December 27, 2016
To Ms. Rena Glinton,
We write to you to provide comments on the proposed “FISHERIES RESOURCES (JURISDICTION AND CONSERVATION) (FLATS FISHING) REGULATIONS, 2016” dated October 17, 2016, as representatives of Bonefish & Tarpon Trust. As you know, BTT is an international, non-profit, membership-based, conservation organization with a strong record of contribution of scientific information to the Bahamas. We also write to represent those involved in the Bahamas Flats Fishery who have expressed concerns about the draft regulations. Many have signed this letter.
It is BTT’s assessment that the top threats to the long-term health of the bonefish fishery in the Bahamas are habitat loss, degradation, and illegal netting. This is not unique to the Bahamas – the same threats are impacting the bonefish fisheries in Belize, Mexico, Cuba, and Florida. Although the Draft Regulations address many management aspects of the fishery, there is no mention of flats habitat conservation and protection, which are essential components of a comprehensive regulation and conservation plan.
BTT has been working with the Bahamas National Trust, Cape Eleuthera Institute, College of the Bahamas, Fisheries Conservation Foundation, Abaco Fly Fishing Guides Association, and many lodges and guides for many years to identify the habitats upon which bonefish depend. The goal of this research is to provide information to Department of Marine Resources, BNT, and others so that they can prioritize areas for conservation and protection. This research has allowed us to identify bonefish feeding areas, spawning migration pathways, and spawning locations on many islands. The feeding areas directly support the fishery, whereas the spawning pathways and spawning locations are essential to the future of the fishery. It is essential to protect all of these habitats to ensure a healthy fishery. This is especially true of bonefish spawning locations, which are in deep water (> 6 feet) that will not be protected by protections of only flats habitats. Nassau grouper provide a cautionary tale on the importance of spawning site protections. Therefore, we hope habitat conservation is a core component of the overall conservation strategy.
We also work with our Bahamas collaborators to identify and address their concerns about the flats fishery. There are many different stakeholders, both foreign and domestic, that are directly and indirectly linked to the flats fishery in the Bahamas. There is broad agreement that there is a need for regulation of the flats fishery in order to ensure its continued sustainability. There is also broad agreement that much in the Draft Regulations are inappropriate and in many cases counterproductive to the long-term health of the fishery.
As defined in the Draft Regulations, the flats are areas of water 1-6’ in depth. This definition lacks the specific characteristics of the flats, and in turn defines all shorelines of the Bahamas as flats, which is incorrect. The flats can be defined as a shallow water environment, 0-6’ in depth with a long shallow grade. The flats environment is made up of a myriad different habitats that bonefish and many other economically and ecologically important species utilize; including mangroves, seagrass, sand flats, marls, channels, and mangrove creeks. Regardless of how flats are defined, however, Without habitat protection and enforcement of current laws, the flats environment is vulnerable to destructive development and illegal fishing that will be detrimental to the environment, the fishery, and the Bahamian people. The proposed regulations in many ways act to distract from the real threats to the fishery, thereby making the fishery even more vulnerable.
Guide training is important, especially when it comes to interacting with clients, safety on the water, and best handling practices for fish. Currently, all a guide needs is a class B captain’s license, and then they receive training from other experienced guides out on the water. In fact, many fishing lodges have training programs to ensure that the guides are all well qualified. It is in the best interest of lodges and of independent guides to provide a professional fishing experience.
In the current Draft Regulations it states that an “approved fly-fishing association” will be tasked with guide training and issuing a flats fishing guide certificate. This is contrary to what you presented to the angling community at ICAST. During the press conference you stated that fly-fishing associations along with NGO’s, and other stakeholder groups would be part of an advisory board to assist the Department of Marine Resources and Ministry of Tourism to develop the guide training curriculum. As BTT has suggested in the past, no private entity, such as an “approved fly-fishing association” should be in charge of guide training and certification guides. This leaves the door open for corruption and favoritism driven by political agendas that disregard conservation science. Government entities such as the Department of Marine Resources or Ministry of Tourism should oversee guide certification, with the focus being on good service, safety when out on the water, and best handling practices. Moreover, numerous international travel outfitters have conducted flats guide training programs, including the past work of Orvis in the Bahamas. There is much expertise available that would be excluded if a single, non-governmental entity is given full power to issue guide licenses.
