Sample DEC Letter                 January 2005


This is a letter sent to the DEC regarding the latest DEC Creel Reduction Proposal. You are encouraged to write your own letter and use this one as a guideline. If you don't want to take the time or elaborate, just send a couple of lines showing your disapproval to the regulation changes. Send to address's listed on this page below.


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Mr. Doug Stang, Chief
NYS DEC Bureau of Fisheries
625 Broadway
Albany
, NY 12233

 Re: Proposed Lake Creel Reduction for Steelhead

Dear Mr. Stang:

The proposal by DEC to reduce the steelhead limit from three to one fish per person is unacceptable to the lake fishing community.

The negative impacts of imposing such a drastic regulations change would be devastating to charter operations, recreational anglers, as well as lakeshore businesses that rely heavily on sportfishing traffic to survive. Reducing the limit to one steelhead would help to paint a negative picture of the lake’s steelhead fishery and contribute to a public perception that will keep people home or force them to other angling destinations. In addition to a decrease in fishing charters, there would be less recreational traffic at a time when we’re struggling to increase angler effort on the lake. We still haven’t recovered from how the stocking cuts in the early 1990s were handled. Bear in mind that lake fishermen, especially charters, have much more invested in equipment and their corresponding costs are much higher when you’re talking economic impact.

Of course, less angler effort on the lake would translate into less fishing licenses (resident and non-resident), less money for the Conservation Fund and less Federal excise tax monies coming into the state for fisheries programs. We’re not willing to support a short term “perceived solution” in an attempt to rectify a long-term problem. Reducing the steelhead limit to one fish per person is not the answer to whatever problem exists with steelhead survival and we’re disappointed that DEC would purposely manipulate user groups against one another – taking the focus off you – and not work toward a solution.

DEC has documented that a one-steelhead limit in the lake would have made a 17 percent difference (roughly 2,000 fish) in overall numbers based on the 2004 creel census of less than 12,000 steelhead harvested. How many of those fish caught came from Canada ? We understand that the creel census shows us that many of the Western Basin steelhead caught in the lake come from our neighbors to the north. When you factor in those additional fish spread out over the south shore of the lake (after you eliminate the Canadian fish that are caught), the end result is miniscule. If the state is stocking more than 600,000 steelhead annually, keeping less than 12,000 of those fish shouldn’t be a problem.

Keeping a three fish limit, but a one steelhead limit option, is not prudent because most of the Western Basin steelhead fishing takes place in the summer months when releasing steelhead carries a high mortality rate while trolling from larger vessels. Charters recognize the fact that this fishery was built on a put-grow-take philosophy and making excuses for releasing fish that simply aren’t going to survive is a tough situation to be in.

Reducing the steelhead limit to one fish doesn’t address the real problem and we firmly believe that numerous factors come into play as to why steelhead recruitment is suffering. At the top of that list, though, is poor product being delivered by the Salmon River Fish Hatchery. That could be substantiated through the success of the pen rearing projects involving steelhead. The Oswego River project led the way to show significant survival and returns for steelhead – at a rate of six or seven to one. Some fisheries experts believe that by increasing water temperatures and improving water quality at the SRFH, a much better stocking product would be realized – increasing chances of survival against other predators like fish and birds.

A final point addressing the problems that would be created by implementing a reduced steelhead creel deals with the marketing nightmare that would result in such a move. By simply crossing the Lake Ontario boundary line between the U.S. and Canada would allow anglers to catch up to five steelhead per person. Nearby Lake Erie and tributaries can catch-and-keep three steelhead per person in New York and that lake is receiving between 2 and 3 million steelhead every year between four states. It’s tough enough to compete.

Counterproposal.  Our counterproposal to the state’s one steelhead limit change is to implement the three fish limit that is currently in place in the Niagara River for the entire lake. When fishing in Lake Ontario , anglers will be allowed to keep three fish per person – trout or salmon. This would include lake trout and Atlantic salmon. With the lake fishing community willing to give up four fish per person based on the current creel scenario for daily limits, we would also ask for the following contingencies to help improve the overall fishery in Lake Ontario :

·        Eliminate the captain/mate or guide limit for all charters on Lake Ontario . While many charter operations already self-impose this regulation, let’s make it a state law. We can also eliminate the “gifting” of all fish. Why would you kill fish if you didn’t intend to keep them?

·        DEC must identify all trout spawning streams (that have the potential for natural reproduction) along the New York shoreline of the lake and impose a closed steelhead season to protect spawning fish (similar to the Province of Ontario ).

·        Eliminate the slot limit for lake trout.

·        To address the immediate need of Lake Ontario, DEC should look at taking up to 50 percent of Lake Erie steelhead and move them to Lake Ontario to help increase overall numbers returning to the tributaries for the next two years – if additional fish cannot be reared at the hatcheries around the state.

·        We need a solution to the problem. Make changes at the Salmon River Fish Hatchery to improve the steelhead quality being produced. Push for more pen rearing projects involving steelhead and get the tributary fishing community more involved with these types of projects. If we stock 600,000 steelhead each year into the lake and we can improve survival by ten percent by holding these fish in pens, we’re talking about an additional 60,000 fish! Yet we argue about whether or not we should kill less than 2,000 fish in the lake. We should also consider pen rearing brown trout, too!

·        We must insist that the Province of Ontario back off on their creel limits and get them in line with New York for salmon and trout. Canadian angler effort seems to be increasing.

·        Conduct a more comprehensive creel census around the lake, to also include the tributaries. We need a more accurate accounting of angler effort and harvest impacts.

Reducing the steelhead creel to one fish in the lake is not the answer and no such move should be implemented until data collected supports such a drastic change. To suggest that reducing the steelhead limit is the answer to the lake’s problem is ludicrous. The lake fishing community, if anything, has enhanced the fishery through its pen projects, the purchasing of equipment for the SRFH, the construction of artificial reefs and other enhancement efforts over the years. It’s time DEC take some accountability and tell us what you think the problems really are.

Thank you for taking the time to read this counterproposal, a proposal that will be pushed through whatever channels we deem necessary – legislative, legal or otherwise – in an effort to protect our businesses, our livelihood and our recreational pastimes.

Sincerely,

Capt. Doug Stein
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Mr. Doug Stang, Chief
NYS DEC Bureau of Fisheries
625 Broadway
Albany
, NY 12233

Paul E. McKeown
Region 9 Fisheries
182 East Union St., Suite 3
Allegany, NY 14706
(716) 372-0645

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