In my opinion, the MNR and F…

In my opinion, the MNR and F has missed all 4 goals as presented in the Draft.

“The following goals were established to guide the bait policy review and are proposed to be carried forward into the Strategic Policy for Bait Management in Ontario: 1) Bait is managed to protect the health of aquatic ecosystems.

2) Sustainable use of bait resources enhances the quality of life for Ontarians by providing recreational, social and economic benefits. 3) Bait is managed to conserve the resource and maintain a viable bait industry.

4) Bait management is adaptable, effective, consistent across the province and simple to implement.”

The goals are noble but the draft policy does not meet them. Arbitrary zone lines fail goal 1, and 2. The ban on bait in parks negates goals 1 and 2. The bait industry (goal 3) also suffers with the arbitrary lines and the potential loss of business from tourist outfitters and anglers affected by the lines as well as the inability to move bait to where it can be used well within the same watershed but over an zone line. Goal 4 is nowhere met with such an ineffective, arbitrary and complicated policy.

Here are more detailed concerns regarding the draft Bait Policy.

A: The proposed bait management zones boundaries following fishery management zone lines is arbitrary and does little to prevent transfer of unwanted species between water sheds. -Much of the proposed zone boundary between A and C follows a railroad track. There cannot be any science behind this. -The proposed arbitrary Zone boundaries between C and B allows invasive species from Zone C near lake Superior to be carried into the western part of Zone C and then follow the Artic water shed either onto zone B (west through Lake of the Woods or north through Wabikimi) or Zone A directly through the Brightsand and Allanwater Rivers in Wabikimi. Not much science in this decision either. Seems this zone boundary is only in place to allow baitfish from Thunder Bay area (Great Lakes shed) into the Artic Water shed through popular fishing locations west of Thunder Bay such as Lac de Mille Lac etc. while preventing bait fish from zone B from being used in the same waters until the water flows into B. -A more logical approach would be water shed management and zone boundaries which follow watershed lines. -We only have two water sheds in this area: The Artic shed which includes proposed Zone B and A and the western part of C. Simple and scientific. Easy to define and enforce, little impact to our businesses and jobs. Makes scientific sense to prevent invasive species from crossing water sheds and contaminating a downstream water shed.

B: The proposed zone lines arbitrarily prevent fly in tourist operators or drive to camps who cross the borders from remaining competitive with other tourism operations who may not have to cross arbitrary lines. -Each of our operations is different but there is potential of reduced economic impact due to our business not being competitive on an arbitrary basis. -Fly in operations have high paying and highly skilled jobs (pilots), which no government wants to lose in the north. Some of these jobs may be in jeopardy – over a minnow. -An unintended consequence is the loss of competitiveness and/or good jobs in the north.

-If a fly in camp is non-competitive with competition in the same geographic area, camps may be shut down due to lack of customers - no customers, no wages to pay employees. Every dollar spent by a non-resident on a quality, generally higher priced, angling experience offered by a fly in is a NEW dollar to Ontario which will recycled many times over and contribute significantly to Ontario.

C: The proposed ban in some provincial parks causes loss of competitiveness to many operators and makes no ecological sense. -There is potential of reduced economic impact if guests choose to book with an outfitter with no bait restrictions. -Fly in operations have high paying and highly skilled jobs (pilots), which no government wants to lose in the north. Some of these jobs may be in jeopardy. -An unintended consequence is the loss of competitiveness and/or good jobs in the north.

-It makes little sense that a waterway park has a live bait ban when any waters flowing into the water way park has no ban. A waterway park only extends a few metres off the waterway. Many tributaries run into these water systems and allowing a minnow on metres from the park yet prohibiting minnows in the park sounds more political than scientific. -How will the MNR and F enforce the transportation of bait within a zone in which one has to cross by land or water from one part of a zone to another part of the same zone to traverse a park such as the case on Hwy 599 or road 625which crosses Sandbar park or Hwy 622 which crosses the Turtle river park? Many of these parks have roads and even highways running through them. There must be numerous situations such as this. -The solution is to not include parks.

D: If none of these issues can be considered, and the true intent is to prevent invasive species from moving into waterways, perhaps the MNR and F should level the playing field, bite the bullet and ban live swimming bait in the province. A last resort but effective? This would certainly accomplish stated goal #1but none of the goals.

[Original Comment ID: 208888]