The LNSA has
taken time to review the MNR's proposed Lake Nipissing management Plan and has chosen
to submit our input as follows:
Page #3
The plan
proposes to improve collaboration with First Nations to better understand the
demand for walleye by their communities for food, cultural, spiritual and
commercial purposes. The plan also proposes to continue collaborative research
efforts, expand the scope of studies to enhance existing information and
increase public awareness of walleye biology and the limitations of some
management tools (e.g. stocking within the current Lake Nipissing context).
The letter published in the North Bay Nugget recently
by the Chief of NFN indicated that they do not intend to make any changes to
their fishery. The 2014 regulation
changes on the Sports Fishing Industry rely on our First Nation friends to adhere
to the recommended harvest provided by the science data delivered in a
collaborative literature “Rowe, R, N. Commanda and S. Kaufman. 2013. Lake Nipissing Walleye Risk
Assessment Model for Joint Adaptive Management. Ontario Ministry of Natural
Resources. 45 pp. Draft” All well respected scientists in our community.
Northern Pike Management
Recent
studies indicate the northern pike population is showing signs of stress with a
decline in the overall abundance of northern pike in the lake. A more thorough
data review of the pike population dynamics and status in the lake is required
and is in process in order to properly inform future management actions for the
species. The pike regulation for the lake will remain unchanged until this data
review is complete.
The LNSA customers value pike greatly. We would like to encourage a study to better
understand why the population appears to be shrinking.
Page #4
Smallmouth and Largemouth Bass Management
Key
highlights include the proposed implementation of a new bass regulation that
promotes angling for bass focussing on their sporting qualities and providing
additional angling opportunities through a one week extension of the open
season.
The LNSA appreciates the opportunity to target bass
earlier in the season. We would
encourage the MNR to implement an annual study to ensure the bass population
does not suffer from the new regulation changes.
Page #8
The MNR also
has authority for fisheries management under a number of provincial statutes
including: the Natural Resources Act (NRA); Crown Forest Sustainability Act
(CFSA); Public Lands Act (PLA); Lakes and Rivers Improvement Act (LRIA); and
the Environmental Assessment Act (EA Act) all of which contain provisions for
the protection and perpetuation of the province’s fisheries resources.
The MNR has a fiduciary duty to ensure the harvest of
the Native run Commercial fishery maintains a sustainable harvest number based
on the fact that over 90% of the commercial harvest is below 46 cm., the very
age group the Biologists say must not be removed from the lake if we
hope to see a recovery.
Page #9
Despite the
fact that Lake Nipissing is being managed at the individual lake level, the
broader landscape scale was considered during the planning process. While
management planning decisions were made specifically for Lake Nipissing, the
effect of these management actions on adjacent fisheries management zones (FMZ
10 and 11) were also considered, including the implications on adjacent SDW’s
(French River and Lake Temagami). It is estimated that Lake Nipissing accounts
for over a third of all angling effort directed at walleye in FMZ 11 (OMNR
2010). Displacement of effort away from Lake Nipissing would likely result in a
significant impact to surrounding waters both within and outside of the zone.
Proposed management actions, particularly those related to walleye have
considered the potential impacts of diverting fishing pressure elsewhere across
the landscape.
Lake Nipissing is the only large lake in Ontario
without a Fish Assessment Unit. After
reviewing the “Lake Nipissing 1995 Data Review” a document that summarizes ~20
years of studies, the LNSA believes that Lake Nipissing would not be facing
this crisis if the Fish Assessment Unit had not been disbanded.
Page #16
The Lake
Nipissing fisheries provide cultural, social and economic benefits to both the
NFN and DFN. The MNR recognizes the constitutional right of both Dokis and
Nipissing First Nation’s to fish Lake Nipissing for sustenance. In addition, R.
v. Commanda 1990 has recognized Nipissing First Nation’s right to commercially
fish Lake Nipissing.
The Supreme Court of Canada needs to consider
population growth when making decisions to allow First Nations right to fish
commercially. Their decisions are based
on trade with Europeans over a hundred years ago. The population has grown significantly, the
resource has not.
The LNSA has suggested that First Nations take a role
aligning their communities with the Sports Fishing Industry as Conservation
Officers on Lake Nipissing. This would
offer First Nation communities sustainable jobs, the resource would last
indefinitely, and both communities would prosper.
Page #23/24
The 2007–2010 Interim Fisheries Management Plan recommended a
study on the effectiveness of the community hatchery stocking program on the
lake to determine how the current program should move forward. The study
examined the relationship between walleye summer fingerling stocking rates and
young-of-the-year catches in the Fall Walleye Index Netting assessment. No
relationship was found. Similarly, there was no significant relationship
between the number of walleyes stocked and the contribution of these fish to
the population or adjacent year classes. Finally, there was no relationship
between the number of walleye stocked and angler catch rates either 2 or 3
years later when those fish would have been recruited to the angling fishery.
The study concluded that this low-intensity stocking program was not providing
a measureable benefit to the walleye population or the fishery of Lake
Nipissing, (Kaufman 2007) which was to be expected by a small scale stocking
program.
The LNSA agrees with Mr. Kaufman’s assessment. Small scale stocking has little if any
positive impact on walleye populations.
This has been the direction of the LNSA from the beginning; we need to
increase the stocking levels to match the size of the lake to see the gains we
require.
