Comment
Death by a Thousand Cuts: How the Proposed Baitfish Legislation Will Fail to Stop the Continued Loss of Quality Fisheries
To start with, I am very unhappy with the lack of publicity provided to the public respecting these proposed changes to the use of baitfish in Ontario. I am a regular angler, I associate with other anglers, and I belong to an angling club, but the first that I heard of these changes is through a chance encounter with an Ontario conservation officer in April 2017. After some digging using my desktop computer, I did find the Draft for Public Comment. Having in the past commented on other (unrelated) issues via the EBR process, I must again repeat that it is not user-friendly for ordinary folks.
Below, I provide comments of both a specific and general nature regarding the proposed changes. Many of my comments use examples from the Sault Ste. Marie area where I fish. I have used both MNRF’s FishON-line data and the Early Detection and Distribution Mapping System data for this submission.
My overall position is this: Every time another unwanted species is introduced into the waters of Ontario, whether it is into a ‘natural trout lake’, a high-quality trout stream, or a coolwater Walleye and Pike lake that supports a significant tourist industry with all its economic benefits, it reflects a failure of the laws and policies that should have prevented it. The limited response to unwanted introductions in the Draft Strategy will only allow the cumulative harmful effects of these introductions to continue.
One of the proposals is that angler-caught and commercial bait can be transported and used within very large Bait Zones in the province, but generally not transported outside of them. At first glance this is reasonable, but on closer inspection it reveals a number of flaws. The first of these relates to some of the Invasive Species (by these I mean from outside North America) that are already found in Ontario waters: 1.The Chinese Mystery Snail has been found and identified in Duborne Lake near Blind River. This lake has coolwater fish species (pike, bass, etc.) and thus is not a ‘natural trout lake’, so under the proposed policy baitfish can be trapped there. Once trapped, those baitfish can also be transported and used in all other waters in the Baitfish Zone that are not ‘natural trout lakes’. But, this invasive species can hitchhike along with trapped baitfish and their holding water into other lakes in the same, huge Bait Zone D that stretches from Lake Superior eastward to the Quebec border, and raises the possibility over time of an exponentially expanding number of waterbodies with this snail. I suggest that once it becomes more widely distributed, it is only a matter of time before it is inadvertently transferred in bait water to ‘natural trout lakes’; this is the distribution pattern of invasive species. 2.Already, the Freshwater Jellyfish has been documented from a number of water bodies not far from Sault Ste Marie including Desbarats and Caribou Lakes, these are warmwater fisheries. The proposed regulation changes will not prevent the taking of baitfish, for personal or commercial use, from these two lakes and then transporting them along with the water clinging to them to other lakes in Bait Zone D. I suggest that the spread of this invasive species could be accelerated and become more widespread as long as bait can be trapped and transported in the zone, and that the best long-term prevention of that is a total ban.
The situation of baitfish being moved from the Great Lakes to inland waters was not fully addressed in the Draft document. For clarity, I suggest that the waters of the Great Lakes and connecting waters be designated as a separate Bait Zone such as Zone F. Also for clarity, I suggest that this new zone be part of the ‘no baitfish movement’ between zones. I give the example of Patterson Lake located not far south of the Montreal River near Rand on the ACR line; this is not far north of Sault Ste. Marie. The lake has both Brook and Lake Trout in it and must certainly be classed as a “natural trout lake”. But it also had a confirmed invasive species: Threespine Stickleback, which has also been reported from various locations in the St. Marys River and North Channel. The proposed changes ought to prevent the movement of baitfish from the Great Lakes to inland waters, despite any belief that the risk of moving invasive and unwanted species is very low. Patterson Lake is proof that such introductions do take place; therefore the risk, instead of being very low, is both high and unacceptable.
