Yellowstone native fish restoration EA ---comment period open.
Those of you familiar with the Park, please submit your comments.
Here's what I had to say:
As a fishing guide in Yellowstone National Park and longtime resident of a border community, I would like to offer the following suggestions and voice the following concerns over efforts to stabilize/restore/reintroduce native fish:
Comment 1A: I believe a catch and kill requirement should be instituted in certain areas for rainbow trout. Likely locations where this requirement might prove effective at limiting cutthroat/rainbow hybridization are the Lamar River system upstream of the Soda Butte Creek confluence, Soda Butte Creek (possibly only above the Pebble Creek confluence), Slough Creek above the gorge dividing the Lower and First Meadows, and the Yellowstone River between the Lamar River confluence and the Lower Falls. A catch & kill regulation should likewise be put in place for brook trout in the upper Soda Butte Creek drainage.
Comment 1B: I believe catch and kill requirements would be counterproductive on other large rivers specifically including the Yellowstone downstream of the Lamar, the Gardner River, and portions of the Lamar drainage not noted above.
Comment 1C: The Yellowstone River below Knowles Falls and the Gardner River are particularly unsuited to catch & kill regulations, for two reasons. First, no barriers to fish movement exist or are feasible between these locations and waters of the Yellowstone drainage outside the Yellowstone boundaries, which are managed by the State of Montana and are unlikely ever to feature catch & kill regulations on rainbow trout. The second, related reason is that these locations already feature overwhelming numbers of non-native trout. A significant percentage of fish caught on the Yellowstone in this section are either rainbows or cutthroats exhibiting some degree of cutthroat/rainbow hybridization. The Gardner River is home to relatively low numbers of cutthroats, with rainbow and brown trout predominating. For these reasons, catch & kill regulations on these waters would result in lower fish densities for little gain in cutthroat population.
Comment 1D: I wish to state my categorical opposition to any catch & kill regulation on brown trout in the area discussed in Comment 1C. Indeed, in reality I would strongly prefer identical regulations on the lower Gardner River as exist currently in the Madison River drainage.
Comment 1E: If catch and kill regulations on rainbow trout are instituted, A considerable effort should be made to educate visiting anglers about the differences between rainbow and cutthroat trout, including placards containing color photos of both species at popular access points and/or more in-depth discussion in the regulations. Despite efforts in this direction in the current regulations, significant numbers of anglers still seem unable to tell the difference between rainbow trout and cutthroat trout and between cutthroat trout and brown trout.
I would support a small additional license fee for anglers who wish to fish the Lamar River drainage, with this additional fee earmarked for lake trout removal or other cutthroat recovery efforts in the Yellowstone drainage above Upper Falls. The Lamar drainage has experienced significant angler crowding over the past several seasons due to the collapse of the upper Yellowstone fishery, which both reduces the overall experience for visiting anglers and contributes to fish stress. A recovery in the Yellowstone drainage would thus benefit the Lamar drainage, as well. If instituted, this additional fee could take the form of a "check box" on the regular licenses, which when checked for an additional fee of say $10 no matter the license duration would allow anglers to fish the Lamar drainage. I should note here that I do not believe closures anywhere in the Lamar drainage except perhaps short-term closures of some small spawning streams upstream of Cache Creek would be beneficial, as anglers impacted by such closures would only crowd other waters also likely home to cutthroat (i.e. the Yellowstone in the Grand and Black Canyons).
If feasible, some headwater streams not historically home to cutthroat trout should be poisoned/shocked to remove current populations of non-native fish. Many headwater streams are likely unsuited to this due to the likelihood non-native fish would escape by hiding in seasonal tributaries, but some, specifically including Elk Creek and upper Tower Creek, might be suited to this process. Some streams in the Madison and Lewis/Snake drainages might also qualify, chiefly upper Sentinel Creek, Aster Creek, DeLacy Creek, Canyon Creek (Gibbon tributary), and Solfatara Creek.
The current regulation allowing children to use worms as bait in the entire Gardner River should be modified to permit bait fishing above Osprey Falls ONLY. Above Osprey Falls no native fish are present and the water character is far more suited to child anglers both in terms of safety and in terms of likely angling success than below Osprey Falls. I have personally witnessed adult anglers below Osprey Falls managing tackle nominally under the control of their children and keeping large numbers of fall-run migratory brown trout which enjoy greater protections outside the Park. Given the increase in hooking mortality associated with bait fishing and the fact that the locations in the lower Gardner suitable for bait fishing (the slower, deeper pools) are also where cutthroat trout prefer to reside, coupled with the fact that this portion of the river is generally too rugged for small children to fish effectively, the use of worms in the lower Gardner is counterproductive.
All tributaries to Yellowstone Lake and the Yellowstone River above the Upper Falls, with the exception of the Yellowstone River itself, should be permanently closed to angling. The inlet to Trout Lake, which currently opens on July 15, should likewise be closed permanently. These waters, in particular, are home primarily to spawning cutthroat trout and lack resident populations of catchable-sized fish, so closures would result in little loss of angling opportunities.
With the exception of the adjustments noted in Comment 5, I wish to specifically note my belief that other changes to angling seasons/waters would prove unhelpful, likely only reducing revenues both for the Park fisheries program and for businesses dependent on anglers visiting the Park, i.e. fly shops and outfitters.
A gradual sunset date for the use of felt-soled angling gear should be implemented, provided sufficient notice is given to allow vendors time to retool their inventories and visiting anglers time to purchase appropriate gear. I believe 3 years notice would be appropriate.
Efforts to restore cutthroat populations via limited stocking programs should be explored. Stocking of the Yellowstone River above the Upper Falls and of some tributaries to the Yellowstone River or Yellowstone Lake, particularly Pelican Creek, might make sense. Transplantation of fluvial grayling (probably from the Big Hole River) to locations such as the Gibbon River might also be explored.
Changes to current regulations governing tackle might also be explored. In particular, changing the current regulation allowing treble hooks would reduce fish mortality. A more appropriate regulation might govern the total number of hook POINTS allowed, with two being my preferred regulation. This would allow anglers to use either two flies each featuring a single point or a single fly with two hook points, or would allow lure anglers to fish either lures with one double-pointed hook (for example a treble hook with one point removed) or two single hooks (for example with two sets of treble hooks, with the trebles replaced by singles).
Closures due to high water temperatures and/or low streamflows are sometimes warranted, but I believe the criteria under which closures are instituted should be clarified. During the summer of 2007, portions of the Yellowstone (above the Lamar) and Gardner (above Boiling River) rivers were closed at the same time as the Firehole River, despite water temperatures averaging 15-20 degrees colder.
Thank you for your time.
Parks' Fly Shop