In response to the MNRF's…

In response to the MNRF's latest proposal on baitfish management in Ontario, I offer the following comments for consideration:

- The introduction of bait management zones for the purpose of restricting bait movement from one part of the province to another looks good on paper, but in practice will be very difficult to enforce. While regulation of where commercial operations source their baitfish should be feasible, restriction of personally caught bait brought from one zone to another cannot possibly be enforced.

- Restrictions on personally harvested baitfish being used only in the waterbody in which they are caught is also unenforceable. How is an angler supposed to prove to a conservation officer that the bait being used was indeed caught in that particular waterbody? Furthermore, if commercially harvested bait is allowed to be transported within a bait management zone, then why does it suddenly become restricted bait when caught by an individual instead of a commercial operation?

- Restrictions within provincial parks make no sense. Waterways parks often see both local recreational traffic as well as tourist outfitter traffic (ie. Lady Evelyn) where bait fish angling is the predominant form of angling. Not only will this affect local tourism and rural job opportunities, it will make poachers out of otherwise law-abiding anglers who will in all likelihood continue to use baitfish regardless of being inside a provincial park or not.

- Education should be the ministry's main focus for restricting the movement of possibly infected baitfish and the movement of invasive species. As an angler who considers himself to be paying attention to the current hot-button topics in the Ontario fishing community, I was not aware the either the spread of VHS (or other diseases) or the spread of invasive species was getting worse to the point of requiring additional legislation. If that's the case, then the MNRF is not doing a good enough job of educating the fishing community of a worsening situation. Additional education will put the onus on the angler, most of whom are very conservation minded, to make sure they are following the rules in terms of bait movement from one zone to another. From my viewpoint, the main intention of this proposed legislation is to restrict the movement of bait across zones. Since a blanket ban or restriction is unenforceable, education will at least allow most anglers to make the right choice when it comes to moving bait. There are already laws in place forbidding the movement of restricted species (invasive or otherwise) and yet very rarely does one hear of a charge or conviction related to these laws. From this one can logically conclude that either bait movement and invasive species movement are not issues or the laws in place already are unenforceable. Education is the only real alternative that has a reasonable chase of successfully limiting the movement of baitfish.

- The reduction in legal baitfish from 47 species to 33 species is likely of little consequence to the common angler, however, it is likely to prevent the spread of some invasive species by making identification of legal baitfish easier. Therefore, it is a welcome change to the legislation.

[Original Comment ID: 209155]