Appendix K

MINIMUM REQUIREMENTS DECISION GUIDE

OVERVIEW , I NSTRUCTIONS , 

AND WORKSHEETS

WASHINGTON DEPARTMENT OF

FISH AND WILDLIFE

C OMMENTS ON THE MINIMUM

REQUIREMENTS A NALYSIS
ENVIRONMENTAL IMPACT STATEMENT 275

APPENDIX K: 

MINIMUM REQUIREMENTS DECISION GUIDE 

OVERVIEW, INSTRUCTIONS, AND WORKSHEETS 

WASHINGTON DEPARTMENT OF 

FISH AND WILDLIFE 

COMMENTS ON THE MINIMUM REQUIREMENTS ANALYSIS
A PPENDIXES

276 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 277
A PPENDIXES

278 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 279
A PPENDIXES

280 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 281
A PPENDIXES

282 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 283
A PPENDIXES

284 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 285
A PPENDIXES

286 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 287

MINIMUM REQUIREMENTS 

DECISION GUIDE WORKSHEETS 

Arthur Carhart National Wilderness Training Center 

“. . . except as necessary to meet minimum requirements for the administration of the area for the 

purpose of this Act...” 

– The Wilderness Act, 1964 

Step 1: Determine if it is necessary to take action.

Briefly describe the situation that may prompt action: 

The situation that may prompt action in the Stephen T. Mather Wilderness is the implementation of a 

Mountain Lakes Fishery Management Plan/Environmental Impact Statement (plan/EIS). The draft 

plan/EIS considers a range of management alternatives, which include fish stocking and removal of 

reproducing populations of fish in select mountain lakes. The following section describes the purpose and 

need for the draft plan/EIS, and the existing conditions that may prompt administrative action in the 

Stephen T. Mather Wilderness. 

The purpose of the draft plan/EIS is to guide management actions by the NPS and WDFW in mountain 

lakes that would: 

• Conserve native biological integrity; 

• Provide a spectrum of recreational opportunities and visitor experiences, including sport 

fishing; 

• Resolve the long-standing debate and conflicts over fish stocking in the naturally fishless 

mountain lakes in North Cascades National Park, Ross Lake National Recreation Area, and 

Lake Chelan National Recreation Area (which together make up the “North Cascades National 

Park Service Complex”) 

Need: 

NPS fishery management actions are governed by various relevant laws, regulations, and policies. In most 

NPS units, natural resources (including lakes and fish) are managed in accordance with the Organic Act 

of 1916 and in concert with NPS Management Policies (NPS 2001a) and Director’s Order 12:

Conservation Planning, Environmental Impact Analysis, and Decision Making and Handbook, which 

allow sport fishing unless it is specifically prohibited, and prohibit stocking in most NPS waters (NPS 

2001a, 4.4.3 and 8.2.2.5). 

In the North Cascades Complex, fish have historically been managed by a combination of agencies and 

user groups. This is partly because the enabling legislation for the North Cascades Complex does not 

define the angling activities that were to be allowed within its boundaries, and partly because the area has 

a history of fish management by the state of Washington and sport fishing groups. This history of fish 

management predates the 1968 establishment of the North Cascades Complex by many years (see 

“History of Fish Management in North Cascades Mountain Lakes” in the “Background” section of the 

“Purpose of and Need for Action” chapter of the draft plan/EIS for more information on the North 

Cascades Complex enabling legislation). 
A PPENDIXES

288 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

The lakes that are the focus of the draft plan/EIS are the 91 mountain lakes in the North Cascades 

Complex that were naturally fishless, but have had some history of fish stocking since the late 1800s. The 

Stephen T. Mather Wilderness portion of the North Cascades Complex encompasses all of the lakes 

(except Thunder Lake) under consideration in the draft plan/EIS. 

