nearby waters. This may already be occurring, but given non-resident angler numbers have been down substantially because of travel restrictions related to Covid-19, the magnitude of any such shift in angler preference of waterbody is unknown.
Indeed, the information on angler harvest for 2020, 2021 and 2022 is unknown, but is likely substantially lower than in the latter years for which data is available (again, owing mainly to Covid-19 travel restrictions, but also because of the extreme high water of 2022 which affected all anglers). This information has been acknowledged, but apparently has been dismissed as insignificant.
There has also been no success in having any agreement on the walleye harvest by Aboriginal and/or Métis. I recognize there are Aboriginal and Treaty Rights involved, but such Rights do not negate the possibility of negotiated agreements. Negotiated agreements on the harvest of moose in Ontario by Métis hunters have been achieved (Métis hunters must have a harvest card issued by a recognized Métis authority).
The other notable issue with respect to harvest is the commercial fishery that many believe is in disarray and poorly regulated. In addition, commercial harvest cannot have a protected slot-size limitation on harvest – the only regulation would be on the size of the mesh, which can be used to let smaller fish escape if large, but would then target larger, older fish almost exclusively. Given there is a concern that there is a dearth of older (large) walleye in LOW, it would seem logical to substantially curtail the commercial fishery, as commercial fisheries target larger fish.
There are other issues that have not been addressed in the assessment of the fishery and the proposals put forward, although they may have been discussed by the council.
In particular, the regulations in effect on Lake of the Woods that target other game fish species are likely directly and indirectly affecting the health and status of the walleye population.
Firstly, the impact that has occurred to the fishery from eliminating the recreational harvest of northern pike > 75 cm TL, and muskellunge < 122 cm TL, does not appear to have been considered.
Northern pike and muskellunge are believed to have the same potential allowable yield as walleye on LOW, namely 22% of the total allowable yield of all of the major fish species.
These regulations have without doubt resulted in a large and growing standing stock of these large predatory fish.
Two things stand out:
1. the annual harvest of pike and muskellunge is nowhere near the allowable yield; and
2. these large fish very likely consume a large number of walleye.
It seems wrong not to allow the harvest of at least some large northern pike. Unlike walleye, larger pike are favoured by humans for consumption owing to their bone structure (large pike are much easier to clean and produce a bone free fillet than small pike). There are a number of studies available that suggest a recreational harvest that would allow anglers to keep 1 pike > 90 cm TL is sustainable (while maintaining the present daily catch and possession limits), would retain a presence of trophy-sized pike, but reduce overall pike biomass. This would likely be a net positive for walleye populations (muskellunge regulations would not have to be adjusted as muskellunge populations in waters like LOW, where both species are present, are much smaller than those of pike. Additionally, harvest of muskellunge is low, a reflection of the angling culture).
A similar situation exists with regulations on the harvest of smallmouth and largemouth bass.
While both species are naturalized in the LOW ecosystem, the fact that both species are exotic introductions (which is an explicit concern that the proposals are meant to address: “…. pressures such as invasive species…”) needs to be acknowledged. Exotics are generally viewed as a negative and usually for very good reasons.
Numerous studies have demonstrated that wherever smallmouth bass and largemouth bass are introduced to walleye waters where these species were previously absent, the allowable yield and standing stock of walleye declines.
If walleye are the most sought after and valued fish in LOW (they are) it would make sense to encourage the harvest of bass by anglers. Given bass are valuable to the recreational fishery, are naturalized to LOW and now have strong protection during their spawning season, at the very least encouraging harvest with more liberal catch and possession limits might reduce somewhat the standing stock of bass without undue harm and simultaneously shift productivity to walleye.
I would also like to ask why the recreational harvest of walleye on Shoal Lake, which has been closed in 1983, has not been re-opened. Sources suggest the walleye fishery in Shoal Lake is healthy and in fact is one of the healthiest large lake walleye fisheries in Ontario.
If the decision has been made to allocate the walleye to Aboriginal people, this should be acknowledged.
At the very least, it is not apparent how Shoal Lake is being managed. For years, there has been little effort to communicate the current status of the Shoal Lake walleye fishery.
To summarize, I do not believe the proposed changes to the regulations governing the recreational harvest of walleye will be beneficial to the walleye fishery in LOW or the surrounding waters.
I believe both proposals will be negative and will contribute to the further deterioration of the walleye fishery in LOW and surrounding waters.