Another issue with the proposal to allow the trapping and movement of bait within each Bait Zone, is the movement of what I would call Unwanted Species. These are not fish or other species that are from foreign lands, but are simply fishes that are not part of the natural, historic ecosystem of a lake or stream and are also unwanted there; a common example is Yellow Perch that have been brought to trout lakes in bait buckets with the result that the water is now infested with stunted Perch and where no trout fishing, or at least no quality trout fishing, exists anymore. These unwanted fish are included as invasive species in the Draft document. 1.Shaw Dam Lake is situated in a natural Brook Trout watershed with the Little Thessalon River entering and exiting it. Century-old records attest to the quality Brook Trout fishery in the Little Thessalon River, it is currently still a viable trout fishery, and until recently the lake was also known for its trout fishing. But all that changed when someone brought in Rock Bass, a species from warmer waters not far away, and let them loose in the lake. Now Shaw Dam Lake hosts a huge population of stunted Rock Bass and virtually nothing else. If I wanted to catch a bucket full of them to use as bait somewhere else, this is where I would go to get them. I am old and hopefully will never see the day when someone does, and tips their bucket of bait into one of the upstream lakes or into a lake further north in the trout watersheds, as I believe this is inevitable no matter how strict the laws, how heavy the penalties, or how intense the education effort . In my view, the only sure way to prevent it is to ban the taking, possession, and use of all live baitfish in all of Ontario. 2.Saymo and Ranger Lakes are large, cold, oligotrophic lakes that harbour Brook and Lake Trout and associated cold-water species. But they now also hold Rock Bass and Pumpkinseed, both of them wholly unwanted species in those waters. As these lakes are a long way north of the historic range of these fishes, they must have been brought in by bait bucket in contravention of both the legislation and common sense. There always have been, and always will be, some anglers who do not know or do not care about the regulations or even their own fishing future, and disregard all the rules; this means that if there are fish that can be obtained cheaply and easily no matter what species they are, they will be caught, transported, and used in waters where they should never be. The only sure prevention of that is to stop the use of live baitfish in Ontario.
The main change affecting anglers for trout in Algoma is that “MNRF is proposing that the harvest and possession of bait be prohibited in native Brook Trout lakes.” This is in Part 4.1.I completely agree with this proposal, although as I elaborate below, I believe it does not go far enough to protect the larger natural resource. 1.The Draft says “It is intended that this proposal would not apply to Lake Superior Park or rivers and streams with Brook Trout.” I am unclear as to what this means. Does it mean that baitfish are allowed in those waters, or does it mean that MNRF does not need to consult on which lakes it will apply to as baitfish will continue to be prohibited in Lake Superior Park? This still leaves the question of “rivers and streams with Brook Trout”. Will baitfish be allowed or prohibited. The proposal wording is not clear. 2.Will this apply to streams that originate outside of a Provincial Park and then flow into it? Let us take a map and look at the Agawa River; it begins on a plateau with a number of Pike lakes not far south of Highway 101 about half way between Wawa and Chapleau. If the use of live baitfish is permitted in these headwaters it may result, at some future time, in an unwanted species moving downstream and affecting the “native Brook Trout” that are a prime, and prize, species down the river near and in Lake Superior Provincial Park. The Agawa River where it enters Lake Superior has an annual and historic run of Coaster Brook Trout, an uncommon and vulnerable fish that MNRF is protecting through a recovery plan and very restrictive regulations. It would seem to be at cross purposes to permit, sometime in the future, the introduction of a species far upriver that might adversely affect Coaster trout. 3.Parts of the Magpie River near Wawa have a high quality fishery for Brook Trout. But the river has its origins in Esnagi Lake which has a high quality coolwater fishery for Pike, Walleye, and Perch; this lake has a number of highly patronized (mostly by anglers from the USA) and successful fishing resorts and it is a major tourist destination. The introduction of unwanted and/or invasive aquatic species could jeopardize not only the economically important fishery on Esnagi Lake, but also the high quality Brook Trout fishery on the downstream Magpie River. I must add that there are a number of fly-in lakes in the area that drain into Esnagi; while the lodge operators on Esnagi may be vigilant in screening baitfish for unwanted species, in the fly-in outpost fishery the anglers must secure and bring in their own baitfish if that is what they want to use. Despite a long-standing prohibition, American anglers are picked up every year at the borders trying to unlawfully bring in live baitfish. 4.This last example leads us to the issue of the interspersion of trout waters and coolwater fisheries for Pike, Walleye, and similar fish in much of northern Ontario. I suggest that allowing the continued use of live baitfish in a Pike lake makes it continuously possible that unwanted or invasive species will be introduced to that lake, and consequently all the waters downstream where they may adversely affect trout, a condition that would irreversible once these species are established.
