Dear All,
Please find attached the latest draft of recommendations for protection of sport fish and sport fish habitat in Belize. This paper is a results of the inputs from the different consultation meetings we conducted in October. Please feel free to make any comments to the document. The plan is to present these key recommendations to the ministers.

Mito, Green Reef






The following presentation summarizes potential development threats and impacts on Belize´s sport fish populations (specifically the country´s bonefish, permit and tarpon stocks) and the rationale behind the key legislative actions urgently recommended to prevent the Sport Fish from being extirpated from Belize. The recommended actions represent a consensus amongst local NGO's, sport fishing guides and Fishing Lodges, as well as many members of the fishing community and other stakeholders working in the marine sector of Belize.

Bonefish were first legally protected in 1977 under the Fisheries Regulations, Statutory Instrument 66 of 1977. Thirty-two years later, in 2009, the Fisheries (Sport fish) Regulations, Statutory Instrument 114 of 2009 was legislated to specifically address the management and conservation of the three major sport fish (bonefish, tarpon & permit) in Belize. All three species are also somewhat protected through the network of marine protected areas. Unfortunately, the country's marine protected areas program does not specifically include conservation of tarpon, bonefish and permit. Given the critical economic and biological resources the sport fishery brings to Belize, the conservation and sport fishing industry of the country recommends that marine protected area (MPA) coverage include sport fish distributions to insure that sport fish habitats are not ruined by inadequate protection from unmanaged development or extraction. Protected areas, although valuable, are only part of a larger resource conservation plan that is needed in Belize.

Threat: Habitat Degradation

The primary sport fish habitats threatened in Belize are mangroves, wetlands, sandy beaches, sea grass beds, coral reefs and sand and mud flats. These habitats support juvenile through adult life stages of the three legally protected sport fish.

Habitat degradation for sport fish arises primarily from pollution, destructive fishing practices and unsustainable coastal and caye development.

Pollution: Pollution from land and sea including sewage, fertilizers, chemicals, oil, and sediments harm juvenile fish, kills prey and destroys habitats for these species such as sea grass, mangroves and corals. Plus, many of the chemicals used in pesticides that enter the sea and coastal lagoons can change the reproductive cycles of sport fish, causing them to be sterile.

Destructive Fishing Practices: Fishing gear such as gill nets and fish traps are highly destructive to fish populations and have been outlawed in many countries but are still used in Belize.

Gill nets kill all ages of fish and their prey, so directly threaten sport fish populations and fisheries. They are often illegally set in marine reserves, creeks, lagoons, river mouths and within 100 yards of the Barrier Reef. Local fishermen also report instances in which gill nets have wiped out entire schools of permit, bonefish and juvenile tarpon. Further, nets often break away from their anchors and drift along the sea-bottom causing even more damage, and snaring yet more fish, doomed to die, wasted.

Unsustainable Coastal Development: Dredging, mangrove removal, seagrass destruction and sales or leases of sub-tidal sand flats are examples of unsustainable coastal development practices that destroy important habitats used by juvenile and adult sport fish for foraging and reproduction.

For example, Big and Little Channel Cayes in the Pelican Range of the Southwater Marine Reserve, are within an area internationally known to saltwater fly fishing guides and anglers as Permit Heaven. This area includes corals, mangroves and seagrass beds adjacent to one another -"a happy environmental circumstance that is one of the richest habitats in the world for fish and other marine life." (Final Report F-7: Near shore Habitats as Nursery Grounds for Recreationally Important Fishes, St. Croix, U.S. Virgin Islands. October 1, 2000 to September 30, 2001). In more technical terms, this is known as a habitat mosaic - a spatially diverse mixture of habitats. This mixture of habitats is essential to supporting multiple life stages of these sportfish and their prey. Development that destroys or degrades some or all of these habitats has implications far beyond the immediate impacted habitats. The proposed Chrysalis Resort Project planned for Big and Little Channel Cayes will destroy critical fish habitat in the area through dredging of corals and sea grass beds and mangrove removal if the development is allowed to proceed.

