The Coastal Conservation Association-FL (“CCA”) is pleased to submit its comments to the Supplement Draft General Management Plan and specifically to the Preferred Alternative, the Alternative 6. CCA has been involved in this process for over ten (10) years and its local members have actively participated in the process. Many of CCA’s members have been lifelong users of the park and were active in this process. It is from that background that these comments are made.

CCA was formed to advise and educate the public on the conservation of marine resources and its objective is to conserve, promote, and enhance the present and future availability of those coastal resources for the benefit and enjoyment of the general public. CCA is the largest organization of its kind in the United States and has over 100,000 members with almost 10,000 located in the State of Florida. Many of CCA’s members, both local and from other states enjoy fishing in Florida and especially in the waters of Biscayne National Park.

Recreational fishing in Florida is a multi-billion dollar industry and its value to the State exceeds that of citrus. Recreational fishing not only is a significant economic engine, but it provides good wholesome activities for families and people of all backgrounds. Its social impact can’t be underestimated. The Park is situated in the sportfishing and arguably the boating capital of America.

 

CCA has reviewed the two new alternatives in the Supplement Draft General Management Plan and in particular Alert Supplement Draft General Management Plan Alternative 6. CCA appreciates the efforts of the Park Service in revising the prior draft plan to include these two new alternatives. As you should know CCA and others in the fishing and boating community strongly opposed four (4) of the five (5) alternatives in the initial
Draft of the Biscayne General Management Plan, especially the large marine reserve/Marine Protected Areas and Pole Troll/No Combustion Engines Zones as they were little more than defacto no fishing/no access zones. CCA strongly believed then as it does now, that less oppressive management measures should be used before anglers are effectively locked out of Biscayne National Park. Those prior comments stand as to Alternatives 2-5 and those alternatives are not addressed herein.

CCA is encouraged that those large objectionable reserves and no motor zones were removed from the new Preferred Alternative. CCA understands that the new alternatives are as a result of the Park Service’s
inclusion of many of the comments that have been made by the anglers and boaters that voiced their views at the comment sessions and in writing. CCA also applauds the efforts of the Florida Fish and Wildlife Conservation Commission (“FWC”). The fact that the FWC has been involved in this process gives credibility to the new Preferred Alternative.

CCA supports the general concepts that are presented in Alternative 6, but suggests certain modifications and revisions. CCA reminds the Park Service that America’s anglers and boater are truly conservationists at heart and simply are asking for reasonable usage of this special marine park. The several concepts in the Preferred Alternative are discussed below.

SPECIAL RECREATION ZONE
The use of a Special Recreation Zone (“SRZ”) within the park seems to be an attempt to adapt concepts that have been used in terrestrial parks with some success. The area proposed for the SRZ consists of a large
and popular reef tract. CCA urges the Park Service to modify the proposed permit process to allow for additional permits beyond the 500 that Alternative 6 suggests as it is CCA’s understanding that the snapper population will support some additional take. CCA also notes that the grouper population is subject to significant seasonal variation, with significantly more grouper coming onto the reef area in the winter and fewer being found on the reef in the summer. Adaptive Management should consider these seasonal variations and should in the short term consider allowing some seasonal take of grouper.

CCA also requests that short term, daily, weekly or seasonal permits should be available. This would allow seasonal visitors to have access to this area during the time they visit our state; this will reduce the potential negative economic impact to those communities in the Park’s immediate vicinity. These permits could be available electronically using a system similar to that used by the FWC in its quota hunt permit system. It may be that a number of annual permits could be available for guides and those who live near the Park or that visit it frequently. Those annual permits should have a “use it or lose it” condition which would make sure that those who seek annual permits actually use the permit and provide the Park and FWC with the necessary data. The limitation on the number or term of these SRZ permits could lead to the denial of access.

The permit application and data collecting segment of the SRZ should use technology such as smart phone apps and web page submission. Such a system could allow not only for data collection, but also send updates and useful information to the Park’s users. This could help with seasonal closures and regulatory updates. CCA also understand that a significant percentage of the fish captured on creel surveys are under-sized. Better education to the permitted users and stronger law enforcement will help reduce the take of under-sized fish.

CCA opposes the proposed prohibition on anchoring with the SRZ. The number of mooring buoys must be able to accommodate the needs of the Park’s users. The combination of the limited number of mooring buoys
and a prohibition on anchoring is a defacto closure or limitation on access. CCA recognizes the need to limit damage to the reef and suggests that the anchoring prohibition be considered as part of the Adaptive Management process and phased in as mooring buoys are put in place. Recently the State has recognized the value of mooring buoys and has statutes in place to begin the installation of mooring buoys in certain areas. The Park Service should work with its state partners and users to secure funding for mooring buoys. The proper use of technology in the permit process would allow the Park to educate the SRZ’s users on properly anchoring techniques and avoidance of anchoring on the reef.

The SRZ must make accommodation for those anglers and spearfishers that have traditionally transitedthrough the Park on their return from fishing or diving beyond the Park Boundaries. Many of those anglers and
spearfishers may have in their possession grouper or other fish that were legally taken in water outside of the Park and might not be allowed within the SRZ. A “direct and unabated” transit rule is necessary.

The Permits for the SRZ should be issued to individual anglers and not to specific vessels. The permit should allow cover the vessel in use by that permittee. To attach the permit to the vessel would be cumbersome
and if issued to a natural person, that person would be required to have photo identification available if stopped.

POLE AND TROLL ZONES
CCA also suggests that the Park Service as part of the initial implementation of the other restrictive zones in the Park (i.e Pole Troll Zones) allow for additional participation from the FWC and comment from recreational anglers. Large Pole and Troll Zones also limit access especially in the Park’s waters as they are influence by tides and wind. The Park service should limit the distance that anglers are required to pole or use trolling motors. An acceptable alternative would be allowing idle or slow speed with the engine trimmed up. The SRZ and these other zones should have defined objectives as part of the initial implementation and as periodic adaptive management occurs.

FISHERIES MANAGEMENT
CCA believes that fisheries managers, such as the FWC and the South Atlantic Fishery Management Council are best suited to consider and regulate fisheries. The Parks GMP should not be a vehicle for fisheries management and those decisions are best left to the FWC and SAFMC. CCA strongly urges the Park Service to adopt the least restrictive of the available alternatives when engaging in the implementation of the SRZ and
other zones established in the GMP and when it begins the Adaptive Management process.

The take by spear of invasive species such as Lionfish should be allowed within the SRZ. If the Park Service is inclined to prohibit the take of other fish by spear, there should be an exemption for the spearing of Lionfish.

Lastly, CCA is generally aware of the comments that have been advanced by the FWC and supports those comments. CCA also encourages the Park Service to continue its consultation with the FWC and users groups like CCA, NMMA and ASA as it begins to implement the Preferred Alternative and as it engages in Adaptive Management.

Sincerely,
Brian Gorsky
Executive Director
CCA Forida