Mr. David Cash, Undersecretary for Policy
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
david.cash@state.ma.us

Re:  Sustainable Water Management Initiative:  Safe Yield and Streamflow Management

Dear Mr. Cash:

Trout Unlimited and its Massachusetts-Rhode Island Council (collectively “TU”) have long advocated for the conservation, restoration and protection of Massachusetts' coldwater streams and their trout populations.  While Massachusetts has historically been a water-rich state, the past century's spider web of population growth and commercial and residential development—compounded by effects of climate change—has increased pressures on the region’s freshwater resources, resulting in extreme seasonal stream flow conditions and negative impacts on aquatic resources.

TU is very concerned about the negative impacts on native wild brook trout and other wild trout species (rainbow, brown, and Atlantic salmon) associated with water withdrawals—especially withdrawals made during the summer months, when rivers and streams are more vulnerable because of already at their lowest annual flow levels, leading to warmer temperatures and adverse effects on trout populations.   We strongly believe that adequate flows throughout the year are critical to ecological balance and to the protection and conservation of trout populations.

Over the past two years, TU members have been following your office's Sustainable Water Management Initiative (SWMI) as it seeks to develop a sound state-wide approach to determine the Safe Yield of the Commonwealth’s rivers and streams, as required by the Water Management Act.   TU applauds the SWMI's intention to rely on population density changes of fluvial fish—primarily brook trout—as a reliable indicator of even small reductions in stream flow.  Brook trout are the most flow-sensitive of the fluvial fish species in Massachusetts, serving as the flow management equivalent of the “canary in the coal mine.”   Any diminution in stream flow in a basin or sub-basin where brook trout populations are present will therefore disproportionately harm this native trout species, and diminish the overall ecological health of the watershed as well.     

Because of the brook trout's sensitivity to small changes in flow, any approach to the determination of Safe Yield must assure that, before a withdrawal is authorized, it will not cause or contribute to a summertime flow reduction in any river, including its headwaters and tributaries, that would adversely impact resident wild native brook trout populations or other wild trout populations.   Committed maintenance of these populations in turn supports the purchase of state fresh water fishing licenses, tourism and quality of life in Massachusetts.

 Particularly during the late summer months of August and September, permitted withdrawals should not be allowed to reduce stream flow below the level necessary to maintain brook trout populations at their pre-established levels.  Further, any basin or sub-basin that falls within Streamflow Categories 1 or 2—those basins that contain high quality resources and hold sensitive brook trout populations that respond more extensively to flow alteration—should not be allowed to backslide, even if the proposed flow reduction does not cause the affected stream to drop to a lower Streamflow Category. 

We acknowledge that a reasonable amount of time must be allowed to reduce water usage to within protective Safe Yield limits in currently over-allocated basins.  However, we feel strongly that this process, which has been put off since the Water Management Act was passed in 1986, should begin without further delay. 

Thank you for consideration of TU’s concerns.  Please do not hesitate to contact me at pknauth@verizon.net or 413.441.8559.