Public comment open on proposed rulemaking

[bigjohn358]

Not to throw this too much off topic but any of you ever watch Fly Rod Chronicles? I can't stand the host and that show. He is ALWAYS promoting stocked fish and the West Virginia stocking programs. Half of his last season was promoting the WV hatcheries and catching fresh stockies. Sad one of the few fly fishing shows on tv is basically teaching the public that the way to catch trout is by chasing a stock truck.

 

[Fish Sticks]

I don’t believe that this proposed rule making is concerned with effluent discharge from hatcheries, at least in the traditional sense. That falls under the NPDES permits that are issued by DEP.

This is more about fish health and stocking fish with possible pathogens, something that is far more concerning to native trout lovers. The PFBC wants the authority to restrict what is stocked and where it is stocked, all the while releasing millions of pathogen laden fish themselves.

Think about it for a moment, the PFBC has already chosen to ignore numerous fish health issues that other states have depopulated hatcheries over, because they are so dependent on the stocked trout industry that they’ve created. We’re seeing it occur right now with NZM in hatcheries, all the while PFBC tries to keep it hush hush. What would happen if a PFBC hatchery was infected with gill lice? Do you trust the PFBC to do the right thing and depopulate? I sure don’t, not with what I’ve seen over the last decade or so.

Agree in general that they maintain stocking at all costs despite a slew of ecological harms because its license sales first not resource first. Its been that way forever and I obviously don’t trust them either they have knowingly omitted brown and rainbow trout from their aquatic invasive species web page despite them being some of worlds most highly destructive invasive species. Also they don’t talk about the value of native brook trout at all hardly or do public education on the dangers of invasive species they stock which would be crucial to changing public unrealistic public fishing expectations in pa that the commission is responsible for creating in the first place.

I wasn’t talking about the effluent, i was talking about the stocked fish themselves being pollution/impairments and deleterious to native brook trout and other sensitive species just like nitrogen or phosphorus ect. That stocking is an impairment and this authorization will at-least tell us where that impairment is happening, the Chesapeake bay comments were just an example showing if someone in dunping something harmful in the water you have to quantify and locate where its happening stocked fish or cow manure all the same so we know the full extent of the impairment.

Thats why the auth is so important because we don’t have that data we are managing blind. When the bar is set this unbelievably low and your lacking basic information needed for fisheries management like where stocked in invasive species are dumped in, you gotta start somewhere. You don’t have to trust PAFB for this to be useful because if we know where stocked invasive fish are being dumped we can hold PAFB accountable alot better than if only the people stocking know where their going in.

Just as you mentioned pa fish and boat’s track record shows they can’t be trusted to do whats right for native fish. So we need this data to take them to task if this authorization becomes a rubber stamp. If they are stocking invasive fish over threatened. endangered, or high conservation need species we need to know regardless of what PAFB feels they should or should not do about it because federal agencies can intervene in some cases. Feds intervened in wv with endangered candy darter. Federal input helped get stocked invasive browns outta those streams. We don’t even know where invasive stocked trout are going inregards to these sensitive species including brook trout, i can’t over emohasize the importance of PA fish and boat mandating private entities atleast require an auth so we know where the fish are going thats step one. We need this data very badly regardless of if pa fish and boat plans to do the right thing with the information or not.

 

[silverfox]

I submitted a comment in opposition of the proposed rule making.

My reasoning is this, if the PFBC wants to restrict fish stockings by private individuals in the state…..fine. I think that they should. I feel that this is killing overdue. However, I feel that PFBC should be leading by example and not stocking fish riddled with disease and invasive species.

Other state and federal hatcheries have depopulated and cleaned out hatcheries for cases of disease that PFBC frequently stocks, such as IPN, Bacterial Kidney Disease, Furunculosis and Whirling Disease. Now an entirely separate can of worms has been opened with the PFBC attempting to sweep the discovery of Mudsnails at two Centre Country hatcheries.

All fish hatcheries in PA need oversight, and not from the PFBC.

Fair enough. One of the most common comments I've read or received regarding this is exactly what you just said. The agency is basically saying, "do as I say, not as I do," with regard to controlling which species go where. If 20% of stocked trout streams contain wild brook trout, I don't have a lot of faith that they'd do anything about the unknown number of private citizens that are stocking over brook trout too.

