The date for giving public comment has been extended to April 1, 2011 because of a website glitch with the DFG. I submitted the comment below


Re: http://cdfgnews.wordpress.com/2011/02/16/dfg-seeking-public-comment-regarding-proposed-listing-of-mountain-yellow-legged-frogs/

I'm writing to give public comment on the listing of Mountain Yellow-Legged Frogs.

There are two aspects to this listing:

1. Whether or not the Mountain Yellow-Legged Frog is indeed endangered as defined by the relevant government regulations.

2. If the Mountain Yellow-Legged Frog is listed as endangered, what mitigating actions the CA DFG will take

Not being a scientist or one who studies frogs, I'm not qualified to speak to #1. However, when reading the Center for Biological Diversities' public statements regarding this listing, it is apparent that they are most interested #2 and are already stacking the "public relations deck" with the notion that stocked trout are the primary cause of frog population decline.

I sincerely hope that if the frog is listed that the Department will rely on peer reviewed scientific data when establishing the true causes for declines in Mountain Yellow-Legged Frog populations and planning subsequent mitigations. While any 5th grader can do a science experiment to prove that rainbow trout will eat something small and wriggly like a frog tadpole, it will take far more analysis to determine if stocked trout are a primary causal factor for frog population decline in all locations of historic abundance or just a small contributing factor.

It seems apparent that the Center for Biological Diversity has made the correct observation that stocked trout form the cornerstone of recreation in the state of California. It seems apparent that they have begun a campaign to reduce or eliminate the stocking of trout in the state. It seems apparent that they know that in a multi-decade time frame, if they can eliminate trout stocking in the state, they can reduce the number of anglers in the state. They know this because they know where fishermen get their start in this state. They get their start fishing for stocked trout. The CBD has a long history of using specific regulatory nuances to force regulating entities to make decisions that support an unrelated or tangentially related end-game on the part of the CBD. Everything about this issue reeks of this same strategy.

While the Department may be forced to list the Mountain Yellow-Legged frog as endangered and while that may be the correct decision, the Department should not base subsequent mitigating actions on speculation or Center for Biological Diversity press releases. Those decisions should be based on unbiased science.

Sincerely,

-Rob Belloni
Owner: www.calfishing.com