A version of these comments were submitted to the New York State Department of Environmental Conservation regarding the draft Saranac Lakes Wild Forest Unit Management Plan.
The Ausable River Association commends the New York State Department of Environmental Conservation for completing the draft Saranac Lakes Wild Forest Unit Management Plan. The plan is comprehensive in its scope. Notwithstanding, there are several areas where the UMP could be improved and one management action that concerns the Ausable River Association.
In general, the draft UMP does not incorporate relevant bodies of scientific knowledge pertaining to natural resource management and protection. In fact, of the 95 references cited, only 4 come from the peer-reviewed scientific literature. The literature used is dated, with an average year of reference of 1985 and 75% of the literature is older than 2003. The most recent resource cited was published in 2012. Further, much of the data used in the management plan is over 30 years old. Most of the data used to make decisions about fisheries management dates to the 1984 ALSC survey, data which is now 33 years old. Our understanding of natural resource management, and the Adirondacks, has advanced significantly since the mid-1980s. It is imperative that DEC demonstrate that their management planning is based on recent science and data. While we recognize the challenges associated with data collection, there is no reason not to incorporate relevant, up-to-date scientific literature into the unit management planning process.
Characterization of Non-Native Introduced Fish Species
The draft UMP provides extensive background information on the history and consequences of fish stocking and, specifically, the introduction of non-native species within the Adirondacks. The Ausable River Association urges the DEC to recognize and discuss the impacts of introduced non-native salmonids (brown trout and rainbow trout) and other introduced non-native species on native species and the aquatic food web of the Ausable. The section titled “Impacts of Fish Introduction” on page 40 of the draft UMP excludes any discussion of the impacts of introduced, non-native salmonid species, even though the scientific literature clearly outlines that such impacts exist.
The presence of brown trout and rainbow trout is often associated with the downstream distribution limit of brook trout (Vincent & Miller 1969; Gard & Flittner 1974; Kozel & Hubert 1989; Rahel & Hubert 1991; Petty et al. 2012), and the impact of these non-native trout species have been linked to declines in brook trout populations in numerous studies (Faush & White 1981; Moore et al. 1983; Waters 1983, 1999; Larson & Moore 1985; Magoulick & Wilzback 1998; McKenna et al. 2013; Wagner et al. 2013; Hoxmeier & Dieterman 2016). There are various mechanisms responsible for the decline in brook trout populations as the result of introduced rainbow trout and brown trout. Generally, they are linked to higher thermal tolerances of the introduced non-native species, displacement of brook trout from preferred resting positions, hybridization by redd superimposition, predation of juvenile brook trout, and preferred harvesting of brook trout by anglers when co-occurring with brown trout (Cooper 1952; Marshall & MacCrimmon 1970; Alexander 1977; Lee & Rinne 1980; Fausch & White 1981; Fausch 1989; Flebbe 1994; Eaton et al. 1995; Sorensen et al. 1995; Essington et al. 1998; Carlson et al. 2007; Cucherousset et al. 2008; Hartman & Cox 2008; Öhlund et al. 2008; Hoxmeier & Dieterman 2013; Chadwick et al. 2015). A recent study by Hitt et al. (2017) shows that brown trout affect brook trout use of foraging habitat outside of cold-water refugia. This has implications for the long-term adaption of brook trout to climate change as it documents a possible mechanism by which the presence of brown trout limit the selective pressure on brook trout populations to adapt to warmer temperatures. Therefore, stocking brown trout in waters deemed too warm for brook trout may limit the foraging habitat for nearby brook trout populations and limit the potential for future adaption to warmer water temperatures.
We encourage the DEC to recognize and utilize the existing body of scientific knowledge detailing the impacts of non-native fish species on native fish populations. This knowledge should be incorporated into the management framework and be balanced against the public desire to fish for non-native species. To be clear, AsRA is not advocating the cessation of stocking non-native trout species. Rather, we urge DEC to recognize the threat these species pose to native fishes and carefully consider expanded stocking of non-native species.
