# Mashkiiziibii Sea Lamprey Stewardship Plan (2024)

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URL: https://www.frixlaw.com/law-library/documents/tribal%3Abad_river_chippewa%3Afecdb4f61109d0d6

## Record

- **Collection:** Tribal code
- **Document type:** Tribal code

## Text

Mashkiiziibii Sea Lamprey Stewardship Plan

February 2, 2024

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TABLE OF CONTENTS
Acronyms .................................................................................................................................................................. 2
Executive Summary ................................................................................................................................................... 2
Mashkiiziibii Sea Lamprey Stewardship Plan Goal .................................................................................................... 3
Description of the Bad River and its Fishery .......................................................................................................... 4
Sea Lamprey .............................................................................................................................................................. 7
The History of Sea Lamprey Activities in the Bad River Watershed ......................................................................... 8
Memorandum of Stipulations ................................................................................................................................. 10
Non-target Organisms ............................................................................................................................................. 10
Options for Supplemental Controls ......................................................................................................................... 13
Summary and Recommendations ........................................................................................................................... 18
References............................................................................................................................................................... 20
Appendices.............................................................................................................................................................. 23

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Acronyms
GLFC
MLC
MNRD
PE
SLCP
SMRT
SOP
TFM
USFWS
YOY

Great Lakes Fishery Commission
Minimum lethal concentration
Mashkiiziibii Natural Resources Department
Population estimate
Sea Lamprey Control Program
Sterile Male Release Technique
Standard Operating Procedures
Lampricide - 3-trifluoromethyl-4-nitrophenol
United States Fish and Wildlife Service
Young of year

Executive Summary
The Bad River, a highly productive Lake Superior tributary, drains approximately 659,000 acres
and provides more than 391 miles of cold and cool-water fish habitat. Since the discovery of the
first sea lamprey in the Bad River during 1955, the river has developed into the largest sea
lamprey producing tributary on the south shore of Lake Superior. Over the past six decades,
control of sea lampreys in the river has been maintained primarily through lampricide
treatments. The U.S. Fish and Wildlife Service (Service), in partnership with the Great Lakes
Fishery Commission (GLFC), controls sea lamprey populations in the Great Lakes. Vision
statements included in the Bad River Band of Lake Superior Chippewa Indians (Band) Integrated
Resource Management Plan and the GLFC Strategic Vision address protecting the environment
by reducing the use of chemicals in the river. The GLFC continues to investigate and develop
alternatives to chemical control of sea lampreys. Barriers are currently the only viable alternative
to lampricide treatments. A suite of experimental removal options may also be considered as
supplemental methods of control. The goal of the Mashkiiziibii Sea Lamprey Stewardship Plan is
intended to eventually reduce the use of lampricide in the Bad River by providing an effective
and dynamic integrated plan based on good science and the vision statements of the Bad River
Band and the Great Lakes Fishery Commission.

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Mashkiiziibii Sea Lamprey Stewardship Plan Goal
The goal of the Mashkiiziibii Sea Lamprey Stewardship Plan (Plan) is to provide an effective and
dynamic integrated plan based on the best available knowledge and the vision statements of
the Band, the GLFC, and the Service.
Looking forward to the Seventh Generation, the Band hopes to achieve the following vision
of the Bad River Indian Reservation:
Our vision is of a Reservation where all living things are in natural balance and are no longer
threatened with negative anthropogenic (human-made) impacts; where all individuals and
institutions value the gifts of Mother Earth and willingly choose to act in a manner which
ensures achievement of sustainable environmental and economic goals; where every Bad River
member, young and old, shares in the benefits of a healthy environment; where each Bad
River member maintains the traditional cultural values necessary to live harmoniously with the
natural world; where every Bad River member accepts the personal responsibility and
challenge of pollution prevention in his or her daily life, and is committed to moving from a
consumer-oriented society to a conservation-minded society; where the Bad River Band gives
high priority to the protection of its environment, its natural resource base, and the functions
of the natural systems on which all life depends; where the majority of the Bad River Band's
subsistence needs are provided for by the local community (Elias, 2001).

The vision statement on integrated sea lamprey control contained in the Strategic Vision of the
Great Lakes Fishery Commission (2021-2025) (GLFC 2001):
The GLFC will suppress sea lamprey populations to levels that permit achievement of fish
community objectives for each Great Lake and to continue investment in research and
development of supplemental methods to augment the traditional sea lamprey control program.

The vision statement of the Service:
We will continue to be a leader and trusted partner in fish and wildlife conservation, known for
our scientific excellence, stewardship of lands and natural resources, dedicated professionals, and
commitment to public service.

