Lynn Sprague, Regional Forester
USDA Forest Service
Pacific Southwest Region
630 Sansome Street
San Francisco, California 94111
Dear Mr. Sprague:
I am writing for California Trout (CalTrout) to appeal your Record of Decision for the Emigrant Wilderness Management Direction. CalTrout represents over 5,000 California citizens who fish in the state as well as 60 affiliated fishing organizations and clubs.
We have followed the review of the Management Plan for the Emigrant from its inception. We have provided comments on the Draft Environmental Impact Statement (DEIS) and we have consulted our members and local anglers on this Wilderness. We take this decision regarding reduction in the function of streamflow dams in the Emigrant to threaten a major resource of wild trout that has been available to anglers in California for decades. We feel there are reasonable alternatives that might be taken to implement the USFS mandate to protect wilderness while preserving this crucial trout resource.
CalTrouts position is that in a thoughtful assessment of the streams supported by these dams any wild trout populations in these streams must be carefully considered. Certainly structures that reduce the quality of the Wilderness experience must be questioned and CalTrout questions the usefulness of many dams. However, in California today wild trout streams are at a premium and any streams with solid populations of fish are a major resource to anglers. From 1991 to 1996 the number of angler hours on California lakes and streams has increased over 50%. It is our understanding that certain of the streams such as those in the Emigrant Lake and Huckleberry Lake drainages support major spawning runs of wild rainbow trout, only with the help of the modest dams. These spawning runs are important not only for the maintenance of wild populations of fish in lakes but also to repopulate streams with larger wild trout that make for an extremely high quality angling experience. Thus, your staffs proposed decision that could lead to the damage of these valuable fisheries is difficult to accept. We propose as an alternative that carefully drafted MOUs be developed in cooperation with the California Department of Fish and Game (DFG) to define the regulation practices on all dams that may affect populations of not only fish but amphibians (there are two candidate species for listing as endangered species that benefit directly from these streamflows: the mountain yellow-legged frog and the Yosemite toad (see page 134 of DEIS). In sum, we feel you can reduce the impact of most dams, but can also preserve this valuable water resource through a cooperative agreement with DFG.
One more detail, we question a novel concept in this decision: to maintain dams some of the 18 dams in question, apparently as historic monuments, but not to allow streamflow regulation except in the case of two dams. This directly reduces flows in several streams. Furthermore, we note that in those two cases streamflow regulation will only be allowed after "sustained low streamflow" which your staff defines to be " the second successive consecutive summer/fall periods when flow is lower than a specified rate for more than a number of days." This was never discussed in the DEIS. We fear that without careful surveillance of these dams that the streams in question can go dry. Such action, both the nonregulation of existing streamflow structures as well as the restrictive regulation of the two remaining, insofar as it is "dewatering" an "existing" river drainage, may be illegal (see CalTrout suits on dewatering of streams into the Mono Basin). Clearly, we feel that the flow in these streams should be maintained until the potential impact of changes in their regulation of fish, amphibians and the full stream environment are carefully assessed.
Finally, we are also concerned that this dewatering of these streams will be directly in conflict with the intent of pending congressional legislation. You may not have been aware of H.R. 1663 by Representative Doolittle that specifically addresses the operation and maintenance of these structures. Caltrout would be willing to work with your staff to develop a working solution to the streamflow issues in light of the pending legislation.
In the future, if we can provide any additional input do not hesitate to be in contact. I would emphasize that CalTrout has a system of "Streamkeepers" who provide information to agencies about local fishing issues as needed. We would be happy to work with you to provide such liaison for the Emigrant.
Jerome Yesavage, M.D.
827 Santa Fe
Stanford, California 94305 650-858-1365 (voice) 650-852-3297 (fax)