August 11, 2003
Mr. Dennis Kubly
Bureau of Reclamation
125 South State Street
Salt Lake City, UT 84138-1107
Re: Proposed Modification to Mechanical Removal of Non-native Fish from the Colorado River in Grand Canyon Arizona, dated July 25, 2003
Via Fax and E-mail
Dear Mr. Kubly ,
Thank you for the opportunity to submit comments on Proposed Modification to Mechanical Removal of Non-native Fish from the Colorado River in Grand Canyon Arizona, dated July 25, 2003.
Living Rivers finds this proposed action constitutes improper science, thus an inappropriate deviation from the original objective. Living Rivers is also disappointed that this proposed action represents yet another example of how the Adaptive Management Program (AMP) is failing to address the long-term recovery needs for endangered fish, and merely perpetuating a reactive strategy with no demonstrated results.
1) No justification for altering the experiment
As noted in materials for the 13-14 August AMP meeting, it is clear that in-migration is occurring in the existing mechanical fish removal zone. The supplemental EA stated the contrary. (The EA should be re-written to reflect this new information, and released again for public comment.) Since there is no confirmation that the experiment is indeed permanently reducing non-native population to desired levels, there is no reason to contemplate any change in the experiment.
Second, while the experiment is certainly demonstrating that fish are being killed, there is no data to support the experiment is leading to improved Humpback Chub recruitment. It is improper to change the parameters of the experiment until such time as there is a demonstrated rational to do so. Such is not the case at present, especially, as noted above, with migration now well underway.
Third, there has been no independent review of this proposal, a consistent recommendation by the National Research Council and the National Academy of Sciences of such GCMRC activities.
2) Demonstrated lack of focus on the long term objectives.
The investment of AMP resources in contemplating and studying the alteration of an incomplete, and so far, inconclusive experiment is yet another unfortunate example of poor leadership within GCMRC and the AMP. There is an extensive amount of work that needs to be undertaken to help recover Grand Canyon's native fish, the principle charge of the AMP. After nearly two decades, seven under the direction the AMP, the results have been abysmal. This is in no small part due to wasted resources, such as plans to alter an experiment with insufficient justification to do so.
A more appropriate investment in resources would be to begin studying and implementing mechanisms to address the need to reduce non-native fish with natural, as opposed to mechanical approaches. An objective of the AMP is to reintroduce presently extirpated species, such as the Colorado Pikeminnow or Otter. Both such species would gladly feed on the non-native fish, likely at a much higher rate than the remaining natives.
With movement now by the AMP to address the need to warm the water, habitat conditions may be sufficient to support Pikeminnows. But the AMP need not wait until the temperature issue has been resolved to implement such a reintroduction, as it may petition to so for experimental purposes, despite the fact that it is unlikely that the Pikeminnow can reproduce in the present system. However, if it appears that they are helping to significantly reduce the non-native population, with minimal impact to the native fish, and thus aiding in Humpback Chub recruitment, this would be cause to accelerate efforts to realize this species recovery as well.
While the Park Service has so far been resistant to Otter reintroduction due to inconclusive evidence regarding which sub-species dominated Grand Canyon habitat, it is clear that the increased interest and assumed need to increase predation on non-native fish, amplifies the call for implementation of a reintroduction plan.
Such nature-based proposals to mimic and rebuild the natural system should be the focus of the AMP, not short-term efforts to modify inconclusive experiments.
Thank you for your attention to these concerns.
John Weisheit Conservation Director