My Letter to LDWF Commission on Tripletail Regulation
 

Below is a draft of my proposed letter to the LDWF Commission. Permission is granted for others to use in whole or in part for their own letters without any attribution to the original author. Permission is granted to use in whole or in part (without attribution) to develop talking points if you prefer to go to the meetings.


Jason Adriance
Fisheries Division
Department of Wildlife and Fisheries
Box 98000
Baton Rouge, LA 70898 9000

jadriance@wlf.la.gov

Dear Mr. Adriance and LDWF Commission,

Sportsmen's liberties in pursuing and harvesting game should only be restricted when there is sound and compelling scientific data demonstrating a true conservation need. Regulations should not be based on irrational fear that the resource might not remain for future generations; they should be based on sound scientific data showing the resource cannot be sustained for future generations under current management practices.

Sustainable harvests and use of the resources should always be allowed, and the burden of proof for those proposing new regulations should be on those proposing to impose new criminal penalties for liberties which have been previously enjoyed and unregulated. I see no wisdom in adopting restrictive regulations copying the example of neighboring states. Louisiana waters are generally less pressured and allow a more bountiful harvest than neighboring Gulf states. Whenever possible, Louisiana would do well to support the tourism industry and justify the expense of non-resident hunting and fishing licenses by maintaining more liberal harvest limits than other Gulf states. Our "Sportsman's Paridise" allows us to share our resources more liberally than other Gulf states.

There is simply no sound scientific data showing that maintaining current harvest levels of tripletail in Louisiana waters and offshore is not sustainable indefinitely into the future. The proposed regulations are Draconian and based in irrational fears. The Federal intrusion into the red snapper fishery is bad enough, but seizing the opportunity to fill coolers with abundant tripletail has salvaged more than a few charter and recreational trips offshore, making good use of an abundant resource.

Data justifying such a radical change in tripletail harvest regulations is sorely lacking. Do the SEAMAP ichthyoplankton surveys show a dramatic downturn in successful spawning in Louisiana waters over the past five or ten years (reduced larval counts)? Do other accepted approaches to comprehensive stock assessments show the tripletail stocks to be in imminent danger of collapse? Why should LDWF set such a dangerous precedence to impose drastic harvest restrictions based on political response to irrational fears rather than sound scientific data-driven policy making? Certainly, the legislature is Constitutionally empowered to make stupid laws in response to public pressure, but shouldn't the LDWF Commission be insulated against rash, politically motivated decision making and patiently require sound scientific support before exercising its regulatory powers?

An unpublished study suggesting a recapture rate of 2.5 times "other species" and a single published study (Brown-Peterson and Franks, 2001) describing the preliminary findings of length at 50% sexual maturity of 18" for females and 12" for males does not justify the proposed harvest restrictions of an 18" minimum limit and a bag limit of five fish. With so little known about tripletail life history and so little documented about the recapture study, it is likely that most tripletail have feeding and habitat preferences that leave them unvulnerable to capture in the first place and that only the specimens subject to capture once are strongly subject to recapture. Furthermore, until the length at age of each sex is independently determined, a harvest limit of 18" runs the risk of exerting most of the harvest pressure on breeding females and shifting the remaining population to male dominance. It should also be considered that the length limit of 18" will tend to force boats further offshore (the bigger fish are more commonly found further out) raising the costs of participating in this fishery.

The LDWF Commission should be working to enhance the quality of fisheries science in Louisiana and should strengthen its commitment to data driven policy making. When faced with political pressure increase the regulatory restrictions on recreational and commercial fishers, its response should be to educate the public in the need for better science before implementing policy changes that may be detrimental to the fishery and tourism industries.

Best Regards,

MathGeek
(real name and address to be used)

kudos to you man!

Brilliant!

Nice work man ! Too bad they will read the first sentence and send you some bs automated reply.

Very well said.

tl;dr









































j/k, that's pretty well put together with sound resoning behind it

Well put...

Very Nice, but I'm afraid it will fall on deaf ears, or in this case "blind eyes".

Because Will Drost said so that's why, Regards.

CC: will@towerlandllc.com

Atta boys are nice, but suggested improvements help more. In light of W's suggestion, I have added all the commission members as email recipients on my working draft.

jadriance@wlf.la.gov
ronnygraham@lincolnbuilders.com
bbillypb@kaplantel.net
annt@heraldguide.com
swsagrera@hotmail.com
patmanuel.wlf@gmail.com
will@towerlandllc.com
ddavis@marlin-services.net

I have also made the correction that the commission is properly the "Louisiana Wildlife and Fisheries Commission" not the "LDWF Commission."

Other recommendations?

Just a couple grammatical errors. Sorry to be a grammar nazi

I would move Paragraph #3 down to the bottom just above the last paragraph... I think by saying "There is no scientific data..." and then immediately asking question after question about the scientific data sounds a little condescending...

To me it sounds better to ask those questions in paragraph 4 and then in summary at the bottom say "There doesn't seem to be any scientific data..."

Grammar nazis are welcome when they save me embarrassment. Much appreciated.

A definite improvement. Thanks.

A couple of suggested changes shown below.

Lastest Draft
 

Here's the latest draft, incorporating the above suggestions.

