rayfound wrote:The thing that I find interesting about this whole debate, is that, we, as flyfishers are concerned about kern river rainbows, and the detriment stocking causes to their genetic purity. The EIR and the lawsuit was all about protecting the Hardhead minnow - KRRs were never a concern.
KRR have not been fully identified. A genetic study funded by the Edison Fisheries Enhancement Trust, aka KRRP, is being done by UC Davis. The study did find what they believe to be geneticly pure and distinct strain up in the headwaters and their final report is due literally anyday. If you read my SSFF EIR comment letter, attached below, I pushed the DFG on the Kern River Rainbow and pushed hard for the KRRP to be completed. The KRFF sent off an almost identical letter.
The KRR up to Kern Falls are hybrids now due to stocking. The KRRP is not a full restoration but eventually only native strains will not be stocked above Fairview Dam.
shane
Jim Starr
California Department of Fish and Game
830 S Street Sacramento, CA 95811
SUBJECT: Draft DFG Hatchery & Stocking Program EIR/EIS comments State Clearinghouse #2008082025
Dear Mr. Starr,
The Southern Sierra Fly Fishers Club (SSFFC) wish to present the following comments for the record involving the Draft Department of Fish and Game Hatchery Environmental Impact Report and Environmental Impact Statement. The SSFFC is headquartered in Kernville, California, the gateway to the Southern Sierra and Golden Trout Wilderness. This nonprofit club with 120 members from several regions of California promotes the awareness, the art and skills of fly fishing, and the conserving of our natural resources.
The SSFFC also would like to stress that the economic impact of the approved EIR/EIS will be significant, no matter the outcome, to the Kern River Valley’s economy due to the fact there are no other local places for people to fish and we encourage the decision makers to think locally as well as county and statewide.
We endorse Preferred Alternative #2 in the draft EIR hoping that the EIR/EIS will be approved and stocking of hatchery-raised trout be resumed in the Kern River, below SCE's KR3 Fairview Diversion Dam. However, we have concerns on the effect of resumed stocking on the native Kern River Rainbow Trout above Fairview Dam. We’d like to see the proposed program known as the Kern River Rainbow Project included in the preferred alternative 2. If only native strain Kern River Rainbow were planted in sections 6-7 above Fairview Dam and nonnative below the dam until the program can supply the entire river, it would be a boost to this CDFG designated HeritageTrout species by mitigating further hybridization from nonnative stocks. Plus, it would help attract fisherman to the Kern River Valley. This would be an economic boost to the local merchants who rely on fishermen as a major source of their economy by attracting visitors to a possible trophy fishery. It would also help the CDFG hatchery operations meet mandates within Assembly (AB) 7 regarding the Heritage and Wild Trout Program, noted in EIR chapter 1, and help avoid future lawsuits.
The Kern River is our home water and it does not make sense to have the stocking ban or only one alternative picked for an entire 85 mile river. The river has several different ecosystems, both natural and artificial from dams and diversions where different species live and thrive. Listed below are the SSFFC’s preferred alternatives along with an endorsement of proposed DFG Trout and Inland Salmon Stocking Evaluation Protocol figure K- 1 to be used for evaluation of stocked waters.
