New Hampshire Fish & Game Denies NFC Wild Trout Management Signs

 
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We are disappointed to announce that New Hampshire Fish and Game (NH F&G) has denied the New Hampshire chapter of Native Fish Coalition (NH NFC) request to post informational signs at New Hampshire's formally designated and specially regulated Wild Trout Management (WTM) waters.  To view the letter from NH F&G click here

Note: Another potential co-sponsor of the sign was contingent on NH F&G endorsing the project.  We have removed their logo from the proposed sign and caampaign at their request. 

Endorsed by The Nature Conservancy, Tin Mountain Conservation Center, Natural Resource Conservation Service, New Hampshire Rivers Council, Mountain High Fly, North Country Angler, Lopstick Lodge and Tall Timber Lodge, the intent was to inform anglers and others as to the status of the respective water (self-sustaining) and the rules in place to protect it.  To learn more about the project click here

In addition to addressing the refusal itself, there are some specific statements made by NH F&G in the letter that we would like to discuss further.  We will be replying to NH F&G in detail with copies to our sponsors and partners to formally address these concerns.  This letter will be posted on our website and Facebook page as well.

Below are the specific comments that concern us most and why:

...many of these waters that fall under ‘wild trout management’ have not been adequately evaluated since the regulations were implemented. Staff feels it is important to first evaluate the effectiveness of these regulations prior to enhancing the promotion of such waters.

The WTM waters are already "promoted" as a group on the NH F&G website.  A simple "wild trout" search from the website will direct you to the page (see below).  One can easily Google their way to the page as well.  Click here to view.  

https://www.wildlife.state.nh.us/fishing/trout-mgt.html

https://www.wildlife.state.nh.us/fishing/trout-mgt.html

The WTM waters are also included in the online and print versions of the New Hampshire Freshwater Fishing Digest.  While they are not specifically noted as WTM waters, their regulations state "Managed for wild trout" - click here to review (scroll down to Carroll Brook for an example.)

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http://www.eregulations.com/newhampshire/fishing/freshwater/rivers-streams-special-rules/

http://www.eregulations.com/newhampshire/fishing/freshwater/rivers-streams-special-rules/

...the Department does not want to imply that we are giving up our control over how various waterbodies are managed... Implying that we are engaged in a partnership for wild trout management would jeopardize the agency’s flexibility to adapt our management of certain waterbodies.

Putting up signs that state what the rules in effect today are does not in any way imply "giving up control."  How waters are managed at any given time is solely up to NH F&G.  We are simply talking about what is happening now and if the rules change the signs would be taken down or changed accordingly.

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Government agencies co-branding with organizations and businesses on signage is a common practice.  In fact, the Maine chapter of Native Fish Coalition is doing exactly that with Maine Department of Inland Fisheries and Wildlife as well as Maine Department of Marine Resources.  These signs involve 578, 20+ (and countless miles of river and stream), and 10 waters respectively.  Click on sign to read more. 

Other example of where government agencies, non-profits, and businesses have co-branded on informational signs are numerous, broad ranging, and found throughout the country.  Many involve state fish and game agencies: 

In fact, NH F&G has partnered with other organizations such as New Hampshire Lakes and New Hampshire Audubon on co-branded signs:

The Department already produces signs with our wild trout regulations on them. If signage needs to be updated for a particular water, please do not hesitate to contact us and we will request the appropriate staff member address the signage shortcomings.

NH F&Gs statement that they already have WTM signs, and are willing to post such if asked to, contradicts their earlier statement about drawing attention to these waters.  And the statement "signage shortcomings" implies that signs are in fact warranted, and in some cases missing.

Unfortunately, having NH F&G print and post signs to address WTM waters that no longer have them, which is most, would have to be done at the expense of the department, and by default sportsmen who fund them through their license purchases.  

...when promoting sensitive wild trout fisheries we have concerns about an increase in angler pressure on these fragile ecosystems.

Again, the WTM waters are already listed on NH F&G website under the WTM program, as well as the online and printed rule books (see above.)  And these waters once had signs on them and apparently some still do.  Plus as noted above, NH F&G has offered to put up their standard WTM sign if we would like them to. 

It is also important to note that these waters have tackle, harvest and season restrictions to protect the fish.  These restrictions are similar to those found on the Rapid and Magalloway rivers in Maine, two of the finest and most heavily fished rivers in New England.  And due to the small size of the WTM waters, the small fish typically found in them, and the type of angler attracted to waters with tackle restrictions and harvest prohibitions, it is unlikely that angling pressure would increase noticeably. 

Lastly, the proposal was to be able to post signs at access points.  Unless you happen across these signs you would not know they are there.  What NH F&G is doing on their website is drawing far more attention to these waters than what we are proposing.  But to be clear, NH NFC does not see strictly regulated pressure as an issue as evident by the fact that many of the nations finest fisheries are heavily fished.   

...if it is later decided that the current regulations are ineffective, not suitable for this particular management, or if the Department chooses to initiate stocking due to a population decline and there is a need for reintroduction.

