“Exploring Strategies To Enhance Protections For Brook Trout and Arctic Charr While Preserving Traditional Fishing Methods And Fishing Economies”
Native Fish Coalition
PO Box 332
Windham, ME 04062
October 12, 2018
Commissioner Chandler Woodcock
Maine Department of Inland Fisheries and Wildlife
284 State St
Augusta, ME 04330
Re: Comments Regarding MDIFW’s Proposal: “Exploring Strategies To Enhance Protections For Brook Trout and Arctic Charr While Preserving Traditional Fishing Methods And Fishing Economies”
Dear Commissioner Woodcock,
I am writing on behalf of Native Fish Coalition. Our intent is to provide comments on IFW’s recent public notification regarding the State Heritage Fish Working Group’s proposal to enhance protections for brook trout and Arctic charr while preserving traditional fishing methods and economies.
Native Fish Coalition (NFC) is a non-profit conservation organization whose mission is to protect, preserve and restore native fish. We are a 501(c)(3) national organization incorporated in Maine. The Maine chapter has a Board and Advisory Council as well as members, partners and volunteers. Native brook trout and Arctic charr are focal species for Maine NFC.
What is being proposed is the result of nearly two years of negotiations between IFW and the State Heritage Fish Working Group. It came about as a result of an attempt by members of NFC to amend the State Heritage Fish (SHF) law to extend the protections provided to so-designated waters to their "tributaries." Under Maine law (Title 12), "tributary" means "inlets up to the first Great Pond," and does not include outlets. While the amendment failed, MDIFW was asked by the legislative committee to address the problems via policy not law.
If approved, the current IFW proposal would protect more waters than the proposed amendments as it is not limited to inlets, or in fact even moving water. As a result, live bait would be prohibited on numerous streams that would not have been included in the proposed amendment. It would also be prohibited on some level of lakes and ponds not currently open to ice fishing. While we have not seen the list, this could easily impact dozens and maybe even hundreds of waters, none of which would have been protected under the proposed amendment.
The proposal is a major step in the right direction regardless of any omissions and exceptions. While the proposal clearly states that waters currently open to ice fishing will not change, it also notes that there will also be some yet-to-be-determined level of "exceptions" where live bait will continue to be allowed on moving water and lakes and ponds not currently open to ice fishing. The extent of this will greatly influence how effective the proposal will be.
While far better than what we have today, the proposal will primarily prevent anglers from doing in the future what they are already not doing today, figuratively not literally. It will not stop what they are doing today that is potentially harmful to the resource -- using live fish as bait in delicate wild native salmonid waters. And while the current proposal leaves the door open for the expansion of the use of live bait in the future via the "exception" clause, we hope this is more about protecting and preserving what is being done today than it is expanding it in the future.
NFC supports the proposal with the caveat that while it is a major step in the right direction, it falls short of what is needed to protect our wild native brook trout and charr in perpetuity. As a "fish" not "fishing" centric group, we cannot say or even imply that this is a cure-all for our wild native trout and charr woes -- it is not. But while what it doesn't do is important to note, what it does is more important.
We are suggesting that others support the proposal as we are, as it is good for wild native brook trout and Arctic charr. We hope this will leave the door open for further dialogue as to how to best protect Maine's irreplaceable wild native salmonids for generations to come.
Thank you for the opportunity to submit comments on this proposal.
Maine State Chair, Native Fish Coalition
CC: Maine NFC Board and Advisory Council