Dredging at Rendezvous Caye off the Placencia coast has already destroyed one of the best tarpon fishing grounds in southern Belize. Similarly, dredging at Ropewalk Caye has destroyed the best permit flat in Turneffe Atoll. In northern Belize, the Government of Belize sold several sand flats critical for the sport fishing industry to private investors. The impacts of such habitat loss are not only local and short term. The loss of these critical habitats will impact the fishery forever. In general, the population size of sportfish and others is limited by the amount and quality of available and suitable habitat. As habitat is lost, the long-term size and health of the populations are impacted.

Mangrove ecosystems are a crucial part of the Belize Barrier Reef Complex. The Water Center for the Humid Tropics of Latin America and the Caribbean (CATHALAC) study, "Identification of Threatened and Resilient Mangroves in the Belize Barrier Reef System," found that Belize's national mangrove cover declined from 76,250 to 74,684 hectares during 1980-2010. Belize's mangroves have been protected since 1989 under the country's Forests Act, which requires legal permission for altering areas with mangroves. The clearing of some 1,566 hectares of mangrove from 1980-2010 translated to an average loss of 53.6 hectares per year. An analysis of the 'hotspots' of clearing showed that almost 90% of all mangrove clearings occurred in four zones near major coastal settlements: Belize City, the Placencia peninsula, San Pedro Town, and Dangriga. Destruction of mangroves - largely for the development of urban- and tourism-related infrastructure - was also found to have caused the fragmentation of 2.1% of the country's mangrove ecosystems. Since mangroves provide habitat for at least one life stage of most coastal fishes, this loss of mangrove habitats has wide-ranging impacts.

Aquaculture and agricultural run-off, extensive dredging and mangrove removal around the Placencia Lagoon, important habitat for many of the fish caught off the Placencia coast, including permit, tarpon and bonefish, have caused alarming drops in water quality, loss of sea grass beds and shallow water habitat for all life stages of fish, especially juveniles.

Economic Justification

In Belize, there are at least 13 fishing lodges that offer fishing packages and over 100 independent fishing guides that cater to recreational anglers. A recent study conducted by Fedler & Hayes (2008) conservatively estimated that sport fishing for these three species in Belize generates gross annual revenue of BZD $56 million, creating BZD $30 million in annual wages that support 1,800 full-time jobs for Belizeans, and generating $2.7 million in taxes for the Government of Belize. Anglers who travel to fish for bonefish, tarpon, and permit tend to spend more time and more money than other tourists. Moreover, recreational fishing guides are among the highest wage earners in the private sector of Belize.

Further, virtually all bonefish, permit and tarpon caught by sport fishermen in Belize are released back to the sea alive making this annual economic contribution fully sustainable. With adequate management of the fishery and habitats, it is therefore quite realistic to suggest that sport fishing for bonefish, permit and tarpon will generate an economic impact of roughly $600 million for Belize over the next decade.

Management Options:

Sport fish management efforts should protect juvenile fish, and the breeding and survival of adult fish stocks as well as the habitats that juvenile and adult species depend on. We have identified six (6) key management options that will slow or prevent the further decline and possible extinction of protected sport fish from Belize. These may be summarized as follows:

1. Ban on the sale and development of shoals and sand flats- This option will protect critical sport fish habitats from being destroyed. Critical habitats including shoals, bajos, pancake flats, and sand flats should be legislated as protected status to prohibit sale and development.
2. Ban dredging of sand flats, coral flats, seagrass beds, wetlands and mangroves- This option will protect critical habitat from being destroyed.
3. Integration of critical habitats into the National Coastal Zone Plan or the proposed Ecosystem Management Act- This option will protect critical sport fish habitats including sand flats, pancake flats, mangroves, creeks, lagoons, seagrass beds, wetlands used by juvenile and adult sport fish for foraging and recruitment.
4. Ban gill nets, the importation of gill nets and gill net fishing throughout Belize - This is the most crucial action required to reduce fishing mortality of all sizes of sport fish. The use of gill nets in Belize waters is the cause for most of the mortality of juvenile and adult sport fish and other protected species.
5. Phase out the use of gill net fishing over a three year period- This option will gradually reduce sport fish mortality until a complete ban on gill nets is implemented. Undertaking a gradual approach to the elimination of gill netting would allow the few fishers nearing retirement age to continue to earn their livelihood from gill netting, while providing time for younger fishers to find an economic alternative for the activity. The TIDE, Oak/Oceana buy back program should be promoted country wide to reduce the economic impact on Belizean net fishermen should 4 or 5 be implemented.
6. Increase Protected Areas coverage- This option will protect critical sport fish habitats including sand flats, pancake flats, mangrove cays, creeks, lagoons, seagrass beds, wetlands used by juvenile and adult sport fish for foraging and recruitment.


