• There are much more effective and more enforceable management measures to protect spawning aggregations of reef fish. Far greater benefits are obtained by prohibiting harvest and sale during the spawning season. Such measures protect spawning aggregations THROUGHOUT THE ENTIRE RANGE OF THE FISHERY, instead of only the “No Fishing Zone” (NFZ) subsets of the range.
  
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  “No Fishing Zones” (NFZs) will create a large and unnecessary confrontation between fishery managers and saltwater recreational anglers – the very individuals and groups which have been the primary supporters of fisheries conservation initiatives in the past. The confrontation will delay and divert attention from enacting proven and effective management measures such as Spawning Season Closures (SSCs).
  
  
• “No Fishing Zones” (NFZs) place an unfair and disproportionate burden on fishers in the NFZ area. Harvest restrictions should be enacted and distributed fairly throughout the range of the fishery.
  
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  NFZs unfairly and inappropriately prohibit all forms of recreational fishing (even catch and release) on fishery stocks that are clearly healthy and not overfished – such as sailfish, redfish, dolphin and Spanish mackerel.
  
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  NFZs place unrealistic and unfunded enforcement burdens on state and federal fish and wildlife agencies, which are already understaffed. However, Spawning Season Closures (SSCs) are so simple to enforce that you do not even need a boat – simply check the catch of returning fishermen when they return to land.
  
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  Without the necessary and proven management measures to control total commercial and recreational fishery take throughout the range of the fishery, the

NFZs will merely shift fishing effort to non-NFZ areas. We are unaware of any instance where marine “no fishing” reserves (NFZs) have been used as a primary management measure to restore an overfished fishery.

• The national groups promoting the establishment of Marine Protected Areas (MPAs/NFZs) take extreme and unyielding positions on allowable uses in the areas – i.e. absolutely no fishing, no take of any kind – even when certain types of recreational fishing have less impact on fisheries and habitat than other allowable uses. The Tortugas “no fishing reserves” are prime examples of this extreme position.
  
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  The “Type 2 MPAs” (where certain types of fishing such as surface trolling may continue) are at best merely a precursor, or at worst, simply a trick to establish a “No Fishing Zone.” Very clear examples of this are:
  

1)      Gulf gag grouper closure zone – touted for 18 months as closure for reef fishing only. At final Gulf Council vote it was converted to a total closure – NFZ.

2)      Ocullina Banks – originally established to protect coral habitat from bottom tending gear and to prohibit reef fish fishing. It is now on “the list” for the second time in 4 years for a “no take” – NFZ.