Purpose of

and Need

for Action
You are now in the "Purpose of and Need for Action" chapter.

Here are the topics you can read about.

I NTRODUCTION 3

P URPOSE OF AND NEED FOR ACTION 3

OBJECTIVES IN T AKING ACTION 5

P ROJECT SITE L OCATION 6

B ACKGROUND 1 0

S UMMARY OF E XISTING RESEARCH 1 5

S COPING P ROCESS AND P UBLIC P ARTICIPATION 2 4

RELATED L AWS , P OLICIES , PLANS , AND C ONSTRAINTS 30

Welcome
ENVIRONMENTAL IMPACT STATEMENT 3

The National Park 

Service (NPS) is the 

lead agency for 

development of this 

plan/EIS, and the 

Washington 

Department of Fish 

and Wildlife (WDFW) 

is a cooperating 

agency. 

INTRODUCTION 

his “Purpose of and Need for Action” chapter describes the reasons why the 

National Park Service (NPS) is taking action at this time to evaluate a range 

of alternatives and management actions for the mountain lakes fishery in the 

North Cascades National Park Service Complex (the North Cascades Complex). 

This Draft Mountain Lakes Fishery Management Plan / Environmental Impact 

Statement (plan/EIS) presents three action alternatives for managing the 

mountain lakes fishery and assesses the impacts that could result from 

continuation of the current management framework (the no-action alternative) or 

implementation of any of the three action alternatives. Upon conclusion of the 

plan/EIS and decision-making process, one of the four alternatives would 

become the “Mountain Lakes Fishery Management Plan” and guide future 

actions for a period of 15 years. 

This plan/EIS is mostly programmatic in nature, which means it provides a 

framework for taking a range of management actions. Some actions would 

require additional, more site-specific analyses before they could be implemented. 

If additional analyses were required, environmental compliance, including an 

opportunity for public comment, would be completed. 

PURPOSE OF AND NEED FOR ACTION 

The “Purpose of the Plan” section of this chapter explains what the plan/EIS is 

intended to accomplish. The “Need for Action” section explains why action is 

necessary at this time. Brief summaries of both purpose and need are presented 

here, but a great deal more information is available in the “Background” section 

of this chapter. 

P URPOSE OF THE P LAN

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

order to 

conserve native biological integrity 

provide a spectrum of recreational opportunities and visitor experiences, 

including sport fishing 

T
P URPOSE OF AND N EED FOR A CTION

4 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Biota: The combined

plant and animal life

of a particular region.

Biological integrity 

refers to “the 

capability of 

supporting and 

maintaining a 

balanced, integrated, 

adaptive community 

of organisms having a 

species composition, 

diversity, and 

functional 

organization 

comparable to that of 

the natural habitat of 

the region” (Karr and 

Dudley 1981). 

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 three NPS administrative units known as 

“North Cascades National Park Service Complex” or “the North Cascades 

Complex”). 

N EED FOR A CTION

In most NPS units, natural resources (including lakes and fish) are managed in 

accordance with the Organic Act of 1916 and NPS Management Policies, which 

allow sport fishing unless it is specifically prohibited (NPS 2001a, 4.4.3), but 

prohibit stocking in most NPS waters (see the section in this chapter titled 

“Planning Documents for North Cascades National Park Service Complex”). 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 would 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 pre-dates 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 this chapter for more 

information on the North Cascades Complex enabling legislation). 

The lakes that are the focus of this plan/EIS are the 91 mountain lakes in the 

North Cascades Complex that were once naturally fishless, evolving over 

hundreds or thousands of years without any fish, but have had some history of 

fish stocking since the late 1800s. 

Because of the differences in policies and missions between the WDFW and the 

NPS, the two agencies drafted a Memorandum of Understanding in 1985, 

followed by a Supplemental Agreement in 1988 (see appendix A) that 

established a mutually agreed to list of lakes in North Cascades National Park 

that the WDFW would stock with fish as part of its fish management program 

while further studies were being done. A long-term research study was then 

initiated to determine how continued stocking practices would affect native biota 

in mountain lakes. 

Before this research could be completed, the NPS was challenged in court by the 

North Cascades Conservation Council on several issues relating to management 

of the North Cascades Complex. As a result, the NPS entered into a 1991 

Consent Decree (see appendix A), wherein the NPS agreed to complete its 

research and then “conduct a NEPA [National Environmental Policy Act] review 

of the fish stocking of naturally fish-free lakes.” The research was completed in 

July 2002 (Liss et al. 2002) by a team that included scientists from the U.S. 

Geological Survey (USGS) - Biological Resources Division and Oregon State 

University (OSU). The research was completed in three phases; full reports of the 

findings for each of these phases are available on the NPS website at 

http://www.nps.gov/noca/pphtml/relatedlinks.html. This plan/EIS was initiated 
Introduction 

ENVIRONMENTAL IMPACT STATEMENT 5

shortly after the research was completed and is the document required in the 

1991 Consent Decree. 

OBJECTIVES IN TAKING ACTION 

Objectives are more specific statements of purpose that support the goals an 

alternative must meet, to a large degree, for this plan/EIS to be considered a 

success. Meeting objectives to a large degree is part of what makes an alternative 

“reasonable.” Objectives also support the purpose of this plan/EIS as stated in the 

“Purpose of the Plan” section above and help to resolve the need for action. 

Objectives for fishery management are grounded in the North Cascades 

Complex’s purpose, significance, and mission goals and are compatible with 

direction and guidance provided by both the General Management Plan (NPS 

1988b) and Strategic Plan (NPS 2000a) for the North Cascades Complex (see the 

section titled “Planning Documents for North Cascades National Park Service 

Complex”). This plan/EIS must also be consistent with the following mission 

statement for the North Cascades Complex, which is derived from its enabling 

legislation (PL 90-544): 

As a unit of the National Park Service, the North Cascades 

National Park Service Complex is dedicated to conserving, 

unimpaired, the natural and cultural resources and values of North 

Cascades National Park, Ross Lake National Recreation Area and 

Lake Chelan National Recreation Area for the enjoyment, 

education, and inspiration of this and future generations. We also 

share responsibility for advancing a great variety of national and 

international programs designed to extend the benefits of natural 

and cultural resource conservation and outdoor recreation. 

The following objectives were developed for this plan/EIS: 

Obtain support from interested parties and groups to implement a new 

management plan for mountain lakes within the North Cascades Complex 

should the governing agencies decide a new plan is needed. 

Advance the protection and rehabilitation of native biological integrity by 

maintaining native species abundance, viability, and sustainability. 

Provide a spectrum of recreational opportunities, including sport fishing, 

while minimizing impacts to the biological integrity of natural mountain 

lakes. 

Apply science and research in decision-making at multiple spatial scales 

that include landscape, watershed, lake cluster, and individual lakes. 

Provide to the public and interested parties full and open access to 

available information. 
P URPOSE OF AND N EED FOR A CTION

6 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

State Route 20 follows 

the Skagit River and 

Skagit River 

Hydroelectric Project 

for much of its way 

through the North 

Cascades Complex. 

PROJECT SITE LOCATION 

The 684,000-acre North Cascades Complex is located in 

the northwest part of Washington State, with its northern 

boundary forming the international border with Canada 

(see “Figure 1: Vicinity Map”). The North Cascades 

Complex is made up of three NPS administrative units: 

North Cascades National Park, Ross Lake National 

Recreation Area, and Lake Chelan National Recreation 

Area. The North Cascades Complex lies within the 

Washington counties of Whatcom, Skagit, and Chelan. The 

only drivable access is by way of scenic Washington State 

Route 20, commonly referred to as the North Cascades 

Highway, which bisects the North Cascades Complex as it 

makes its way through Ross Lake National Recreation Area, the most accessible 

part of the North Cascades Complex. State Route 20 intersects with Interstate 5 

approximately 70 miles to the west and with State Route 97 approximately 

85 miles to the east. Three reservoirs within the Ross Lake National Recreation 

Area (Ross Lake, Diablo Lake, and Gorge Lake) serve as water gateways to the 

remote areas within the North Cascades Complex. 

As shown on figure 1, many other public lands surround the North Cascades 

Complex. The Okanogan National Forest to the east includes two wilderness 

areas: the Pasayten Wilderness Area that runs along the eastern boundary of Ross 

Lake National Recreation Area and the Lake Chelan-Sawtooth Wilderness Area 

that is adjacent to the eastern boundary of the Lake Chelan National Recreation 

Area. 

The Glacier Peak Wilderness Area adjoins most of the southern boundary of 

Lake Chelan National Recreation Area and the South Unit of North Cascades 

National Park. The Glacier Peak Wilderness Area encompasses parts of the 

Wenatchee National Forest and Mount Baker-Snoqualmie National Forest. 

The Mount Baker-Snoqualmie National Forest extends along the western 

boundary of the North Cascades Complex and includes two other wilderness 

areas: the Noisy-Diobsud Wilderness (situated between North Cascades National 

Park and Baker Lake) and the Mount Baker Wilderness farther north. These two 

wilderness areas are adjacent to parts of the North Unit of North Cascades 

National Park. Fish stocking has occurred in the lakes within these National 

Forest System boundaries since the late 1800s. 

The geographic study area for this plan/EIS includes all three administrative units 

of the North Cascades Complex. However, the focus of this document is the 

91 naturally formed mountain lakes in the North Cascades Complex that have a 

history of fish presence. As noted below in the section titled “History of Fish 

Management in North Cascades Mountain Lakes,” the North Cascades Complex 

comprises a total of 245 mountain lakes. At least 154 of these lakes have always 

been, and would continue to be, fishless regardless of the alternative selected. 

Because no changes in this policy are anticipated for any of the 154 lakes, and 
Introduction 

ENVIRONMENTAL IMPACT STATEMENT 7

FIGURE 1: VICINITY 

MAP
P URPOSE OF AND N EED FOR A CTION

8 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

because they have never been part of the managed fishery at the North Cascades 

Complex, they are not addressed further in this document. Reservoirs, streams, 

and their associated beaver ponds are also not included in this plan/EIS. 

The 91 lakes include all naturally fishless mountain lakes that have documented 

stocking records, as well as those where no stocking records exist but where 

observations or harvest of fish have been documented. Documented stocking 

records are taken from the database maintained by Trail Blazers, Inc., a volunteer 

group founded in 1933 with a focus on fish stocking and surveying activities (see 

the section in this chapter titled “User Groups’ Involvement in North Cascades 

Complex Fishery Management”). The 91 lakes analyzed in this plan/EIS include 

those stocked with fish that are now reproducing and self-sustaining, lakes that 

are stocked repeatedly because they contain nonreproducing fish, and lakes that 

have been stocked in the past, but are now fishless. 

“Map 1” (contained in the envelope that accompanied this plan/EIS) shows the 

locations of the 91 lakes: 69 lakes are in the national park, 7 are in Ross Lake 

National Recreation Area, and 15 are in Lake Chelan National Recreation Area. 

