I am submitting the comments…

I am submitting the comments outlined below regarding the proposed Strategic Policy for Bait Management #012-9791. Although I am strongly in favor of measures being taken to halt the spread of environmental diseases and invasive species that may threaten our fisheries and the biodiversity within our vase water systems in Ontario, I am not convinced that this proposed strategic policy for bait management will have the expected impact in minimizing the ecological risks to our aquatic ecosystems. The reality is that personally harvested bait fish by anglers is an end link in the chain of many other more significant factors in the introduction of invasive species into our aquatic ecosystems. The inter-provincial and international movement of boats, trailers, and fishing related equipment from one system to another has a greater potential to cause the spread of diseases and invasive species then does a private angler using live bait acquired within the same ecosystem and aquatic watershed. If bait management zones (BMZ) were to be imposed then this needs to be an all-in policy . As a community of Anglers, no matter whom or where one is from, any expectations imposed to minimize the potential ecological risks must apply to everyone with no exemptions or exception. If there are exemptions and exceptions then the entire premise for this policy is scientifically void. If any angler is permitted to ignore the rules, for whatever reason, then the ecosystem will become compromised despite the dedicated efforts of all other anglers. The proposed BMZ as tendered are somewhat skewed in that the outlined designations between BMZ-B, and the westerly part of BMZ-C are all one watershed, with the lakes, rivers and endless tributary within these regions already sharing the same waters flowing north into James Bay . These are already one coexisting ecosystem. BMZ-B, and the westerly part of BMZ-C designation, if imposed, needs to reflect this fact by become one BMZ designation. I harvest my own bait and strongly believe in my right to continue to do so freely as an Ontarian and Canadian. Crown land belongs to me too. I am adamantly opposed to losing this right for any reason or that a fee to harvest will be imposed on me in the future. There is no need for this. The required licences and fees currently imposed on me to “enjoy a day of fishing” in our province is already far beyond what is necessary. I strongly object to MNRF using the significance of the preservation of our aquatic ecosystems as facade to impose an additional fee on not only anglers, but hunters and outdoor enthusiasts. (If zoning were to be imposed then simply add this designation status to the existing outdoors card or fishing licence).

In reviewing the study “Ecological Risk of Live Bait Fisheries: A New Angle on Selective Fishing” (by Dr. Andrew Drake - University of Toronto & Nicholas E. Mandrak), which I was directed to as the premise for the development of the proposed Strategic Policy for Bait Management #012-9791, I found that the conclusions drawn and recommendations outlined were only based on predictive studies and theories surrounding sample data gathered from the Great Lakes and Lake Erie’s watersheds systems within Canada and the USA. The MNRF, using this data, states within their presentation “that the spread of diseases and invasive species pose a significant threat to Ontario’s fisheries and biodiversity” and that as a result of this “provincial” bait review the proposed Strategic Policy for Bait Management #012-9791 (BMZ) has been developed. This statement is significantly flawed as there is no evidence within the Andrews’/Mandrak study or the MNRF information that qualifies this as a “provincial” bait review. There is no indication of scientific research or supportive data being gathered from the Far North or the Northwest regions of Ontario (BMZ-A ,BMZ-B, and the westerly part of BMZ-C), yet despite this the same conditions and restrictions for harvesting of live bait is being impose on Northwestern Ontario Anglers.

The Andrews’/Mandrak study outlines concerns in regard to the angler’s ability to identify “game imperiled and invasive or non-targeted species as bait” no matter what the manor of harvesting live bait from the wild was , yet based on the reported stats, greater than 50% of anglers can successfully identify invasive species. If the MNRF has apprehension regarding the angler’s ability to identify invasive species then there should be an obligation on the MNRF’s part to better educate Ontario Anglers, not impose punitive restrictions. Through opportunities like regional seminars, podcasts, online information, educational posters, pamphlets and illustrative materials, anglers become informed participants in the campaign to halt the spread of aquatic diseases and invasive species. Through this approach we as anglers, being “the last control point,” become empowered to be greater advocates in protecting our environment and respective ecosystems.

[Original Comment ID: 209957]