Fish Stocking EIR/EIS - Part 3

In this post I'll focus on one of the most serious shortcomings of the EIR-EIS: the method used to evaluate the impacts of the current stocking program. In most CEQA documents the environmental impact of a new project is judged by comparing environmental conditions expected under the new project against the current environmental conditions (i.e., without the project). Applying this approach to the current CEQA fish stocking analysis would suggest that impacts of the current fish stocking program would be judged relative to those under a "no stocking" alternative. Paradoxically, the EIR-EIS assesses impacts by comparing those caused by fish stocking in the period 2004-2008 (the "baseline") against impacts caused by previous stocking. As stated on page 1-3,

"DFG’s intent in this EIR/EIS is to analyze the environmental effects of a number of specific programs it currently manages that surround the rearing and stocking of a specific set of fish species. The whole of these individual programs is referred to as “the Program” in subsequent chapters, and serves as the baseline and No Action alternative as defined by CEQA. The detailed analysis of the current condition or baseline, as contained in Chapters 3–6, is not typical for CEQA or NEPA, which usually analyze a proposed project or proposed action. However, the court order that directed preparation of this EIR/EIS mandated that DFG analyze its current fish stocking program."

Under this analysis approach, as long as the impacts that occurred during the 2004-2008 baseline were similar in magnitude to those that occurred during previous stocking the impact of the current stocking would be deemed "non-significant". This conclusion regarding impact significance would be unchanged even if the impacts of the 2004-2008 stocking and previous stocking were both severe.

That this twisted logic produces scientifically unsupportable assessments of impact is hardly surprising. One example relates to the assessment of trout stocking impacts on the long-toed salamander (Ambystoma macrodactylum). In California, this species was historically widely distributed in the Sierra Nevada, Klamath Mountains, and Cascade Mountains where it inhabited a wide variety of perennial fishless ponds and lakes. Several recent studies have reported that A. macrodactylum is typically eliminated from these habitats following trout introductions and this species is clearly much less common in California today than it was historically. Similarly severe impacts of stocked trout on A. macrodactylum have been reported from elsewhere in the western U.S. Despite these well-documented impacts of stocked trout, the EIR-EIS concludes the following (page 4-76):

"Although historic trout stocking likely resulted in a geographically widespread extirpation of long-toed salamander populations from high mountain lakes in the Sierra Nevada, Cascade and Klamath mountain ranges, the continuing conduct of the trout-stocking program during the 2004-2008 baseline period has likely not resulted in any further population changes that would constitute a significant impact on the long-toed salamander. Thus the impact of the trout stocking program is less than significant."

In light of well-established impacts of stocked trout on A. macrodactylum, this finding of non-significance is untenable. Unfortunately, the EIR-EIS is replete with many other scientifically indefensible conclusions that are a consequence of the flawed methods used in these impact analyses. The only way to thoroughly analyze the impacts caused by the current stocking program is to compare those impacts against the impacts that would occur with no stocking.

In my next post I'll focus on the failure of the EIR-EIS to analyze the impacts of the current stocking program on resident trout fisheries. To give people time to read this post before comments to the DFG are due (November 16), I'll move my next post up from November 16 to the middle of this week.

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