Anybody who read the California Department of Fish and Game (CDFG) draft fish stocking EIR-EIS knows that this document is badly flawed. Many of these flaws, such as an inadequate range of alternatives, are fundamental to the entire document and addressing them would require a major rewrite of the EIR-EIS. However, the court-ordered deadline for the final EIR-EIS is January 11, 2010. How is the CDFG going to make all the necessary changes to this document in time to meet this deadline?
One possibility would be that the CDFG could go back to the Court and request a deadline extension. However, the CDFG is apparently determined to meet the original January 11 deadline, so I'm guessing that instead we will see a final EIR-EIS that is only marginally improved from the draft version. That will undoubtedly result in another lawsuit, and given that the same CDFG legal counsel who lost the previous fish stocking lawsuit will be providing advice again this time around, the CDFG will lose again and will be forced to make the necessary major revisions to the EIR-EIS that many people have been calling for all along.
The inadequacy of the current draft EIR-EIS and all the shenanigans that are likely to follow could have been avoided if the CDFG had decided from the very beginning of this process to thoroughly and honestly evaluate the environmental costs and benefits of their fish stocking program. Instead the CDFG did what they usually do on this issue, which was to first decide what the document's conclusion would be (i.e., continue the current fish stocking program), and then use every imaginable argument to justify this conclusion, no matter how ridiculous these arguments are. When this process has finally run its course, I suspect that the CDFG would have spent much less money, done a better job of protecting native species, and produced better recreational fisheries if they had used the CEQA process the way it was intended.
And this from an agency whose stated mission is "to manage California's diverse fish, wildlife, and plant resources, and the habitats upon which they depend, for their ecological values and for their use and enjoyment by the public". If only the CDFG would take their stated mission seriously....
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November 24, 2009
Fish Stocking EIR/EIS - Part 5
November 11, 2009
Fish Stocking EIR/EIS - Part 4
The court order required the DFG to analyze the environmental impacts of the current stocking program and it is difficult to conceive of such an analysis not including an assessment of impacts of stocking on resident trout fisheries. In the EIR-EIS, this analysis is restricted solely to the effects of trout stocking on a few special-status native trout species (e.g., golden trout). Such a narrow interpretation of "environmental impacts" is unacceptable. As the following discussion makes clear, the potential exists for the current trout stocking program to seriously impact resident trout populations and adversely affect recreational fishing opportunities. These impacts should be analyzed and disclosed.
In an overview paragraph describing the effects of stocked trout on other salmonids the EIR-EIS (page 4-66) states,
“Most hatchery rainbow trout that are stocked for put-and-take fisheries in streams are caught within 2 weeks of planting (Butler and Borgeson 1965; Moyle 2002), and the remainder likely die of starvation or stress within a few weeks (Moyle 2002). Therefore, the potential for impacts on native trout species through competition and predation associated with catchable-sized rainbow trout plantings in streams appears to be low.... Catchable-sized hatchery rainbow trout released into lakes survive for longer periods than stream stocked fish because of lower energy costs associated with the absence of stream currents, and a relatively lower vulnerability to angling and predation (Moyle 2002). Therefore, the duration of competitive and predatory impacts on native lake populations following stocking of catchable-sized trout should be greater than the impacts following stream stocking.”A less selective presentation of the available scientific literature would clearly indicate that the introduction of hatchery trout can negatively impact resident trout in both streams and lakes. In streams, direct effects are well-documented and usually result from competition between stocked and resident trout. This competition can produce slower growth rates (Weiss and Schmutz 1999, Bohlin et al. 2002), increased movement (Vincent 1987), and increased mortality of resident trout (Petrosky and Bjornn 1988, Baer and Brinker 2008). In addition, stocking catchable trout can increase fishing effort and in turn increase capture and removal rates of resident trout (Baer et al. 2007). These effects can subsequently result in lower overall trout densities (Vincent 1987).
