406 Victoria Avenue East,…

406 Victoria Avenue East, Thunder Bay, Ontario, Canada, P7C 1A5

Phone: (807) 623-4635 Email: Consultation@RSMIN.ca

www.rsmin.ca

June 26, 2017

Scott Gibson

Senior Fisheries Biologist

Ministry of Natural Resources and Forestry

Policy Division

Species Conservation Policy Branch

Fisheries Section

300 Water Street

Peterborough Ontario

K9J 8M5

Phone: (705) 755-5395

Fax: (705) 755-2901

Good Afternoon Scott,

Following a review of the strategic bait policy on bait management document and discussions with the Red Sky Métis Independent Nation (RSMIN) community we have identified several concerns with the policy. We have also noted that the concerns of the stakeholders present at the June 14, 2017 share similar concerns and it appears that the overall result of implementing the policy will result in a major impact to the local bait industry in the region. The following list outlines the main concerns of RSMIN.

1.Bait Management Zones Restrictions

Bait Management Zones A,B,C located in northern and northwestern Ontario have a deeply rooted relationship when with it comes to sharing bait resources. The bodies of water within the BMZ’s contain similar baitfish and are unlikely to have detrimental impacts to one another. The bait industry in northwestern Ontario relies on the demand of the northern region to supplement income. These restrictions will reduce annual profits of the trappers, which will impact the price that both vendors and consumer will need to absorb. It is possible that the increased price will result in less angling or alternate bait sources.

2.The removal of baitfish from provincial parks

Outfitters, vendors and bait trappers that have businesses that rely on provincial park lakes identified in the document as a bait free area will result in loss of business or eliminated completely. Most of these jobs are positioned in rural setting which is desirable for indigenous employment. The removal of baitfish will also encourage anglers to fish in other inland lakes adding negative pressure to the fish populations in lakes near the conservation provincial parks.

3.Bait Trapping Permit and Two week bait limit

In considering the rationale of the Bait Management Policy, it is important to be accountable for harvesting locations, RSMIN understands the need for the permits. The concern from the RSMIN community lies in the rationale to monitor small quantities of baitfish within the region.

4.Enforcement

The enforcement of monitoring and issuing penalties to individuals in contravention may not be too much for the MNRF officers to administer in their daily roles, however Ontario courts are understaffed and overworked. The backlog of court cases will increase upon approval of this policy and will take officers from the field to be in court. With this in mind, currently there are no such restrictions and a vast change in regulation will result in high number of occurrences. Unless additional officer will be employed to offset the court appearances, it will result in less monitoring and it is likely that more serious infractions will occur.

5.MNRF Fishing Strategy

Within the 2014 proposed Ontario Fishing Strategy, it states “The primary purpose of this Strategy is to improve the conservation and management of fisheries and the ecosystems on which fish communities depend, and to promote, facilitate and encourage fishing as an activity that contributes to individual well-being and the social, cultural and economic well-being of communities in Ontario”. The Strategic Bait Management Policy focuses mainly on the conservation and management of fisheries and ecosystems but neglects to encourage fishing activities and economic well-being. By increasing bait regulations that are unnecessary, particularly in North-western and Northern Ontario makes it more difficult for anglers and discourages fishing activities.

A potential partial solution to the issues mentioned above could be an amalgamation of BMZ A,B and C into a single zone. The combined zone would allow for sharing and utilizing bait within the zone and reduce enforcement and economic impacts. Furthermore, we suggest that if a person lives within BMZ A, B or C they should not have to produce a receipt or comply to a two week rule if they are fishing within their respective zones.

RSMIN expects ongoing communication as decisions are made in regards to the Bait Management Policy that could potentially have negative impacts to the environment or to the RSMIN community itself.

Thank you for the opportunity to comment on the Strategic Bait Management Policy. If you have any questions and would like to contact me please use the email address or phone number above.

Salute et Meegwetch,

Dean Whellan

Community Consultant

Red Sky Métis Independent Nation

[Original Comment ID: 209891]