!!!!ALERT!!!! We only have until 3-18-11 by 5PM to submit comments to DFG on this one. If this happens trout planting in CA will become a thing of the past in most waters, just to protect this frog.

I have just learned that CA DFG intends to put the Mountain Yellow-Legged Frog on the CA Endangered Species List. They supposedly announced this Feb 16, 2011 and gave us until Mar 18 to submit public comments. Did anyone else hear about this? Here's there public notice.

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

Who's behind this? The Center for Biological Diversity. Here's their Press Release from Jan 2010 which puts most of the blame squarely on DFG and trout planting.

http://www.biologicaldiversity.org/news/press_releases/2010/mountain-yellow-legged-frog-01-25-2010.html

Here is a link to the Wikipedia page on this frog:

http://en.wikipedia.org/wiki/Mountain_yellow-legged_frog

DFG has already stopped planting in some places, but if this widely spread frog population is put on the CA ESL it could force them to shut down planting in a whole lot more streams and lakes.

We need to write Letters to DFG now, to oppose the listing of this frog.
Time is short, so please E-mail your comments to Mitch Lockhart at:

MYLF@dfg.ca.gov

or send overnight to this address:

Fisheries Branch – High Mountain Lakes Program
Department of Fish and Game
Attn: Mitch Lockhart
830 S St.
Sacramento, CA 95811

Mitch's Office # (530) 906-3934

Thanks for posting this.

The question is, what will CBD go after if the yellow-leg frog is listed?

Will they only go after trout stocking in locations where yellow-leg frogs are present today? What about historical presence?

What about trout stocking in general, eg warm water fisheries where yellow-leg frog was never present.

I see Jeff Miller is the one working the issue. Jeff is also head of Alameda Creek Alliance, same organization that got Alameda Creek closed to all fishing including Shadow Cliffs Back Ponds.

But Jeff was also very reasonable about getting those ponds re-opened and went so far as to send a letter to DFG Commission in support of reopening the ponds.

So I would not view this listing as the sky is falling necessarily. I'll try and call Jeff soon to get an understanding as far as what they are after with regards to the listing.

If they are only interested in stopping trout stocking for locations with historic yellow-leg frog populations where trout are the competing apex predator, I don't have a huge problem with that.

If they're after trout stocking at warm water reservoirs where trout are the infinitesimal factor in frog population decline, then I would have a problem

Generally, when I read the CBD press release which attributes yellow-leg frog population decline to stocked trout as the primary cause, I cringe because that logic has to be flawed. Trout stocks have not increased significantly at high-sierra locations in recent times. So to say that suddenly yellow leg frog populations are down because of trout stocking is probably not correct attribution of the problem.

The factual data that should be presented (but is not in the CBD press release) is a comparison of stocking data against frog populations.

I have to agree with you swimbait, for the most part.

But what happens after the Mountain Yellow-Legged Frog (MYLF) is listed as Endangered is anyone's guess and could negatively impact us in the future. Will DFG say we cannot wade in streams because we will kill eggs and tadpoles and frogs, or disturb the habitat of the Endangered MYLF? Sounds like the CBD would like that, among numerous other protections for this frog.

BTW - Why hasn't the DFG started a MYLF planting program. I mean, how hard can it be to raise frogs? :)

Since the USFWS chose not to immediately list the MYLF as Endangered, where is the current 2011 scientific data showing they are "now" endangered. It's quite possible that the current restrictions on trout planting in some waters has already made a positive impact on a species that was not yet Endangered, by definition.

I think we should all write comment letters to the DFG and e-mail them up to Sac by 5PM tomorrow, and oppose the ESL listing before this gets way out of control.

Just doing my little part here, to make folks aware of what's happening in Sacramento, that could affect them someday. If this goes through we'll never be able to get it off the ESL, then we are at the mercy of the next CBD, or the next DFG Program Manager trying to appease them.

OK. Thanks for listening folks. Ive said my piece, and now I'll get down off my soapbox *L*

Regards
Mike

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