Maine Department of Inland Fisheries and Wildlife Approves Crescent Pond Stocking
In a disappointing decision, Maine Department of Inland Fisheries and Wildlife (MDIFW) has decided to go forward with a plan to stock Crescent Lake in the Allagash with lake trout from another water.
A related proposal to remove Crescent Pond from the State Heritage Fish (SHF) list was not challenged by NFC due to the fact it had been stocked within the last twenty-five years and was therefore ineligible for SHF designation under the law.
Unfortunately, removing Crescent Pond from the SHF list removed the prohibition on stocking provided by the SHF law. This left no legal challenge to the proposed stocking so all we could do is challenge it via the rule-making process.
This proves once again why the SHF law is so important and such a necessary check-and-balance. A similar proposal to stock Arctic charr from another water into a SHF water was withdrawn after NFC, TU, Audubon, and SAM all opposed it.
The proposal to stock lake trout from a secondary source to try to control state-introduced smelts that are stressing rare native whitefish was opposed by NFC for several reasons:
• Stocking is what got us into trouble at Crescent Pond in the first place, the state-sponsored introduction of highly invasive smelts. While you can stock your way into trouble, you can rarely stock your way out of it.
• Stocking lake trout at a rate of 200 or so fish as stated in the proposal to try to reduce introduce smelts that are competing with the native whitefish is unlikely to have any real or long-term effect on the smelt population. Smelt are highly fecund and capable of laying from 20,000 to 80,000 eggs depending on their size. A far more affective, and safer, way to reduce the smelt population would be targeted bulk removal as is being done at Bald Mountain Pond.
• Lake trout are highly piscivorous – they eat mostly minnows. Prior to the introduction of smelts it is likely that whitefish were their primary forage. It is fair to assume that the stocked lake trout will not only eat the undesirable smelt, but some level of whitefish, the species you are trying to protect. The low recruitment of lake trout noted is probably what allowed the whitefish and lake trout to coexist peacefully prior to the introduction of smelts. Artificially increasing the lake trout biomass could have unexpected results.
• If "Spawning habitat is limited for lake trout" as is stated, a single stocking event would at best provide temporary relief. Our concern is that this could become an ongoing and costly, and potentially ineffective, program.
• As a water that has not been stocked in eighteen years, Crescent Pond is now seven years away from being considered for SHF designation. Stocking it with lake trout would set the clock back to twenty-five years, putting the genetically pure native brook trout population at risk of intra- or inter-species stocking, disease from stocking, predation, etc., for over a generation to come
• There are no special regulations in place to protect the whitefish in Crescent Pond – they fall under the "General Law" which allows 3 fish of any length to be taken per day. Before we stock lake trout to eat the introduced smelts to try to save the whitefish, it would be prudent to put a catch-and-release restriction on the fish you are trying to protect – whitefish.
• The rules in place for lake trout allow one fish to be taken per day. Since we are trying to use lake trout to keep the smelt in check, it would be prudent to protect these fish with a catch-and-release regulation rather than use supplemental stocking which comes with a cost and a number of risks such as disease and parasites, accidental fish introductions, etc.
In response to our concerns and the concerns of others, and as part of the public notification process, MDIFW defended their decision to go forward with the Crescent Pond stocking proposal as follows:
• [The source water for the lake trout] is within the drainage and a reoccurrence of a previous transfer and therefore does not pose a disease or pathogen risk to resources of the State.
NFC Comment: The last transfer was done 18 years ago. Are we 100% sure that nothing has happened to the source water since then?
• This transfer is considered to be an experimental strategy to suppress smelt and will be assessed following transfer to document effects.
NFC Comment: A similar experiment using splake on Thissell Pond failed to reduce the smelt population leading to the eventual and severely delayed reclamation of the pond. And this involved significantly more fish than is being proposed here. Also no data has been provided indicating whether the first attempt to do this had any measurable impact on the smelts.
• Transferred Lake Trout will be marked so their origin can be identified during future surveys.
• The Department acknowledges that this strategy is not a long-term solution and will continue to explore opportunities for long-term conservation of Lake Whitefish. In this situation, use of a temporary strategy over doing nothing reduces the risk of extirpation of another Lake Whitefish population in Maine.
• Lake Trout may interact with Brook Trout and Lake Whitefish to a minimal extent, but the overall effects are expected to be positive, and the assemblage more accurately represents the historical occurrence of these three native species in Crescent Pond.
NFC Comment: Any artificial manipulation of the population could be a threat to either or both brook trout or whitefish. A tilt toward more lake trout than are occurring naturally could do more harm than good.
• The Department acknowledges that allowing recreational harvest of Lake Whitefish and Lake Trout may be perceived as inconsistent with management objectives. However, due to its remote location, angler use at Crescent Pond is extremely low and the few anglers that do fish it, rarely encounter Lake Whitefish or Lake Trout. Crescent is closed to ice fishing and the use of live fish as bait is prohibited. A special regulation prohibiting harvest would have little effect as harvest is not a limiting factor, but would largely serve to alleviate the perception of a concern. Having said that, the use of regulations that eliminate the perception of inconsistency may be explored in the future.
NFC Comment: We believe this is more than just a “perception”, and common sense says that anglers are having at least some negative impact on both the stressed whitefish population and the apparently important lake trout. And if anglers “rarely encounter” whitefish or lake trout, then prohibiting the harvest of such should not be a problem. When a population of any form of wildlife is in trouble, stopping the recreational harvest of such is standard practice.
• Physical removal of smelt (as has been experimentally attempted at Bald Mountain Pond) is a possible strategy that has been considered. However, the long-term results of this strategy are not yet known and are currently being evaluated at Bald Mountain Pond. The remote location of Bald Mountain Pond creates significant challenges with the execution of this strategy. Crescent Pond is located in a far more remote area of the state, and therefore is not a suitable candidate for this highly intensive, time consuming, and yet to be proven suppression strategy.
NFC Comment: While unproven, it is hard to believe that 200 lake trout in a 320-acre pond could have any more affect on the smelt population than even a marginally applied removal program.
• Crescent Pond has recently gone through the APA rulemaking process to be removed from the State Heritage Fish Waters list, because the transfer that occured in 2000 violates the eligibility criteria. Crescent will officially be removed on October 1st, 2018 and the transfer will not occur prior to that date.
NFC Comment: With the exception of the previous 200-fish lake trout stocking, Crescent Pond has never been stocked. The brook trout are likely genetically pure and classified as a “Principal Fishery”. As a result of this “experiment”, Crescent Pond will not be eligible for SHF designation for 25 years or more. If the proposal was withdrawn, we could revisit it in just 7 years and get it the designation and protection the resource warrants.