Mr. Jim Starr
California Department of Fish and Game
830 S Street
Sacramento, CA 95811

RE: Comments of California Trout on the California Department of Fish and Game Hatchery and Stocking Program Draft Environmental Impact Report/Environmental Impact Statement

Mr. Starr:
California Trout (CalTrout) appreciates the opportunity to provide comments regarding the Department of Fish & Game Hatchery and Stocking Program Draft Environmental Impact Report/Environmental Impact Statement (DEIR). CalTrout believes this issue deserves due attention and appreciates the Department’s work to address this important issue.

CalTrout has and continues to support the role of hatcheries and the State’s stocking program. We have worked with the Department to ensure resources are available for hatchery production as well as working with legislators in Sacramento to pass policy supporting hatcheries throughout the state. Most recently, we supported the passage of Assembly Bill 7 that, among other measures, calls for progressive hatchery reform.

CalTrout also recognizes that stocking hatchery produced fish can serve to offset angling pressures and in doing so, help to ensure more delicate fisheries are not over-fished to the detriment of the systems themselves. Lastly, CalTrout acknowledges that along with a mandate to protect and restore fisheries in the state, the Department is also tasked with helping to ensure angling opportunities are made available to the populace to the extent possible. Balancing these two mandates is challenging to be sure.

A comprehensive review of hatcheries, stocking practices and their potential impacts, be they positive or negative, on California fisheries is an important step towards ensuring both the health of California fisheries as well ensuring angling opportunities. The DEIR is a step in the right direction. However, while CalTrout supports the need and benefits that hatcheries provide, CalTrout believes that a more robust, comprehensive and thorough evaluation of hatcheries and their role on the span of fisheries throughout the state is warranted.

In general we support the following recommendations when considering hatcheries and hatchery reform:

• Develop a statewide hatchery policy that has as its first goal protection of wild populations of fish, rather than enhancing fisheries.

• All hatchery fish should be marked and mark-ive fisheries instituted.

• Hatcheries should be used as a progressive management tool.

• Provide details and opportunities for the public to comment on Stocking Plans and Hatchery Genetic Management Plans.

• All facilities should have a monitoring plan, genetic management plans, clear production goals and clear mechanisms to adjust goals and operational guidelines if necessary to provide data on benefits and impacts.

• Build out hatchery program to include the use of more native California species, following tenets of AB 7.

Our more specific comments on the DEIR follow:

Wild Trout Management: Hatcheries as a Tool not a Purpose
Our primary concern is the limited scope of DEIR. The stated purpose of the DEIR is “to continue rearing and stocking fish from existing hatchery facilities for recreational anglers.� This self fulfilling purpose compromises the document from the beginning. The DEIR misses an opportunity to analyze progressive measures for managing California’s trout waters and hatchery facilities. Wild trout management, with its emphasis on fishing regulations and protecting and restoring habitat, has been a proven model of fisheries management in other western states. The EIR should analyze wild trout management as an alternative to stocking and as a means of sustaining trout populations. Hatcheries are only one means of sustaining
fisheries and are often far from the cheapest or least-harmful way to do so.

Limited Project Alternatives
Limited Project Alternatives were considered. CalTrout believes the three Alternatives considered represent a narrow array of potential alternatives and additional alternatives should be considered and addressed in the revised DEIR. The requirement set forth by the California Environmental Quality Act (CEQA) to analyze impacts of alternatives within an EIR is crucial to CEQA’s mandate to fully inform the public of actions taken by public officials.

Only three Alternatives were considered:

Project Alternative 1No Action/No Project. This is baseline conditinos with no changes to past operations.

Project Alternative 2—Continue to stock fish as in the past five-years and stock based on new fish guidelines. This alternative is the Department’s preferred alternative and is similar to Project Alternative 1 with the caveat being new guidelines and the development and implementation of Hatchery Genetic Management Plans.

Project Alternative 3—No stocking would occur within the range of the 25 sensitive native species noted.

The DEIR should analyze effective wild trout management as one alternative to meeting one of the stated goals of conservation and species restoration. Included in consideration of additional alternatives, the Department should consider what the implications would be if there were no hatcheries and stocking programs. In some instances Wild Trout and anadromous waters may in fact be improved as a result of halting stocking programs.

