Re:EBR 012-9791 – Strategic…

Re:EBR 012-9791 – Strategic Policy for Bait Management in Ontario

Dear Sirs:

Ontario Rivers Alliance (ORA) is a Not-for-Profit grassroots organization acting as a voice for several stewardships, organizations, private and First Nation citizens who have come together to protect, conserve and restore healthy river ecosystems.

ORA commented in 2014 and 2015 on EBR postings 012-4222, 012-2835, 012-2836 regarding bait policy in Ontario, and we are very pleased to have the opportunity to provide comments on the Strategic Policy for Bait Management in Ontario (Bait Policy).

While ORA agrees that the commercial bait industry provides considerable benefit to the recreational fishery and the provincial economy, we do not agree that it is necessary to maintain the industry in its present form when it is contributing to the spread of disease and invasive species, and poses a significant risk to Ontario fisheries, protected areas and biodiversity.

ORA feels this proposed Bait Policy falls short of the Ministry of Natural Resources and Forestry’s (MNRF) goal of finding options that minimize the ecological risks associated with the use, movement and harvest of baitfish, while also reducing the complexity of current management regimes and increasing business certainty to the bait industry.

In fact, this proposed Bait Policy is extremely complex, is not evidence or science based, and is unlikely to achieve the necessary results. It places the onus on fishermen to understand and abide by a complex policy that requires different rules for each Fish Management Zone (FMZ), for native Brook Trout lakes, provincial parks, wilderness, conservation and nature reserves, and seems doomed to fail. Additionally, the enforcement mechanism proposed is a demerit point system that requires entries in logbooks, receipts, and different species rules for the many different FMZs. All of the above will make it especially challenging for MNRF to monitor and enforce and, most importantly, for this Bait Policy to be an effective deterrent.

MNRF is proposing that commercial bait harvesting be prohibited in wilderness, nature reserve, natural environment, waterway and cultural heritage class provincial parks; however, these bait harvest prohibitions do not extend to the tributaries outside of the protected areas, so would be largely ineffective. Additionally, commercial bait licence holders would not be restricted in the amount of bait they can possess (with a few exceptions); however, overharvesting is a major concern as there is “little biological knowledge on the productivity of bait species which can be used to establish quotas to prevent over harvest”.

It is unfortunate that there was no information provided on the success or failure of the ban in October of 2006, that the US Department of Agriculture’s Animal and Plant Health Inspection Service’s placed on all imports and interjurisdictional transport of 37 listed species of fish from eight Great Lakes states and two Canadian provinces. It would have also been informative to know how the other provinces that have banned bait fishing have been environmentally and socio-economically impacted. This information should have been made available to stakeholders to better understand and inform our comments.

In ORA’s view, MNRF has been streamlined to the point where it would be very challenging to effectively monitor and enforce this very complex Bait Policy. Consequently, ORA makes the following recommendations:

1.Commercial and personal harvesting of baitfish be banned in all Ontario waterways.

2.Commercial bait operators be required to establish a bait fish hatchery to raise the appropriate locally common bait species for sale in each Bait Management Zone. 3.Issuance of a fishing license should require the holder take a short course and be tested in identifying fish species, prevention of the spread of invasive species, as well as angler responsibilities in maintaining sustainable fisheries and waterways. 4.A compliance framework that would entail heavy fines for anyone contravening Bait Policy.

The above recommendations are designed to be simple, but effective in maintaining a viable commercial baitfish industry, protecting biodiversity, and preventing the spread of additional invasive species and disease into Ontario waters.

Thank you for this opportunity to comment.

[Original Comment ID: 209875]