Of the 69 lakes inside the national park boundary, the WDFW manages 40 under 

the terms of the 1985 Memorandum of Understanding with the NPS. The WDFW 

also manages 19 lakes in the national recreation areas—3 of those lakes are 

fishless and not actively managed. The remaining 29 lakes are not actively 

managed by either the WDFW or NPS. Of the 91 lakes, 62 currently have fish, 

and 29 are fishless (see figure 2). 
Introduction 

ENVIRONMENTAL IMPACT STATEMENT 9

FIGURE 2: MOUNTAIN 

LAKES IN THE 

NORTH 

CASCADES 

COMPLEX WITH A 

HISTORY OF 

FISH 

STOCKING

Note:

Two lakes (Silver and Pyramid) are in Research Natural Areas and subject to strict protection for their scientific values. Both lakes have a history of fish presence but are currently fishless. Silver Lake was last stocked in 1961, and 1980 surveys showed no fish remained. Pyramid Lake was last stocked in 1968, and 1999 surveys showed no fish were in the lake.
10 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Fish stocking

Thunder Lake

 in the early years.

BACKGROUND 

This section is divided into two parts—the administrative background, including 

the history of fishery management practices in the study area, and a summary of 

the scientific background, which includes major findings of the research study 

described above in the “Need for Action” section.

ADMINISTRATIVE BACKGROUND

From the time the United States established title to the Oregon Territory in 1846, 

until the 1890s, the area encompassing the North Cascades Complex was 

administered as part of the public domain. During the 1890s, Congress 

established two large forest reserves that were administered by the General Land 

Office of the Department of the Interior. Out of these reserves, Congress created 

Mount Rainier National Park in 1899, and the rest of the land was transferred to 

the administrative jurisdiction of the U.S. Forest Service, which established five 

national forests in the area. Over the years, in recognition of the outdoor 

recreation values of the area, the Mount Baker Recreation Area was established, 

and almost a million acres of wild and roadless primitive areas were set aside. In 

1963 President Kennedy ordered a review of the North Cascades region to 

determine the highest and best use of the area. The resulting report included a 

recommendation to establish a national park, which Congress acted on, thus 

creating the North Cascades Complex in 1968 (Louter 2003). 

H ISTORY OF F ISH M ANAGEMENT IN 

N ORTH C ASCADES M OUNTAIN L AKES

The North Cascades Complex contains 561 natural water bodies that include 

lakes, tarns, and ponds. Approximately 245 (44%) of these water bodies are 

considered mountain lakes because of their elevation, 

size, and depth. As noted in the “Need for Action” 

section above, the focus of this plan/EIS is on the 

91 mountain lakes that were stocked in the past or are 

currently stocked but that were once naturally fishless 

due to the lack of inlets or outlets to streams or the 

presence of impassable physical barriers (such as 

cascades) to upstream fish migration. 

Settlers began stocking North Cascades lakes in the 

late 1800s with exotic (nonnative) fish. By the 20th 

century, stocking was a routine management practice 

of the U.S. Forest Service and various counties. 

In 1933 the Washington Department of Game (currently the WDFW) assumed 

responsibility for stocking mountain lakes throughout the state in order to 

establish and maintain a recreational fishery. The department’s involvement grew 

largely out of the need to prevent haphazard stocking by individuals without 

expertise in biology. With particular emphasis on systematic assessment of fish 
Background

ENVIRONMENTAL IMPACT STATEMENT 11

species and stocking rates, the department conducted the first high-lakes fisheries 

research. Since its creation, many agencies and groups have collaborated to assist 

in managing the natural resources in the North Cascades Complex. These include 

state and federal agencies, such as the WDFW, and sport fishing groups such as 

the Washington State Hi-Lakers and Trail Blazers, Inc. (see the section titled 

“User Groups’ Involvement in North Cascades Complex Fishery Management”). 

According to Louter (2003): 

The 1960s marked an important turning point for resource 

management based upon ecological principles in national parks. 

The Park Service shifted its management direction in response to 

critics and scientific studies that claimed that the agency had too 

long managed parks for their scenic facade. Without scientific 

research to inform management decisions, the Park Service had 

manipulated nature’s paradise—such as killing predators—often 

with unintended and long-term consequences to the natural 

systems of parks. The most influential critique of the agency’s 

management of nature was the so-called Leopold Report of 1963. 

Prepared by the Advisory Board on Wildlife Management in 

National Parks, and chaired by A. Starker Leopold, son of 

ecologist Aldo Leopold, the report recommended maintaining, and 

when possible restoring, “natural park environments to the greatest 

extent possible.” On May 2, 1963, Secretary of the Interior 

Stewart L. Udall approved the board’s recommendations and 

directed that they become part of Park Service policy. 

Although Park Service policies and legislation would further 

strengthen the agency’s commitment to environmental protection, 

the Leopold Report was its first expression and thus formed the 

cornerstone of the Park Service’s management of North Cascades. 

Beginning in the late 1960s and early 1970s, the agency focused on 

ecological research and restoration as the primary elements of the 

park’s resource management program. One of its major efforts was 

the protection and restoration of the park’s fragile alpine 

ecosystems, but it also turned its attention to the question of fish 

stocking in the park’s high alpine lakes. 

Consistent with the recommendations of the Leopold Report, Sequoia Kings 

Canyon and Yosemite National Parks began phasing out trout stocking in the late 

1960s. In 1972 the NPS released its policy that stated, “No artificial stocking of 

fish species exotic to a park will occur, artificial stocking of fish or eggs may 

only be employed to reestablish a native species. Naturally barren waters will not 

be stocked with either native or exotic fish species” (Louter 2003). Limited 

stocking was continued in these park units until 1991, when an agreement was 

negotiated with the state to terminate all fish stocking in these parks (Knapp 

1996). 

When the North Cascades Complex was established in 1968, its enabling 

legislation did not define the fishing activities that would be allowed within its 
P URPOSE OF AND N EED FOR A CTION

12 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

boundaries. This has left the North Cascades Act open to interpretation. 

According to Louter (2003), 

The WDFW has noted that the legislation did more than give it the 

authority to issue hunting and fishing licenses. In earlier versions 

of the Act, Lake Chelan had been included in the national park. 

But lobbying from hunters, who did not want to see some prime 

areas closed off to them, convinced Congress to place the region 

within a recreation area. Congress also responded to concerns 

about the state’s fishery management program for Lake Chelan 

with the creation of the recreation area, for it specifically 

accommodated the fish hatchery programs in the Stehekin River 

drainage at the headwaters of the lake. The department further 

believed that because the Act granted it licensing authority for 

hunting and fishing, it recognized and thus approved of its past 

management practices in the new park. In short, it authorized the 

state game department [currently WDFW] to carry on with its fish 

stocking program (1986 memorandum [see appendix A]). 

In addition to the influence of the Leopold report, NPS Management Policies

(NPS 2001a) prohibit stocking in units of the NPS in order to protect native 

ecosystems. 

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. Both of these documents (see appendix A for copies) 

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 

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]. 

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. 

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. 
Background

ENVIRONMENTAL IMPACT STATEMENT 13

To be able to continue stocking in light of NPS policies generally prohibiting it, a 

memorandum from the NPS Director was issued in 1986 (hereinafter referred to 

as the “policy waiver”). The policy waiver states “fishing is an acceptable 

recreational activity in the park, provided it is done consistent with NPS 

Management Policies and with provisions of the General Management Plan, and 

other approved plans” (see appendix A). The policy waiver only allowed 

stocking with fish species that are native to the national park or native to the 

ecological region. Any species native only to the ecological region were to be 

restricted so that the species did not become established (that is, reproducing 

populations) in natural zone waters. The waiver acknowledged long-standing 

fish-stocking practices and allowed for continued stocking in selected lakes while 

ecological research was conducted to determine the impacts of fish stocking. The 

policy waiver allowed fish stocking to continue in 17 lakes and self-sustaining 

(reproducing) fish populations to continue in 23 lakes in the park. 

The 1988 Supplemental Agreement (also known as the Fisheries Management 

Agreement) formalized these practices in the 40 lakes inside the park for 12 years 

while planned research on the effects of fish management activities could be 

completed and assessed. Any additions or deletions to the list of lakes in the park 

would be made only by mutual agreement, and the two agencies would consult 

on the number and species of fish, specific lakes, and the schedule for the lakes 

to be stocked. The agreement added the caveat that research results would be 

considered in future decisions. A long-term research study was initiated by 

Oregon State University soon after the 1988 Supplemental Agreement was 

finalized. The Supplemental Agreement between the NPS and WDFW that 

permits fish stocking in the national park was reaffirmed in February 2000 and 

again in July of 2002. The agreement expired in December 2004. Any future 

agreements between the NPS and WDFW concerning mountain lakes fishery 

management, including fish stocking in the national park, would depend on the 

outcome of this plan/EIS process. 

The lakes in the two national recreation areas were not part of the 1988 

Supplemental Agreement, and the WDFW continued to manage the fisheries in 

the Ross Lake and Lake Chelan National Recreation Areas according to 

historical practices. The management program currently in place is further 

described as “alternative A” in the “Alternatives” chapter. In 1991 the North 

Cascades Conservation Council challenged the NPS on a number of issues that 

brought about a Consent Decree between the two parties. In part, the Consent 

Decree ordered the NPS to “conduct a NEPA [National Environmental Policy 

Act] review of the fish stocking of naturally fish-free lakes within [the park] upon 

completion of ongoing research.” As noted above, this plan/EIS has been 

prepared, in part, as a result of the Consent Decree. This plan/EIS incorporates 

the results of the OSU study and other research into the impact analysis of the 

alternatives for management of the mountain lakes fishery as identified in the 

“Alternatives” chapter. 

Despite the ongoing commitment to provide for a cooperative arrangement with 

the WDFW, there is still a question of what Congress intended when it 

established the North Cascades Complex in 1968 (NPS 1968). Throughout the 

years leading up to 1968, the WDFW and Trail Blazers had stocked 75 lakes in 

the newly designated North Cascades Complex. During public hearings on the 
P URPOSE OF AND N EED FOR A CTION

14 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Members of the 

Trail Blazers stocking

Doug’s Tarn.

bill to establish the North Cascades Complex, NPS Director George Hartzog 

made statements as to whether the NPS intended to continue stocking lakes in the 

North Cascades Complex. In May 1967 he stated that within the park the NPS 

would not participate in a ‘put and take’ program, and would not concur with 

stocking lakes that historically did not have fish. Then, in July 1968, Director 

Hartzog stated, “[w]e have an active fish-[stocking] program in every single 

major park . . . [n]ow, if the stream already has its limit of fish comparable with 

its food-carrying capacity, then obviously, we do not engage in a put-and-take 

fishing program. But, we [stock] fish in practically every area that I can think of 

off the top of my head now, including all of our major parks.” Proponents of 

stocking believed they were promised that stocking would continue after the park 

was established (Trail Blazers and Hi-Lakers, S. McKean, public scoping 

comment, 2003, see the “Public Comment Summary Report” for comments 

received during the public scoping process: 

http://www.nps.gov/noca/highlakes.htm). 

Proponents of stocking also believed that the circumstances surrounding the 

creation of Lake Chelan National Recreation Area reflected the need to 

accommodate sport fishing and hunting. Although there is no specific language 

in the 1968 enabling legislation that permits stocking, proponents claim that 

continuation of stocking is implied through a reference to cooperative 

management between the NPS and the state of Washington (Louter 2003: 

http://nps.gov/noca/whitepaper.htm). While the current NPS Management 

Policies and practices prohibit stocking in areas designated as 

national parks, it allows stocking in areas designated as 

national recreation areas that have been historically stocked, 

provided the impacts of such stocking are acceptable (NPS 

2001a, 4.4.3). The NPS recognizes that stocking is a part of the 

management legacy it inherited from the U.S. Forest Service 

(Louter 2003). Given these questions, the NPS seeks, as part of 

this planning effort, clarification from Congress on the NPS 

authority to enter into future agreements regarding stocking 

fish in the North Cascades Complex. Depending on the 

congressional response, the NPS may not be able to implement 

some alternatives (see the section in the “Alternatives” chapter 

titled “Implementing the Fishery Management Plan through 

Congressional Action”). 