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Description of the Bad River and its Fishery
The Bad River system provides more than 391 miles of cold and cool-water fish habitat and drains
approximately 659,000 acres. Major cold-water tributaries to the Bad River include the Potato,
Tyler Forks, Brunsweiler, White, and Marengo rivers. Within the exterior boundaries of the Bad
River Reservation (Figure 1), the Bad River system is composed of approximately 200 miles of
stream.
The main stem of the Bad River (Figure 2), downstream from the confluence with the Marengo River,
supports a diverse fish community which includes lake sturgeon/namé (Acipenser fulvescens) and
walleye/Ogaa (Sander vitreus). Both species are anadromous, although resident populations exist in
the river. Other anadromous fishes found in the lower Bad River include white (Catastomus
commersoni), longnose (Catastomus catastomus), silver (Moxostoma anisurum), and shorthead
redhorse (Moxostoma macrolepidotum) suckers/Namebin.
Resident fishes in the lower Bad River include northern pike/Ginoozhe (Esox lucius),
muskellunge/Maashkinoozhe (Esox masquinongy), yellow perch/Asaawe (Perca flavescens),
smallmouth bass/Noosa’owesi (Micropterus dolomieu), rock bass/Ashigan (Ambloplites rupestris),
and a variety of forage and minnow species. In addition, at least five nonindigenous fish species
reside in this portion of the Bad River including the sea lamprey (Petromyzon marinus), white
perch (Morone americana), rainbow smelt (Osmerus mordax), carp (Cyprinus carpio), and
Eurasian ruffe (Gymnocephalus cernuus).
Upstream from the confluence with Marengo River, the Bad River and its major tributaries support
resident brook/maazhmegoons (Salvelinus fontinalis) and brown (Salmo trutta) trout and provide
spawning and nursery areas for anadromous coho (Oncorhynchus kisutch), chinook (Oncorhynchus
tshawytscha) and pink (Oncorhynchus gorbuscha) salmon/miskwemeg wag, and
rainbow/namegoshens (Oncorhynchus mykiss) and brown trout. Of these salmonids, only the
brook trout is native to these tributaries. Forage fish ( minnows, darters, and dace) are also
present, but a comprehensive species inventory has not been conducted. Sea lampreys, rainbow
smelt, and perhaps other non-native fish species inhabit some of these waters.
The White River also provides spawning habitat for walleye and a variety of sucker species
(longnose and white suckers, and shorthead and silver redhorse) that migrate into this system
from Lake Superior. Lake sturgeons have been documented downstream of the White River
hydroelectric dam and it is likely that spawning occurs in the system (Mattes 2001). While the
dam is a barrier to fish migration, prior to dam construction a waterfall at this site prevented
upstream fish migration.

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Figure 1. Exterior boundaries of the Bad River watershed and sub-watersheds.

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Figure 2. Mainstream and major tributaries of the Bad River watershed including historical treatment extent.

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Sea Lamprey
Native to the North Atlantic Ocean, sea lampreys entered the Great Lakes during the 1800s and
were first recorded in Lake Superior in 1938. In the Atlantic, sea lampreys live in saltwater,
feed on large ocean host fish, and migrate to freshwater streams to spawn. Sea Lampreys found
in the Great Lakes have adapted to live their life entirely in freshwater.
Sea lampreys are parasitic on other fishes. The mouth of a sea lamprey consists of a tooth-lined
sucking disc, which enables the lamprey to attach to its host. The lamprey rasps a hole in the
side of its host with its rough tongue and secretes an anticoagulant to keep the blood from
clotting and the wound open. A lamprey may remain attached to its host for hours, days, or even
weeks, while it feeds on blood and other body tissue fluids. A sea lamprey kills approximately
40 pounds of fish during its lifetime and sea lampreys in the Great Lakes annually kill significant
numbers of trout, salmon, whitefish, and other host fish.
The Bad River produces more larval sea lampreys than any other U.S. tributary of Lake Superior,
contributing 20-30% of the parasitic sea lamprey population (Schleen et al. 1996). This high
productivity of parasites threatens Lake Superior fisheries. A sea lamprey stewardship plan is
beneficial to all resource users and will maintain and enhance the fishery of the Bad River system
and help protect the fishery in Lake Superior.
Sea lamprey populations in the Great Lakes have been reduced by approximately 90% of precontrol levels primarily through the application of the lampricide 3-trifluoromethyl-4-nitrophenol
(TFM) to streams which targets the removal of sea lampreys during their larval phase. The
reduction of sea lampreys has allowed fish populations to rebound (Bronte et al. 2004). Despite
this success, continuous control is required because a sufficient number of larval sea lampreys
remain after treatments and cause high mortality of fishes in Lake Superior (e.g., the combined
loss of lake trout/Namegos (Salvelinus namaycush)). Spawning adult sea lampreys continue to
reproduce annually in the system and repopulate the river.
While lampricide treatments have proven to be an effective control technique, reducing the
dependence on lampricides continues to be important to the Band, Service, and GLFC. Currently,
barriers are the only alternative control method to lampricides. Future alternative control methods
include the development and application of pheromone technologies and other experimental
removal options that are being investigated to determine their feasibility for implementation.
The Band is committed to control of sea lamprey populations through an integrated approach
that works toward a goal of minimizing and eventually eliminating the use of TFM in the Bad
River watershed and actively engaging and involving community members in the process. Tribal
leaders and the Mashkiiziibii Natural Resources Department (MNRD) have expressed strong
interest in the use of alternative and supplemental controls for sea lampreys in the watershed
to assist in the reduction of lampricide use.

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The History of Sea Lamprey Activities in the Bad River Watershed
Larval Assessment
Assessment activities in the Bad River began during 1952 when Service crews identified the
system as having significant potential to produce larval sea lampreys. The Service verified the
presence of sea lampreys in the Bad River system during 1955. Personnel from the Service’s
Marquette Biological Station continue to conduct sea lamprey assessments in the Bad River
with assistance from MNRD. These assessments include surveys to determine numbers of larvae,
document larval distribution, prepare for lampricide treatments, assess the success of the
previous treatment, monitor re-established populations, and search for new infestations. Data
from assessments are used to document habitat characteristics of sea lamprey-producing
streams, estimate larval populations, and provide information on sea lamprey production, growth,
and survival.
The population of larval sea lampreys in the Bad River watershed (including the White, Marengo,
Brunsweiler, and Potato rivers) was collaboratively estimated by GLIFWC, MNRD, and the
Service during 1991, prior to lampricide treatment. A post-treatment estimate was made during
1992 that measured a 96% reduction in the larval sea lamprey population (from 951,735
prior to treatment to 38,056 after treatment; Schleen et al. 1996). Since that time, the population
of sea lamprey larvae in the river has remained significantly high by the third year after treatment
with a mean larval population estimate (PE) of 1,269,000.
Electric Barriers
Sea lamprey control activities in the system began during 1956 when Service crews installed
electrical barriers on the Bad and White rivers. While the electrical barriers were targeted
to control lampreys, they also served to provide information on the abundance of spawningphase sea lampreys that were captured in traps at the electrical weir sites. The electric
barriers were in operation through the 1960 season. They proved ineffective as control
structures because during high water periods the barriers were easily negotiated by sea
lampreys or became non-functional due to damage from debris and high water. Lampricide
treatments became the primary means of controlling lampreys in the Great Lakes.
Lampricide Control
The Service first used TFM in Lake Superior tributaries during 1958 and in the Bad River
during 1960. During 1962, after the first round of treatments in Lake Superior tributaries was
complete, the lake-wide lamprey population was reduced by 84%. Since then, portions of the Bad
River watershed have been treated by the Service on 25 occasions. A review of sea lamprey control
activities and a biological inventory of non-target organisms (organisms other than sea lampreys)
collected during these activities can be found in the Service document, Background Information
on Sea Lamprey Control in the Bad River (October 13, 1994), and in an appendix to that document
(May 5, 1997), both available at MNRD. In addition, non-target mortality was monitored by
MNRD in treatments beginning in 1997 and are documented in internal MNRD and Service
reports.

