Dear Secretary Haaland, Deputy Secretary Estenoz, Maureen Foster, Gary Fraizer, Martha Williams, Alyssa Houseman and other wildlife conservation leaders,
We request that the upcoming decision to protect Wisconsin’s Lake Sturgeon population by listing the species under the Endangered Species Act (ESA) not be derailed by politicians using species for gain or elections instead of listening to scientific experts and trust obligations in this small window we have to shift the paradigm of wildlife management to biodiversity loss and extinction mitigation. The Lake Sturgeon population in Wisconsin is on the brink of extinction, and it is crucial to consider designating them as a Distinct Population Segment (DPS) and granting them federal protection through the ESA. Without such protection, the survival of the Sturgeon population could be at even greater risk from pollution, invasive species, and climate change.
We strongly oppose the SPEAR Act from Wisconsin Congress lawmakers, which would exempt Wisconsin and the USFWS from any listing of Lake Sturgeon under the ESA. The Protected and Exempt from Absurd Regulations (SPEAR) Act needs to be revised for its potential implications on conserving Lake Sturgeon. In light of the accelerating extinction crisis, politicians should refrain from interfering with the Endangered Species Act or the assessment of experts in decisions about critically endangered fish in the United States.
We want to emphasize that the Wisconsin Sturgeon population is a public resource that belongs to everyone, not just the residents of Wisconsin. The public trust doctrine states that wildlife belongs to us all, and our shared responsibility is to protect and conserve these species. By working together, we can guarantee that the Sturgeon population in Wisconsin and beyond remains healthy and abundant, benefiting everyone.
The interconnected waterways of Lake Winnebago represent a crucial habitat for Sturgeon species. However, populations of Sturgeon across the United States are declining rapidly due to various factors such as habitat loss, pollution, overfishing, poaching, and dam construction. According to the International Union for Conservation, Sturgeon species are among the most critically endangered globally, and over 85% of them are at high risk of extinction due to overexploitation. The high demand for Sturgeon’s roe is one of the primary reasons behind this.
The state management plan of Wisconsin has some positive aspects, but it is vital to prioritize preserving Sturgeon populations to restore them in other areas. The current approach seems outdated as it prioritizes the interests of spear fishermen and selling licenses instead of taking steps to mitigate the extinction crisis.
Restoring Lake Sturgeon populations in areas requiring species restoration is challenging due to their unique life history and environmental challenges. It takes 12-15 years for males to mature and 20-25 years for females to mature. Male Sturgeons typically spawn every two or three years, while females may only spawn once every four to nine years. Improving the survival or recruitment of young fish today will not increase Lake Sturgeon populations, which have declined for 15 to 25 years. Restoring these populations will require a long-term commitment and the relocation of adult Sturgeon. These fish are important indicators of water health and are highly sensitive to water quality and temperature. They accumulate toxins in their bodies over time, making them unsafe for consumption. Recovery measures could only be implemented under the Endangered Species Act.
The survival rate of Lake Sturgeon hatchlings is dismal in waters with even slight temperature increases. We saw mass die-offs of sturgeon across the county in 2023. Lake Winnebago and other areas of Wisconsin are at risk, and one catastrophic event such as disease, sudden invertebrate die-off, or harmful algal bloom growth could lead to the extinction of the fish within a year. It is crucial to prioritize wildlife conservation over consumptive-based conservation practices that must be fixed.
Given the increasing pollution levels and rising water temperatures in Lake Winnebago, it is critical to classify the Sturgeon as at least a threatened species in Wisconsin. This classification would enable the government to take necessary actions to protect the species and its habitat.
The Department of Natural Resources conducted research that recommended harvest reduction and harvest size reductions for the long-term health and survival of Sturgeon in Wisconsin. This recommendation needed to be followed, and, as a result, Wisconsin Lake Sturgeon has suffered to favor the short-term success of harvesters. In 2022, about 2500 licenses were sold, and 914 fish were registered as harvested, despite the recommendation from both internal and independent researchers to reduce harvest for the year 2023.
Looking more specifically at the 16-day spearing season in February on the Winnebago System, the Department of Natural Resources sold a whopping 13,219 licenses for sturgeon spearing, and 1,405 sturgeons were registered. These sales generate funds to support DNR sturgeon management and help protect the population. However, a fine of $60 is imposed for poaching, and, likely, sturgeon fishermen and spearers would only continue to purchase licenses if the harvest was available or reduced.
