CCA FLORIDA DOES NOT SUPPORT ANY OF THE FWC PROPOSED CHANGES FOR REDFISH.  FLORIDA’S REDFISH MANAGEMENT PROGRAM HAS BEEN A HUGE SUCCESS UNDER THE CURRENT SET OF REGULATIONS.

 IT DOES NOT NEED ANY CHANGES!

A. COMMENTS

1. Florida’s redfish management plan has created a highly successful and economically valuable fishery. Creating North zones and increasing bag limits will place the entire management plan at risk.
   
   
2. In 1988, CCA Florida led the successful campaign to prohibit commercial sale. At the same time major new restrictions were approved for recreational take of redfish. Prohibiting commercial sale and the additional protection measures have resulted in major increases in size and abundance, making redfish one of Florida’s premier gamefish.
   
   
3. Currently the FWC’s resource management goal for redfish is 40 percent Escapement. In other fisheries the FWC has management goals of 40 percent SPR (spawning potential ratio) for snook, 35 percent SPR for spotted sea trout, and 35 percent SPR for mullet. The 40 percent escapement goal equals the percentage of redfish that grow to be adults and leave the inshore waters to join the offshore spawning stocks. Escapement is a goal that is comparable to SPR for the other species making the resource management goal for redfish similar to snook, Florida’s other premier gamefish.
   
   
4. The data from FWC stock assessments does not support an increase in redfish take. As shown in the FWC escapement charts (attachments) regarding escapement rates on the east and west coasts from the past assessments the escapement rate has been steadily declining over the last 20 years. At the same time, as shown on the FWC’s fishing effort graphic (attachment) the fishing effort on both coasts has steadily and dramatically increased. The west coast annual trips went from just under a half million trips to 2 million trips. The east coast trips went from about ¼ of a million trips to 2 million trips annually. It is clearly obvious that the long term upward trend in effort, coupled with any increase in bag limits will cause more rapid declines in escapement resulting in a failure to achieve the resource goals.
   
   
5. Increasing the bag limit to 2 fish will have a significant impact on take. Those anglers who catch and keep one legal redfish normally catch more legal size redfish on the same trip. Therefore the increase to 2 fish will double the take of redfish. The FWC staff has not included such effort increases in their decision making process. In addition, the ongoing federal waters closures and take restrictions on snapper and grouper is likely to divert some of that fishing effort to inshore state waters.
   
   
6. There is no biological evidence to support creating north and south zones on each coast. Genetic and tagging data indicates that the west coast is one stock of fish and the east coast is another stock of fish. The inshore juvenile stocks do mingle along the coast and the larger spawning adults migrate substantially along both coasts. Thus the proposed creation of north and south zones, with greater take in the north zones, would adversely impact the long term sustainability of the west and east coast stocks.
   
   
7. Such division of north and south causes the north areas to appear to have higher escapement. However; the southern zones will decline substantially. The SW and SE areas will have to have additional restrictions, including closed months, in order to stay close to the 40 percent escapement goal. The short term benefits to north zone anglers will be countered by major increases in restrictions in the southern zones. North zones will benefit while the south zones will be hit with greater restrictions. The Florida east coast escapement rate will be in non-compliance with the Atlantic States Marine Fisheries Commission’s redfish management requirement.
   
   
8. Florida’s conservation minded anglers are very supportive of the current management program. They do not want to endanger the great fishery that they have now. The FWC staff has held public hearings in Panama City, Tallahassee, and Cocoa. Thus far, none of the attendees at any of those hearings supported an increase in the bag limit.
   
   
9. Recreational anglers are being hammered by draconian federal regulations on snappers and groupers. Knowing that, the Commission may be trying to give something back to anglers instead of constant new restrictions. We appreciate what the Commission is trying to do; however, increasing the bag limit on redfish is not the way to do it. Spotted sea trout are currently closed in February in the NW region and November and December in all other regions. A new stock assessment will be completed in December 2010. The anticipated increases in sea trout abundance could allow for the elimination of some or all of the closed months. Opening those months provides increased opportunities for anglers and allows more sea trout to be taken. It is a much better option than placing the redfish plan at risk.

CLOSING COMMENTS
Redfish populations and redfish fishing have changed substantially since the low abundance periods in the early 1980’s. Redfish numbers have risen in numbers and size, and in angler interest, to be one of the most sought after gamefish on both the Gulf and Atlantic Coasts. As conservationists and as anglers we need to continue the protection and management measures for the long term health of this great gamefish and recreational fishery.Prepared by Ted Forsgren- CCA Florida Executive Director (850) 224-3474.