[CMCEmail] Action Alert: Comments due THIS TUESDAY (12/17)
cmcemail at californiamountaineer.com
Sun Dec 15 21:02:45 EST 2013
w6swDb52nue5taWsNZPXL4VNAmeLQ==> HSHA mountain range logo and address
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
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
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
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
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
3) The impacts of physical fish removal on the enjoyment of park visitors
would be far less than the massive intrusion of chemical poisoning
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
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
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
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
Sequoia and Kings Canyon National Parks
ATTN: Restoration Plan/DEIS
47050 Generals Highway
Three Rivers, CA 93271
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 !!!
NPS project website
for SEKI poisoning plan
High Sierra Hikers Association | P. O. Box 8920 | South Lake Tahoe | CA |
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