Preference of EIR/EIS Alternatives by Section of River
Kern River Sections
0 (Below Kern River No. 1 powerhouse (KR1)) – ALTERNATIVE 1 (this section was not previously stocked)
1 KR1 to Democrat Dam – Alternative 1 (this section was previously stocked)
2 Democrat Dam to Borel Powerhouse (Sandy Flat) - Alternative 1 (this section was previously stocked)
3 Borel Powerhouse (Keysville Bridge) to Main Dam - ALTERNATIVE 1 (this section was not previously stocked)
4 Lake Isabella (Riverside Park, Kernville) to Kern River No. 3 powerhouse (KR3) - Alternative 1 (this section was previously stocked)
5 KR3 to Fairview Dam - Alternative 1 (this section was previously stocked)
6 Fairview Dam to Johnsondale Bridge – Alternative 2 using CDFG Stocking Evaluation Protocol Figure K-1
7 Above Johnsondale Bridge - Alternative 2 using CDFG Stocking Evaluation Protocol Figure K-1
8 South Fork Kern River - Alternative 2 using CDFG Stocking Evaluation Protocol Figure K-1
Comment on specific EIR comments
EIR Chapter 1 Introduction (page 2)
DFG determined that, as part of its analysis of ongoing fish stocking, it would also include an evaluation of the fish stocking mandates included in Assembly Bill (AB) 7, passed by the State legislature in 2005 and included in the California Fish and Game Code (CFGC) as Section 13007. This section of the CFGC mandates that one third of the fees collected from the issuance of sport fishing licenses be deposited into the Hatchery and Inland Fisheries Fund (HIFF) and used for the management, maintenance, and capital improvement of California’s fish hatchery facilities, the Heritage and Wild Trout Program, other sport fishing activities, and enforcement of these activities.
We believe the Kern River Rainbow Project will help the CDFG hatchery operations meet mandates within Assembly (AB) 7 regarding the Heritage and Wild trout Program.
EIR Chapter 4 (116-117) Effects of Anglers at fishing sites
Recreational fishing activity may deliver a variety of potential impacts on native fish or wildlife or to sensitive ecosystems.
We agree and emphasize that the 2008 stocking ban has led to a direct effect of increasing pressure on the native Kern River Rainbow trout on the North Fork Kern River above Johnsondale Bridge, section 7. Many reports come in from club members who frequent this special regulations section about a huge increase of conventional anglers and an increased harvest of native fish. The CDFG does not have the budget to patrol the backcountry and the current regulations are confusing to anglers and many keep more than the legal limit. We’d like to see the problem of over harvest of the native Kern River Rainbow Trout mitigated through resumed stocking below Fairview dam. Lake Isabella has been stocked for decades with nonnative fish that move upstream to spawn and find cooler water so nonnative strains cannot be removed from this section of river. This will also help mitigate the financial losses of local merchants who depend on fishermen showing up to fish.
Alternatives Considered and Eliminated from Detailed Discussion in the EIR
Eliminate Trout Stocking in Flowing Waters Chp 7 (page 5-6)
This 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 flowing waters in California.
Although this alternative was eliminated, the current stocking ban has led to a direct effect of increasing pressure on the native Kern River Rainbow trout on the North Fork Kern River, just as the CDFG feared. The number of anglers in the Wild & Scenic sections 6-7above Fairview Dam has exploded since the ban due to the depletion of stocked fish in the lower sections and has resulted in an increased harvest of native fish. The CDFG does not have the budget to patrol the backcountry and the current regulations are confusing to anglers. We’d like to see these problems mitigated through resumed stocking below Fairview dam, an artificial barrier with no fish ladder, until the Kern River Rainbow Trout program can provide the entire river’s stocked fish.
EIR Chapter 4 (page 69)
Impact BIO43: Predation and Competition Effects from Stocked Trout on Kern River Rainbow Trout (Less than Significant)
CDFG believes that wild Kern River rainbow trout in stocked reaches of the Kern River (waters downstream of Johnsondale Bridge) represent hybrid fish due to the legacy of past interbreeding between stocked and wild fish. The remaining range of non hybridized Kern River rainbow trout lies above impassable falls in the upper Kern River drainage, 30 to 60 miles upstream of the stocked reaches. Studies, in progress, of the genetic status of Kern River rainbow trout indicate that the trout least affected by genetic mixing with non native rainbow trout, and therefore of greatest conservation value, are those located in the Kern River and portions of select tributaries located in the Golden Trout Wilderness and Sequoia National Park more than 30 miles upstream of the stocking locations on the Kern River. These upper basin Kern River rainbow trout are no longer affected by stocking hatchery rainbow trout. As a result, the current trout stocking program does not have the potential to result in predation and competition impacts on Kern River rainbow trout, and such impacts are less than significant.
We agree with this point that the Kern River Rainbow have been hybridized between Fairview diversion dam and Kern Falls but even though these fish may be hybrids, they are naturally reproducing and a fish has to reproduce to become a hybrid! We would like to see this hybridization mitigated through completion of the Kern River Rainbow Project. Furthermore the EIR states section 6 and 7 of the Kern River are only rated a 2 in hatchery dependence. So if the ban is lifted why continue to stock with nonnative strains that can further deplete the native Kern River Rainbow gene pool in their natural range?
Impact BIO29: Predation and Competition Effects from Stocked Trout on Hardhead (Less than Significant)
GIS analysis indicates that there are 67 trout stocking locations within the range of hardhead (Figure 4‐45). Reeves (1964, in Alley and Li 1977:27) speculated that rainbow trout and hardhead compete for food. However, a subsequent field study (Alley and Li 1977) showed differences in microhabitat use and found no behavioral interactions between the two species. Additionally, competition for spawning space with stocked hatchery species is unlikely, due to non‐overlapping spawning periods and differing temperature requirements for trout and hardhead. There is no evidence of hatchery trout predation on hardhead. Hardhead have been observed to co‐occur in the Kern River where nonnative rainbow trout have been stocked in waters occupied by hardhead for 70 years with no perceived impacts upon hardhead (Cassity 2008). Because the hardhead and stocked trout use different microhabitats, and there is no evident prey on hardhead, effects of predation and competition from stocked trout are less than significant.
We agree that the impact is less than significant. Furthermore, the Southern Sierra Fly Fishers would like the final EIR to recognize the 2009 study entitled Hardhead and Trout in the Kern River, February 27, 2009, by Christine L. McGuire. This is a biological study of the interaction between the hardhead minnow and Kern River rainbow trout. The hardhead minnow is the native species of concern in the Kern River listed in the November 24, 2008 lawsuit brought against CDFG by the Center for Biological Diversity and the Pacific Rivers Council. Ms McGuire is the CDFG Associate Biologist located at the Kernville Hatchery and is one of a number of CDFG officials who are responsible for providing scientific and regulatory oversight over the populations of fish in the Kern River. This study employs 4 decades of fish studies in the Kern River conducted by the California Department of Fish and Game, California Regional Water Quality Control Board, University of California Davis, and Southern California Edison.
McGuire states that “There were no studies identified which indicated predation of hardhead minnow by rainbow trout. Optimal temperatures for rainbow trout are 12-18 degrees Celsius while hardhead prefer water in excess of 20 degrees Celsius. In riverine situations the hardhead tend to feed from the bottom third of the water column and prefer calmer waters, whereas rainbow trout tend to feed from riffles and the surface, in swifter waters.”
In significant conclusion the McGuire study found that: “since stocking has remained a constant since the early 1930's, and prior to that native trout evolved concurrently with hardhead, there is no indication that stocking hatchery trout is associated with fluctuation in the population of hardhead. The years when the hardhead population was robust and extended well into the normally colder reaches of the upper Kern would seem to indicate that stocking hatchery trout is not associated with detrimental effects on hardhead.” In short, the minnow and trout occupy completely different parts of the river. The hardhead minnow lives in slow, warm waters and the trout live in fast, cold waters. We find it highly doubtful that either species will ever be a significant predator on the other. We encourage CDFG and the court to use the good science available in the McGuire study to put to rest any concerns that the hardhead minnow is in any way impacted by stocking trout in the Kern River.
Chp 7 (pages 3-5) Alternatives
Input from the Public Scoping Process: Chp 7 (page 3)
Suggestions for changes in the Program made during the public scoping process also played a role in developing alternative hatchery and stocking management strategies. These suggestions are listed below.
-Consider the possibility for smaller, watershed‐based hatcheries that would repopulate local stocks of rainbow trout, steelhead, and salmon.
The Kern River Planting Base/hatchery with upgrades can be used for these purposes by raising native strain Kern River Rainbow Trout, Little Kern Golden Trout, and California Golden Trout.