U SER G ROUPS ’ 

I NVOLVEMENT IN N ORTH C ASCADES 

C OMPLEX F ISHERY M ANAGEMENT

The Washington State Hi-Lakers are a diverse group of anglers “dedicated to the 

preservation of the high-lake environment and to the maintenance of a quality 

fishery that is compatible with the high lake environment” 

(http://groups.yahoo.com/group/hilakers/). The Hi-Lakers work with the WDFW 

to survey lake conditions and provide data to the department’s biologists. The 

department’s biologists, in turn, use this data to assist in managing the lakes of 

the North Cascades Complex. The Hi-Lakers’ fishing reports have also served as 
Background

ENVIRONMENTAL IMPACT STATEMENT 15

A memorial to a 

dedicated Trail Blazer. 

a data source for some of the information used to manage the mountain lakes 

fishery program in the North Cascades Complex. 

Founded in 1933, Trail Blazers, Inc. is a 55-member volunteer group 

that also works with the WDFW to assist with managing lake fisheries 

across the state of Washington. The group’s focus is on fish stocking 

and surveying activities. Over the years, the Trail Blazers have been 

involved in carrying and stocking fry, collecting data, building a lake 

and stream database, and providing funds for fish-related equipment. 

The Trail Blazers have stocking and survey records dating as far back 

as 1934. The Trail Blazers’ database has also been useful in compiling 

much of the stocking and user information used for this plan/EIS. The 

database provides information on lake and stream identity, water 

chemistry, water biology, fish observations, fish stocking, and 

recreational use. 

Another notable group that has influenced the fishery management 

program is the North Cascades Conservation Council. Formed in 1957, 

the council’s mission is to “to protect and preserve the North Cascades' 

scenic, scientific, recreational, educational, and wilderness values” 

(NCCC 2004). The group seeks to keep “government officials, 

environmental organizations, and the general public informed about issues 

affecting the Greater North Cascades Ecosystem.” The 1991 Consent Decree 

(described in the “Need for Action” section above) was the result of a 1989 

lawsuit brought on behalf of the council in the U.S. District Court, Western 

District of Washington. 

Other important milestone information related to fish stocking in the North 

Cascades Complex is contained in appendix B. 

SUMMARY OF EXISTING RESEARCH 

After the 1988 Supplemental Agreement was finalized, the NPS initiated a longterm research effort through Oregon State University to evaluate the effects of 

fish stocking on native biota in mountain lakes. Later efforts included research by 

the USGS-Biological Resources Division. A scientific peer review panel of 

subject matter experts was established to evaluate the OSU research results and 

to ensure objectivity and scientific merit. Representatives from the NPS and 

WDFW were invited to attend all review panel meetings. The phase I research 

report was completed in March 1995 (Liss et al. 1995), the phase II report was 

completed in April 1999 (Liss et al. 1999), and the third and final phase was 

completed in July 2002 (Liss et al. 2002). The full text for the three reports is 

available at 

http://www.nps.gov/noca/pphtml/relatedlinks.html. 

In addition to the results of these contracted studies, this section summarizes 

relevant research completed in the region. The way this research was used in 

formulating the alternative is described in the “Alternatives” chapter in the 

section titled “Application of Research.” 
P URPOSE OF AND N EED FOR A CTION

16 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Taxa or taxon: A 

category of 

organisms. Any of the 

groups to which 

organisms are 

assigned according to 

the principles of 

taxonomy, including 

species, genus, family, 

order, class, and 

phylum. 

Trophic Levels: The 

various positions of a 

food web that are 

occupied by specific 

organisms, from the 

lowest-level 

organisms, such as 

phytoplankton, to top 

predators, such as 

amphibians or fish. 

The OSU studies, and later the USGS studies, were aimed at gaining an 

understanding of the aquatic ecosystems in mountain lakes in the North Cascades 

Complex and determining whether, or to what extent, different fishery 

management practices had altered those ecosystems. First, the researchers studied 

the lakes—the shape and depth, temperature, surrounding vegetation, location, 

geology, and other features. They then examined the aquatic life in each lake, 

including sensitive taxa at each of the “trophic levels” of the aquatic food web. 

Phytoplankton are very small, usually single-celled floating plants that make up 

one part of the base of the aquatic food web. Zooplankton are microscopic 

floating animals that include copepods and cladocerans. Certain types of 

copepods were found to be particularly affected by fishery management practices 

and so were researched in more depth. Macroinvertebrates (such as worms, 

snails, and amphipods) are larger animals than zooplankton in a lake ecosystem 

and live on the lake bottom. The top predator in fishless lakes in the North 

Cascades Complex is usually an amphibian and most commonly the long-toed 

salamander. These vertebrate animals feed on macroinvertebrates and larger 

zooplankton which, in turn, feed on phytoplankton. (A detailed and informative 

discussion about how aquatic systems work is presented in “Introduction to Lake 

Ecology” under the “Aquatic Resources” section in the “Affected Environment” 

chapter.) Fish can also be top predators, and when they are introduced to a 

naturally fishless lake, they eat some of the same foods as salamanders, including 

macroinvertebrates and larger zooplankton. Fish also consume larval 

salamanders themselves. Long-toed salamanders occur over a large area of the 

North Cascades Complex, and they are particularly sensitive to changes in 

fishery management practices; therefore, to understand impacts to the top 

predator in lake food webs, researchers focused their efforts on the long-toed 

salamander. 

Lake Characteristics. The phase I (Liss et al. 1995) and phase II (Liss et al. 

1999) reports examined different characteristics of mountain lakes. The 

researchers found that some characteristics were different depending on whether 

the lake was on the east or west side of the hydrologic divide (Cascade Crest) of 

the North Cascades Mountains. On the west-facing side, skies were generally 

cloudier, and the climate was more maritime, with temperatures less extreme in 

both winter and summer than on the east side of the divide. Conditions on the 

east side of the crest were consistent with a semiarid continental climate—

summers were sunnier and hotter and winters colder than on the west side. A 

given vegetative type occurred at higher elevations on the east side than the west 

side; however, the date at which a given lake would normally “ice-out” or thaw 

in the spring or summer was still earlier for east-side lakes in a particular type of 

vegetation than those on the west side. Regardless of whether the lake was on the 

east or west side of the crest, both the date of ice-out and water temperature were 

related to the elevation of the lake, ice-out occurred later, and the average 

temperature was lower at lakes with higher elevations. 

The water quality of lakes was found to be associated with elevation as well. As 

elevation decreased, pH, alkalinity, conductivity, and concentrations of total 

phosphorus and total Kjeldahl nitrogen (TKN) generally increased (there were 

some exceptions). East-side high-elevation lakes had significantly higher pH and 

alkalinity levels and concentrations of TKN and phosphorus than west-side highelevation lakes. In addition to the climatic differences described above, the 
Background

ENVIRONMENTAL IMPACT STATEMENT 17

Abiotic Factors: The 

nonliving physical 

and chemical aspects 

of an organism’s 

environment. Abiotic 

refers to such factors 

as light, temperature, 

elevation, and 

topography. 

authors indicated these changes were associated with increased biomass of 

terrestrial vegetation, soil depth and maturity, dissolved substances, and nutrient 

availability (Larson and Lomnicky et al. 1999). The majority of lakes studied in 

the North Cascades Complex had very low nutrient levels. 

In terms of possible impacts to lake characteristics from fishery management 

practices, the literature indicates that removal of fish can result in increased water 

clarity, higher dissolved oxygen concentrations, reduced phosphorus cycling, and 

decreased ammonia concentrations (Hanson 1990; Sondergaard et al. 1990; 

Schindler et al. 2001). In contrast to the low-nutrient and relatively undisturbed 

conditions in mountain lakes analyzed in this plan/EIS, these prior studies were 

conducted in highly disturbed, nutrient-rich lakes containing high densities of 

fish. For example, researchers in the Sierra Nevada have demonstrated through 

modeling and paleolimnological (study of the organic and chemical history of 

lakes through analysis of bottom sediments) analyses that introduced fish in 

oligotrophic (nutrient poor) mountain lakes can nearly double the rate of 

phosphorus regeneration and exploit benthic (lake bottom) sources of phosphorus 

that would normally not be available to pelagic (open water) communities in the 

absence of fish. The increased availability of nutrients (such as phosphorus) 

made possible by stocked fish can stimulate primary productivity and 

fundamentally alter nutrient cycling (Schindler et al. 2001). The USGS research 

at the North Cascades Complex did not study the effect of fish on water quality 

or nutrient cycling. It instead focused on abiotic factors, such as characteristics of 

the drainage basin and elevation and their effects on water quality (Liss et al. 

1995). It is unknown, but considered unlikely, that similar water-quality changes 

would be associated with the presence of fish or fish removal (Drake and Naiman 

2000). 

Phytoplankton. The concentration of phytoplankton in study area lakes 

generally increased with increasing concentrations of dissolved solids, TKN, 

total phosphorus (there were exceptions to this), and temperature. The density of 

phytoplankton generally increased as lake elevation decreased. Species richness 

was positively correlated with the concentration of total phosphorus that, with the 

exception of glacially turbid lakes, increased with decreasing elevation. The form 

in which nitrogen was available to phytoplankton (for example, as either 

dissolved or TKN) in a lake was an important variable in identifying species 

differences of the phytoplankton assemblages among lakes. 

Phytoplankton surveys performed in mountain lakes in Mount Rainier National 

Park showed that, for the most part, the species of phytoplankton in individual 

lakes remained consistent from year to year (Larson and McIntire et al. 1999). 

Drake and Naiman (2000) compared fossil remains of one type of phytoplankton 

(diatom) in historically fishless lakes, lakes with stocked fish, and lakes where 

stocked fish were removed in Mount Rainier and found that in unstocked lakes, 

the array (variety and abundance of species) of diatoms had not changed 

significantly in the last 315 years. Changes had occurred in diatom arrays in lakes 

where fish were introduced and are still present today. For those lakes where the 

stocked fish had been removed, diatom arrays did not appear to have returned to 

the arrays similar to those found in fishless lakes. Changes in species arrays, 

resembling those observed in the Drake and Naiman (2000) study, have also been 

observed in other studies, such as Douglas et al. (1994). Several studies have 

Total Kjeldahl 

Nitrogen (TKN): A 

measure of ammonia 

plus all organically 

derived nitrogen, and 

in combination with 

phosphorus 

concentrations, is a 

good indicator of a 

lake’s productivity. 
P URPOSE OF AND N EED FOR A CTION

18 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

shown that removal of fish from lakes can result in decreased total numbers of 

phytoplankton (Hanson 1990; Sondergaard et al. 1990). It is difficult to quantify 

fish impact on nutrient cycling, especially in oligotrophic lentic (still or slowmoving water) systems, and the magnitude and variation of impact has not been 

fully explored (Schindler et al. 2001). 

