Superintendent,
Sequoia and Kings Canyon National Parks,
47050 General Highway,
Three Rivers, CA 93271

I am writing for California Trout (CalTrout) to provide our comments on Preliminary Restoration of Mountain Yellow-legged Frogs: Environmental Assessment for Sequoia and Kings Canyon National Parks. CalTrout is supported by over 5,000 California citizens who fish in the state as well as 60 affiliated fishing organizations and clubs.

CalTrout strongly urge you to adopt alternative 1, and to avoid any unnecessary gill netting of wild trout. Your Park has not been planted with trout in decades and the wild trout in the High Sierra is a treasure valued by many California anglers. I feel more thought and input is needed before taking this drastic action.

The main reasons for our position is outlined in the attached policy of CalTrout. But in short, researchers have noted many factors that could be affecting these populations, including 1) Chytridiomycosis fungal infections, 2) Contaminants such as pesticides and acid rain, 3) Exotic species introductions such as trout and bull frogs, 4) Forest management practices, and 5) Ultra violet radiation. Given all these adverse factors affecting frogs aside from fish and prior failed attempts at reintroduction and repopulation, it is not at all clear that the proposed projects will work, especially at high altitude sites such as those proposed. There is current research already ongoing to attempt to answer that question in the John Muir Wilderness under the direction of Dr. Roland Knapp. CalTrout has supported Dr. Knapp?s work in the Muir as a logical first step in this process. Thus, our basic argument is that the outcome of the Knapp studies in the Muir should be known before one attempts the same experiment at the cost of the elimination of valuable trout populations.

I emphasize that I take this position not only as a Board Member of CalTrout but as a physician-scientist and tenured professor at Stanford Medical School. I currently receive over 3M$ a year in peer-reviewed funding from the federal government to support my research. I emphasize that if this study were proposed to any National Institute of Health peer review panel for funding it would not be funded as it replicates ongoing work. The bottom line is that either the ongoing work is inadequate and should be stopped, or one needs to wait for its outcome before one proposes the next logical step in a scientific investigation.

In addition to the global problem I have with this proposals overall design, there are some more specific deficiencies:

1.There does not appear to be an appropriate way and to evaluate the outcome of the project.
2.There seems to be an under estimation of the difficulty of removing trout from lakes using gill netting.
3.There is no plan to prevent the potential reintroduction illegally of fish into the lakes in question.
4.The background section is deficient. For example only two sentences regarding the potential for fungal infections in amphibians.
5.There is no mention of statistical analyses or control populations.

Furthermore, I would suggest that before any action is taken to remove Golden Trout (GT) from any lake in California that you consult carefully with the State of California Department of Fish and Game. This fish has just been proposed for listing as an endangered species. My understanding is that some of these areas proposed for gill-netting were originally (before 1920) planted with GT taken with hook and line directly from the South Fork of the Kern or its tributaries. Thus the GT may be pure, near pure or good quality hybrids (i.e., few rainbow trout alleles). Your actions may be contrary to major efforts made by the State of California, US Fish and Wildlife and the US Forest Service to save relatively genetically pure reservoirs of this fish. Furthermore, the gill netting itself may reduce populations of a species that may be soon listed. In this context, furthermore, one wonders why not wait until the frog is listed and a full recovery plan instituted. The proposed actions may eventually be contrary to such plans and as such a potential embarrassment to the NPS. Thus, we feel you need at a minimum full service to applicable NEPA standards, input from all relevant groups, and this process needs to be exhaustive, public and transparent.

Finally, I would emphasize that I have personally visited some of the lakes proposed for gill netting and have seen the fish in those lakes eye to eye. These are beautiful lakes and beautiful fish. The argument that few people may fish them so they are prime candidates for netting is analogous to saying that it is fine to drill for oil of the North Slope in Alaska since few people go there either. It is the quality of the angling experience that is at risk in those areas, and such quality angling experiences are all too rare in California today.

Yours truly,



Jerome Yesavage
Governor
California Trout