The Federal government just locked up another 3,000 sq. miles of public land in California by designating it as “Critical Habitat” for three different species of amphibians.

This knee jerk land lock-up action is no surprise to me.  For the past 16 years I’ve been watching as Federal and State wildlife biologists have granted certain species of frogs and toads an elevated, almost mythic status similar to gray wolves.   In 2002 retiring National Park biologist Harold Werner bragged about the trout eradication program he began in Yosemite National Park.  Werner referred to trout removal as a “lake restoration” program designed to benefit amphibians and insects.  Werner and his colleagues hoped to expand trout removal, a.k.a. “lake restoration”, to 150 Sierra lakes in order to mitigate a “known threat” to the amphibian population.

The fact that introduced trout have co-existed with frogs and toads since they were planted in California’s Sierra Nevada Range nearly 90 years ago didn’t matter to Werner.  The fact that other natural and environmental  factors, such as chytrid fungus, air pollution, ultra violet radiation, and/or climate change, may be negatively impacting amphibian populations didn’t matter either.  A lawsuit filed by environmental groups led by the Center for Biological Diversity claims that all introduced, or “non-native trout species” must be eliminated from our National Parks and Wilderness Areas because they are not endemic to the area and their elimination is considered absolutely essential in order to save “native” frogs.

To mitigate one perceived threat to amphibians, Federal and State agencies have embarked on a poisoning and gill netting campaign to exterminate “non-native” fish both inside and outside of national park boundaries.  By early 2013 some 89 named lakes and hundreds of miles of streams throughout the Sierra Nevada range had been “restored to their natural, fishless condition”.   A very small percentage of these water bodies were re-stocked with “native” California Golden Trout, but the vast majority of waterways treated in the “restoration” program have been rendered fishless.   The official number of lakes and streams where all non-native trout have been exterminated is likely understated.  For example, the area known as “Sixty Lakes Basin” appears to have been counted as one waterway.

frog habitatThe recent USFWS mandated “Critical Habitat” designation comprises an area of close to 1 million acres exclusively set aside for the protection of the Sierra Nevada yellow-legged frog, an additional 221,498 acres for a sub-species of mountain yellow-legged frog, and another 750,926 acres for the Yosemite toad.  The  mandate will likely expand the trout removal program ten fold and include hundreds of additional alpine lakes and thousands of miles of streams across several western states.

But trout fishing in the Sierra Nevada is not the only activity that will take a hit because of these new protections for frogs. Other activities that will be more strictly controlled or eliminated altogether include cattle grazing, flood control (dam building), fire management and suppression, and timber harvesting.  The USFWS has identified sixteen risk factors that need to be mitigated in order to insure the survival of frogs and toads. 

These factors are:

  • Acid deposition
  • Airborne contaminants, including pesticides
  • Climate change
  • Disease
  • Fire management, including fire suppression
  • Habitat loss and fragmentation
  • Introduced fish and other predators
  • Livestock grazing
  • Locally applied pesticides
  • Recreational activities, including packstock
  • Research activity
  • Restoration
  • Roads
  • UV-B radiation
  • Vegetation and fuels management
  • Water development and diversion

Unfortunately, as I predicted in my 2014 article entitiled, “Where Does Your Treasure Lie- How Preserving Native Species has become a Religion“, the removal of “non-native” trout to protect frogs is not limited to California, but is spreading across the country.

In Wyoming, the Teton Wilderness “lake restoration” project is expected to be completed be the summer of 2017.   Currently, the Wyoming Department of Fish and Game (WDFG) is killing “non-native” trout in two lakes and creeks in the Teton Wilderness just south of Yellowstone National Park.  Introduced Rainbow and Brook Trout will be eradicated with Rotenone applications in Dime Lake and Mystery Lake and their corresponding outflows.   Mystery Lake will be restocked with “native” cutthroat trout, while Dime lake will be left fishless in order to protect the “native” Columbia Spotted Frog population.

Further south, in the Wind River Range, research is currently being conducted on other Rocky Mountain amphibian populations to determine how best to mitigate threats to their survival.   Quoting from one field study (linked below),  “threats include diseases such as amphibian chytrid fungus (Batrachochytrium dendrobatidis) and Ranavirus, pesticides, herbicides, environmental pollutants, invasive species, non-native species, ultraviolet radiation, and habitat loss and fragmentation.”

The terms invasive and non-native refer to multiple species of introduced trout.  It is a historical fact that just as the high mountain lakes in the Sierra Range were historically fishless, most of the alpine lakes and high mountain streams in the Wind River Range were also fishless prior to the fish stocking programs conducted in the 1930’s and ’40’s by Finis Mitchell and others.  As a result of the tireless work of these individuals, the Wind River Range was transformed from a barren landscape into one of the most unique and diverse trout fisheries anywhere in the world.  But now, after nearly 90 years of living side by side with frogs the trout have all of a sudden become a “known threat”, and must be destroyed.

“Critical Habitat” designations open the door to limitless Federal land grabs. Wake up Wyoming!  Wake up America!  In a few short years hundreds of Wind River lakes and streams that now contain self-sustaining populations of trout species such as Rainbow, Brook, German Brown, California Golden, Yellowstone Cutthroat, and Arctic Grayling, may be rendered fishless in order to protect one or more arbitrarily designated “keystone” frog species that are very likely succumbing to factors other than “non-native” trout.

Sources for this article:

Click to access 2016-20352.pdf

Click to access stelprd3836426.pdf

Click to access stelprdb5363180.pdf


  1. It should be noted that Trout Unlimited joined the Center for Biological Diversity lawsuit to eradicate trout in the Sierra Nevada range. TU’s take was that Rainbow, Brook, and Brown trout should be removed to enhance the native California Golden trout population. To date, a small percentage of “restored” waterways have been restocked with California Golden trout, but the VAST MAJORITY of “restored” waterways have been left in their historically fishless condition in order to protect frogs.

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