10 August 2004
Communications
Bonneville Power Administration – DM – 7
P.O. Box 14428
Portland, OR 97293-4428
Re: comments on DEIS for South Fork Flathead Watershed
Westslope Cutthroat Plan
Folks:
Thanks for the opportunity to comment on the DEIS
for conserving westslope cutthroat trout in the South
Fork Flathead watershed. These comments represent
those of Montana Trout Unlimited, which represents
2,700 Trout Unlimited members in Montana. You could
also be receiving comments from individual TU chapters
or members.
Montana TU and its Flathead Valley Chapter have
been discussing this project with Montana FWP for
more than two years. We have met agency biologists
and we have submitted written comments for scoping.
The project is an important conservation priority
for TU in Montana. It is important that this project
succeed.
We support Alt. B, the preferred alternative, but
with some changes. We are disappointed, however,
that the DEIS didn’t analyze the effects of
restocking the 21 project lakes, especially in regards
to lost opportunities for researching how or whether
native fauna can repopulate high lakes once introduced
fish are removed. In addition, we are disappointed
the DEIS didn’t evaluate genetic risk from
stocking MO12 fish on top of cutthroats comprised
of the local genotype. Because decisions to restock
or not are connected to the removal actions, that
BPA is required to work with Montana FWP to evaluate
and disclose the effects of different restocking
alternatives. Without the removal project there would
be no restocking. The actions are connected.
We have identified these major issues, which we
believe can be addressed in part by modifying the
preferred alternative as we suggest:
1. Using piscicides in high mountain lakes
2. Using motorized equipment in designated wilderness
3. Stocking lakes that were historically fishless
in wilderness once removal is complete
4. Interfering with recreational angling in the
short term and long term
5. Conserving the genetic integrity of the
local cutthroat genotype.
First, issues involving whether removal is appropriate
or not are best met with improved education and communication.
The public needs to know that the risks of this project
to angling, public health and ecosystem values are
low. The main risk is that the project might not
succeed in eliminating or reducing to acceptable
levels genetic drift from introgressed populations.
The public also needs to better understand, without
employing patronizing “government knows better
than you” approaches, that the net result of
this project is likely to be a higher quality sportfishery.
Importantly, this project could help produce a sport
fishery for westslope cutthroats that has a higher
that has a higher likelihood of enduring. It is reasonable
to hypothesize that native westslope cutthroats,
especially the local genotype, are more fit and probably
better able than non-native species (or hybrids)
to adapt to long-term geological and climatological
change. They are also, all things being equal and
given their genetic predisposition or life-history
behaviors, probably more able to adapt to fish health
challenges (such as whirling disease).
Thus, because the South Fork population of westslope
cutthroats is one of the most diverse and largest
remaining in the subspecies’ range, conservation
of the genetic integrity of these fish is very important.
It is also important to acknowledge that conservation
of the population comprised of fish with an ancestral
genetic lineage means protection of a high-value
sportfishery. Anglers come from all over the nation
today to fish for westslope cutthroats in the South
Fork of the Flathead, and many of its major tributaries.
The four major issues we have identified can be
addressed by modifying the Alt. B. this way:
1. Sequence removal projects so that the non-wilderness
lakes are done first (unless there is evidence that
genetic drift from the wilderness lakes is severe
enough that they should be done first). This will
best occur by hitting several lakes a year.
2. Use helicopters in the non-wilderness lakes to
get the job done most expeditiously. This also avoids
conflicting with current Forest Service management
to not allow packstock in the Jewel Basin.
3. Restock the nonwilderness lakes with MO12 fish,
but consider not stocking those lakes that have poor
or no trail access. They have the least amount of
existing angling use anyway.
4. Encourage FWP to develop a local “near neighbor” stock
of westslope cutthroats for conservation purposes.
It is possible fish from this program could be available
within 8-10 years. Once a “near neighbor” strain
is available for stocking, phase out the use of MO12
fish in the South Fork drainage and use fish comprised
100 percent of a locally developed genotype.
5. Once removal is complete in the non-wilderness
lakes, proceed with chemical removals in the wilderness
lakes. Lakes with good trail access should be done
mainly using packstock. Where access with packstock
is difficult, FWP and the Forest Service should design
a “minimal use” motorized access plan
for chemical removal using helicopters.
6. Do not restock any lakes in the wilderness with
MO12 fish.
7. Once a near-neighbor stock is available, FWP should,
on a case-by-case basis, evaluate with the cooperation
of the Forest Service, which lakes can be left fishless
and which might be stocked with the “near neighbor” strain.
8. Wilderness lakes without FS trail system access
should be left fishless, providing an opportunity
to study how naturally fishless lakes recover.
Because access is difficult to these lakes, it
is likely
that little recreational angling will be lost.
This sequenced implementation plan should be evaluated
before a final recommendation is made for the FEIS.
These modifications of the preferred alternative:
1. Provide a reasonable likelihood, given the technological
limitations of piscicide application in wildlands,
that ongoing undesirable genetic drift will be slowed
considerably in the South Fork watershed, and probably
significantly swamped or eliminated in specific drainages.
2. Provide for reduced temporary impacts on recreation
and angling in the nonwilderness areas.
3. Reduce, though doesn’t eliminate all, the
temporary impacts of motorized use in the wilderness
4. Provide higher assurance than the preferred alternative
(as describe in the DEIS) that the ancestral lineage
of the South Fork fish is conserved.
5. Promote development of a conservation program
of a near-neighbor population of westslope cutthroats
for future use in the South Fork drainage (a resource
available for both conservation and recreational
purposes).
6. Minimize impacts on angling opportunities. The
impacts on the nonwilderness lakes will be limited
in duration and geographic location (by doing a handful
of lakes a year, there will still be nearby lakes
available with fish. When they are treated, the lakes
that were done first could be restocked.)
7. Does reduce high lake angling opportunities in
the wilderness. However, the existing opportunities
in streams in the South Fork drainage (and in nearby
nonwilderness lakes) are a considerably valuable
alternative. Moreover, aside from the use posed by
a few commercial outfitters as well as incidental
angling use by a few other wilderness users, the
overall angling use in the wilderness lakes today
is very light. FWP has told Montana TU that overall
angling use for all 21 lakes is around 2,000 angling/days/year.
It appears most of this use occurs in the nonwilderness
lakes, and that which occurs in the wilderness most
likely occurs in lakes with trail access (especially
for packstock). It seems reasonable to conclude that
lakes that don’t have good trails to them don’t
get much use (such as George and Lick Lakes). And
thus it doesn’t seem that critical that they
be stocked. If these assumptions are in error, the
DEIS should provide better disclosure of the specific
and quantified impacts on each wilderness lake. As
is, the DEIS includes little detail about existing
angling use in the 21 lakes.
8. Provides an opportunity after removal to monitor
the biological recovery of lakes that were historically
fishless.
We are confident the methods described in Alt. B.
for removal – application of piscicides with
downstream detoxification stations and monitoring – are
ample to get the job done with minimal adverse impacts.
These methods have worked well elsewhere. The biggest
challenge of the project is gaining public acceptance.
The modifications we suggest for implementing Alt.
B go directly at increasing acceptance from anglers,
nonwilderness recreationalists, wilderness users,
USFS, FWP and conservation biologists.
We look forward to the decision reflecting our
suggestions.
Sincerely,
Bruce Farling
Executive Director
cc. Flathead Valley Chapter TU
Montana FWP
USFWS
Flathead National Forest
