The draft Strategic Policy…

The draft Strategic Policy for Bait Management in Ontario offers improvements to OMNRF’s current baitfish policy. The authors should congratulate themselves for this draft. They still need to address these and other comments to make it an outstanding policy.

I have two major concerns with this draft policy document: 1) the quality of the writing is not up to par, and 2) the policy ignores upstream and downstream movements of fish and diseases. As well, I have questions about disposal of commercially harvested bait within two weeks of purchase.

In my opinion, the quality of writing in this document does not meet past standards for Ontario policy documents. For example, throughout this document sentences are overly long, and run-on. They are difficult to understand. GOV.UK limits sentence length to 25 words and explains why (https://insidegovuk.blog.gov.uk/2014/08/04/sentence-length-why-25-words….) A 20-word limit for sentence length is a more common recommendation as longer sentences are difficult to read (https://strainindex.wordpress.com/2008/07/28/the-average-sentence-lengt….) In addition, the use of “There is...” or “There are…” at the start of a sentence is poor style for this type of document. This style may be okay for popular writing, but should be limited severely in more technical works. In this type of document the subject (topic) of the sentence should be the subject (a noun) of the sentence. As well, other minor writing issues in the document are left for you to find and fix. Unfortunately, most biologists receive very little training in technical writing. Accordingly, I suggest that this document should be edited by a professional technical writer.

The draft policy ignores upstream and downstream movements of fish and diseases. Accordingly, the proposed possession policies (4.1 and 4.2) are fatally flawed for some Brook Trout lakes and some wilderness, nature reserve, natural environment, waterway and cultural heritage class provincial parks. Legally used baitfish may escape and establish themselves in lakes and streams upstream and downstream of protected waters. Emigration to the protected waters is now likely where no dams or waterfalls bar movement. In such cases the policy fails its Purpose (1.1). The solution is to use a watershed approach. Restrict bait possession at all lakes and streams upstream and downstream to the first impassable barrier for the lake or park of interest. For example, the policy works well for most of Algonquin Park where all headwaters are protected. However, it does not work for the few streams with headwaters outside the park. Most Brook Trout lakes in Ontario are headwater lakes. However, their tributaries are not included in the policy. To remove this policy flaw all tributary and some downstream lakes and streams should be included with Brook Trout lakes. This may be unacceptable for many parks, and so a limited number of parks could be included in this policy. Those parks that are unacceptable for using a watershed approach should not be included in this policy.

Please explain why commercially harvested baitfish must be disposed of within two weeks of purchase. This makes no sense to me because of inconsistencies with policies, regulations, and ethics with respect to OMNRF’s conservation mandate. Would salting (by the angler) be considered valid disposal?

[Original Comment ID: 209657]