Existing Conditions: 

Approximately 1000 anglers per year fish in the mountain lakes in the Stephen T. Mather Wilderness. The 

lakes are naturally fishless. In order to maintain a viable mountain lakes fishery for these anglers, some of 

the mountain lakes are stocked periodically by the Washington Department of Fish and Wildlife and their 

approved representatives. The Washington Department of Fish and Wildlife and various user groups 

advocate allowing fish stocking to continue in order to maintain the mountain lakes sport fishery. 

Past stocking efforts have created reproducing, self-sustaining populations of nonnative fish in 37 lakes in 

the Stephen T. Mather Wilderness. Research demonstrates that these self-sustaining populations of fish 

can overpopulate the lakes and cause a variety of ecological effects. These effects include predation and 

competition with native organisms, and the potential for downstream dispersal and hybridization with 

native fish populations. 

Administrative Actions analyzed in this Minimum Requirements Analysis: 

The administrative actions of fish stocking and fish removal in the Stephen T. Mather Wilderness are 

considered in this analysis. Fish stocking would involve placing hatchery produced, nonreproducing trout 

in select mountain lakes. Methods for transporting stocked fish would include hand stocking via backpack 

access, and stocking by air with fixed wing aircraft. Fish removal would include various means of 

removing reproducing fish populations from select lakes. Fish removal would involve mechanical 

methods such as gillnetting combined with electrofishing and blocking access to spawning grounds in 

lakes with very limited spawning habitat. Fish removal would also involve application of the piscicide 

antimycin. The draft plan/EIS also considers a passive or “natural” method of fish removal that simply 

involves stopping the ongoing practice of stocking certain lakes that do not contain reproducing 

populations of fish. Since ceasing to stock as a means of removing fish does not involve administrative 

action in the Stephen T. Mather Wilderness, it is not considered in this analysis. Fish stocking and fish 

removal are considered separately in the following sections of this Minimum Requirement Analysis 

because they have different consequences for wilderness resources and the wilderness experience. 

A. Describe Valid Existing Rights or Special Provisions of Wilderness Legislation 

Are there valid existing rights or is there a special provision in wilderness legislation (the Wilderness 

Act of 1964 or subsequent wilderness laws) that allows consideration of action involving Section 4(c) 

uses? Cite law and section. 

 Yes: 6 No: 6 Not Applicable: 

Explain: 

Valid Existing Rights: There is disagreement between the Washington Department of Fish and Wildlife 

and the National Park Service over the degree of jurisdictional authority to stock waters in the national 

park portion of North Cascades Complex. For the purpose of this analysis, it is asserted that this issue is 
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 289

not subject to existing rights. The basis for this assertion is the NPS interpretation of the enabling 

legislation and legislative history for the North Cascades Complex. 

Special provision in legislation (the 1964 Wilderness Act or subsequent laws), that allows this 

project or activity: 

Fish Stocking: There is no provision in the enabling legislation, the Wilderness Act, or the Washington 

Park Wilderness Act that explicitly allows for fish stocking. 

Fish Removal: There is no provision in the enabling legislation, the Wilderness Act, or the Washington 

Park Wilderness Act that explicitly allows for fish removal. However, as an administrative unit of the 

National Park System, the North Cascades Complex is governed by the National Park Service Organic 

Act (39 Stat. 535, codified at 16 U.S.C. sections 1 through 4), which prohibits the NPS from allowing 

impairment of park resources or values. Thus, the NPS would have the authority to remove fish from 

wilderness lakes if their presence has the potential to impair park resources or values. 

B. Describe Requirements of Other Legislation

Do other laws require action? 

 Yes: 6 No:  Not Applicable: 

Explain: 

Provisions of the NPS Organic Act (39 Stat. 535, codified at 16 U.S.C. sections 1 through 4), and the 

Redwood National Park Expansion Act, as amended (92 Stat. 166, codified at 16 U.S.C. 1a-1), prohibit 

NPS from taking any action that may potentially impair park resources and values. For a complete 

description of other related laws, see appendix D of the draft plan/EIS. 

C. Describe Other Guidance 

Does taking action conform to and implement relevant standards and guidelines and direction 

contained in agency policy, unit and wilderness management plans, species recovery plans, tribal 

government agreements, state and local government and interagency agreements? 

