January 18, 2010

"Final" Fish Stocking EIR/EIS Is Even Worse Than Feared

The final fish stocking EIR/EIS is now available on the California Department of Fish and Game (DFG) web site. A reading of the pertinent sections has left me, well, dejected. With this document, the DFG had an unprecedented opportunity to develop future fish stocking practices that would benefit both native species and anglers. Instead, they've done everything in their power to maintain the status quo and that status quo will benefit neither native species nor anglers. With a few exceptions, the document is substantively unchanged from the draft version. The objective statement ("...continue the rearing and stocking of fish from its existing facilities...") remains the same, the analyses still use the same flawed baseline (2004-2008 stocking program), and the three narrowly-defined alternatives are unchanged. 

The only significant change that I've found is one that makes the document even worse. In the draft EIR/EIS, the DFG acknowledged that the annual pumping of more than 12,000 acre-feet of groundwater to supply the Black Rock fish hatchery has caused significant impacts to springs and riparian areas due to groundwater draw-down. To mitigate this impact, the draft EIR/EIS proposed reducing groundwater extraction to 8,000 acre-feet per year, an action that was applauded by the California Native Plant Society and others. The Los Angeles Department of Water and Power, which sends the 12,000 acre-feet to L.A. after its use in the hatchery, complained mightily about this mitigation, and it is absent from the final EIR/EIS. 

In reading over the Responses to Comments (Appendix M), I often couldn't believe my eyes. For example, in my comment letter I stated, "It is paradoxical that the DFG's primary objective is to "continue the rearing and stocking of fish from its existing facilities" before impacts of those activities are analyzed, disclosed, and mitigated". The DFG response to this comment states, "It is difficult to understand why the commenter considers this objective paradoxical; DFG is required by law and Fish and Game Commission guidance to provide hatchery-reared fish for recreational fishing in California.... The commenter seems to suggest that DFG should consider an alternative that eliminates hatcheries...". Actually, I said nothing of the kind. I was simply noting that the stated objective of continuing the current stocking program would make it difficult to propose any substantive changes to that program. With their stated objective, the DFG is in effect preordaining a conclusion that fish stocking has minimal effects and no serious changes to the program are necessary. And, lo and behold, that is exactly what we got. 

My comments on the draft EIR/EIS also argued that the document failed to analyze stocking impacts on recreational trout fisheries. In response, the DFG stated (in part) that the management of recreational trout fisheries is specified by the 2004 Strategic Plan For Trout Management and is therefore outside of the purview of the EIR/EIS. This is absurd for a couple of reasons. First, the court required the DFG to analyze the environmental impacts of its current trout stocking program on the environment. That, in my mind, includes analyzing impacts on existing trout fisheries. Second, the Strategic Plan for Trout Management is not a CEQA document. Instead, it is a brief plan that outlines some vague goals for the hatchery trout program and does not even discuss the impacts of hatchery trout on resident trout populations. I can only conclude that the DFG will do anything in its power to avoid dealing with this important issue. 

I guess I've learned one important lesson from all of this. Over the years, I've heard lots of complaints about how agencies are sometimes prone to advocating positions that serve only the agency itself. The lengths to which the DFG went in the EIR/EIS to advocate for the status quo drove this home for me. The DFG is always quick to tout how its stocking program is largely responsible for California's many fishing opportunities. And yet the available evidence makes it abundantly clear that fish stocking often has negative impacts on resident trout populations and that as a consequence the current fish stocking program could actually be making fishing worse. The EIR/EIS objective statement promoting the status quo and the DFG's refusal to acknowledge impacts on resident trout fisheries (much less propose any mitigation measures) indicates to me that the DFG's interest lies not with producing high quality fishing opportunities. Instead, its interest is simply in continuing the current trout stocking program (and associated budget) regardless of whether this program benefits California's anglers. That is unacceptable.

Back to The Mountain Yellow-legged Frog Site.


  1. you're suprised because why? why wouldn't DFG look out for their current implementations (and employees.) It's very unlikely you can make a change to an organization from the outside unless you're absolutely solid on your data. I would say that your data is pretty solid, but they didn't listen. I hope the new director can be appropriately influenced with real impact data. That still remains to be seen.

  2. Hi Russ. Thanks for your thoughts on this. I'm actually not overly surprised that the DFG is trying so hard to maintain its current fish stocking program. As you suggest, that is a pretty natural reaction. I am surprised at the arguments they made to achieve this goal. For example, if they wanted to maintain their current level of hatchery trout production, they could have made a rational argument for reducing the stocking of waters where impacts to native species and resident trout populations were likely, and reallocate those trout to other waters where impacts are less likely (e.g., reservoirs). Few would have complained about such a proposal. Instead they opted for a much riskier strategy of defining any impacts out of existence. In my opinion, this wasn't about data. It was about politics, the nature of bureaucracies, and dogmatic leaders who fail to see the writing on the wall.

  3. Mr. Knapp, I worked hard for years to continue the maintenance on the small check dams in the Emigrant wilderness and had no help what so ever from groups like yours that care about amphibians. It is a proven fact that these dams provide hundreds of acres of habitat for amphibians. The so called environmentalist did not care one bit about the dams and worked to defeat efforts to maintain them. I wonder why? I think it is because they are so wrapped up in fighting fisherman and sportsman that they are blind to what is really going on. In the emigrant wilderness,study's show that there is plenty of fish less habitat for frogs and plenty of water for fish. There is a balance and a compromise already. Why are these groups still focusing on fish stocking and now recreational stock grazing? It is because they want to end all fishing and eliminate horse use in the sierras. This is not science, it is just using a species in turmoil to further a political agenda. If amphibian groups were to use real science and be honest then I think they would find a broader support for there cause. Thanks, Matt

  4. Hi Matt. I write this blog as a scientist who has studied Sierran lakes for two decades. I am not affiliated with any environmental group. Your concerns about the role of environmental groups in issues related to the Emigrant dams and recreational stock grazing should be directed at the groups involved: Wilderness Watch and High Sierra Hikers.