ERO # 025-0263 Overall, I…

ERO # 025-0263
Overall, I think this document is lacking in detail and necessary information (data) to support the regulatory changes presented. Many of the figures are far too complicated for the intended audience of this document. My specific comments are below.

Page 16 provides some historical rehabilitation objectives for walleye but there is no present objective set out in this document. What objective is the IGLMU working toward in terms of rehabilitating this walleye stock? Rehabilitation targets and objectives and targets for the fishery ie harvest rates, mortality etc are two different things.

Three regulation changes are being presented in this document (open season change, change to the sanctuary, harvest slot size introduction, allowing for increased bycatch in the commercial fishery). I think it's important for resource users to know exactly where the 11 NGOs on the working group, and their membership stand (vote?) on these changes. Similarly, of the 11 NGOs, how many are dissatisfied that they cannot fish in the north end of the bay?

I would like to know what data was used to come up with the harvestable slot. The length distribution of walleye from the assessment netting has not been presented. It's important for anglers to see what the population looks like in terms of length, and we need to know what proportion of the population outside of the slot is protected. As well, how old are male and female walleye when they enter the fishery (at 46 cm, 18”) and what is the state of maturity at that length?

Creel Information on the open portion of black Bay (presently) would be a good baseline to compare to if the whole Bay is open to harvest. I would like to know how much anglers are harvesting (kg), the size of walleye being harvested and the amount of effort being expended on the open part of the Bay prior to any regulation changes. I think this information is needed to properly feed an adaptive management process and to look at changes.

Indigenous harvest is unaccounted for. This is important to know in establishing Fishery targets.

Figure 25 seems to be a comparison of small versus large walleye CUE (but I’m unsure) but the text that references this figure on page 57 indicates the figure displays the abundance of large walleye greater than 350mm. Why are you adding 10 -2 to the CPUE? Why are there only error bars on the three red dots and are those the 95% confidence limits? Why don't all of the dots have error bars around them? This figure presents a comparison of relative abundance (CPUE) not abundance. This figure is far too confusing for the average angler, if it is indeed correct. It does nothing to convince me that walleye abundance is significantly higher (statistically) than other populations displayed.

Why does the pike objective (harvest a trophy pike greater than 101 centimeters) not appear in the action strategy section? The proposed regulation is no fish greater than 90 centimeters. Did the working group disagree?

Lake sturgeon are a threatened species under Ontario’s species at risk act, in northwestern Ontario. The UGLMU is responsible for lake sturgeon rehabilitation in Black Bay and GLFC and LSTC identifies Black Bay as a priority area for rehabilitation. The sturgeon section passes the buck to MECP and washes the UGLMU hands of any responsibility to the species. I have very little faith that any agency is doing anything substantive to rehabilitate this species. What background information exists as to the status of lake sturgeon in the Bay and what initiatives is the lake unit carrying out to satisfy its responsibility under the rehabilitation plan?

I realize that the dam is out of scope, but some food for thought. The reason walleye abundance “increased significantly” from 2000 to 2008 is due to the closure of the commercial perch fishery in 2003 (increased survival). After the initial increase, there has been no increase in walleye CUE over a 16 year period of assessment. The commercial harvest of walleye presented in figure 2, specifically the collapse and lack of rebound, looks like a classic example of recruitment failure due to habitat loss. The potential for any significant increase in walleye abundance or lake sturgeon seems unlikely given the dam habitat issue.