The April Bay Journal contains a seriously flawed representation of the facts by the Pennsylvania Fish and Boat Commission concerning hatchery problems, including Big Spring Creek near Newville, PA.

For nearly five years, Dr. Jack Black of Buffalo, NY and I conducted a study of Big Spring Creek. We examined the history, chemical and biological conditions of the stream as affected by the effluent from the hatchery.

This peer-reviewed study was released as a report, “An Ecological Survey of Big Spring Creek with Emphasis of the Effects of Fish Hatchery Effluent,” in 1997 to the Pennsylvania Fish & Boat Commission and the Department of Environmental Protection. It was the impetus for two follow-up studies by DEP biologists whose data and results backed up our work (1998 and 1999, Botts of DEP).

(Further, a preliminary investigation by Susquehanna Basin River Commission biologist Jennifer Rowles in June 1997 reported organic pollution and a pollution-tolerant macroinvertebrate community in Big Spring.)

Our pro bono study is now in the hands of Citizens for Pennsylvania’s Future, a nonprofit environmental law group out of Harrisburg, PA.

The PFBC denied they were the problem from the beginning and blamed a host of other causes. Only recently have they admitted that they are “partially to blame.” They are not partially to blame. They are totally to blame. All other causes of sedimentation and organic enrichment in the stream are minor compared to the massive amounts of enrichment coming from the hatchery.

The PFBC fails to understand the basic biogeochemistry of the stream and this shows in their consistent media releases which to this day fail to take blame for their lack of scientific competence. Further, it should be noted that the PFBC has the same problem with five other hatcheries throughout the state.

An analysis of PFBC fishery data by Dr. Black showed that 98 percent of the trout inhabited a 150-meter stretch of stream below the effluent of the hatchery. The other four-plus miles of stream were basically barren!

The PFBC had this data for more than 20 years but continued to issue media releases and print publications touting the stream as a world class trout stream. They continued to promote the stream as viable healthy trout stream even though their own data showed this not to be true.

To this day, the PFBC believes they have done nothing wrong in misrepresenting the facts to the public. In an academic institution, this would have been grounds for dismissal as scientific fraud!

Currently, the entire stream’s trout population has been estimated at less than 2,500 trout, or less than 10 percent of historic population numbers. This small population is easily accounted for by the stocked trout and hatchery escapism.

Robert Schott, a biologist for the DEP, in a Sept. 13, 2000 letter to Dennis Guise, the deputy director/chief council of the PFBC, offered this analysis of Big Spring, “Essentially, the upper reach of Big Spring Creek, in our opinion, has become an extension of the hatchery populated by escapees from the hatchery with minimal reproductive success.”

It is likely that the original strain of wild brook trout that made Big Spring famous no longer exists. They were ultimately destroyed by the PFBC to accommodate its hatchery. All that is left of this magnificent stream is 150 meters, which even the DEP calls an extension of the hatchery.

The PFBC continues this distortion with comments by its spokesman, Dan Tredinnick, who states that brook trout were on the wane by the 1940s. On the other hand:

  • The PFBC media release in 1970 on the development of the Big Spring Fish Cultural Station at the headwaters of Big Spring talked of the “excellent water quality” and natural-spawning population of trout.
  • An article in the Pennsylvania Angler (a PFBC publication), by editor Jim Yoder, stated, “The hatchery was constructed above the spring in order to retain Big Spring as a topnotch trout stream.”
  • A 1971 April survey of the headwaters of Big Spring by the PFBC showed an unbelievable number of young of the year brook-trout fingerlings to be present.

The PFBC and Tredinnick should examine their own files, publications and media releases over the last 30 years before they try to rewrite the history of Big Spring.

The hatchery was built in 1972. In 1973, it produced 750,000 trout. By 1975, the brook trout population had crashed. The PFBC’s own data showed the collapse but they chose to ignore it.

It should be noted that all independent and historical accounts show Big Spring Creek was one of the 100 best trout streams in the world at one time.

Flyfisherman magazine rightly called it perhaps the greatest brook trout stream in the world. Its editor, John Randolph, called Big Spring a “goose that laid golden wild brook trout eggs.” He said an economic study showed that a restored Big Spring would bring as much as $10 million into the region’s economy. Today it is nothing more than a deposition basin for the effluent of Big Spring Hatchery.

Before the advent of the PFBC hatchery, Big Spring was considered a “mayfly and insect factory.” Flyfishermen from around the world trekked to its waters to fish for the free rising brook trout as they fed on the surface for the mayflies and caddisflies. The Sulfur mayfly (Ephemerella rotunda Morgan) had huge populations in the stream.

This clean water mayfly is now absent from the upper four miles of stream. It cannot withstand the low oxygen levels on the bottom of the stream and the organic enrichment.

My studies of the benthic community, using EPA Rapid Bioassessment Protocols, showed once-vibrant, pollution-intolerant invertebrates dominated mostly by mayflies and caddisflies now replaced by pollution-tolerant invertebrates.

Two later studies by DEP biologists came to the same scientific conclusions.

The macroinvertebrate community is the best indicator of the health of an aquatic ecosystem. Water quality measurements of the Big Spring hatchery indicate elevated levels of nutrients (nitrogen and phosphorous compounds) as well as elevated levels of suspended solids.

