May 21, 2001
Jim Vashro
Region One Fisheries Manager
Montana FWP
490 N. Meridian Road
Kalispell, MT 59901
Dear Jim:
Thank you for your letter requesting our support for the hybrid trout removal project in mountain lakes of the South Fork Flathead River basin. It is unfortunate that the initial EA for use of motorized equipment to implement this project has generated more confusion and opposition than informed comment about the overall merit of the plan. To be frank, we were not at all pleased to discover the Montana Chapter of the American Fisheries Society listed among the groups that �have endorsed the project� in the initial EA and in a Hungry Horse News article. This was, at best, a presumptuous statement considering that we were never formally asked to review or comment on the specifics of this proposal.
As a signatory to the Westslope Cutthroat Trout (WCT) Conservation Agreement, we do fully support Objective 1 of the Agreement: �Protect all genetically pure WCT populations�. We also recognize the importance of the South Fork Flathead River basin as the largest-remaining interconnected core habitat for native WCT, and the need to address the genetic threat from non-native and hybridized trout in headwater lakes. Therefore, we agree in principle that removing these trout is consistent with the Conservation Agreement. There is no doubt that use of motorized equipment in the wilderness to implement this plan is more efficient and probably less impactive in the long term to local environments. But this may ultimately be a social issue where some compromises become necessary to gain public acceptance. A more limited use of motorized equipment may be feasible for some of the lakes.
It is not possible for us to provide unqualified support for poisoning and repopulating all the mountain lakes with a single approach. We expect that many biological and social issues will need to be addressed in the individual EAs for treating each lake. It seems most prudent to us to identify the lakes which pose the greatest threat to WCT genetic integrity in the South Fork Flathead River basin, and to develop specific proposals to reduce or eliminate the threat from these lakes first. As these lakes are successfully treated and rehabilitated, public skepticism and resistance may diminish. Subsequent proposals will certainly benefit from experience gained in the first treatments, and adjustments can be made to improve effectiveness and test rehabilitation alternatives. Launching a more broad scale, all-encompassing plan from the start may prove to be too threatening to many different interest groups and could generate an insurmountable public backlash.
We believe that many issues must be carefully considered in developing the aquatic rehabilitation plan for each lake. Some critical questions include:
- Should the lake be left fishless (return to historical condition) to best protect the local
adaptations of downstream extant WCT populations and to provide better habitat for
native amphibians and invertebrates highly vulnerable to fish predation?
- What is the best WCT source for rebuilding the lake fishery? Can a downstream pure
WCT population or other nearby wild WCT population serve as the donor?
- Is the �swamp out� approach really necessary to neutralize the hybrid threat from the
lake? Is it consistent with preserving the genetic diversity of all remaining pure WCT
populations?
- How can opportunity and motivation for sabotage of the rehabilitation effort be
minimized?
We hope these comments are useful to you and we welcome the opportunity to provide further review as this WCT protection plan is developed. Although we have concerns
about specific rehabilitation alternatives for the lakes, we commend your staff for taking the initiative to address existing threats to native WCT in the South Fork Flathead basin.
Sincerely,
Michael Enk
President, Montana Chapter AFS
c/o USFS
PO Box 869
Great Falls, MT 59403