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Adult Assessment
The assessment of adult (spawning-phase) populations of sea lampreys is used to gauge the
success of the sea lamprey control program. The Bad River adult sea lamprey PE is important
because this river along with other Lake Superior stream populations are used to calculate the
total number of spawning sea lampreys in Lake Superior. The estimate is obtained using portable
assessment traps that are set at the lower falls in the Bad River and monitored by the Great
Lakes Indian Fish and Wildlife Commission (GLIFWC) personnel working in partnership with the
Service. About 10 percent of the spawning-phase sea lampreys captured in the traps in the
river are marked and transported downstream for release. Some of these are later recaptured in
the traps as they migrate back upstream and are then removed from the river. The number
of lampreys captured, marked, released, and recaptured is used to estimate the total number
of adult sea lampreys spawning in the river.
An annual index of adult Sea Lamprey abundance has been estimated in Lake Superior from 1986
to present. The adult index is derived by summing individual population estimates from traps
operated in a specific suite of streams (index streams) during spring and early summer. Markrecapture estimates are attempted in each index stream; however, in the absence of an estimate
due to an insufficient number of marked or recaptured Sea Lampreys, abundance is estimated
using the annual pattern of adult abundance observed in all streams and years and adjusted to
the stream-specific average abundance estimate in the time series. The three-year (2020-2022)
average adult index estimate in Lake Superior was 23,000 (PE: 106,724) and has been holding
steady over the past five years (Figure 3).

Figure 3. Index estimates with 95% confidence intervals (vertical bars) of Lake Superior adult sea
lampreys, including historic pre-control abundance (as a population estimate) and the three-year
moving average (line). The PE scale (right vertical axis) is based on the index-to-PE conversion
factor of 4.64. The adult index in 2022 was 19,000 (95% CI 17,000-21,000). The three-year (20202022) average of 23,000 was above the target of 10,000. The index target was estimated as the
mean of indices during a period with acceptable marking rates (1994-1998).

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The Service has estimated the number of adult sea lampreys in the Bad River watershed annually
since 1986 (Appendix 1). The average Bad River adult sea lamprey PE during the last 36 years
has comprised about 33 percent of the total Lake Superior adult abundance.
The target sea lamprey population for Lake Superior is based on the fish community objective
to Suppress Sea lampreys to population levels that cause only insignificant mortality on
spawning-phase lake trout (Horns et al. 2003).
The GLFC’s Lake Superior Committee agreed that an annual abundance of 46,400 (based on data
through 2022) adult sea lampreys should lead to the target of 5 wounds per 100 lake trout and
achievement of the fish community objective for Lake Superior. The target number and range
were calculated from the average number of adult sea lampreys estimated for the five-year
period ( 1994-1998) when wounding rates were closest to 5 marks per 100 lake trout. Wounding
rates of less than 5 per 100 lake trout indicated that sea lampreys were inflicting less than 5%
mortality on lake trout.

Memorandum of Stipulations
A Memorandum of Stipulations signed by the Band, Service and GLFC has facilitated efforts to
control sea lampreys and address concerns of the Band. The first set of stipulations was drawn
up prior to the 2001 lampricide treatment and has been updated for each subsequent
treatment. The Memorandum of Stipulations for the 2021 treatment is included in Appendix 2.
A current version will be developed for each future treatment.

Non-target Organisms
Mortality of non-target organisms during lampricide treatments has been a concern of fish
managers since the implementation of the sea lamprey control program. The Service and other
agencies have conducted studies to determine short-term and long-term effects of TFM on fish
and other aquatic organisms. These studies have shown that TFM is a selective toxicant (i.e., TFM
is relatively specific to sea lampreys), and when used according to label specifications, is acutely
toxic to sea lampreys.
Some non-target organisms including burrowing mayflies (Hexagenia spp.), native lampreys,
juvenile lake sturgeons (<100mm) in high alkalinity water, and tadpole madtoms (Noturus
gyrinus) are sensitive to TFM at concentrations close to those applied during treatment. Once
these sensitive species are identified in a river, the Service takes special precautions to reduce
or avoid stress to the organisms.
Lake Sturgeon (Namé)
An example of an effort to reduce TFM induced stress on non-target organisms is ensuring
treatments are scheduled when a species is least sensitive. Streams that have reports of spawning
lake sturgeon are treated after August 1 to allow young-of-year lake (YOY) sturgeons to grow to
a size where they are less sensitive to TFM. Since 1995, treatments of the Bad River have

