389 Rick Oshay Road
Whitefish, Montana 59937
amyclint@montanasky.us
31 August 2004
Montana Fish, Wildlife & Parks Commission
1420 East Sixth Avenue
Helena, Montana 59620
Dear Commissioners:
The Montana Chapter of the American Fisheries Society (MCAFS) appreciates the opportunity to comment and provide scientific information regarding the recent proposal to stock sterile walleye west of the Continental Divide, thereby lifting the 1989 ban by the Montana Fish, Wildlife & Parks (FWP) Commission. One of our objectives is the conservation, development and wise utilization of Montana’s fisheries. We are keenly interested in the conservation of native and recreational fisheries in Montana, and we believe that the proposal will compromise our mutual objectives.
MCAFS is adamantly opposed to stocking sterile or fertile
walleye anywhere west of the Continental Divide, including closed-basin lakes.
We support maintaining the existing ban on stocking walleye west of the
Continental Divide, and strongly urge the Commission to reject the current
stocking proposal.
As you are aware, in 1989 an Environmental Assessment (EA)
was completed to assess the potential impacts of walleye introductions beyond
their current range in Montana. Due
to unsuitable habitat conditions, potential impacts to recreational and native
fisheries, and other available opportunities to improve or develop walleye
fisheries within their current range, it was concluded that it was not prudent
or necessary to expand the range. Accordingly,
the FWP Commission voted to set a policy of no stocking of walleye west of the
Continental Divide due to biological and social concerns.
The biology of walleye and the aquatic environments on the west side has
not changed since the 1989 EA. It
may appear, however, that social demands have changed due to a vocal minority.
We believe that a policy change of this magnitude based on social demands
would set a dangerous precedent for future management of fish and wildlife in
Montana, and result in deleterious impacts to aquatic ecosystems.
Therefore, we urge the Commission to use the best available scientific
information to ensure the long-term health and persistence of Montana’s
fisheries resources, and thus reject the proposal to introduce an exotic, top
predator into western Montana.
Currently, there is no proven procedure to produce 100%
sterile walleye. This is a major
limitation because the proposal is founded on the fact that sterile walleye will
be used for introductions in western waters. Female adult walleyes produce approximately 25,000 eggs per
pound, which has proven to be more than enough reproductive capacity to cause
significant impacts on existing fisheries, including Canyon Ferry Lake.
Therefore, if a few fertile fish are accidentally released in a given
water body, because there is not a 100% success in sterility procedures, there
could be significant impacts to other waters.
This threat is exacerbated by the high rate of illegal fish introductions
in western Montana.
Introduction of walleye will provide a source for
additional illegal introductions that have already impacted fish populations and
aquatic ecosystems. Introductions
of walleye elsewhere have displaced native fish species and ultimately impacted
sport fisheries for other species, primarily due to increased predation and
competition. Science has
demonstrated that non-native fish introductions are a primary cause of declines
in fish abundance and diversity throughout Montana and worldwide.
The bull trout is currently listed under the Endangered Species Act (ESA)
and the westslope cutthroat trout is classified as a species of special concern.
Both fish have declined due to habitat loss and negative interactions
with non-native fish species. The
proposed walleye stocking proposal may jeopardize or delay bull trout recovery
efforts (i.e., delisting) and may result in listing westslope cutthroat trout if
populations are impacted and continue to decline.
A major problem of introducing walleye west of the
Continental Divide is that people will likely move them to other waters
illegally. In Region 1 alone, FWP
has documented 251 illegal fish introductions into 134 waters, which is more
than half the 466 illegal introductions to 266 waters statewide.
Further, despite the existing ban on stocking west of the Continental
Divide, walleye have been illegally planted in eight waters in Region 1 and 2,
including Lake Five, Noxon Rapids Reservoir, Milltown Dam, the Clark Fork below
Milltown Dam, Placid Lake, Salmon Lake, Church Slough (Flathead River) and the
Bitterroot River. In Noxon Rapids
Reservoir, the walleye population is apparently reproducing and self-sustaining.
