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Advocacy Position



Biscayne National Park has issued a Supplemental Draft General Management Plan which includes two additional alternatives. These two new alternatives, Alternatives 6 and 7 both establish a Special Recreation Zone (SRZ) and are similar except that Alternative 6 allows access to the SRZ based upon a limited number of annual permits and Alternative 7 allows general access except it is closed to fishing during the summer months.  You can find the plans by clicking here.  

Alternate 6 is the Park Service’s new preferred alternative and it eliminates the large marine reserve which was universally rejected by Florida’s recreational anglers.  The preferred alternative also removes the large no combustion engine zones and in their place includes slow-speed and no-wake zones.

As part of the preferred alternative a SRZ would be established in the south east portion of the Park and includes the southern portion of the reef track that runs from  Hawk Channel east to the Park’s eastern boundary. The SRZ comprises approximately 14,500 acres or 8% of the parks waters.

Under Alternative 6 a recreational angler would be required to have a special permit to fish within the SRZ. The permit would be a dual state and federal permit and would be administered by the Florida Fish and Wildlife Conservation Commission (FWC).  Only 500 of these special activity permits would be issued annually with 430 assigned to recreational anglers and 70 being assigned to licensed guides.   

Within the SRZ special regulations would apply, including a prohibition on the  harvest of grouper and lobster: a ban on spearfishing; no commercial fishing (other than ballyhoo) and only hook and line fishing would be allowed. Anchoring within the SRZ would be prohibited, requiring anglers and divers to use the few existing mooring buoys. The plan suggests additional buoys would be installed but, no definitive source of funding is available for those additional buoys. Unless additional mooring buoys are installed, user conflicts and de facto denial of access will occur. The SRZ will be subject to periodic adaptive management and all permit holders will be required to submit a monthly logbook identifying the number of trips taken, the number of anglers, the species and size of fish caught and harvested. Data collection by the submission of the monthly log book is a significant element of this Alternative and will affect future management decisions.

The FWC has been actively involved in the discussions with Biscayne National Park’s Management. CCA applauds the efforts of FWC which is largely responsible for the concessions obtained in the development of Alternative 6. While CCA is encouraged by this progress, further adjustments are necessary to provide for reasonable angler access.

First, Alternative 6 only offers a limited number of annual permits which would be open to anyone who applies. The plan does not require the permit to be used or forfeited nor does it allow for the issuance of short-term permits. The number of permits could be expanded by allowing a segment of them to be shared access, meaning several anglers would share an annual permit with each receiving a number of one day permits.

 Shared permits would allow for more access and should include short duration access for visitors, including out of state anglers that desire to fish the Park as part of their vacation plans. The NPS must also plan and fund additional mooring buoys to avoid user conflicts.  If concern is for grouper population, descending devices could be required. The Park should also consider limited access for seasonal trolling for pelagic species.

The Park also needs to address concerns of those who spearfish or fish east of the Park’s boundary and that transit through the Park’s SRZ as they return to port. Thus, direct transit through the SRZ with disallowed gear stowed should be permitted.

CCA is pleased that the new preferred alternative has eliminated the large marine reserves (no fishing zones) and offers some level of recreational angling access. We hope that these suggestions will be positively received. CCA looks forward to working with  Park management and the FWC to ensure reasonable public access while addressing the resource concerns.

The National Park Service (NPS) will hold three public comment sessions. All interested parties are encouraged to attend any of three identical public meetings as follows:

December 9, 6-9 p.m. - Newman Alumni Center, University of Miami, 6200 San Amaro Drive, Coral Gables, FL 33146
December 10, 6-9 p.m. - City Hall, Commission Chambers, 404 West Palm Drive, Florida City, FL 33034
December 11, 6-9 p.m. - Holiday Inn Key Largo, 99701 Overseas Highway, Key Largo, FL 33037


1. CCA Florida supports the catch and release provisions and other final rule changes being proposed by the FWCC.

2. CCA Florida supports the revised definition of snagging for tarpon, with a couple clarifications that are in capital letters below:

“Snagging” or “snatch hooking” is the intentional catch of a tarpon by any device intended to impale or hook the tarpon by any part of its body other than the mouth, or INTENTIONALLY catching or INTENTIONALLY attempting to catch a tarpon in any manner or method other than enticing or attracting a tarpon to strike with, and become hooked in, its mouth”.

3. With respect to the proposed draft rule for new gear restrictions in Boca Grande Pass, there has been controversy over the use of tarpon fishing gear in Boca Grande Pass for many years. The FWCC and its predecessor, the Florida Marine Fisheries Commission, have held numerous public hearings and Commission discussions on the subject. A 2002-2004 FWCC tarpon study compared jig fishing and live bait fishing and found that there was no significant difference in release mortality. CCA Florida sees no credible evidence of change in the fishery since this issue was last discussed and CCA Florida does not believe that any changes to current regulations related to tarpon fishing in Boca Grande Pass are warranted.


  • CCA Florida has reviewed the Proposed Draft General Management Plan Alternatives (GMP) issued by Everglades National Park and finds the Preferred Alternative Unacceptable! The Preferred Alternative denies reasonable access to anglers and boaters!

  • The Park’s Preferred Alternative will turn ONE THIRD of its waters in Florida Bay into large Pole and Troll Zones (PTZs).The scale of these PTZs is unprecedented! The PTZs are too large and, contrary to statements within the planning document, they lack reasonable access. The PTZs in the Preferred Alternative are de facto exclusionary zones. CCA is concerned that the Park has ignored several years of comments from boaters and anglers in developing its Preferred Alternative.

  • The proposed PTZs in Florida Bay are significantly influenced by tidal flow, winds and seasonal variations in water levels. These conditions as well as safety and weather concerns require access corridors. The distances proposed to access the PTZs are too great to be poled or for the use of electric trolling motors. Access corridors and idle speed access zones are necessary. The Park should establish access corridors in its proposed PTZs similar to those in use in the Pole and Troll Zones of the Merritt Island National Wildlife Refuge. These corridors should be marked with buoys.

  • CCA supports the protection of the Park's marine resources and knows that the vast majority of the anglers/boaters in the Park are good stewards of the resource. Anglers and boaters will favorably respond to better marking and educational programs. Informational markers are necessary.

  • The Snake Bight PTZ should be modified to allow access through Snake Bight Channel, Christian Point and the natural deep water tidal runoffs along the Snake Bight channel.

  • CCA recommends the Park incrementally establish new and accessible PTZs, starting with the areas around Flamingo and progressing outward as funds become available to properly mark access corridors and PTZs.

  • The proposed shoreline zones will enhance the experience of anglers, but the historically used channels in those areas should be maintained for access and boating safety reasons. These lesser channels/corridors should be marked by buoys or indicated as “local knowledge required”.

  • The implementation of a PTZ along the western portion of Gopher creek is not warranted and is a no boating zone. The Cross Bays/Hurdles Creek area should not be restricted as they provide historic access and passage during rough weather.

  • South Florida and the Florida Keys will be significantly and irreparably economically harmed by the restrictions in the Preferred Alternative.

  • CCA requests now as it has in the past, that the Park establish Working Group of experienced anglers to work with Park planners to identify access corridors.

  • CCA requests the Park produce the promised study of the Snake Bight PTZ before the final GMP is issued.

  • CCA believes that additional marking is needed on the Parks access points to educate boaters on proper navigation, prevailing water levels, resource protection and areas requiring local knowledge.

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