Introduction of Largemouth Bass to Little Cherrypatch Pond
We explicitly oppose the proposal to introduce largemouth bass to Little Cherrypatch Pond. This decision is directly contradicted by the management framework outlined elsewhere in the draft UMP. On page 45, the UMP states “Department Fisheries occasionally introduces largemouth bass to waters that are too warm to support trout or are already dominated by non-native species. Such waters are chosen carefully to avoid impacting any downstream trout waters.” At a very minimum DEC should document that the waters of Little Cherrypatch Pond are too warm to support trout and justify why largemouth bass stocking won’t potentially impact the West Branch of the Ausable River which is directly downstream of the pond. Beyond that, it is widely recognized that largemouth bass negatively impact native fish communities and alter aquatic food webs (Crossman 1991; Chapleau et al. 1997; Whittier et al. 1997; Azuma & Motomura 1999; Bourke et al. 1999; MacRae & Jackson 2001; Jackson 2002; Maezono & Miyashita 2003; Takamura 2007)
The most recent fish survey data, 1984 ALSC, reports that brook trout are present in the pond. Without updated fisheries data, we must assume that brook trout are still present, and thus the waters are not too warm to support trout. DEC stocked largemouth bass in the pond in 1993 but presents no subsequent fish survey data to inform whether that stocking effort was successful. The introduction of largemouth bass and/or brown trout, would put a new non-native species that is detrimental to brook trout populations (a) into a waterbody that may have brook trout and (b) near Big Cherrypatch Pond which is known to have brook trout. DEC has failed to provide an ecological justification for the introduction of a non-native species to this waterbody.
Given the difficulty in accessing this waterbody for fishing, there would appear to be little or no desire from anglers to stock largemouth bass in this pond. This further suggests that there is no need to stock any non-native species, largemouth bass or brown trout, in this pond. We encourage the DEC to reconsider this proposed stocking and avoid the unnecessary introduction of a non-native fish to this waterbody.
Monument Falls Accessible Trail and Facilities
We support the creation of an accessible trail at Monument Falls along the West Branch of the Ausable River. Additionally, we would encourage the DEC to install a permanent vault toilet facility at this location. Currently, there is a pit privy off the back of the parking lot that is in disrepair and poorly signed. In addition, the Ausable River Association provides a wheelchair accessible portable-toilet at this location from Victoria Day through Labor Day each year. The addition of a DEC maintained permanent facility would address the issue of human waste disposal year-round and would be able to handle the added volume of users associated with a newly created trail. The issue of improper human waste disposal has been a problem along the river and popular trails in the area for many years. The Ausable River Association manages a Porta-John program, at considerable time and expense, each year to mitigate this problem. After nearly a decade, the program has proven successful in addressing this issue along the river. Given the success of this program it makes sense for the DEC to install permanent facilities where reasonable and possible. These facilities would be no different than the ones at state boat launches and other fishing access sites. In fact, the Cascade Lakes day use area sets a precedent for their installation at hand launch fishing access sites.
We thank the DEC for the effort put forth in creating the draft Saranac Lakes Wild Forest Unit Management Plan, and for the opportunity to provide public comment.
Alexander G.R. 1997. Consumption of small trout by large predatory brown trout in the North Branch of the Au Sable River, Michigan. Michigan Department of Natural Resources, Fisheries Research Report 1855.
Azuma M. & Motomura Y. 1999. Feeding habits of largemouth bass in a non-native environment: the case of a small lake with bluegill in Japan. Environmental Biology of Fishes, 52: 379-389.
Bourke P., Magnan P., & Rodriquez M.A. 1999. Phenotypic responses to lacustrine brook charr in relation to the intensity of interspecific competition. Evolutionary Ecology, 13: 19-31.