 Yes: 6 No: 6 Not Applicable: 

Fish Stocking: Stocking of naturally fishless lakes in the National Park portion of the Stephen T. Mather 

Wilderness violates current NPS management polices regarding stocking of nonnative fish into national 

park waters. However, NPS policies do allow for stocking of nonnative fish into national recreation areas 

under certain circumstances (see section below entitled “NPS Management Policies 2001” and 

appendix D). 

Fish Removal: The removal of nonnative populations of fish from lakes in both the park and national 

recreation areas would conform to NPS management policies. Fish removal would also conform to the 

terms of the 1985 MOU between the NPS and WDFW regarding fish and wildlife management provided 

that the NPS consults with the WDFW before taking any action (see section below entitled “MOU 

Between the NPS and WDFW” and appendix A). 
A PPENDIXES

290 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Explain: 

NPS Management Policies (2001) 

NPS Management Policies instruct park units to: 

Maintain as part of the natural ecosystems of parks all native plants and animals by minimizing 

human impacts on native plants, animals, populations, communities, and ecosystems, and the 

processes that sustain them (NPS 2001a, 4.4.1). 

Reestablish natural functions and processes in human-disturbed components of natural systems in 

parks (unless otherwise directed by Congress) (NPS 2001a, 4.1.5). (Human disturbances include the 

introduction of exotic species and the disruption of natural processes. Using the best available 

technology and within its staff, funding and other resource constraints, park units are to restore the 

biological and physical components of these systems.) 

Seek to return human-disturbed areas to the natural conditions and processes characteristic of the 

ecological zone in which the damaged resources are situated” (NPS 2001a, 4.1.5). 

Allow recreational uses in wilderness that enable the areas to retain their primeval character and 

influence; protect and preserve natural conditions; leave the imprint of man’s work substantially 

unnoticeable; provide outstanding opportunities for solitude or primitive and unconfined types of 

recreation; and preserve wilderness in an unimpaired condition (NPS 2001a, 6.4.3). 

Evaluate recreational uses --particularly new and emerging uses-- that compromise the stated 

purposes and definitions of wilderness or unduly impact the wilderness resource or the visitor 

experience within wilderness, to determine if these uses are appropriate, or should be limited or 

disallowed (NPS 2001a, 6.4.3.1). 

Sport fishing is generally allowed in NPS units unless specifically prohibited, providing it “does not 

jeopardize natural aquatic ecosystems or riparian zones” (NPS 2001a, 8.2.2.5). At least one-third of the 

areas administered by the NPS have substantial fish resources and fishery activities. Sport fishing has 

been permitted in national parks since the establishment of Yellowstone National Park in 1872. Sport 

fishing is managed under 36 CFR 2.3, which states in part, “fishing shall be in accordance with the laws 

and regulation of the State . . . Nonconflicting State laws are adopted as part of these regulations.” The 

NPS is allowed to restrict fishing activities wherever needed to achieve its own management objectives. 

In contrast to sport fishing, the practice of stocking fish is generally prohibited in park units. Stocking 

cannot “impair park natural resources or processes,” and it must take place only in national recreation 

areas or preserves that have historically been stocked (only the same species that has historically been 

stocked may continue to be stocked) (NPS 2001a, 4.4.3). Exotic species cannot displace native species (if 

displacement can be prevented), and parks are to manage “up to and including eradication” if control is 

feasible and the exotic species interferes with native species, natural habitats, or disrupts the integrity of 

the native species (NPS2001a, 4.4.4.2). If an exotic species is introduced or maintained to meet specific 

NPS management needs, all “feasible and prudent measures to minimize the risk of harm” to native biota 

or invasion of habitat by the exotic species must be taken, and the exotic species must “be known to be 

historically significant, to have existed in the park during the park's period of historical significance, or to 

have been commonly used in the local area at that time (NPS 2001a, 4.4.4.1).” 