Zooplankton. Zooplankton include a wide variety of organisms such as rotifers 

and crustacean zooplankton. Rotifers are widely distributed in the lakes of the 

North Cascades Complex and may be the dominant zooplankton under certain 

conditions; however, they are small and seldom a significant portion of the diet 

of stocked fish in mountain lakes (Dawidowicz and Gliwicz 1983). The 

crustacean zooplankton community includes cladocerans and copepods. In the 

studies performed by Oregon State University and the U.S. Geological Survey 

(Liss et al. 2002), analysis of stomach contents indicated that salamanders 

primarily consumed cladoceran zooplankton (Daphnia rosea, in particular), and 

fish preferred large copepods of the genus Diaptomus. These are referred to in 

the reports and in the remainder of this plan/EIS as “diaptomid” copepods. Both 

salamanders and fish also ate other species of zooplankton and benthic 

macroinvertebrates. 

Researchers found that crustacean zooplankton vary depending on lake 

characteristics, soils, vegetation, and elevation. The high-elevation west-side 

lakes, which on average had lower water temperatures, alkalinity, and nutrients, 

were dominated by Diaptomus kenai (D. kenai). Smaller, shallower lakes on the 

east side were populated primarily with the smaller copepod, D. tyrrelli, which 

was also found only in lakes with higher nutrient levels. D. kenai is widespread 

in lakes in the study area and is apparently able to tolerate a wide range of abiotic 

conditions. However, in lakes where the average water temperature was below 

50oF–54oF (Fahrenheit), these and all other larger copepods were virtually absent 

regardless of whether fish were present (Liss et al. 2002). Although the smaller 

D. tyrrelli rarely occurs together with large copepods (such as D. kenai) in eastside lakes, they do occur together in lower-elevation west-side lakes. In these 

cases, the density of D. tyrrelli is depressed compared to lakes where it occurs 

without D. kenai, suggesting predation by the larger copepod on D. tyrrelli (Liss 

et al. 1995). 

In lakes where abiotic conditions were favorable for large copepods (generally 

where temperatures were warmer than 54oF), densities of copepods were much 

lower where the lake also supported reproducing fish populations. Reproducing 

fish populations are believed to exert a particularly great predation pressure 

because densities of reproducing fish can be high. In addition, the population 

produces a range of age and size classes, making a wider range of prey 

vulnerable. Researchers found no significant differences in the density of large 

copepods in lakes with low fish densities (such as in many stocked lakes) and in 

fishless lakes (Liss et al. 1998). Where both deep lakes and shallow lakes had 

reproducing fish populations, deep lakes (deeper than 32 feet) supported higher 

densities of large copepods than shallow lakes. The researchers theorized that this 

is because the zooplankton are able to migrate to deep water during the day and 

avoid predation. Researchers also found D. tyrrelli to be abundant in shallow 

lakes with high fish densities where larger diaptomids were either absent or low 

in abundance. This is an example of an indirect effect of stocking or of 
Background

ENVIRONMENTAL IMPACT STATEMENT 19

Salmonid: Member 

of the family of fish 

that includes trout, 

salmon, whitefish, 

and char. 

reproducing fish populations (for instance, if the larger copepod is removed 

through predation by fish, the smaller species is able to increase its density). The 

OSU/USGS team came to several conclusions: 

Introduced fish can reduce or eliminate large, more visible diaptomid 

copepods from lakes if fish abundance is excessive. 

Impacts on large copepods vary with fish density, with the greatest effects 

occurring at high fish densities. 

Impacts on large copepods from fish introductions are greater in shallow 

lakes. 

A significant negative relationship between large diaptomid density and 

D. tyrrelli density exists when the species occur together; that is, it appears 

that larger copepods prey on the smaller D. tyrrelli. 

These effects are similar to well-known and well-documented effects in other 

regions of the world. In other studies (Anderson 1972; Northcote et al. 1978), 

stocking fish at high densities was found to reduce the abundance of larger 

zooplankton species to undetectable levels using standard sampling methods. 

Fish stocked at high densities in British Columbian lakes were found to 

selectively prey upon a large planktonic larva (Chaoborus), reducing its 

abundance (Northcote et al. 1978). Two large species of zooplankton, Diaptomus 

arcticus and Daphnia pulex, were no longer captured in zooplankton samples in 

Snowflake Lake (Banff National Park, Canada) after the establishment of high 

densities of stocked fish (Anderson 1972). Similar effects of stocked fish on large 

zooplankton species have been observed in other mountain lakes, typically under 

conditions of high fish density (Crumb 1978; Divens et al. 2001; Donald et al. 

1994; Leavitt et al. 1994). 

Also similar to the OSU/USGS research, a study of D. kenai in a mountain lake 

in the Olympic Mountains of Washington found that it coexisted in mountain 

lakes with low densities of stocked salmonids more than 20 years after the fish 

were initially stocked (WESI 1993). Other studies have documented the 

coexistence of large diaptomids with low densities of stocked salmonids 

(Hoffman and Pilliod 1999; Bahls 1990; Anderson 1972; McNaught et al. 1999). 

The indirect effect of fish predation on large copepods in increasing the density 

of smaller species of zooplankton is also known to occur in other mountain lake 

communities outside the study area (Paul and Schindler 1994; Gliwicz and 

Rowan 1984). Earlier studies (Anderson 1972; Crumb 1978; Northcote et al. 

1978) documented a shift in dominant zooplankton in mountain lakes from large 

to smaller species following the stocking of salmonids, although total 

zooplankton abundance was not affected. In mountain lakes that were 

temporarily stocked with nonreproducing salmonids, the majority of lakes 

sampled showed that populations of large zooplankton were significantly 

reduced; however, the population density increased in an apparent rebound after 

fish were gone or reduced in abundance (Nilsson and Pejler 1973; Divens 

et al. 2001). 
P URPOSE OF AND N EED FOR A CTION

20 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

Substrate: The 

nonliving material 

or base upon 

which plants or 

animals live and 

grow. 

pH: The measure 

of the alkalinity or 

acidity of a 

substance such as 

water or soil. 

Macroinvertebrates. Macroinvertebrates are an important food source for 

salamanders and fish in mountain lakes in the study area, and these vertebrate 

predators can, in turn, affect densities of macroinvertebrate prey. For example, 

one study (Reimers 1958) found that brook trout under conditions of extreme fish 

density were able to deplete mayfly and caddisfly populations in a small, highaltitude lake in the eastern Sierra Nevada in California. Fish also induce changes 

in behavior of nearshore macroinvertebrates; for example, stoneflies select darker 

substrates and change their activity patterns during the day in the presence of fish 

(Feltmate and Williams 1989; Feltmate et al. 1992). In the study area, it appears 

that vertebrate predators may affect the distribution of 3 of 15 nearshore 

macroinvertebrates: the stonefly, mayfly, and caddisfly. The larval stonefly was 

far less abundant in lakes with vertebrate predators, though the role of fish 

predation in reducing its abundance could not be determined. The mayfly was 

found almost exclusively in lakes without salamanders or fish, but salamander 

predation, not fish predation, appeared to limit its distribution. Only the caddisfly 

appeared to be limited by fish predation (Liss et al. 1995). 

In the study area, the mean number of nearshore macroinvertebrate taxa 

inhabiting a lake was directly related to maximum temperature. The higher the 

maximum temperature, which is also associated with lower elevations, the higher 

the species richness of macroinvertebrates. Water chemistry, pH in particular, 

and the type of substrate were also important. In other studies (Bell 1991; Schell 

and Kerekes 1989), the level of successful emergence in aquatic insects and 

species richness of macroinvertebrates in lakes have all been shown to be 

positively correlated with pH. Generally, taxa associated with organic substrates 

are found in lower elevation lakes and those with inorganic substrates at higher 

elevations. 

Researchers at lakes in the North Cascades Complex generally did not analyze 

the impact of fish or amphibian predators on macroinvertebrates, but other 

studies have examined responses of benthic macroinvertebrates to stocked fish 

(Divens et al. 2001). The effects were found to vary by macroinvertebrate 

species; however, most coexist with fish although their average size and 

abundance may decline (Olive 1953; Reimers 1958; Walters and Vincent 1973). 

As with zooplankton, larger macroinvertebrate species are more vulnerable, and 

higher densities of fish exert a more substantial impact on benthic 

macroinvertebrates (Bahls 1990; Reimers 1958; Hoffman and Pilliod 1999). 

Also, similar to copepods, the presence of refuge habitat (such as wood debris, 

talus, aquatic vegetation, and cobble along rocky shorelines) can substantially 

reduce the effects of fish predation on macroinvertebrates (Johnston 1973; Olive 

1953). The presence of more terrestrial insects in high-lake ecosystems helps to 

buffer the impact of non-active fish on benthic macroinvertebrates (Divens et al. 

2001) because it has been documented that fish will disproportionately favor 

terrestrial insects over benthic animals as food items (Norlin 1967). 

Amphibians. The effects of stocked fish on the native amphibians of mountain 

lakes have been studied throughout the mountain west, including Alberta, Canada 

(Graham et al. 1999; Graham and Powell 1999; Huynh et al. 2002; Fukumoto 

1995); Idaho (Pilliod and Peterson 2000; Pilliod and Peterson 2001); California 

(Jennings 1996; Knapp 1996; Knapp et al. 2001; Knapp and Matthews 1998; 

Knapp and Matthews 2000; Drost and Fellers 1996; Bradford and Tabatabai 
Background

ENVIRONMENTAL IMPACT STATEMENT 21

Species of Concern: 

A species that might 

be in need of 

concentrated 

conservation 

actions, which can 

vary depending on 

the health of the 

species’ population 

and degree and 

types of threats. 

1993); and Montana (Maxell 2000; Funk and Dunlap 1999). In Washington, 

these effects have been noted on amphibians in Olympic National Park (Adams 

et al. 2000; Bury et al. 2000) and Mount Rainier National Park (Larson and 

Hoffman 2002). Much of the available information on the effects on native biota 

from stocking fish in mountain lakes has been summarized by Divens et al. 

(2001). 

Although lakes in the study area are populated by four frog, one toad, one newt, 

and two salamander species, in this case researchers focused their efforts on 

determining the effects of fishery management practices on native vertebrates, 

specifically the long-toed salamander (Ambystoma macrodactylum), a species 

that is integral to the food web of fishless mountain lakes in the North Cascades 

Complex. Northwestern salamanders (A. gracile) also occur in some of the study 

area lakes on the slopes west of the hydrologic divide; however, they are not as 

vulnerable to predation by stocked or reproducing fish. Only long-toed 

salamanders occupy lakes on the east side. It is rare that the two salamander 

species occur together in a given area, but when they do, the long-toed 

salamander tends to occupy smaller, shallower lakes than the northwestern 

salamander. The long-toed salamander is also found in shallow pools in lake inlet 

and outlet streams that may not be accessible to fish and in small temporary 

ponds and seeps near lakes with fish. Northwestern salamanders have a variety of 

tools to defend themselves against fish predation, including nocturnal activity, 

noxious secretions, and larger larvae than long-toed salamanders (Liss et al. 

1995). These same protective devices are known to exist in Northwestern 

salamander populations in Mount Rainier National Park (Funk and Dunlap 1999; 

Bury and Adams 2000; Bury et al. 2000; Stevens-Ayers 1997; Larson and 

Hoffman 2002; Hoffman et al. 2003). 

Rough-skinned newts (Taricha granulosa) have usually been documented in the 

literature to coexist with stocked fish in mountain lakes. This is likely because 

the skin of both the larvae and adult rough-skinned newt contains a potent toxin 

(Nussbaum et al. 1983). 

