Our Florida Reefs
c/o Francisco Pagan, Ph.D
Manager, FDEP Coral Reef Conservation Program
Florida Coastal Office
1277 NE 79th Street/JFK Causeway
Miami, FL 33138-4206

Dear Mr. Pagan:

Coastal Conservation Association (CCA) supports healthy fisheries and habitat, including our coral reefs. When appropriate, CCA has supported a number of spawning season area closures in the South Atlantic and the Gulf of Mexico. CCA has an active habitat restoration and artificial reefs placement program. CCA's mission is focused on scientific approaches to sound fisheries management for present and future generations to enjoy the resource. Within these parameters, CCA supports angler access.

First, Recommended Management Action (RMA) N-146 proposes up to 24 marine protected areas (MPAs) that in some cases will ban fishing over 20% to 30% of the reef tract from the northern boundary of Martin County to the southern boundary of Dade County. CCA does not support the establishment of MPAs unless, they are scientifically based, have stated goals and that MPAs are the last resort. CCA does not support using MPAs as a first stage management tool. While CCA is opposed to implementing no take/no fishing zones or Sanctuaries, CCA would ask that fisheries managers consider protecting spawning aggregations by limited time and area closures if warranted by stock assessments and good fisheries management practices.

Second, RMA S-65 seeks to create a National Marine Sanctuary for the entire Southeast Florida reef tract. This is an unnecessary delegation of state authority over its sovereign waters to a Federal agency. The state has an excellent record of managing its fisheries and resources. The sanctuary process is cumbersome and there are existing procedures for state action when needed.

CCA can support the RMAs relating to Land Based Sources of Pollution. CCA strongly supports N-69 and S-28 as the discharges to our estuaries must be stopped and the natural flow of fresh water to the south is needed. The mechanisms for moving the water south involve complex intergovernmental relationships and need a dependable source of immediate funding. The impacts of local storm water, sources of population and over fertilization are also major problems.

CCA also commends the working group as it also came up with a number of good management tools, like N-137 protecting the reefs by limiting damage from anchoring by large vessels in areas designated as Particularly Sensitive Areas or Areas to be Avoided. This would discourage or possibly prohibit large commercial vessels form anchoring in these areas. Likewise, if implemented correctly, the use of mooring balls for divers and recreational fisherman would create less disturbance to our reefs.


A potentially positive recommendation with unintended negative consequences is N-7. N-7 proposes to offer a reduction in licensure fees for those that take an online class regarding reef protection and boating; it would be optional for those over 16 years of age and mandatory for those under 16 years old. The establishment of an optional online education course for boaters is acceptable as long as it did not affect the funding of the FWC. CCA is concerned that if a reduction of licensure fees were imposed, the funds earmarked to protect and manage our fisheries would be reduced and would negatively impact the very resources the RMA was intended to help. Further. The age criteria of this RMA ignores the fact that children under 16 are not required to purchase a saltwater fishing license.

CCA opposes N-59 as it seeks to ban spearfishing for divers using SCUBA. This is a gear restriction which is within the type of restrictions considered by the FWC in its regulations. CCA is unaware of any specific problems caused by this gear. Similarly, CCA opposes N-64, S-97 (Lobster mini season bag reduction) and S-87( Parrot fish take).

Recommendation S-54 seeks UNESCO designation for the reef tract. CCA does not oppose recognition of our resources, but opposes any such designation that would restrict access or uses.
Those decisions are best left to the FWC and Florida law.

CCA is also concerned with the process used. The OFR meetings were weekday meetings and the comment process by commuter or separate comment card for each RMA may be efficient for OFR, but is cumbersome for the users, especially those that may not have good computer skills.

Thank you for allowing CCA to comment. Our overarching concern is the insertion of another bureaucracy or layer of government in areas where the State of Florida has an excellent track record or the establishment of no fishing zones where other proven methods of fisheries management have not been tried.


Paul Giordano