For more information regarding NPS Management Policies, refer to appendix D of the draft plan/EIS. 
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 291

Memorandum of Understanding between the NPS and WDFW 

To resolve differences in policy and to foster a spirit of cooperation, the NPS and WDFW negotiated a 

series of agreements beginning in 1979 that allowed stocking to continue in selected lakes in the North 

Cascades Complex. Currently, the management of mountain lakes is performed under a temporary 

extension of the 1985 Memorandum of Understanding and 1988 Supplemental Agreement between the 

two agencies. The Memorandum of Understanding and Supplemental Agreement (see appendix A for 

copies of both documents) were written “to continue cooperative efforts in management of protection and 

enhancement of the fisheries and wildlife resources of mutual concern.” The Memorandum of 

Understanding provided “Statements of Work” (or directives) for both the NPS and the WDFW. The 

three main management directives from the Memorandum of Understanding that, in part, pertain to fish 

management are: 

1. To consult with the Department [WDFW] prior to initiating research projects or implementing 

plans, programs, or regulations affecting fish and wildlife species distribution, numbers, or public 

use of fish and wildlife found within areas administered by the Service [NPS]. 

2. To practice those forms of management which will benefit fish and wildlife, and their habitats, 

and to maintain or restore their natural and historic distribution and abundance, consistent with 

the respective Service [NPS] policies and park objectives. 

3. To permit the harvest of fish and wildlife in accordance with applicable state laws and regulations 

of the Department [WDFW] in those areas under the jurisdiction of the Service [NPS], which are 

open to hunting and/or fishing. It is recognized that some park regulations may vary for 

management purposes. 

D. Describe Options Outside of Wilderness 

Can this situation be resolved by action outside of wilderness? 

 Yes:  No:  Not Applicable: 6

Explain: 

Only one lake in the study area is outside of wilderness boundaries within the North Cascades Complex 

(Thunder Lake). There are hundreds of fishable lakes outside of the North Cascades Complex boundaries 

located within surrounding National Forests, but most of these lakes are also within wilderness 

boundaries. The NPS would not have authority to take actions outside its boundaries. In addition, some 

anglers who desire continued sport fishing believe that sport fishing in North Cascade lakes is a 

recreational opportunity that cannot be duplicated elsewhere. 
A PPENDIXES

292 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

E. Wilderness Character 

How would action contribute to the preservation of wilderness character, as described by the 

components listed below? 

 Yes: 6 No: 6 Not Applicable: 

• “Untrammeled” – Wilderness is ideally unhindered and free from modern human control or 

manipulation. 

• “Undeveloped” – Wilderness has minimal evidence of modern human occupation or 

modification. 

• “Natural” – Wilderness ecological and evolutionary systems are substantially free from the 

effects of modern civilization. 

• “Outstanding opportunities for solitude or a primitive and unconfined type of recreation”

– Wilderness provides opportunities for people to experience natural sights and sounds, 

solitude, freedom, risk, and the physical and emotional challenges of self-discovery and selfreliance. 

Untrammeled: 

Stocking naturally fishless lakes, even with nonreproducing trout, would not leave the wilderness “ideally 

unhindered and free from modern human control or manipulation.” Stocking of fish would manipulate the 

native ecology of a lake and introduce a nonnative species for the purpose of enhancing recreation. 

Fish removal would also entail short-term human control or manipulation, with the objective of 

reestablishing sustainable native ecological conditions. Over the long term, removal of self-sustaining 

populations of trout would reestablish the untrammeled nature of the wilderness character by reducing 

evidence of human manipulation (e.g., nonnative fish) in lakes. 

Undeveloped: 

Development of the wilderness would not occur under any of the alternatives. 

Natural: 

Stocking with nonreproducing trout would temporarily affect the natural character of naturally fishless 

lakes in wilderness by introducing a nonnative species, thus manipulating the ecological structure of the 

lakes. 

Removal of self-sustaining populations of nonnative fish would help to reestablish and conserve the 

biological integrity in naturally fishless lakes. 