The frog species in the study area include Cascades frogs (Rana cascadae), 

Columbia spotted frogs (Rana luteiventris), northern red-legged frogs (Rana 

aurora aurora), and Pacific tree frogs (Pseudacris regilla). Western toads (Bufo 

boreas) have also been documented in the North Cascades Complex. Only a few 

populations of Cascades frogs have been reported in the North Cascades 

Complex (Bury and Adams 2000; Bury et al. 2000). In other parts of 

Washington, Cascades frogs do not occur in deeper lakes and ponds containing 

fish, suggesting they are vulnerable to predation. In these same areas, the species 

was common in shallower lakes and ponds where no fish were present. A few 

populations of Columbia spotted frogs, northern red-legged frogs, western toads, 

and Pacific tree frogs have been documented in the North Cascades Complex, but 

most populations are in lower lakes and beaver pond habitats in the lower valleys 

(Bury and Adams 2000; Bury et al. 2000). Populations of these species, along 

with rough-skinned newts, appear to be rare and highly fragmented in lakes and 

ponds within the North Cascades Complex, regardless of the presence of fish 

(Bury 2002). Cascades frogs, Columbia spotted frogs, northern red-legged frogs, 

and Western toads are all federal species of concern, which is an informal 

designation that means population sizes are decreasing, and they are being 
P URPOSE OF AND N EED FOR A CTION

22 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

monitored for possible listing as threatened or endangered in the future. The 

North Cascades Complex is near the edge of the range for Cascades frogs and 

Columbia spotted frogs (Bury and Adams 2000; Bury et al. 2000), so it is often 

very difficult, or even impossible, to attribute the absence of these amphibians to 

fish presence in some of the North Cascades Complex lakes. 

The long-toed salamander is an amphibian known to be important to the ecology 

of mountain lakes in the study area and one sensitive to the presence of fish. It is 

an “indicator” species (for example, it is capable of showing early signs of 

change if fishery management practices change) and was the subject of several 

biotic research studies in the study area conducted by the OSU/USGS team. The 

larval stage of the long-toed salamander is the top vertebrate predator in highelevation fishless lakes in the North Cascades Complex and an integral 

component of the aquatic food web (Tyler et al. 2002). One abiotic factor, the 

concentration of TKN (total Kjeldahl nitrogen), appears to be important in 

determining the density of long-toed salamanders in fishless lakes in the study 

area (Liss et al. 1995; Liss et al. 1998; Tyler et al. 2002). TKN concentration is a 

measure of ammonia plus all organically derived nitrogen, and in combination 

with phosphorus concentrations, is a good indicator of a lake’s productivity or 

the amount of phytoplankton. Where phytoplankton densities are higher, 

cladoceran zooplankton, which are a primary prey source for long-toed 

salamanders (and the salamanders themselves), are also more abundant. 

The density of long-toed salamanders in lakes where abiotic conditions could 

support them appears directly related to the fish population. As noted above, 

reproducing populations of fish in study area lakes tended to be denser than 

stocked (nonreproducing) populations, and they also have a wider variety of size 

and age classes, with the capacity to exert a more sustained and broad-ranging 

predation pressure on salamander larvae. Data collected from a sample of lakes 

in the study area showed the average density of long-toed salamanders in fishless 

lakes where TKN levels (0.045 mg/L [milligrams per liter] or higher) would 

sustain them is about 24 per 328 feet of shoreline. The average density of longtoed salamanders for all fishless lakes studied in the North Cascades Complex 

regardless of TKN levels is 13.2 per 328 feet of shoreline (Tyler et al. 1998a, 

1998b). The average density of salamanders in study area lakes with 

nonreproducing fish is 3.47 per 328 feet of shoreline, and for lakes with 

reproducing fish, it is 0.1310 per 328 feet of shoreline. Researchers also found 

more larval salamanders under woody debris or rocks or engaging in other 

“hiding” behaviors when these refuges were available and fish were present 

(Tyler et al. 2002). 

The OSU/USGS team also compared the density of long-toed salamanders in 

fishless lakes, lakes with reproducing populations of fish, and lakes with 

nonreproducing populations of fish that had high, medium, or low concentrations 

of TKN. They found no difference in the density of salamanders when TKN 

levels were low (less than 0.045 mg/L), which is probably because salamanders 

require a certain TKN concentration before they can occupy a habitat. At 

medium levels of TKN (between 0.055 mg/L and 0.09 mg/L), they did find a 

significant difference in the density of long-toed salamanders in fishless lakes 

compared to those lakes with reproducing populations, but not between fishless 

lakes and those with nonreproducing populations of fish (normally fewer fish). In 
Background

ENVIRONMENTAL IMPACT STATEMENT 23

Metapopulation:

Geographically 

separate populations 

of the same species 

that are connected 

by infrequent, but 

critical, 

interbreeding. 

lakes where TKN levels were high (above 0.09 mg/L), however, researchers 

found the density of salamanders at fishless lakes compared to those with 

nonreproducing populations of fish to be significantly different (Liss et al. 1998; 

Tyler et al. 2002). One way to interpret this information is to say that lakes with 

very high TKN levels can support very high densities of long-toed salamanders. 

When even low levels of fish are introduced into these lakes, they can reduce 

these salamander densities enough that it is statistically noticeable. 

Researchers also noted that these denser or larger populations of salamanders 

may be particularly important in the study area because they are less vulnerable 

to extinction from unpredictable events and can serve as important sources of 

colonists to reestablish extinct local populations (Tyler et al. 2002). These core 

populations and the satellite colonies that draw from them are called 

metapopulations. 

Although studies of long-toed salamanders and stocked fish in other areas in the 

region were not as complex, they did support the conclusions reached by the 

OSU/USGS team that fish can affect the density of salamander populations. For 

example, surveys in Olympic National Park found few or no long-toed 

salamanders in lakes containing fish, but many populations in shallow ponds and 

lakes without fish (Bury and Adams 2000; Bury et al. 2000; Adams et al. 2000). 

The authors, as did researchers in the study area, concluded that long-toed 

salamanders may be able to regionally coexist with fish by using temporary 

wetlands and other fishless habitat as breeding sites (Bury and Adams 2000; 

Bury et al. 2000). 

Overall, the OSU/USGS team concluded that lakes with relatively high TKN 

concentrations (about 0.55 mg/L or greater), and those with warmer temperatures 

(greater than about 54oF), were favored by native biota such as phytoplankton, 

large copepods, and long-toed salamanders. The aquatic life in these “more 

productive” lakes could therefore be at highest risk of impact from high densities 

of reproducing fish and may benefit most from fish removal. For additional 

information on the OSU/USGS research, see the section titled “Application of 

Research” in the “Alternatives” chapter. 
24 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

SCOPING PROCESS AND 

PUBLIC PARTICIPATION 

Public scoping began on January 16, 2003, with the publication of a notice of 

intent in the Federal Register. Four public scoping meetings were held in March 

of 2003 in these Washington State communities: Sedro-Woolley, March 18; 

Wenatchee, March 20; Bellevue, March 25; and Seattle, March 27. 

Approximately 72 people attended the four meetings, and 190 comments were 

received. In response to public input and issues expressed during the scoping 

process, the interdisciplinary planning team reworked the preliminary 

alternatives to those analyzed in this plan/EIS. 

ISSUES AND IMPACT TOPICS 

Issues are problems, opportunities, and concerns regarding the current and 

potential future management concepts for managing aquatic resources, impacts of 

anglers, and sport-fishing opportunities in the 91 mountain lakes that are included 

in this plan/EIS. The issues were identified by the NPS, WDFW, other agencies, 

and the public throughout the scoping process. The impact topics are a more 

refined set of concerns that were analyzed for each of the management 

alternatives. The impact topics were derived from issues, and in the 

“Environmental Consequences” chapter, the impact topics were used to examine 

the extent to which a problem would be made better or worse by the actions of a 

particular alternative. A summary of the agency and public scoping activities is 

available in the “Consultation and Coordination” chapter. 

A QUATIC O RGANISMS

As described above in the “Summary of Existing Research” section, impacts on 

aquatic organisms in a lake food web take the form of impacts on individual 

components of each trophic level. Phytoplankton, zooplankton, 

macroinvertebrates, and fish are all components of the food web (for an 

informative description of the food web, see the “Affected Environment” 

chapter). The specific problems that might occur from fishery management 

practices are described in the following paragraphs: 

Plankton. Under some alternatives, certain lakes may continue to be stocked or 

would continue to host reproducing fish. Other alternatives may involve 

removing fish. Fish, especially dense reproducing populations, consume 

zooplankton and may reduce the numbers, and possibly the presence, of some 

planktonic species in lakes. Waste products from fish may change the nutrient 

balance of a lake, which may create a favorable condition for some organisms, 

causing increases in their numbers. As noted above in the “Summary of Existing 

Research” section, fish may feed on larger zooplankton, which can in turn allow 

smaller herbivorous zooplankton to flourish with resulting impacts on 

phytoplankton and lake productivity and chemistry. The presence of reproducing 

fish, therefore, could result in a change in the abundance of various organisms 
 Scoping Process and Public Participation

ENVIRONMENTAL IMPACT STATEMENT 25

Natural Variation: 

The changes that 

occur naturally in an 

ecosystem (includes 

physical 

characteristics, 

plants, and animals) 

over time without 

human disturbance. 

and a change in the food web as to which organisms are dominant. Because many 

other factors affect the numbers and interactions of organisms, the change caused 

by fish may be outside the range of natural variation over time within the lake or 

in similar lakes. These effects may be notable among planktonic organisms. 

Macroinvertebrates. Macroinvertebrates (such as aquatic insects, worms, and 

snails) consume phytoplankton and zooplankton, as well as periphyton 

(microscopic algae growing on a lake substrate such as rocks or sediment or on 

larger plant surfaces), detritus (dead plant and animal material that drifts to the 

bottom of a lake if it is not consumed), and aquatic plants. Macroinvertebrates 

are eaten by top predators (including salamanders and fish) in a lake system. 

Fishery management practices, especially those resulting in high densities of fish 

over a long period of time, can reduce or eliminate some species of 

macroinvertebrates, with resulting impacts on salamanders, plankton, detritus, 

and nutrient concentrations and on the fish population itself. In addition to these 

generic effects on aquatic food webs, there is a particular interest in a blind 

amphipod that is found in two mountain lakes in the North Cascades Complex. 

Although this amphipod could be unique and rare in the North Cascades 

Complex, neither the U.S. Fish and Wildlife Service nor the WDFW has plans to 

designate or list this species. 

Amphibians. As noted above, salamanders are the natural top vertebrate predator 

in many of the mountain lakes in the study area. When these lakes are stocked 

with fish, the number of salamanders drops, presumably because fish eat 

salamander larvae. Long-toed salamanders, which historically occupied several 

naturally fishless lakes on the east side of the study area and some lakes on the 

west side, are particularly vulnerable to predation from stocked fish because they 

do not have the variety of tools (such as noxious secretions or larger larvae) to 

defend themselves as do Northwestern salamanders. When salamanders are 

eliminated or greatly reduced by fish, the aquatic food web is also changed. For 

example, the type of zooplankton that salamanders normally consume would 

increase, especially compared to the type of zooplankton that fish consume. 

Fish. Stocked fish also can affect native fish species. Hatchery-raised fish of 

most species are genetically different and usually weaker and less able to survive 

harsh environmental conditions than native species. If fish escape from lakes into 

streams that are occupied by native fish of the same species, interbreeding may 

adversely affect the adaptive characteristics of the native population. 

