Impacts of Fish Stocking on Willow Flycatchers - Really?

As opening day for trout fishing season approaches, stories in the local papers often dwell on impending issues that might affect the number of fish stocked and stocking locations. Last year the stories focused primarily on issues surrounding the court order that mandated that the California Department of Fish and Game (DFG) prepare an environmental impact report detailing the effects of its fish stocking program. This year the stories have focused almost exclusively on the concern that the presence of willow flycatchers could preclude fish stocking. All of the media stories that I've read on this issue have failed to provide much context for this issue, focusing instead on how outside environmental groups are to blame for the current "crisis". The following is my attempt at clarifying how the willow flycatcher got wrapped up in the fish stocking issue and what the current DFG plans are related to this species. 

When I read the DFG fish stocking EIR-EIS I was quite surprised to see the willow flycatcher listed as a "decision species" ("decision species" were defined as those species potentially affected by hatchery and stocking programs). My surprise stemmed from the fact that there were no published studies suggesting such impacts on willow flycatchers. Furthermore, the interim court order that was developed jointly by the Center for Biological Diversity, Pacific Rivers Council, and the DFG (the intent of which was to prevent harm to sensitive species while the EIR-EIS was being written) focused only on fish and amphibians (13 and 11 species, respectively). So, how did the willow flycatcher end up in the EIR-EIS as a decision species? 

It turns out that it was the DFG that added the willow flycatcher to the decision species list, and without any prompting from environmental groups or the public at large. The rationale was basically that trout and willow flycatchers both depend on insect prey for a large proportion of their diets. Because the introduction of trout into mountain lakes dramatically reduces the biomass of aquatic insect larvae and the subsequent emergence of adult forms of these aquatic insects, the DFG reasoned that this reduction in adult aquatic insects could reduce prey availability for willow flycatchers. The willow flycatcher was on the DFG "radar screen" because it is listed as "endangered" under the California Endangered Species Act. 

The possibility that trout stocked into aquatic ecosystems could affect adjacent terrestrial ecosystems is a fascinating area of ecological study, and recent research in the Sierra Nevada shows that stocked trout have in fact altered the distribution and foraging habits of the Gray-crowned Rosy-Finch, one of the few species that nests in the alpine zone. This soon-to-be-published study provides evidence that trout-containing lakes had 98% fewer mayflies than did neighboring fishless lakes, and that Rosy-Finches were six times more abundant at fishless lakes than at fish-containing lakes as a result (mayflies make up a significant fraction of Rosy-Finch diets during the emergence period). However, it is a stretch to extend these Rosy-Finch findings to willow flycatchers, but that is exactly what the DFG did. 

In the EIR-EIS the DFG suggested that impacts of trout on willow flycatchers were possible, and proposed to mitigate these impacts by conducting a "pre-stocking evaluation" at each mountain lake that receives hatchery trout and that lies within the range of the willow flycatcher. As stated in the EIR-EIS (page 4-100), "Under the protocol, each stocking location shall be evaluated in a stepwise fashion to determine whether interactions between stocked trout and willow flycatchers may occur and to evaluate the potential for trout stocking to result in an (sic) substantial effect on willow flycatchers. If such an impact is determined likely, then DFG shall either cease stocking at that location or develop and implement, prior to stocking at that location, an ABMP". (ABMP = Aquatic Biodiversity Management Plan).

With the EIR-EIS finalized in January of this year, the upcoming opening of the trout fishing season is the first in which all fish stocking is required to meet the guidelines specified in the EIR-EIS. The range of the willow flycatcher includes the eastern Sierra Nevada so technically no lakes can be stocked in preparation for the season opener unless a pre-stocking evaluation for willow flycatchers has been conducted, and until a few weeks ago no such evaluations had been conducted for stocked waters anywhere in California. And how can evaluations be conducted when most mountain lakes are still surrounded by snow and it will be weeks before willow flycatchers arrive to breed? The DFG has been scrambling to figure this out and the ensuing confusion has generated a slew of rumors, including how the Center for Biological Diversity forced the DFG to include the willow flycatcher in the EIR-EIS and how the willow flycatcher is being used as an excuse by bureaucrats in Sacramento (including DFG bureaucrats, in some version of the rumors) to shut down the fish stocking program. That these rumors have little basis in fact has not stopped the local media from reporting and elaborating on the rumors and innuendo. 

