2817 Third Ave. North
Great Falls, MT 59401
March 18, 2004
General
William Grisoli
Division
Engineer
U.S. Army Corps of Engineers
Northwestern
Division
12565
W. Center Road
Omaha,
NE 68144-3869
Attention: Missouri River Master Manual FEIS
Dear General Grisoli,
I am writing on behalf of the Montana Chapter of the American Fisheries Society to provide comments on the Final Environmental Impact Statement (FEIS) of the Missouri River Master Water Control Manual Review and Update prepared by your agency and dated March, 2004. The American Fisheries Society (AFS) is the oldest and largest professional society representing fisheries scientists. The mission of the AFS is to improve the conservation and sustainability of fishery resources and aquatic ecosystems by advancing fisheries and aquatic science and promoting the development of fisheries professionals. The Montana Chapter is comprised of approximately 260 fisheries professionals representing state and federal agencies, tribal governments, universities, and the private sector in our state.
Of particular interest to our membership is the long-term conservation of Montana’s native fishes. The 185-mile reach of the Missouri River between Fort Peck Dam and the North Dakota border is of high importance due to the diverse native fish community present. This reach supports 29 of Montana’s 56 native fish species. This list includes the federally Endangered pallid sturgeon and 6 Montana fish Species of Special Concern, including shortnose gar, sicklefin and sturgeon chub, sauger, blue sucker, and paddlefish.
Our organization is very concerned that the Master Manual’s Preferred Alternative and the associated Final Environmental Impact Statement (FEIS) represent more of the status quo and lack any ecologically meaningful progress towards recovery of the Endangered pallid sturgeon. The status quo caused the decline of the pallid sturgeon; continuing the status quo will cause the pallid sturgeon’s extinction. For that reason, we do not support the Preferred Alternative. The Missouri River must be operated to mimic a more natural hydrograph as soon and as often as possible. This regime includes a spring rise, reduced summer flows, and somewhat reduced winter flows. Of the alternatives presented in the FEIS, the GP2021 alternative best meets these requirements. In order to implement this alternative, it is imperative that drought conservation efforts commence immediately, and water savings must be used to bring Fort Peck Reservoir up to the spillway so that a spring pulse can occur in the reach below Fort Peck Dam as soon as possible. Our specific concerns are outlined below.
There
is no commitment to restoring conditions that will prevent extinction of the
pallid sturgeon.
The FEIS Summary states “Native fish in the river reaches are naturally adapted to the high, warm, and muddy spring and early summer flows, and the lower late summer and fall flows characteristic of the historic Missouri River.” This statement is correct, yet the Preferred Alternative does virtually nothing to re-establish these conditions. The Preferred Alternative will actually decrease warmwater (native) fish habitat relative to the current Water Control Plan (CWCP; Master Manual Summary, Figure 11). We note that the CWCP represents the conditions under which the pallid sturgeon declined to the point of becoming endangered; the Preferred Alternative, if implemented, will likely represent the conditions under which the pallid sturgeon becomes extinct. Time is rapidly running out; the best science indicates that the strongest population of Endangered wild pallid sturgeon (in the Yellowstone-Missouri rivers confluence area) will be extirpated by 2018 (Kapuscinski 2003).
The
best science indicates that we know how to recover pallid sturgeon.
We
disagree with the statement that “there is scientific uncertainty regarding
the lifecycle requirements of pallid sturgeon” (Page 8-1 FEIS).
The life cycle requirements for pallid sturgeon are conceptually simple:
they are those conditions with which the species evolved.
The pallid sturgeon did not evolve in a river system with dams and
navigation; it evolved in a free-flowing river system.
The pallid sturgeon cannot adapt fast enough to the change in riverine
processes caused by dams and navigation. In
contrast, humans are an adaptable species; we can change our behavior.
Therefore, to recover the pallid sturgeon, some approximation of pre-dam
conditions must be restored. This
has been known for over 10 years. The
Pallid Sturgeon Recovery Plan (Dryer and Sandvol 1993) states that the first
action needed is to “Restore habitats and functions of the Missouri and
Mississippi River ecosystems…”; yet to date there has been no meaningful
progress towards such restoration.
The
Preferred Alternative increases coldwater fish and lake fish habitat and
decreases warmwater and native river fish habitat.
This emphasis on non-native coldwater fishes is clearly inappropriate. There are no native coldwater fish to the entire Missouri River below Ft. Peck dam. Managing for nonnative coldwater fish is at the expense of the native species, especially the Endangered pallid sturgeon, is irresponsible and inconsistent with the intent of the Endangered Species Act.
Adaptive
management requires a change in management in order to work.
Under the Preferred Alternative, there is no meaningful change in river operations. The only substantial change predicted by models in the FEIS is for piping plover and least tern habitat. The model predictions for fish habitat impacts are all very slight (Figure 11, FEIS Summary). Adaptive management, like any experiment, requires a change in order to have a response to measure. The lack of any significant change in river operations is inconsistent with the basic principles of adaptive management.
We
encourage you to take meaningful actions to restore riverine function and
prevent the extinction of pallid sturgeon.
As stated in the FEIS Summary “Native fish in the river reaches are naturally adapted to the high, warm, and muddy spring and early summer flows, and the lower late summer and fall flows characteristic of the historic Missouri River.” Unless meaningful, aggressive action is taken to restore the riverine functions of hydrograph, thermograph, and sediment transport, we will very likely witness the extinction of wild pallid sturgeon in our lifetime, and even perhaps within the span of our professional careers. While we applaud your efforts to restore river function by land acquisition and reopening old oxbows and chutes, we believe the maintenance of aquatic habitat is most effectively and economically done by letting the river do the work.
We appreciate the opportunity to offer our comments on the FEIS. We believe the Preferred Alternative should be abandoned and replaced with an earnest effort by the Corps of Engineers to restore the Missouri River to a functional, self-sustaining river that is capable of maintaining healthy populations of native fishes.
Sincerely,
Stephen A. Leathe
President
C: Mr. Ralph Morganweck, Regional Director USFWS
References
Dryer, M. P., A. J. and Sandvol. 1993. Pallid sturgeon recovery plan. U.S. Fish and Wildlife Service. Bismarck, North Dakota.
Kapuscinski, K. 2003. Abundance of wild pallid sturgeon in recovery-priority management area #2 of the Missouri and Yellowstone rivers during 1991-2002. Montana, Fish, Wildlife, and Parks, Helena.
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