ALERT!! Yellow-Legged Frog may go on ESL and Kill dredging

[mojavejoe]

YOU MUST WRITE a letter to DFG by 5PM 3-18-11
or dredging in most of California's streams and rivers will be stopped to protect this potentially listed frog.

Here is a link to the Center For Biological Diversity's Press Release putting the blame squarely on the shoulders of DFG's practices and a few other causes.
http://www.biologicaldiversity.org/news ... -2010.html

It is essential that we quickly submits comments to DFG on why putting the mountain yellow legged frog on the California Endangered Species List will not help them.
On why they are in decline, primarily due to trout planting practices, pesticides and disease (chytrid virus)

Here is a link to DFGs website on this subject:
http://cdfgnews.wordpress.com/2011/02/1 ... ged-frogs/

Be clear on this point ---- Your letter should address (not dredging issues) the primary reasons the Mountain Yellow-Legged Frogs are being killed and recommend that all those causes be addressed first. Then state that the "mountain yellow-legged frog" should not be listed.

E-mail your comments to Mitch Lockhart at MYLF@dfg.ca.gov ,or overnight it to their mailing on the webpage above.

<<<<<< Sample Draft Letters below >>>>>>>>>
(DO NOT copy these letters verbatim or they will not be counted as against this proposal)
(Paraphrase or summarize, and add something new.)


March 15, 2011
Mitch Lockhart
Dept of Fish and Game
830 S St
Sacramento,
CA 95811

Re: Proposed listing of Mountain Yellow-legged Frog as an endangered species under the California Endangered Species Act.

The species, Rana sierrae, or the Sierra mountain yellow-legged frog is already a candidate species under the U.S fish and Wildlife. They declined to list the species as endangered.
In the Sierra Nevada, mountain yellow-legged frogs have disappeared from nearly all known low elevation sites on the west slope (4500-9000feet), and are extremely rare east of the Sierra crest and are increasingly uncommon in the most remote alpine habitats along the west side of the Sierra Crest (10,000-12,000 feet). In addition, most remaining mountain yelow-legged frog populations are located in Sequoia, Kings Canyon, and Yosemite National Parks and are very rare in national forests and wilderness areas. (Vrendenberg et al 2007, and Knapp and Matthews 2000a).

"Mountain yellow-legged frogs are adapted to high elevations without aquatic predators. Widespread stocking of non -native trout in high elevation Sierra Lakes by the Dept of Fish and Game has been the Primary cause of the decline for the species." This quote is from Knapp from the Center for Biological Diversity. It places most of the blame at the feet of CA DFG. However, it also seems to lay some blame on all other predators of the frog such as otters, bears, and even German browns which eat everything. If All of these are removed, then we would seem to have a rebound of the frog but at what cost to the other species?

Other reasons for the decline of the species seem to be disease and pesticides. Why doesn't the DFG work with the National Park Service to remove the trout from the parks and get a healthy and thriving population of frogs there and then work on one lake at a time to remove the trout.

Listing the species will not help it recover and I support the no action alternative.

Sincerely,


=====================================================================================

Mitch Lockhart
Dept. of Fish and Game
830 S St
Sacramento, CA. 95811


RE: Mountain Yellow-legged Frog

March 14, 2011


These comments are in response to the proposed listing of the Mountain Yellow-legged frog as an endangered species under the California Endangered Species Act.

All of the scientific data seems to point directly to the DFG as the main culprit in the demise of this species. The DFG's continued efforts to stock fish in the habitat for the Sierra Mountian yellow-legged Frog is the primary cause of the decline of the species. Unless this practice is stopped immediately and the all of the trout are removed from the lakes, streams and waterways that the frog inhabits, then the species will continue to decline. Listing the species as endangered will do no good.

Pesticides also contribute to the decline of the species by killing them outright or weakening them so they are susceptible to diseases, including a chytrid fungus that recently ravaged many yellow-legged frog populations.

