November 17, 2006
Patrick Schmalz
Bureau of Fisheries Management and Habitat Protection
P.O. Box 7921
Madison, WI 53707
Dear Mr. Schmalz:
On behalf or our 10,866 members in Wisconsin, I would like to thank you and the Natural Resources Board for your efforts to protect and enhance the natural resources of the state. However, we are seriously concerned with the proposed changes to Wisconsin Administrative Code NR 20.40, as it pertains to tournament regulations.
Specifically, prohibiting live-release from July 1st through August 31st does nothing to help the resource. Even if mortality is relatively high (which it should not be with the proper education for tournament organizers and participants), at least some fish survive. With the proposed regulation, you are mandating 100% mortality. There is no biological evidence anywhere that indicates this practice would benefit the resource. A better approach would be to encourage tournament participants to make use of fish that may succumb to mortality, just as non-tournament anglers do when they elect to harvest the resource. They each have an equal right to pursue and harvest those fish. They should also have an equal right to release those fish to be caught another day. One group should not be dictated to kill their catch, while others can still release theirs.
Next, having been a former state biologist in charge of data collection and analysis from bass tournament organizations, I seriously doubt that the program costs would be $76,000 annually. Not only do the proposed tournament fees attempt to fund the program at that level each year, but they also collect additional fees to cover the cost of the pilot program ($90,000). After the cost of the pilot program is recovered, will the tournament fees go down? If not, where will the excess money go? Since this is essentially a “tax” on tournament participants, then we would argue that those funds need to be returned to the participants in the form of improved access areas, expanded parking at popular tournament sites, state-of-the-art weigh in facilities, etc.
In addition, since the tournament anglers are essentially paying twice (once with license fees/excise taxes and now with tournament fees) for routine data collection, each participant should receive an annual report giving the statistics for the previous year. Statistics on the lake/river with the most number of bass over 5 lbs, average catch per angler, average weight per fish weighed, etc. This gives the anglers some guidance on the best places to fish the following year, and it is a simple, added benefit for the money they invest in your program.
We also have a problem with the tournament organization being required to file an aquatic invasive species plan (AIS). Unless the WI DNR will require EVERY boater in WI to have similar procedures, this is an unjust regulation. Tournament officials could be required to recommend boat/trailer cleaning and disinfection, but to make it mandatory for a very small group of users and not all boaters is neither fair nor acceptable. Unless every vessel is similarly treated, this regulation will do nothing to prevent the spread, while placing one more stringent requirement on tournaments. This regulation deals with perception and not biological reality.
Furthermore, the attempt to recover the costs of enforcement of the regulations on the water and at the permitted events is an additional, unjustified burden on tournament participants. Enforcement offers are already paid (by anglers, including tournament anglers) to enforce Wisconsin code, and should treat the tournament participants no differently than any angler on state waters. It is their responsibility to enforce all fishing and boating regulations without discrimination.
Finally, to say that the new regulations would have no impact on local businesses demonstrates that the DNR Board does not adequately understand the ramifications of their decision on the Wisconsin economy. The University of Wisconsin found that one major tournament (BASS Elite 50 on Lake Wissota) generated over $2 million in economic output in the area. BASS/ESPN Outdoors will not hold a tournament where we are required to kill the catch. It simply goes against our principles of conservation and doing our best to leave the resource just as we found it. How would deterring large tournament organizations from visiting Wisconsin not have a significant impact on local economies?
These stringent regulations taken as a whole leave the perception that the Wisconsin DNR does not welcome tournaments in your state. If these regulations go into effect, you can expect to see a decline in tournament participation, especially from larger organizations, which will translate into lost revenues for local communities and the state.
In reality, tournament anglers are just fishermen who want to compare their catch, then release them to be caught another day. They are not taking anything away from the resource. Tournament anglers could legally harvest every fish they catch within the daily creel, just like the non-tournament anglers often do, but they do not because they, more so than most, want to conserve the resource.
We cannot support the currently proposed changes to Wisconsin Administrative Code NR 20.40.
Sincerely,
Chris Horton
Associate Director, Conservation
BASS
P.O. Box 10000 • Lake Buena Vista, FL 32830
407-566-BASS • Fax 407-566-2072
[email protected]
