"Ignorance is Bliss": Really?

In my view of the world, science has a central role to play in resource management decisions. Scientific information, if obtained from well-designed studies, can serve as a foundation for such decisions, providing a description of the problem and of potential solutions. To be sure, scientific information is only part of the equation, and social, legal, and financial considerations are also critical to the development of sound management practices. Ideally, all of these information sources are used to develop proposed actions that are presented to the public and then amended as necessary. For this process to be effective, scientists and managers need to be clear about their intent and unbiased in their description of the problem and proposed solutions. Similarly, for public input to be useful the public must educate themselves on the issue. Problems in any of these areas can derail the process of developing sound decisions, and there are ample examples of such derailments. 

I've made a concerted effort to help members of the public educate themselves on the fish-frog issue (in part by writing this blog and maintaining the Mountain Yellow-legged Frog Web Site), and perhaps that is why I find it frustrating to see members of the public refusing to avail themselves of readily available information and instead advocating strongly-held opinions based only on hearsay. The recently released fish stocking EIR-EIS contains a summary of all comments submitted in response to the draft document (Appendix M), and one letter in particular provides a telling example of the dangers of being uninformed. This letter was submitted by the Backcountry Horsemen of California and it states (in part) that "there has been no conclusive scientific evidence to prove that frogs and fish cannot coexist", and that for mountain yellow-legged and Cascades frogs "it has not been determined beyond a shadow of a doubt the absolute specific cause of the decline". Based on this, the letter-writer argues for the "continued management and support of hatcheries to produce adequate number of fingerlings to accommodate the high levels of stocking to provide for high quality recreational fishing in all the high mountain lakes of the Sierras, Cascades and Klamath mountain ranges of California". 

Based on these comments, I'd be willing to bet that the letter-writer has not read a single one of the scientific papers that describe the impacts of introduced trout on amphibians in California's montane habitats. These studies were conducted by different research groups (including the California Department of Fish and Game) and include detailed surveys of amphibians and fish at more than 15,000 lakes and streams. The various studies are unanimous in their conclusion that trout introductions can cause negative impacts to mountain yellow-legged and Cascades frogs, and also demonstrate that trout removal can result in their rapid recovery. These studies have also clearly shown that the amphibian chytrid fungus is a major cause of the mountain yellow-legged frog's decline. Finally, these studies have identified pesticides as a possible additional cause of declines, although evidence in support of pesticides remains relatively weak (including my own paper on this topic). By any analysis, there is ample evidence that ongoing trout stocking has serious consequences for mountain yellow-legged and Cascades frogs. 

The letter-writer also ignores the evidence that the majority of mountain lakes in the Sierra Nevada (and elsewhere) actually harbor self-sustaining trout populations that would likely be negatively impacted by supplemental stocking of hatchery trout. So, in arguing that all mountain lakes in California be stocked with hatchery trout, the letter-writer is unwittingly arguing for policies that would decrease the quality of California's backcountry fisheries. That is hardly a reasonable position to advocate. 

To be productive partners in resolving the "fish-frog" debate, the public needs to make the effort to inform themselves. The best-available science on this issue isn't perfect, but it is by far the most detailed information source collected on the impacts of hatchery trout anywhere in the world. This literature provides a solid foundation for asking the critical questions that all of us interested in this issue should be asking. For example, given that angling is an important activity in California's mountain lakes but that fishless habitat is essential for several amphibian species, (1) what is the appropriate balance between fish and fishless habitat? Assuming that such a balance exists (and I believe that it does), (2) how should that distribution of fish and fishless habitats be achieved? Is a halt to the stocking of critical lakes sufficient? Should gill netting be employed to remove trout from critical habitats? If so, which ones? Should rotenone be used to remove trout from some entire basins? And (3) what role should fish stocking play in the management of California's montane lakes? Which lakes are self-sustaining and do not need to be stocked and which are which ones need to be stocked to maintain important fisheries?

Finding creative solutions to the fish-frog issue will require the informed, open-minded involvement of managers, scientists, and the public. Assertions that trout do not impact amphibians are not supported by the available evidence and hinder any attempts to find those solutions.


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"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.


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"Final" Fish Stocking EIR/EIS Released

On November 7, 2008, Judge Marlette of the Sacramento Superior Court ordered the California Department of Fish and Game (CDFG) to prepare an Environmental Impact Report on the impacts of its fish stocking program. This document was to be submitted "no later than January 11, 2010". That would be today. Rumor has it that the document will be submitted today but no information has yet been posted on the DFG Hatchery EIR-EIS web page. I'm assuming that the document will be available to the public in the next few days. 

As I've detailed in previous posts, this document will guide the CDFG fish stocking program for decades to come. So, it is incredibly important that the EIR-EIS be thorough in the development of measures to mitigate the impact of fish stocking on California's aquatic ecosystems. The draft document was badly flawed in this regard and I'm not expecting that the "final" document will be much better. This just doesn't seem to be the way the CDFG operates. Instead, I suspect that this "final" document will be similarly lacking and that these failings will precipitate further litigation to force the CDFG to get it right. That sure is a screwy way to make policy decisions but for the CDFG it seems more the rule than the exception. My blog posts for the next few weeks will describe the changes that the CDFG made to the earlier draft document in response to input from the public. Stay tuned.


In other news, acting CDFG Director John McCamman has been appointed as Director. Don't expect this to change agency politics. As always seems to be the case, science will generally only be used to guide management decisions when the scientific results are convenient. When it comes to fish stocking impacts, you can bet that the "best available science" is far from convenient.


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The Origin of the Amphibian Chytrid Fungus

One of the most pressing questions related to the amphibian chytrid fungus (Batrachochytrium dendrobatidis - "Bd") is where this pathogen originated from. Unfortunately, we still don't know, but a recently published paper adds an interesting wrinkle to what we do know. Until recently, the available data suggested an African origin. The "Out of Africa" hypothesis was based on the fact that the earliest known record of Bd was from South African amphibians collected in 1938. Under this hypothesis, Bd was spread around the world as a consequence of the large-scale export of African clawed frogs (infected with Bd) from Africa for medical research starting in the 1940s.


Now Goka and colleagues present detailed information on the distribution and genetic structure of Bd in Japan, the first such study for any Asian country. In addition to showing that Bd is widespread in amphibian populations across Japan, the authors also state that Bd was detected on amphibian specimens collected as early as 1902. Furthermore, one of the species infected with Bd is the Japanese giant salamander (Andrias japonicus - shown in photograph), an ancient species that reaches a length of more than 1 m (39") and is apparently not negatively affected by Bd infection. This species was infected with unique Bd strains that were not found on any other Japanese amphibians, suggesting that the Bd-Andrias relationship is the result of a long-term coevolution between pathogen and host. These findings led Goka et al. to suggest that Bd originated in Japan, not Africa.

Additional research will be necessary to validate this conclusion, but the possibility that Bd originated in Asia certainly has shaken up our current thinking on the origin of this pathogen. For now, all we can say with some certainty is that Bd originated somewhere in the world and was subsequently moved around the globe by human activities. 

For details on the Japanese study: Goka, K., J. Yokoyama, Y. Une, T. Kuroki, K. Suzuki, M. Nakahara, A. Kobayashi, S. Inaba, T. Mizutani, and A. D. Hyatt. 2009. Amphibian chytridiomycosis in Japan: distribution, haplotypes and possible route of entry into Japan. Molecular Ecology 18:4757-4774.


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