The U.S Fish and Wildlife declined to list the Rana Sierrae as an endangered species, but placed the population on the candidate list. This should be sufficient until the DFG takes the actions necessary to protect the species such as stopping trout stocking, pesticide release, and fisherman from tromping through the shallow waters that the frog lay their eggs in.

I favor the No-Action Alternative in this matter.
======================================================================================================

[CalGoldDredger]

My question is if the ones trying to save this frog are going to hold a Frog Aid festival and serve up some plates of frog legs just like the indians did with their Salmon Aid, serving up the very thing they are trying save.
Who was really benefiting from that salmon aid deal, it wasn't the salmon as there were eaten.

[russau]

i like frog leggs with butter and garlic on them!

[mojavejoe]

Hey guys,

Have you written a letter that covers “why” the CA ESL listing of the MYLF is unwarranted? Or have you written a letter about why it’s endangered? You may want to write another letter focusing specifically on "why" it should not be listed, which is the major point of this DFG proposal. Maybe a letter on “Why the MYLF has not been proven to be endangered” or “What are the current results of DFGs limited trout stocking in the MYLF’s major habitats? If no one knows, then how do they know the MYLF is endangered right now?” Just a couple ideas to help prove our point that the MYLF should not be listed in the CA ESL.

This a copy of my Comments as submitted to DFG today. You may use any of the ideas or quotations cited, but do not copy verbatim the entire letter. It may not count as Opposed to the ESL listing unless you make it look like your own letter. This is my long version of the arguments, but after you read it you should be able to reduce the ideas to 2 or 3 simplified paragraphs restating the general principles (even just one) in your own words, and send it off.

FYI:
===================================================

Subject: Should the Mountain Yellow-Legged Frog be put on the California Endangered Species List?


I do not believe the Mountain Yellow-Legged Frog requires CA ESL listing at this time for the following reasons:

In January 2010 the Center For Biological Diversity’s Press Release stated in part the following:
http://www.biologicaldiversity.org/news ... -2010.html

“In 2006 the Center for Biological Diversity filed suit against Fish and Game for failing to complete an environmental review of the impacts of fish stocking on sensitive aquatic species.”

“In 2007 a court ordered the state agency to conduct a public review of the stocking program’s impacts.”

“In 2008 Fish and Game agreed to interim restrictions prohibiting stocking trout in water bodies with species sensitive to nonnative fish. Although the state has taken steps to reduce trout stocking in areas with yellow-legged frogs, stocked trout continue to harm frog populations and limit recovery.”

“Permanent protection and management decisions to stop stocking and remove trout in key frog habitats are necessary to reduce trout predation of mountain yellow-legged frogs.”

To further quote the CDB article:

“Surveys since 1995 at 225 historic frog localities show extinction of 93 percent of the northern and central Sierra populations and 95 percent of southern populations.”

“This month ( Jan 2010, added) the California Department of Fish and Game released a final environmental impact report on the impacts of stocking of hatchery fish on mountain yellow-legged frogs and other imperiled species, which unfortunately failed to adopt sufficient mitigation to protect the species from the impacts of past and ongoing fish stocking.”

So....the DFGs EIR on Trout Stocking was finalized in Jan 2010 but they failed to propose enough mitigation measures for decreasing the stocked trout threat, to satisfy the CDB.

If the EIR was done in 2008 and 2009, how does the CDB or DFG know what the status of the frog populations are now in 2011?

So where is the current 2011 surveys of the 255 sites that show this MYLF listing on the CA ESL is still a valid issue? There could just as easily have been a MYLF population explosion since Jan 2010 (Well after the last surveys were likely done. Which was when?) . It’s even likely the populations at those sites moved to a more inviting habitat where their numbers are not being counted. Plus the previous year in in CA has been unusually wet from rain and snow, which will surely mitigate the drought extinction factor.