To identify which lakes these restrictions would apply to, the MNRF will develop and consult on a list that outlines the lakes that are considered ‘native’ under this proposal. But, MNRF proposes that the baitfish ban not apply to stocked lakes; I presume the intention is that commercial and personal baitfish harvesting would also be allowed in those lakes. I believe that allowing baitfish to be brought to stocked lakes has the potential for unwanted, invasive, or otherwise harmful species to be brought into those lakes. This would occur most likely in those lakes situated alongside major roads or near population centres where large numbers of uneducated (in terms of recognizing bait species) anglers are found. In each case where an unwanted introduction occurs, that lake becomes the new front line and another inroad into areas where those unwanted species do not yet exist. Some examples illustrate my point: 1.An hour’s drive north of Sault Ste. Marie is West Joco Lake, it is stocked intermittently with Brook Trout, has good road access, and is popular with anglers. Under the proposed regulations, and not being a “natural Brook Trout lake”, anglers could use live baitfish in this lake. But less than 1 km downstream is Joco Lake, a ‘natural’ Brook Trout lake as it is not stocked. The outlet creek from the latter runs into the Little Batchewana River, that runs into the Batchewana River; these latter are angled for Brook Trout. If an unwanted species was introduced into West Joco by bait bucket, it could travel downstream and affect other waters and fisheries including a “natural Brook Trout lake”. 2.Northeast of Ranger Lake, according to the Fish ON-Line website, Pine Lake 38 is stocked with Brook Trout, so live baitfish would be allowed under the proposed rules. Via a short creek, fish in that lake can go downstream into the much larger Tujack Lake which holds Brook and Lake Trout. 3.Saymo Lake and immediately downstream Ranger Lake, north of Sault Ste. Marie, have been extensively angled for many years, and now contain Rock Bass and Pumpkinseed. As desirable as these panfish may be in the right place, they have no place in these oligotrophic waters far north of their normal range, and they were undoubtedly introduced by anglers. They are a good example of the tendency, despite existing regulations, for anglers to transport and release undesirable fish species. These introductions, like all such bait bucket introductions, are irreversible—it would be absolutely impossible to remove the panfish species from Saymo and Ranger Lakes. At the outlet of Ranger Lake is the Garden River where many kilometres of regulated flies-only water begin. I can attest to the high quality of the fly fishing for Brook Trout there, and I believe that by any measure it is one of the highest quality Brook Trout stream fisheries in Ontario. But Saymo and Ranger Lakes, because of the presence of these unwanted species might not be considered ‘natural Brook Trout lakes’, and thus the use of live baitfish might continue under the proposed policy. While Rock Bass and Pumpkinseed probably will never thrive in the Garden River this still raises the spectre that some other kind of introduced fish, perhaps a strong competitor of Brook Trout, might become established and ruin this uncommon and high quality fishery. This situation would be exacerbated if commercial bait harvest is simultaneously allowed in lakes that are not “natural Brook Trout lakes” if they have, known or unknown to MNRF and/or the industry, unwanted or invasive species; this has the potential to distribute unwanted species farther and faster.
In my view, and I believe it is a view that is closer to the ‘do no harm’ philosophy than what is proposed currently by MNRF, use of live baitfish should not be allowed in any lake holding Brook Trout, no matter whether those trout are self-reproducing or stocked.
I am very familiar with angling for Lake Trout. Even more so than when angling for Brook Trout, anglers like to use live baitfish when they fish for Lake Trout through the ice; they are the preferred bait. Where live baitfish are prohibited they may use freshly killed baitfish, but I have seen these come back to life after they appeared to have frozen and died. Further, there are many waters inland from the Great Lakes where smelt have taken hold; these were brought in for angling in a live, dead, or egg state. Given the general interspersion and often the close proximity of Brook Trout and Lake Trout waters in northern Ontario, I am surprised that bait fish of any kind, live or dead, will be allowed in Lake Trout lakes. I propose that the use of any live or dead fish, whether defined officially as a baitfish species or not, be prohibited to stop the spread of smelt and other species into waters where they are not indigenous.
It is proposed that the possession of baitfish in wilderness, nature reserve, natural environment, waterway and cultural heritage class provincial parks be prohibited, but that the possession of baitfish in recreational class parks and conservation reserves is to be generally allowed. If as the Draft Strategic Policy states that the proposals are intended to reduce the risks to the ecological integrity of provincial parks and conservation reserves, then it should apply to ALL Provincial Parks and Conservation Reserves; this applies not just to fish introductions, but also to the virtually invisible hitchhiker species and diseases in the baitfish bucket water. To allow the use of baitfish in some parks but not others would be simply too confusing. In addition, some parks, such as the Goulais River, Aubinadong River, Mississagi River, and Little White River Parks currently have little or no signage to tell anglers where the boundaries are. In my view, the complete prohibition on the use or possession of baitfish would eliminate all such confusion.
