photo courtesy Skip Dixon via Terry Gunn
The National Park Service is conducting an Expanded Non Native Aquatic Species Management Plan Environmental Assessment (EA) that includes elements having a potentially damaging impact on the Lees Ferry trout fishery and the business and guide services dependent on that fishery. Submitting your comments is the only way to protect and support the fishery.
The Park Service is proposing a wide range of actions, including electrofishing mechanical removal of brown trout, for controlling or eradicating non native species that may pose a threat to native aquatic species. Except for mechanical removal of brown trout in Lees Ferry/Glen Canyon the other proposed actions would not impact the trout fishery.
The EA proposes electrofishing mechanical removal in Lees Ferry/ Glen Canyon with “long‐term, intensive and repeated electrofishing “. Collateral damage to the rainbow trout fishery from mechanical removal on the proposed massive scale will be unavoidable. Rainbow trout not removed at the time of brown trout removal will be intensely and repeatedly shocked as the electrofishing process progresses along the river and continues over recurring lengthy periods of time. Surviving rainbow trout, while recovering, would be unfishable for extended periods. This action would have a catastrophic impact on the quality of the Lee Ferry trout fishery, the welfare of the local community, and the regional economic benefits tied to the fishery. We strong oppose this action for the following reasons:
(a) We are unaware of any scientific data which indicates that electrofishing mechanical removal will be an effective tool for controlling brown trout in the main stem of the Colorado River. In fact, intense, repeated and long term main stem electrofishing throughout the upper Colorado River Basin has been largely ineffective at managing or controlling nonnative fish. The proposed removal action as a means to control brown trout on the scale and in a setting like Glen Canyon has little to no prospect of attaining the EA’s purpose and need objective.
(b) Many more rainbow trout would be shocked for each brown trout captured. The focus of mechanical removal would be on shoreline areas that are also prime fishing areas. In addition to direct rainbow trout mortality, there is ample scientific literature that shows that the behavior of salmonids that are subject to electrofishing is affected by the electrofishing, which would impact angler catch rates and satisfaction.
(c) The collateral damage to the Lees Ferry rainbow trout fishery from mechanical removal and the public perception it creates will decimate an already distressed economic community that has been impacted by dam operations. In addition, National Park Service and Bureau of Reclamation opposition to actions that would benefit the trout fishery has resulted in ongoing damage to visitor use and experience and has had a deleterious socioeconomic and environmental social justice effect on the local community.
(d) Native American tribes have long objected to mechanical removal efforts below Glen Canyon Dam as an affront to their religious and spiritual beliefs. As such we believe it is unacceptable for the National Park Service to propose mechanical removal as a strategy for managing brown trout in Lees Ferry/Glen Canyon.
(e) The cost for implementing long term intensive and repeated electrofishing would be very high and put a major drain on Department of Interior Agencies budgets which could be used to address other priorities.
(f) Possible or potential causes for the recent increase in brown trout are ignored i.e. sequential fall High Flow Events, warmer water temperature, and fall High Flow Event related aquatic food base shift, etc.
(g) Recent sampling results are ignored that show a potential halt or change in the direction of brown trout numbers,
(h) Marble Canyon, the sixty river miles between Lees Ferry and native fish at the Little Colorado River, is ignored. No actions are proposed in Marble Canyon to address present or future and immediate threats to native fish in Marble Canyon or at the Little Colorado River,
(i) Park Service authority and control are asserted over the Colorado River fishery by relegating Arizona Game and Fish Department to a coordinating/cooperating agency as a fishery manager with only the Park Service having decisional authority,
(j) The Bureau of Reclamation that has authority over dam operations isn’t included in the EA and therefore potential flow related causes and related corrective actions are not available.
By submitting your comments in opposition to mechanical removal of brown trout in Glen Canyon you will affirm angler support, demonstrate the importance of the Lees Ferry trout fishery, and provide direction to the Park Service for acceptable alternatives in the EA.
Submit personal scoping comments by copying and pasting this browser link:
Commenting using the provided email form is easy and fast. In commenting your personal view is what’s important, particularly what having angling opportunities available means to you and what the Lees Ferry trout fishery represents to you. Use or don’t use some of the reasons above whatever is consistent with your view. Comments are more effective written in your own words rather than cut and paste. There will be organizational comments submitted but individual comments are equally as important in putting the Park Service on notice to not unnecessarily jeopardize the Lees Ferry trout fishery. Comment cutoff date is midnight January 5, 2018.
The Park Service Scoping Notice containing additional detail is available at: