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Draft EIR/EIS on Hatchery and Stocking Program

Until Monday, November 16, the California Department of Fish and Game is taking comments on a Draft Environmental Impact Report for fish stocking and hatchery operations.

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Jim Starr

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Dear (recipient name),

Experience in other states has shown that focusing on habitat is the best way to improve fishing conditions. Take care of the fish, and the fishing will take care of itself. In addition, an overwhelming body of evidence shows that hatchery fish can devastate wild and native trout populations through genetic contamination, disease, predation, and competition. 
 
DFG’s EIR is a perfect opportunity to shift the balance in California away from discredited hatchery focused management and toward wild trout management. Unfortunately, the draft EIR falls short of the mark.  
 
California can do better.  I don’t oppose all stocking of hatchery fish, but it’s not appropriate in free flowing waters that are capable of supporting wild, self-sustaining fisheries. Sadly, the state continues to stock numerous California waters that have the potential, with proper management, to support high-quality wild trout fisheries – and at much less cost to taxpayers. It’s high time for DFG to start fulfilling in practice what its strategic plan already calls for on paper – using hatchery trout only as a last resort, to reintroduce wild fish or for waters that are truly incapable of sustaining natural production.
 
•The EIR should address the effects of hatchery fish on all of California’s wild and native trout, not just those populations that are already imperiled. The draft EIR only considers harms to species that are listed as threatened, endangered, or “of concern,” like the California golden trout and Kern River rainbow. While these imperiled species are obviously important, so are the much larger populations of native rainbows and other wild trout that form the backbone of key fisheries like the McCloud, Pit, and upper Sacramento rivers. The draft EIR ignores the effects of hatchery fish on these important populations.
 
•The EIR should analyze wild trout management as an alternative to stocking as means of sustaining trout populations.  DFG’s stated reason for preparing the EIR is “to continue rearing and stocking fish from existing hatchery facilities for the use of recreational anglers.” This focus is too narrow. The purpose of a hatchery program is not to perpetuate itself, but rather to sustain fisheries. Hatcheries are only one means of sustaining fisheries, and are often far from the cheapest and least-harmful way to do so. The draft EIR should analyze wild trout management – i.e., a halt to stocking combined with harvest restrictions and habitat protection – as an alternative to continued stocking on many waters. Where other states have adopted such strategies, size and numbers of wild trout have actually increased – even on waters with heavy fishing pressure.
 
•The EIR should clearly state the conditions that must be met before DFG will resume stocking hatchery fish in waters containing sensitive species. Last November, in response to a court order, DFG suspended its stocking operations in most waters containing rare, threatened, or endangered native species of fish and amphibians, in order to prevent any further harm from hatchery fish. The draft EIR proposes resuming stocking these waters on a case-by-case basis, as soon as a plan is developed for “minimizing” harms to native species from stocked fish. But the draft EIR 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.
 
•The EIR’s estimates of the dependence of California fisheries on stocking to support recreation are overstated and should be reevaluated. In order to help justify the current hatchery program, the DEIR estimates, on a scale of 1 to 5, of the degree to which various popular California streams and lakes depend on stocking to maintain viable fisheries. It rates the vast majority of these fisheries as 4s and 5s. Yet many of these waters have not been stocked since last November due to the court order, and their fisheries have not crashed – suggesting that the state’s estimates of stocking dependence are inflated.

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Draft EIR/EIS on Hatchery and Stocking Program

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Jim Starr

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