Therefore, legal introductions will likely result in additional illegal
introductions (i.e., bucket biology) that will decrease FWP’s ability to
effectively and efficiently manage our fisheries, cost millions of dollars in
restoration, such as the costs incurred with perch in Lake Mary Ronan, and
result in further population declines of native species, including the
threatened bull trout and westslope cutthroat trout.
The biology of walleyes makes them poorly suited for most
waters west of the Divide. Walleye
require large bodies of water (over 250 acres) that contain abundant near-shore
habitats to complete their life cycle and forage base requirements.
Water bodies that are suitable for viable walleye populations should
include closed-basin lakes (250 acres or larger) that have sufficient habitat,
including, moderate to high productivity, a good forage base, and no salmonids,
species of special concern, or recreational fisheries that could be impacted.
However, there are few closed-basin lakes that satisfy these criteria,
but most of these lakes already have productive sport fisheries that will likely
be adversely impacted. In Region 1,
only 2 potentially suitable lakes have been identified, Spar
(382 acres) and Echo (674 acres) Lakes.
Spar Lake (situated at 3300 ft. elevation) is an oligotrophic lake (low
productivity) with steep bank drop-offs (limiting the amount of shoreline
habitat) and already supports a popular salmonid fishery.
Echo Lake is shallow productive lake that supports an extremely popular
largemouth bass fishery that would likely be jeopardized by the establishment of
walleye. Therefore,
according to the stocking criteria, there are few opportunities for walleye
introductions in Region 1 and elsewhere in western Montana.
Despite the
proponent’s claims, introductions of walleye may not benefit local economies
and create fishing opportunities. In
Montana, Canyon Ferry Lake provides a good example of the potential economic
loss from introducing non-native walleye into a water body. There is a misperception that the walleye boom in Canyon
Ferry Reservoir has increased fishing pressure and benefited the local economy.
In fact, fishing pressure has not significantly increased during the
walleye boom because spring, fall and winter fishing for perch and
trout has declined substantially due to walleye predation on these popular sport
fish. There were approximately
92,000 angler days of fishing use on Canyon Ferry in 2003, compared to over
100,000 angler days when trout and perch were at their peak in the 1980's.
Also, there were about 65,000 angler days in early 1990's when trout
fishing was poor. Canyon Ferry Lake
does not show benefits to local economies and fishing opportunities at this
time.
An assessment of new forage species introductions needs to be considered in tandem with the walleye proposal, because walleye advocates will likely request forage fish introductions in the future. Additionally, walleye are known to devastate forage fish communities (including yellow perch). This often results in a diminished overall fishery and creates a need to expend more money on supplementation. Forage fish stocking requests (i.e., spottails, cisco, smelt, gizzard, shad etc.) usually follow closely on the heels of walleye introductions due to unrealistic expectations by the angling community. The impacts of walleye on existing fish communities are usually profound and measurable within 5 to10 years. Based on experiences in Wyoming, Al Conder of Wyoming Game and Fish advised Montana to stay with basics and stress the concept of the trophic pyramid. This will be especially useful in the relatively unproductive waters in the west.
Finally,
we believe that the Commission
should carefully consider the recommendations of fisheries experts throughout
Montana. The people of Montana rely
on state and federal officials to make wise decisions on the use of our
fisheries resources to provide recreational fishing opportunities and conserve
native fishes for future generations. The
FWP Fisheries Division supports the existing ban on walleye plants west of the
Divide. FWP’s recommendation
should be carefully considered, as they are the experts in fisheries management
and follow a clear mandate to protect and conserve native fish and provide
recreational fishing opportunities. Past
experience has shown that non-native species introductions can devastate local
fisheries in Montana, such as walleye in Canyon Ferry, lake trout in Flathead
Lake, and northern pike in the Clearwater Chain of Lakes, to name a few.
Thank you for your interest and mandate to manage and conserve our fisheries resources in Montana, as the decisions made now will influence these important conservation areas for future generations. The proposal to stock walleye west of the Continental Divide should be rejected for the biological, economic, and social issues and concerns addressed in this letter. We urge you to consider our recommendations to conserve native and sport fisheries in western Montana. Thank you for the opportunity to comment, and we look forward to providing oral comments at the Commission meeting in Missoula on September 8, 2004.
Sincerely,
Clint Muhlfeld
President, Montana AFS