The MYLF Life Cycle-
http://www.mylfrog.info/naturalhistory/lifecycle.html

A MYLF lays frog 40-300 eggs in the early spring each year. Though it may take up to 4 years for the MYLF to reach full maturity (i.e. in the most extreme habitat where a high mountain lake is very cold for half the year), that would mean if only half the eggs reached maturity in 4 years, there would be a population increase of 150 times the parental population every four years. So where is the current data showing that DFG’s reductions in some area trout plants has not improved the situation since the last survey at the 225 historic MYLF survey sites? It’s more likely that one frog at each site has turned into 150 juvenile frogs the first year after the last survey. Or 150x150 frogs the second year, etc etc. In lower elevations not subject to long freezing winters, this conservative calculation could easily be doubled, since the warmer climate and water allows for a faster growth cycle to frog maturity and reproductive mating.

How many thousands or millions of these frogs are spread throughout CA in different water bodies right now? Does every water body where they live need to be protected to maintain a healthy population statewide? Is 100,000 enough of them, or 1,000,000? A low survey count at any site, or even dozens of them, doesn’t mean the frog population is endangered, but could equally mean that they may have been forced to relocate because it was too hot or cold or too dry or wet for them to remain at the survey site to be counted again next year. (i.e low water, flood event {natural or damming} or temperature changes)

Finally, since the MYLF was not put on the USFWS ESL in 2000, but was only put on their waiting list, doesn’t that indicate that there was inadequate evidence presented to the USFWS to prove an “immediate” need for its listing? Sounds like the case here in CA.

DFG should be able to mitigate enough of the major factors endangering the MYLF to bring it back quickly and safely, if in fact that has not already happened.

In light of aforementioned reasons, CA ESL listing for the Mountain Yellow-Legged Frog should NOT be pursued.

Respectfully submitted,

[Bluebeard]

Here' my version of the letter- going a little different route:

To whom it may concern:

Re: Listing the Mountain Yellow Legged Frog as an endangered species (or any other amphibian species as an endangered species) and its effect of those who own properties where this amphibian may or may not reside:

Due to modern industrialization and masses of population increases in local urban populations over the last 100 years, not to mention the steady increasing of the output of the sun’s intensity, and the degradation of the ozone layer; all of the once pristine outdoor environments are changing. Accompanying this change is an extreme modification of the outdoor environment.

It is prudent to list species whose numbers are being threatened, but what can you do to actually modify the constantly changing environmental conditions where all of these now threatened species once thrived? How do you diminish the intensity of the sun? How do you remedy the breakdown of the ozone layers in our atmosphere? How do you limit the acid rain and airborne industrial pollution that daily rains down on the natural environments which are now ever so close to urban centers?

Evolution is change, and as the natural environment changes, so must all the species that live in the environment. As the outdoor environment grows more acidic due to industrial pollution, the internal metabolisms of all the species that used to thrive in a less acidic environment must find a way to adapt. And if they cannot adapt, they will die.

According to the American Institute of Biological Sciences it is becoming increasingly apparent that the amphibian populations are in decline in a wide variety of geographic regions and habitats (Halliday, T., (1998). New evidence confirms amphibian declines in protected habitat. DAPTF (online) 1-2-01).

Scientists suspect declines may be due to:

UV radiation
Pesticides
Fungi
Surfactants
Parasites
Habitat Destruction
Water Pollution
Introduction of non-native trout species
Global Warming
Viral Infections
Grazing by cattle
Alien Predators

As per their findings, “Recent evidence shows that ultraviolet radiation, perhaps linked to ozone depletion, causes the formation of cyclobutane pyrimidine dimers, leading to a higher mortality rate and slower development time in amphibian embryos. If such is the case, increasing ultraviolet radiation could be a major cause of population declines in the amphibian world”

“Frog species such as the Colorado River toad, Yosemite toad, foothill yellow-legged frog, mountain yellow-legged frog, cascades frog, spotted frog, leopard frog, tailed frog, and Western spade-foot toad are all on California’s protected species list.”

