The Anglers of the Au Sable’s comments to the Fisheries Division of the Michigan Department of Natural Resources, 2nd Draft of the Management Plan for Inland Trout in Michigan.

April 14, 2017




Thank you for the opportunity to comment on the 2nd 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,


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



issue 13


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



Goal 2,


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


Goal 3,


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,


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

Issue 2,


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,


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,


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


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



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


Anglers of the Au Sable 30th Anniversary Banquet

April 29, 2017, 4:30 – 10 pm (Dinner at 6 pm)

Otsego Club, Gaylord, MI

If you’re going to have a banquet on the Opening Day of Trout Season, it better be good. The Anglers of the Au Sable’s banquet

only happens every five years. Live and silent auctions, raffles, camaraderie, and a cause. This isn’t just for looks, this is to raise

money to protect the river from a discharge permit for a fish farm. Fly fishers know how important this fight is, which is why the

donations have been pouring in from guides, fly shops, sales representatives, and even the companies themselves. We’ve hardly

had to ask to receive what we think is a still accumulating line-up of goods and services.


• Guide trips from noted Michigan guides including Eric Grajewski, Jeff Hubbard, Jon

Ray, Kevin Feenstra and many others…

• Rare and collectible fly rods from Bob Summers, Sweetgrass Fly Rods, and Keystone

Rod Company…

• Top end items from Sage, R.L. Winston, Simms, Bauer, Hatch and many others…

• Collectibles from Tom Morgan, Dennis Potter, Ogden Pleissner, Kent Lund and more…

• Excursions to Brookhaven Pond, a two-day midnight mousin’ adventure, a cast-andblast


• Original signed copies of Seasons on the Au Sable, by Rusty Gates…

• And a whole bunch more…

Tickets are $100/person. Tables are $1000. Tickets include choice of five entrees and two bar tickets.

To secure your tickets, CLICK HERE TO PURCHASE TICKETS ONLINE or contact Josh Greenberg: or 989-348-8462. This event

will sell out so please don’t delay.

Please note: We are holding a block of rooms at the OCR Blue Spruce Lodge for April 29th with departure

the 30th. Cutoff date for these rooms is March 15, 2017. Individual rooms @ $99 plus tax can be

reserved by calling the resort’s main reservation line 989-732-5181.


Congressman Dan Kildee: Protecting Michigan Rivers

U.S. Rep. Dale Kildee, D-Flint, announced introduction of legislation intended to prevent development of for-profit fish farms in the Great Lakes and connecting rivers. It may not be in time to help with our fight against the fish factory the state is allowing to pollute the Au Sable, but it’s a good step to prevent further pollution by fish farms in critical waters. Anglers President Tom Baird endorsed the effort on our behalf.



Breaking news on Fish Farm:

Anglers of the Au Sable plans to challenge a recommendation by a state administrative law judge issued Feb. 1 requiring some alterations to a Department of Environmental Quality permit issued to a fish farm in Grayling, but still allowing pollution of the Au Sable River.

“While the judge did call for additional monitoring of the river, and he mandated some minor improvements at the Grayling Fish Hatchery, his ruling still allows fish feces, excess food and escaped farm trout to continue polluting this pristine cold water resource,” said Tom Baird, president of Anglers of the Au Sable, an organization formed to protect the river. “The fish farm will still use the river as its sewer, and that should be unacceptable to all who use and live on this outstanding waterway. We will ask DEQ Director Heidi Grether to reject this permit completely and restore common sense to this situation.”

Read the entire AotA press release HERE.

Senate Bills 39 and 40

Have you seen these bills? A little scary? We think so to.