Interbreeding can also occur between some fish species (brook and bull trout, for 

example), eliminating the purity of a native fish species, subspecies, or 

evolutionarily significant unit of fish. In the extreme, this could result in the 

localized elimination of that species or subspecies in a lake, park, or region. 

Escaping fish may also prey on native fish species and compete with native fish 

for food or habitat. 

O THER W ILDLIFE

Fish-eating (piscivorous) wildlife have benefited from stocked fish at a number 

of lakes in the North Cascades Complex. Mergansers (Lophodytes cucullatus, 

Mergus merganser, and M. serrator), ospreys (Pandion haliaetus), bald eagles 
P URPOSE OF AND N EED FOR A CTION

26 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

(Haliaeetus leucocephalus), belted kingfishers (Ceryle alcyon), common loons 

(Gavia immer), and river otters (Lutra canadensis) have been observed at 

mountain lakes. Also, if there is an opportunity, carnivores such as black bears 

(Euarctos americanus), Cascade red foxes (Vulpes fulva cascadensis), wolves 

(Canis lupus), raccoons (Procyon lotor), mink (Mustela vison), and coyotes 

(Canis latrans) will feed on spawning fish in shallow tributary streams in the 

North Cascades Complex, but they do not depend on stocked fish as a primary 

food source. If fish are removed, or the density decreased, individuals of these 

species will either find alternative food sources or relocate to another habitat. In 

the extreme, if habitat is not available, individuals may be eliminated. 

Anglers and other recreationists, as well as stocking or fish removal activities, 

may temporarily disturb wildlife through the presence of humans and noise. 

S PECIAL S TATUS S PECIES

Plants. No plants with formal federal special status would be affected by 

management actions, but several species with state special status or considered 

sensitive or rare do grow in the study area and may be inadvertently trampled by 

recreationists, including anglers. 

Fish. The genetic integrity and ability to reproduce in bull trout may be affected 

if stocked brook trout escape from lakes and move to downstream drainages 

occupied by bull trout. It is also possible that stocked fish migrating from lakes to 

downstream drainages containing Chinook or Coho salmon might compete with 

and adversely affect these species. Westslope cutthroat trout are native to stream 

basins on the east side of the Cascade Crest where they have been replaced or 

adversely affected through competition and hybridization with stocked rainbow 

trout dispersing downstream. 

Amphibians. Cascades frogs, Columbia spotted frogs, and northern red-legged 

frogs are species that occupy lake habitat and may be subject to predation by fish. 

Although tailed frogs and western toads also occupy habitat in the study area, 

either they do not occupy the same habitat as stocked fish, or they are not subject 

to predation by trout. 

Other Vertebrates. Noise from fish stocking or treatment activities to remove 

fish may result in disturbance or displacement of individuals from several federal 

species with special status. These include American peregrine falcon, California 

wolverine, Canada lynx, gray wolf, grizzly bear, Pacific fisher, marbled murrelet, 

Northern spotted owl, and Yuma myotis (bat). Bald eagles and Harlequin ducks 

may experience some changes to their food base (fish for eagles, aquatic 

invertebrates for ducks) from management decisions. 

V EGETATION

Shoreline vegetation around lakes (riparian zones) may be sensitive to trampling 

by recreationists, and in particular, those attempting to fish, hike, or ride horses 

around the lakeshore. Vegetation can also be trampled or lost through fishery 
 Scoping Process and Public Participation

ENVIRONMENTAL IMPACT STATEMENT 27

Social Trails: These 

trails are not part of 

the formal network 

of managed trails; 

rather, they are 

informal routes that 

access a variety of 

backcountry 

destinations and 

create visible 

patterns of human 

use. 

management actions, the creation of social trails, or by cross-country travel to 

reach more remote lakes. 

In addition to the direct loss of vegetation, trampling can result in changes to soil 

such as compaction, erosion, and sedimentation. These changes in habitat can 

keep vegetation from regrowing, particularly in more severe environments (such 

as the alpine zone) where natural recovery can be quite slow. Erosion and 

sedimentation can cause increases in turbidity or concentrations of organic matter 

and nutrients in a naturally nutrient-poor lake environment. 

C ULTURAL R ESOURCES

The areas surrounding or in the vicinity of many lakes in the study area have not 

been surveyed, but because prehistoric cultures are known to have occupied the 

areas, they could contain buried archeological resources or historic resources. 

The use of these areas, especially lakeshores, by anglers, campers, and other 

recreationists can remove vegetation, increase soil erosion, and increase the 

chance of exposing these resources to weathering, theft, or vandalism. 

V ISITOR U SE AND E XPERIENCE

Recreational Use. Changes in the fishery management program could disrupt 

anglers who may have been fishing at certain lakes for several years, or even 

several generations. Changes in the fishery management program could also 

affect non-anglers. 

Social Values. Stocking fish in remote lakes, most of which are in wilderness, is 

a practice favored by some and considered undesirable and inappropriate by 

others. Anglers may have a more utilitarian approach to stocking, whereas 

conservation groups and conservationists are associated with naturalistic, 

ecology-based, or social values. While many anglers are also conservationists, 

there is a distinction between those who value the stocking of lakes for their 

enjoyment in contrast to those who value the conservation and protection of 

natural processes. 

Wilderness Values. Approximately 93% of the North Cascades Complex lies 

within designated wilderness. Wilderness extends beyond the border of the North 

Cascades Complex, encompassing a region of designated wilderness that exceeds 

2 million acres. This figure does not include much of the wild, remote Canadian 

land that borders the park. Some conservation groups and conservationists 

particularly object to stocking because it is an unnatural practice involving 

human manipulation of an ecosystem in a national park and a wilderness area. 

Trails, trampling of vegetation around a lakeshore, or occasional noise associated 

with stocking practices may be particularly offensive as evidence of human 

activity in violation of the wilderness values of a primitive and natural 

experience. 
P URPOSE OF AND N EED FOR A CTION

28 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

H UMAN H EALTH

Chemicals may be the only feasible way to remove stocked or reproducing fish 

from some larger, naturally fishless lakes. The NPS proposes to use antimycin to 

remove fish (antimycin has limited impacts on nontarget species). The required 

dosage of antimycin would be very small, and the only pathway for human 

exposure would be through consumption of treated fish, which is unlikely. 

Nonetheless, there are public concerns regarding human exposure to antimycin 

through the consumption of treated fish. 

Research has shown that fish stocked in these remote high-elevation lakes have 

been exposed to methyl-mercury and persistent organic pollutants (POPs) 

deposited from the atmosphere. There is potential for human consumption of 

methyl-mercury and POP-contaminated fish and, therefore, some level of 

concern for human exposure to these chemicals through fish consumption. 

S OCIOECONOMIC R ESOURCES

Some businesses in the region may directly depend on anglers purchasing 

equipment, food, lodging, and guide services. Changes in the fishery 

management program could reduce the number of anglers who fish in the North 

Cascades Complex, thus reducing both direct and indirect economic benefits 

associated with them. 

N ORTH C ASCADES C OMPLEX 

M ANAGEMENT AND O PERATION

Changes in the fishery management program would require NPS involvement to 

carry out management actions such as monitoring, lake treatments, and 

restocking. Monitoring and management by NPS and WDFW, in some cases, 

would require extensive effort and staffing, with resulting changes to the 

agencies’ budgets. 

In the past, lakes have been stocked without approval from the NPS and/or 

WDFW, and in some instances, lakes have been illegally stocked following 

costly fish removal efforts (for example, Tipsoo Lake at Mount Rainier National 

Park). In the future, unsanctioned stocking could undo costly fish removal 

efforts, significantly undermine fishery management activities, and cause a 

variety of unacceptable ecological impacts. 
 Scoping Process and Public Participation

ENVIRONMENTAL IMPACT STATEMENT 29

ISSUES DISMISSED 

FROM FURTHER CONSIDERATION 

M INORITY AND 

L O W - I NCOME P OPULATIONS 

( E NVIRONMENTAL J USTICE ) 

Executive Order 12898, Federal Actions to Address Environmental Justice in 

Minority Populations and Low-Income Populations, directs federal agencies to 

address environmental and human health conditions in minority and low-income 

communities so as to avoid the disproportionate placement of any adverse effects 

from federal policies and actions on these populations. This topic is dismissed 

from further consideration for the following reasons: 

Visitors to the North Cascades Complex are not disproportionately 

minority or low-income. 

Minority or low-income populations would not be disproportionately 

affected by changes in fishery management. 

F LOODPLAINS

Management actions for fish would have no effect on floodplains. 

S PECIAL S TATUS S PECIES

Although many wildlife and plant species that are listed as threatened, 

endangered, or otherwise of special concern do occur in the North Cascades 

Complex, not all of them occur in habitat included in the study area. The full list 

of species that occur in the region is included in appendix C. Several special 

status species in the study area are being analyzed as part of this plan/EIS (refer 

to the “Issues and Impact Topics” section in this chapter). 

V ISITOR S AFETY

No impacts on visitor safety or to those park operations that maintain visitor 

safety, such as search and rescue, are expected to occur from changes in the 

fishery management program. 

P RIME AND U NIQUE 

A GRICULTURAL L ANDS

No prime or unique farmlands exist in the North Cascades Complex, and no 

actions would affect agricultural soils. 
30 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

RELATED LAWS, 

 POLICIES, PLANS, 

AND CONSTRAINTS 

The following laws, policies, and plans by the NPS, WDFW, or agencies with 

neighboring land or relevant management authority are described in this section 

to show the constraints this plan/EIS must operate under and the goals and 

policies that it must meet. These goals and constraints are summarized in the 

beginning of this chapter but described in more depth in the following sections. 

GUIDING LAWS AND POLICIES 

NPS O RGANIC A CT OF 1916 

By enacting the NPS Organic Act of 1916, Congress directed the 

U.S. Department of the Interior and the NPS to manage units of the national park 

system “to conserve the scenery and the natural and historic objects and the 

wildlife therein and to provide for the enjoyment of future generations” 

(16 United States Code [USC] 1). The Redwood National Park Expansion Act of 

1978 reiterates this mandate by stating that the NPS must conduct its actions in a 

manner that will ensure no “derogation of the values and purposes for which 

these various areas have been established, except as may have been or shall be 

directly and specifically provided by Congress” (16 USC 1a-1). 

Despite these mandates, the Organic Act and its amendments afford the NPS 

latitude when making resource decisions. By these acts, Congress “empowered 

[the NPS] with the authority to determine what uses of park resources are proper 

and what proportion of the parks resources are available for each use” (Bicycle 

Trails Council of Marin v. Babbitt, 82 F.3d 1445, 1453 [9th Cir. 1996]). 

Yet, courts have consistently interpreted the Organic Act and its amendments to 

elevate resource conservation above visitor recreation. Michigan United 

Conservation Clubs v. Lujan, 949 F.2d 202, 206 (6th Cir. 1991) states, “Congress 

placed specific emphasis on conservation.” The National Rifle Association of 

America v. Potter, 628 F. Supp. 903, 909 (D.D.C. 1986) states, “In the Organic 

Act Congress speaks of but a single purpose, namely, conservation.” The NPS 

Management Policies (NPS 2001a) also recognize that resource conservation 

takes precedence over visitor recreation. The policy dictates, “when there is a 

conflict between conserving resources and values and providing for enjoyment of 

them, conservation is to be predominant.” 

