Ralph Cutter dated 11/17/2011

November 17, 2011

Mr. Jim Kellogg, President
California Fish and Game Commission
1416 Ninth Street
P.O. Box 944209
Sacramento, California 94244-2090

Dear Mr. Kellogg:

The proposal to mitigate ESA species loss by reducing the number of striped bass in the Sacramento/San Joaquin Delta is as simplistic and outdated as it is flawed.

As far back as 1920 Aldo Leopold understood that eliminating predators to favor prey invariably backfired with a resulting net loss of a healthy and vibrant prey population. This dynamic has been demonstrated time and time again as wildlife mangers culled wolves, bears, mountain lions, and coyotes only to find that the prey species suffered as a result. I urge you to demand that your biologists provide a single example where removing an established apex predator from a balanced environment created a healthier ecosystem.

The striped bass is an introduced species that, over the course of a century, has found its niche in the Delta ecosystem. In terms of species dynamics, things are at a relative equilibrium. The trophic cascade following the proposed regulations will be as violent as it will be unpredictable. Frequently, in the state of flux following apex predator removal, mesopredator numbers skyrocket far beyond the system’s carrying capacity and prey species are decimated. This could be the coup-de-grace for our wild salmon.

The vacuum created by removing striped bass will not be ignored by other predatory fishes. Large mouth bass have been identified as the largest consumer of native fishes in the delta. Eliminating a primary competitor and predator of large mouth bass (and Sacramento pike minnow) will likely result in an unmitigated population boom. As some of the world’s top fisheries biologists have predicted, the loss of striped bass will likely result in a net loss of salmonids and other ESA species.

I have extensively reviewed the DF&G staff report’s bibliography. Any report based on these papers will read like a sales pitch rather than an educational document. As one who has received numerous “staff reports” I expect to be provided a synopsis of the entire picture rather than blind sided by some staffer who wishes to pursue his or her agenda.

Demand that your staff produce a balanced report that includes the conclusions of doctors Moyle, Bennett, Ostrach, Prugh, Clinton and others. I am confident that an honestly informed Commission will be reluctant to tweak Mother Nature at this immense scale.


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