The above statement is especially concerning as it implies a possible migration away from the absolute protection these waters have been granted since their inclusion in the WTM program.  This mirrors some of what we have heard from others at NH F&G in the past who have stated that they are no longer sure that catch-and-release (C&R) is warranted, and that some waters may be removed from the program due to "low usage."

And the fact that stocking is entering this conservation at all should be of great concern to anyone who cares about wild native brook trout.  The WTM waters represent some of the only accessible self-sustaining native brook trout waters in the state.  They are some of the only places in the state where anglers can enjoy season-long fishing for trout as most stocked fisheries decline noticeably once stocking has been suspended for the season.      

While the WTM waters are not currently stocked, prior to their inclusion in the program they were.  This was not only a biologically unsound practice, the position that stocking is bad for wild fish is virtually unchallenged, it was also economically unsound as it was unnecessarily costing NH F&G and by default sportsmen money.

We are unaware of single WTM water where the wild trout population has declined to a point where stocking would be warranted.  In fact, most boast what would be considered relatively robust populations after twelve or more years of not being stocked.  In addition to having what would be termed "natural" population levels, they also have natural distribution unlike stocked waters where fish are most common near stocking sites.   

 
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New Hampshire's WTM waters offer a type of fishing not found in many places in the state -- uncompromised wild native brook trout.  Brook trout are New Hampshire's official freshwater fish, and worthy of far more protection than they are currently getting.  They need more protection not less and any discussions to the contrary should be challenged. 

The WTM waters also save NH F&G, and by default sportsmen, money while allowing stocked fish to be used where they are truly needed.  Most accessible rivers and streams in New Hampshire are stocked.  Most ponds are as well -- including remote waters stocked by plane.  The WTM waters are an exception to the rule.       

 
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New Hampshire's WTM program is best-in-class when it comes to the inclusion criteria (see below).  Unlike Maine's State Heritage Fish (SHF) law which requires that a water not be stocked for 25-years before it can be included, New Hampshire's WTM program is based on the "presence" of wild trout at a defined level, and regardless of whether it is currently being stocked.  

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New Hampshire's WTM program is also best-in-class in regard to the protections it provides.  Unlike Maine's State Heritage Fish (SHF) law which only prohibits the use of live fish as bait (worms are allowed on many waters), New Hampshire's WTM program restricts tackle to single hook barbless lures and flies only to lessen incidental mortaility, prohibits the harvest of fish (C&R), and closes the season early to protect spawning fish.   

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It is also important to note that unlike Maine's State Heritage Fish law which only prevents waters from being stocked the future, New Hampshire's WTM program actually stops active, and by default unnecessary, stocking programs saving NH F&G and the anglers that support them through their license purchases money.

Unfortunately, New Hampshire's WTM program has been very lightly applied.  Specifically, there are just thirteen WTM streams statewide which represents just a fraction of the actual, and potential, self-sustaining brook trout streams in the state.  And at just three ponds, while better represented than streams this too is an incomplete list. 

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Interestingly, there are no WTM designated streams in the White Mountains Region, home to the densest population of wild trout streams in the state.  The same can be said for Pittsburg, the most popular brook trout fishing destination in the New Hampshire, and in this case there are no streams or ponds.   

 

WTM PROGRAM STATUS

At best New Hampshire's WTM program is badly stalled out.  While referred to as "ongoing" by NH F&G, they have not added a water in twelve years even though there are a number of waters that according to their own data clearly meet the inclusion criteria. 

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For example, the Wildcat River in Jackson, one of just two Wild & Scenic Rivers in the state, has not been added to the WTM program even though NH F&G survey data shows a wild brook trout biomass well over the WTM program inclusion criteria.  Members of NFC have tried for three years to get this invaluable resource the protection it deserves.

Another example is the Dead Diamond River near Errol, considered by most to be the finest wild native brook trout river in New Hampshire, and one of the four best in the country along with the Rapid, Magalloway, and Kennebago rivers in Maine.  After roughly seven years of "studying" the river, no action to further protect it has been taken.   

 

CONCLUSION

It is clear that NH F&G is not as committed to wild trout management, or the Wild Trout Management program, as it once was.  It has been over a decade since they added a water to the WTM program, the only formally designated wild trout waters in the state and some of the only unstocked easily accessible trout waters in New Hampshire. 

We at NFC are gravely concerned that the WTM program could be weakened, or have waters removed from it.  This should concern anyone who wants more than just stocked and nonnative fish in New Hampshire.  We will need to work very hard to keep this program from being weakened, downsized, or worse, terminated.   

If you disagree with NH F&Gs position regarding the joint NH NFC/NH TU WTM sign proposal and/or are concerned about what you have read here, we strongly encourage you to contact the following people and voice your displeasure:

Jason Smith, Chief - Inland Fisheries Division (jason.smith@wildlife.nh.gov)

Glenn Normandeau, Executive Director (director@wildlife.nh.gov)

New Hampshire Fish and Game Commission - click here for contact information

 
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