Mason-Griffith Founders Chapter, Trout Unlimited
P.O. Box 502  •  Grayling, MI  •  49738

January 18, 2013

Board of Commissioners
County of Crawford
200 W. Michigan Avenue
Grayling, Michigan 49738

Dear Commissioners:

The Mason-Griffith Founders Chapter of Trout Unlimited has been a consistent supporter of the Grayling Fish Hatchery both as a tourist attraction and as an educational tool in teaching school children of our community about the historical and natural resource roots of Crawford County.  We have donated thousands of dollars to the Children’s Free Fishing Pond and have used the hatchery for our fly-fishing classes and the very popular “Trout in The Classroom” program, in conjunction with the Grayling Middle School.  Our community is important to us, and we want to ensure its prosperity and environmental quality for those who come after us.

We would very much like to see the hatchery remain open and available to the public. However, as the founding chapter of a nationwide organization dedicated to the conservation, protection and restoration of North America’s coldwater fisheries and their watersheds, we would be remiss if we didn’t express our concerns about the proposal for the hatchery to become a full-time commercial operation.  The hatchery is located in the headwaters of the most famous river in the Midwest.  We feel it’s important to recognize that the proposed commercial operation of the hatchery is markedly different than the way in which the hatchery has been operated for the past several years. 

Mr. Vogler intends to run the hatchery as a full-time for-profit commercial venture which poses inherent risks and could negatively affect one of the most prized natural resources in the state. There will be a tremendous increase in the pounds of fish raised on site.  A great increase in the pounds raised per year causes concern about a number of potential problem areas:  spread of disease, discharge of both excess nutrients and waste products, escapement of genetically altered fish and the species of fish to be raised, and the length of the proposed lease. Another major concern is the reconnecting of the East Branch with the rest of the Au Sable River Watershed.

The Au Sable River system is world renowned for the quality of its trout fishing, a fame that brings people from around the world to Grayling and surrounding communities.  Sportfishing is a multi-million dollar industry that provides a large number of jobs, and revenue to businesses in Crawford County.   Also important to the county is the tax base from homes on the river, which is as high as it is specifically because of the quality of the river and the world-class trout fishing it offers.  It behooves us all to protect this natural jewel.     

A lease agreement with the operator is now being drafted and we feel it’s very important for the county to incorporate appropriate safeguards in that lease, as we cannot depend upon the state’s rules and regulations to protect this community’s most valuable coldwater resource.

Every fish rearing facility has issues – disease issues, escapement issues, waste disposal issues, etc.  County residents need to be reassured that there is a process in place to address these concerns:

Disease - whirling disease, for one example, was identified in the Au Sable River system in 2002.  Myxobolus cerebralis is the invasive species of microbe that causes this disease.  Though this disease does not affect the fish population at present, discharge from intensive hatchery operations provide inviting conditions for the microbe to live and thrive thus increasing the probability of infection of the natural trout population. There are also other fish diseases to be concerned with.  An outbreak of any disease in the Au Sable River would be disastrous to the local economy. Any fish brought into the Grayling Hatchery should be certified disease free.

Waste Disposal - rearing large numbers of fish in a confined space produces a large volume of waste (effluent).  This facility presents a special challenge for handling this waste due to the facility’s layout and its multiple discharge points into the East Branch.  We urge the commission to have a detailed plan included in the lease agreement showing how this waste is to be removed. There should also be a regular water quality monitoring plan in place to ensure the waste treatment plan in working as expected.

Escapement - while we recognize that it is good business on the part of a hatchery operator to prevent the loss of product, escapement does and will happen.  The Michigan Aquaculture Development Act, Act 199 of 1996, currently governs the species of fish allowed to be reared.  However, no one can predict what species of fish will be deemed popular or profitable several years from now and this act allows the rearing of over fifty (50) different species of freshwater fish.  We would like language regarding the species of fish to be raised at the hatchery  in any agreement with the operator. We feel it would be a serious mistake to allow anything other than brook, brown or rainbow trout to be present in the hatchery in order to ensure that any fish that does escape poses no threat to the wild trout population either genetically or through inter-species competition.

Reconnecting the East Branch to the Mainstream - before the County took over hatchery operations from the state to operate it as a tourist attraction, fish had free passage through the facility to the upstream reaches of the East Branch.  During the County’s operation, attempts were made to allow fish passage over the dam that had been installed to allow rearing in the facility.  Those attempts had marginal success, at best.  This past year, MDNR Fisheries staff designed a series of rock weirs to allow full fish passage through the facility and still maintain the fish rearing capabilities of the hatchery’s raceways. Prior to that, in 2010, the State of Michigan funded a $200,000 intensive in-stream fish habitat project upstream of the hatchery to improve trout fishing opportunities for all anglers. Anticipated reestablishment of fish passage to these reaches of the East Branch was a key part of these efforts.  This is consistent with previous state work wherein nearly half a million dollars had been spent to successfully improve fish passage in the upper Au Sable through the Grayling and Salling dam sites. Funding is becoming available now to complete a project that will reconnect the East Branch with the Mainstream. We urge the County to insist on modification that allows free passage of fish to spawning grounds.

Term of Lease – based upon the available information, it is our understanding that it is the county’s intention to lease this property for a period of 25 years with little or no compensation in return. The State of Michigan’s conveyance of this property to the County was contingent upon public access and the educational opportunities that the property provides.  Since this will now become a for-profit operation, we hope that free access for the public, as well as schools and other educational organizations and events is provided for in the lease. 

Again, based upon the available information, nothing that we’ve seen in writing addresses the aforementioned concerns - disease, escapement, waste management, fish passage, etc.  Should any of these become worst-case scenarios, the effect would be devastating to county businesses, jobs, and property values.

The Mason-Griffith Founders Chapter of Trout Unlimited’s mission is to “Conserve, Protect and Restore North America’s coldwater fisheries and their watersheds.” As stated earlier, we have been and continue to be supportive of community efforts to provide jobs, recreational opportunities and tourism in Crawford County. This is a great opportunity for the County and the Chapter to work together to protect the Au Sable River and we sincerely hope that this venture works out to everyone’s benefit.

If you have any questions or feel that we might be of any assistance please feel free to contact us at mgfc.tu@gmail.com.

Thank you for your serious and thoughtful consideration.

Sincerely,

  

Bob Andrus
President, Board of Directors
Mason-Griffith Founders Chapter of Trout Unlimited

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