Following removal of reproducing populations, two of the alternatives propose to restock some of the 

lakes with nonreproducing fish as a means of continuing to provide sport fishing opportunities while 

minimizing impacts to biological integrity associated with reproducing populations of fish. Restocking, 
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 293

however would have minor to moderate adverse impacts to native biota over the long-term, and would 

provide no substantive benefits to the natural character of naturally fishless lakes within the wilderness. 

Outstanding opportunities for solitude or a primitive and unconfined type of recreation: 

Fish stocking would provide approximately 500 to 1,000 anglers per year with the opportunity to fish and 

have a wilderness experience while doing so. Fish stocking, the presence of anglers, fishing tackle left 

inadvertently behind, and other evidence of this human activity may impact the opportunities for solitude 

for some visitors who seek a wilderness experience within the North Cascades Complex. 

Removal of reproducing populations of fish would take many years. During this time, some anglers and 

nonanglers would experience removal activities such as helicopters flights, motorized equipment use and 

the routine presence of field crews in limited areas of the wilderness. These activities would adversely 

affect opportunities for solitude and other elements of the wilderness experience for some wilderness 

users. 

Other unique components that reflect the character of this wilderness: 

Some anglers have reported through the EIS public scoping process that fishing the mountain lakes in the 

Stephen T. Mather Wilderness is a unique wilderness experience cannot be duplicated elsewhere. They 

cite the ruggedness of the terrain and the remoteness of the mountain lakes as providing outstanding 

opportunities for a wilderness experience while fishing within the North Cascades Complex. 

F. Describe Effects to the Public Purposes of Wilderness 

How would action support the public purposes for wilderness (as stated in Section 4(b) of the 

Wilderness Act) of recreation, scenic, scientific, education, conservation, and historical use? 

Explain: 

Fish stocking would continue to enhance recreational opportunities (sport fishing) in natural mountain 

lakes for approximately 1,000 anglers per year who use the wilderness area. Stocking and sport fishing 

have been a historic use of the area for several generations prior to the wilderness area’s establishment. 

Stocking of nonreproducing trout in a scientifically informed manner using adaptive management 

principles would minimize impacts to the scientific and conservation purposes of wilderness. However, 

various elements of the scientific and conservation purposes of wilderness would remain compromised to 

some degree because the lakes were naturally barren of fish. For example, some of the mountain lakes 

would no longer provide scientists with the opportunity to study the ecology of naturally fishless 

mountain lakes because the lakes would contain nonnative fish. 

Removal of self-sustaining populations of trout would best protect the scientific and conservation 

purposes of wilderness because removal would help to conserve biological integrity by reestablishing 

fishless conditions. Following removal, it is assumed that ecological structure of the lakes would revert to 

naturally fishless conditions although this could take many years. However, removal of reproducing 

populations of fish would reduce the recreational opportunities for a wilderness experience for some 

anglers because there would be fewer lakes available for fishing. 

Following removal of reproducing, self-sustaining populations of trout, restocking of some lakes with 

nonreproducing populations of trout, as proposed in two alternatives, would support the recreational and 

historical use purposes of the wilderness area while minimizing impacts to biological integrity. 
A PPENDIXES

294 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Step 1 Decision: Is it necessary to take action? 

 Yes: 6 No: 6 Not Applicable: 

Explain: 

Fish Removal: Yes. Given the well-documented impacts of nonnative, reproducing populations of fish 

on native organisms, the NPS believes it is imperative to remove, wherever feasible, populations of 

reproducing trout from naturally fishless lakes. The draft plan/EIS concludes that if reproducing 

populations remained in the lakes, over time there would be major adverse impacts to native biota. 

Therefore, removal of reproducing, self sustaining populations of fish is required for administration of the 

area as wilderness in spite of the short term impacts to the wilderness experience that will occur during 

fish removal. 

