April 14, 2017

Gentlemen,

Thank you for the opportunity to comment on the 2^nd draft of the Management Plan for Inland Trout in Michigan.  After submitting our comments to the first draft of this document we were confident that the second version would be an improvement. We provided comments that reflected the concerns of our membership and made recommendations intended to make the document acceptable to a majority of inland trout anglers.

Upon reading the first few pages of the draft plan we were encouraged that the authors had removed the wording regarding flies only regulations that we found most inappropriate. Unfortunately, as we proceeded through the document we discovered only superficial changes had been made throughout the rest of the plan and most of our recommendations were ignored.  Under the heading of Gear Restricted Regulations, none of the statements backed by discredited studies or the use of cherry-picked data were corrected.  Additionally the authors have added statements that reflect negatively on the use of Gear Restricted Regulations.  The original draft included a statement correctly pointing out that Gear Restricted reaches were some of the most heavily used by anglers.  In the second draft, this statement was removed, all that remained was a statement intended to present these regulations in a negative way. It is our expectation that the final version of this trout plan document will remove all reference to data that is not fully presented, documented or explained including method confidence level.  If these actions are not taken we will continue to oppose the implementation of this document.

The remainder of our comments will list the sections of the draft with which we have concerns. We will also provide supporting documentation where appropriate for these proposed modifications to the document.  Unlike the way this process was handled during the first comment period it would be most helpful if the authors would respond to this correspondence and share their reasons for not utilizing our suggestions.  This will facilitate a discussion that will hopefully lead to a finished document that we can support.

Goal 1,

p-1

lines 56-137:  The Anglers of the AuSable support this section with the following

suggestions.  This goal includes proposed specific actions.  It is not clear who is

responsible for carrying out these actions.  If responsibility is assigned it will

provide accountability and proper oversight of the implementation of these

objectives.

issue 13

p-3

lines 135-39: We agree that there are great demands placed upon the

Research Section staff, but there are also significant demands placed upon the

regional Management Biologists and staff as well.  These biologists and staff

should also be provided adequate time and resources to do what is required of

them.

Goal 2,

p-4-5

lines 142-207:  We support this section as written.

Goal 3,

p-5

lines 210-251:   We support this section with the following suggestion.  Under

Issue 3, lines 227-8 the authors recommend working to install more wader wash

stations.  We have been actively involved in the invasive species efforts of the

Fisheries Division and the DEQ.  Since the discovery of New Zealand Mud

Snails in the AuSable River we have expressed our concerns to both agencies

regarding the use of the wader wash stations.  There is currently no protocol for

controlling the spread of NZMS that is applicable with the wader wash stations.

With that in mind we are no longer maintaining the wader wash stations that we

have installed at fly shops on the AuSable river.  The concern is that mud snails

could actually be spread by the improper use of the wader wash stations instead

of the intended result.  We suggest that for now this statement be removed or

corrected to state that when a suitable protocol is developed the wader wash

stations will again be promoted.

Goal 4,

p-6

lines 254-290:  We support this section with the following changes.

Issue 2,

p-6

line 263:  The second sentence stating that Gear Restricted rules are

controversial is not required to promote the message of this issue.  All

recommendations for new regulations or changes to existing regulations are

vetted through the Fisheries Division Management Team, the Trout Committee,

the CWRSC.  There is also opportunity for public comment before the

regulations are proposed to the NRC for approval. We request that this statement

be removed.

Issue 3,

p-6

line 274:  This issue begins speaking of the use of C&R regulations in

the off season to provide additional angling opportunity.  The final sentence then

refers to using type 4 regulations which are not C&R.  We suggest removing the

last sentence or re-writing the entire section to reflect the desired objective.

Issue 6, line 287:  The sentence states that statewide regulations were last

reviewed in 2008-9.  Coldwater regulations were reviewed in 2009-10 and

implemented in 2011.  It was agreed at the time of the approval of the current

suite of regulations by the CWRSC that they would be left in place at least five

years.  It is now time to consider this review.

Goal 5,

p-7-8

lines 292-325:  We support this section with the following comment.  It is critical

that DNR personnel are also open to opinions that are different than theirs.  It is

also possible for agency personnel to inject bias into their communications.

Biology of Trout,

pages 17-18

lines 764-82:  This section contains 16 lines of data that

repeat the same information.  One study should be enough to demonstrate the

percentages of hooking mortality in trout.    The Shetter and Allison data seems

representative and should suffice to document the data.  The section on “actively

fished bait” is not germane to this discussion unless you are proposing it as a

regulation type.  This information adds nothing to the document and serves to

reinforce the perception that the authors are promoting that method of angling.

page 18

lines 783-7:  The document states that the use of barbless hooks have

been promoted to reduce hooking mortality, but Schill and Scarpella, (97)

review of many studies indicated that barbless hooks did not reduce hooking

mortality for fly-or lure caught trout. They also concluded there was no

biological reason for imposing hook restrictions on fly or lure anglers.

First, with hooking mortality percentages near zero for fly or lure caught fish how

much improvement in hooking mortality percentages could be expected to occur

by any changes to the type of terminal tackle used in a reach that requires the use

of artificial lures or flies? Changing regulations from those that allow the use of

bait to the Gear Restricted variety is the only proven method to reduce hooking

mortality.

Secondly, most fly anglers today voluntarily use barbless hooks to facilitate

releasing fish.  Requiring the use of barbless hooks in fly fishing only reaches will

not be a significant imposition on anyone.  We believe that the use of single hooks

and barbless hooks on artificials only reaches merits some further study and is

a good issue for discussion for the CWRSC.

