#12243, "Request to change CA DFW policy regarding the stocking ..."
Triploid trout are sterile and cannot reproduce. They are also more difficult for hatcheries to grow. As a result, trout stocking in CA has been significantly reduced state wide. I'm told that the reduction has been as much as 50%. While other factors like the shut downs at the Fillmore hatchery and the flood at the Moccasin hatchery have had impacts, the change to triploid trout has been a significant reason why you see far less trout in our lakes than pre-2010.
I wrote this letter to the DFW Director and copied the Commission in hopes of changing this. You may be interested to know that the decision to change to triploid trout was triggered because someone from the Center for Biological Diversity who lives in another state used a proxy attorney to sue the Department. This change affected a huge percentage of the people who fish in the state but none of us were ever given the chance to give public comment or even receive notice when the change was made.
To: Director Bonham and DFW Commissioners Date: April 22, 2020
I’m writing to ask the Department to reconsider Department policy regarding the stocking of triploid (sterile) trout in waters where it has already been demonstrated that steelhead genetics are significantly affected by past interbreeding with stocked trout. In these cases I respectfully request a policy change from the Department to allow stocking “normal” hatchery trout. This will enable the Department’s hatcheries to grow and stock more fish - while creating no significant new impacts to native steelhead.
In 2010 when the CBD sued the Department over the trout stocking program, I traveled to Sacramento and gave public comment in hopes of influencing the outcomes from this suit. Unlike the time when I successfully lobbied the Commission to keep portions of Alameda Creek open to catch and release barbless hook fishing (you may find this regulation on page 34 of this year’s booklet) - the change in trout stocking rules was implemented as policy.
At the time I was baffled that a group led by someone from another state (Noah Greenwald at the time - who lives in Washington) could cause the Department to change policy that materially affected a huge percentage of California’s anglers, and do so by lawsuit - with no notice or comment period from citizens of the state of CA. So I was not surprised to see in 2015C072486 | Super Ct. No. 06CS0145 | California Association of Recreational Fisherman v Department of Fish and Wildlife that the Department had to roll back elements of policy that affected aquaculture and the Fishing in the City Program. I studied this with great interest, as it successfully challenged the idea that some policies implemented by the Department as a result of the CBD suit were actually “underground regulation”.
I’ve spoken with attorneys about pursuing a similar suit over the policy aspects that require - in my view unnecessarily - that the Department stock triploid trout in places like Lake Cachuma, Lake Casitas, Castaic Lagoon where the downstream population of “steelhead” are no longer pure genetic steelhead. While it would be my preference not to sue the Department, when decisions are made as policy with no notice or comment period - we are left with no other option.
With respect to the waters below these lakes - in some cases hatchery fish have been stocked for as many as 95 years (eg the Santa Ynez river). The idea that Lake Cachuma should therefore be stocked with only triploid trout, and not stocked at all when the lake is greater than ⅔ full is absurd. The genetics of the fish downstream of Bradbury dam are long ago altered and no amount of time spent in stocking triploid trout can restore that. Only a multi-year full scale fish killing operation throughout the entire Santa Ynez river followed by restocking from native fish stocks could ever recover this. No operation of this scale has ever been attempted nor should it be.
Additional information on the genetic state of trout and steelhead can be found in a number of studies like the NOAA Southwest Fisheries Science Center and University of California – Santa Cruz’s study - presented to the CA DFW in 2014 https://swfsc.noaa.gov/publications/FED/01312.pdf
These studies make it clear that with the exception of a few isolated populations in the upper reaches of a few southern California creeks - the native steelhead trout are gone from our CA waters. While I fully appreciate and value the success stories in our state around restoring native trout - for example the Paiute trout on the Silver King - the idea that native steelhead can be restored to these places where triploid trout or no trout are being stocked upstream is not a reality.
Please change Department policy to allow stocking of normal hatchery trout in lakes and streams where native steelhead genetics are no longer present.