So, here is my take on all of this. While I applaud the DFG for acknowledging that fish stocking impacts likely extend beyond the water's edge and can in some cases impact songbirds and other terrestrial predators, it is ill-advised to change fish stocking management without a scientific rationale. There are no data suggesting that willow flycatchers are negatively impacted by fish stocking. The current lack of evidence certainly does not indicate that no such impacts are occurring, but the lack of any scientific evidence makes designing effective mitigation essentially impossible. I would have much preferred a more cautious approach in which the DFG acknowledged the potential for impacts of fish stocking on willow flycatchers and committed to studying the issue over the next year. Subsequent management actions and mitigation could then have been designed based on the results of the accumulated evidence.


I never thought I would criticize the DFG for being overly aggressive in developing mitigation strategies to reduce impacts of fish stocking. Go figure.

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Lawsuit Update and Other Legal Intrigue

In my last post I mentioned that in addition to the fish stocking lawsuits recently filed by the Center for Biological Diversity and the Owens Valley Committee I'd heard rumor of a third lawsuit. That rumor has now been substantiated. It was filed by Californians for Alternatives to Toxics, the Environmental Protection Information Center, Wilderness Watch, and Public Employees for Environmental Responsibility. Their petition focuses on many of the same issues covered by the other two petitions, including use of an improper objective, improper baseline against which impacts were evaluated, inadequate range of alternatives, and failure to adequately mitigate impacts of fish stocking. In addition, the petitioners argue that the practice of stocking fish into designated wilderness areas violates provisions of numerous laws related to wilderness.

On a somewhat different topic, on March 3 the California Fish and Game Commission is scheduled to vote on a petition to list the California Tiger Salamander as "threatened" under the state Endangered Species Act. This will be an interesting vote given its potential to put into place additional protections for this species, and also for what it will tell us about the likelihood that the Commission will vote to list the mountain yellow-legged frog under the California Endangered Species Act. The effort to list the California Tiger Salamander under the state Endangered Species Act is quite a twisted tale, with the Commission rejecting the original 2001 petition, rejecting a subsequent 2004 petition, this decision being overturned by the Sacramento Superior Court, the Commission appealing the court's decision, and the 2008 decision by the Third District of the California Court of Appeals upholding the original Superior Court decision. Now, almost 10 years after the original petition was filed, the Department of Fish and Game is recommending to the Commission that the species be listed as "threatened". For more information on this issue, click here.

The information upon which the latest petition is based is essentially unchanged over the decade since the original petition was filed, so why all of the legal contortions to prevent the listing? Delaying the inevitable seems to be the name of the game. It doesn't make for good policy, but it does make for good politics for those whose sympathies lie more with unbridled economic development than with the fate of this inconspicuous salamander that spends its life in and around vernal pools in California's grasslands. 

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Déjà Vu - Lawsuits Filed Against DFG Over Fish Stocking Document

The California Department of Fish and Game (DFG) released their court-mandated fish stocking EIR-EIS on January 11, 2010. In response, at least two groups (and I've heard rumor of a third) have filed separate court petitions against the DFG. The Center for Biological Diversity petition focuses broadly on a wide variety of deficiencies in the EIR-EIS, including a flawed baseline against which environmental impacts were judged, failure to include an adequate range of alternatives, and the failure to adopt reasonable mitigation measures. The Owens Valley Committee petition focuses more specifically on groundwater withdrawals that supply two fish hatcheries in the Owens Valley and the failure of the EIR-EIS to adequately mitigate the associated impacts.

