I urge you to contact RIDEM...my letter as follows:
December 22, 2011
Janet Coit, Director
RI Dept. of Environmental Management
235 Promenade St.
Providence, RI 02908
RE: RIDEM Fisheries regulation 1.17
Dear Director Coit:
I wish to express my concern with the implementation of the above regulation prohibiting the use of felt soled wading shoes in RI waters, effective January 1, 2012.
There seems to have been little or no advance notice of this regulation which affects a large segment of the licensed fishermen and women who wade in Rhode Island waters. In fact, leaders of some of RI’s largest groups representing sport fishermen, when contacted, knew nothing about the regulation scheduled to go into effect in a week’s time.
In researching this issue, only three states, as of this date, have implemented such a ban. In those cases, confirmation of aquatic invasives, namely didymo, have been confirmed in their waters. I’m not aware of any confirmation of same in RI waters, certainly not in saltwater. Many of these states took a pro-active approach to educating and advising their fishing public before implementing their regulations as did Maryland:
" Back in 2009, the Department started placing Wader Washer Stations around areas where they had located Didymo in state waters. After further monitoring and concern of spreading Didymo and other invasive organisms and diseases, the Department began scoping the idea of a felt-soled wader/boot ban in March 2010. The Department discussed this at its non-tidal public meetings throughout the spring of 2010 and scoped the idea at its May 2010 Fisheries Service regulatory scoping meeting. Additionally, the Department posted this idea up on its draft regulations webpage in May 2010 and took emailed comments on this idea until it was proposed in December 2010. The idea was scoped a second time at the September 2010 Fisheries Service regulatory scoping meeting. Throughout the summer and fall of 2010, the Department sent information about the idea of a ban to stakeholders, put posters at sporting shows and fairs and worked with the media to get out information. Once the regulation was proposed, the Department held a public hearing in Cumberland, Maryland in January 2011 and took nearly 44 days worth of public comment (approximately 2 weeks longer than required by law). During the public comment time period, the Department again reached out to the media to help disseminate information. The Department will also be handing out information cards throughout 2011."
I’m not aware of a public comment period on the RI regulation, nor any serious effort to educate the fishing public about the spread of invasives, aside from posters directed to the boating public at state boat ramps.
As an individual, concerned about these environmental issues, I and others have taken steps through my blogsite, http://team7x.com, to make fishermen aware of the need to properly care for wading gear by placing signage at popular locations in the Eastern Connecticut area, where I am also licensed. Nothing that I can immediately reference on the RIDEM website seems to be directed toward this education effort.
Further, the ban on felt in saltwater cannot be supported by any reasonable means. The state of Missouri for instance recommends cleaning of wading gear by using salt water as follows:
"So the conservation department built wash stations at four of the trout parks in Missouri, so anglers can wash off before and after fishing to make sure no algae is on their waders.
"You just simply step down into the salt water solution. There is a brush that's attached to the hand rails that you can scrub your waders down with. You should also check to make sure you don't have any vegetation, algae, or whatever on your waders,” Van Patten said. “If you do just remove it in the cleaning station."
The large majority of anglers who wade in RI waters with any frequency own and rely on felt soled wading shoes for safety. If properly disinfected, which I find many of my fishing acquaintances do after leaving the water, the spread of any KNOWN aquatic invasive is minimized. Again, to my knowledge no KNOWN invasive has been identified in our waters.
To require many of our licensed anglers to now purchase wading boots without felt to comply with what is to become a regulation in a few days, is financially burdensome.
I would respectfully ask that you suspend implementation of this regulation until the fishing public and stakeholders have an opportunity to become aware of the issue of aquatic invasives and the pros and cons of this issue can be weighed in public.