MA Crab Traps: The Difinitive Discussion of Laws/Regs

[Jonesy02719]

With all due respect I think I'll take Derek's advice.

Do you want to volunteer to call the DMF contact or shall I?  It doesn't seem like he intends to post here to clarify.  In fact he's asked us to call him directly or visit the less-than-helpful DMF site.  If that doesn't illustrate that there's a problem with educating the resource users, what does?  So that leads us to use logic and discuss.  I welcome his knowledge & experience, and I sincerely hope he actually posts.  Lets face it, if the DMF info was on point, there would have been no need to even have this discussion. Furthermore, THIS is the PREMIER online spot for discussion of all things blue crab.  IMO, We should be discussing these matters and linking and CITING the appropriate rules HERE among our user group.  So if it takes one of us to call DMF (again in my case), we should.

Tons of threads on this site have mis-information regarding the subject, with matter-of-fact statements with absolutely zero fact behind them.   So it's pretty darned clear that this is one of the lesser understood fisheries in terms of regs.  I consider this thread somewhat of a success.  It got people talking, and we actually got a real, live State Biologist to comment!!!

These traps are not considered pots that is probably why. They dont fall under typical crab/lobster gear which is where I think much of the confusion comes from.

It doesn't matter.  If you read the regs I posted, ALL methods of catching crab via trap or "other contrivance" are technically illegal unless you have a Permit (MGL 130 s. 37).  All stop.  The term "other contrivance" is a catch-all.  I assure you there are no statutes or regulations that define "pot", "trap", "star trap", etcetera in terms of crabbing, specifically.  I've spent hours searching.  Therefore, any exception would/should be in writing via Policy or Guidance for the statute/regulations, and might not be on-line or easily accessed.  Dip-netting, on the other hand, actually HAS been exempted through guidance and DMF documents.

Somewhere, somehow, DMF has made a determination that "open traps" (for the sake of discussion assume star-traps & ring traps) are allowed for CRABBING.  This may mean  "a trap" or "traps" PLURAL, pursuant to the above-posted flyer or the 2016 Recreational Salt Water Fishing Guide (link provided above), respectively.  

However, what you can find about "star traps" in terms of lobster is verrrry interesting (quoted directly):

• "American Lobster - Collapsible Traps: In 2011, Massachusetts Environmental Police requested MarineFisheries clarify whether or not collapsible fishing traps, commonly referred to as "star traps", were a gear type authorized to catch and retain lobster. Massachusetts laws do not provide a legal definition of a lobster trap or pot, but collapsible traps, which are actively tended and fished in an open configuration, do not meet the common knowledge definition of a lobster trap. MarineFisheries´ deemed use of the gear to be tantamount to "dipping", which is a prohibited activity for the harvest of lobsters. Therefore, with MFC support, the Division took to public hearing in May 2011, a rule change to clarify that the taking of lobster by open and collapsible traps is prohibited. The MFAC approved the final rule to adopt the revision in June 2011."
  
  http://www.mass.gov/eea/docs/dfg/dmf/publications/2011-dmf-annual-report.pdf
  
  and;
  
• "Open and Collapsible Traps: MarineFisheries has prohibited the take of lobsters by actively tended collapsible traps fished in an open configuration (i.e., star trap). This activity is the equivalent of "dip netting", which is expressly prohibited by Massachusetts state law for the take of lobsters.
  
  Star traps are actively fished open, giving the appearance of a star. The crabber watches until a crab crawls onto the center square, where the bait is laid, before pulling the cord to bring in the corners and fold the trap into a pyramid shape. The trap is then hauled up, emptied, and deployed again for its next crab."
  
  http://www.mass.gov/eea/docs/dfg/dmf/publications/dmfnq1212.pdf

Therefore, there is a policy precedent that star-traps are akin to dip-netting.  If this applies to American Lobster, why would it not apply to crabbing?   I'd even bet a previous policy exists in respect to crabbing!  This does not, however, clear up how many traps you may fish.   It does seem to imply that open traps are intended to be "actively" fished.    I'd argue that if you're actively tending to your trap(s) - whether affixed to your gunwale or in your actual hands - you are actively fishing.   If that is not the case, most people might argue that you are "passively" fishing, or are not in direct control of your gear. This is definitely where clarification is needed.