This leads to a related issue, that of a huge patchwork of lakes and streams within a Baitfish Zone, including Zone D, where in some lakes live baitfish will be allowed, and in some they will be banned. Not too many years ago the Ontario Fishery Regulations were revisited and changed in order to harmonize the fishing rules over large swathes of the province; the feeling was that there were too many individual regulations from lake to lake. In particular, the former wide range of minimum, maximum, and slot size rules on Walleye in adjacent lakes were unified into the single current regulation.
But this Draft proposal seeks to spray the province with a shotgun blast of different rules from one lake to the next, such lakes being sometimes adjacent to each other, some lakes in a Park with one rule and a nearby lake just outside of a Park with a different rule, etc. How will the angling public be educated to this confusing set of rules? Will it be at all effective? As there are no more conservation officers in the field now than there were twenty years ago, how effective would enforcement be?
I suggest that it will be more effective in the long-term prevention of the introduction of unwanted species of fish, other organisms, and diseases into trout lakes, and to make the whole thing easier to understand (and comply with) by anglers, by simply prohibiting the use of baitfish in Ontario altogether. This will reduce confusion on the part of the public, and will make enforcement of the regulations much more effective. I am aware that despite the many years of prohibition of live baitfish in Lake Superior Provincial Park (LSPP), there is a long history of their unlawful use that have resulted in convictions; I suggest that in LSPP this regulation was knowingly violated and it was made easy to violate by the ease of purchase and possession of live baitfish by anglers. A total prohibition will make it much harder for anglers to engage in deliberate violations of that nature.
The Draft Strategy would let anglers take baitfish in a lake, but use them only in that same lake. Human nature being what it is, I suggest that is an open door to violations; some anglers will follow the easiest path and take bait where it is easy and productive, and transfer the bait by bucket to where they are fishing but where bait is harder or impossible to get. Even if the number of field conservation officers was doubled or tripled, this practice would still occur. The most effective way to prevent this practice is to totally prohibit the use of live fish for bait.
Regulations have long been in place in Ontario limiting the use of live fish for bait to a defined list of species. Carp and Goldfish are prohibited for use. But, word on the street is that in places in southern Ontario, some anglers have been using Goldfish for bait simply because buying a dozen of them from a pet store is much cheaper than buying a dozen permitted species from a commercial baitfish dealer. That word on the street also suggests that introduced Goldfish are now rampant in lakes in the Peterborough area. If true, this is similar to the situation I have described in Shaw Dam Lake, where introduced Rock Bass have completely taken over the lake to the point that I have heard of underground angler discussion to bring in a few pails of Pike to control the Rock Bass. This indicates that one unwanted introduction can lead to a cascading set of introductions, none of which in the end returns the lake to its original ecosystem, and none of which has any guarantee of providing a quality fishery in the future. The real solution to this is a complete ban on using live fish for bait. This may be unpopular with some anglers, but generational change will come into effect and in a matter of years it will be accepted, as have other regulations that were unpopular when first put in place.
