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Little Cherrypatch Pond

Saranac Lakes Wild Forest Unit Management Plan

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. 


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