Fish Stocking EIR/EIS - Part 2

Last week I mentioned that in my next post I'd write about the flawed evaluation of fish stocking impacts in the California Department of Fish and Game (CDFG) draft EIR/EIS. So, here goes. The flawed evaluation derives from two sources: (1) an inadequate range of management alternatives considered, and (2) the use of the last five years of fish stocking as a baseline against which to judge impacts. I'll focus on #1 this week and on #2 next week.

The draft EIR/EIS analyzes three alternatives. These are (1) no project/no action, under which no changes would be made to hatchery operations and stocking programs; (2) continue to operate hatcheries as in the past five years and stock fish based on new guidelines - this is the "preferred alternative"; and (3) permanently operate the hatchery and stocking program as directed in the interim court order, under which no stocking would occur where any of 25 sensitive native species occur or where surveys for these species have not been conducted. Given that the "new guidelines" proposed in the EIR/EIS for the preferred alternative (#2 above) are minor mitigation measures at best, these three alternatives represent an unnecessarily narrow range of alternatives and none would result in a substantive change in the current fish stocking program. This failure to analyze a broader range of alternatives is very unfortunate because it means that the CDFG is missing a chance to change its fish stocking program in ways that would benefit native species AND recreational fisheries. An alternative that seems an obvious one to have been included in the analysis is one that proposes halting stocking in flowing waters and refocusing the stocking program on less sensitive habitats such as artificial impoundments. No such luck.

On page 7-6 of the EIR/EIS it is mentioned that the termination of stocking in flowing waters was considered as an alternative but it was eliminated from further analysis. The rationale for its elimination was as follows: "The alternative was suggested as patterned after a similar practice followed by the State of Montana regarding its stocking guidelines. Demand for recreational fishing in flowing waters is far greater in California than in Montana. Eliminating stocking altogether in flowing waters would place considerable pressure on native and wild stocks that already exist in flowing waters and would eliminate a large proportion of the recreational fishing opportunities for anglers that wish to camp and fish along waters in California." This rationale is absurd.

The state of Montana stopped stocking all flowing waters based on studies that showed that this stocking was having such serious impacts on resident trout that the net result of stocking flowing waters was a dramatic reduction in trout numbers. The termination of stocking resulted in similarly dramatic increases in the number of trout present. These studies (summarized here) were conducted, in part, on the Madison River which is one of the most heavily fished rivers in Montana. So, for the CDFG to argue that they have to continue stocking flowing waters because of high angler pressure makes absolutely no sense when stocking could in fact be harming these fisheries. Once again the CDFGs working assumption is that stocking is the only solution to improving angling opportunities. At the very least, the CDFG should have included an alternative that proposed eliminating stocking in flowing waters and analyzed the alternative in detail.

Some might reasonably wonder why a "no stocking" alternative was not included in the EIR/EIS. For the trout stocking program, the reason appears to be that the CDFG is mandated by recent legislation (AB 7, passed in 2005) to stock a certain number of trout per fishing license sold. In 2009 and subsequent years, the CDFG is required to stock a minimum of 2.75 pounds of trout per fishing license sold in 2008, 2.0 pounds of which must be of catchable size or larger. The portion of the California Fish and Game Code that summarizes these requirements is available here. The fact that this legislation dramatically constrains the range of alternatives that the EIR/EIS could consider is very unfortunate. But there os a deeper irony here. Legislators tried for several years to pass AB 7 and were always stymied by California Trout ("CalTrout"), a fishing organization that opposed the legislation. CalTrout finally threw its support behind the bill after getting language inserted into the draft legislation that allocated two million dollars to CDFGs chronically underfunded Heritage and Wild Trout program. With CalTrout now supporting the legislation, AB 7 was signed into law. Now a few years later, AB 7 is precluding the EIR/EIS from considering reductions in the number of trout stocked annually, reductions that could actually improve fisheries. I hope the directors of CalTrout are fully aware of the consequences of their support for this screwy legislation.

More next week....

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