Originally Published in the August 1992 issue of The Outfitter Magazine.

NOTO’s Suggested Improvements to Proposed License Structure

NOTO shares the Ministry’s desire for a more easily administered license system that generates sufficient revenues for the Ministry and for fish and wildlife management programs. However, we cannot accept the Ministry’s proposed fishing license structure as it currently stands. NOTO would like to suggest a number of modifications to the structure, as outlined below.

Hunting and Angling Cards

NOTO supports the concept of a Hunting and Angling Card. We are also pleased that the Ministry is proposing to eventually make it available to non-residents who hunt and fish in Ontario on a regular basis. It would benefit our industry, however, to allow these persons to be brought into the system as soon as possible. Furthermore, we would like some clarification as to the definition of “on a regular basis”.

Number and Typed of Fishing Tags

The proposal for offering seven fishing tags closely resembles a NOTO resolution to Minister Wildman that was passed at our 1991 Convention. There are two major differences, however. First, NOTO recommended a 7 day non-resident conservation license be implemented, which does not appear in the Ministry’s recommendations. The cost of this license would be one-half the cost of the proposed 7 day non-resident license.

We strongly believe that this tag would be purchased extensively by our industry’s non-resident clients. Therefore, we propose that this tag be reconsidered by the Ministry. We request that an explanation be provided as to why it has not been include thus far.

Second, the NOTO resolution considers Canadian residents living outside Ontario as non-residents. Therefore, the license structure should only contain two classifications (residents and non-residents) not three as the Ministry proposes (Ontario residents, Canadian residents and non-residents).

The Need For a Spousal/Family Tag

Both the NOTO resolution and the Ministry’s proposals failed to recognize the need for retaining the non-resident spousal/family tag. We believe this must be corrected.

Ontario is being promoted increasingly as a family vacation destination, and our industry is repositioning itself to meet the demands of this new market. Retaining the spousal/family tag would allow this client group to enjoy the best that Ontario’s water has to offer without having to spend upwards of $180.00 for licenses (i.e. husband and wife with two kids of 16, who stay for over 7 days).

Retain the non-resident spousal/family tag, in both the regular “take” format and the “conservation” format. As with the other tags, the spousal/family conservation tag must be one-half cost of the regular tag.

NOTO’s Proposed License Structure

NOTO proposes an 8 tag license structure as follows:

We recognize that this structure contains one more tag that the Ministry’s proposal. However, it will make it easier for the Ministry of Tourism and Recreation and our industry to encourage non-residents to experience an outdoor vacation in Ontario.

“Conservation” Licenses: Protecting the Resource

NOTO proposes the following parameters be placed on all forms of conservation licenses to help ensure they reflect a true “conservation” ethic, as opposed to one that simply advocates reduced harvesting.

With the exception of those species noted below, the catch and possession limit on the license be set at two (2) fish. This would allow anglers to catch two (2) fish for a “shore lunch”, but would not allow for the export or transport of fish off the water. The exceptions are lake trout, muskellunge and sturgeon, where the catch and possession limit would be zero (0).

It is time for anglers to fully recognize the benefits to the fisheries resource that accrue from practicing catch and release angling. It is also time to promote Ontario as a place where tremendous angling opportunities can be experienced, without having to take fish home.

The NOTO resolution also recommended the issuance of a conservation pin/badge to anglers who bought conservation licenses, to identify them as conservation-minded fishermen. There is no mention of such a pin/badge in the Ministry’s report. We urge the Ministry to reconsider its position and make such a pin/badge part of the conservation license structure.

Cost of Fishing Tags

NOTO feels the costs proposed by the Ministry are too high. At the 1991 NOTO Convention, delegates were told by Ministry staff that the Ministry’s proposed fee structure would be in line with those of surrounding jurisdictions. The original fees proposed in the NOTO resolution were, therefore, based on that assumption.

Subsequent research, however, has shown that the Ministry’s fees are up to 40% higher than those in some surrounding states and provinces. As such, NOTO does not support the Ministry’s proposed fees and recommends they be lowered.

For example, in the Ministry’s proposed structure, the 7 day non-resident license would cost $30.00. A non-resident 7 day conservation license (if accepted) would cost $15.00. In the NOTO resolution, however, the costs for the same licenses are $22.00 and $11.00 respectively.

Many operators who offer American Plan packages have expressed reservation over eliminating the non-resident 4 day tag, due to the amount of 3 and 4 day business they receive. They seem to be willing, however, to endorse the 7 day conservation license as a compromise, but only if the price is right.

The Ministry should, therefore, consider NOTO’s proposed fees in this example, as the maximum amount that operators feel their guests are prepared to pay. Furthermore, we urge the Ministry once again to do its utmost to lower all tag prices in a similar fashion.

We would recommend that NOTO work with the Ministry to develop an entirely new fee structure that more accurately reflects the needs of our industry.

The perception among many non-resident guests is that a vacation in Ontario is already too expensive, given the high cost of goods (food, alcohol, gasoline) and stiff tax rate. The cost of the Ministry’s proposed tags will do nothing to change this perception. NOTO would like to receive a further explanation as to how the Ministry arrived at its proposed fee levels, and why in some instances, the fees proposed in the NOTO resolution were rejected in favour of higher fees.

Need for Education and a Flexible System

NOTO understands that the introduction of conservation licenses will necessitate the increased education of those who fish in Ontario. As such, we will make every effort to encourage our industry operators to explain to their guests the differences between the regular and conservation licenses, in order that an informed purchase may be made.

Furthermore, the issuance of a pin or badge to conservation tag purchasers would serve as a reminder of the importance of conserving our fisheries and protecting them from over-harvest.

Invariable, however, there will be times when anglers purchase a conservation license, and later wish to buy a regular license (i.e. to be able to export or transport fish home), or vice versa. In such instances, the license system must be flexible enough to allow anglers to purchase a second license. This would provide the government with extra revenue. The license issuer would also get his regular commission for selling the second license.

Fees Paid to License Issuers

The proposed increase in fees paid to license issuers is welcomed and long overdue. We believe; however, that the increase should have been greater, to more sufficiently remunerate operators for their efforts in administering the licenses and paperwork.

Directing License Revenues to Fish and Wildlife Programs

NOTO has previously expressed its dismay over the recent reductions in the Ministry’s budget for fish and wildlife management to the Premier and Minister Wildman (letter from NOTO President to Premier Rae on March 20, 1992, and response from Minister Wildman on May 28, 1992). Once again, we implore that revenue generated from license sales be channeled back into fish and wildlife management, and especially programs like CFIP.

In particular, the Minister must make a formal commitment that all fishing license revenues (resident and non-resident) will be allocated to the Ministry’s fisheries budget.

Thank you for the opportunity to make comments on the Ministry’s discussion paper. We hope you will give serious consideration to our modifications. We believe that, if implemented, they will result in a better licensing system than that proposed by your Ministry.

We look forward to receiving your response.

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