Because conservation remains predominant, the NPS seeks to avoid or minimize 

adverse impacts on park resources and values; however, the NPS has discretion 

to allow negative impacts when necessary to fulfill park purposes (NPS 2001a, 

1.4.3). 
Related Laws, Policies, Plans, and Constraints 

ENVIRONMENTAL IMPACT STATEMENT 31

While some actions and activities cause impacts, the NPS cannot allow an 

adverse impact that constitutes resource impairment (NPS 2001a, 1.4.3). The 

Organic Act prohibits actions that impair park resources unless a law directly and 

specifically allows for the acts (16 USC 1a-1). An action constitutes an 

impairment when its impacts “harm the integrity of park resources or values, 

including the opportunities that otherwise would be present for the enjoyment of 

those resources or values” (NPS 2001a, 1.4.4). To determine impairment, the 

NPS must evaluate “the particular resources and values that would be affected, 

the severity, duration, and timing of the impact, the direct and indirect effects of 

the impact, and the cumulative effects of the impact in question and other 

impacts” (NPS 2001a, 1.4.4). This plan/EIS, therefore, assesses the effects of the 

management alternatives on park resources and values and determines if these 

effects would cause impairment. 

NPS Management Policies require an analysis of potential effects to determine 

whether or not actions would impair park resources (NPS 2001a). The 

fundamental purpose of the national park system is to conserve park resources 

and values for the use and enjoyment of future generations. NPS managers have 

the discretion to allow impacts on park resources and values when necessary and 

appropriate to fulfill the purposes of a park, as long as the impact does not 

constitute impairment of the affected resources and values. That discretion to 

allow certain impacts within the park is limited by the statutory requirement that 

the NPS must leave park resources and values unimpaired, unless a particular law 

directly and specifically provides otherwise. The prohibited impairment is an 

impact that, in the professional judgment of the responsible manager, would 

harm the integrity of park resources or values. An impact on any park resource or 

value may constitute an impairment, but an impact would be more likely to 

constitute an impairment to the extent that it has a major adverse effect on a 

resource or value whose conservation is 

necessary to fulfill specific purposes identified in the establishing 

legislation or proclamation of the park 

key to the natural or cultural integrity of the park 

identified as a goal in the park’s general management plan or other relevant 

NPS planning documents 

NPS M ANAGEMENT P OLICIES (2001) 

Several sections from the NPS Management Policies (NPS 2001a) are relevant to 

fishery management in the North Cascades Complex, as described below. 

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) 
P URPOSE OF AND NEED FOR A CTION

32 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

re-establish 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). 

As noted above, 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 Code of Federal Regulations (CFR) 2.3, which states in part, “fishing 

shall be in accordance with the laws and regulation of the State . . . 

Non-conflicting 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 (NPS 2001a, 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). Because stocking in the North Cascades Complex 

has not met all of these conditions, a policy waiver from the director of the NPS 

has been required to continue stocking (see the “History of Fish Management in 

North Cascades Mountain Lakes” section in this chapter). For more information, 

see “Appendix D: Related Regulations, Policies, Laws, and Legislation.” 
Related Laws, Policies, Plans, and Constraints 

ENVIRONMENTAL IMPACT STATEMENT 33

D IRECTOR ’ S O RDER 12: 

C ONSERVATION P LANNING , 

E NVIRONMENTAL I MPACT A NALYSIS , AND 

D ECISION M AKING AND H ANDBOOK

NPS Director’s Order 12 and Handbook (NPS 2001b) lay the groundwork for 

how the NPS complies with the National Environmental Policy Act (NEPA). 

Director’s Order 12 and Handbook set forth a planning process for incorporating 

scientific and technical information and establishing a solid administrative record 

for NPS projects. 

NPS Director’s Order 12 requires that impacts on park resources be analyzed in 

terms of their context, duration, and intensity. It is crucial for the public and 

decision makers to understand the implications of those impacts in the short and 

long term, cumulatively, and within context, based on an understanding and 

interpretation by resource professionals and specialists. Director’s Order 12 also 

requires that an analysis of impairment of park resources and values be made as 

part of the NEPA document. 

N ORTH C ASCADES N ATIONAL 

P ARK S ERVICE C OMPLEX E NABLING 

L EGISLATION ( P UBLIC L AW 90-544) 

Each NPS unit is guided by the Organic Act, NPS Management Policies, the 

National Environmental Policy Act, and other laws and policies, but each unit 

also has more specific guidance provided by its own enabling legislation; 

statements of mission, purpose, and significance; and broad planning documents 

such as a general management plan and strategic plan. These documents, and 

how they relate to the North Cascades Complex, are summarized in the following 

sections. 

The North Cascades National Park was established in 1968 by an act of Congress 

(PL 90-544) “in order to preserve for the benefit, use, and inspiration of present 

and future generations certain majestic mountain scenery, snowfields, glaciers, 

alpine meadows, and other unique natural features in the North Cascade 

Mountains of the State of Washington” (82 Stat. 926). 

The Ross Lake National Recreation Area was created “in order to provide for the 

public outdoor recreation use and enjoyment of portions of the Skagit River and 

Ross, Diablo, and Gorge Lakes, together with the surrounding lands, and for the 

conservation of the scenic, scientific, historic, and other values contributing to 

public enjoyment of such lands and waters” (82 Stat. 927). 

The Lake Chelan National Recreation Area was created “in order to provide for 

the public outdoor recreation use and enjoyment of portions of the Stehekin River 

and Lake Chelan, together with the surrounding lands, and for the conservation 

of the scenic, scientific, historic, and other values contributing to public 

enjoyment of such lands and waters.” 
P URPOSE OF AND NEED FOR A CTION

34 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

The following key administrative provisions of the 1968 legislation related to this 

current planning effort are: 

The Secretary of the Interior shall administer the recreation areas 

in a manner which in his judgment will best provide for (1) public 

outdoor recreation benefits, (2) conservation of scenic, scientific, 

historic, and other values contributing to public enjoyment, and 

(3) such management, utilization, and disposal of renewable 

natural resources and the continuation of such existing uses and 

developments as will promote or are compatible with, or do not 

significantly impair, public recreation and conservation of the 

scenic, scientific, historic, or other values contributing to public 

enjoyment. 

The Secretary shall permit hunting and fishing on lands and waters 

under his jurisdiction within the boundaries of the recreation areas 

in accordance with applicable laws of the United States and of the 

State of Washington, except that the Secretary may designate 

zones where, and establish periods when, no hunting or fishing 

shall be permitted for reasons of public safety, administration, fish 

and wildlife management, or public use and enjoyment. Except in 

emergencies, any regulations of the Secretary pursuant to this 

section shall be put into effect only after consultation with the 

Department of Game [now the WDFW] of the State of 

Washington. 

P URPOSE AND S IGNIFICANCE 

OF N ORTH C ASCADES 

N ATIONAL P ARK S ERVICE C OMPLEX

The purpose and significance of the North Cascades Complex comes from its 

enabling legislation and NPS Management Policies. The North Cascades 

Complex’s enabling legislation, mission, and its purpose and significance 

provide a framework for addressing mountain lakes fishery management within 

the North Cascades Complex. The purpose, need, objectives, and range of 

alternatives presented in this plan/EIS are grounded in the North Cascades 

Complex’s purpose and mission. 

The mission statement of the North Cascades Complex is that it “is dedicated to 

conserving, unimpaired, the natural and cultural resources and values of North 

Cascades National Park, Ross Lake National Recreation Area and Lake Chelan 

National Recreation Area for the enjoyment, education, and inspiration of this 

and future generations. The North Cascades Complex also shares responsibility 

for advancing a great variety of national and international programs designed to 

extend the benefits of natural and cultural resource conservation and outdoor 

recreation.” 
Related Laws, Policies, Plans, and Constraints 

ENVIRONMENTAL IMPACT STATEMENT 35

“To preserve for the benefit, use, and inspiration of present and future generations certain majestic 

mountain scenery, snowfields, glaciers, alpine meadows, and other unique natural features, biological 

processes, and cultural resources in the North Cascades” (Strategic Plan for North Cascades National 

Park Service Complex). 
P URPOSE OF AND NEED FOR A CTION

36 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

The purpose of the North Cascades Complex as stated in the Strategic Plan (NPS 

2000a) is as follows: 

To preserve for the benefit, use, and inspiration of present and future 

generations certain majestic mountain scenery, snowfields, glaciers, alpine 

meadows, and other unique natural features, biological processes, and 

cultural resources in the North Cascades. 

To provide outdoor recreation use and enjoyment for the public, and for the 

conservation of the scenic, scientific, historic, and other values contributing 

to public enjoyment within Ross Lake and Lake Chelan National 

Recreation Areas. 

To preserve and protect the lands legislatively designated as the Stephen T. 

Mather Wilderness for use and enjoyment of the public in a manner that 

will leave them unimpaired for future use and enjoyment as wilderness. 

The significance of the North Cascades Complex as stated in the Strategic Plan

(NPS 2000a) is as follows: 

The North Cascades Complex contains more glaciers than any other 

national park in the United States outside Alaska. The North Cascades 

ecosystem has over half the glaciers in the lower 48 states. These glaciers 

are an important source of water for salmon, other wildlife, plants, and 

people in the Puget Sound region. 

The 9,000-plus feet of vertical relief, and the great contrast between 

climates east and west of the Cascade Crest, provide habitat for one of the 

greatest diversities in North America and for varied fauna including rare 

and sensitive species. 

The variety of waters (lakes and rivers) and topography provides a large 

and expanding nearby population with a wide array of recreational 

opportunities, from boating and camping to climbing and backpacking. 

The North Cascades Complex, which adjoins public lands preserved in 

Canada, is the core of one of the largest protected wild areas in the United 

States, a substantial portion of it is designated Wilderness. 

The North Cascades Complex contains structures or sites that are on the 

National Register of Historic Places and others that are eligible for listing 

on the National Register, 3 historic districts, and over 250 archeological 

sites. The North Cascades Complex was once home to at least four tribes 

whose descendants now live nearby and includes, within its boundaries, 

three contemporary communities. 
Related Laws, Policies, Plans, and Constraints 

ENVIRONMENTAL IMPACT STATEMENT 37

PLANNING DOCUMENTS 

FOR NORTH CASCADES 

NATIONAL PARK SERVICE COMPLEX 

G ENERAL M ANAGEMENT P LAN 

The North Cascades National Park Service Complex General Management Plan

(NPS 1988b) includes management guidance for North Cascades National Park 

and Ross Lake and Lake Chelan National Recreation Areas, and that 

management guidance is relevant to the objectives of this plan/EIS. For natural 

resources in the North Cascades Complex, the General Management Plan

stresses increasing knowledge and understanding of the interrelationships of 

natural processes, preserving and restoring natural resources as part of a regional 

ecosystem, and providing research opportunities in “as natural a system as 

possible.” For the national recreation areas, the policy statements are similar 

regarding natural resources, calling on the NPS to conserve scenic and primary 

natural resources, but also to balance ecological processes with recreational 

activities. For the Ross Lake National Recreation Area, the General Management 

Plan states that this balance should be maintained to provide “the closest natural 

resource condition consistent with recreational use and existing power 

development.” For the Lake Chelan National Recreation Area, the General 

Management Plan says “to conserve the scenic and the natural resources and to 

balance ecological relationships and processes with recreational activities in 

order to maintain the closest natural resource condition consistent with 

recreational use and the Stehekin community.” 

The General Management Plan speaks of the need for cooperation with agencies, 

residents, organizations, and the public to ensure land use in and adjacent to 

North Cascades Complex is compatible with park purposes to the greatest extent 

possible, to develop resource management programs, and to develop plans and 

programs to deal with any other problems of mutual concern. 