Believe it or not, one doesn't have to work for a State agency to understand regulations, nor should anyone have to.  I've been reading and interpreting regs professionally for 15+ years.  I have google-fu skills researching regulations, so I am supremely confident that every statute/reg I previously quoted is ACCURATE and UP-TO-DATE.   As said initially, I did take the initiative in calling DMF to discuss this matter before I even posted.  That conversation led me down this research/discussion wormhole.  

I used to think I knew how to answer to all of those questions.  I still think I do, but can no longer do so with total confidence.

I think I'm in the same boat as you now.  I've become even more confused after doing this research.  Though, the more we dig and discuss, the more we are all learning!

[Professor_Leakey]

Hopefully this discussion can lead to more clear regs being written.  There is nothing definitive about the regs at the moment.  This thread is very frustrating but hopefully will lead to something more concrete and less susceptible to multiple interpretations.  With the way they are currently written, it is possible to make the argument both ways; it should not be that way.  

[Ron]

Do you want to volunteer to call the DMF contact or shall I? It doesn't seem like he intends to post here to clarify.

It doesn't?   Based one what?    The fact he didn't immediately reply to follow up questions within a four hour window?

In fact he's asked us to call him directly or visit the less-than-helpful DMF site.

Call him directly.    He is the Crab Biologist for the MA Division of Fisheries.   I don't think it gets much more authoritative than that.     In other parts of this forum, we have provided specific questions and asked for specific answers from DNR/Fisheries/F&W agents.   I recommend doing the same here.

Tons of threads on this site have mis-information regarding the subject, with matter-of-fact statements with absolutely zero fact behind them.

Oddly, it would appear that your initial statements, which I admittedly agreed with, being corrected by the gentleman from the Department of Fisheries might actually now fit into the category of threads you described above.    You did your research and posted in good faith, yet a fisheries authority has deemed the original statement/presumption incorrect, so it hardly seems fair to characterize your statements that way.   In light of that, let's not be so quick to broadbrush previous posters/statements on this subject as having "absolutely zero fact behind them."  

I think I'm in the same boat as you now.  I've become even more confused after doing this research.  Though, the more we dig and discuss, the more we are all learning!

Send this gentlemen specific questions and/or examples and get precise answers from him.    You now have an open line of communication.    I recommend you use it.

[Jonesy02719]

Oddly, it would appear that your initial statements, which I admittedly agreed with, being corrected by the gentleman from the Department of Fisheries might actually now fit into the category of threads you described above.    You did your research and posted in good faith, yet a fisheries authority has deemed the original statement/presumption incorrect, so it hardly seems fair to characterize your statements that way.   In light of that, let's not be so quick to broadbrush previous posters/statements on this subject as having "absolutely zero fact behind them."  

I'm sorry, but you are patently incorrect.  I challenge you to back that up. Fishgeek/Derek did not dispute nor correct a single thing on here.  Other than telling us not to rely on a "website", posting an already-referenced flyer, or a link to the already-confusing DMF site, he said this:

"I am not aware of a regulation that gives a specific number of open top/collapsible traps that can be fished for edible crabs."

That's it.  I even posted this EXACT discrepancy in the very first post of the discussion.  That's because there IS NO REGULATION.  Their own public documents don't even agree with each other.

There was precisely NOTHING cleared up by DMF.   He didn't tell us ANYTHING.  Didn't refute, didn't agree.

Again, I hope he posts again.  If not, I will gladly call.  If I am wrong, I'd actually LOVE to be corrected.  And, I'll gladly eat sh!t. [SOME SH!T EATEN] But until then...

I'm going to stand by what I wrote and cited, unless someone can link me to an actual written policy/guidance document OR produce a regulatory citation that refutes any of that.  Despite a lot of discussion, nobody has offered any kind of referenced info.  I'm researching and discussing publicly-available documents, regulations, and guidance to offer for discussion.   Nothing searchable on mass.gov gives me anything but what I've presented here.   You know you can actually search ALL general laws by keyword, and that you can search the language in each and every state Regulation?  I've done my homework.

Again, I challenge anyone to find otherwise. The laws and regs, despite being completely muddy, are also as clear as day.  If nobody can produce a policy to clarify the statute and regs, than it doesn't exist!    

You may confuse me for someone who's trying to be the boss.  I don't care what people do.   Ignorance is sometimes the best policy.  I'm offering up a discussion based on what's out there for info.  I'm not the royal authority, which is why I posed the discussion.  I can guarantee though, if I can raise these issues, than any enforcement agency out there can do the same.

