To All Northern California Fly Fishers:
We have a challenge before us we ALL need to address. On June 12th, the Department of Fish and Wildlife (DFW) and Fish and Game Commission (F&G) will be addressing proposed termination of the 1996 Striped Bass policy in the Delta and supporting changes to the Delta Fishery Policy. Both of these changes are a major step to opening the door to increased take of Stripers throughout the watershed, including rivers, the Delta, San Francisco Bay, as well as in the ocean.
What appears to be behind this is the continued push by water users and agriculture interests that the problem with declines of salmon & other California Endangered Species Act (CESA) listed fish is predation by striped bass. We feel this is misplaced and wrong. I’ve attached our Council letter to the Commission and DFW Director for you to use as you wish.
This will be discussed at the F&G Commission meeting on June 12, 2019 in Redding – https://fgc.ca.gov/Meetings It appears to be Agenda Item 11 on day one (June 12th) of the meeting. Though they are not saying striped bass or Delta Fisheries Policy, these are the recommendations from the Wildlife Resources Committee meeting in May (as item 11 says).
I ask you to do two things: 1) Write a similar letter to the Director and Commission and send via email by June 9th, and 2) make phone calls to the Commission asking them to put this on hold until they know more and we can have a chance to respond appropriately. The addresses are on the letter. Here’s the email addresses and phone numbers:
F&G Commission: [email protected] – Attn: Melissa Miller-Henson 916-653-4899
Director Chuck Bonham, DFW: [email protected] 916-445-0411
Please act quickly! Emails must be received by June 9th before the Commission meeting on the 12th in Redding.
Fly Fishers International
Northern California Council
May 30, 2019
To: California State Fish and Game Commission
P.O. Box 944209, Sacramento, CA 94244-2090
DFW Director Chuck Bonham
1416 9th Street, 12th Floor, Sacramento, CA 94244-2090
Attn: Melissa Miller-Henson & Director Bonham:
Gentlemen & Ladies:
I am writing on behalf of the Northern California Council, Fly Fishers International and our 20 member clubs and thousands of members. We are an organization which has been part of the recreational fishing community in California for more than 40 years and is focused on supporting fly fishing as a sport and protection of the habitats within which sport fish reside. We have worked extensively with the Department of Fish and Wildlife on protections for recreational fishing opportunities and the many species of fish that reside in California. The S.F. Bay-Delta has long been a region of California within which our fly fishing community recreates, spends time and money, and fly fishes for resident and non-resident fish.
Of concern to us are two issues before the Commission. One is the proposed repeal of the 1996 California Fish & game Commission Striped Bass Policy, and second is the changes to the Delta Fisheries Management Policy. The Striped Bass policy has long been in effect and focused to not only protect but enhance the population of Stripers in the Bay-Delta system. We support that policy as it was written in 1996. Second, the change to the Delta Fisheries Management policy appears to be a subtle change to open the door to allowing increased recreational take of predatory fish to ESA and/or CESA listed fish. We DO NOT agree that this is appropriate and do not agree that science sup- ports such actions.
Changing policies which
guide the management of fishes in the S.F.
Bay-Delta is appropriate in times
like today, but these changes must be
supported with good science, and benefit the ecosystem within which both listed
and non-listed fish exist. It appears that the CDFW and Commission are moving to focus on changing the predator-prey relationships in the Bay-Delta in
an effort to improve listed species
populations. Though we appreciate a
heightened focus on recovery of listed fish species that occupy or pass through
the Bay-Delta, we do not agree that science supports reduction of predators as
the solution to declining populations of listed fish species.
There have been numerous scientific studies on the predator-prey relationships in various watersheds. Dr. Peter Moyle, et all, in a May 22, 2016 article in The California Water Blog discuss extensively the unlikely success of focusing on reducing predators in the Bay-Delta to help salmon, steelhead and other pelagic fish listed under ESA and CESA (https://californiawaterblog.com/2016/05/22/6206/). They state unequivocally that the best strategy is to improve the Bay-Delta ecosystem habitat; not focus on predators. As we all know there are many different predators that impact listed fish, from birds, to sea lions, to other fish species, as well as mammals living in the region including man. In this case it appears that the main focus is Striped Bass, the single most important game fish the public fishes for in the Delta and its tributaries. We feel this focus is misplaced and ill advised!
Striped Bass, though a non-native fish, has been in the Bay-Delta system for more than
150 years. It is also important to recognize, as the article above states, that population levels of salmon and striped bass fluctuate up and down at the same time. Thus, when salmon populations are up, striped bass numbers are up, and visa versa. This is a clear indication that salmon are not driven down by predatory striped bass but are negatively or positively influenced by the surrounding conditions of the ecosystem around them. The referenced paper in the Water Blog also states unequivocally that Striped Bass are NOT the problem (see item 6).
An August 21, 2018 paper in The California Water Blog expanded on the previous article by Dr. Moyle, giving several summaries of papers related to survival of listed species and the predator-prey relationship in watersheds.
(https://californiawaterblog.com/2018/08/21/science-the-delta-and-the-future-of-san-joaquin-salmon/) It is clear that predators are seldom, if ever, the cause of extinction, but the single driving factor is poor ecological watershed conditions. Science is telling us that improving habitats to support listed species is the solution, and the focus and funding needs for improving those habitats should be the focus. Additionally, more time and funding are needed to allow hatchery managers to create a more diverse procedure for smolt release – varying release locations, timing and water conditions so smolts have a greater opportunity to survive.
One last issue of concern for this organization is the continued focus on hatcheries for salmon. We recognize that hatcheries are an “old” model to compensate for impacts of rim dams and water development. History now tells us that hatcheries have not lived up to their predicted success and have not provided ‘replacement’ numbers of returning adults consistent with historical wild populations. This is especially true for spring-run and winter-run Chinook and central valley Steelhead. What is now known is that hatchery fish do not have the genetic characteristics of wild fish, and don’t have the in-bred survival abilities of wild fish. Hatchery fish are much LESS capable of escape from predators than wild fish. Additionally, hatchery fish weaken the genetic integrity of what is left of the wild populations by inter-breeding in river systems below rim dams. In essence, what is needed is a long-term focus on returning to wild populations and eliminating hatcheries. This may take many years, but not doing so will result in continued genetic declines in wild fish leading to extinction.
In summary, we do not agree that predators are the cause of significant declines of listed fish in the S.F. Bay-Delta, and a focus on reduction of numbers of Striped Bass in the system is inappropriate. We do not support repeal of the 1996 Striped Bass policy. Striped Bass, along with largemouth bass, are the leading game fish in the Bay-Delta, bringing in millions of dollars to local businesses and towns, as well as pleasure to those who come to fish and recreate. We also do not agree with changes to the Delta Fisheries Management policy, as drafted. It allows changes to ‘take’ of non-listed fish by anglers and others and is not support in science.
As stated in the articles linked in this letter, a proper focus would be to improve the Bay- Delta habitat, along with increased water flows in the systems. Fish need water and they need places to spawn, grow and rest, all of which are habitat issues.
Dr. C. Mark Rockwell, D.C.
President, Northern California Council, Fly Fishers International