BTT is happy to see that there is a single fishing license for flats fishing, prices have been reduced to nominal levels to match fees in other locations, and that the license will be easily accessible online to anglers. But, there are still concerns surrounding this that need to be addressed. A license that is purchased online prior to coming into the country traveling to the Bahamas should not require a visiting angler to have it stamped upon arrival in the Bahamas. The potential for problems with this system is very high. What about anglers who purchase an online license while already in the Bahamas, would they have to get theirs stamped as well? Given limited personnel at some ports of entry in the Bahamas, will there be enough certified officers at these ports of entry to stamp licenses? Only a fisheries officer and other law enforcement should be able to check anglers for fishing licenses, which is common practice in other jurisdictions. To our knowledge, no US state or other bonefish fishing location has such a procedure, instead requiring only personal information and the required fee.
In the license application form there are two options for purpose of application, one for sports fishing and the other for research. How will the permit (license) application process impact bonefish research? Our research is already conducted under a permit from Fisheries, but it is unclear if the proposed regulations will supersede the Fisheries research permit. This is of concern since bonefish are captured for tagging research using both seine nets and hook and line, by scientists and in partnership with guides.
As you know, an economic report published in 2010 by BTT, Bahamas National Trust, and Fisheries Conservation Foundation found that the annual economic impact of the recreational bonefish fishery exceeded $141 million, with the greatest relative impacts in the Family Islands. Further, the cultural importance of the fishery on the Family Islands is reflected by the occurrence of the family relations of bonefish guides – an occupation proudly passed from fathers to sons, among brothers and cousins. The report also showed that anglers that travel from the United States, Canada, and Europe to fish for bonefish in the Bahamas contribute to the Bahamas economy in multiple ways. Many anglers stay at fishing lodges, where their expenditures support guides and lodge staff. Other anglers stay at hotels and guest houses, where their expenditures support the local communities where they stay. Others have second homes in the Bahamas. These anglers might fish with a guide or fish on their own (known as Do-It-Yourself, DIY). Moreover, these anglers spend more money per visitor night and more money per total visit than non-angler tourists.
DIY anglers contribute a significant amount to the Bahamian economy. In addition, many DIY anglers are second home-owners or own a private yacht, who either like to wade the flats or fish from a personal boat. Requiring a ratio of one “certified guide” to every two anglers if they are fishing from a boat is unnecessary. This would prohibit friends and family from fishing together, unless they hire a guide. For many of these anglers, being able to fish on their own and figure out the fishery for themselves is one of the main attractions that brought them to the Bahamas, and is why they contribute to the Bahamas economy by purchasing second homes or spending money for hotels, food, etc. No other country in the region requires people who have a boat to hire a guide.
While we are pleased that 50% of fishing license fees will be deposited in a Conservation Fund, it is unclear how these funds will be allocated and who determines this allocation. Surveys of anglers who fish in the Bahamas show strong support for a fishing license as long as the fees are applied to flats conservation and enforcement. Therefore, we suggest that an advisory committee comprised of guides, lodge owners, and NGOs is created to determine how conservation funds are spent.
On the topic of catch and release and the permission to possess one fish per person, it is unclear whether this is one fish total or one fish per species.
In recent years, the Bahamas has made good progress in flats conservation, including the declaration of new national parks that will protect important bonefish habitats. This not only benefits the flats fishery through habitat conservation, it also helps in the very competitive international tourism market. Flats anglers prefer to fish in locations that practice strong conservation. Unfortunately, the negative press that the Draft Regulations will cause will greatly offset the benefits that the habitat protections have brought to the Bahamas. With increasing competition for anglers coming from Cuba, Belize, Mexico, and Florida, the negative impacts of poorly constructed regulations should be considered.
Thank you for considering of our comments. As always, please consider BTT an information resource for bonefish and flats conservation efforts. Please don’t hesitate to contact us with any questions or concerns.CC: Rt. Hon. Perry G. Christie, Prime Minister of the Bahamas Hon. V. Alfred Gray, Minister for Agriculture and Marine Resources Micheal Braynen, Director of Fisheries Benjamin Pratt, Senior Manager at Bahamas Ministry of Tourism
Sincerely, Justin Lewis, MSc. Bahamas Initiative Manager, BTT Aaron Adams, Ph.D. Director of Science and Conservation, BTT Rob Neher East End Lodge Peter Mantle Delphi Club Oliver White
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