Carlson S.M., Hendry A.P., & Letcher B.H. 2007. Growth rate differences between resident native brook trout and non-native brown trout. Journal of Fish Biology, 71: 1430-1447.
Chadwick J.G., Nislow K.H., & McCormick S.D. 2015. Thermal onset of cellular and endocrine stress response correspond to ecological limits in brook trout, an iconic cold-water fish. Conservation Physiology, 3: 1-12.
Chapleau F., Findlay S.C., & Szenasy E. 1997. Impact of piscivorous fish introductions on fish species richness of small lakes in Gatineau Park, Quebec. Ecoscience, 4: 259-268.
Cooper E.L. 1952. Rate of exploitation of wild eastern brook trout and brown trout populations in the Pigeon River, Otsego County, Michigan. Transactions of the American Fisheries Society, 81: 224-234.
Crossman E.J. 1991. Introduced freshwater fishes: a review of the North American perspective with emphasis on Canada. Canadian Journal of Fisheries and Aquatic Sciences, 48 (Supplement 1): 46-57.
Cucherousset J., Aymes J.C., Poulet N., Santoul F., & Céréghino R. 2008. Do native brown trout and non-native brook trout interact reproductively? Naturwissenschaften, 95: 647-654.
Eaton J.G., McCormick J.H., Goodno, B.E., O’Brien D.G., Stefan H.G., Hondzo M., & Scheller R.M. 1995. A field information-based system for estimating fish temperature tolerances. Fisheries, 20: 10-18.
Essington T.E., Sorenson P.W., & Paron D.G. 1998. High rate of redd superimposition by brook trout (Salvelinus fontinalis) and brown trout (Salmo trutta) in a Minnesota stream cannot be explained by habitat availability alone. Canadian Journal of Fisheries and Aquatic Sciences, 55: 2310-2316.
Fausch K.D. 1989. Do gradient and temperature affect distribution of, and interactions between, brook char (Salvelinus fontinalis) and other resident salmonids in streams? Physiology and Ecology Japan, 1: 303-322.
Fausch K.D. & White R.J. 1981. Competition between brook trout (Salvelinus fontinalis) and brown trout (Salmo trutta) for positions in a Michigan stream. Canadian Journal of Fisheries and Aquatic Science, 38: 1220-1227.
Fleebe P.A. 1994. A regional view of the margin: salmonid abundance and distribution in the southern Appalachian mountains of North Carolina and Virginia. Transactions of the American Fisheries Society, 123: 657-667.
Gard R. & Flittner G.A. 1974. Distribution and abundance of fishes in Sagehen Creek, California. Journal of Wildlife Management, 38: 347-358.
Hartman K.J. & Cox M.K. 2008. Refinement and testing of a brook trout bioenergetics model. Transactions of the American Fisheries Society, 137: 357-363.
Hitt N.P., Snook E.L., & Massie D.L. 2017. Brook trout use of thermal refugia and foraging habitat influenced by brown trout. Canadian Journal of Fisheries and Aquatic Sciences, 74: 406-418.
Hoxmeier R.J.H. & Dieterman D.J. 2013. Seasonal movement, growth and survival of brook trout in sympatry with brown trout in Midwestern US streams. Ecology of Freshwater Fishes, 22: 530-542.
Hoxmeier R.J.H. & Dieterman D.J. 2016. Long-term population demographics of native brook trout following manipulative reduction of an invader. Biological Invasion, 18: 2911-2922.
Jackson D.A. 2002. Ecological effects of Micropterus introductions: the dark side of black bass. In. Philip D.P. & Ridgeway M.S. Black Bass: Ecology, Conservation, and Management. American Fishereis Society Symposium 31. Bethesda, MD.
Kozel S.J. & Hubert W.A. 1989. Factors influencing the abundance of brook trout (Salvelinus fontinalis) in forested mountain stream. Journal of Freshwater Ecology, 5: 113-122.