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been conducted during September after the manoomin harvest and when YOY lake
sturgeon are less vulnerable to TFM.
Wild Rice (Manoomin)
Manoomin is culturally important to the Ojibwe as it is a part of their origin story. During
their migration, the Ojibwe people would know they were at their final destination by the
presence of food growing on water (manoomin). Manoomin is present in the lower Bad
River near the mouth and is harvested by community members. Because the effects of TFM
on manoomin is unknown, lampricide treatments are scheduled after the fall harvest.
Additionally, TFM is not applied below US HWY 2 which allows the lampricide to dilute down
through the drowned river mouth. Recently, Bad River elders requested data on the
duration of time that TFM is detectable in manoomin areas. MNRD and Service staff
conducted a study during 2021. Water and sediment samples were collected before
(control), during, and after the treatment to determine lampricide concentrations. Results
show that TFM concentrations quickly dropped below detection limits in both water and
sediment and would not pose a significant risk to manoomin (Solomon et al. 2022). This is
supported by other studies (Thingvold and Lee 1981 and McConnell et al. 2017) that
demonstrated that TFM does not bioaccumulate and is degraded by sunlight within a few
days depending on amount of photolysis and microbial organisms that breakdown the
lampricide.
Mussels
During the September 1995 treatment of the Bad River, tests were conducted to determine
the toxicity of TFM to the green frog tadpole (Rana clamitans), eastern ellipto freshwater
mussel (Eliptio complanata), river club dragonfly (Stylurus amicola), and sea lamprey larvae
in the White River. The non-target species were found to be less sensitive to TFM than sea
lamprey larvae. No mortality occurred at TFM concentrations that were used to kill sea
lampreys (Approximately 2.7 mg/l) in the Bad and White Rivers.
During 1996, a team of investigators from the U.S. Geological Survey, Service, and MNRD
evaluated the effects of TFM treatments on adults and juveniles of two freshwater mussel
taxa in the White River. No mussels were killed at treatment concentrations or at
concentrations as high as 1.6 x Minimum Lethal Concentration (MLC) of TFM to kill larval
sea lampreys. During 1997, this research group measured effects of the combination of TFM
and niclosamine (another lampricide) on freshwater mussels during a twelve-hour exposure.
This lampricide combination is more toxic to sea lampreys than TFM alone. Again, no mussel
mortality occurred at concentrations greater than those used in sea lamprey treatments.
Growth and mortality rates of mussels were not reduced when exposed to TFM at treatment
concentrations during 1998 (Waller et al., 2003). Non-target mortality was monitored by
MNRD during the 1997-2017 treatments and was documented in internal reports, which
were forwarded to the Service.
Cultural impacts caused by sea lamprey attacks on native fish
Lake trout/Namegos (Salvelinus namaycush), lake whitefish/Adikameg (Coregonus
clupeaformis), and other fish mortality in Lake Superior caused by sea lampreys impacts

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cultural and economic opportunities of the Bad River Band. By allowing native fishes to
thrive, sea lamprey control in the Bad River provides a direct benefit to Bad River members
and other user groups who fish Lake Superior for commercial or subsistence p urposes. This,
in turn, aids in the re-establishment of a balanced ecosystem.
TFM in fish tissues
Bad River community members and others eat fish from the Bad River and are concerned
about the safety of eating fish that have been through a treatment. Numerous studies have
been conducted on fish tissues after exposure to treatment concentrations of TFM and have
determined that TFM residues in fish tissue decreases rapidly, falls below detection limits
within 6-24 hours after exposure (Hubert et al. 2005 and Vue et al. 2002), and poses no
apparent risk to consuming fish after a treatment.
Testing for impurities in lampricide
During the late 1980’s, dioxin-like impurities were detected in TFM. To test for these
impurities, the Service collected walleye, white suckers, and sediment samples from the
river. The samples were analyzed by private laboratories. Results showed that while dioxinlike impurities were found in the TFM formulations, no dioxins or dioxin-like impurities were
found in fishes or sediment samples. The manufacturing process was changed to eliminate
the contaminant. The MNRD listed the dioxin-like contaminant as a concern for the 1995,
1998, 2002, and 2005 treatments, however, no dioxin-like impurities were detected in TFM
prior to treatment in these years. Because dioxin-like impurities have not been detected in
TFM in over 30 years and the manufacturing process has not changed, the service asks to
discontinue future testing of TFM used for treatments unless the manufacturing process
changes. At some point in the future, testing may be discontinued or the length of time
between testing further increased if agreed to by all parties.
Mercury in sea lampreys
Sea lampreys affect fish in the open waters of Lake Superior and the faunal elements of its
associated watersheds. This occurs when elevated methyl mercury burden in the parasitic
stage sea lampreys provides bio-available mercury to Great Lakes watersheds exposed to
spawning runs of sea lampreys. The exposure to the food chain in the watersheds is
exacerbated, when adult sea lampreys die in the stream after spawning, further increasing
the availability of mercury to the food chain (Moses et al. 2018). Adult bald eagles/migizi
(Haliaeetus leucocephalus) have been observed feeding eaglets sea lampreys, and the Band
had initiated a food habits study in an area that has high concentrations of spawning sea
lampreys and poor eagle productivity. In the Bad River falls study area, one nest has
produced two young in eight years. Other Lake Superior bald eagle nests have r ecords of
sea lamprey remains in nests as prey items (Papp, Pers. Comm., 2007)
Treatment planning
The Sea Lamprey Control Program strives to apply lampricide to the Bad River to remove
larval sea lamprey without negatively affecting non-target organisms. Effective stream
treatments require knowledge of the chemical and physical characteristics of a stream. Pre treatment studies typically include application of an inert vegetable-based dye (rhodamine)