Gill net fishing restrictions can only promote the recovery of sport fish. The wider the scope of the application of restrictions, the faster will be the recovery of Belize's native sport fish population. Sport fish are already protected under the Fisheries (Sport fish) Regulations, Statutory Instrument 114 of 2009, but the continued use of gill nets in Belize water continues to contribute to the further decline and mortality of juvenile and adult sport fish. The sport fish population has been all but eliminated in many areas of Belize as a direct result of gill nets. The majority of the gill net fishing is done by Guatemala nationals with valid fishing licenses. Regulatory enforcement in regards to enforcing existing gill net fishing is poor in Belize because of departmental budgets constraints. Consequently, we recommend a nationwide ban on the gill net fishing in Belize.

Increasing marine protected areas coverage will benefit sport fish stocks in both the short and long term with relatively low compliance cost, and therefore is recommended for implementation. The existing network of marine protected areas addresses about half of the critical sport fish habitats in Belize, leaving some key important sites without any statutory protection whatsoever. Ideally, sport fish stocks might best be protected from habitat degradation and gill netting with the formation of at least four new marine protected areas. These include: Placencia Lagoon, Turneffe Atoll; the Savannah Flats and northern bajos; and the Hick's cay range/ Long Cay range. However, protected areas, although valuable, are only part of a larger resource conservation plan that is needed in Belize and we urge the adoption of the other recommendations in this submission as well as increasing marine protected area coverage.

Turneffe Atoll was recognized as a conservation priority in Belize's 2005 GAP Analysis, but remains essentially unprotected. The back-reef "flats" at Turneffe Atoll are known throughout the sport fishing world for their beauty and sport fishing productivity. As the largest and most biologically diverse coral atoll in the Western Hemisphere, we recommend that Turneffe Atoll be designated as a Marine Reserve as a first priority (see illustration I). A Marine Reserve would offer several administrative and enforcement advantages and it appears that this concept has broad-based support from all Turneffe Stakeholders including commercial fishermen, tourism operators, Coastal Zone and pertinent NGO's.

The world-famous Savannah Flats west of Ambergris Caye represent the largest tarpon flat in all of Belize. Several sand flats in northern Belize including the savannah flats, cayo negro flats, cayo Rosario flats, punta bajo flats etc. have been sold to private developers. Additionally, the wetlands and lagoons between Laguna de San Pedro and Laguna de Cayo Frances are been disposed of as "land" for development. These areas represent some of the most important nursery grounds in Ambergris Caye. Consequently, we recommend that the Government of Belize re-acquire these sub-tidal sand flats, lagoons and wetlands and incorporate them into a marine protected area (see illustration II).

Large migratory tarpon of 80-180 pounds take up residence during late spring and summer in Belize in areas around Haulover Creek, Buttonwood Bay, Tarpon Cove, Hick's Cay, Long Cay, Savannah Flats and Cayo Cangrejo Shoals. Anglers have observed several hundred tarpon "rolling" and moving in the direction of Cayo Cangrejo and/or St. George's Caye. These tarpon have been observed to swim in circles near Cayo Cangrejo, a behavior referred to as a "daisy chaining" and is believed to be a pre-spawning courtship-type behavior. Tarpon landed near Cayo Cangrejo have been observed with swollen gonads or releasing gametes when being reeled in. Researchers believe that these migratory tarpon come to Belize to spawn. Consequently, we recommend that the Long Caye, Hick's Cay and Buttonwood area be designated a marine reserve (see illustration III).