The study by Vincent (1987) provides a particularly detailed description of the consequences of stocking hatchery trout into rivers and streams that contain resident trout populations. In this study, the long-term stocking of hatchery trout into the heavily-fished Varney section of the Madison River was halted and concurrently an unstocked tributary (O’Dell Creek) began receiving plants of hatchery trout. After four years of no stocking in the Varley section, the number and biomass of 2-year-old and older resident brown trout increased by 160%. Resident rainbow trout numbers increased by 800% and biomass increased by 1000%. In contrast, three consecutive years of hatchery trout stocking into O’Dell Creek resulted in a 49% reduction in the numbers and biomass of 2-year-old and older resident brown trout. The obvious conclusion from this study is that the stocking of hatchery trout can have dramatic impacts on resident trout populations and can in some cases actually decrease the quality of trout fisheries. As a result of the Vincent (1987) study, the State of Montana eliminated all stocking of flowing waters and restricted stocking only to lakes and reservoirs.
Impacts from stocking trout into lakes that contain resident trout are more poorly understood than impacts in flowing waters. However, two studies provide important insights. Elser et al. (1995) studied the consequences of halting rainbow trout stocking in Castle Lake, a historically fishless lake in northern California that at the time of the experiment contained introduced rainbow trout and brook trout. The brook trout population was capable of natural reproduction in Castle Lake but the rainbow trout population was maintained entirely by stocking. When rainbow trout stocking was halted, brook trout recruitment increased. Three years after rainbow trout stocking was halted, total trout numbers had increased by 20% (previous dominance by rainbow trout now replaced with dominance by brook trout) and total trout biomass had increased by 30%. In the Sierra Nevada, Armstrong and Knapp (2004) compared trout densities and growth rates in 61 alpine lakes before and after a 4-8 year period of no fish stocking ("stocking-termination" lakes), and also between the stocking-termination lakes and control lakes that continued to be stocked. Contrary to the expectation that Oncorhynchus species stocked into alpine lakes rarely establish reproducing populations, results indicated that 70% of the stocking-termination lakes actually contained reproducing trout populations. For these reproducing populations, 4-8 years of no stocking resulted in no detectable change in trout density and may have resulted in increased trout growth rates in some lakes. Therefore, as in flowing waters the stocking of hatchery trout into lakes can actually reduce total trout numbers and biomass, with negative consequences for fishery quality.
In summary, the results from these and many other studies lead one to the unavoidable conclusion that in at least some situations no stocking will actually result in better fisheries than intensive (and expensive) fish stocking. Given the potential severity of fish stocking impacts on resident trout populations and trout fisheries (and the associated costs), it is clear that the EIR-EIS must provide a thorough analysis of these impacts.
References
Armstrong, T. W. and R. A. Knapp. 2004. Response by trout populations in alpine lakes to an experimental halt to stocking. Canadian Journal of Fisheries and Aquatic Sciences 61:2025–2037.
Baer, J., K. Blasel, and M. Diekmann. 2007. Benefits of repeated stocking with adult, hatchery-reared brown trout, Salmo trutta, to recreational fisheries? Fisheries Management and Ecology 14:51-60.
Baer, J. and A. Brinker. 2008. Are growth and recapture of hatchery-reared and resident brown trout (Salmo trutta L.) density dependent after stocking? Ecology of Freshwater Fish 17:455-464.
Bohlin, T., J. I. Johnsson, and J. Pettersson. 2002. Density-dependent growth in brown trout: effects of introducing wild and hatchery fish. Journal of Animal Ecology 71:683-692.
Elser, J. J., C. Luecke, M. T. Brett, and C. R. Goldman. 1995. Effects of food web compensation after manipulation of rainbow trout in an oligotrophic lake. Ecology 76:52-69.
Petrosky, C. E. and T. C. Bjornn. 1988. Response of wild rainbow (Salmo gairdneri) and cutthroat trout (S. clarki) to stocked rainbow trout in fertile and infertile streams. Canadian Journal of Fisheries and Aquatic Sciences 45:2087-2105.
Vincent, E. R. 1987. Effects of stocking catchable-size hatchery rainbow trout on two wild trout species in the Madison River and O'Dell Creek, Montana. North American Journal of Fisheries Management 7:91-105.
Weiss, S. and S. Schmutz. 1999. Response of resident brown trout, Salmo trutta L., and rainbow trout, Oncorhynchus mykiss (Walbaum), to the stocking of hatchery-reared brown trout. Fisheries Management and Ecology 6:365-375.
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November 8, 2009
Fish Stocking EIR/EIS - Part 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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November 2, 2009
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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