Souderton - Harleysville Game, Fish and Forestry Association
Fishing Committee
Dave Haywood
215-260-5725
Proposed Regulations from the Pennsylvania Fish and Boat Commission (PFBC) – Effective on January 1, 2025
We're writing to ask for your help. There is a proposed regulation from Pennsylvania Fish and Boat Commission, "FISHING - Proposed Rulemaking - Propagation and Introduction of Fish into Commonwealth Waters", up for public comment before final review and vote by the Commissioners. While there are parts of this rulemaking that we see a need for, and think will benefit PA fisheries, there are other parts that are unworkable for those wishing to stock fish in PA. Because it still needs work, we are asking that you take a few minutes to comment and vote NO so that it gets sent back to PFBC staff for the necessary changes.
The proposed regulation can be found by going to:
https://www.pacodeandbulletin.gov/Display/pabull?file=/secure/pabulletin/data/vol52/52-25/895.html
To comment, go here:
https://pfbc.pa.gov/regcomments/index.htm?title_number=Rulemaking325
If this regulation goes through as is, we will be unable to supply trout for stocking in PA beginning 1 January 2025. Though that's 2 years away, the comment period on this ends 18 August 2022.
Please comment and forward this to anyone you know that might be affected or might otherwise have an interest in stocking fish in PA and ask them to comment as well. Below are our suggested comments. Feel free to cut and paste into the comments section.
I am against this rulemaking for the following reasons:
1. It grants too broad of power to staff at PFBC to regulate without established rules defining the boundaries of that power, public access to those boundaries, required timeframe, or oversight by Commissioners.
2. It creates a situation of impossible compliance causing all of us stocking fish to stop or to break the regulations.
3. It creates additional barriers to those wanting to stock fish in PA.
Those are broad statements, but we feel they cover most of our issues with the proposed regulation. Though not exhaustive, here is a more detailed explanation of why we feel this is so important to halt:
Compliance with the requirements under Subchapter C., section (a) is not practically possible.
"Persons authorized by the Commission to stock fish shall ensure water used to transport fish does not contain nonnative, injurious, or harmful pathogens, or any other fish or aquatic species other than those expressly authorized." The testing/certification cannot be done by the general public with readily available products/instruments or knowledge. Arguably, it can't be done at all. Water exposed to air has the potential to contain something that is harmful to something, and without clarification on the 'injurious, or harmful' language, this is a situation in which the public cannot obtain compliance.
Because it's not practically possible, it automatically places the person stocking, or their authorized agent, in non-compliance. While this part technically falls on the person stocking the fish, not us as providers of the fish, we still must be able to reasonably assure our customers that we, and our water, can comply. No honest operator, private or public, can make this assurance.
The public is at a disadvantage.
Subchapter C., section (c) - "If ... staff determine the proposed stocking activity creates a likelihood of adverse impacts to fish, fish habitat, or fishing, staff may amend an application for fisheries management or fish health purposes in order to approve a proposed stocking activity. If no such amendment is possible, a stocking authorization may be denied."
How will staff determine this? How does the public access the standards used by staff to make these decisions? Without transparency in the requirements for approval, the process is arbitrary - subject to the whims of staff, and if the judgement of staff is all that's required, there seems to be very little chance of an appeal going the way of the petitioner.
With no known (or expected) timeframe for the application process, and no published standards by which the public can reasonably assume their application's approval, any stocking that isn't planned months ahead of time is in jeopardy of not happening. And even with a long planning period, you still won't know until you know.
As a more general concern, why is this necessary at all? We understand the PFBC's goal of protecting our aquatic resources, but if there are importation requirements for fish coming into the state, and fish health testing requirements for stocking, why must a person also have authorization from the PFBC? They already regulate which species can be stocked in PA, and already designate which waterways can be stocked with which species, and that information, while not terribly easy to find, is publicly available ... so why do we need the additional approval using unidentifiable standards?
The Stocking Authorization creates additional barriers to fishing in PA.