Fish Stocking: No. Stocking non reproducing trout into the high mountain lakes would continue to 

benefit the recreational wilderness experience for certain wilderness anglers. Stocking, however, would 

adversely impact the wilderness experience for other wilderness users. Fish stocking would also adversely 

impact, to varying degrees, the scientific, conservation and natural purposes of wilderness. If stocking 

were discontinued, opportunities for fishing in the high mountain lakes would be severely limited. 

However, various opportunities for sport fishing would remain in the rivers and streams, and other types 

of primitive and unconfined forms of recreation would still exist in the Steven T. Mather Wilderness. 

Therefore, the NPS believes that fish stocking is not required for administration of the area as wilderness. 

If action is necessary, proceed to Step 2 to determine the minimum tool for action. 
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 295

Step 2: Determine the minimum tool. 

Description of Alternative Actions 

For each alternative, describe what methods and techniques will be used, when the action will take place, 

where the action will take place, what mitigation measures are necessary, and the general effects to 

wilderness character. 

Alternative # B, C, and D 

Description: 

Fish removal methods under alternatives B, C, and D would include mechanical, natural and chemical 

methods. 

Mechanical methods would include gillnetting in combination with electrofishing and cobbling over of 

spawning grounds to break the cycle of reproduction. 

Natural methods would be a passive means of eliminating fish by stopping stocking. 

Chemical methods would be limited to application of the piscicide Antimycin to lakes larger than 5 acres 

in size where removal of fish using mechanical methods would probably not be feasible. 

For a complete description of methods and mitigation, see the “Alternatives” chapter of the draft 

plan/EIS. 

Effects: 

Natural methods would have a beneficial effect on wilderness character for some wilderness users 

because stocking would cease and there would be less evidence of human manipulation of wilderness. For 

those who enjoy fishing in mountain lakes, there would be a loss of fishing opportunity and this would 

have an adverse impact on their wilderness experience. 

Mechanical methods would have long-term beneficial impacts on mountain lakes by reestablishing 

historically fishless conditions. However, intensive use of gillnets and electrofishing equipment would 

also impose a variety of adverse, short-term impacts to wilderness character in limited areas of the 

wilderness. These impacts would include: 

• Periodic use of helicopters to transport heavy equipment to lakes undergoing fish removal. 

Reduced opportunities for solitude in limited areas of the wilderness due to the short-term, 

seasonal presence of crews and mechanized equipment at select lakes undergoing fish removal. 

• Some nontarget taxa would be inadvertently harmed or killed by gillnets. Although individual 

members of the population would be harmed, these adverse impacts would not be expected to 

affect the populations of nontarget taxa. 

• Mechanical methods would only be feasible for removing reproducing populations of fish from 

small, shallow lakes. They would not be effective on larger deeper lakes. 

Chemical methods would be limited to application of the piscicide antimycin in larger, deeper lakes with 

reproducing and self-sustaining populations of fish that could not be removed using mechanical methods. 
A PPENDIXES

296 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

The impacts of chemical methods would be similar to that of mechanical methods in many respects. For 

example, helicopters would be periodically needed to ferry heavy equipment to select lakes each season. 

In addition, field crews would be present at lakes undergoing treatment for several weeks at a time. 

Overall, field crews would not need to spend as much time at lakes undergoing antimycin treatment 

compared to lakes undergoing mechanical treatment, because antimycin treatment would remove fish 

more rapidly than mechanical treatment. 

Application of antimycin would require use of motorized inflatable boats and other mechanized forms of 

equipment that would not be necessary for mechanical treatment. 

Antimycin application would impact different forms of nontarget taxa compared to gillnetting. Impacts to 

nontarget taxa would be limited to those taxa most sensitive to antimycin, such as certain aquatic 

invertebrates. Nontarget taxa such as mammals and birds would not be affected by antimycin, whereas 

some individuals could be harmed or killed by gillnet entrapment. 

Application of the piscicide antimycin in wilderness waters would offend some wilderness enthusiasts 

who would not support the use of pesticides in wilderness, the objective of fish removal, or both. 

