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A. RECOMMENDATIONS
#1. INCREASE MINIMUM SIZE FROM 10 INCHES TO 11 INCHES FOR BOTH RECREATIONAL AND COMMERCIAL FISHERIES. We do not support the current proposals to reduce bag limits and trip limits.
#2. POSSESSION AND
SALE
OF POMPANO UNDER 11 INCHES SHOULD BE PROHIBITED. By-catch and other exceptions are loopholes that can be utilized by illegal fishers. However, a prohibition on possession and sale of undersize fish (just like the FWC’s current regulations on groupers and snappers) cannot be circumvented.
#3. SUPPORT STAFF RECOMMENDATION TO ELIMINATE THE SPECIAL PERMIT TO ESTABLISH FEDERAL WATER GILLNET FISHERIES. CCA Florida has consistently claimed that there is no legitimate federal water gillnet fishery and the permit program has proved that we were correct.
#4. SW FLORIDA – COLLIER / MARCO - FEDERAL WATERS GILLNET AREA SHOULD BE RESTRICTED TO ONLY THOSE NET FISHERS THAT HAVE DEMONSTRATED TO FWC OBSERVERS THAT THEY CAN GILLNET POMPANO IN FEDERAL WATERS. In the 2½ years that the FWC has been dealing with this issue only 2 fishers off of
Marco
Island
have shown observers that they can gillnet pompano in federal water. Yet, 86 permits have been issued to fishermen to gillnet pompano in that area.
#5. REDUCE COMMERCIAL TRIP LIMIT TO 200 LBS. – OR THE EQUIVALENT NUMBER OF FISH. The total lack of participation in the special federal waters gillnet permit program clearly demonstrates that the only legitimate pompano commercial fishery in
Florida
is the commercial hook and line fishery. FMRI trip ticket analysis shows that 97.5% of the commercial hook and line gear trips for pompano landed less than 200 lbs.
#6. THE FWC SHOULD INITIATE AND STRONGLY SUPPORT LEGISLATION INCREASING THE PENALTIES FOR MAJOR ILLEGAL NETTING VIOLATIONS TO A THIRD DEGREE FELONY. It is absurd and totally inequitable that a first time offense for “molesting” commercial crab traps is a felony, yet illegally gillnetting hundreds, or even thousands, of pounds of pompano is just a misdemeanor.
B. COMMENTS
We have stated at each FWC pompano hearing that if the FWC would simply control the illegal netting of pompano no actions would be needed to reduce take of the legal fishers. However, control of illegal netting remains an elusive task for the FWC and thus further restrictions are being placed on the legal recreational and commercial fishers.
Pompano are a high dollar fish and a lucrative target for illegal netters which, even if they are caught and successfully prosecuted, are subject only to a misdemeanor. The FWC should have supported proposals to increase major gillnetting violations from a misdemeanor to a felony.
An increase in the minimum size has historically proven to be a better resource management option, particularly at beginning stages of regulations, than bag or trip limits. For example, in sea trout the increase in minimum size increased the spawning stock size (resource benefit) and yields in the fishery (fisherman’s benefits). Additionally, the initial reductions in take are normally short term as the 10 inch fish simply grow to be 11 inches.
Release mortality resulting from increased minimum size should not be a problem with pompano which have a small mouth and are rarely “gut hooked.” Size selection is just as easy for the commercial hook & line fishers as it is for anglers.
CCA Florida opposes the reduction to 5 fish because we believe that 5 is too much of a reduction given the nature of the recreational fishery and the current biological status of the fishery. Most of the people we contacted preferred the increase in minimum size over the reduction to 5 fish. Most people felt that 10 fish may be too many; however, 5 fish was too low because pompano fishing is seasonal and sporadic. When the fish are there some would like to be able to take 6 or 7 fish.
The FWC staff report notes that there has been about a 350% increase in recreational take in recent years. The increase sounds impressive but it is primarily the result of mathematics and percentages resulting from the fact that recreational anglers caught so few fish before the net ban. Prior to the net ban, recreational take of pompano was only about 10% of the total take. That has changed substantially. Since the net ban, recreational take has risen to more than half of the total take.
Recent FWC stock assessments indicate that pompano are overfished and that commercial and recreational take must be reduced by 10 % in order to eliminate overfishing. On paper, the 11 inch minimum size would reduce recreational take by 9.5% and commercial take by 16%. However, those reductions in pounds / take would be short-term and as the fishery re-adjusts at the 11 inch minimum size the yields in both fisheries will increase. It is important to note that past fisheries management actions (gag grouper, snappers, etc.) clearly indicate that size limit increases always have a greater impact on recreational fishers. Additionally, it can clearly be argued that much of the 16% reduction in commercial take will be borne by the illegal fishery not the commercial hook & line fishery in state waters.
The issue and concern regarding size selectively and gillnet mesh sizes in directed federal waters fisheries is not a legitimate issue because, to date, only two net fishers have even demonstrated that they can gillnet pompano in federal waters.
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