In conclusion, after reviewing Schill and Scarpella and other studies, Robert

Arlinghaus in his 2007 publication stated; ”nonetheless, the majority of the data

available support the notion that the use of barbless hooks is beneficial for

discards and can only benefit fish.  Sub-lethal injuries physiological disturbances

(due to longer handling times) are more extensive with barbed hooks (Cooke et al

2001) and for those reasons barbless hooks can be an effective conservation and

management tool”.  With this in mind the primary reason to use barbless hooks is

to minimize damage to fish that are released, often many times during their

lifetime.  It is our position that this restriction should be considered for all

artificials or flies only regulation reaches that experience heavy fishing pressure.

Gear Restricted Regulations

page 23

lines 1024-33:

The Draft Document states; Gear-Restricted (especially flies-only ) regulations on

these high-quality reaches are among the most contentious of Michigan’s trout

stream regulations for two primary reasons.  First, field studies in Michigan have

not clearly demonstrated that these regulations produce the desired biological

effects, namely increased trout recruitment and catch (via reduced hooking

mortality) and increased density of sub-legal sized trout (Shetter and Alexander

1962; Latta, 1973).  We have two comments on this paragraph.

First, a significant increase in fish populations due to reduced hooking mortality

is not likely in streams that have been overwhelmingly utilized by fly anglers who

have voluntarily released fish for many years.  This is one of the concerns that

we as anglers have had with requirements of FO 213.  Secondly, as demonstrated

above, with significant changes to angler behavior, how it is possible to believe

we can rely on studies that are  55 and 44 years old respectively to provide an

accurate biological assessment of these fisheries.  The authors state that it is

difficult to demonstrate that Gear Restricted regulations have produced their

desired effect.   If this is true it must also be true that it will be difficult to show

that these regulations are not providing their desired results.  On line 632 of the

original draft of this document it is stated that “gear restricted streams currently

attract tremendous fishing pressure to the point that anglers are voicing concerns”.

With this in mind, there must be something drawing these crowds of anglers to

these special places again and again.  It is curious that this statement disappeared

from the current draft of the plan.  We will have to guess that it did not fit well

into the image of gear restricted reaches that the authors are trying to portray.

page 23

lines 1034-36: The reference to a study by Poppoff and Neuman was added to

the second draft.  This information is not incorporated in the regulation suite that

was approved for 2011.  It also was not discussed with the regulation committee

at that time.  This may be a good subject for the CWRSC to discuss but it only

adds to confusion here.  This statement should be clarified or removed from the

document.

page 23

lines 1037-53: In summarizing his 1973 study on flies-only regulations in

Michigan and Wisconsin, Latta notes, “the most obvious change with imposition

flies-only regulation, was a dramatic decrease in fishing pressure.  It appears that

at the present time the flies-only regulation is operating in a sociological manner

to create a limited entry fishery”.  It appears that Latta had not observed the recent

“tremendous fishing pressure” that the author observed in the above paragraph.

(and removed the reference from this draft) As far as a limited entry fishery it

should be noted that both The International Federation of Fly Fishers and Trout

Unlimited and their affiliate chapters provide fly fishing instruction, often at no

charge, to anyone who wants to learn the sport.  This training also provides

outreach to women and youth who might be uncomfortable in traditional settings.

The world has changed dramatically since 1973 and the world of fly fishing is no

exception.   Observations around the country are contrary to those found in

Latta, including the statement from the previous draft of this document referenced

above.  Michigan has conducted no research to this matter, but it is common

knowledge that the flies-only reaches of the AuSable, Manistee, and Pere-

Marquette rivers are among the very highest fished in the state, and are vital to the

economic support of the surrounding communities.   Any reference to the Latta

study should be removed from the document unless peer reviewed current studies

are produced to corroborate his claims.

On page 23, line 1043: the authors list the percentage of anglers that fish with

particular methods as determined in the 2015 Inland Trout Angler Survey.  Fly-

Fishing accounted for 48% of the respondents.  Still, the next sentence utilizes

data from a study by Knoche that posed hypothetical fishing situations to

determine angler preferences.  The authors correctly quote Mr. Knoche in stating

that according to his hypothetical survey questions the average angler is

substantially and negatively impacted by restrictive regulations.  The authors

neglect to report Mr. Knoche’s final statement in this section that says that from

an equity standpoint we should be looking at creating more fly fishing or even

no-kill regulation reaches.  According to Knoche 22.5% of inland trout anglers

favor fly angling regulations, and at this time .6% of our trout fishing waters have

fly-fishing regulations.  If Mr. Knoche’s advice and the conclusions from Dr.

Zorn’s Michigan 2015 Inland Trout Survey are to be followed, fisheries managers

should be searching at ways to increase Gear Restricted regulation usage not scale

it back.

There are large sections of the plan for which we have not provided specific comments. The majority of these sections we support and approve of the way they are addressed in the plan.  Others sections we do not have the expertise to adequately comment in such a short timeframe.  Our current comments on this draft plan are limited to items we feel need to be corrected or eliminated from the plan.  Previous correspondence has assured us that there will be ample time to provide additional comments to the authors before the plan is finalized.

We are confident that the current Draft Plan can be further modified to better serve all stakeholders. This version of the Draft Plan is definitely a step in the right direction.   We would like to thank everyone involved in this project for their efforts to revise the previous version of the Draft Plan.  We look forward to working together to produce a final version of the Inland Trout Management Plan that reflects our constituents views.

Thank You

Terry Lyons,

Anglers of The AuSable

Habitat Committee Chair, and CWRSC representative