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An unpublished study suggesting a recapture rate of 2.5 times "other species" and a single published study (Brown-Peterson and Franks, 2001) describing the preliminary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