The effluent is also high in oxygen-consuming substances.

The values of the pollutants were within the range associated with altered fish and benthic invertebrate community structure. By any standard evaluation, the fish and benthic structure of the stream would be deemed severely impaired.

An examination of the substrate in areas of the stream released the smell of hydrogen sulfide, which forms under anaerobic conditions. Yet the PFBC failed to understand what was going on in Big Spring and failed to do proper scientific studies.

Another argument that falls flat on its face after the examination of scientific data and fishery studies is that the upper part of the stream cannot be restored to a brook trout fishery. Tredinnick’s comments that competing rainbow and brown trout would have to be physically removed to begin such a program is nonsense.

Once again, the PFBC fails to recognize the history of the stream. The stream was stocked with brown and rainbow trout for years but these species failed to gain a foothold in the upper section of the stream.

These comments are even more an embarrassment for an agency that claims to understand fishery biology.

Brook trout have a reproductive advantage: They become reproductively mature at a much younger age than brown or rainbow trout. Brook trout reproduce so well that in western streams where brookies have been introduced, that they have literally become a nuisance driving out native species of trout.

The PFBC contention is that they met all permit requirements, and that they did nothing wrong is typical of the nonscientific analysis that is forthcoming from the PFBC.

According to documents from DEP and PFBC files, there were at least 39 violations at Big Spring from 1983 to 1988 alone. These were considered minor in nature by the DEP. However, in 1989, the DEP relaxed the permit requirements because the hatchery could not meet the standards!

The cumulative effect of 30 years of effluent has doomed Big Spring.

The National Pollution Discharge Elimination System Program (NPDES) permits assigned to protect Big Spring are based on chemical averages and do not take into account cumulative effect.

Trout don’t live in chemical averages. They live in minima and maxima of the chemical parameters and the cumulative effects of those parameters over time.

The EPA issued a waver to the PFBC and has little concern for water quality in spite of the federal Clean Water Act. One only need look at the 303(d) List of Impaired Waters to find out that the EPA’s vigilance is less than stellar.

To return Big Spring to its previous incarnation as one of the premier trout streams in the world, the hatchery must be closed. Dr. Black and I believe that if the hatchery is closed, within three years or less, the stream will begin to return to its former glory.

Once the hatchery is closed, the stream should be biologically, geologically and chemically mapped to record its historical return for science and to understand what is happening in the stream.

This mapping should be done independent of the PFBC because they have proven in the past to be lacking in the competence necessary to do proper peer-reviewed scientific studies.

Furthermore, they have proven to be a stumbling block rather than an asset in saving this stream because they refuse to use modern fishery and aquatic science. By refusing to give up the “megahatchery” mentality of 30 years ago.

Once the stream completes its transformation, then and only then should any stream improvement work be done. The nutrient load from the hatchery controls the flora and water channels over time. Once the nutrient load from the hatchery is shut off, the channels will change as the stream reverts back to its normal nutrients loadings.

Dr. Black and I have nothing against hatcheries. They are a proper part of modern fishery management. Dr. Black is a leader in recirculation technology and even runs his own hatchery outside of Buffalo, NY.

But the PFBC should give up its megahatchery mentality. Instead, cost-effective small– to medium-size recirculation hatcheries should be built throughout the state that would cause very little pollution.

Big Spring is a jewel among streams in the world. She is worth so much more than the hatchery because with today’s technology, they can build hatcheries nearly anywhere in the state. Streams like Big Spring are not found everywhere. Spring creeks are magical places and to have one with more than 4 miles of water this close to major metropolitan areas is in itself a miracle.

There are many lessons to be learned from Big Spring, including the failure of a state agency, the PFBC, which was given stewardship of one America’s greatest streams, and the DEP and EPA, which failed to monitor what was going on for nearly 30 years.

Perhaps the biggest lesson is what Big Spring represents as a symbol of what is happening in the Chesapeake Bay. I have argued this point for years but it seems to fall on deaf ears. `f you want to save the Chesapeake … then you had better save the streams that empty into it!

To do this, NPDES permits cannot be based primarily on water chemistry and averages. The chemical data which the permits are based on are not adequate to protect any stream.

NPDES permits are seldom monitored as far as I am concerned. Chemical data cannot stand alone and is not a proper study of any stream or lake. Only biological data which include the macroinvertebrate community tell the true story of what is happening in aquatic ecosystems, because they reflect long-term conditions.

Any competent aquatic scientist knows that chemical data is used to back up biological data, and would never try to do a study using chemical data alone. NPDES permits must be based primarily on biological data such as EPA Rapid Bioassessment Protocols to be effective.

If the present NPDES permits cannot protect one of the world’s greatest streams, what do you think is happening to lesser waters? Unless the NPDES permit process is changed and agencies like the PFBC are held accountable by the EPA and the public, then these streams will continue to be polluted.

These streams serve as the arteries of the Chesapeake Bay. Their nutrient load will continue to cause the Bay to die the slow death she is experiencing.

Unless these things are changed no amount of research, money, politics or scientific modeling will save the Bay.

To save the Bay, you must save her streams, and let it start with perhaps one of the most wondrous spring creeks in the world … Big Spring.