August 22, 2001
Fisheries Division
Montana Fish, Wildlife and Parks
4600 Giant Springs Road
Great Falls, MT 59405
Subject: Cottonwood Creek Cutthroat Trout Restoration Project
The Montana Chapter of the American Fisheries Society would like to express our support for the proposed rehabilitation of Cottonwood Creek in the Beartooth Wildlife Management Area. Restoration of a westslope cutthroat trout population in this stream would be an important step toward improving the status of this imperiled native trout species in central Montana. The project would provide an opportunity to replicate a wild native westslope cutthroat trout population facing a high risk of extinction from another stream in the middle Missouri River basin.
There is a substantial body of scientific evidence and professional experience which supports the use of rotenone in the manner you are proposing to safely remove non-native fish and restore native fisheries with minimal other environmental consequences. We feel your proposal poses very little risk to downstream fisheries while potentially enhancing the viability of a donor cutthroat trout population. The loss of a small non-native brook trout fishery is insignificant and a very minor sacrifice to make for restoring native westslope cutthroat trout. However, we do feel that safeguards should be used to avoid unnecessary adverse effects on native amphibians which may be present in the Cottonwood Creek drainage. Application of rotenone after mid-August when amphibian larvae will have completed metamorphosis to adults should avoid the most serious effects on these populations. Off-channel wetlands which do not support fish but may provide breeding or foraging habitat for amphibians should be spared from chemical treatment.
Small projects like Cottonwood Creek WCT Restoration offer an important opportunity for FWP to demonstrate to the public that chemicals can be used safely and effectively to restore native fisheries. We applaud this effort and hope it will lead to more widespread restoration projects.
Sincerely,
Michael Enk
President, Montana Chapter AFS
c/o USFS, PO Box 869, Great Falls, MT 59403
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