Dear Chairman Biebel,
I am writing on behalf of the Vermont chapter of Native Fish Coalition to provide comments about simplifying Vermont’s fishing regulations and protecting wild native brook trout.
Native Fish Coalition is a nonpartisan, grassroots, 501(c)(3) nonprofit organization dedicated to the conservation, preservation, and restoration of wild native fish. Founded in 2017, NFC has chapters in Alabama, Connecticut, Maine, Massachusetts, New Hampshire, Pennsylvania, and Vermont. Wild native brook trout are a focal species for Vermont NFC.
Vermont’s wild native brook trout are under stress from climate change and other factors. Streams and ponds that once held wild native brook trout are bereft of such. Other waters have been compromised by invasive species including baitfish, nonnative trout, and warm water gamefish. Additionally, fisheries biologists have noted shifts in land use, where riparian buffers are being removed to improve the landowner’s view of a stream, removing critically important tree canopy. In short, habitat trends are challenging from the viewpoint of cold water fishery management. These and other trends suggest conservation of the fish themselves is a prudent course when considering this proposed rule.
Concerning the rule proposal: NFC’s comments focus on an important feature of the rule change – reducing the daily limit on brook trout in rivers and streams. We generally support the proposal to lower the daily limit on brook trout in rivers and streams, though the coalition raises two concerns.
First, NFC believes that a daily brook trout limit of six fish, consistent with the current six-fish limit for nonnative brown and rainbow trout, would be prudent. This has been VT NFC’s consistent position over time; it supports conservation, is simple for anglers to understand, easily enforced, and easy to implement. And it comports with the department’s goal of rule simplification.
Compared with other states, Vermont’s current limit of 12 brook trout a day in rivers and streams is more than double that of the 15 of 22 states in the brook trout native range, and twice that of three others. The two highest states – Georgia and Massachusetts – have an eight fish limit, which is still 33% lower than Vermont. A better look at how Vermont compares to other states may be seen at www.nativefishcoalition.org/campaigns/2020/11/21/vermont-going-from-twelve-fish-to-eight-is-not-enough.
In late 2020, the Fish and Wildlife Department held “listening sessions” and collected public input. Twenty-six comments addressed the harvest limit. Twenty-two supported reduced harvest, most of those recommending limiting harvest to six trout, not eight as is now being proposed.
Note that the department’s proposal of eight fish a day for rivers and streams would still leave Vermont tied for the highest in the native range of brook trout.
NFC would also like to see the department begin discussions with stakeholders to produce a long-range plan specifically for Vermont’s wild native brook trout. Such a plan would include policies for preserving or restoring habitat for Vermont’s official Cold Water fish, brook trout, as well as other protective measures. Local conditions may warrant site-specific regulations in support of long-term conservation goals set forth in a plan, as district fishery biologists are well positioned to fine tune regulations for waters they know best via habitat assessment and frequent sampling of fish populations. VT NFC believes that a carefully formulated wild native brook trout plan would help optimize populations, protect habitat, and improve angler experience.
Thank you for the opportunity to comment.
Sincerely,
Chris Owen
Vermont State Chair, Native Fish Coalition