Look at it this way, if you get pulled over by a state trooper and they cite you with an offence, doesn't it behoove you to look up to see if there is any basis behind it?  Meaning: do the statute/regulations back up the violation?  The same applies here.  Another example... Have you ever read/heard stories about some police officers and environmental police who are actually completely mis-informed about MGL Chapter 91 rules (public waterfront access)?    I see it ALL the time (especially on SOL/Surftalk forums), but yet the guidance on those laws are far more prevalent and accessable than those on blue crabbing.  You can actually get fact sheets about public waterway access that you can show an officer if the issue comes up.  Not so much with blue crabbing.  To me, that's ridiculous and unacceptable.

Call him directly.    He is the Crab Biologist for the MA Division of Fisheries.   I don't think it gets much more authoritative than that.     In other parts of this forum, we have provided specific questions and asked for specific answers from DNR/Fisheries/F&W agents.   I recommend doing the same here.

Did you miss the part where I called DMFNew Bedford - the very same office where he works - prior to posting the first post?   They linked me to the regulations, which started this whole confusing deal!!!

You have convinced me.  I will call him in the morning and report back.  I have a list of questions I'd like to ask anyway.  I'll report back.  

[chef]

Although there are conflicting statements and regulations, I'm fully confident that I'm not breaking the law in crabbing in the manner that I have been.

I will go by the signs posted at the popular crabbing areas that I frequent that my traps are in compliance. According to Derek as of right now there is no regulation stating that multiple traps are illegal and I believe him. If there isn't a law stating that the 8 to 10 traps I use on my crab outings is too many then I have a hard time believing that I'm somehow not in compliance by doing so.

I agree with Jonesy's assessment that the state classifies star or open wire traps as a form of handlining and the DMF's position on the matter, whether it conflicts with other state fisheries regulations or not, I believe would be more than adequate to defend myself in court if that unfortunate event were ever to arise (which I seriously doubt it will).

I believe most fish and game officers would go by the DMF signs posted at the numerous crabbing locations rather than go on some ludicrous witch hunt to burn someone for harvesting 25 crabs.

Keep in mind that kissing in public and attending sporting events on a Sunday are also prohibited in the state of Massachusetts yet I don't see many people behind bars for going to Pats games. I think most of us can rest easy.

Just my $0.02

[Professor_Leakey]

Although there are conflicting statements and regulations, I'm fully confident that I'm not breaking the law in crabbing in the manner that I have been.

I will go by the signs posted at the popular crabbing areas that I frequent that my traps are in compliance. According to Derek as of right now there is no regulation stating that multiple traps are illegal and I believe him. If there isn't a law stating that the 8 to 10 traps I use on my crab outings is too many then I have a hard time believing that I'm somehow not in compliance by doing so.

I agree with Jonesy's assessment that the state classifies star or open wire traps as a form of handlining and the DMF's position on the matter, whether it conflicts with other state fisheries regulations or not, I believe would be more than adequate to defend myself in court if that unfortunate event were ever to arise (which I seriously doubt it will).

I believe most fish and game officers would go by the DMF signs posted at the numerous crabbing locations rather than go on some ludicrous witch hunt to burn someone for harvesting 25 crabs.

Keep in mind that kissing in public and attending sporting events on a Sunday are also prohibited in the state of Massachusetts yet I don't see many people behind bars for going to Pats games. I think most of us can rest easy.

Just my $0.02

[slanted]

Hey folks,

I did a little more digging on this to look for the DMF's intent when it apparently does not regulate collapsible crab traps.

Part of the problem is the state statutes, as it seems to me, too broadly conflate the lobster regs with the blue crab regs (and the regs for other edible crabs), creating the confusion we see here.

So I went looking for signs of the DMF's regulatory intent. I found a couple of docs so far that seem to be on point to the ongoing discussion here. One of those docs Jonesy already homed in on, another used very similar language (a notice for public hearing) so I am not linking that notice here; it's redundant.

The below link is a June 2015 public hearing notice on the regulation of jonah crab. Several interesting tidbits in there. First DMF admits trying to regulate lobsters and crab within the same statutory and regulatory framework is very problematic. They also admit crab traps are not regulated.

http://www.mass.gov/eea/docs/dfg/dmf/marinefisheriesnotices/pubhearings/asmfc-jonahcrabfmp-phnotice-062515.pdf

Excerpt: "Because crab traps are similar in design and function to lobster traps, but are not specifically regulated, there may be implications with the lobster fishery and marine mammal interactions compromising the effectiveness of the Large Whale Take Reduction and Lobster plans."

