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| TROUT PLAN RESPONSE March 12, 2004 John MacMillan, Biologist Inland Fisheries Division Nova Scotia Department of Fisheries and Aquaculture Box 700, Pictou, NS, BOK 1H0 Dear John: Thank you for submitting Inland Fisheries' draft trout management plan to Trout Nova Scotia directors for consideration. Attached is our critique of the draft plan. Upon review, the directors concluded that while the draft provides a good historical and scientific summary of trout within the province, it lacks the most important part-clearly defined goals, objectives, strategies and measurable outcomes. These paramount aspects must be included within the plan and we expect that you will include them in your next draft. Without them, the document will not be a trout plan. We feel the most important goal of the plan should be to ensure a healthy and vibrant wild trout population through the protection and enhancement of existing and future wild trout stocks. To achieve this fundamental goal, it is imperative that the first steps be to develop strategies that identify and protect all "Type A" trout waters. Included as Appendix A is a sample action plan which includes clearly defined goals, objectives, strategies and measurable outcomes based on the first steps of identifying and protecting all "Type A" trout waters. You may wish to consider a similar template when revising the current draft. In addition, we have provided summarized responses from those who have had an opportunity to review the draft; these are divided into general, specific, and scientific/technical comments. Once you have had an opportunity to review our submission, we would like to arrange a face-to-face meeting with you in April to discuss revisions and next steps. To set up a meeting please contact me by phone at 823-1839 or via e-mail at asimages@ns.sympatico.ca. Your initial draft is a good first step; however, much more is required if we are to produce a plan which will truly protect the future of wild trout in this province. I look forward to your response. Sincerely, James Steeves, President, Trout Nova Scotia 1.0 GENERAL COMMENTS · Inland Fisheries has made a good effort to summarize what is known about the trout fishery in the province (identified the problems, trends, management techniques, issues, species, management structure, public interface etc.). This is a good first step and needs to be included in any final plan. However, the more challenging parts are insufficiently represented. Specifically, there needs to be a section which clearly identifies the goals and objectives of Inland Fisheries and a second section expanding on the first which lays out a year by year management implementation strategy for the next five years. This latter section is represented in the draft plan, but has little structure or content and is incomplete. · I feel the Department is relying too heavily on direction from the public to determine what the priorities are for each RFAC Zone. My concern is that management by the public with the goal of "let's please everyone," is too much of what currently exists. I think department biologists need to have more of a role in identifying what's best for the fish in the future, not just collecting data on where we are now. Most of the issues identified in the management section were brought forward through the RFAC process in the last 12 months. · As a management tool this document will not provide an adequate framework to accomplish the work necessary over the next five to ten years to protect, conserve and improve the brook trout fishery in Nova Scotia. It does not attempt to address the issues directly and provide imaginative and creative solutions to obvious problems. · If the provincial and federal governments will not provide increased financial support for the trout fishery in Nova Scotia, we must take this opportunity to set up a management plan that recognizes the limitations to funding, staffing etc., and develop creative initiatives to accomplish the work through non-government agencies and volunteers working in cooperation with the department. In turn, the department must be prepared to work with the resource users to build this framework and to support, in defined and measurable ways, the community of resource users. Any strategic plan should consist of the following parts: · Goals: statements of desired results in general terms, to be achieved by an organization over a period of time. The primary purpose of goal setting is to pull change in the direction you have chosen-one that fits your expertise and overall plan. · Measures: describe in specific terms how one would express progress towards achieving the goal. How will we know when we've got them? · Standards: quantitative statements of the level of performance or quality that is desired in the future. Ultimately, what would be a satisfactory and challenging level for these results in terms of our measures? · Strategies: major elements of plan to achieve standard. What new ideas do we have about the ways in which we might achieve these standards and resolve critical issues? · Objectives: statement of specific results to be achieved in measurable terms, over a specified time. Objectives must be achievable, time referenced and measurable. A review of the Inland Fisheries Trout Plan indicates that it is neither strategic nor operational. The draft plan could be described as a background document from which a plan may be generated. With the exception of some objectives (not actually objectives but high level goals) there is a fundamental lack of "planning" in the document. To make the draft document useful requires that a planning process be incorporated that includes goals, measures, standards, strategies and objectives. · Any Trout Management Plan should be a guiding, operating document with a defined period of time (say three to five years) with periodic review and adjustment. It should clearly include: - A mission or purpose - Measurable objectives (easily defined and prioritized) - A time frame to reach those objectives - A detailed plan of how the objectives will be met (action plans) and - Defined responsibilities The current draft Nova Scotia Trout Management does not adequately address these areas. 