Michigan Public Land Management At Risk – Calls and Letters Are Needed NOW! Stop Michigan Senate bills 39 & 40

These bills represent the most significant legislative intervention in public land management in the State’s history. These provisions include:

  • The potential forced opening of our few remaining special management areas to motorized vehicles
  • Increased timber harvest to levels which may be in conflict with publicly-adopted sustainable forest management plans
  • Calls for the elimination of some habitat management activities which benefit both game and non-game wildlife species
  • Transfers authority for strategic public land decisions in most areas of northern Michigan to a small number of local officials
  • Requires accelerated and preferential sales of public land to adjacent private landowners, including lands which are NOT designated as surplus
  • Reduced application fees for the private acquisition of public land or easements to levels which are well below the DNR’s cost of application review and administration
  • Prohibits the DNR from rejecting even flawed real estate appraisals involving the State sale of public lands
  • Prohibits public land management activities which are intended to preserve biological diversity
  • Requires the development of new strategic land plans to facilitate these policies in spite of the fact that the DNR’s 2013 plan has never been legislatively approved or even formally considered

These proposed requirements collectively represent a significant diversion of DNR field staff time and resources away from the management of our forests, fisheries and wildlife. Don’t take our word for these provisions, here’s the bill analysis from the Senate Fiscal agency.

Please call or write Governor Rick Snyder (517-373-3400), State House Natural Resource Committee members and your District House Representative and voice your opposition to Senate Bills 39 & 40. (see links below); also, please call the DNR Administrative offices (517-284-6367) and ask them to oppose SB-39 & 40.

Gov. Snyder Contact link:,4668,7-277-57827-267869–,00.html

House Rep. Contact Link:

Coalition to Stop MI Senate Bills 39 & 40


DNR response to your emails

Thank you to all that wrote to the MDNR regarding the New Zealand Mudsnail issue. If you did you likely received the following email from them in response. 

If you have already read Mr. Dexter’s email and would like to see Pres. Baird’s response please scroll down.

