The use of the word…

ERO number

012-9791

Comment ID

1027

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

The use of the word strategic in the title for this review appears to be misleading. The stated purpose is to provide proposal direction for the sustainable use and harvest of bait in Ontario in order to reduce ecological risk while maintaining a viable bait industry. If it was meant to be strategic, there should've been an analysis of what other jurisdictions are doing, analysis of the effectiveness of the existing controls on movement, and some discussions as to why the existing system isn't working. The absence of a wider examination strongly suggests that maintaining a viable bait industry was the key objective. The proposed solution is a different form of geographic boundary system while at the same time offering no discussion as to how effective these restrictions were in the past. Was there any discussion about the costs and benefits of continuing to administer the program even though the revenues do not cover the admin costs of a program where most of the benefits fall to the private sector? This is difficult to understand when it appears that the reporting system would not control undeclared income. Assuming that geographic restrictions work even though there is no discussion about it in the document, why would you allow under this policy bait management zone F to touch the Ottawa River? Wouldn't the cautionary principle dictate that Fishery Management Zone 18's boundary become a stand- alone bait management zone, given I believe that BMZ F is for most part the current source of the trouble is with VHS.

[Original Comment ID: 209687]