Introduction…

Introduction

NOTO consulted with industry on the proposed draft policy on the Strategic Policy for Bait Management in Ontario. In our discussions we highlighted the purpose of this policy and the context under which the draft policy was developed. Members of NOTO are stewards of resource protection and most of them have an exceptional grip of the importance of maintaining healthy aquatic systems. The livelihood and business success of tourist outfitters heavily relies on the protection and preservation of the natural resources. In the same breath, NOTO members are users of the resource base at the “on the ground” level and over the years have accumulated enormous knowledge and insights of the geography, ecological values and the working of the eco system, especially in the northern part of the province.

NOTO has received a considerable amount of feedback on this draft policy and we have summarized the main concerns below.

Movement of Bait

The most resounding concern we have received from our industry on the Strategic Policy for Bait Management in Ontario – Draft for Public Comment, is the crippling effect the proposed Bait Management Zones will have on tourism businesses. The ability of anglers to use bait to fish is an important aspect of the decision making process when one is considering a destination. Being able to use bait to fish has been a significant factor in choosing Northern Ontario as the destination of choice for a vacation. The new proposed Bait Management Zones will severely curtail the ability of tourist operators, especially those that are fly-in operators to obtain bait for use at their outpost locations.

We have tabulated the number of operators that cross boundaries in proposed BMZ’s A, B, C, D and E that will be affected by the boundaries and our preliminary numbers indicates that over 65 tourism businesses will be affected. This preliminary scrub only covers operators that are members of NOTO and of the three main travel associations that covers Northern Ontario, it is in no way a true reflection of the actual number of tourism businesses that will be affected of the approximately 950 tourism businesses present in Northern Ontario. It is a calculated guess that the number of operators that will be affected by this restriction will well exceed 65.

In our request for information regarding how this proposed policy will affect tourist operators, we were told that the BMZ’s as proposed and measures to curtail the movement of bait between zones, especially between zones, B, C, D and into A, will do nothing to achieve the purpose of the policy, but on the flip side will reduce the tourism receipts of Northern Ontario which is approximately $ 1.5 Billion, potentially creating negative economic impacts on the local economies of regional tourism sub-regions A, B and C.

At this point our efforts at finding out who will be crossing the boundary lines when moving from their base to outpost camp has been focused on fly-in remote operators. However we are cognizant of the fact that drive-in and boat-in operators will also be affected by this measure.

Proposed Solutions

- The combined FMZ’s is not a feasible option for Northern Ontario. A number of our member outfitters have discussed with us to great lengths why this is a bad idea and they are willing to provide years of knowledge of the geography of Northern Ontario to assist the MNRF to come up with realistic zones based on detailed analysis of the primary watersheds, topography and geographic landmarks that will provide a workable and realistic mechanism to manage movement and will definitely be more effective in achieving the purpose and objectives of this proposed policy.

- Making exceptions for operators crossing the present boundary lines may be a consideration that can be further analyzed and discussed but is an option that may provide some relief on the economic considerations but not on the actual objectives that this policy sets out to achieve.

- Using the 3 main primary watersheds of the province is an option that has been identified. Although this option may pose some challenges, it is, however a better option than the combined FMZ’s and a provision in the policy of how to deal with specific matters arising that pose ecological risk, such as VHS, should be built into the policy, in order to give the MNRF leverage to effectively address such risk when they arise elsewhere in the province.

Baits in provincial parks and conservation reserves

A number of tourism businesses across Northern Ontario operate within the boundaries or at some point cross the boundary of; wilderness, nature reserves, natural environment, waterway and cultural heritage class provincial parks and have been using bait responsibly for decades. Prohibiting their guests from using bait will have impacts, such as:

-Fishing opportunities will be less attractive and they will potentially lose clients which could wipe out their business. -Force them to purchase and use artificial lures, which are not as effective as live bait, and can be a much more expensive option. -Impact on the fishery when fish swallow rubber bait and expire due to wasting.

While outfitters that will be affected appreciate that bait in recreational class parks and conservation reserves is to be generally allowed, those businesses that operate on waterway and other classes of parks that and is currently allowed to use bait is fearful that they could go out of business because of the new measures.

Proposed Solution

- Review current tourist operators who conduct their business in classes of parks that propose total bans on use of bait to be individually evaluated, taking into consideration their operation and business model and what level of risk they pose to the aquatic system. Depending on the level of risk they pose, they should be granted permission to operate within a framework of reasonable conditions set out to ensure they conduct themselves responsibly.

In Conclusion

Overall, the feedback that we have gained from the resource-based tourism industry has pointed to the flaws in the currently proposed strategy. The concerns surrounding the proposed policy`s ability to meet the objectives of protecting our lakes and waterways from invasive species will not be met if it moves forward in its current form. It is our hope that NOTO will be offered an opportunity to discuss the concerns and recommendations that we have outlined with those within MNRF that are involved in developing this strategy before it becomes finalized.

We would like to explore amiable policy positions that will better meet the objectives of the overall strategy and to enable the tourism business environment to transition smoothly and ensure business certainty to those that will be adversely affected.

[Original Comment ID: 209932]