A comprehensive description of the impacts of fish removal on wilderness resources and values is 

provided in the “Environmental Consequences” chapter of the draft plan/EIS. 
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 297

Step 2 Decision: What is the Minimum Tool? 

The selected alternative is: (To be implemented prior to management action) 

Describe the rationale for selecting this alternative:

Describe any monitoring and reporting requirements: 

Please check any Wilderness Act Section 4(c) uses approved in this alternative: 

 mechanical transport  landing of aircraft 

 motorized equipment  temporary road 

 motor vehicles  structure or installation 

 motorboats 

Be sure to record and report any authorizations of Wilderness Act Section 4(c) uses according to agency 

procedures. 
A PPENDIXES

298 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Approvals Signature Name Position Date 

Prepared by: 

Recommended: 

Recommended: 

Approved by: 
Appendix K

ENVIRONMENTAL IMPACT STATEMENT 299

WASHINGTON DEPARTMENT OF FISH AND WILDLIFE 

COMMENTS ON THE MINIMUM REQUIREMENTS ANALYSIS 

The Washington Department of Fish and Wildlife (WDFW) appreciates the opportunity to work closely 

with National Park Service (NPS) staff in the development of the Draft Mountain Lakes Fishery 

Management Plan / Environmental Impact Statement (plan/EIS) for the North Cascades National Park 

Service Complex, and overall, we are generally satisfied with its technical content, and the responses to 

our technical comments and resultant revisions. The WDFW has carefully reviewed this appendix K. We 

were unable to find any mention of fish stocking in the Wilderness Act, including 4(c), where prohibited 

activities are defined. Our interpretation of the minimum requirements under the Act was that it would be 

applied to proposed prohibited activities. We now understand that it is NPS policy that requires any 

management action in wilderness administered by the NPS to undergo a Minimum Requirements 

Analysis (MRA). The WDFW expects that NPS will include additional text in their EIS to clarify this 

with citations. 

With regard to the MRA on fish stocking itself, WDFW contends that the perspective brought forth in the 

following argument leads us to conclude that some limited, biologically based stocking of 

nonreproducing trout is necessary for the administration of the Stephen T. Mather Wilderness, and the 

NPS conclusion reached in Step 1 of the MRA regarding fish stocking should be reversed. 

A fishery management program that is biologically based on limited stocking of nonreproducing trout 

would continue to provide high lakes recreational angling in park waters where fish stocking and 

wilderness angling are longstanding historical practices, while excessively reproducing fish populations in 

park high lakes are removed. Such a program would facilitate opportunities for angler education on 

conservation issues and reduce the risks of unsanctioned introductions of fish. Such a fishery management 

program has already been determined by the analyses documented in the EIS to conserve biological 

integrity of park lakes and their biota, leaving no permanent evidence of human presence and allowing 

natural processes to prevail. 

Detailed comments on sections of the Worksheets for the MRA follow: 

Section A. While there is no provision in the park’s enabling legislation or the Wilderness Act that 

explicitly allows for fish stocking, there are also no provisions prohibiting it. Fish stocking itself does not 

fall under the 10 prohibitions defined in 4(c) of the Wilderness Act. Therefore, we believe very strongly 

that all analysis of Fish Stocking per se is unnecessary and inappropriate in sections A through F of the 

Worksheets. However, we fully agree with the need for an MRA for the Fish Removal aspect of the 

fishery management plan since the use of aircraft would likely be required. Aircraft use in wilderness is 

one of the prohibited uses noted in section 4c. WDFW believes the correct response for Section A is “Not 

Applicable” for fish stocking, although we reiterate that WDFW believes the correct approach is to not 

consider fish stocking as part of the MRA. The overall effects of fish stocking are more than adequately 

treated in the body of the EIS. Further, WDFW asserts that backpack stocking methods are the minimum 

tool for administering the stocking element of the fishery management plan, and backpack stocking of 

low numbers of trout fry has a minimal to undetectable impact. 

Section D. As noted earlier, WDFW believes the MRA should not be applied to fish stocking per se. 

