Bill Bramlette October 21, 1998

Acting Forest Supervisor Inyo National Forest

1600 Tollhouse Road

Clovis Ca 93611-0532 Re: Wilderness Plan (DEIS)

Dear Sir:

I am writing for California Trout (CalTrout) to provide our comments on DEIS for the Ansel Adams, John Muir, Dinkey Lakes and Monarch Wildernesses. CalTrout is supported by over 5,000 California citizens who fish in the state as well as 60 affiliated fishing organizations and clubs.

1. By various counts your proposal would cease stocking in perhaps 70 of 400 lakes. Your DEIS does not follow a format of previous Wilderness DEIS insofar as it has not excluded decisions about fish stocking, though as noted below it excludes grazing issues. We applaud the current lake-by-lake evaluations ongoing in the Desolation Wilderness, for example, and hope such cooperation between USFS and DFG continue in the future. We feel that careful collection of data makes a reasonable starting point for discussion about revised MOUs between the USFS and CDFG on stocking of such lakes. We also feel that decisions must be made on a lake by lake basis rather than by an arbitrary system of "opportunity classes" such as suggested in your DEIS. The fact of the matter is that the Wilderness Act has grandfathered in the management of fisheries in Wilderness Areas to the appropriate state agencies. It is unclear under what authority you appear to take this responsibility to direct DFG operations and that you are inviting wasteful litigation from that agency.

Furthmore, regarding stocking, you appear to see the Class A "pristine" opportunity class as an area which should exclude fisheries. I would like to quote for you from the letter of an experienced backwoods angler, John Wakabayashi, who is quite eloquent about the high values he places on such fisheries. Removing such fisheries from California, especially given the lack of such fisheries in the National Parks that cover the Sierra (see map below), will leave anglers such as Wakabayashi no alternative than to fish for trophy examples of the state trout in Wyoming!

The list of lakes recommended for cessation of stocking in the John

Muir/Ansel Adams,/Dinkey Lakes/Monarch Wilderness DEIS includes some real jewels. The rationale of stopping fish stocking to enhance 'opportunity class A' severely hurts the fishing community, particularly the more adventurous part of that community. There are so many other types of activities that are not restricted that disturb the wilderness experience far more than trout being in a lake. Arguments I've heard in the press that the stocking plane itself is an intrusion on the wilderness experience are not valid. I've visited over 550 backcountry lakes in California and have seen an air drop only once, whereas private planes fly over wherever one is several times a day. Mountain yellow legged frogs cannot be used as rationale for the USFS target list, because the target list seems to be based on inaccessibility of the lake, rather than frog habitat.

The list of lakes scheduled for stocking termination is ESPECIALLY disturbing for hikers that specifically seek the 'opportunity class A' experience. All of the targeted lakes appear to be remote trailless lakes, precisely the type of lake that exploratory anglers such as my wife and me seek out. We are seriously alarmed.

The termination list includes some of the most storied trout fishing lakes in the High Sierra.

Of special concern are the following lakes:

Echo Lake, Bishop Creek drainage: This lake is one of the most legendary lakes in the High Sierra. Prior to the 70's it was famous as an extraordinary big brookie fishery. Since then it has been one of the finest rainbow lakes in the east Sierra.

Cathedral Lake (west of the White Divide). Another lake with a long standing reputation for unusually big fish.

Lost Lakes (1 through 4), Glacier Divide. The upper lake in this chain is a producer of really big goldens.

Goethe Lakes, Glacier Divide. More big golden lakes.

Spire Lake, near Bear Creek Spire. A stunningly beautiful lake with big goldens.

Dana Lake #4. Well known for nice goldens to 14".

Many of the other lakes on the termination list are promising enough that they are high on the priority list for me and Judy to visit in the future. The USFS plans would strike a serious blow to us.

2. Regarding streamflow dams, we are concerned about the four of streamflow dams in the Wilderness Areas. CalTrout’s concern is that a thoughtful assessment of the streams supported by these dams and any amphibian or wild trout populations in these streams must be carefully considered before any dams are removed or allowed to deteriorate or are removed. In California today wild trout are at a premium and any streams with robust populations of fish are a major resource to anglers as well as to local economies. The DEIS does not even start to discuss such issues. May I refer you to the lively and ongoing discussion of such issues in the Emigrant Wilderness and the fact that these issues are not simple and cannot be solved merely by removing dams without thought to the consequences.

3. It is also important to note that a balance has already been struck whereas it appears that a good portion of the High Sierra areas may occur are presently granted full protection from planting or wild trout programs because of their national park. Please see the diagram below. It should be considered carefully before even more of this terrain is excluded from planting for anglers. If people want fishless "pristine" areas there are hundreds of square miles of that in the two National Parks.

4. For the record, here is California Trout’s Policy on Wilderness Waters:

Revised (4/96) CalTrout Wilderness Fishing Policy

California Trout recognizes that while angling in wilderness areas constitutes a major recreational resource not all wilderness waters are suitable as fisheries. Many high mountain lakes are notably low in food production and cannot sustain major trout populations. Other waters have adequate levels of food production, but are lacking in spawning habitat and thus unsuited for self-sustaining wild-trout populations. California Trout’s policy regarding the management of wilderness lakes and streams is that those waters that currently have self-sustaining wild populations of trout should be managed as defacto wild trout waters with appropriate angling regulations to limit the harvest of fish to levels that will ensure a stable population in good condition. Those waters that have historically provided angling opportunities and in which there is sufficiently abundant production of food, but which are otherwise incapable of containing a self-sustaining population of wild fish, should be considered for put-grow-take fisheries on a site by site basis, taking into consideration other environmental concerns. Other waters should not be managed as fisheries.

In cases of dispute between the United States Forest Service and the California Department of Fish and Game, decisions about stocking and maintenance of streamflow dams decisions should be made on a lake by lake or stream by stream basis. Decisions should take into account the historical and current value of the fishery as well as the environmental costs of maintaining that fishery. Of particular value is the identification and preservation of wilderness wild trout streams.

  1. We also note that the production grazing issue is "off the table." CalTrout has been concerned about the impact of grazing in wilderness areas in California for some years. We would be happy to provide input as needed on issues relating to fisheries in this wilderness. It is difficult to understand how this issue can be excluded from discussion whereas fisheries included?


In the future, if we can provide any additional information, do not hesitate to be in contact.


Jerome Yesavage, M.D.


827 Santa Fe

Stanford, California 94305 415-858-1365 (voice) 415-852-3297 (fax):