2.0 SPECIFIC COMMENTS Policies and Objectives · The mission statement should be reviewed and refined. It is the guiding principle for the rest of the plan. · The remainder of this section suggests how the department will meet the objectives. As is evident throughout the document, the suggested objectives and action plans are not well defined and are not measurable. There is a lack of responsibility and accountability and no measurable yardsticks defining success or failure. The document must clearly define objectives and provide a measurement for determining if the objectives have been met. Resource, Assessment and Enhancement · This section should be restructured as an overview of challenges with specific action plans. It should tie in directly with the mission and objectives. · The section on Competition and Illegal Introductions requires a much more aggressive approach. One issue is the financial support and encouragement of the bass fishery. Should the department continue to foster this fishery at the cost of trout, which is already under- funded? Perhaps there should be a separate bass license with the extra funds going to reclaim trout habitat. Perhaps there should be an action plan to identify and reclaim trout habitat that was lost by the introduction of bass. · On page 10 the plan suggests that management options will be successful if the resource users accept them. This sends the wrong message and lacks the definitive priority that preserving the resource takes precedent regardless of the acceptance of the users. There are times when the trout resource needs to be protected from us. The objectives must be prioritized to deal with inevitable conflicts. Certain decisions may be politically unpopular - such as introducing new rules and regulations that limit angling, types of equipment, bait and lures. For the sake of the trout it is important to adhere to these new regulations despite political pressure. · There is no mention of policy regarding aquaculture and the department's policy concerning the protection of trout in this regard. · Why is there time and money being spent on the rainbow trout fishery (other than put and take stocking) when it is a non-native, unsuccessful introduced species? Would the resources not be better spent on trout? The same is true of lake trout. · A statement of particular concern is "The goal of a regulatory change should not be to reduce access to the resource, but to increase the opportunities available, often translating into an increase in the opportunity to catch and retain larger trout." This appears be a statement to appease "Catch and Keep" trout anglers who see any attempt to better manage the resource through regulation changes as a threat to their traditional ways of thinking. While the philosophy of "Catch and Keep" has its merits in certain situations, the retention of large breeding trout is an overall threat to the resource. Funding · The funding section of the report is inadequate. It does not commit to any funding from the government. It needs to be more creative in identifying new sources of funding. For example, why couldn't 100 percent of the revenue generated by angling licenses be put back into the recreational fishery instead of the Province's general revenues? Also there are numerous grants available through various foundations, which could be accessed to conduct habitat protection and restoration work. Angler Participation/Input · To get angler buy-in, it is important to conduct a province-wide survey of trout anglers by RFAC Zone. · It is also important that the department work with conservation groups and individual anglers to conduct research aimed at protecting wild trout stocks. This will encourage angler buy-in to the trout plan. 3.0 SCIENTIFIC/TECHNICAL ISSUES TO CONSIDER Managing Wild Trout Stocks at Healthy Sustainable Levels A key objective should be to manage all wild trout stocks at a healthy sustainable level-this means to maximize numbers whenever possible which buffers bad year classes. Maximizing the adult trout population maintains genetic diversity, maximizes recruitment and produces a quality recreational fishery (i.e. trophy fish, high CPUE). To accomplish this requires restricted harvests and the management of habitat and water quality. Angler harvest (exploitation) is probably the most critical component in the decline of fish stocks with habitat loss being a close second. To reduce harvest will require regulations to accomplish stated goals. The reason reduction limits often do not work is due to increased angling effort. For example, if the limit on brook trout is five but the average angler keeps two this is no different if the limit is reduced to one but pressure doubles. In the end the harvest will be the same. Alternatives to Creel Limits Minimal size regulations are based on the maximum size of the oldest maturing member of a population. This allows all members of the population to spawn at least once (maximizing genetic diversity). Harvest therefore would be limited to a few older fish (i.e. one fish limit over 40 cm). Slot sizes are a poor alternative in many cases because it selects for a component of the gene pool and often does not work due to too much harvest below the slot. Unfortunately "band aid" solutions