Thank you for your recent emails of concern regarding New Zealand mudsnails (NZMS) in the Au Sable River in relation to the Grayling Fish Hatchery.  I have been asked to respond to your concerns on behalf of Director Creagh.
You are concerned that the Department of Natural Resources’ (DNR) response to the positive finding  of NZMS in the Au Sable River has been inadequate.  I want to address these concerns and assure you that everyone at the DNR recognizes the fact that the Au Sable River is a natural resources jewel.  Our goal is to keep it as such.
There is misinformation circulating about this subject within your social network.  The facility in question is the Grayling Fish Hatchery.  The Harrietta Hills Fish Hatchery is situated on Slagle Creek which is located in Wexford County and is not even part of the Au Sable River watershed.  In fact, Slagle Creek was surveyed by the Department of Environmental Quality for the presence of NZMS and none were found.  While we work closely with our sister agencies in the Quality of Life (QOL) group, the DNR does not regulate agricultural activities.  Statute defines commercial aquaculture as an agricultural pursuit which puts it under the regulatory authority of the Department of Agriculture and Rural Development.  I do not point this out to deflect or divert criticism, but rather to point out that legal authority for the DNR to simply shut down the Grayling Hatchery does not exist nor does it exist for any private aquaculture facility regulated under the commercial aquaculture statute.  Regardless of your thoughts about commercial aquaculture, I think everyone will agree that no one’s rights should be trampled as the DNR does the important work of managing our state’s natural resources.
As Fisheries Chief, I firmly stand by the assertion that, where NZMS are concerned, the stocking requirements imposed on the Grayling Hatchery are indeed appropriate and protective of the state’s resources.  There are two primary means by which the stocking of hatchery reared fish can serve as a vector for moving NZMS to new areas.  The first is that fish can ingest them and subsequently pass through the digestive system and eventually be released into a new environment.  While it is true that ingested NZMS can pass through a trout’s digestive system alive, research and experience in western states’ fish hatcheries has shown that fish held off of feed for four days or more are much more likely to have eaten NZMS while foraging for food.  The DNR has gone one step further and conservatively set the maximum purge (no-feed) period prior to loading fish for transport at only 36 hours.  This is being done to ensure that there is low likelihood that trout will forage prior to being removed from the facility.  The QOL agency staffs inspection of digestive tracts dissected from fish at the Grayling Hatchery indicates that there was no foraging activity going on with fish that had been off feed for nearly 24 hours.  In fact, these fish still had stomachs that were very full of food pellets.  No NZMS were found in any digestive tracts.  This sampling event even sampled fish that had been off of feed for several days and these fish had obviously been foraging.
The second way that stocking can serve as a vector for NZMS is by using hauling water that is pumped without filtering from an infected water source.  At first, stocking requirements imposed on the Grayling Hatchery required microfiltration of water from the Au Sable River.  However, the operator of the Grayling Hatchery voluntarily took it a step further and is now using only well water for hauling fish, whether for stocking purposes or for market.  The use of well water for hauling fish and limiting the no-feed period to no more than 36 hours reduce the likelihood of fish hauling as a vector to the minimum level possible.
Some have suggested that the DNR take actions that reduce the risk of NZMS in the Au Sable being moved to other waters to zero and that doing anything less is unacceptable.  While there is no question that aquaculture can be a vector, the literature consistently lists anglers and other recreational activities as high risk vectors for NZMS.  Any call for reducing the risk of spreading NZMS to zero would have to include limiting or even eliminating angling activity in positive waters.  Please understand that DNR has no intention of taking this step.  However, any call for drastic measures that does not acknowledge the role that anglers and other recreationalists can play in hastening the spread of NZMS rings hollow and disingenuous.  It is the desire of all of the QOL agencies to continue to work with the commercial aquaculture industry and the recreational users of our world class waterways to do all we can to prevent the further spread of this and all aquatic invasive species.
To summarize, the state has taken strong steps to prevent the movement of NZMS from the Grayling Fish Hatchery.  Anglers also need to take important precautionary steps to further prevent the spread of NZMS and other invasive species every time they enter or leave fishing waters.  NZMS will remain a high priority for the QOL agencies and we will continue to address all potential threats.
Thank you for your concern for the Au Sable River and the fish community that reside therein.  The DNR looks forward to working together with the angling community to get the word out that all of us need to take steps to protect the waters we so deeply value.
Jim Dexter
Fisheries Chief
Constitution Hall
525 West Allegan
Lansing, MI  48933
AotA would like to clarify that we did not lead anyone astray via social media as the Director stated in his reply. We reported the truth as always. You responded. As always. And we thank you for that! We can’t get any of this done without your support. Please see below for our response to that letter.

November 14, 2016

James Dexter, Fisheries Chief

Michigan Department of Natural Resources

Constitution Hall

525 West Allegan

Lansing, MI   48933

Re: New Zealand Mudsnail Response – Au Sable River

Dear Chief Dexter:

I am writing in response to your recent email communication regarding New Zealand mudsnails in the Au Sable River. I write to offer several clarifications to the DNR and the other quality of life agencies. The Anglers of the Au Sable will go the extra mile to educate anglers and others about invasive species, wader washing and the importance of other measures. But in this case, we believe that the QOL group’s handling if the Grayling fish farm, especially the snail issue, has been woefully inadequate.

You used the term “hollow and disingenuous” to describe our expressions of concern and our calls for a strong and speedy response to the discovery of NZMS just downstream from the fish farm. Respectfully, we submit that the most hollow and disingenuous statement in this entire affair is to continue to claim that the state is vigorously protecting the Au Sable River. To review: 1) the DNR made this entire project possible when it illegally waived its right to enforce statutory use restrictions on the hatchery and allowed an industrial fish farm, 2) the DEQ issued a pollution discharge permit allowing the river to be used as the farm’s private sewer, 3) the DNR has openly acknowledged that low-tech aquaculture facilities like the Grayling fish farm are a prime threat for the spread of NZMS, but 4) when notified of discovery of the NZMS in the river, refused to inspect the fish farm and instead blamed anglers as the probable cause of the infestation.

In early June, a scientist we retain discovered NZMS in the East Branch of the Au Sable. He determined that the snails were directly below the fish farm – and only below the fish farm – not upstream, and not further downstream. Anyone can see that a possible source of the infestation was the fish farm. This was reported to DNR and DEQ immediately.