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to monitor the flow of water, stream discharge measurements, and analysis of water
chemistry (pH and alkalinity) to determine variables that may influence treatment
effectiveness. When needed, onsite toxicity tests are conducted by the Service to determine
the specific concentration of lampricide required to kill sea lampreys without harming non target organisms. The Service applies lampricides to a river only when the results of
preliminary studies indicate that a successful TFM treatment will result. Duri ng application,
TFM is metered into the stream for about 12 hours. The treated water is analyzed
periodically at several locations along the stream course and application rates are adjusted
to ensure proper concentration (GLFC-SOP 2021).
Although TFM is applied at minimal effective concentrations, a few species of fish have
tolerance levels only slightly greater than those of sea lampreys, and occasionally some of
these fishes are killed. Fishes are most sensitive to TFM during spawning; c onsequently,
TFM treatments are routinely scheduled to avoid spawning periods of sensitive organisms.
The Service has strived to reduce the amount of TFM used during treatments to further
protect non-target organisms. For example, during the 1995 treatment, the use of TFM was
reduced by 31% from the 1991 treatment. This reduction was due to 1) the entire Bad River
system treated at one time rather than in multiple stages, and 2) TFM was applied closer to
MLC required to kill sea lamprey larvae but utilized more application sites.

Options for Supplemental Controls
The GLFC is committed to reductions in TFM use through the implementation of alternative and
supplemental controls. While lampricides target the removal of sea lampreys during their
larval phase, supplemental controls to barriers and/or lampricide treatments, can further reduce
sea lampreys (Johnson et al. 2020). The focus is on reducing reproduction of lampreys during their
spawning-phase and includes trapping, electrical barriers and guidance systems, sterile-male
release, pheromone applications, and other experimental removal options.
Supplemental technologies that strive to reduce reproduction by targeting actions during the
sea lamprey spawning-phase can work, but they are subject to variability in effectiveness. Jones
et al. (2003) and Dawson (2007) observed a significant positive relationship between spawning
density and recruitment, but they also observed considerable density independent variation
in the relationship. However, when spawning populations are low, reducing reproduction by
trapping or other means should result in lower recruitment on average. Two subsequent studies
(Young 2005, Velez- Espino et al. 2008) observed similar patterns in lake-wide modeling studies.
In addition, reduction in reproduction in scenarios where lamprey populations were already low
or suppressed through lampricides resulted in further suppression of lamprey abundance but had
little effect when spawning densities were relatively large.
Trapping
Technologies currently employed to capture spawning phase sea lampreys are passive systems
that exploit the strong urge of sea lampreys to find passage around stream- borne obstacles
during their migration. When a barrier to migration is encountered, a sea lamprey will follow

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its edge and aggressively probe for passage, seeking any indication of flow that may guide it
past the obstacle. In this manner, traps with funnels placed against a barrier (natural or
manmade) with an attractant flow of water and a lead (such as the face of a dam) has proven
to be very effective at capturing sea lampreys. Sites without these characteristics or with
extreme flows can be challenging to trap. Trapping devices used to capture adult sea lampreys
generally fall into one of four categories:
Nets – These are fyke or modified hoop nets (D-ring) that are often used in shallow sections of
streams where barriers are absent. Long leads or wings are used extending downstream to guide
the lampreys to the net opening. As much of the river width is covered as practical. Nets are labor
intensive, require frequent cleaning, are susceptible to floods and debris and typically have a low
efficiency.
Portable assessment traps - These are rectangular sheet mesh cages hung from a structure or
placed on the stream bottom in shallow waters during the period of the sea lamprey run and
removed afterward (Schuldt and Heinrich 1982). Their portability allows fine-scale adjustment in
a variety of locations. High velocities and high flows can dislodge the traps and make them
unserviceable. Portable traps are often less effective on very large rivers.
Permanent traps – These are structures that have been engineered to provide consistent and
optimal operating characteristics at specific sites. They are usually made of concrete or steel,
square or rectangular in shape, and are built into a permanent barrier or a trap-and-sort fishway.
Most have a method of providing attractant water through the trap either by a pump, pipe, or
physical structures that direct the flow of water in the desired direction. Operating efficiencies
for these traps are usually higher and less variable than for portables.
Semi-permanent traps – These are structures that have many of the same operating advantages
of permanent traps, but have seasonal parts (leads, wings, screens) that usually require more
annual setup. Like permanent traps, they typically have large square or rectangular traps and
tend to be more efficient than portables or nets.
Traps have been used in the Bad River and have consisted of a network of portable traps fished
at the lower falls cooperatively by GLIFWC and Service staff. The efficiency of the trapping
network is low and averages about seven percent. This is due to the physical nature of the
trap site, challenging flow conditions and the lack of a barrier to congregate and lead lampreys
into a trap. While the efficiency of traps fished at the lower falls is low, the information from
trapping is important in assessing the population in both the river and Lake Superior.
A permanent or semi-permanent trap may have potential to increase trapping effectiveness
in the river. Possible locations include sites near the upper falls (Brownstone Falls) of the
mainstream Bad River or in conjunction with a barrier in the Marengo River. If pheromones are
demonstrated to increase trap efficiency, they could be used in conjunction with the
development of this type of trap.