are often used as tools to manage the resource. One of the worst is supplementary stocking on top of wild self-sustaining stocks. This creates "Out Breeding Depression" or the introduction of less fit stock to the environment. If you manage habitat and harvest you should never need stocking. The only place for stocking is lakes and streams where there is no chance of developing self-sustaining populations. Importance of Collecting Baseline Data Whenever new regulations are established or habitat work undertaken, it is imperative that baseline data is collected. This enables you to determine where the problems exist and allows you to evaluate the new regulations or determine if the habitat improvements achieved their objectives. This is referred to as "Adaptive Management or Experimental Management." Let's take for example a four-year population study conducted on a resident brook trout population. The data collected indicates that the adult population is small and recruitment of juveniles minimal. The maturity schedule of the adults indicates that all are mature at 40 cm. A regulation is put in place that allows one brook trout to be harvested over 40 cm. Five years later the study is repeated and recruitment has doubled and the adult stock shows several year classes represented and numbers have increased. By doing this process we learn from our successes and failures. Specialized Regulations With respect to specialized regulations, make sure they are "enforceable" (get input from your Conservation Officers). Special classification for rivers and streams should be well thought out, based on good science that achieves the proposed objectives. Regulations to consider include: catch and release only, minimal size, no organic bait, fly fishing only, etc. Keep in mind that if harvest is restricted, the quality of the fishery may dramatically improve (i.e. trophy fish and high daily catches). Importance of Angler Involvement Regulations that greatly reduce harvest are often difficult to sell to all stakeholders. This is why follow up studies are critical. One way to overcome the problem with stakeholders is to involve them in partnerships. If you involve anglers in study design, data collection and management strategies, they are much more willing to accept the final management plan. APPENDIX A SAMPLE ACTION PLAN Below is a sample action plan template that could be implemented on a province-wide by RFAC Zone. It defines clear goals, objectives, strategies and outcomes. This is the most important aspect of any trout plan. We feel the most important goal of the plan should be to ensure a healthy and vibrant wild trout population through the protection and enhancement of existing and future wild trout stocks. To achieve this fundamental goal, it is imperative that the first steps be to develop strategies that identify and protect all "Type A" trout waters. This strategy is outline below. Recreational Fishing Area 1 (Cape Breton) Mission Statement To protect, conserve and enhance the quality and diversity of the trout fishery resources throughout Nova Scotia. Program Goal: Ensure a healthy and vibrant wild trout population. Objective 1: Identify all "Type A" trout waters, including tributaries, that represent irreplaceable and high value wild trout habitat. Strategies: Work with representatives from various conservation organizations and other levels of government to identify all "Type A" trout waters. Outcome: 100 percent of all "Type A" trout waters identified over the next five years at 20 percent per year beginning in 2005. 2005 2006 2007 2008 2009 % Of Habitat Destruction Sources in "Type A" Waters 20% 40% 60% 80% 100% Objective 2: Identify sources of habitat destruction in all "Type A" trout waters including, but not limited to, forestry practices, agriculture practices, industrial practices, illegal dumping, land development activities, improper use of ATV's and other off-road vehicles and acid rain. Strategies: Work with representatives from various conservation organizations and other levels of government to conduct a site survey to identify sources of habitat destruction within all "Type A" trout waters. Outcome: Identify all sources of habitat destruction in all "Type A" waters over a five-year period at 20 percent per year beginning in 2005. 2005 2006 2007 2008 2009 % Of Habitat Destruction Sources in "Type A" Waters 20% 40% 60% 80% 100% Objective 3: Repair and restore sources of habitat destruction identified in all "Type A" waters. Strategies: Develop policy/legislative and regulatory frameworks that will reduce and over time eliminate human activities that negatively impact on trout habitat. Develop programs to restore damaged trout habitat. Increase provincial enforcement to monitor "Type A" waters either through the hiring of additional officers and/or increased monitoring effort on "Type A" waters. Outcome: Develop a policy framework over the next three years beginning in 2005 to prevent livestock from damaging stream banks and riparian zones. 50 percent of the sources of habitat destruction on "Type A" waters to be repaired and restored at 10 percent per year beginning in 2005. Objective 4: Create a number of Special Management Areas within the "Type A" trout waters to protect wild trout stocks and wild trout habitat using one or more of the following criteria-size limits, bag/possession limits, catch and release regulations, gear restrictions, delayed openings and sanctuary areas. Strategies: Work with representatives from various conservation organizations and other levels of government to identify particular watersheds for Special Management Area Status. Outcome: 50 percent of the "Type A" trout waters designated as Special Management Areas over the next five years beginning in 2005. |