Also, as Jonesy has pointed out, DMF has taken a previous regulatory stance when it came to prohibiting collapsible traps for catching lobsters, it was due to it being "tantamount" to dipping. And dipping, of course, is legal for blue crab.

Excerpt, as previously posted by Jonesy and found in the DMF 2011 annual report: "Massachusetts laws do not provide a legal definition of a lobster trap or pot, but collapsible traps, which are actively tended and fished in an open configuration, do not meet the common knowledge definition of a lobster trap. MarineFisheries´ deemed use of the gear to be tantamount to "dipping", which is a prohibited activity for the harvest of lobsters."

http://www.mass.gov/eea/docs/dfg/dmf/publications/2011-dmf-annual-report.pdf

To me, that there is no legal definition of a lobster pot, further roils the waters of confusion.

So – no legal definition for lobsters pots, no regulatory scheme for crab traps. Crab traps, plural I might add (as used by the regulators themselves), are the equivalent of dipping.

I say you actively use a trap by laying said trap, or set of traps, and then checking your traps. That would be the common-sense understanding of laying a trap, a standard courts often fall back on in interpreting the gibberish legislators and regulators send their way.

Where does that leave us?

Since there is no clear-cut info on several important aspects of the blue crab/trap statutes and regulations, it seems to be a regulatory black hole – one that DMF may now be addressing, per fishgeek/Derek.

In the meantime, the DMF-posted crabbing signs – which are a boiled down version of the DMF's intent – seem to say collapsible traps (or a single trap, to take the literal reading) without a permit is permissible.

And that may well be why no one in Massachusetts has ever jumped on the forums to say environmental police issued a citation for using multiple collapsible traps.

Cheers for such an interesting topic! Keep it coming folks...

[Ron]

I'm sorry, but you are patently incorrect.  I challenge you to back that up. Fishgeek/Derek did not dispute nor correct a single thing on here.

I'm not going to get into a further debate about whether or not you originally stated that traps out of your control absolutely required a permit as it serves absolutely no productive value.   I am, however, going to repeat the statement to tell you not to be so quick to dismiss the posts of previous posters on this subject as being baseless as it is an unfair characterization on your part.   

As far as calling, that's the right thing to do.   I'd also recommend you memorialize any questions you have with a follow up email to him and get a response.   Here would be a good example of an email repost from the NJ forums regarding NJ Trotlines:

Received a response email this morning.    

This guy is a friend/neighbor who has always been very helpful in updating me on F&W issues, so please do not bomb him with emails in response to this.     If we have follow up questions, which I am sure there will be, please post them here and I'll send him a complete compilation of questions.    I appreciate everyone's cooperation in advance with this request.  

In summary:

150' trotline is measured first snood to last snood, no anchor or guidelines are included in the measurement.

Two trotlines may not be tied together.

Two trotlines can share a common anchor line, provided that a buoy or stake is marking the ends of each individual line and the baited portions of the lines are separated by at least 100'.


-------------------------
From: Babb, Russell [mailto:[email protected]]
Sent: Thursday, March 24, 2016 9:34 AM
To: Ron Meischker <[email protected]>
Subject: RE: Need a written determination about crabbing with recreational trotlines

Ron,

See my answers in red below.  Any other Qs, let me know.  

Russ


Russ Babb, Supervising Fisheries Biologist
Marine Fisheries Administration
Bureau of Shellfisheries
Nacote Creek Station - (609) 748.2040
Delaware Bay Office - (856) 785.0730
***PLEASE NOTE NEW E-MAIL***
[email protected]  



From: Ron Meischker [mailto:[email protected]]
Sent: Tuesday, March 22, 2016 11:34 PM
To: Babb, Russell
Subject: Need a written determination about crabbing with recreational trotlines

Russ,

Please forward this question to the appropriate individual and ask them to provide me with a written determination to clarify rules about crabbing with a recreational trotline in New Jersey.   The speculation is thick on bluecrab.info about this and I want to help set it to rest.