However, WDFW would answer “No” to this question. Too many, if not most, users of the remote, offtrail fish-bearing lakes in the wilderness fishery within the North Cascades Complex are unique, and 

suggesting “action” (stocking) in other wilderness areas is not applicable, and diminishes the value and 

importance of the North Cascades high-lake fishery. Within the Park, there are no lakes outside the 

Stephen T. Mather Wilderness that could be stocked to recreate the current opportunity, either in quality 

or quantity. WDFW, working cooperatively with NPS staff, has already greatly reduced the historic 
A PPENDIXES

300 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

extent of the stocked trout fishery in the wilderness lakes, as fully described in the body of the EIS. (For 

fish removal, the answer to this question is obviously ‘No,” and WDFW supports the removal of the 

problem fish populations.) 

Section E. WDFW recognizes that naturally barren lakes are not completely free from human 

manipulation if they harbor introduced fish, even low numbers of nonreproducing fish. However, WDFW 

has worked diligently over the past several decades and more recently with NPS technical staff to develop 

a responsible, biologically based fish stocking program that conserves biological integrity. A great deal of 

research now supports the premise that low numbers of nonreproducing fish can occupy certain lakes 

without causing significant deviations, or in some cases, even detectible changes in the structure or 

function of native high-lake ecosystems. These lakes show little evidence of human modification and are 

substantially free from the effects of modern civilization. Moreover, they still provide outstanding 

opportunities for solitude and primitive and an unconfined type of recreation, particularly a North 

Cascades wilderness fishing experience that cannot be met outside of the Park. Stocking effects are minor 

and temporary, and the periodic and dispersed nature of this fishery is unlikely to have major impacts on 

wilderness experience. Again, WDFW believes fish stocking should not be part of the MRA but is in 

agreement with the NPS analysis of the effects of fish removal on wilderness character. 

Section F. With regard to the effects of fish stocking to the public purpose of wilderness, WDFW not 

only views fish stocking as an enhancement of the North Cascades Complex high-lake fishery, but as the 

fundamental support of this long-standing historic fishery, given the fact that WDFW agrees that most of 

the excessively reproducing fish populations in park high lakes should be removed. In providing this 

fishery, WDFW also places great value on the close relationship it has developed with the backcountry 

angling community. This relationship fosters ongoing efforts to educate anglers on conservation issues 

such as bull trout, amphibians, and the importance of biological integrity to high-lakes ecology. WDFW 

believes these efforts promote conservation throughout wilderness areas and reduce the likelihood of 

unsanctioned spread of nonnative fish species in wilderness areas. While scientific opportunity to study 

fishless ecosystems may be diminished in some individual lakes, there are still many such lakes where 

these opportunities exist. Opportunities to study recovery will also emerge as a collaborative and 

successful fish removal program moves forward. Moreover, the presence of low densities of 

nonreproducing fish does provide research opportunity for the study of how this important management 

approach affects native lake biota. 

These points lead WDFW to the conclusion that fish stocking is the primary means by which this longstanding historical fishery is supported without significantly impacting other uses and, therefore, meets 

the minimum requirements for administering the Stephen T. Mather Wilderness. 

Conclusion. WDFW does not believe fish stocking is a needed, or an appropriate, part of the Minimum 

Requirements Analysis because it is not prohibited under the Wilderness Act, and the paragraph on Fish 

Stocking should be removed from the MRA. However, we clearly agree that fish removal that uses any of 

the prohibited uses or actions within wilderness (such as aircraft use) requires the MRA, and that fish 

removal should occur in the agreed-upon lakes. Since park policy requires an MRA on all proposed 

activities, then the conclusion regarding fish stocking should be that limited, biologically based stocking 

of nonreproducing trout is necessary for the administration of the Stephen T. Mather Wilderness. 

Minimum Tool. WDFW supports the use of helicopters as described in the body of the EIS to enable 

those fish removal projects requiring aircraft support. We are not aware of any other need to use any of 

the “10 Prohibited Uses” listed in section 4c of the Wilderness Act.