And so the legal wrangling begins anew. The DFGs strategy on fish stocking -related CEQA issues has always been to frame the issue as narrowly as possible. For years, that meant denying that fish stocking was subject to CEQA. They got away with that for 35 years. When an environmental group with sufficient guts (Center for Biological Diversity) finally called the DFG bluff and sued them in court, the DFG arguments were finally revealed for what they were - a house of cards. But unable to abandon their tired strategy, the EIR-EIS was written as a defense of the current fish stocking program instead as a thorough evaluation of the environmental impacts the program has caused. This failure reeks of a DFG leadership unwilling to take the inevitable political and public flak and lead. 

The DFG public response to the petitions so far has been a predictable plaintive whimper of "but we've already spent so much money on the EIR-EIS". Instead of complaining about how much money the EIR-EIS process is costing, the DFG should realize for once and for all that hijacking the CEQA process to justify a pre-ordained conclusion will not fly. Perhaps someone within the DFG will raise the obvious point that many of the complaints raised in the recently-filed court petitions were also raised by the DFG-appointed EIR-EIS Scientific Advisory Team. Those concerns were summarily dismissed by the DFG but are now coming back to haunt them.

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California Endangered Species Act Petition is Filed

On January 11, 2010, the California Department of Fish and Game (DFG) released their badly flawed fish stocking EIR-EIS. In response to the failure of the EIR-EIS to put into place provisions to adequately protect the imperiled mountain yellow-legged frog from impacts caused by hatchery trout, on January 25 the Center for Biological Diversity petitioned the California Fish and Game Commission ("Commission") to list the mountain yellow-legged frog as "endangered" under the California Endangered Species Act (CESA).

The CESA is similar to the federal Endangered Species Act in most regards but the CESA is administered by the DFG. The DFG now has 90 days to recommend to the Commission whether the petitioned action may be warranted. If so, the DFG has 12 months to prepare a report for the Commission, based on the best scientific information available, which indicates whether the petitioned action is in fact warranted. The Commission then makes it final decision soon thereafter. So, it will be more than a year before the petition makes its way through the process, a process that I suspect will be full of twists and turns. This could get interesting. 

Additional details on the petition process are provided in Fish and Game Code Section 2070-2090. The mountain yellow-legged frog CESA petition is available on the Center for Biological Diversity web site.

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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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Fish Stocking EIR/EIS - Part 5

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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Fish Stocking EIR/EIS - Part 4

The DFG trout stocking program currently introduces millions of fingerling, sub-catchable, and catchable trout into lakes and streams throughout California with the goal of improving existing fisheries. In addition to stocked trout, recipient habitats typically also harbor native trout populations or established non-native populations, with the latter having become established following earlier stocking efforts (both are referred to here as “resident” populations). In light of the fact that numerous studies have indicated that trout stocking has the potential to impact these resident trout populations and thereby negatively affect fishery quality it is ironic that the EIR-EIS fails to analyze stocking impacts on recreational trout fisheries.

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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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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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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Fish Stocking EIR/EIS - Part 1

As stated in last week's blog post, the California Department of Fish and Game (CDFG) recently released their draft fish stocking EIR/EIS to the public. Comments are due on November 16. When the CDFG was ordered by the court to conduct this environmental analysis I had some hope that the CDFG would use this as an opportunity to fully evaluate their current stocking program and make changes that would benefit native wildlife (e.g., native amphibians and fish) and improve fisheries. Unfortunately, a read of the document's objectives statement indicates that this environmental analysis was largely an effort to justify the current fish stocking program. The objectives statement (page 5) reads, "The fundamental objectives of DFG’s Program are to continue the rearing and stocking of fish from its existing hatchery facilities for the recreational use of anglers, for mitigation of habitat loss attributable to dam construction and blocked access to upstream spawning areas, for mitigation of fish losses caused by operation of the state‐operated Sacramento–San Joaquin River Delta pumps, and for conservation and species restoration."

