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Glenn Krevosky & Russ Cohen

There are available methods to get wild trout streams you know about (but that the state may not know about) better recognized and protected against degrading activities. Here’s a message explaining how - prepared (with Russ Cohen’s help) by Glenn Krevosky of EBT, Environmental Consultants, Inc.:

As you (may) know, development projects adjacent to streams supporting naturally-reproducing populations of wild trout can seriously degrade trout habitat by contributing excessive levels of sediment, thermal and other pollution to the receiving water. While the full implementation of best management practices (BMPs) at these developments can substantially reduce (if not completely eliminate) these adverse impacts, this is frequently not done because the developer’s environmental consultant(s) and/or the project’s environmental reviewers at the local or state level are not aware that a stream affected by the project supports a wild trout population that is in danger of serious harm from the project.  

One way to help increase awareness of the location of wild trout streams to developers, landowners, environmental consultants and reviewers is to propose that they be added to the Mass. Division of Fisheries and Wildlife (MassWildlife)’s “CFR” (coldwater fisheries resources) list, maintained by MassGIS and the DFW GIS program. This list includes all the waterways for which MassWildlife has documented the presence of naturally-reproducing populations of trout or other “coldwater” fish species (i.e., fish species that cannot generally tolerate water temperatures in excess of 72°F).  There are other streams deserving CFR status that are not yet on the list simply because MassWildlife has yet to evaluate them.      

Throughout the course of field consultant work, wetland scientists encounter cold water fisheries that are not found on MassWildlife’s CFR list. [Volunteer water quality monitors, Shoreline Survey participants, anglers and others may also become aware of the presence of wild trout and/or other coldwater species that have yet to be documented by the state.] MassWildlife staff are interested in hearing about these streams and evaluating them for possible inclusion on their CFR list. As you (may) know, this identification as a “cold water fishery” affords the stream "Critical Area" status under Mass. DEP Stormwater Management Guidelines (see here
) and requires a more rigorous implementation of stormwater BMPs to help ensure development projects don’t harm sensitive trout populations and habitats.

EBT Environmental has been involved in cold water fisheries projects since 1979. We are asking that you consider contacting the MA Fish & Wildlife Field Headquarters when you encounter unlisted trout streams. A USGS locus map should be sufficient to initiate the process for stream assessment.   

Unfortunately, even if a stream is listed on the MassWildlife’s “CFR” (coldwater fisheries resource) list, it may fail to get full recognition and protection because the stream segment in question is not also listed as a cold water fishery in DEP’s Surface Water Quality Standards at 314 CMR 4.00 et seq. The DEP’s list of cold water fisheries is much less extensive than MassWildlife’s list (more about that below). Some developers and/or their consultants erroneously believe that the failure of a stream to be officially classified as a cold water fishery by DEP means that there is no obligation on their part to implement rigorous BMPs as required for “critical areas” under the DEP Stormwater Policy. (The fact is that inclusion of a stream on MassWildlife’s CFR list is enough to qualify a stream for “critical area” status.)          

Ideally, the optimal status for a wild trout stream to receive the highest degree of recognition and protection is for it to be listed on both MassWildlife and DEP’s list of cold water streams. The “triennial review” (i.e., the public comment period on the Massachusetts Surface Water Quality Standards discussed above) provides an opportunity for anyone to suggest to the DEP that specific stream segments that you believe qualify for official classification by the DEP as a “cold water fishery” should be re-classified as such. You may also want to propose that DEP simply define “cold water fishery” in the Standards in a manner that would enable most if not all of the streams on MassWildlife’s CFR list to qualify for incorporation into DEP’s “cold water fishery” list

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