Again, this situation highlights the importance of science dictating policy, which the agency responsible for waterways often ignores under state and federal public trust.
While many people buy licenses to promote conservation and biodiversity, even if they have no intention of hunting or fishing, most of us have endangered plates or give them to the fund. When anti-wildlife regulations and rules are unpopular, inhumane, or impact wildlife in an often detrimental way on predator or non-game species, refunds are not requested, given, or demanded by GLWA’s wildlife advocates. We respect the process and believe in government transparency and democracy. Even when the right to due process and participation by those the agency decides are not stakeholders matter, wildlife advocates still want to help transform wildlife management at the table and happily respect and promote conservation efforts.
Most hunters and DNR staff in Wisconsin are demonstrating the opposite. In this case, the lake sturgeon listing is not an exception, if a season is canceled or the species cannot sustain itself. However, unpopular policies rooted in science with the best interest of fish at hand, such as reducing harvest, should be guiding decisions. One look at the disregard of native rough fish in Wisconsin, undesired by sports fishermen, can tell you the trickle-down license theory is unsubstantiated. While no one is entitled to or guaranteed a successful harvest with purchase, the agency hands out refunds of much-needed conservation dollars if the vocal minority doesn’t approve despite research. Even when we tell them this is the only way to preserve heritage and do what is best for wildlife populations and individuals.
If the Lake Sturgeon were listed under the ESA, the U.S. Fish and Wildlife Service would allow indigenous harvest rights and permit state fisheries to hold a lottery, similar to Elk Management. We simply need a management plan that is consistent with national recovery efforts. The limited season, which could be temporary and lead to more Sturgeon for future generations, is being protested by self-minded individuals who believe that a federal restoration program removes local voices. However, it would not.
If the Lake Sturgeon were listed under the ESA, the U.S. Fish and Wildlife Service could allow indigenous harvest rights and permit state fisheries to hold a small lottery, similar to Elk Management. We simply need a management plan that is consistent with national recovery efforts. The limited season, which could be temporary and lead to more Sturgeon for future generations, is being protested by self-minded individuals who believe that a federal restoration program removes local voices. However, it would not.
It is crucial that the government agency and trustee responsible for overseeing waterways and wildlife, for the benefit of all and the future at both state and federal levels, prioritizes policies informed by reviewed scientific research on wildlife management. Scientists should also feel empowered to speak up and advocate for these changes without fear of consequences. The current situation is undemocratic and top-down, where only preferred game species are prioritized, while lethal take is the only means of achieving their goals. But more than that, Wisconsin’s constitution guarantees my right to hunt, fish, and trap. What if the decline is so detrimental or unscientific that it removes the possibility of exercising my rights? What about the right to fish for other states that could one day have a robust sturgeon population again? What about the rights of all citizens to use the resource in a legitimate, meaningful, and lawful way?
Finally, Warnings have been issued across Wisconsin that the ice is unstable for fishing or spreading. This is a significant concern as it is not 50 degrees on February 8th in Wisconsin, suggesting a considerable problem. Therefore, it is essential to prioritize preserving Sturgeon over-harvesting and caviar production, at least temporarily, to protect the species from sudden extinction and protect future harvest and heritage for the people of Wisconsin and beyond. Wisconsin citizens have a strong conservation ethic and would be happy to do whatever it takes to keep this iconic species thriving, even outside of our borders.
Therefore, we also will urge our Congressional lawmakers, on behalf of our nearly 10,000 supporters and many Wisconsin voters, to repeal the current SPEAR Act and then take the necessary steps to evaluate, protect, and restore the Lake Sturgeon population.
We are happy to suggest appropriate bill language: The Lake Sturgeon Evaluation and Sturgeon Protection, Assessment, and Restoration (SPEAR) Act is an essential piece of legislation in Wisconsin that aims to protect and conserve the state’s lake sturgeon population. This act provides funding for research, monitoring, and restoration efforts related to lake sturgeon and increased penalties for illegal harvesting and trade of sturgeon. It also sets up a coordinated effort between state agencies, tribal authorities, and USFWS, implementing trustee obligations and democracy to ensure the long-term survival of this iconic species.
Thank you for your attention to this matter.
Sincerely,
Melissa Smith
Executive Director, Friends of the Wisconsin Wolf & Wildlife
Great Lakes Wildlife Alliance | Wildlife Policy & Government Affairs
608.234.8860 | PO Box 259891 Madison, WI 53715
wiwolvesandwildlife.org 
Save the sturgeon!
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