---------------------------------------------

New Jersey's recreational trotline regulations allow a crabber who purchases $2 recreational crab pot license to utilize two trotlines of no longer than 150' in length and containing no more than 25 baits each.    The regs also state that trotlines must be marked at each end by a clearly visible stake or buoy.

With these facts in mind, please answer the following questions.

Question #1
What constitutes the 150 foot length of each trotline?     The baited portion of the line itself only, or do we need to calculate the anchor and buoy lines into the length calculation?  

DFW enforces the 150' regulation by measuring from the first snood (i.e., baited line) to the last snood, the length of which would not include the anchor or float lines.


Question #2 & 2a
Some recreational crabbers believe it is acceptable to tie two trotlines together to create 300 total feet and 50 baits of linked line.     Others think this is not correct, because that would be one 300 foot trotline as opposed to two 150 trotlines, defeating the purpose of the maximum trotline length being set at 150 feet.   Additionally, the regs say each trotline must have both ends marked by a clearly visible stake or buoy, which would seem to defeat any argument that you can tie two lines together, because then each end would not be marked by a buoy.

Can two trotlines be tied together?  

Connecting two trot lines together to form one 300' trot line is a definite no.  Must be separate.  

If no, may they share a common anchor line between the two lines as long as both ends of each line are clearly marked by a stake or buoy?

It would be acceptable for someone to use the same anchor for two separate trot lines provided that a buoy or stake is marking the ends of each individual line and the baited portions of the lines are separated by at least 100'.

I'd recommend these questions be asked right out of the chute...

Is a permit required to deploy open top, basket or star traps with floats away from your vessel, so long as you are actively tending your said traps?

If the answer is no, please define "actively tending" traps in terms of distance and/or frequency of use.

Is there a limit to the # of open top, basket or star traps one may use in a single outing without a permit?

[Professor_Leakey]

I want to thank both Derek and Steve for being so helpful in their communications on this matter.  These guys were readily available, prompt in their responses, as well as extremely knowledgeable and professional. 

[Jonesy02719]

I want to thank both Derek and Steve for being so helpful in their communications on this matter.  These guys were readily available, prompt in their responses, as well as extremely knowledgeable and professional.  

Thank you for getting that in writing.  Now it's record, and pretty hard to argue against.    You undoubtedly have posted the best (only) definitive answer on star-traps so far.   

I have amended the initial post and a few others, including where I had to eat sh!t on some bad info.  

I think the discussion was still worthwhile, but I am still in need clarification on a bunch of things.   Ron had some good questions, and I have a handful more.  I tried calling Derek a few times today, but was unable to reach him.   

[chef]

Great job Professor. Im glad we can finally put this baby to bed and my wife is glad that I wont be commandeering the basement fridge for the 1000 foot  trotline I was about to construct.

[fishgeek]

Wow. That turned into quite a discussion. 

Judging by the most recent posts it sounds like some of the confusion has been alleviated. 

I do not check this site every day, the best way to reach me is via email or phone which has been posted numerous times in this thread.  I'm in the field a lot, especially this time of the year so I may not be at my desk.  I may not be able to answer you right away, but if you leave a message I will get back to you.   

If anyone has further questions about our statutes (interpretation, history, wording, etc) you can contact our Regulatory Coordinator/Administrative Law Clerk at (617) 626-1534. 

Good luck crabbing,
Derek Perry
Massachusetts Division of Marine Fisheries
Invertebrate Fisheries
1213 Purchase Street
New Bedford, MA 02744
phone: (508) 990-2860 ex. 148
fax: (508) 990-0449
[email protected]

[Jonesy02719]

I just spoke to Jared Silva, the Regulatory Coordinator/Law Clerk at DMF by telephone.  He's obviously extremely knowledgeable about DMFs laws, regs, and policies.  He speaks my language, so it was even better to discuss these issues directly with the DMF source on regulatory issues.  I probably should have gone directly to him in the first place, rather than get conflicting info from my initial call to field staff.

To sum up the conversation, DMF is aware that the laws regarding blue crabs are confusing.    According to Mr. Silva, the rules were written in a time when there wasn't much of a blue crab fishery in Massachusetts.   Clearly, that has changed.  More and more people are participating in the fishery, which will require DMF to be more clear in policy directives and/or develop additional rules.