Page #29
Explore the feasibility and necessity to calibrate the FWIN
survey specifically to Lake Nipissing for resource managers to get an
actual versus an estimate of fish density. This would be done with the use of a
mark/recapture technique that would be incorporated into the spring walleye
spawning assessments and would run through the course of the open water fishing
season and the FWIN. This would provide direct estimates of fishing mortality,
natural mortality and population density, which can then inform model-based
management decisions with empirical data (actual observation data from
experiments) versus theoretical data (generalized scientific rules of thumb).
The Fish
Assessment Unit (FAU) did these studies and the LNSA agrees. We need to add
resources to Lake Nipissing. Bring back
our FAU, it’s worth the cost.
Page #54
Opportunities:
MNR is already participating in a water level management
program that is meeting the needs of identified valued ecosystem components
such as spawning habitat.
Explore incorporating key elements of the natural daily,
seasonal, annual and inter-annual patterns in this regulated system to address
issues that may be affecting components of the broader lake ecosystem.
MNR can increase public understanding of how we are managing
water levels on the lake.
The LNSA’s
members require a stable water level to maintain a healthy business. However,
we understand the challenges that come along with dam control but we would
appreciate further education by the MNR to allow stakeholders to anticipate
water levels based on anticipated weather conditions.
Page #57
MANAGEMENT ISSUES, CHALLENGES, AND OPPORTUNITIES
Issues and challenges:
MNR has limited legislative authority and influence on
activities that affect fish habitat
Naturalized shorelines which promote fish habitat and
healthy aquatic ecosystems do not always provide for shorelines preferred by
property owners
Fish habitat mapping and enhancement projects often not
viewed as rewarding or providing immediate benefit to volunteers/stakeholders
Inventory of habitat for all species in the lake (distribution,
quantity, and quality) does not currently exist
LNSA
members would be willing to volunteer for habitat rehabilitation provided a
fulltime Biologist from the MNR would educate and guide our group.
Page #66
MANAGEMENT ISSUES, CHALLENGES AND OPPORTUNITIES
Issues and Challenges:
The public perception of threats to the walleye population
by cormorants
The public perception of water quality impacts from
cormorants
The general public opinion of cormorants as a “nuisance”
The limited understanding of the ecological role of
cormorants as a top predator in structuring the lake’s fish community
The limited understanding of the impact of the species on
the aquatic ecosystem
The occurrence of the public taking illegal action(e.g.
oiling eggs on nest sites)
The unnecessary protection afforded to
double-crested cormorants, by the Fish and Wildlife Conservation Act, should be
removed. This can be accomplished by adding them to the list of species under section
5 (2)(a) that includes American crows, brown-headed cowbird, common grackle,
house sparrow, red-winged blackbird and starling. Please note that these
species are in no way compromised. Crows and starlings are in no way
compromised. Fisheries and wildlife management objectives would determine
population management. Overpopulation of cormorants continues to decrease
benefits, and increase costs associated with fisheries and terrestrial
ecosystem values.
The current population of cormorants on Lake Nipissing
consume in excess of 500 000 kg of fish.
This bird is a stakeholder and needs to have their numbers reduced.
Page
#68
STATUS OF THE LAKE NIPISSING FISH DISEASES
Lake Nipissing has been home to many common fish pathogens and
parasites and to date there have been no known major fish disease epidemics. Of
primary concern for Lake Nipissing and Ontario at this time is the emerging
invasion of VHS (viral hemorrhagic septicemia) across the landscape. The
establishment of VHS in Lake Nipissing has the potential for significant
biological and socio-economic impacts.
As of 2012, Lake Nipissing was confirmed
VHS free. Unfortunately however, due to the location of the lake, the nature of
the disease, the close proximity to VHS positive zones, the option for baitfish
retailers to purchase baitfish from Lake Simcoe, and a significant user base
that comes from or travels through that zone, Lake Nipissing has a high risk of
becoming contaminated with VHS.
The
LNSA members recognize the need for bait controls to minimize the spread of
VHS. We have been educating clients on
the risk of bringing untested bait to Lake Nipissing but we struggle to
understand why the MNR is slow to implement legislation on individuals carrying
bait from southern Ontario. This makes
it very difficult for Resort owners to enforce safe bait practices.
Page
#75
7.1 Enforcement
The role of enforcement within the Ministry is to safeguard
the public interest by leading and delivering professional regulatory
protection of Ontario's natural resources.
Enforcement post development of the fisheries management plan
and associated regulations is extremely important. Without enforcement there is
a serious and potential risk that illegal fishing activities could compromise
the implementation of the management plan and potentially impact the resource.
STATUS OF LAKE NIPISSING ENFORCEMENT
MNR Enforcement prioritizes their
workloads on an annual basis and has and will continue to promote the use and
respond to TIPS received by the TIPS line on an as needed basis.
The
LNSA members are on the Lake 300 days of the year and as such, have observed
inadequate MNR enforcement. We have
great respect for our Conservation Officers (CO’s) but would like to see them
more often. There is great value in
education and the CO’s are in a position to work closely with Resort owners,
helping educate sports fishermen from southern Ontario. The most effective
method of regulation compliance is education.
Page # 79
Opportunities:
There is support from the public and stakeholders that
supports implementation of a fee for commercial ice hut use on the lake
There is support from the LMFMPAC to develop stewardship
products that promote both proper ice hut use and ice fishing etiquette on the
lake
Consider standardizing commercial ice hut registration and
licensing for province.
The LNSA
supports a fee for commercial Ice shack licences provided the money goes
directly back to the Lake. The current
ROI (return on investment) is less than 1% by the current MNR.