Mr.
Steve Williams
Director,
USFWS
3245
Interior Building
1845
C Street NW
Washington
DC, 20240
July
12, 2003
Dear
Director Williams:
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. Of particular
interest to our membership is the long-term conservation of Montana’s native
fishes.
Our
organization is very concerned with apparent lack of progress at implementing
the recovery plan for endangered pallid sturgeon in the upper Missouri River Basin.
At our 2003 annual meeting, we heard a panel of experts involved in
recovery efforts provide a dismal outlook for the pallid sturgeon.
The situation is dire enough that extinction seems imminent.
We strongly appeal to you to take immediate action to ensure that the
Recovery Plan is being implemented by a functional recovery team Please
consider the following :
Lack
of a collaborative decision-making process and a non-functioning Recovery Team.
The designated recovery team for pallid sturgeon is inactive, at best.
The Team has not convened a meeting in two years.
In these two years, priority tasks identified in the recovery plan have
lain dormant. Rather than a
constructive, collaborative approach to recovery, it appears that decisions are
being made unilaterally, without regard to the expertise of the highly qualified
network of fishery professionals on the Recovery Team. The
lack of leadership, collaboration and cooperation among the upper basin working
group has resulted in setting back sturgeon recovery and has created a very
non-productive work environment for the group as a whole. This viewpoint is
apparently shared by many
professionals directly involved in the working group across agency boundaries.
Given the critical state of pallid sturgeon in Montana there is no room
for wasting time and resources. Please
consider a review of decision-making processes and ensure that leadership,
cooperation, and collaboration become integral in the recovery effort.
Lack
of dedicated USFWS funding toward recovery of Pallid Sturgeon in the upper
Missouri Basin and hatchery-related problems. The
only source of funding for pallid sturgeon recovery efforts apparently comes
from the Western Area Power Administration (WAPA).
This “soft” money is simply not a reliable, long-term funding
source for pallid sturgeon recovery.
The USFWS has a responsibility to plan adequate out year budgets
dedicated to the recovery of the species. The recovery program is focused on
hatchery production and supplementation and yet even this component is not
adequately funded. We were informed that the Gavins Point National Fish Hatchery
does not have sufficient capacity to hold the required number of brood fish,
even though the manager of that facility has been requesting funding to expand
that facility since 1993. Recent
correspondence suggests that Gavins Point will run out of space for pallid
sturgeon by the end of 2003 or 2004. If
adequate space is not available, the primary goal of a genetically diverse brood
stock cannot be met. Providing
funding to support an effective multi-hatchery framework to produce healthy fish
for stocking is an immediate concern. It
appears there is an unacceptably high mortality rate associated with capture,
handling, and spawning of wild fish during gamete collection. It also
appears that the Garrison NFH has many fish health problems.
Because of these issues, we cannot rely on Garrison NFH to produce pallid
sturgeon of sufficient quality and quantity to sustain recovery efforts.
Habitat
issues are priority for recovery. The
pallid sturgeon Recovery Plan, issued in 1993, identified habitat loss as the
primary cause of the decline of the species.
Restoration of riverine habitat, emulation of the natural hydrograph, and
restoration of the natural temperature regime were identified as the top three
recovery measures in the Plan. However,
10 years later, precious little progress has been made on these issues and time
is running out. Recent projections
indicate both populations of wild pallid sturgeon in Montana will become extinct
within 10-15 years. The artificial
propagation program is fraught with difficulties and there are no guarantees it
will be successful as a stop-gap measure to prevent extinction.
Consequently, we believe that timely restoration of more natural river
flows and temperatures is critically important in order to provide the remaining
wild adult fish every opportunity to reproduce naturally before they disappear
from the system.
Collection
of viable gametes from adult fish in both recovery areas in Montana and the
recent discovery of naturally produced pallid sturgeon larvae in the wild
indicate the remaining adults are fully capable of producing viable progeny.
It appears there has been a profound change in river habitat, which has
eliminated successful natural recruitment for the past 40 years or so.
Radio-telemetry and field observations of adult fish in both Montana
populations during the spawning season over a period of several years confirm
these fish do not make extensive mass upstream migrations (i.e. Bramblett and
White 2001) and likely spawn in preferred habitats only a few miles upstream
from major reservoirs. Laboratory
studies of larval drift rates suggest any naturally produced larvae drift into
downstream reservoirs, which apparently do not provide suitable rearing habitat. The recent discovery of naturally produced larvae near the
headwaters of Lake Sakakawea tends to confirm this interpretation.
Consequently, we believe the best way to encourage successful natural
reproduction in the upper river is to restore appropriate flows and temperatures
over river reaches of adequate length to allow natural drift and settlement of
larvae. Alternatively, additional
river miles could be re-created by substantially lowering reservoir operating
pools, which is likely a far less palatable alternative.
We
believe the 185-mile reach of the Missouri River from Fort Peck Dam to the
Montana/North Dakota border within Recovery Area 2 represents the best possible
remaining pallid sturgeon spawning and rearing habitat in the Upper Missouri.
Much of this reach contains sandy substrates, which is preferred by
pallids (Bramblett and White 2001) and this Recovery Area also contains one of
the highest known remaining populations of wild adult fish.
However, these fish make limited use of the “Fort Peck” reach,
probably because of a radically altered hydrograph and temperature regime caused
by cold-water releases from Fort Peck Dam.
We
are pleased that the Fish and Wildlife Service has issued Biological Opinions
that appear to obligate the Corps of Engineers to mimic natural flows (high in
the spring, low in the summer) in the Missouri River.
We are disappointed the Corps has failed to produce these flows and, in
particular, failed to produce low summer flows in recent drought years, which
could benefit pallids and other sensitive native fish species in the river.
Restriction of summer flows would also conserve water in Fort Peck
Reservoir to hasten the arrival of a time when a “spring rise” could be
produced. The perilous situation
faced by the few remaining wild adult pallids dictates that a manipulated
“spring rise” should be produced below Fort Peck at every opportunity over
the next 15 years, rather than the “1 of 3” years proposed in the most
recent Biological Opinion. We
strongly urge the Fish and Wildlife Service to fully and forcefully exercise all
of its authority to ensure these critically important flows occur as soon and as
often as possible for the foreseeable future.
We
are hopeful this letter will generate some productive dialogue among
administrators, initiate some
direct oversight of current pallid sturgeon recovery efforts, and initiate an
investigation into direct actions which will improve the situation and set the
recovery program back on course. We
believe that these shortfalls in
the recovery program under the leadership of USFWS are
contributing to the accelerated extinction of pallid sturgeon in the Upper
Missouri River Basin. Our
organization is unwilling to stand
aside and watch as administrative factors
contribute to a profound loss of Montana’s
natural heritage.
Thank
you for taking our concerns into consideration and please inform us of your
proposed actions in remedying this situation
Sincerely,
Patrick Byorth, President
Montana
Chapter American Fisheries Society
REFERENCES
Bramblett,
R.G., and R.G. White. 2001. Habitat
use and movements of pallid and shovelnose sturgeon in the Yellowstone and
Missouri Rivers in Montana and North Dakota.
Transactions of the American Fisheries Society 130:1006-1025.
Cc:
Ralph Morgenweck, Regional
Director
Conrad Burns, U.S. Senate
Max Baucus, U.S. Senate
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