Regarding multiple traps:  The presumption I offered was that one person can only dip so many nets at one time (two at best).  How then could it be legal to fish multiple open traps on a pot string? According to Mr. Silva, the intention/historic interpretation of the rule to allow dip-netting and so-called "open traps" was that they were to be "actively fished" (e.g. in your hand since true collapsible traps are designed to be fished that way) and NOT to allow people to fish multiple open traps.    Furthermore, Mr. Silva told me not to bother looking for anything in writing, because there is nothing saying this.  I personally find this troublesome, but that's the way it is.

That being said, and given current information or lack thereof, there is nothing preventing you from using multiple OPEN traps (of ALL TYPES), according to laws, regulation or policy.

To illustrate the conundrum, I posed another question/scenario:

Say a husband, wife and two sons ("immediate family" as defined by statute) go crabbing one day.   They each set 10 of their own open traps in their own strinsg (so 40 traps total), and come back later in the day to check traps.   For purposes of this discussion, I specified 5-sided, open-topped, rigid wire box-style traps. They each get their limit of 25 crabs per person.   They are allowed to take 100 crab. 

Now, conversely, the same immediate family wants to now fish 6-sided or closed traps.  They paid for and have the required Recreational Crabbing Permit for said traps, and follow all rules related to that gear.  As an immediate family, they can only harvest 25 crabs TOTAL per day.

This scenario is another reason why the regs make absolutely NO sense    If you look at fishing intensity, potential mortality (as crabs do love eating each other), and the harvest/taking of crab, fishing multiple open traps can be more damaging to the resource than the closed-trap/permitted fishery.    I asked why would I even bother getting a Rec Permit, when a family could fish more gear and harvest 4 times more crab without one?  Mr. Silva agreed that there was a lack of clarity, and admittedly never even considered this being a potential issue.   In fact, he said it is something DMF should be considering in the future.

[skikid00]

To illustrate the conundrum, I posed another question/scenario:

Say a husband, wife and two sons ("immediate family" as defined by statute) go crabbing one day.   They each set 10 of their own open traps in their own strinsg (so 40 traps total), and come back later in the day to check traps.   For purposes of this discussion, I specified 5-sided, open-topped, rigid wire box-style traps. They each get their limit of 25 crabs per person.   They are allowed to take 100 crab. 

Now, conversely, the same immediate family wants to now fish 6-sided or closed traps.  They paid for and have the required Recreational Crabbing Permit for said traps, and follow all rules related to that gear.  As an immediate family, they can only harvest 25 crabs TOTAL per day.

This scenario is another reason why the regs make absolutely NO sense    If you look at fishing intensity, potential mortality (as crabs do love eating each other), and the harvest/taking of crab, fishing multiple open traps can be more damaging to the resource than the closed-trap/permitted fishery.    I asked why would I even bother getting a Rec Permit, when a family could fish more gear and harvest 4 times more crab without one?  Mr. Silva agreed that there was a lack of clarity, and admittedly never even considered this being a potential issue.   In fact, he said it is something DMF should be considering in the future.

If a family of 4 set their 40 open traps for a few hours before checking then most likely they will be pulling up traps without bait.  Also means no crabs.  Even if they don't lose any bait, you hardly see more than 1 per trap.  I'm no crabbing expert but I know one needs to be active to catch crabs.

If convenient(in this scenario) is what this family looking for then 25 is what they get.  A permit for closed traps is luxury crabbing in my opinion.

[Professor_Leakey]

If you look at fishing intensity, potential mortality (as crabs do love eating each other), and the harvest/taking of crab, fishing multiple open traps can be more damaging to the resource than the closed-trap/permitted fishery.   

I do not agree with that statement one bit.  Not sure why you have it out for people trapping crab.  Why the agenda?     

[Jonesy02719]

Not sure why you have it out for people trapping crab.  Why the agenda?     

LMAO.  I'm a proud and honest fisherman, crab fisherman and outdoorsman.    Reading some of your posts, I gather that Consider yourself the same.  But because I have a differing opinion than you, I'm anti-crab trapping?  Comedy.  Look, I couldn't care less what you think of me, I'm not attacking you or anyone else personally.

I have no agenda.  I'm a student of studying Mass environmental laws, whether fishing, access or whatever.  Whether you agree or not on why this post was created, it's your right.  But it has identified some serious gaps in the regs, and there's nothing wrong with that.  There for once, has been concrete answers to this topic.

[Ron]

For the sake of being concise, I've consolidated the tacked part of this topic down to two posts and untacked the rest.