Screw the People, Save the Frogs!

Below is the text of a paper I received from an industry expert on what the new Fish & Game regulations realy mean.  I have not researched all of the particlars but I have looked at a few of them and found them to be correct. 

Please take a few minutes to read why anyone who has ever cast a line in California should be concerned about what the future will hold for our state.

ISSUES CONCERNING PRIVATE STOCKING AND AQUACULTURE

(Title 14, Section 238.5 of the California Code of Regulations)

1. Bio 223 states "There is thus a substantial risk that fish stocking under the private stocking program MAY SUBSTANTIALLY impair populations of these species, affect designated critical habitat for these species." "The risk is POTENTIALLY significant for all species listed above." A logical question is what studies have been conducted over the life of private stocking programs that prove beyond any doubt that the statements made in Bio 223 are based on substantiated fact rather than meaningless POSSIBILITIES?
2. Private stocking of ponds under permit and stocking where permits are currently not required have been going on for years. If private stocking has had such an adverse effect on various aquatic invertebrates, amphibians and other species within a particular habitat, the damage has long since been done.
3. Bio 236 deals with the POSSIBILITY of introducing pathogens to wild populations of native fish. Since the "Pathogen” problem is a POSSIBILITY, are there any studies of sever adverse affects that have actually occurred? The mitigation for a POSSIBILITY is to require expensive, certified laboratory certifications of disease and parasite free fish inventories, once each year. Aquaculture Facilities are monitoring their own farms, on a daily basis, to eliminate disease and parasites.
4. Bio 238 deals with the introduction of invasive species to wild populations of native fish and amphibians through private stocking, Bio 238 makes a significant statement, 'While there is no record of transmitting invasive species from private aquaculture facilities to State waters, the risk would be POTENTIALLY significant." It states, no record of adverse effect exists, yet proposals are made for expensive laboratory and biological testing of Aquaculture Farms. These costs will have a significant financial burden on Aquaculture Facilities that are struggling to exist with the increase in costs of food, labor and a tailing economy.
5. Bio 240 deals with the distribution of invasive species by anglers. It states "California Department of Fish and Game 2008, identifies recreational fishing as a primary vector for introduction of aquatic invasive species, noting that initial introduction can occur when bait buckets and live tank contents are clumped, gear used for fishing, boats, nets, floats, anchors, wading boots, tackle, can spread AIS." This is such a narrow sighted view of identifying the PRIMARY cause of the spread of invasive species and totally ignores the major factors beyond anyone's control. For example, Lake Mathews in Southern California is infected with Quagga Mussels, no fishing is allowed in the Lake. No Aquaculture Facility stocks this Lake. Kramer Lake received water from Lake Mathews and had now been identified as having Quagga Mussel. No fishing is allowed in Kramer Lake and the Lake is not stocked with fish, Irvine Lake also receives Mathew's water and is infected. The spread of Quagga Mussel is down the entire Colorado River, with infestations from Lake Mead to Yuma, Arizona. Ten or more San Diego Lakes are infected. The infection of Quagga Mussel started in the Great Lakes and has spread from there, through out the entire United States.
6. Mitigation measures Bio 225, Bio 233b, Bio 233a, Bio 238, and Bio 240, will eliminate private stocking exemptions, institute annual certified, laboratory testing of Aquacultural Facilities for disease pathogens and quarterly inspection of Aquacultural Facilities for invasive species. All of these proposed mitigation solutions are based on "POSSIBILITIES" of the risk of POTENTIALLY significant adverse effect on wild species, could POTENTIALLY affect salmonid species, and there is NO RECORD of transmitting invasive species from private Aquaculture Facilities. These statements of POSSIBILITIES, without factual studies of verification, are from the various BIO discussions above. With these uncertain POSSIBILITIES, the proposed mitigations are expensive burdens and may very well cause the collapse of the Aquaculture Industry and Private Stocking Programs. The mitigation measures herein defined are designed to take the most convenient method of regulation, by concentrating mitigation or the relatively few Fish Farms and private Lakes and Ponds. The entire mitigation process does not even address a larger and virtually impossible problem to regulate, the importation of disease and invasive species from bait fish and minnow importers. Each year thousands and thousands of pounds of minnows, gold fish and a variety of amphibians, turtles, salamanders, crawdads, etc., are imported into the State. These imports come from all areas of the United States; from un-regulated Hatcheries and even seined from wild sources. NONE of these sources are inspected, controlled or investigated for disease and invasive species. The problem becomes even more serious when these imports cross the State Line and are sold to literally thousands of pet shops and live bait dealers through out the State. Once these fish and the various amphibians are sold to the public, they are fished as live bait through out the State. Many times, those who purchased fish for aquariums, dispose of these fish in private Lakes and Ponds when they are no longer wanted. Because of the magnitude of this problem and the number of terminal markets involved these mitigation measures over took and fail to inspect, regulate, or even test these importers and terminal markets for diseases and invasive species. Our decisions in life cannot be based upon POSSIBILITIES. If you get in your automobile there is a possibility you will be involved in an accident or if you are a passenger in an aircraft, that plane could crash. We DO NOT AND CANNOT base decisions on possibilities. Only when there is verified evidence of actual danger and destruction can mitigation take place. Without actual fact, the mitigation will be costly and not needed, or if needed, too late to change an existing and unsolvable problem. These burdensome regulations will undoubtedly be the end of many Recreational Fishing opportunities in California and the closing of many Aquacultural Facilities, who are operating on very close margins in today's economic climate. Hundreds of jobs will be lost at Recreational Fishing Lakes and at Fish Farms through out the State. There will be a substantial economic impact on the Fishing Tackle Manufactures, Retailers, Sporting Goods Dealers, Bait Companies and Boat Manufactures and Retailers. A prudent course would be to go slowly and study the actual adverse effects of stocking programs in the past and the potential damage to Aquaculture and Recreational Fishing in the future.

 

THE PROBLEM WITH THE DFG EIR IS THREE FOLD:

1. The EIR named every specie of frogs, birds, plants, fish, amphibians & reptiles, most of which are NOT endangered, that could be present at a pond, lake or stream. Because many of these 80 species are wide spread through out the State, it is doubtful any body of water will be free of every single specie.
2. The EIR names 35 diseases, that could be at hatcheries, that may have an adverse effect on The frogs, birds, plants, fish, amphibians, reptiles and 7 invasive species, such as mussels and aquatic plants. The DFG admits many of these diseases and invasive species are wide spread throughout California and it is doubtful any fish hatchery is free of every single disease and invasive species that could have an effect on the frogs, amphibians, etc.
3. When you name a State wide target of 80 species of frogs, birds, plants, fish, amphibians and reptiles, and aim 35 diseases, and 7 invasive species at them, you will undoubtedly hit every pond, lake, stream and hatchery in the State. It is very likely that no hatchery will be able to stock fish. No body of water will be able to get a permit to stock. THIS ENDS FRESH WATER FISHING IN CALIFORNIA!!!