Re: Comments on U.S. Fish & Wildlife Service (USFWS) Draft Recovery Goals for endangered fish of the Colorado River basin (published September 10, 2001)

Dear Dr. Muth:

LIVING RIVERS submits the following comments in support of recovering four listed, endangered fish species native to the Colorado River: bonytail, Colorado pikeminnow, humpback chub, and razorback sucker.

We note that recent data from the Grand Canyon Monitoring & Research Center indicate a steeply declining population trend for humpback chub in Grand Canyon. This is a warning sign that current efforts in the lower basin (at least) are not protecting the fish, much less providing for their recovery.

The U.S. Fish & Wildlife Service (USFWS) has primary responsibility for ensuring the protection and recovery of these species. We call on the agency to reconsider its current strategies and devise effective, workable solutions that will assure survival and recovery of the humpback chub and the three other species that are currently absent from Grand Canyon.

Regarding the draft recovery goals, we request that the USFWS submit them to an independent, external scientific peer review panel before final publication. The panel should consider also all comments submitted in response to the draft document.

Because of the seriousness of the fishes' plight throughout the Colorado River basin, LIVING RIVERS requests the USFWS prepare a basinwide Environmental Impact Statement (EIS) to address recovery goals throughout the fishes' historic ranges. An effective and adequate recovery goals document must necessarily address a wide range of water management issues throughout the basin. Because the implementation of the recovery goals for the four listed fish--a federal action--necessarily entails significant impacts to water management, dam operations, and other environmental factors, the agency is required by law to prepare an EIS.

LIVING RIVERS opposes adoption of the recovery goals in their current form. We believe that, in general, the USFWS has emphasized too much the use of hatcheries and pond rearing to achieve numerical population increases, while ignoring the need to restore suitable habitat across the fishes' historic range. A true recovery plan must ensure that sufficient habitat is available to give species the greatest hope for survival over the long term.

1) LOWER BASIN CONCERNS: In the draft, USFWS emphasizes recovery of viable populations in the upper basin at the expense of lower basin populations, which have long been at much greater risk. The draft recovery goals appear to reflect an agency assumption that little can be done in the lower basin besides continuing the hatchery stocking program. USFWS must make recovery a priority in the lower basin as well as the upper basin, and must not permit downlisting/delisting of the fish so long as lower basin populations remain endangered. In addition, the USFWS must consider the Colorado River delta below Morelos Dam as potentially suitable habitat, and require that stream flows and viable populations be restored to that reach of the river in Mexico before recovery can be deemed to occur.

2) EMPHASIZE WILD FISH: The USFWS should give more attention to protecting and encouraging propagation of extant populations of wild fish, as opposed to hatchery-raised fish. Over the long term, much more robust and genetically diverse populations are likely to result from wild fish. Recovery goals should require wild populations and aggregations to be viable and reproducing.

3) STUDY DAM REMOVAL/DECOMMISSIONING: In that light, LIVING RIVERS calls on the USFWS to address the need for removing dams throughout the Colorado River basin, as an obvious and beneficial way to restore potentially large areas of suitable habitat. Dam decommissioning can make available habitat that is currently inundated by reservoirs, as well as improve conditions in reaches downstream of dams. Dam removal will allow for re-establishing long-blocked fish migration routes, which may be beneficial for the Colorado pikeminnow, in particular.

In the Grand Canyon in particular, the benefits to the endangered fish of decommissioning Glen Canyon Dam must be considered as part of any long term recovery effort. Hundreds of stream miles above and below the dam could be made habitable once again with this single restoration strategy. Other dams in the basin should be studied for removal/decommissioning as well, including Navajo Dam on the San Juan, Flaming Gorge on the Green River, and one or more of the lower basin dams below Hoover (e.g., Laguna). USFWS cannot ignore the benefits of these undertakings.

4) DOWNLISTING/DELISTING: We fear that the emphasis on strict numerical targets, coupled with the reliance on hatcheries to produce maximum numbers of fish in the shortest period of time, reflects the intense political pressure on the agency to downlist and delist the fish at the earliest possible date. We urge USFWS to back away from the timetable-driven, "by-the-numbers" approach to recovery that is so evident in the draft goals document. Apparently healthy populations have been known to precipitously crash when diseases or environmental disasters occur. A habitat restoration-oriented model is much more likely to benefit species in the long term. Recovery goals should place as much emphasis on ensuring that a maximum amount of additional suitable habitat is made available, as on counting fish. Once downlisting or delisting has occurred, it is often much more difficult to protect populations from unforeseen disasters.

5) STUDY BENEFITS OF REDUCING DIVERSIONS & DEPLETIONS: The Upper Colorado River Endangered Fish Recovery Implementation Program has emphasized that endangered fish management strategies are designed to permit additional water storage and diversions in the future. LIVING RIVERS calls on USFWS to abandon this policy, as it biases the agency against considering potentially substantial recovery benefits. The USFWS should analyze in detail the expected benefits to the fish of reducing current diversions (and overall depletions), and provide a range of alternative scenarios for instituting cutbacks on water deliveries to aid fish recovery. Such criteria would be especially valuable in dry years when streamflows are dramatically reduced, and fish are often stressed.

6) REMOVE NON-NATIVE COMPETITORS AND PREDATORS: The USFWS should emphasize an aggressive program to remove introduced, non-native fish that compete with and prey on endangered fish. Much scientific work remains to be done to determine effective strategies for doing this, yet very little is currently being done. Indeed, throughout much of the upper and lower basins, "game fish" are still encouraged and stocked by state fish management agencies. USFWS should make recovery dependent on limiting or eliminating non-natives, including trout and other game species, wherever appropriate to achieve recovery.

Thank you for the opportunity to submit these comments. We look forward to publication of the final recovery goals, and we urge you to address the substantive issues we have raised, and implement all of our suggested changes.

Thank you for your consideration,

David Orr Director of Field Programs LIVING RIVERS PO Box 466 Moab, UT 84532

435-259-1063 fax 259-7612

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Last Update: October 30, 2007