One such example is Hot Creek, located in the Eastern Sierra. At one time, Hot Creek was regularly stocked but has not been now for several years. Anecdotal evidence as well as recent fish population studies conducted by the Department’s Wild and Heritage Trout Program staff suggests the Hot Creek fishery is in at least as good a condition, if not better, compared to when it was stocked. To be sure, scientific review to confirm this is warranted. However, there are other examples which have been well documented and which conclude that a fisheries post-stocking has improved using varying metrics. CalTrout’s point here is that an analysis of wild and native trout waters with respect to the Department’s hatchery and stocking program should be conducted.

Another opportunity exists in the Klamath River to explore the potential benefits of the cessation of stocking. In the National Academy of Sciences Endangered and Threatened Fishes in the Klamath River Basin: Causes of Decline and Strategies for Recovery (2004, see pages 303-304), it is acknowledged that stocking operations on the Klamath River are not well understood but are likely having an negative impact on Chinook and coho salmon populations. The recommendation is made to conduct an experiment by
shutting down Iron Gate Hatchery for 6-8 years while stocking practices continue at the Trinity River Hatchery. This paired analysis could allow for comparisons to be made. Such a large-scale, adaptive management based experiment could provide useful information if accompanied by adequate monitoring of juvenile and adult populations.The authors also recommend an ecological risk analysis be conducted, especially for coho salmon. If these efforts conclude hatchery operations result in a net loss of wild salmon, hatchery operations should be discontinued.

Sensitive Species
CalTrout agrees that emphasis should be place on our most sensitive native species. Perhaps nowhere in the world is the diversity of salmonids and their problems more evident than in California. The state not only marks the southern end of the range of all anadromous species, but its dynamic geology and climate has resulted in the evolution of many distinctive inland forms, such as the three golden trout subspecies of the Sierra Nevada. Fragmentation, genetic drift, and isolation by distance, owing to very low levels of migration, and/or hybridization with hatchery fish are the major forces shaping genetic diversity within and among California populations.

The DEIR proposes resuming stocking in water with sensitive species on a case-by-case basis, as soon as a plan is developed for “minimizing� harms to native species from stocked fish. But the DEIR provides almost no detail about what these plans will contain. The DEIR should provide this detail up front, or else confirm that the specific plan for each water will, once developed, be released for public review before stocking resumes on that water.

Recreational Fisheries and Wild Trout Waters
While we appreciate the focus on sensitive species, the lack of analysis on the potential effects of hatchery stocking on all California’s wild and native trout waters is given short thrift. Many of California’s premier recreational fisheries rely on a combination of effective fishing regulations and healthy habitat to support some of the most well-known fisheries in California such as the Lower McCloud River and Fall River. We believe it is critical to scientifically understand how stocking programs may be influencing significant trout waters that are providing so many opportunities for angling state-wide.

Hatchery Genetic Management Plans
Guidelines for developing Hatchery Genetic Management Plans (HGMP), which are intended to provide “pre-stocking evaluation protocol(s)� as well as process oriented details, are severely lacking. This information should be included in the DEIR enabling a more fundamental and comprehensive understanding regarding what is being proposed. Five Draft Hatchery Genetic Management Plans are on the DEIR website, but not all of them. When CalTrout called/emailed about the Iron Gate Hatchery Plan, we were told the draft plan was not available for comment.

DFG's preferred alternative is Alternative 2: Continue to Operate Hatcheries as in Past Five Years and Stock Fish Based on New Guidelines. According to DFG, "this alternative provides guidance that will be followed throughout DFG to address the impacts described within the current Program as the No Project/No Action alternative. New guidance was developed by DFG to minimize impacts associated with the current trout stocking program, and DFG will rely on the process currently underway to prepare and implement Hatchery Genetic Management Plans (HGMP) for each of the anadromous fish hatcheries." This basically punts any stocking and hatchery management changes to a non-public process (HGMPs) and allows DFG to make changes in current hatchery management that may be incredibly detrimental to wild salmon without taking public comment on the exact changes in hatchery management. A public process for review of the Hatchery Genetic Management Plans should be instituted.

The DEIR clearly indicates that DFG will rely on "processes currently underway" and a couple of sentences later adds that these processes have "potentially significant adverse impacts" (page 7-8 of the Executive Summary), yet no way is given to asses those processes as regards to Iron Gate Hatchery and others as there is no draft of the Iron Gate Genetic Management plan. The Department has indicated that the plan is not complete and won't be available for review within the DEIR. We believe this is a flaw in the DEIR since it merely refers to "operations" without defining what those operations might be.