Invasive species have been the most ignored, danced around, and straight up swept under the rug threat facing Pennsylvanias brook trout. We need large scale stocking reform like lake mead needed water this summer. You can’t over state how desperately this is needed relative to the crazy stuff we are doing in this state while other states are adopting science based management already paying HUGE dividends for native brook trout.

I don't think this point is mentioned enough. The top 4 threats to brook trout are 1) Poor Land Management 2) High Water Temperature 3) Sedimentation and 4) one or more nonnative fish species. We hear about 1-3 all the time from NGOs and the state environmental agencies including PFBC, and there is a lot of money and time being spent to reduce impacts 1-3. Aside from a small group of advocates, issue #4 is rarely mentioned, never mentioned by PFBC, and in fact, PFBC is the primary source of threat #4 either via introduction or protection of nonnative fish.

So at best, the public is ill-informed about the issue of nonnative fish, and at worst, they've been misled into believing they aren't a problem. Now we expect the public to understand the need to control where nonnative fish are stocked and there's poor support for a rule to better regulate the introduction of nonnative fish and people are shocked about it?

I get the sentiment that PFBC should reduce or eliminate stocking over brook trout before or instead of regulating private stocking, but we need the latter regardless. Both should happen, but this is the opportunity to support the agency on the private stocking issue. I guess we should be happy with what we get because it sure doesn't seem like there's much chance of anything significant happening on the main issue.

 

[Cznymph]

Fair enough. One of the most common comments I've read or received regarding this is exactly what you just said. The agency is basically saying, "do as I say, not as I do," with regard to controlling which species go where. If 20% of stocked trout streams contain wild brook trout, I don't have a lot of faith that they'd do anything about the unknown number of private citizens that are stocking over brook trout too.

With the recent information in another post about the NZM at PFBC hatcheries and the limited amount of information made public about it, do you still feel that the PFBC is truly “Resource First”.

The way I see it, PFBC hatcheries have the potential to do far greater damage to waterways than private stockings. As we saw with the gill lice several years back, a private hatchery services a much smaller area. PFBC hatcheries have a far greater footprint, are almost always located on high quality trout streams, and they have a massive hatchery network to share and pass pathogens between.

If the PFBC isn’t willing to play by it’s own rules, I can’t support them restricting stocking by private individuals.

 

[silverfox]

With the recent information in another post about the NZM at PFBC hatcheries and the limited amount of information made public about it, do you still feel that the PFBC is truly “Resource First”.

The way I see it, PFBC hatcheries have the potential to do far greater damage to waterways than private stockings. As we saw with the gill lice several years back, a private hatchery services a much smaller area. PFBC hatcheries have a far greater footprint, are almost always located on high quality trout streams, and they have a massive hatchery network to share and pass pathogens between.

If the PFBC isn’t willing to play by it’s own rules, I can’t support them restricting stocking by private individuals.

The gill lice issue originated in private hatcheries and was transmitted to wild populations by private citizens stocking those infected brook trout. Disease is only one part of the equation, though. The state has greatly reduced the number of brook trout they raise and/or stock, which I give them credit for. Right now, however, several private hatcheries all over the state are still raising brook trout for sale to private citizens, and without any way to track where those fish are going, they may end up in native brook trout streams.

The studies on introgression looked at PFBC-sourced stocked brook trout, which are likely far less fecund and poorly suited for survival in the wild. These private hatchery fish today are likely more fecund and better suited for survival in the wild. That's evidenced by the existence of obviously wild offspring of a certain private hatchery's brook trout traits showing up in year 1 aged fish in the wild.

How much damage could disease or highly fecund hatchery brook trout cause in a Class A brook trout stream or an entire system? What happens when some private hatchery-sourced brown trout end up in an unstocked allopatric Class A brook trout stream? There is a significant threat to wild populations that might be irreversible by allowing the unrestricted sale and distribution of private hatchery-sourced fish. Much like the gill lice issue, it may be too late before we discover what happened, with no way to at least document what fish are going where.

