APW Trout Unlimited's Response to DEC Trout Management Plan

Below is the response drafted by the board of directors of The Ashokan-Pepaction Watershed Chapter of Trout Unlimited and presented to the New York State Department of Conservation regarding the draft proposal for changes to the statewide Inland Trout Management Program.

NYS DEC recently announced that they are accepting comments on their Inland trout stream management plan proposal until Thursday, June 25th.  DEC plan details can be found here: https://www.dec.ny.gov/outdoor/111015.html

The Ashokan-Pepacton Watershed Chapter’s board of directors conducted several virtual meetings to review and discuss this plan; chapter president Mark Loete drafted the letter on behalf of the board.  Its essence focuses on DEC’s classification of the Esopus Creek.  We encourage all chapter members and friends to review DEC’s proposal and submit their own comments.  A simple email will suffice.

Email your comments to: trout@dec.ny.gov

Or if you prefer, write and mail your comments to: Fred Henson, Coldwater Fisheries Unit Leader, NYSDEC-Division of Fish and Wildlife, 625 Broadway, Albany, NY 12233-4753

Ashokan-Pepacton Watershed Chapter – Trout Unlimited Response and recommendations to the NYS-DEC Trout Management Draft Proposal

The Ashokan-Pepacton Watershed Chapter of Trout Unlimited applauds the efforts of the NYS-DEC to update the trout management regimen in New York State to better address current realities. Our bailiwick in the Catskill Mountains is the drainages of the Ashokan and Pepacton Reservoirs – the Esopus Creek, Upper East Branch of the Delaware, and their tributaries. We are the anglers who live, work, and raise our families on these waters. We are the people who are on these rivers every day. We know them best. We welcome this opportunity to offer our observations and opinions.

The reputation of the Esopus Creek as one of America’s premier trout streams is well documented. It is widely regarded as one of the premier wild rainbow trout fisheries on the East Coast. As one of the Catskill drainages that comprise the “Cradle of American Fly Fishing,” the Esopus is an irreplaceable jewel in the crown.
The APWC-TU fully supports the new emphasis on the wild trout angling experience.

We cite the draft plan:

“The top five desired outcomes:” (page 10)

• The opportunity to catch wild trout and to a lesser extent stocked trout that have been in the stream longer that freshly stocked trout;

“Guiding Principles – wild trout” (page 13)

• We will always strive for self-sustaining populations with an emphasis toward native trout.

• Trout stream reaches will be managed according to their ecological potential.

• DEC will not stock in a reach managed for wild trout.

The draft proposal lists the Esopus Creek as a “Stocked-Extended” designation. We believe the high fish density, robust health and density of the self-sustaining wild rainbow population, mean size of the stream, unparalleled water quality (maintained by the NYC-DEP as 40-45% of New York City’s unfiltered drinking water), quality of habitat, and widely available easy access make the Esopus Creek the poster boy for designation as a “wild” fishery. No current verifiable data exists, but the DEC’s own internal memo from 1976 cited 9,400 fish per mile. Surely today’s population density exceeds the 300 trout/mile parameter for “Wild” trout management designation published in the proposal.

Based on the defining parameters published in the draft proposal, we ask that the DEC re-designate the Esopus Creek as “Wild-Quality” from the Allaben Portal to the Ashokan Reservoir, and “Wild” from the Portal upstream to its source. We further ask that the tributaries to the Esopus Creek (the wild trout nurseries) also be designated “Wild” category. The importance of a contiguous watershed of varied habitat for robust trout propagation is well documented.

The deleterious effect stocked trout have on a wild population is also well documented. (Fresh 1997; Hilborn 1992) In contrast, the Gunpowder River in Maryland, the Little Juniata River in Pennsylvania, the Battenkill (in Vermont) are regional success stories of how wild trout populations blossom when stocking ceases. The DEC’s own draft “Top five desired outcomes” states that “management success should be based on more than just catch of trout per hour”. The DEC designation of the Esopus Creek as “Stocked-Extended” would seem to abrogate the DEC’s own goal of managing for a wild trout preference in favor of increased angler catch rate (CROTS management model). In fact, the published target of 21,927 stocked fish per year would make this pristine trout habitat the most heavily stocked stream in New York State! Why is the Esopus singled out for CROTS management in contradiction of the DEC’s own stated goal of emphasizing wild trout management?

A self-sustaining wild trout stream is a precious thing. There aren’t enough of them. The Ashokan-Pepacton Watershed Chapter of Trout Unlimited respectfully submits the above for your consideration, and strongly urges that you reconsider the proposed designation for the Esopus Creek.

Mark Loete
President
Ashokan-Pepacton Watershed Chapter of Trout Unlimited
June 20, 2020

Sample Letter

Subject: Esopus Creek // "Wild" Designation

Hello Fred,

My name is FIRST LAST, and I believe we have a monumental opportunity to build and extend Esopus Creek's reputation as a world-class Wild fishery. I believe the Esopus Creek and NY State could become a national fly-fishing destination rivaling anywhere in the country, including wild rivers in Colorado, Montana, and Wyoming.

One of the greatest opportunities an angler can have is to catch a wild fish. The chase for fish that have existed for millions of years is exhilarating and taps into a deeper story. Fishing has never been about the literal story (as exemplified by countless fish stories exaggerating the size of our boyhood catch!), fishing is about a greater pursuit. And the most exhilarating pursuit for a fisherman is to catch wild fish.

Importantly, the pursuit of wild fish does run counter to the notion of abundant fish. As proven by other trailblazing fisheries over the past 30 years, a wild fishery can yield population density exceeding the levels of stocked trout. For some fishermen, the benefits of wild fish may be that they simply catch more fish. It's not an either / or scenario, it's a both / and. There is a proven path to have BOTH abundant AND wild fish, and that path allows NY's Esopus Creek to maintain it's reputation as the "Cradle of American Fly-Fishing" and lead us into a brighter future that attracts anglers across the state and beyond.

I respectfully ask that you reconsider the proposed "Stocked-Extended" designation, and instead redesignate the Esopus Creek as "Wild-Quality" from the Allaben Portal to the Ashokan Reservoir, and "Wild" from the portal upstream to it's source. Additionally, I ask that you designate the Esopus tributaries as "Wild". I believe we have an incredible opportunity that will change and extend the next 50-100 years of NY's great fishing legacy. I hope that you will strongly consider the above suggestions.

Best,
-FIRST LAST

*Special thanks to Rusty Ralston for generating this letter.