We underscore the importance of the HGMP’s in maintain viable fish populations. In a recent study, Carry-over effect of captive breeding reduces reproductive fitness of wild-born descendents in the wild a significant negative effect was detected on the survival of wild descendents of hatchery fish. The reduced fitness of captive bred fish has long been recognized, but this study shows reduced fitness by fish that are progeny of hatchery fish born in the wild. This carry-over of reduced fitness to wild descendents has been shown to have a negative influence on wild fish population size. This underscores the need to have HGMP’s that are peer reviewed and incorporate recent genetic and fishery management information.

In addition to the lack of transparency and due process supporting HGMPs, CalTrout does not understand the logic behind limiting such plans to anadromous species. Inland trout genetics are equally complex and implications for stocking on genetic integrity is critical to maintaining robust populations.

Mitigation Measures
Table ES-2 focuses on potentially significant impacts requiring mitigation measures. Similar to there being a lack of comprehensive analysis for Project Alternatives, there is also a paucity of depth and detail with respect to proposed mitigation measures. For example, BIO-123-Distribution of invasive species by anglers as a result of the trout program states the mitigation measure is simply to “educate anglers to control invasive species.� This strategy to address the potential threat from invasive species is simply inadequate and falls short of what needs to be done to address such a vast threat to California’s fisheries.

One objective of a stocking program is to attract anglers to particular locales. Indirectly, therefore, stocking creates incentives to fish certain bodies where fish are thought to be more plentiful. In many such locales, boat and various float vessels are used and are viable vectors for invasive species transfer. Education about the issues surrounding invasive species is simply not enough. Instead, a more comprehensive mitigation measure would include guidelines and protocols for boat inspections. This is one example of how the DEIR insufficiently addresses at least some mitigation measures.

All mitigation facilities should be REQUIRED to pay for all marking of hatchery fish as well as monitoring necessary for measuring benefits, impacts, etc. (including, but not limited to: survival rates, harvest rates, straying rates [for anadromous fish], and impacts on naturally produced fish such as competition, predation, disease transmission, and superimposition).

CalTrout Policy
We offer the following CalTrout policy for the management of California’s wild trout resources and the use of hatcheries:

1. Those waters that currently have self-sustaining wild populations of trout should be managed as de-facto wild trout waters. Do not plant lakes that are self-sustaining fisheries. Do not plant non-native fish above native populations of native trout or other native fish.

2. Decisions about resource management should be made on a lake-by-lake or stream-bystream basis. Decisions should take into account the historical and current value of the fishery as well as the environmental costs of maintaining that fishery. Of particular value is the identification and preservation of wilderness wild trout streams.

3. Appropriate angling regulations should be applied to optimize theses fisheries. The goal is a stable, sustainable population with an appropriate mix of age classes for the specific lake or stream. The blanket application of standardized regulations should be discouraged.

4. Those waters that have historically provided angling opportunities and in which there is sufficiently abundant production of food, but which are otherwise incapable of containing self-sustaining populations, should be considered for put-grow-take fisheries.

5. Waters with the potential of growing "trophy" sized fish, should be managed without planting if possible, or reduced frequency of planting, so that a high quality, rather than quantity, fishing experience is encouraged.

6. Other waters, with marginal ability or no ability to sustain fish in high population areas or
close to trailheads, should be considered as managed fisheries to provide recreational activity and should be so designated as “Trout Parks�.

7. Further research is needed on Sierra fisheries so that angling opportunities can be properly cataloged, impact of fish on other species minimized, and higher quality angling experiences promoted.

Conclusion
CalTrout appreciates the opportunity to comment on the Hatchery DEIR. We believe this analysis and process will lead to improved management of our states wild trout, salmon and steelhead fisheries. We appreciate the Department’s efforts.

We also believe an opportunity is being missed to take a more progressive and comprehensive look at the way we manage our states fisheries. The scientific literature is replete with examples of hatchery operations reducing the fitness of wild stocks. We believe more emphasis should be placed on wild trout management as the primary means of sustaining wild trout, salmon and steelhead populations in California.

Sincerely,
Curtis Knight
California Trout