Stocking practices: Chp 7 (page 3)
-Emphasize fish planting in water bodies where fisheries would be self‐sustaining but where fishing pressure exceeds natural productivity.
-Plant native fish species rather than introduced species where streams allow for reproduction and self‐sufficient trout fisheries.
-Prohibit stocking of hatchery‐reared fish where fish do not naturally occur.
The Kern River Rainbow Project will both supplement and protect a native fish strain that the EIR says has no conservation value due to hybridization with stocked fish above Fairview Dam up to the impassable Kern Falls 30 miles upriver.
Trout Stocking Chp 7 (page 4)
To address alterations in the genetic make‐up of native trout species due to interbreeding with stocked strains of rainbow trout, eliminate trout planting in waters occupied by native trout populations, or plant triploid trout where necessary to maintain a recreational put and take fishery.
Consider the development of specialty native trout hatcheries to augment existing native trout populations.
-To address declines in native trout populations, in part due to competition for spawning grounds, food and space from hatchery‐reared fish, eliminate trout planting in waters occupied by native trout populations. Consider the eradication of non‐native fish populations in waters within the range of native trout populations.
-To address the impacts of non‐target harvest on native fish species from planting trout, clarify the role of recreational fishing in species management plans and recommend special fishing regulations that minimize risk of non‐target harvest of native species.
We agree and believe that the Kern River Rainbow Project should be a major part of this strategy for the North Fork of the Kern. Fish from this program should be used exclusively above Fairview Dam to help restore the native Kern River Rainbow’s range and to mitigate the hybridization that has already occurred above the dam in sections 6-7.
California Fish and Game Commission Policies
Appendix (page 1) III.
Artificial propagation and rearing of trout is a major Department program, but will be utilized only when necessary to augment natural production. Stocking fingerling and sub catchable sized trout shall take priority over planting catchable sized trout in the hatchery stocking program when the smaller fish will maintain satisfactory fishing. Hatchery trout shall not be stocked in waters where they may compete or hybridize with trout which are threatened, endangered or species of special concern. Exceptions may be made for stocking waters which are not part of a species recovery program.
We support and encourage California Department of Fish and Game to now actively pursue full implementation of the Kern River Rainbow Project which is designed to identify a genetic native rainbow broodstock for propagation to replace the existing nonnative rainbow broodstock for the Kernville hatchery.
Appendix E Biology of Decision Species, Draft CDFG Hatchery EIR/EIS, page E-19
Efforts are being made to identify streams still retaining Kern River rainbow trout and extensive collections of fish for genetic analysis were made 1991–1993. A management plan for the upper Kern River basin (above Isabella Reservoir) was completed in 1995 (Moyle et al. 1995). Problems addressed in the plan include grazing in riparian areas and heavy recreational use of the basin. Population surveys to monitor trout populations and identify habitats in need of protection are scheduled on a five year interval. To reestablish populations of Kern River rainbow trout, anglers are now allowed to keep only two fish with a maximum length of 10 inches in most of the upper basin. The CDFG ultimately plans to replace nonnative rainbow trout stocked in tributary streams with catchable size Kern River rainbow trout if hatchery production of the native trout is successful According to the management plan, if native hatchery production is unsuccessful, stocking of nonnative rainbow trout will stop (Moyle et al. 1995)
The Southern Sierra Fly Fishers support and encourage the California Department of Fish and Game to now actively pursue full implementation of the Kern River Rainbow Project.
Final Comment
The Southern Sierra Fly Fishers Club believe it makes sense to prevent the Kern River Rainbow Trout from becoming a species of concern, threatened, or endangered through more hybridization with domestic hatchery fish and the Kern River Rainbow Project being part of Alternative Plan 2 will help accomplish this, and avoid future lawsuits.
Sincerely,
Shane R. Goslin
Southern Sierra Fly Fishers Club
Conservation Chair
yep... I said it.
Darn stockers getting in the way of the natives 