Standard operating procedure in such cases is to do an immediate survey to assess the source and extent of the infestation, and to determine if emergency measures can be deployed. We asked that you inspect the fish farm. You said the owner wouldn’t let you! We asked that you have the Attorney General obtain a warrant. To our dismay, you refused to do so, saying you wanted to “work with” the owner to find a “mutually agreeable third party” to survey the fish farm. In the end, that never happened, either. Months went by. The snails spread upstream and further downstream from the fish farm. It is now probably impossible to determine if the fish farm was the source of the snails, and it is impossible to treat the river to eradicate them. Four months later there was an inspection and, no surprise, NZMS were found in the facility.

Regarding your eagerness to blame wading anglers for the snails, we note the snails were only found directly below the fish farm. There is very little public access there. Very few, if any, anglers fish there. Have you considered how infinitesimally small the probability is that any angler 1) came to the Au Sable from another watershed, 2) which was already infested with NZMS, 3) which were on the angler’s waders, and 4) chose this inaccessible and deserted stretch of the East Branch as their best fishing location?

Worst, after all your protestations of concern for the waters of our state, you have concocted a scheme where the fish farm will be allowed to transport potentially infected fish for stocking in other waters The NZMS is asexual. It only takes one snail, in one fish, to start a new population. You say this protocol creates a “low likelihood” that the farm trout will forage on snails before shipment. We have been made aware of studies that show even recently fed fish may forage and ingest snails, and that using fresh water for transport might not work. Thus, there is a “definite likelihood” that fish will be shipped after ingesting snails.

Anglers of the Au Sable has built wader wash stations and distributed them to local shops.  We have sent educational material to our members and posted it on the Internet. In cooperation with MGFCTU, we worked with our communications firm and biologists to draft, print and post signs warning of the dangers. Similar handouts were placed in local stores, too. This was all done in less than a week. In the meantime, has the DNR contacted local businesses, organizations and governmental agencies to warn of the problem and enlist their participation in educating the public?

We will always vigilantly protect the Au Sable River system. That is the reason we exist. We prefer, as always, to do so in full partnership with the DNR and other state agencies. We will also call it like we see it, back up our conclusions with science, and unfortunately and too often, fight tooth and nail against state agency decisions and actions which put the river at risk. This is one of those times. The DNR and other state agencies simply didn’t do the job on this one. You permitted an ill-conceived project in the finest trout stream east of the Mississippi, and then you dawdled in the face of a real threat. You only entered the fish farm when the owner “invited” you to do so. What kind of vigilance is that? The state can claim that it will “do all it can” to preserve the Au Sable as a “natural resources jewel,” but its actions in this instance are to the contrary.

Sincerely yours,

Thomas A Baird, President

Anglers of the Au Sable

The Mud Snail, the State of Michigan, and the Au Sable Fish Farm…a timeline.

The Mud Snail, the State of Michigan, and the Au Sable Fish Farm…a timeline. 


June 6, 2016. Dr. Mark Luttenton discovered mud snails directly below (and at that time ONLY directly below) the hatchery during a routine water quality inspection. AotA notifies DNR and DEQ immediately. AotA and TU groups post NZMS info signs at access points to educate anglers and boaters on how not to spread the snails.


DNR releases State of Michigan’s Status and Strategy for New Zealand Mudsnail Management WHICH STATES: “Managing potential pathways of introduction for the New Zealand mudsnail is essential in preventing dispersal into new waterways. Pathway specific management plans include close visual inspection and the treatment of fish hatcheries and aquaculture operations.” They did not inspect the hatchery.

July 29, 2016. Nearly two months later the DNR sent Anglers their first response essentially blaming anglers for the spread of the mud snails. Also noted in this response is the hatchery operator’s refusal of admittance to state agencies to do testing of the facility for NZMS.


