Anglers of the AuSable Members and Supporters,
Recently the DNR Fisheries division released a second draft of their
proposed Management Plan for Inland Trout in Michigan. The DNR is asking
for interested individuals to make comments to this draft plan. The
plan can be seen here. The first 45 pages contain the text of the plan and can be read quickly.
The first 45 pages contain the text of the plan and can be read quickly.
It is important that you respond to this request and send your comments to the authors before the April 14 deadline. Submit comments via email to DNR-FISH-ManagementPlans@michigan.gov by
Friday, April 14. Written public comments are also being accepted.
Please send them to Marquette Fisheries Research Station, attention Troy
Zorn, 484 Cherry Creek Road, Marquette, MI 49855.
I realize this is short notice but please take the time to send your
thoughts on this plan. It will help as we work with the fisheries
division to iron out our differences regarding the content of the plan.
To make this task a little easier we have posted a copy of our response
letter on our website. Additionally I have listed a few of our major
concerns about the current draft document below.
We previously provided comments to the first draft. In the revised
draft the authors removed the issue calling for the end of the use of
“flies-only” regulations that we found most inappropriate. We also
commented about several other areas of concern and none of those were
corrected. In order for the Anglers to endorse the plan we feel that the
following issue must be corrected.
Throughout the draft plan the authors use language and site references
to create the impression that “gear-restricted”(flies-only,
artificial-only, and no-kill) regulations are not effective or unfairly
treat the majority of anglers. The studies that they have cited are out
of date or use questionable data. They have also used data from
studies that have not been published or subjected to peer review. We
have provided more recent studies that discredit those cited. We have
also pointed out where the authors have “cherry-picked” data from some
studies while ignoring the conclusions cited in the study. To resolve
this issue we have asked that the authors remove all reference to data
that is not fully presented, documented or explained including method
confidence level.
There are also other minor issues that we feel should be corrected but do not carry the same importance as the one above.
We have asked that the DNR discontinue the promotion of wader wash
stations until a protocol for disinfection can be found that is useful
for killing New Zealand Mud Snails in a wader wash station. The current
methodology may inadvertently spread these invasive species instead of
controlling them.
The authors contend that there is no benefit from using barbless hooks.
It may be true that hooking mortality in reaches with gear-restricted
regulations will not decrease significantly. What we found in a
compilation of studies by Arlinghaus et al, 2007 is that while the use
of barbless hooks with flies may not lower hooking mortality it does
significantly reduce physiological damages of released fish. Our
concern is for the condition of the fish that are caught multiple times
in our heavily fished reaches. It is for this reason that we think this
issue, along with the use of single as opposed to treble hooks should
studied by the DNR Trout Team and the Cold Water Resources Steering
Committee.
The document also proposes allotting more time for Fisheries Division
Research Section to develop new models to be used for the management of
trout streams. We have proposed that the Regional Management Biologists
and their staff also need more time allotted to develop their
management prescriptions for these streams. We do not believe that
models will ever replace the value of a biologist or technician working
in the field.
Once these issues are corrected we will provide our support for this plan.
Thanks in advance for helping out with this important project.
Terry Lyons
Habitat Committee Chairman
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