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Barriers
Typical sea lamprey barriers consist of a fixed-crest low-head structure that maintains at least an
18-inch drop. Sea lamprey barriers have an overhanging metal plate at the crest of the barrier
that, in combination with the drop, prevents sea lampreys from moving upstream. While barriers
block upstream sea lamprey migrations, streams with barriers may still require treatment
downstream from the barrier if the area downstream supports spawning and larval habitat.
It is recognized that extreme flows during the lamprey migration period may result in sea lamprey
recruitment upstream of the barrier that cannot be mitigated in low-head barrier design due to
practicality of barrier height. As such, a barrier does not have to block 100% of the lampreys 100%
of the time to be considered successful. However, it is expected to block often enough that it at
least reduces the need for treatment. Barriers may be designed with an option of increasing barrier
height during high water using removable stoplogs or a periodically activated electrical field.
A barrier may be possible on the Marengo River below its confluence with the Brunsweiler River,
but this is not known without a comprehensive analysis of a proposed site. Treatment of the
Bad River watershed costs an estimated $470,000 of which an estimated $184,000 is spent on
treating the Marengo River. This does not include larval and spawning-phase assessments in the
watershed between treatments. Estimated cumulative costs of a treatment every three years
and annual adult and larval phase surveys and treatments would be about $700,000 (USFWS,
2022). A barrier on the Marengo River would result in: 1) less of the Bad River watershed being
regularly exposed to lampricide; 2) a decrease in habitat available to sea lampreys for
reproduction and infestation; and 3) a decrease in mortality of lake trout, whitefish, and other
host fish in Lake Superior. During recent treatments, about 126 miles of the Bad River system
were exposed to lampricide including the main stem of the Bad River, lower White River,
Potato River, and Marengo River. A proposed barrier site on the Marengo River would reduce
44 miles of stream requiring treatment.
To date, there has been no suitable site identified for a sea lamprey barrier on the mainstream
of the Bad River. This option was explored in depth at the Elmhoist Bridge, the upper, and the
lower falls. Due to cultural and environmental issues (passage of desirable fishes, aesthetic value
of a free-flowing river, sensitive cultural properties, and extreme fluctuations in flow), these
sites were eliminated from further study and development during 2002.
Experimental barrier designs including some seasonal, electrical or velocity barriers have not
demonstrated consistent reduction in the need for lampricide treatments. Therefore, they are not
pursued as a feasible option for new barriers, but they could be tested as supplemental controls.
Sterile-Male-Release Technique
The sterile-male-release technique (SMRT) was implemented experimentally in Lake Superior
and the St. Marys River during 1991-1996 (Bergstedt et al. 2003) and exclusively in the St. Marys
River during 1997-2011. Evaluation of the technique had been challenging given the longl i f e cycle of sea lampreys and lack of an experimental control for the large-scale experiment.
Nevertheless, several evaluations suggest the technique can contribute cost effective
suppression and reduction in reproduction in smaller river systems (Siefkes et al. 2021).

16

Experimental releases into Lake Superior occurred during 1991-1996 with 96,670 sterilized male
sea lampreys released into 33 tributaries. Of these, approximately 14,500 sterile male sea
lampreys were released into the Bad River during 1992-1997 (Table 1). The technique in Lake
Superior was discontinued in 1996 to focus the effort and limited supply of males in the St. Marys
River. Releases continued in the Bad River in 1997 as part of an agreement with the Band to
continue alternative controls in the river. However, revelations about mercury contamination
(Madenjian et al. 2014) in sea lamprey flesh caused the Band to request cessation of further
releases after 1997.
Table 1. The estimated population of male sea lampreys in the Bad River, the number of sterile
male sea lampreys released, the estimated ratio of sterile to normal males, and the predicted
percent reduction in larval production for the years 1992-1997.
Year

Estimated male
population

Sterile males
released

Sterile:normal
male ratio

Predicted
reduction (%)

1992

1,404

3,170

2.3:1

70

1993
1994
1995
1996
1997

1,231
1,129
1,152
4,108
1,875

3,927
3,500
2,151
1,669
1,500

3.2:1
3.1:1
1.9:1
0.4:1
0.8:1

76
76
66
29
45

Expansion of the sterile-male-release technique to areas other than the St. Marys River (i.e., Bad
River) is limited by the supply of male sea lampreys. For the SMRT to again be considered for
the Bad River, a source of male sea lampreys would need to be identified and the technique
would need to be coupled with other aggressive efforts to reduce reproduction. The most likely
scenario would first involve a more rigorous lampricide treatment frequency to reduce spawner
densities to very low levels. Given the Band’s interest in options that reduce lampricide
treatments, lack of effective trapping in the river, limited supply of source males and a continued
concern with mercury levels in spawning-phase sea lampreys, this method is not a feasible
option in the Bad River at this time.
Experimental Removal Options
Exploration of new technologies to remove spawning-phase sea lampreys is underway and has
the potential to capture lampreys in difficult locations such as large rivers and sites without
barriers. Recently attempted or proposed technologies include the following:
•

Mashkiiziibing Sea Lamprey Project –Buckner et al. (2020) crafted a project proposal
designed to be implemented for a minimum of 7 years. The project vision is to serve as a
model for culturally aligned non-native species stewardship that enriches and preserves our
shared human and ecological communities for fellow Native Nations within the Laurentian
Great Lakes and beyond. The project tasks MNRD to contact Pacific Northwest (PN) tribes

17

to connect on traditional methods of harvesting Sea Lamprey. After finding a contact within
a PN tribe, MNRD would contract that contact as a mentor for Bad River (BR) tribal
members. After a few BR tribal members have been fully trained in the art of capturing Sea
Lamprey these members will become mentors of other BR tribal members. After enough
tribal members are trained enough to capture lamprey a full implementation of the
traditional capture methods will commence. After 3-years of traditional capture methods
are complete, an assessment of Sea Lamprey population will occur. The measure of success
of this project is to delay treatment of the Bad River watershed. If the capture method is a
success the lamprey population would be low enough to not need treatment after the first
3 years of this method. This project expresses support for a barrier or multiple barriers on
the Bad River and its tributaries if the experimental method is not successful enough to
delay treatment.
•

Pheromones - A suite of pheromone compounds have been identified that are
instrumental in drawing sea lampreys to suitable spawning environments and mates.
Researchers continue to evaluate additional pheromone components and trapping
scenarios (Li et al. 2007). Pheromones are likely to be most useful in the short-term to
enhance trap captures, but other longer-term strategies may include a variety of
disruptions to spawning success. Research into pheromones, antagonists, and other
chemical cues is ongoing and has shown some success (Fissette et al. 2021).

