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Comments needed NOW on proposed listing for Mountain Yellow-legged Frog in California

March 16, 2011

We received late notification of this possible listing, so please act now to get some comments in on behalf of miners. The comment deadline has been extented from March 18 to April 1, 2011.

The California Department of Fish & Game (CDF&G) is considering listing the Mountain Yellow-legged Frog as an endangered species under the California Endangered Species Act.

While such a listing for this frog could negatively effect mining -- particularly in and around waterways -- the answer to solving their demise lies with the government. Numerous studies are available on the Internet which conclude that the biggest threat to these frogs is trout that are being raised and released into waterways by government agencies.

According to the Center of Biological Diversity, “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."

Following are two sample letters. (Please use them as a guide only -- if you submit the exact same comments then your comments will not be considered.)

First Sample Letter (from Public Lands for the People):
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.
 
These comments are submitted by me as an individual, as a mineral Estate owner, and as a Board member of Public Lands for the People. INC.
 
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,
 

Second Sample Letter (from Public Lands for the People):
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 action.

Sincerely,
 

Please email your comments to: MYLF@dfg.ca.gov

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