The argument that the use of live baitfish in angling is a long-held tradition that should be continued for that sake alone, is simply wrong. If tradition were the sole criteria by which we kept or eliminated regulations regarding the taking of fish and game in Ontario, all of us would still be able to take fish at night by spearing with the aid of a light, we would all be able to have a piece of gillnet for our own use, and prospectors could still take fish by dynamite; moreover, since there were virtually no fishing regulations at all in Ontario before about 1890, we would not have any seasons, size limits, or possession limits. Of course, we would also not now have a productive and high-quality sport fishery. A large and still growing Ontario population, coupled with continual advances in access and technology, makes it easier than ever before to adversely affect our remaining high quality sport fishery. Tradition must give way to a modern, rational level of natural resource protection and management that is necessary now and in the future if we are to maintain that level of high quality. The baitfish industry has understandably argued against regulations that would infringe on its ability to keep the industry viable. But, that industry is only the smallest part of the overall business of sport fishing in Ontario, in which the bulk of revenues and expenditures are in travel, accommodation, and meals, in the retail sales of boats, motors and tackle, and in on-site accommodation in fishing resorts. It is these fields, not minnow sales, which accounts for angling being a major part of the sportfish-related economy in Ontario. At times industry must give way to the greater common good. I can cite many examples, including the closure of asbestos mining (even though asbestos is a useful material that once supported a whole town), to the current ban on neonictide insecticides to protect bee species, to the reduced use of road salt. Clearly these are industries or parts of industries that have been shut down or reduced for the purpose of a better environment in the long run. Those are examples of resources that are essentially in corporate or private hands. In the case of baitfish and their use and impact we are dealing with a small industry that is exploiting a mostly publicly-held natural resource that I think is better managed by Ontario in a manner reflective of long-term benefit for the public and the environment, namely, by prohibiting the use of baitfish. The baitfish industry is profit driven; it is part of the larger commercial fishery in Ontario waters. MNRF records show that there is a very high rate of infractions in the commercial fishing industry; following the rules is far less important to the participants than making money. Some years ago a review of violation rates by anglers in Ontario revealed that roughly 3% of the huge angler population was found to violate, but that the very much smaller number of commercial fishers had, on average, numerous violations per licence. For instance, it is not uncommon for inspections of baitfish dealer premises to reveal that non-legal fish are mixed in with the baitfish in the tanks. An up to date examination of these statistics may show that continuing the baitfish industry carries a high risk. I argue that it is a risk that is not necessary, its harmful effects are permanent, and it can be eliminated. While the use of baitfish may be popular with some anglers, the fact is that they are not at all necessary to catch sportfish. I have caught a wide variety of sportfish and panfish using plugs, spoons, jigs, spinners, and flies; the manufacture and sale of these artificial baits is a huge industry in itself. It would be an interesting exercise to compare the total economic effect of the live baitfish industry with that of the artificial bait industry. I’ve been watching the Saturday morning fishing shows on television for many decades, and I do not recall a single one of them where live baitfish was used to catch fish. As I was writing these comments, I happened to watch a television program featuring fishing in Ontario that was at least partially sponsored by the Ontario government for tourist promotion purposes; the angling personalities on the show were using only artificial baits, and quite successfully, to take fish. Many of these shows are sponsored by or feature some of the fishing resorts spread across Ontario, and no live bait is used on any of the shows that I have seen. If the use of live baitfish was so critical to success—and success is critical in the filming of these programs—then it would have been used, but it never is. If angling with only artificial baits is successful in the high pressure world of television programs, it will be successful for the larger angling public.
Maintaining the Ontario baitfish industry and traditional angler use of baitfish in the short term should be replaced with long term policy and legislation to protect existing aquatic ecosystems and the existing high quality Ontario fishery. That would be entirely consistent with the Precautionary Principle, but the proposed policy and regulations are not. It is true that the proposed changes go towards it, but they are only half-way measures. There are a number of variant wordings of the Precautionary Principle. One of them is: if an action or policy has a suspected risk of causing harm to the environment, in the absence of consensus that the action or policy is not harmful, the burden of proof that it is not harmful falls on those taking that action. There is, unfortunately, already overwhelming and widespread evidence that the existing policies and regulations allowing fishing with live bait have already harmed the environment by introducing unwanted and invasive species to otherwise pristine waters—this is plainly admitted in the Draft Strategy. These introductions are irreversible, and future introductions will in turn be irreversible. All of the evidence indicates that the continuation of the status quo will result in more harm. I am not aware of any evidence to the contrary, that is, the existence of any evidence from anglers or commercial bait fishers that there is no harmful effect from the use of baitfish and from the release or escape of baitfish or other fish or organisms mixed with baitfish. Given that the use of baitfish has been harmful, and will continue to be harmful if allowed to go on, the rational course is to prohibit it.