“The apparent sensitivity of some amphibians to current levels of ultraviolet radiation has lead to a hypothesis that increasing ultraviolet radiation has contributed to global amphibian declines.3,4 This hypothesis could explain the puzzling recent extensive declines of species in relatively undisturbed habitats. Declines are occurring in such diverse habitats that finding a single common cause is not likely. Declines attributable solely to ultraviolet radiation are therefore suspect.”

• “Because frogs and toads lead a double life, meaning both terrestrial and aquatic, they are twice as likely as other vertebrates to be effected by their environment.

• What makes frogs such important bioindicators is their permeable skin, which makes them highly vulnerable to toxins and threats present in the water, on land, and in the atmosphere.

• Amphibians are among the first organisms to suffer from the effects of global pollution and climate change — providing an early warning of environmental degradation.


Other pertinent articles:

• Ghosts in Our Midst: Coming to Terms with Amphibian Extinctions.”
A global mass extinction of amphibians is well under way, driven both by habitat loss and by environmental changes. As amphibian communities in Central America are being decimated by chytrid disease, scientists are working to fashion an emergency response. They are also sending out an urgent warning about what the loss of these environmentally sensitive species may portend. Learn more about the decline of the first vertebrates on Earth in the April 2007, BioScience article by Scott Norris. Free to read.
http://caliber.ucpress.net/doi/full/10.1641/B570403

• » “Amphibian Population Declines: Evolutionary Considerations.”
Numerous factors, such as global environmental changes, habitat destruction, introduced species, diseases, and chemical pollution, appear to be contributing to amphibian population declines. Blaustein and Bancroft (BioScience, May 2007) believe that a better understanding of amphibian population declines requires that scientists and policymakers consider the ecological processes associated with the declines in light of specific evolutionary principles. Free to read.
http://caliber.ucpress.net/doi/full/10.1641/B570517


Recognizing the declines of the varieties of amphibian species is important, but by including these species on the endangered species creates a policy that hurts businesses, property owners and farmers in order to protect animals that are at risk. In many cases (as noted by the environmental changes affecting the amphibian populations listed above) the land owners had no direct effect upon the decline of the species, yet the are being penalized because the species may (or may not) exist on their property and the ecological effects that caused the decline of the specific species is completely beyond the control of the property owner.

The greatest problem with the Endangered Species Act (ESA), passed in 1973, is its land use provisions. These provisions penalize public and private landowners by:

• Fining landowners up to $100,000 and/or sentencing them to up to one year in jail for harming one eagle, owl, wolf or other protected species, or even its habitat, whether the habitat is occupied or not.

• Prohibiting, or tightly regulating, otherwise normal and legal land uses, such as farming, lumbering, construction, human habitation or even visiting the land.

• Providing no compensation landowners for the loss of land value, loss of income or lost use of land.

• Extending regulations to land that isn't currently occupied by an endangered species — but might be suitable for the species' breeding, resting, roosting or feeding.

• Subjecting millions of acres and millions of human residents to land use regulations for a single protected species.

The key to future success for endangered species protection is to set a new course based on the recognition that landowners can be cooperative and even helpful when they benefit from, or are at least are not harmed by, conservation initiatives. This means stripping the ESA of its land-use controls.

Please re-consider adding any species to the endangered species list until a fair and equitable provision is also included to the act to protect the private property owner.

Thank you for your time,


Of course, do not copy it verbatim, but you get the gist- a couple of things to look up on a goggle search is: Amphibian Die off & Endangered Species Act effects on landowners. There is a lot of info on both of these subjects.

[CalGoldDredger]

All good guys!

Rick, don't forget to comment on the "Foothill" variety yellow-legged frogs for the SDEIR. Or it will stand as it is for the species-based restrictions for us brother.

[mojavejoe]

Hey Guys,

I found this DFG management plan from 1999? which makes for some very interesting reading and discusses the MYLF in several places. It's 21 pages in pdf format. Gives some insight to their thinking, and possible solutions to the whole MYLF problem.

http://www.dfg.ca.gov/habcon/conproj/bi ... bp_txt.pdf

Want more on DFG & the MYLF?

Google "habcon dfg mylf"