In late August, DNR fisheries biologists write in a draft trout management plan: “Improperly operated fish hatcheries have the potential to harm coldwater streams and their aquatic communities in a number of ways….Stocking of hatchery fish can serve as a vector for aquatic invasive species such as the New Zealand mud snail, unless appropriate measures are taken to prevent their spread… Many of the hatchery threats identified above are exacerbated in poorly designed flow-through systems” (like the Grayling hatchery). Still no inspection. The plan in place to prevent spread to other waterways in the state via stocking is questionable and likely to fail according to experts.


Sept 6, 2016. AotA sends letter to Governor Snyder asking for Snyder to order state agencies to do the required testing at the hatchery.


Sept 14, 2016. Gongwer publishes article with this opening paragraph: “The Department of Natural Resources agrees that the Grayling Fish Hatchery could be a source of invasive snails and has been working with the owners to prevent further transport, officials said late Tuesday.”


Sept 28, 2016. DNR director Keith Creagh sent a letter to AotA stating: “We are making arrangements to inspect the hatchery. We are planning to have representatives of all three QOL agencies onsite to verify that appropriate measures are being implemented to reduce the risk of NZMS movement and to test for the presence of snails inside the hatchery.”


Oct. 4, 2016. DNR press release stating they have inspected the hatchery. See below:




Anglers of the Au Sable asks Gov. Snyder to order inspection of hatchery that may be spreading invasive species

Tom Baird


Anglers of the Au Sable

Via email at


The Honorable Rick Snyder

Governor of the State of Michigan

P.O. Box 30013

Lansing, MI 48909


Sept. 6, 2016


Dear Gov. Snyder,

I am writing to ask that you order state agencies to immediately investigate whether the Grayling Fish Hatchery, recently licensed as a fish farm by state agencies, is responsible for the introduction of an invasive species, the New Zealand Mud Snail, into the Au Sable River system.

Anglers of the Au Sable is a conservation and sporting group focused on preserving and enhancing the Au Sable River. We have long been a guardian of the Au Sable. We take very seriously our responsibility of protecting this world-renown fishery, and have worked with – and sometimes against – state agencies over the last 30 years to ensure that it will continue to be a special place in our state for those who enjoy nature, solitude, recreation – and fishing for its wild trout.

We are now engaged in litigation over use of the Grayling Fish Hatchery as a commercial fish farm under the management of Harriett Hills-Grayling. We are contesting the permit issued by the Department of Environmental Quality to allow it to operate as a flow through facility with minimal pollution abatement as it moves from 20,000 pounds of fish production annually to a possible 300,000 pounds. That legal battle is now before an administrative law judge, and will be moving to the director of the DEQ for a final decision later this year or early in 2017.

In the meantime, we have discovered that a new invasive species has been found in the river in recent months. A well-known aquatic biologist under retainer by Anglers first found the New Zealand Mud Snail directly downriver from the hatchery in the East Branch of Au Sable. The Department of Natural Resources agrees that this fast-spreading species has now been found in other locations.

Our experts advise that the hatchery may have been the source of the invasive New Zealand Mud Snail now in the river – and may spread the snail into other waters as the hatchery operator distributes fish around the state.

We have asked officials the Department of Agriculture and Rural Development, Department of Environmental Quality and Department of Natural Resources to inspect the hatchery and its fish. To date, they have told us they have no plans to do so. We find this completely baffling, and totally irresponsible. It’s as if they don’t want to know what is going on in this hatchery.


We believe the agencies are potentially creating a scenario that may threaten more of our state’s cold water resources due to the risk of spreading disease vectors throughout the state. Fish diseases are often first discovered in fish farms suggesting they may be the entry points for many diseases.

One of our major concerns is that the New Zealand mud snail may not be the only invasive species associated with this recent discovery. Other organisms commonly associated with the New Zealand mud snail may now be in the Au Sable River system.

