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