14 May 2002

 

Wade Fredenberg

Fisheries Biologist

U.S. Fish and Wildlife Service

780 Creston Hatchery Road

Kalispell, Montana 59901

 

Dear Mr. Fredenberg:

 

The Montana Chapter of the American Fisheries Society (MCAFS) is an organization of professional fisheries scientists and students from agencies, universities, and the private sector across Montana.  Our objectives are: conservation, development, and wise utilization of Montana�s fisheries; promotion of the educational, scientific and technological development and advancement of all branches of fisheries science and practice; and exchange and dissemination of knowledge about fish, fisheries, and related subjects.   

 

The MCAFS would like to take this opportunity to comment and provide information on development of critical habitat designation for the threatened bull trout (Salvelinus confluentus) in Montana and range-wide.  The following are recommendations and biological information to assist the U.S. Fish and Wildlife Service (Service) with determination and designation of critical bull trout habitat to protect areas of habitat that are critical to conservation and recovery efforts.  We believe that the designation of critical habitat process will be an effective tool for bull trout conservation only if the process is conducted in a comprehensive and ecologically-based manner based on the best available scientific data.

 

As you are aware, over the past eight years, state, federal and private organizations have successfully worked together to develop a bull trout recovery plan in Montana (i.e. The Montana Bull Trout Restoration Team and the Montana Bull Trout Scientific Group).  During this planning process, status reports were prepared for bull trout populations in 12 restoration/conservation areas.  Each of these restoration/conservation areas consists of a number of critical populations.  In an effort to maintain self-sustaining populations that contain a full expression of life history forms and genetic diversity, �core areas� and �nodal habitats� were delineated for all critical populations.  Core areas are drainages that historically and currently support the strongest remaining populations of bull trout.  Nodal habitats are waters that provide migratory corridors, overwintering areas, critical overwintering habitat, or are otherwise critical to the population at some point during its life history.  Further, there are several �disjunct� populations with associated core areas and nodal habitats.  All these habitats are considered key to the continued existence of bull trout and are the highest priority for protection and restoration activities.

 

Therefore, based on the best available scientific data, we recommend that critical bull trout habitat should include all watersheds that contain core areas in the Clark Fork Recovery Unit as described in the Montana Bull Trout Status Reports.  The following are the Bull Trout Status Reports that list these important core areas (developed by the Bull Trout Scientific Group for the Montana Bull Trout Restoration Team).

  • Flathead River drainage bull trout status report (1995);

  • South Fork Flathead River drainage bull trout status report (1995);

  • Swan River drainage bull trout status report (1996);

  •  Lower Kootenai River drainage bull trout status report (1996);

  • Middle Kootenai River drainage bull trout status report (1996);

  • Upper Kootenai River drainage bull trout status report (1996);

  • Bitterroot River drainage bull trout status report (1995);

  • Blackfoot River drainage bull trout status report (1995);

  •  Lower Clark Fork River drainage bull trout status report (1996), including Graves, White Pine, Swamp, and Martin Creeks;

  • Middle Clark Fork drainage bull trout status report (1996);

  • Upper Clark Fork bull trout status report (1995); and

  • St. Mary River drainage bull trout status report (1996)

The upper Clark Fork and Flathead River systems in Montana harbor some of the few remaining bull trout strongholds in the Columbia River basin.  These populations occur in large areas of contiguous habitats that support a full expression of resident and migratory bull trout life history forms.  Migratory forms utilize tributaries for spawning and rearing, while resident forms complete their entire life cycle in the tributary stream in which they spawn and rear.  For example, in Montana, migratory bull trout make extensive migrations in the Flathead River system, while resident forms overwinter in tributaries to the Bitterroot River.  Migratory corridors (rivers and lakes) link seasonal habitats and provide critical rearing and overwintering habitat for all bull trout life history forms.  . Viable bull trout populations need quality connected habitat to maintain genetic diversity and dispersal among populations which is critical to the long-term persistence of bull trout range-wide.  

 

Therefore, based on the best available scientific data, we recommend that critical bull trout habitat should include all interconnected habitats essential to the development and persistence of all bull trout life history forms (e.g. nodal habitats) in the Clark Fork Recovery Unit.  These areas include:

 

  • The Flathead River drainage:  North Fork Flathead River, Middle Fork Flathead River, the upper mainstem Flathead River and Flathead Lake

  • South Fork Flathead River drainage:  South Fork of the Flathead River downstream from Gordon Creek, including Hungry Horse Reservoir;

  • Bitterroot River drainage:  East Fork of the Bitterroot River, the West Fork of the Bitterroot River, Painted Rocks Reservoir, and the entire Bitterroot River main stem;

  • Blackfoot River drainage: Blackfoot River, Clearwater River, and the Clearwater Chain of Lakes (Salmon, Seeley, Placid, Inez, Alva, Rainy, and Clearwater Lakes);

  • Lower Clark Fork River drainage: Noxon and Cabinet Gorge Reservoirs;

  • Middle Clark Fork River drainage: Thompson River, Flathead River, and Clark Fork River;

  • Upper Clark Fork River drainage: Clark Fork River from Warm Springs downstream to Milltown Dam;

  • Swan River drainage: Swan Lake and the Swan River upstream of the lake;

  • Lower Kootenai River drainage: Kootenai R iver and Kootenay Lake, B.C.;

  •  Middle Kootenai River drainage: Kootenai River between Libby Dam and Kootenai Fall s;

  • Upper Kootenai River drainage: Lake Koocanusa, the Kootenay River upstream of Lake Koocanusa, and the Tobacco River; and 

  •   St. Mary River drainage: The entire interconnected river/reservoir/lake system from St. Mary Falls, at the upper end of St. Mary Lake, downstream to the US/Canada border; including portions of the watershed occupied by bull trout upstream of Sherburne Dam, the frequently dewatered section of Swift Current Creek downstream of Sherburne Dam, and the headwaters of Lee Creek in Montana.

Further, we recommend that the Service should carefully consider designating critical habitat to areas that are not currently occupied by bull trout but that will be needed for successful recovery efforts.  Many populations currently occupy only a small percentage of their former distribution in Montana and range-wide.  These populations have been extirpated because of human impacts to the environment such as habitat degradation and fragmentation and negative nonnative species interactions.  In response to population declines, fisheries managers have focused on identifying, protecting, and restoring critical bull trout populations and the habitat on which they depend.  These areas should be protected to ensure the long-term viability of imperiled populations.

 

The bull trout represents a valued cultural and economic heritage in the United States.  We urge the Service to designate critical habitat to all watersheds that support core areas and nodal habitats in Montana.  Further, we encourage the Service to consider designating critical habitat to areas that are not currently occupied by bull trout but that will be needed for conservation of this threatened species.  Human development and resource extraction impact bull trout populations, and unless proper protection is established on critical spawning and rearing areas, these habitats will continue to be lost or degraded.  The critical habitat designation process is an opportunity to provide a regulatory process to protect and sustain our natural heritage for future generations to enjoy and appreciate.  We urge your agency to consider our recommendations and biological information with determination and designation of critical bull trout habitat in Montana and range-wide.

 

Sincerely,

 
Pat Clancey

Chapter President

Box 1336

Ennis MT  59729

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