INTRODUCTION
The Biscayne National Park (BNP) contains some of the finest saltwater recreational fishing areas in Florida. The Park’s location in highly urbanized southeast Florida makes it an extremely valuable component of Florida’s 4.5 billion dollar saltwater recreational fishery. High recreational usage is one of the major values and benefits of the Park. Such recreational use can create management challenges and opportunities. In recent years, some groups and managers have been promoting “no entry” and “no fishing zones” as a means to protect natural resources. Such measures have been pushed even before other more reasonable and proven measures have been tried. The real challenge to Park managers is to not shut down access but rather, instead, to work cooperatively with recreational fishers to develop plans which provide access and resource protection. It is in that regard that we offer the following comments and recommendations.
1. USE LOCAL ADVISORY PANEL TO DEVELOP GENERAL MANAGEMENT PLAN MODIFICATIONS
* The most important recommendation we make is for the Park to use the recently formed Fishery Working Group to make specific recommendations and modifications on the proposed zones in the Park’s preferred alternative. Local knowledge and local buy-in is critical to the success of the plan. The Working Group contains diverse and knowledgeable local recreational and fishery interests. It is the perfect group to provide detailed comments and recommendations. We would like to point out that such groups have previously been used by the National Park Service in Florida to develop access and resource protection plans. About ten years ago, the Ft. DeSoto National Park, Pinellas County and knowledgeable local anglers and guides developed a successful plan which provided seagrass and manatee protection and access for various types of fishing.
2. ENFORCEMENT AND VOLUNTARY COMPLIANCE
* At a recent meeting of the Working Group, Park staff stated that creel surveys show that 40-45% of the mutton and yellowtail snapper taken in the Park are undersize. Such information demonstrates that the Park already has a serious enforcement and/or public information problem. Adding more regulations with complex zones and areas is not going to provide any real benefits unless the existing enforcement and/or public information problems are resolved. Using the local Working Group can help solve the problem by enhancing local buy-in and voluntary compliance.
3. ACCESS RESTRICTION ZONES IN THE DRAFT ALTERNATIVES
* CCA firmly believes that “no fishing/no entry zones” should be the last, not the first, management option. Alternatives 2, 3, 4, and 5 contain increasingly larger “no combustion engine zones.” The size, management, and configuration of many of these zones will make them defacto “no-fishing” zones. The Park should modify many of the no-combustion engine zones to provide access corridors for reasonable on plane boat speeds, slow speed zones, or reduce the size of the zones. Again, the local Working Group can provide specific recommendations. To further describe our position on “marine protected area/no fishing zones” we have attached our national CCA position statement. Again, we feel that prohibiting fishing and access should be the last resort not the first option.
* The “no combustion engine zones” in the Arsenicker Keys area in alternatives 4 and 5 are two miles wide in some areas. In addition, the Featherbedbank “no combustion engine” zone is about 1.5 miles square. Such zones would effectively eliminate most recreational fishing. Not everyone has the financial means to afford a boat with a poling platform and/or electric trolling motors. Even with such equipment poling or electric trolling for 2 miles in and 2 miles out of an area is very difficult or even impossible under some wind and tide situations. We recommend that much of these zones be eliminated and/or modified to “slow speed” with some designated higher speed access corridors. Slow speed would allow use of a combustion engine and would still provide protection for seagrasses and other resources. Again, the Working Group can help identify boating access corridors which would allow reasonable fishing access while protecting seagrass areas.
* Alternatives 3 and 5 contain “access by permit only” zones. CCA Florida does not support “access by permit only” zones. It is unclear from the Park’s alternatives who or what would be allowed and who would be excluded. In addition, the current enforcement problems indicate that such measures would be extremely difficult to implement and enforce. Thus, any benefits of such zones are highly questionable.
In closing, we look forward to working with Biscayne National Park and the Florida Fish and Wildlife Conservation Commission to develop a General Management Plan which will to protect the Park’s valuable natural resources while maintaining excellent access for saltwater anglers.