•

Tube traps - Tube traps (also called bucket traps) are cylindrical tubes with funnels at both
ends that are placed in the river for spawning-phase lampreys to use for daytime refuge.
They target early run lampreys in the lower reaches of rivers in deeper slack water.
Placement in appropriate substrate and stream environment is critical to their success.
They have not contributed substantially to lamprey captures to date.

•

Fishwheels - A fishwheel uses river current to turn baskets on an axle, captures
upstream migrating spawning-phase lampreys in the baskets, and deposits them into a
live holding cage. Fishwheels may provide trapping opportunities in rivers without
barriers or where velocities are too high to fish traditionally. Fishwheels can be
cumbersome to deploy but are relatively easy to operate and service once in place.
Sufficient velocity and depth are critical, and the nets need to sweep very close to the
bottom to be effective.

•

Manual removal – This technique relies on a person walking a length of stream,
removing observed spawning-phase lampreys from nests and evacuating eggs from nests
where reproduction has occurred. It is applicable in wadable streams but is labor
intensive. Anecdotal information suggests that this technique has been successful in a
limited setting.

•

Downstream trapping of metamorphosing-phase sea lampreys – This method captures
metamorphosing-phase lampreys on their downstream migrations to the lake to begin
their parasitic-phase. Recent investigations with a rotary screw trap and nets have shown
promise for capturing substantial numbers of migrating sea lampreys in certain

18

environments. The feasibility of trapping downstream migrants continues to be
evaluated for control as well as to meet population assessment needs. The approach
may be useful in streams that have been delayed from treatment but is not a substitute
for lampricide treatments. GLIFWC partners with the USFWS to trap juvenile lampreys on
their downstream migration to Lake Superior in the fall.
Manual removal of spawning-phase sea lampreys and their eggs from nests and downstream
trapping of metamorphosing-phase sea lampreys may have applicability in some areas of the Bad
River system. However, it is important to evaluate and quantify the potential of these
experimental options to determine the level of reduction they can contribute. Reductions would
have to be significant and cost-effective enough to reduce the need for lampricide treatments.
Additional portable traps, nets and fishwheels are not recommended for the Bad River because
they are not capable of removing enough spawning-phase lampreys to elicit a level of control that
would reduce the need for lampricide treatment.

Summary and Recommendations
The Bad River is widely recognized as the largest producer of sea lampreys on the south
shore of Lake Superior, contributing between 20-30% of the parasitic sea lampreys in the U.S.
waters of Lake Superior. It is imperative that the larval population in the river be effectively
controlled on a regular basis to allow fish populations in Lake Superior to thrive.
The Band would like the use of lampricides and other chemicals to be reduced and eventually
eliminated. Tribal leaders and the MNRD have expressed interest in barriers to block sea lamprey
spawning migration and supplemental control methods. However, the use of TFM is currently
the only proven effective method of sea lamprey control in the Bad River. Supplemental
control options currently available may not eliminate the need for lampricide treatments although
new technologies are continually researched and tested. The GLFC is committed to the
development of effective alternative and supplemental control techniques to reduce sea
lampreys. Options to enhance lampricide control in the Bad River watershed include trapping
and barriers. Options under development that may be further investigated include the use of
pheromones, antagonist chemosensory cues, manual removal, and downstream trapping of
metamorphosing-phase sea lampreys. In the future, additional options may arise as the GLFC
continues with its commitment to develop alternative sea lamprey control techniques.
Recommendations for a fully implemented integrated sea lamprey control plan in the Bad River
are:
1. Lampricide treatment during 2024 and then every three years thereafter prior to
metamorphosis and outmigration of the oldest year class. If a lampricide treatment is
ineffective and the larval sea lamprey population requires a follow-up treatment, one will be
scheduled within the 3-year treatment cycle. Until alternative and supplemental controls can
reliably and effectively be used to control sea lampreys in the Bad River, lampricide treatments
will be required.

19

2. Collaboratively conduct larval assessments to delineate distribution of larval sea lampreys in
the river, monitor the effectiveness of treatments, and other larval phase surveys as needed.
3. Test TFM used for treatments of the Bad River for dioxin-like compounds when a new
manufacturing process occurs.
4. Continue to schedule lampricide treatments of the Bad River after the tribal harvest of wild
rice on the reservation, which typically occurs in early September.
5. Continue of use of portable assessment traps to assess the abundance of spawning-phase sea
lampreys at the lower falls.
6. Consider the implementation of the following alternative and supplemental controls methods:
a. Investigate feasibility of constructing a barrier with trap on the Marengo River
downstream of the confluence of the Brunsweiler River or at another location that would
reduce the miles requiring a lampricide treatment.
b. Investigate feasibility of constructing permanent trap(s) at the upper falls.
c. Investigate feasibility of manual removal and downstream trapping to reduce the need
for lampricide treatments in applicable sections of the river.
d. When available, use novel trapping technologies that do not rely on barriers and are
proven effective to capture sea lampreys.
e. When available, use pheromones as part of an integrated control strategy to reduce
lamprey reproduction, in concert with other supplemental control methods when such
techniques have been field-proven and cost effective.
f. Consider re-implementation of the sterile-male-release technique once mercury-free
lampreys and effective trapping are available, and there is a sufficient supply of adult male
lampreys to meet all program needs.