Determining in what waters you can fish, when you can fish there, for what, and with what tackle is an absurdly difficult task in PA as is. For those fortunate and dedicated enough to provide fishing opportunities by stocking fish, we see no way this process can enhance those efforts. It can only, at best, detract and at worst, prevent them entirely.
Fishing is done for sport and entertainment. Once being entertained becomes too burdensome; you find a new source of entertainment.
While it is extremely important that we all comment through the official public comment site (linked above), because those comments are given to the Commissioners that ultimately vote to approve or reject the proposed rulemaking, a call to your state representative's office can't hurt. They should know how this regulation will affect fishing and tourism in their district. If this passes as is, we don't see how stocking in PA can continue.
We're happy to discuss this with anyone that has questions.
We have appreciated your business over the years, and we hope to continue to be able to provide fish to you, and the generations that follow.
Thanks for listening,
Mark Ely, Owner
Limestone Springs
717-585-2721
Fall Trout Fishing 2021
We will stock 1,550 trout in the lake, ponds and creek on November 4th and 5th. There will be no fishing allowed until November 6th at 6:00AM.
On November 6th, the catch and release pond will be fly fishing only.
PA State Limits for Bass
The dates below are for the 2021 season and will change each year.
Jan. 1 - April 16 and Nov. 1 - Dec. 31 4 (combined species) 15 inches
April 17 - June 11 NO HARVEST
June 12 - Oct. 31 6 (combined species) 12 inches
Below is a link for the PA state size limits:
https://www.fishandboat.com/Fish/FishingRegulations/Documents/bookfish-pocketguide.pdf
PLEASE do not feed the fish in the holding tanks...they are on a controlled diet to keep them healthy and to promote their growth. For those interested, this is where we get most of trout from....
To Fish on Club Property, you'll need the following:
1. Current Club membership badge
2. Current PA fishing license with trout stamp
3. A valid photo ID
Anyone caught attempting to bring in a non-member to fish will immediately lose their
membership in the Club. No Exceptions.
NOTICE - 2022 New Additional Club Fishing Rules
Club Fishing Rules As previously mentioned, during past trout fishing seasons a number of dead trout have been discovered in our stream and ponds. Please familiarize yourself with the rules below:
1. Recommendation to use barbless hooks or pinch the existing barbs down.
2. Anyone using live bait or Power Bait must keep the fish they catch; no catch and release allowed.
3. If you plan to catch and release, barbless hooks are required and/ or pinch the existing barbs down. Barbs must also be pinched on all flies if you plan to release. Please use common sense and care when catch and releasing.
4. Recommendation to move after five (5) catch and release in same area to allow for other members to fish a hot spot.
5. The maximum number of trout permitted on one stringer is five (5).
6. Our Club follows all PA State fishing and creel limits.
7. Please police our fish cleaning station. Remember, it is a privilege to have available and we must keep it clean, or it will be removed.
8. Kid’s day is exactly what it says, FOR KIDS ONLY. No adult fishing. Adults may assist in casting, but that is all; the child must reel in fish. Adults with no children near-by and a line in the water will be asked to leave promptly.
The Fly Fisher’s Code of Ethics
1). Obey all laws and regulations, and report violations.
2). Release fish carefully and quickly.
3). Be considerate of private and public property.
4). Set a good example for and help others who are not as experienced as you are.
5). Rotate the pool and /or positions, so others may have an opportunity to fish, especially during a hatch.
6). Respect the area in which someone is fishing. Do not intrude or crowd other anglers.
7). Assist another angler who has hooked a fish, including reeling in your line if appropriate.
8). Keep our waters and surrounding property free from trash and litter.
9). Wade carefully and do not disturb water unnecessarily.
10). Treat others as you would want them to treat you.
This applies to all types of fishing, not just fly fishing.
Reminder...the Club follows all the PA State regulations and rules for fishing. You must display your fishing license and Club membership card while on Club property. No more than five (5) trout per person per day allowed and ONLY five (5) trout allowed on a stringer. This changes to three (3) trout depending on the date. Please report any violations to a Club Director (contact information can be found on page two of your newsletter). Please be calm, safe and friendly to fellow Club members. Please do not litter. Thank you and good luck