The Ontario government recognizes the Precautionary Principle. Ontario is a signatory to the Great Lakes Water Quality Agreement in which it is embodied in Section 10 of the Guiding Principles. It is also embodied in Principle 4 of the Great Lakes Protection Act. The Supreme Court of Canada has recognized the Precautionary Principle and its importance in protecting the environment. In Castonguay Blasting, the court presented a version of the similar Bergen Declaration when it said: ‘This principle recognizes that since there are inherent limits in being able to determine and predict environmental impacts with scientific certainty, environmental policies must anticipate and prevent environmental degradation.’ It added: ‘Where there are threats of serious or irreversible damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.” The Draft for Public Comment of the proposed Baitfish Policy, and the final approved policy and legislation, is an environmental policy. It is designed to stop the further degradation of aquatic ecosystems by the continual transfer of unwanted species to them. When we apply these Principles to the existing situation and the Draft policy and regulations, I would argue that: 1.The best and correct way to anticipate and prevent environmental degradation of natural fish ecosystems, regarding baitfish (and I include all kinds of fish used for bait, and all ‘hitchhikers’ in bait water), is to stop the transport and use of baitfish of all kinds. 2.Since there has been proven serious and irreversible damage to natural fish ecosystems through the transport and use of baitfish (etc, see par. 1 above), Ontario should not postpone the complete ban on the use of baitfish in its waters. However, as an industry is involved, it may be necessary to have a short, defined, phase-out period.
Another way of looking at the Precautionary Principle is, and this is most relevant as it applies to baitfish as an industry, is: do the expected benefits exceed the expected costs? I suggest that the long term financial benefit in a continued baitfish industry (finite contribution to the economy through number of workers, wages, profits, taxes, etc.) is small when compared to the long term economic value of a continued high quality angling fishery that is catered to by many air services, lodges and other accommodations, retail stores and many employees. It, and not baitfish by itself, is a major industry in northern Ontario. And since nobody wants to go fishing in a trout lake where the main catch is now stunted Rock Bass, as in my Shaw Dam Lake example, the Principle suggests that it is the sport fishery, and not the baitfish industry, that must be managed for, and protected, for the long term. I do not object to a phase-out period, as suggested in the policy, to provide time to the industry to switch over to other pursuits.
In order to protect Species at Risk, if the province continues to allow personal and commercial baitfish harvest, then baitfish use and harvest should be prohibited from waters where those species exist. Some of them, such as the endangered Redside Dace, closely resemble non-protected species, and it is not practical to expect that harvesters can, or will, differentiate them. This is an area where even experts might have difficulty. Also, the continued transfer of bait and bait bucket water may bring new parasites and diseases to waters that contain a species at risk, putting them even further at risk. Along the same line, if Ontario continues to allow harvest of baitfish, if there are waters with Invasive Species that can be mistaken for native species, then baitfish harvest should be prohibited from those waters. As this is beginning to include more waters all the time, it is more practical in terms of framing the wording of the regulations and more effective in protecting the aquatic ecology, to simply prohibit the taking and use of all live fish for bait.
Section 5 of the Draft Strategy proposes to restrict angler-caught baitfish for use only in the lake or zone in which they were caught, and outside that with the proper documentation. As someone who has angled for 60 years in Ontario, I am confident when I say that this proposal is entirely impractical if its goal is to protect the existing aquatic ecology and the existing high quality and valuable fishery. Anglers will not follow this restriction, education will not affect changes in current practice (it’s my experience that most anglers rarely read the regulations), and it will be virtually unenforceable. The whole of Section 5 of the Draft policy paper is hard to understand and seems contradictory. Under it, the current high risk of transfer of all kinds of unwanted and invasive species will continue unabated. The only practical and long term viable strategy is to eliminate the use of baitfish.
I will finish with a review of the Conclusion in Section 8 of the Draft Strategy. In it, MNRF admits that there has been much loss in aquatic ecology and fishery quality due to the movement of fish as a result of the use fish for bait. But it also admits that is trying only to reduce the risks and effects of bait use, not to eliminate the risks and effects. When examined in depth, none of the proposed changes will have any real effect in preventing the continued loss of the susceptible trout fishery in lakes, or in preventing more invasive species from being transferred to more waters in Ontario; only a prohibition on the use of fish for bait can achieve that. The Conclusion section also places a disproportionate importance on continuation of the baitfish industry, rather than on the long-term protection and viability of the province’s remaining healthy aquatic ecosystems and high-quality fisheries for the benefit of the people of Ontario. It should be the other way around.
[Original Comment ID: 209160]
Submitted February 9, 2018 3:52 PM
Comment on
Strategic policy for bait management in Ontario
ERO number
012-9791
Comment ID
930
Commenting on behalf of
Comment status