Jason Adriance
Fisheries Division
Department of Wildlife and Fisheries
Box 98000
Baton Rouge, LA 70898 9000

jadriance@wlf.la.gov
ronnygraham@lincolnbuilders.com
bbillypb@kaplantel.net
annt@heraldguide.com
swsagrera@hotmail.com
patmanuel.wlf@gmail.com
will@towerlandllc.com
ddavis@marlin-services.net


Dear Mr. Adriance and LWF Commission,

Sportsmen's liberties in pursuing and harvesting game should only be restricted when there is sound and compelling scientific data demonstrating a true conservation need. Regulations should not be based on irrational fear that the resource might not remain for future generations; they should be based on sound scientific data showing the resource cannot be sustained for future generations under current management practices.

Sustainable harvests and use of the resources should always be allowed, and the burden of proof for those proposing new regulations should be on those proposing to impose criminal penalties for liberties which have been previously enjoyed and unregulated. I see no wisdom in adopting restrictive regulations copying the example of neighboring states. Louisiana waters are generally less pressured and allow a more bountiful harvest than neighboring Gulf states. Whenever possible, Louisiana would do well to support the tourism industry and justify the expense of non-resident hunting and fishing licenses by maintaining more liberal harvest limits than other Gulf states. Our "Sportsman's Paradise" allows us to share our resources more liberally.

Data justifying such a radical change in tripletail harvest regulations is sorely lacking. Do the SEAMAP ichthyoplankton surveys show a dramatic downturn in successful spawning in Louisiana waters over the past five or ten years (reduced larval counts)? Do other accepted approaches to comprehensive stock assessments show the tripletail stocks to be in imminent danger of collapse? Why should the LWF Commission set such a dangerous precedence to impose drastic harvest restrictions based on political response to irrational fears rather than sound scientific data-driven policy making? Certainly, the legislature is Constitutionally empowered to make stupid laws in response to public pressure, but shouldn't the LWF Commission be insulated against rash, politically motivated decision making and patiently require sound scientific support before exercising its regulatory powers?

An unpublished study suggesting a recapture rate of 2.5 times "other species" and a single published study (Brown-Peterson and Franks, 2001) describing the preliminary findings of length at 50% sexual maturity of 18" for females and 12" for males does not justify the harvest restrictions of an 18" minimum limit and a bag limit of five fish. With so little known about tripletail life history and so little documented about the recapture study, it is likely that most tripletail have feeding and habitat preferences that leave them invulnerable to capture in the first place and that only the specimens subject to capture once are strongly subject to recapture. Furthermore, until the length at age of each sex is independently determined, a harvest limit of 18" runs the risk of exerting most of the harvest pressure on breeding females and shifting the remaining population to male dominance. It should also be considered that the length limit of 18" will tend to force boats further offshore (the bigger fish are more commonly found further out) raising the costs of participating in this fishery.

There is not sufficient scientific data showing that maintaining current harvest levels of tripletail in Louisiana waters and offshore is not sustainable indefinitely into the future. The proposed regulations are draconian and based in irrational fears. The Federal intrusion into the red snapper fishery is bad enough, but seizing the opportunity to fill coolers with abundant tripletail has salvaged more than a few charter and recreational trips offshore, making good use of an abundant resource.

The LWF Commission should be working to enhance the quality of fisheries science in Louisiana and should strengthen its commitment to data driven policy making. When faced with political pressure increase the regulatory restrictions on recreational and commercial fishers, its response should be to educate the public in the need for better science before implementing policy changes that may be detrimental to the fishery and tourism industries.

Best Regards,

MathGeek, PhD

Here is my letter:

Dear Mr. Adriance and LWF Commission,

I wanted to address the recent letter of intent to impose an 18" minimum length and 5 fish creel limit on Tripletail fish for Louisiana recreational anglers.

First let me say that sustainable harvests and use of the resources should always be allowed, and the burden of proof for changing existing regulations should be on those proposing them. I do not see the point in limiting an abundant resource because of unsubstantiated/unpublished data and political pressure. These changes should ALWAYS be based on scientific data.

Unfortunately, data justifying such a radical change in tripletail harvest regulations is sorely lacking. The questions you need to be asking anyone proposing such a change are these:

1. Do the SEAMAP ichthyoplankton surveys show a dramatic downturn in successful spawning in Louisiana waters over the past five or ten years (reduced larval counts)?
2. Is there any data that shows tripletail stocks to be in imminent danger of collapse specifically from recreational anglers using a rod and reel?
3. Shouldn't the LWF Commission be cautious in imposing radical restrictions when there is little to no science to back up the decision?

After some comprehensive study looking for the answers to these questions, I have found that there is not any basis for the proposed change.
There just is not sufficient scientific data showing that maintaining current harvest levels of tripletail in Louisiana waters is not sustainable indefinitely into the future.
Remember, the burden of proof is on the person or persons proposing any change and the Commission should not take lightly their duties to demand any statistics given must be proven.

Based on the above information, I implore you to vote NO on the proposed letter of intent to change the Creel limits on Tripletail in Louisiana waters.

Thank you,
Reggie Himel
Louisiana Resident Lifetime Hunting & Fishing License #12345678
I am also submitting this on behalf of my 3 minor children which are also all Lifetime Hunting and Fishing License Holders

Awesome! Well done!

Mine is half way done


Im still collecting data from other sites to state my case

I'm gonna sound like a bit of a tool here... but


BRAVO... Mathgeek, Reggoh, and W if you get the other half of yours done... you to...

Way to not just ***** and do something... I am going to be proud to forward copies of this letter to the people noted, as well as others to start a movement to make this happen.

WELL DONE!