S TRATEGIC P LAN

The Strategic Plan for the North Cascades National Park Service Complex (NPS 

2000a) includes goals for preserving park resources that are consistent with the 

goals and objectives of this plan/EIS. 

Mission Goal I.a. states that 

Natural and cultural resources and associated values of the North 

Cascades National Park Service Complex are protected, restored, 

and maintained in good condition and managed within their 

broader ecosystem and cultural context. 

Mission Goal I.b. states that 

The National Park Service at the North Cascades National Park 

Service Complex contributes to knowledge about natural and 
P URPOSE OF AND NEED FOR A CTION

38 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

cultural resources and their associated values, management 

decisions about resources and visitors are based on adequate 

scholarly and scientific information. 

Subgoals on species inventories and species abundance and distribution are 

furthered by the information contained in this plan/EIS. 

R ESOURCE M ANAGEMENT P LAN

The Resource Management Plan for North Cascades National Park Service 

Complex (NPS 1999a) is an internal North Cascades Complex document that 

elaborates on the resource conditions and management strategies set in the 

General Management Plan (1988b) described above. The primary purpose of the 

Resource Management Plan is to develop a program to achieve the mission 

related to natural and cultural resource stewardship. The Resource Management 

Plan contains individual project statements that describe the existing resource 

conditions and how they differ from the desired conditions. The plan then 

outlines a strategy for addressing each resource issue. With regard to fish 

stocking of natural lakes, the plan describes the following tasks: 

conducting fish impact evaluation 

refining risk criteria to native biota 

preparing a fishery management plan and NEPA review (in accordance 

with the 1991 Consent Decree described earlier in this chapter) 

implementing the plan including monitoring and mitigation 

MANAGEMENT IN WILDERNESS 

W ASHINGTON P ARKS W ILDERNESS A CT 

AND THE W ILDERNESS A CT OF 1964 

The federal Washington Parks Wilderness Act signed into law by Congress on 

November 16, 1988 (100 PL 668, 1988), created approximately 634,614 acres of 

wilderness and approximately 5,226 acres of potential wilderness within the 

North Cascades Complex, which is now known as the Stephen T. Mather 

Wilderness. This designation encompassed over 93% of the North Cascades 

Complex. 

In designating these areas as wilderness, Congress extended all of the protections 

and mandates of the Wilderness Act of 1964 (16 USC 1131 et seq.). The 

Wilderness Act established a national wilderness preservation system, 

“administered for the use and enjoyment of the American people in such manner 

as will leave them unimpaired for future use and enjoyment as wilderness, and so 

as to provide for the protection of these areas, the preservation of their wilderness 

character, and for the gathering and dissemination of information regarding their 

use and enjoyment as wilderness” (16 USC 1131). The Wilderness Act defines 
Related Laws, Policies, Plans, and Constraints 

ENVIRONMENTAL IMPACT STATEMENT 39

wilderness as “an area where the earth and its community of life are untrammeled 

by man, where man himself is a visitor who does not remain.” An area of 

wilderness is further defined to mean “an area of undeveloped Federal land 

retaining its primeval character and influence, without permanent improvements 

or human habitation, which is protected and managed so as to preserve its natural 

conditions and which (1) generally appears to have been affected primarily by the 

forces of nature, with the imprint of man's work substantially unnoticeable, 

(2) has outstanding opportunities for solitude or a primitive and unconfined type 

of recreation, (3) has at least five thousand acres of land or is of sufficient size as 

to make practicable its preservation and use in an unimpaired condition, and 

(4) may also contain ecological, geological, or other features of scientific, 

educational, scenic, or historical value” (16 USC 1131). 

With regard to designated wilderness, section 6.4.3 of the NPS Management 

Policies (NPS 2001a) states, “Recreational uses in National Park Service 

wilderness areas will be of a nature that enables 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 unimpaired condition.” 

Lands in the study area that are also in designated wilderness are more restricted 

in the kinds of uses that can take place because of the Wilderness Act

requirements. These restrictions include the tools the park is able to use to 

conduct fishery management practices. For more information, see “Appendix D: 

Related Regulations, Policies, Laws, and Legislation.” 

W ILDERNESS M ANAGEMENT P LAN

The Wilderness Management Plan (NPS 1989) outlines how the NPS will 

manage wilderness in the North Cascades Complex according to a “limits of 

acceptable change” approach. The plan governs use of the wilderness by all 

visitors, including anglers, but does not address fishery management. The 

Wilderness Management Plan divides the park and recreation areas into four 

opportunity classes (backcountry use zones): Day Use, Trailed/Established 

Camp, Cross Country I, and Cross Country II. Within these zones, limits are set 

on use numbers, and thresholds are established for impacts. These use numbers 

are maintained through the requirement of a permit for backcountry camping. 

RELATED LEGISLATION AND POLICIES 

Washington State 

Environmental Policy Act (SEPA) 

The state of Washington has a State Environmental Policy Act (SEPA), enacted 

in 1971, that parallels the National Environmental Policy Act. While the National 

Environmental Policy Act applies to federal agencies and actions, the Washington 

State Environmental Policy Act applies to state and local agency actions that may 

have a significant effect on the quality of the environment (unless those actions 
P URPOSE OF AND NEED FOR A CTION

40 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN

are defined as exempt by the state). Some undertakings require both federal and 

state or local actions and, therefore, are subject to both the National 

Environmental Policy Act and State Environmental Policy Act. This plan/EIS has 

been prepared as a NEPA document and may subsequently be adopted by the 

state of Washington prior to its taking action on this document. 

W ASHINGTON D EPARTMENT 

OF F ISH AND W ILDLIFE 

G OALS , P OLICIES , AND O BJECTIVES

The WDFW manages fish resources throughout the state, including those in the 

North Cascades Complex and surrounding public lands administered by the U.S. 

Department of Agricultural-U.S. Forest Service (National Forests System lands 

and wilderness areas). The goals, policies, and objectives of the WDFW guide 

that management (WDFW 1995). The WDFW’s high lakes fishery management 

program applies to all of the lakes in the lands surrounding the North Cascades 

Complex (for a discussion of the history of this program, see WDFW 2001). 

Inside the North Cascades Complex, authority for fish management is shared 

with the park. 

S TATEWIDE F ISH P OLICY

The Washington Fish and Wildlife Commission is the supervising authority for 

the WDFW. The department’s goals, policies, and objectives were published on 

February 2, 1995 (WDFW 1995). 

The WDFW’s mission is sound stewardship of fish and wildlife. Goals in pursuit 

of this mission include “Maximizing fishing, hunting, and nonconsumptive 

recreational opportunities compatible with healthy, diverse fish and wildlife 

populations,” and “Maximizing recreational opportunity for fish and wildlife 

constituents consistent with the preservation, protection, and perpetuation of the 

fish and wildlife resources.” Goals specific to fish management include 

“providing for significant recreation opportunities through artificial propagation 

programs” and “maximize[ing] fish and recreation opportunities.” 

One of the objectives under the goal of maximizing sport fishing opportunities is 

to implement “balanced management strategies that provide for a variety of 

recreational activities including unique fishing opportunities and optimum 

harvest.” A related objective directs the department to “maintain maximum 

recreation through population manipulations with the use of stocked fish, partial 

treatments with rotenone, and other strategies in appropriate waters.” 

S TATEWIDE F ISHING R EGULATIONS 

Fishing in the North Cascades Complex is governed by Washington State fishing 

regulations. A state fishing license is required for all persons 15 years or older, 

and licenses must be carried when fishing, including in the North Cascades 

Complex. The legal fishing methods and gear are described in the regulations 

(hook and line only), and using live bait, chemical irritants, or multiple fishing 
Related Laws, Policies, Plans, and Constraints 

ENVIRONMENTAL IMPACT STATEMENT 41

rods is prohibited. Lakes are open to fishing for most species all year. Daily 

harvest limits are generally five fish, but specific lakes may have a limit of two 

fish. Some waters have size limits, and special gear limitations are imposed on 

some waters. 

Washington State fishing regulations control catch limit, size, and fishing method 

for each species. Special rules for individual rivers specify the location, season, 

catch limit, size, and other unique regulations for the individual river. A 

summary of the 2004 Washington State freshwater fishing regulations is 

contained in appendix D (for the complete pamphlet, visit the WDFW website at 

http://www.wa.gov/wdfw/fish/regs/fishregs.htm). 

OTHER FEDERAL AGENCY 

PLANS, POLICIES, AND ACTIONS 

U.S. F OREST S ERVICE

Three national forests are in the region of the North Cascades Complex: 

Okanogan, Wenatchee, and Mt. Baker-Snoqualmie. While this plan/EIS only 

covers a study area within the boundaries of lands managed by the NPS, anglers 

are able to fish in lakes in the neighboring forests and wilderness areas. Should 

the selected alternative include the removal of stocked or reproducing fish from 

some of the lakes in the study area, mountain lakes on U.S. Forest Service lands 

or in Canada are likely to experience increases in use. 

U.S. F ISH AND W ILDLIFE S ERVICE

Some fish-bearing lakes in the North Cascades Complex and the surrounding 

areas drain to waters supporting fish populations currently listed under the 

Endangered Species Act. Pursuant to the Act, management plans for mountain 

lakes fisheries on federal lands are expected to be consistent with recovery 

planning goals for listed species. One listed species considered at risk in the 

study area is the bull trout (Salvelinus confluentus). Currently, recovery plans 

related to the Endangered Species Act have been completed in draft form by the 

U.S. Fish and Wildlife Service for the Puget Sound and Upper Columbia River 

Recovery Units for the threatened bull trout. Chinook salmon, another listed 

species, may also be at risk, although the recovery plan for this species is still in 

development. 

N ATIONAL M ARINE F ISHERIES S ERVICE

The recovery plan for Puget Sound Chinook salmon (Oncorhynchus 

tshawytscha) is currently under development and will be completed by the 

National Oceanic and Atmospheric Administration Fisheries (National Marine 

Fisheries Service). This is because Chinook are an anadromous species, meaning 

they spend some portion of their lives at sea. 
P URPOSE OF AND NEED FOR A CTION

42 DRAFT MOUNTAIN LAKES FISHERY MANAGEMENT PLAN
Related Laws, Policies, Plans, and Constraints 

ENVIRONMENTAL IMPACT STATEMENT 43

L OCAL P LANS AND P OLICIES

Although portions of the North Cascades Complex lie within Whatcom, Skagit, 

and Chelan Counties, the counties do not have planning jurisdiction over these 

federally managed lands. Any long-range planning efforts of small, 

unincorporated communities (such as Stehekin and Newhalem) that are within 

the boundaries of the North Cascades Complex are coordinated between the 

appropriate county and the NPS. 

T RIBAL G OVERNMENT I NTERESTS

Based on discussions with various tribes affiliated with the North Cascades 

Complex, there is no indication that Native Americans stocked fish in mountain 

lakes, although several tribal members suggested it could have been possible. 

While the mountain lakes fishery is an artifact of contemporary culture, the lakes 

themselves are very important to various tribes, as documented in the 

archeological record and in consultation with the tribes. These consultations 

currently indicate that tribal government interests will be protected provided 

there is no ground disturbance from management actions. The “Consultation and 

Coordination” chapter (see the “Native American Tribes” section under “Agency 

Consultation”) lists the tribes that have been consulted.