Formal Comments re: Listing of Atlantic Salmon of the Gulf of Maine as
Endangered
My name is Roger Wheeler and I live in Fryeburg Maine. I represent the Friends
of Sebago Lake.
Over the last 18 years we have had a great interest in researching the natural
history of Maine’s anadromous fish. Our research was a key factor in the US
Supreme Court Case of South African Paper Products International (SAPPI) vs
State of Maine where the court unanimously defended the State’s right to mandate
fish passage on Maine dams. We do believe that Atlantic Salmon should be
declared an endangered species in the Gulf of Maine and that Maine’s former
salmon rivers be designated as critical habitat.
The success of Anadromous fish restoration in the late 1800’s was faciltated
by restoring access of anadromous fish to numerous large inland lakes and rivers
for spawning and thus providing protection and food for young fish. Because of
instinct, anadromous fish strive to reach the farthest reaches of a watershed as
this is also the safest habitat for their spawn. Because they were aware of
this, the US Fish Commissioners adamantly professed in their reports, dams with
inadequate passage severly harmed the anadromous fish populations.
Another significant impact on anadromous fish populations is the severe
unnatural flowage regulation of our inland waterways. If fish passage is
restored anadromous fish will encounter many lakes, lake wetlands and rivers in
their historical range where the unnatural regulation will prevent the
successful propagation of their species. In the mid 1970’s the lake interest
groups under Congress of Lakes Association (COLA) successfully lobbied the
legislature to pass legislation that keeps water levels in Maine lakes
constantly high as possible. On Federally controlled lakes boating interests
have forced higher lake levels. As a result lake wetlands and littoral areas
have been degraded. Lake wetlands are crucial for the lake ecosystem to support
anadromous fish. China Lake is a key example where lake wetlands disintergrated
when water levels were kept constantly high and no longer support a viable
salmon fishery. It is mentioned in scientific literature that when a lake is
unnaturally regulated fish assemblages change. The greatest changes occur when
lake water levels are kept high and fluctuation is minimized.
I am requesting that NOAA help secure funding sources for studies
regarding the impacts of unnatural lake regulation on lake wetlands and the
relationship of various regulation regimes on lake wetland biota, water quality,
and fish assemblages.
The most in depth scientific knowledge of unnatural regulation impacts
on lake wetland biota are from studies on the Voyageurs Lakes and Lake Ontario.
It is worthy to mention that a more lake environmentally friendly regulation
plan on Lake Ontario is supported by the Moses Saunders Dam hydropower
interest
and fishing groups for they understand it is in their best interest to do so.
Like Maine however it is the intransigent recreational and boating interests who
dictate regulation of surface water flows.
Fish passage restoration and lake regulation that mimicks natural seasonal
cycles together can rebuild what was once one of the finest anadromous fisheries
in the world.
By the 1880’s When fish passage was fully restored on the Presumpscot River,
Sebago Lake was restored to a world famous salmon fishery. I would like to quote
a passage from a May 10, 1886, Boston Globe article where the Maine Fish
Commissioner has set up a trapping station on the Crooked River for securing
salmon eggs.
“Then came a heavy rain and after that, about November 2, a remarkable “run”
took place which, considering the size of the stream, exceeds anything of the
kind known either to State or the United States commissioners..
In the twenty-four hours ending Wednesday, November 3, no less than
sixty-nine salmon, weighing, on an average, sixteen pounds each, came into the
trap. One of them, a male, tipped the scale at twenty seven pounds, and in the
depth of body and general appearance is unlike any ever seen in Maine waters.”
Fish Commissioners reports document that many of the large salmon in Sebago
Lake
were actually sea salmon
The 1800’s success of Atlantic Salmon restoration in Sebago Lake was due to the
work of the US and Maine Fish Commissioners to plant salmon fry in the
Presumpscot and Sebago waterways and to the regulation of Sebago Lake outlet
dam
which mimicked the natural seasonal hydrological cycle with interannual
variability. Sebago Lake in the 1800’s despite intense watershed land use was a
remarkable clean sandy bottom lake with shoals and drowned tributary rivers
highly suitable for salmon spawning because of the lake regulation that mimicked
the natural water level cycle.
In conclusion, I do emphasize the necessity for studying the impacts
of unnatural lake level regulation, its effects on lake and riverine wetlands
and its impact on successful anadromous fish restoration.
Roger Wheeler
Friends of Sebago Lake
PO Box 561
Fryeburg
Maine 04037
email: friendsofsebago@yahoo.com
Comment from Roger Wheeler, Friends of Sebago Lake
This is comment on Proposed Rule
Endangered and Threatened Species; Proposed Endangered Status for the Gulf of Maine Distinct Population Segment of Atlantic Salmon
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