This objectives statement ignores abundant evidence that the stocking of trout and salmon can actually have negative effects on the resident fishery. For example, stocking of "catchable" trout into streams results in high levels of competition between stocked and resident trout. The end result is often a reduction in the total number of trout present. Similar problems beset stocking of salmon species. Given an abundance of these sorts of findings it is not at all clear that fish stocking is always the preferred means of providing recreational angling opportunities or that stocking can in fact mitigate for habitat loss caused by dams. As such the objectives statement in the EIR/EIS indicates the CDFGs interest in continuing the current stocking program regardless of whether some aspects of that program actually have negative effects on fisheries.

I would have liked to see an objectives statement such as the following: "To provide a stocking program that supports diverse anadromous and inland salmonid fisheries and protects native species and natural resources from adverse impacts from stocking." This statement makes it clear that fish stocking is a management tool that would be used when necessary to improve fisheries. I proposed this objectives statement to the CDFG some months ago but obviously my suggestion fell on deaf ears.

Given the flawed objectives statement upon which the EIR/EIS is based it is little surprise that the environmental analysis supports the continued fish stocking program with few meaningful changes. Next week I'll discuss the CDFGs flawed evaluation of fish stocking impacts.

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Another Field Season has Come and Gone

My 2009 summer field season ended in late September. Now weeks later all of the research gear is put away and the data is safely in my lakes database. The summer went largely as expected, with some notable successes and some unanticipated challenges. Below I've provided a summary of what our summer objectives were and what we actually accomplished. But first a sad note....

This summer I lost a close friend and fellow field biologist. On August 30, Jeff Maurer died in a climbing accident while ascending Third Pillar on Mt. Dana. Jeff had worked in Yosemite National Park since 1988, studying Peregrine Falcons, Great Gray Owls, and Northern Goshawks. In 2006 he took on the task of leading Yosemite's new lake restoration program, and in that capacity he directed fish removal efforts in numerous key locations around the Park. These efforts will continue, of course, but Jeff's infectious enthusiasm and unmatched dedication to this restoration effort will be sorely missed. He was truly one-of-a-kind. For stories about Jeff, check out http://yosemite-jeffmaurer.blogspot.com/.

So, what did we set out to do this summer? Our research team (me, Cherie Briggs, Vance Vredenburg, Erica Rosenblum, and more than a dozen field and laboratory assistants) had two primary objectives. The first objective follows from our field observations that after the arrival of the amphibian chytrid fungus (Batrachochytrium dendrobatidis - "Bd") at a site most mountain yellow-legged frog populations decline to extinction but a few persist despite the disease, albeit at markedly lower densities. There are several potential explanations for these different disease outcomes, including inherent differences in frog susceptibility to chytridiomycosis (the disease caused by Bd) or differences between Bd strains in their virulence. So this summer we conducted a laboratory experiment to evaluate the relative roles of these two factors in driving different disease outcomes (frog population persistence versus extinction). We hope to wrap up the experiment by December.

Our second objective was to use a field experiment in which mountain yellow-legged frogs are cleared of Bd to determine whether this treatment influences the outcome of Bd epidemics. Frogs were treated with an anti-fungal drug at three lakes in each of two basins located in Kings Canyon National Park. Frog populations in both basins had suffered catastrophic declines in the past four years following the arrival of Bd, and without intervention it is likely that these frog populations would have been extinct within another couple of years. It will be 1-2 years before we have any definitive results but for now, suffice it to say that we were able to significantly reduce Bd loads on frogs in the field and this treatment dramatically improved frog survival. I'm hopeful that such frog treatments may provide us with an important conservation tool in the future, but we still have lots of unanswered questions that need to be addressed. I'll provide further updates as the results come in.

Finally, the California Dept. of Fish and Game (CDFG) released a draft fish stocking EIR/EIS to the public on September 25 (available from the CDFG web site). Comments on the draft document are due to the CDFG by November 16. Given that this document will guide CDFG fish stocking practices for many years I encourage everyone interested in this issue to read the EIR/EIS and provide comments to the CDFG. I'm still working my way through the 8 chapters and 12 appendices but it is clear that there is lots of room for improvement. I'll provide additional details on this document in upcoming blog posts. Stay tuned....

Now that I'm back behind my desk I'll be posting new Frog Blog entries every Monday morning. I hope you find them interesting and informative.

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