I urge all SEKI backcountry users to read through this High Sierra Hikers Assoc. alert.
Comments Due this Tuesday (Dec 17) by 10:59 pm Pacific Time
Tell the Park Service how you feel about its proposal to use chemical poisons to remove fish from lakes and streams in Sequoia and King Canyon National Parks
Background
Sequoia and Kings Canyon National Parks (SEKI) recently released a Draft Environmental Impact Statement (DEIS) that proposes to "restore" native species in high-elevation aquatic ecosystems within these parks. The plan focuses on eradication of nonnative trout from numerous backcountry lakes for the primary purpose of improving conditions for mountain yellow-legged frogs, which have suffered significant declines in recent decades, are preyed upon by trout, and are at growing risk of extinction due to several environmental stressors.
The plan calls for fish to be removed from 32 backcountry lakes, 50 ponds, 5 marshes, and 41 miles of streams. SEKI's "preferred alternative" proposes to use a combination of both physical methods (i.e., electrofishing, gillnetting, and manual destruction of fish nests or "redds") and poisoning wilderness waters with chemical pesticides.
The plan calls for poisoning 6 lakes, 26 ponds, 4 marshes, and 27 miles of stream---in some of SEKI's most remote and pristine areas---using pesticides containing rotenone, which kills all gill-breathing organisms by blocking the uptake of oxygen. Lakes on the "hit list" for chemical poisoning include: Amphitheater Lake (near Observation Peak), Slide Lake (near the Monarch Divide), lakes and ponds in lower Sixty Lakes Basin, Moose Lake (near Tablelands and Tokopah Valley), and two unnamed lakes in the headwaters of the Kern River (near Lake South America). The 27 miles of streams proposed to be poisoned include streams that connect various lakes and ponds, as well as streams below lakes that would be treated using only physical methods.
The High Sierra Hikers Association supports reasonable efforts to protect and restore the disappearing mountain yellow-legged frog, but we strongly object to the use of chemical poisons in SEKI's wilderness, for numerous reasons. First, the use of poisons is unnecessary; fish could be removed using manual methods. Second, many areas of the park would be closed during chemical poisoning, significantly affecting wilderness visitors. Third, wilderness waters would be unsafe to drink for weeks (or even months) after poisoning. And fourth, fish poisons such as rotenone are non-selective, and are known to kill other non-target animals.
The National Park Service (NPS) euphemistically labels rotenone and other fish-killing chemicals as "piscicides," implying that such poisons are selectively toxic to fish; however, the reality is that they are toxic to any gill-breathing organisms, including amphibians, aquatic insects, zooplankton, and other invertebrates. Consequently, the NPS is in effect arguing that the aquatic ecosystems to be "restored" for the benefit of frogs must first be largely destroyed.
The DEIS freely acknowledges that rotenone will have severe impacts on aquatic invertebrates and other non-target organisms, but opines that these impacts are outweighed by potential benefits to frogs and other organisms that are preyed upon by fish.
The NPS attempts to rationalize the use of chemical poisons by arguing that attainment of its restoration goals cannot be achieved using physical methods alone. It argues that 100% eradication of fish from the lakes it wants to poison is not possible because the lakes are "too large and deep" for physical methods. Yet, the NPS acknowledges that it has already entirely removed fish from 11 lakes within SEKI using only physical methods, and two of those lakes are larger in size than most (four of the six) lakes now proposed for chemical poisoning.
As one example, the NPS proposes removing fish from Wanda Lake---at 228 acres the largest lake in SEKI in terms of surface area---using only physical methods. How is it possible that NPS can achieve fish eradication in this lake using gill nets, but not in Amphitheater or Moose lakes? The likely answer is that the NPS does not want to employ chemical poisoning in full view of the public. Wanda Lake lies along the John Muir Trail, and the NPS would likely have to close the area to human use if this lake were to be poisoned.
The NPS also rationalizes chemical poisons in stream/wetland networks because they are "too complex" to eradicate fish using electrofishing and gill nets. Yet those same characteristics also make it extraordinarily difficult to achieve a complete fish kill using chemical methods. This means that many lakes, streams, and ponds would have to be repeatedly poisoned---multiple times over multiple years. And during those treatments the areas would be repeatedly closed to public use until the concentration of rotenone decreases to "safe" levels.
Because the breakdown of rotenone is temperature dependent (i.e., rotenone persists longer in cold water), it will be weeks or even months before wilderness visitors could safely drink the water after it is poisoned. Additionally, helicopters and/or packstock (i.e., horses and mules) will be used to transport supplies and crews of 8 to 15 people into these remote locations for these treatments, resulting in noise, commotion, damage to fragile ecosystems, and diminished opportunities for solitude.
The DEIS fails to present any compelling evidence that chemical poisoning of wilderness waters is essential for accomplishing the objective of establishing a network of refuge areas for frogs, and HSHA believes that these goals can be met using non-chemical methods, which are far less destructive to aquatic ecosystems, and far less intrusive for wilderness visitors. In short, despite the NPS's claims, the use of poisons is a matter of expediency, not necessity.
What you can do:
Send a letter or electronic comments to the Park Service saying that you strongly oppose the use of chemical poisons in the wilderness of Sequoia and Kings Canyon NPs. Here are some points that you might consider making in your letter, though please keep in mind that it is most effective if you use your own words to describe how the poisoning of wilderness waters would impact your use and enjoyment of SEKI's magnificent backcountry.
1) The DEIS fails to provide a compelling rationale for the necessity of chemical poisoning. Fish removal in most of the areas proposed for chemical treatments could be achieved through manual/physical means. In areas where physical removal is truly not possible, the Park Service should look for opportunities in other basins where fish could be removed by physical means, rather than resorting to chemical poisons.
2) As documented in the DEIS, chemical treatments have severe impacts on aquatic invertebrate communities even at the concentrations proposed for use by the Park Service. Point out that rare and/or endemic invertebrate species may be extirpated by chemical poisons, causing irrevocable changes to these ecosystems.
3) The impacts of physical fish removal on the enjoyment of park visitors would be far less than the massive intrusion of chemical poisoning operations.
4) Evidence from numerous other rotenone applications in the West indicates that frequently a single rotenone treatment does not result in a 100% fish kill, thus requiring multiple treatments over multiple years. Consequently, both the ecological and aesthetic impacts are more severe than the DEIS discloses.
We know this is a busy season of year, and that we haven't given you much time to respond. But your letter can be brief. The most important thing is to let the Park Service know that the public is strongly opposed to the use of highly destructive chemical poisons within wilderness areas---areas that are afforded the highest level of protection of any lands in the United States.
The deadline for electronic comments is:
10:59 PM Pacific Time, Tuesday December 17
Comments can be sent directly to the Park Service via its website at this link:
http://parkplanning.nps.gov/commentForm ... ntID=55701
The NPS's comment webpage for this project will disappear at midnight Mountain Time. You must hit the "send" button by 10:59 Pacific Time.
Comments can also be sent via regular mail (postmarked by Dec 17) to the following address:
Superintendent
Sequoia and Kings Canyon National Parks
ATTN: Restoration Plan/DEIS
47050 Generals Highway
Three Rivers, CA 93271
Fax: 559-565-4202
Please DO NOT forward this alert to the Park Service with your comments. (It's better to not comment at all than to forward our alert to the NPS.)
Get involved. Together, we can make a difference !!!
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~