PRIORITY: TIME CRITICAL
Your comments on a Proposed Ban on Spearfishing in Southeast Florida While Using Scuba are URGENTLY NEEDED.
DEMA requests all members of the Florida diving community submit written comments to the Florida Department of Environmental Protection BEFORE FEBRUARY 16, 2016 on a proposed ban on spear fishing while using scuba in the SE Florida counties of Dade, Broward, Palm Beach and Martin.
DEMA is concerned that this ban is being proposed WITHOUT scientific data that indicate such a ban is warranted. Further, DEMA is concerned that these proposed restrictions are aimed solely at DIVING, and EXCLUDE RECREATIONAL AND COMMERCIAL FISHING, both of which have a much greater impact on fish populations than spearfishing while on scuba.
DEMA FAVORS CONSERVATION REGULATIONS WHICH IMPACT ALL SECTORS
WHEN SCIENCE INDICATES SUCH REGULATIONS ARE WARRANTED.
It is important to note that DEMA supports conservation of fish species when scientific research indicates the need to do so. However, we also believe that when science calls for such harvest restrictions, ALL means of harvest should be subject to those restrictions, including recreational fishing and commercial fishing. This proposed ban is focused SOLELY on spear fishing while using scuba, and excludes any mention of limitations on hook-and-line recreational fishing or commercial fishing.
THE FOLLOWING ARE DEMA’S CONCERNS WITH THESE RECOMMENDED MANAGEMENT ACTIONS:
1. THIS ACTION IS BEING PROPOSED WITHOUT SCIENTIFIC DATA TO SUPPORT SUCH A BAN. Although theRecommended Management Action (RMA) cites many publications to support its proposal for banning spearfishing on scuba, the RMA also acknowledges that there are “Information Gaps.” Specifically the RMA states that, “The relative number of fish taken by spear versus angling is unknown, as is the total magnitude of fish taken by spear. It is a cryptic fishery.”
2. ANY BAN ON SPEAR FISHING MUST ALSO INCLUDE SIMILAR RESTRICTIONS ON COMMERCIAL AND RECREATIONAL FISHING. Florida already has many fishing regulations in place which regulate seasonality as well as size and quantity limits, which appropriately impact all forms of fishing; commercial fishing, recreational fishing AND spearfishing. Absent ANY DATA that specifically points to spearfishing as having a greater impact on supposedly “highly targeted species,” DEMA contends that these current limits and laws are adequate to prevent any “targeting of commercially valuable and ecologically important ‘trophy’ fish.” Further, if additional regulations are needed for spearfishing on scuba, surely these same restrictions are warranted for ALL forms of extraction, including commercial fishing and hook-and-line recreational fishing.
FOR THE REASONS STATED, DEMA OPPOSES THIS PROPOSED BAN. Should such a ban be enacted, there is significant risk that similar bans could be proposed in other Florida counties. It is therefore important for ALL Florida dive businesses to participate in this comment period.
Our Florida Reefs will hold a series of community meetings around South Florida between now and February 17 to discuss this and other proposed regulations. DEMA urges members of the diving community to attend these meetings and voice your opposition to this proposed ban, which unfairly singles out the diving community. Two meetings will be held on each of the scheduled days, the first from noon to 2 p.m. and the second from 6 to 8 p.m. Meetings are being held in Broward, Palm Beach, Palm Beach Gardens, Delray, and Fort Lauderdale.
DEMA STRONGLY URGES ALL FLORIDA DIVERS AND ALL FLORIDA DIVE PROFESSIONALS TO SUBMIT THEIR WRITTEN COMMENTS ON THIS PROPOSED BAN HERE. Written comments will carry more weight than comments made during the scheduled meetings.
Your written comments should include:
· Your business location.
· The amount of revenue generated by this activity and the losses if this ban is put into place.
· Emphasis about the lack of data to support such a highly focused ban on this activity.
· Concerns about singling out spear fishing on scuba without consideration for similar limitations being placed on commercial and recreational fishing.
Finally, OFR is also proposing many other actions that will impact the diving business in Florida. With theseadditional proposals already under consideration, please be prepared to comment on them in writing and during face-to-face meetings. For example, a proposal is being made to change the limits on the number of lobster taken during Florida lobster mini-season. In this instance, be prepared to provide comments on the number of divers coming to your business to participate in this activity.