No hatchery or nonnative trout should be stocked over wild native brook trout populations. Period. Regardless of the source or the party responsible for doing it. We can't say, "well, unless PFBC stops doing it, then private citizens should continue doing it too." Compounding the problem isn't fixing the problem. This stocking authorization is/was an opportunity to prohibit, reduce, or at least document what private citizens are doing. There's no downside to it. It's a free program that creates a paper trail for where fish are being stocked. I don't see how any fan of wild native or wild nonnative trout for that matter would have a problem with the proposed regulations.

 

[Cznymph]

The gill lice issue originated in private hatcheries and was transmitted to wild populations by private citizens stocking those infected brook trout. Disease is only one part of the equation, though. The state has greatly reduced the number of brook trout they raise and/or stock, which I give them credit for. Right now, however, several private hatcheries all over the state are still raising brook trout for sale to private citizens, and without any way to track where those fish are going, they may end up in native brook trout streams.

The studies on introgression looked at PFBC-sourced stocked brook trout, which are likely far less fecund and poorly suited for survival in the wild. These private hatchery fish today are likely more fecund and better suited for survival in the wild. That's evidenced by the existence of obviously wild offspring of a certain private hatchery's brook trout traits showing up in year 1 aged fish in the wild.

How much damage could disease or highly fecund hatchery brook trout cause in a Class A brook trout stream or an entire system? What happens when some private hatchery-sourced brown trout end up in an unstocked allopatric Class A brook trout stream? There is a significant threat to wild populations that might be irreversible by allowing the unrestricted sale and distribution of private hatchery-sourced fish. Much like the gill lice issue, it may be too late before we discover what happened, with no way to at least document what fish are going where.

No hatchery or nonnative trout should be stocked over wild native brook trout populations. Period. Regardless of the source or the party responsible for doing it. We can't say, "well, unless PFBC stops doing it, then private citizens should continue doing it too." Compounding the problem isn't fixing the problem. This stocking authorization is/was an opportunity to prohibit, reduce, or at least document what private citizens are doing. There's no downside to it. It's a free program that creates a paper trail for where fish are being stocked. I don't see how any fan of wild native or wild nonnative trout for that matter would have a problem with the proposed regulations.

I agree with everything your saying, I just don’t think the PFBC has demonstrated themselves responsible enough to oversee private hatcheries, when they can’t keep their own clean.

I’d support this rule making 100 percent if it applied to PFBC hatcheries and was overseen by someone other than PFBC. Who is overseeing the overseers?

 

[silverfox]

I agree with everything your saying, I just don’t think the PFBC has demonstrated themselves responsible enough to oversee private hatcheries, when they can’t keep their own clean.

I’d support this rule making 100 percent if it applied to PFBC hatcheries and was overseen by someone other than PFBC. Who is overseeing the overseers?

One of the arguments against the proposed regulation was that it will function as a deterrent to private citizens buying hatchery trout to stock if they have to go through a permit process to acquire them. While that's a flawed argument because it's absurd to think that you should be able to buy and stock trout unchecked, there's an element of truth to it. That deterrent is beneficial in my eyes.

This will also create a public record of who's doing what so anyone can obtain the information. It also creates a paper trail so that if stocked trout show up in a class A stream somewhere, there's a record of who did it. If a disease outbreak occurs in a wild stream somewhere, then there's a way to determine where those fish came from more easily which could prevent further spread of the disease.

I get what you're saying, but I don't think preventing positive change because of the actions of the agency that oversees the collection of the data gets us anywhere. I do agree that there needs to be more oversight of PFBC. One thing I've learned recently is the esoteric issues around biotic interactions are poorly understood by those in other branches of state government. We take for granted that the general public knows the difference between a brook trout and a rainbow trout, let alone the issues surrounding them living in sympatry.

I remember reading an audit of PFBC published by the state treasury. The audit outlined revenue and expenses related to raising and stocking trout, but not once mentioned that trout reproduce on their own in the wild. That's an important omission as focusing on developing more wild natural reproduction could have a significant positive impact on the expense side. You could argue that shifting expenses more toward habitat and water quality improvements could help reduce the cost of raising and stocking fish. Again, it illuminates that outside of PFBC, very few in our state government understand the issues outside of a basic dollars and cents perspective.

 

[krayfish2]

Brook trout are native.