Larson G.L. & Moore S.E. 1985. Encroachment of exotic rainbow trout into stream populations of native brook trout in the southern Appalachian mountains. Transactions of the American Fisheries Society, 114: 195-203.
Lee R.M. & Rinne J.N. 1980. Critical thermal maxima of five trout species in the southwestern United States. Transactions of the American Fisheries Society, 109: 632-635.
MacRae P.S.D. & Jackson D.A. 2001. The influence of smallmouth bass (Micropterus dolomieu) predation and habitat complexity on the structure of littoral zone fish assemblages. Canadian Journal of Fisheries and Aquatic Sciences, 58: 342-351.
Maezono Y. & Miyashita T. 2003. Community-level impacts induced by introduced largemouth bass and bluegill in farm ponds in Japan. Biological Conservation, 109: 111-121.
Magoulick DD. & Wilzbach M.A. 1998. Are native brook charr and rainbow trout differently adapted to upstream and downstream reaches? Ecology of Freshwater Fish, 7: 167-175.
Marshall T.L. & MacCrimmon H.R. 1970. Exploitation of self-sustaining Ontario stream populations of brown trout (Salmo trutta) and brook trout (Salvelinus fontinalis). Journal of the Fisheries Research Board of Canada, 27: 1087-1102.
McKenna J.E., Slattery M.T., & Clifford K.M. 2013. Broad-scale patterns of brook trout responses to introduced brown trout in New York. North American Journal of Fisheries Management, 33: 1221-1235.
Moore S.E., Ridley B., & Larson G.L. 1983. Standing crops of brook trout concurrent with removal of rainbow trout from selected streams in Great Smoky Mountains National Park. North American Journal of Fisheries Management, 3: 72-80.
Öhlund G, Nordwall F., Degerman E., & Eriksson T. 2008. Life history and large-scale habitat use of brown trout (Salmo trutta) and brook trout (Salvelinus fontanalis) – implications for species replacement patterns. Canadian Journal of Fisheries and Aquatic Sciences, 65: 633-644.
Petty J.T., Hansbarger J.L., Huntsman B.M., & Mazik P.M. 2012. Brook trout movement in response to temperature, flow, and thermal refugia within a complex Appalachian riverscape. Transactions of the American Fisheries Society, 141: 1060-1073.
Rahel F.J. & Hubert W.A. 1991. Fish assemblages and habitat gradients in a Rocky Mountain – Great Plains stream: biotic zonation and additive patterns of community change. Transactions of the American Fisheries Society, 120: 319-332.
Sorensen P.W., Cardwell J.R., Essington T., & Weigel D.E. 1995. Reproductive interactions between sympatric brook and brown trout in a small Minnesota stream. Canadian Journal of Fisheries and Aquatic Sciences, 52: 1958-1965.
Takamura K. 2007. Performance as a fish predator of largemouth bass [Micripterus salmoides (Lacepède)] invading Japanese freshwaters: a review. Ecological Research, 22: 940-946.
Vincent R.E. & Miller W.H. 1969. Altitudinal distribution of brown trout and other fishes in a headwater tributary of the South Platte River, Colorodo. Ecology, 50: 464-466.
Wagner T., Deweber J.T., Detar J., & Sweka J.A. 2013. Landscape-scale evaluation of asymmetric interactions between brown trout and brook trout using two-species occupancy models. Transactions of the American Fisheries Society, 142: 353-361.
Waters T.F. 1983. Replacement of brook trout by grown trout over 15 years in a Minnesota stream: production and abundance. Transactions of the American Fisheries Society, 112: 137-146.
Waters T.F. 1999. Long-term trout production dynamics in Valley Creek, Minnesota. Transactions of the American Fisheries Society, 128: 1151-1162.
Whittier T.R., Halliwell D.B., Paulsen S.G. 1997. Cyprinid distributions in Northeast U.S.A. lakes: evidence of regional-scale minnow biodiversity lossess. Canadian Journal of Fisheries and Aquatic Sciences, 54: 1593-1607.