The Harrietta Hills-Grayling fish factory has been getting special state treatment for some time. Permission to operate the factory was granted by the DNR despite statutory and deed restrictions limiting use of the property to public recreation and museum purposes. The DEQ issued a pollution discharge permit which falls far short of protecting the river from pollution, algae growth, escapement and disease. Your own Water Strategy has noted the negative impact of flow-through hatcheries on waterways, and indicated a strong preference for recirculating water systems. And we know you have expressed strong concerns about invasive species.

We ask you to immediately order the appropriate state agencies to take action to gain entry into the fish farm, test the fish, examine the facility, and determine if it is contaminated. If so, we recommend that the fish not be transported to other locations.

Thank you for any action you can take on this important issue. We know of your commitment to the state’s natural resources, and hope you will move forward to protect the Au Sable River, one of the crown jewels of Michigan.



Tom Baird




Keith Creagh, Director, Department of Natural Resources

Jamie Clover Adams, Director, Department of Agriculture and Rural Development

Heidi Grether, Director, Department of Environmental Quality

Jim Dexter, Chief, DNR Fisheries Division

James Averill, Michigan Department of Agriculture and Rural Development State Veterinarian


P.S. We would love to get you on the river for a chance to float the river and catch one of its many trout – and then to release it back into the water for others to enjoy. We are certain that a day on this outstanding waterway will help you understand why so many of us are so committed to its protection and enhancement. Just let me know!

Brook Trout Telemetry Study

“Anglers of the Au Sable contracted GVSU to conduct this study on the Mainstream and North Branch of the Au Sable during the Summer and Fall of 2014.  17 brook trout were tracked in an effort to better understand their use of habitat in the Au Sable system and to better inform ongoing habitat improvement projects.  This study would not have been possible without the generous funding that Anglers of the Au Sable received from our partners in conservation: Mason Griffith Founders Chapter TU, Headwaters Chapter TU, Challenge Chapter TU, Michigan Fly Fishing Club, International Federation of Fly Fishers, and Patagonia Incorporated.  Thank you all so much for your support!”

Click the link below to read the full report.

Brook trout report

Mud Snail Report

Dr. Mark Luttenton of Grand Valley St. University and a team of experts did some field work recently in response to the recent mud snail discovery below the Grayling Hatchery. Please read Mark’s report below. The report was sent to Anglers President, Tom Baird among others from MITU, TU Mason Griffith chapter, MDNR, and MDEQ.

A group of 6 (Terry L, Steve S, Jim W, Austin (works with Steve), Justin (works with me), and myself) surveyed four additional locations for mud snails on Sunday, they included: Gates Lodge, Burton’s Landing, Grayling Park, and just upstream of North Down River Road.  Sites previously surveyed are: behind the hospital, the Main Branch below the East Branch confluence, the Main Branch above the East Branch confluence, between the I-75 bridge and Wilcox Bridge Rd., immediately below the hatchery, and halfway between the hospital site and the confluence with the Main Branch.
The Main Branch sample sites survey on Sunday were selected because they are popular access points for fishing and canoeing/kayaking.  We spent approximately 40 minutes at each site and sampled the majority of habitat types at each location.  This gave us approximately 240 minutes of effort at each site.  We did not find mud snails in any of our collections on Sunday.
Thus far, we have only found mud snails immediately below the hatchery, behind the hospital, and halfway between the hospital site and the confluence with the Main Branch. The highest densities appear to be associated with the sites that are farthest upstream.
I have also received a note back from Joe Holumzki at USGS in Menlo Park, CA.  Joe worked on mudsnails in NZ.  Here is his response;
“Terry Short and I looked at the snails you sent. We think they’re Potamopyrgus antipodarum, the NZ mudsnail, smooth-shelled morph. The snails you sent are nearly morphologically identical to an invasive population I’ve sampled in Pilarcito Creek on the coast here in CA.”
Please let me know if you have any questions,
Mark R. Luttenton, Ph.D.
Associate Dean of the Graduate School
Professor of Biology
Grand Valley State University
306 C DeVos Center
401 W. Fulton Street
Grand Rapids, MI 49504