Dear Mr. Gibson,…

Dear Mr. Gibson,

I have several concerns about the current and proposed policies regarding bait harvesting and selling. I am licenced bait harvester for almost 10 years and requested to be invited to the meetings to develop these new policies when I was made aware of this current process to review the regulations but was told the panel had been picked. It is very unfortunate that the Ministry did not openly seek out participants as opposed to whatever secret process took place to select the very few harvesters who were chosen. I lobbied to be a stakeholder and despite knowing countless bait harvesters, I do not know of 1 who was part of this committee now has any harvester been identified as being one of these stakeholders.

My first concern is regarding the number of bait seller licences issued. For example, within 20 minutes of my store there were 4 bait sellers, one of which was a lunch counter / general store / liquor store. The Ministry has recently issued another licence 12 minutes from my door step to a hardware store. If the Ministry is truly concerned with conservation, this would not happen. How much need really exists for another location in this area? How badly does someone who operates a general / hardware store need to sell minnows? How much attention will they really give to the care and sale of the minnows when they are making sandwiches, mixing paint, repairing screens and renting tools? If the Ministry raised the prices of bait sellers licences to $1500 a year, many of these part time bait sellers interested only in a quick dollar would disappear and you would be left with individuals who truly want to do a professional job. This would also be more fair to those bait sellers who truly want to be in the fishing industry and would help these businesses succeed.

My second concern is regarding harvesting by-catch. Other commercial fishermen have a by-catch provision. While many of the bait harvesters follow their HCAP plans and work diligently to ensure that only bait fish are transported, no one can be expected to be 100% compliant all the time. Anyone who is dealing with 1000s of fish the size of your finger or smaller at one time even with the best grading equipment and in perfect weather conditions can accidentally have a non-baitfish species mixed in. Currently, this issue seems to be at the officer's discretion, however, that is not a fair practice and needs to be evaluated. A 1% by-catch would be more than fair for any harvester truly concerned with being compliant.

My final concern is regarding the newly proposed F zone. This new zone will unfairly damage the business of any non Lake Simcoe bait harvester in the winter months. Lake Simcoe fall bait harvesting is more plentiful than any other area. Their minnow supply is endless and cheap. Given the new proposed policy and preventing these minnows to go north where there has always been high demand, these countless, cheap minnows will now flood southwestern Ontario and any of the bait harvesters down here will now be out of business and their storage facilities deemed worthless as we can't compete with the Lake Simcoe harvesters. Furthermore, these Lake Simcoe harvesters make the fishery cheap and worthless because of the large amounts they store over the winter months in anticipation of winter sales only to flood the market with them or dispose of them if no ice fishing occurs. This is not a way to preserve the fishery and further consideration should be given to eliminating some of these 22 harvester licences for the sake of conservation. Instead of creating a massive F zone, creating a smaller zone below Toronto would protect the rest of the harvesters and still give the Lake Simcoe harvesters the big city of Toronto for sales. I realize minnows have still made their way north the last few years even under ban and without testing by many of these Lake Simcoe harvesters wanting the big payout and even if a smaller zone is created, there is nothing preventing these same non law abiding harvesters from bringing minnows down south, but there needs to be some thought given to all harvesters and not just the Lake Simcoe harvesters. This new policy only sets the stage for continued harvester shenanigans to the north and now into the south.

If you would like to discuss any of these comments further, please contact me.

[Original Comment ID: 209925]