Plans are underway for extending the boundaries of Port Honduras Marine Reserve to include the area from Monkey River to north of Rocky Point. No gill net fishing will be allowed in this area. Consequently, we support this initiative and recommend that Pimento Caye and Plantation Creek also be include in the marine reserve. Efforts are already underway for some legal reserve status for the Placencia Lagoon.

Critical habitat protection will immediately benefit sport fish stocks and maximize the preservation of these ecologically and economically important stocks for posterity. Coastal development practices for hotel development such as dredging, removal of mangrove and seagrass, and the lease or sale of sub-tidal sand flats, lagoons and inter-tidal areas (for dredging to be used as fill) destroys important habitats used by juvenile and adult sport fish for foraging and recruitment. For example, juvenile permit require sandy beaches with some wave energy, while juvenile tarpon require mangrove wetlands, and juvenile bonefish appear to prefer open sand flats. Sand flats, pancake flats and seagrass beds are important foraging areas used by bonefish, tarpon and permit. Loss of these habitats will cause decline in juvenile survival and in turn cause declines in the fisheries. Critical sport fish habitat might best be protected from habitat degradation by integrating them into the proposed Ecosystem Management Act or the National Coastal Zone Plan. However, both the Ecosystem Management Act and the National Coastal Zone Plan are only in the planning stages of development. In the interim, we recommend the following:
a) The back-reef "flats" at Turneffe Atoll should be fully protected;
b) Dredging on Turneffe Atoll should be prohibited;
c) No dredging on the coral or pancake flats should be allowed;
d) The sand flat between Buttonwood Cay and Rendezvous Cay locally known as the Wreck should be protected;
e) The area from Sibun River to Robinson Point should be protected;
f) Destruction of wetlands, mangroves and seagrass beds should be minimized;
g) The 66 feet buffer zone should be enforced to prevent mangrove clearing.
h) The Placencia Lagoon, Plantation Creek and Palmetto Cay should be protected.

Other Considerations

Alternatives for Fishermen - Gill net fishermen have been given preferential access to training in SCUBA diving and sport fishing by TIDE and Southern Environmental Association (SEA) over the past year. These organizations have provided training and employment for fishermen in techniques for monitoring spawning aggregation. SEA has also employed former fishermen as reserve staff. TIDE has implemented a "buy-back" programme with gill net fishermen whereby, they purchase the gill nets from the commercial fishermen and help them by providing them with alternative livelihood opportunities.

An Oak-funded programme on alternative livelihoods for gill net fishermen is to be carried out by OCEANA and implemented next year. This initiative will specifically target gill net fishermen from coastal communities and will entail a "buy-back" programme and training on alternative livelihoods.

A commercial mangrove oyster farming program is also in the works for the Placencia Lagoon as an alternative livelihood for fishermen - as is sea weed farming. Inland hydroponic aquaculture should also be investigated as an alternative livelihood for fishermen.

Education and Awareness - Several organizations including Green Reef, Ambergris Caye Fly-fishing Club, Grand Slam Alliance, Turneffe Atoll Trust, SEA, OCEANA, CZMAI and Fisheries will support a publicity campaign to inform the general public about the importance of Sport Fish and the need for taking action to conserve our stocks.

Management of Sport Fishing - fees, monitoring, enforcement - There are essentially two mechanisms of regulatory administration in Belize. These include the body of regulatory statements enshrined in the laws of Belize, and the statutory bodies that have been legally charged with the responsibility of regulatory oversight through permitting and/or enforcement.


Based on its complex life history and the current threats to their habitat, management measures to conserve sport fish stocks are needed for both protection of these species throughout as much of their range as possible and protection of the habitat. In light of the following presentation, we the undersigned respectfully recommend the following set of regulatory actions for recovery of Belize's Sport Fish Stocks:

1. Moratorium on the sale and development of ALL submerged lands until enactment of the Ecosystem Management Act;

2. Ban gill nets, the importation of gill nets and gill net fishing throughout Belize;

3. Designate four new marine reserves (Placencia Lagoon, Turneffe Atoll, Hick's Cay/Long Cay and Northern Bajos) and extend the boundaries of Port Honduras Marine Reserve.