20

References
Bergstedt, R.A., McDonald, R.B., Twohey, M.B., Mullett, K.M., Young, R.J., and Heinrich, J.W.
2003. Reduction in sea lamprey hatching success due to release of sterilized males. J. Great
Lakes Res. 29 (Suppl. 1):435–444.
Bronte CR, Ebner MP, Screiner DR, DEVault DS, Petzold MM, Jebnsen DA, Lozano SJ.
2004. Fish community changes in Lake Superior, 1970-2000.
Buckner, C., A. Gries, M. Harris, D. Jennings, and M. Munns. 2020. Mashkiiziibing Sea Lamprey
Project. Environmental Studies 972: Conservation Planning. University of WisconsinMadison. Nelson Institute for Environmental Studies.
Dawson, H. A. 2007. Recruitment dynamics of Great Lakes sea lamprey (Petromyzon marinus)
populations and implications for integrated pest management. Ph.D. dissertation, Michigan
State University.
Elias J. (editor). 2001. Bad River band of Lake Superior Chippewa Indians Integrated Management
Plan. Odanah, WI.
Fissette, S.D., T.J. Buchinger, C.M. Wagner, N.S. Johnson, A.M. Scott, and W. Li. 2021. Progress
towards integrating an understanding of chemical ecology into sea lamprey control. J. Great
Lakes Res. 47: S660-S672.
Great Lakes Fishery Commission. 2021. Standard operating procedures for application of
lampricides in the Great Lakes Fishery Commission Integrated Management of Sea Lamprey
(Petromyzon marinus) Control Program. http://www.glfc.org/sop2021/Introduction.pdf
Hanson, L.H., and Manion, P.J. 1978. Chemosterilization of the sea lamprey (Petromyzon
marinus). Great. Lakes Fish. Comm. Tech. Rep. 29:1-15.
Hanson, L.H. and Manion, P.J. 1980. Sterility method of pest control and its potential role in
an integrated sea lamprey (Petromyzon marinus) control program. Can. J. Fish. Aquat.
Sci. 37:2108-2117.
Horns, W.H., C.R. Bronte, T.R. Busiahn, M.P. Ebener, R.L. Eshenroder, T. Gorenflo, N. Kmiecik,
W. Mattes, J.W. Peck, M. Petzold, D.R. Schreiner. 2003. Fish-community objectives for
Lake Superior. Great Lakes Fish. Comm. Spec. Pub. 03-01.78p.
Hubert, T.D., Bernardy, J.A., Vue, C., Dawson, V.K., Boogaard, M.A., Schreier, T.M., and
Gingerich, W.H. 2005. Residues of the lampricides 3-trifluoromethyl-4-nitrophenol and
niclosamide in muscle tissue of rainbow trout. J. Agric. Food Chem. 53:5342-5346.
Johnson, N.S., A.K. Jubar, D.A. Keffer, P.J. Hrodey, G.A. Bravener, L.E. Freitas, J.T. McCarter, and
M.J. Siefkes. 2020. A case study of sea lamprey (Petromyzon marinus) control and ecology in
a microcosm of the Great Lakes. J. Great Lakes Res. 47: S492-S505.

21

Jones, M.L., Bergstedt, R.A., Twohey, M.B., Fodale, M.F., Cuddy, D.W., and Slade,
J.W. 2003. Compensatory mechanisms in Great Lakes sea lamprey populations. J. Great Lakes
Res. 29 (Suppl. 1):113–129.
Li, W., Twohey, Jones, M.J., and Wagner, M. 2007. Research to guide use of pheromones to
control sea lamprey. J. Great Lakes Res. 33 (Special Issue 2):70-86.
Madenjian, C.P., N.S. Johnson, M.J. Siefkes, J.M. Dettmers, J.D. Blum, and M.W. Johnson. 2014.
Mercury accumulation in sea lamprey (Petromyzon marinus) from Lake Huron. J. Great Lakes
Res. 470: 1313-1319.
Mattes, W.P., and Nelson J. 2001. Namé (Lake Sturgeon) Project on the White River in Wisconsin
during 2001. Great Lakes Indian Fish and Wildlife Commission
Meehan, W.R. 1961. Use of a fishwheel in salmon research and management. Trans.
Am. Fish. Soc. 90(4): 490-494.
McConville, M.B., Cohen, N.M., Nowicki, S.M., Lantz, S.R., Hixson, J.L., Ward, A.S., and Remucal,
C.K. 2017. A field analysis of lampricide photodegradation in Great Lakes tributaries. Environ.
Sci.: Processes & Impacts. 19:891-900.
Moses, S. K., C.N. Polkinghorne, W.P. Mattes, and K.M. Beesley. 2018. Spatial and ontogenetic
variation in mercury in Lake Superior basin sea lamprey (Petromyzon marinus). Bull. Env. Cont.
Tox. 100:95-100.
Schleen, L.P., R.J. Young and G.T. Klar.1996. Integrated Management of Sea Lampreys in the
Great Lakes. 1995. Annual Report to the Great Lakes Fishery Commission
Schuldt, R.J., and Heinrich, J.W. 1982. Portable trap for collecting adult sea lampreys.
Prog. Fish-Cult. 44:220–221.
Siefkes, M.J., S.J. Johnson, and A.M. Muir. 2021. A renewed philosophy about supplemental sea
lamprey controls. J. Great Lakes Res. 47:S742-S752.
Solomon, B., S. Nowicki, and J. Rodmaker. 2022. Determination of TFM concentration and
persistence following a lampricide treatment in water and sediment of northern wild Rice
(Zizania palustris) areas of the Bad River, Wisconsin. In peer review. Great Lakes Fishery
Commission Completion Report.
Thingvold, D.A. and Lee, G.F. 1981. Persistence of 3-(trifluoromethyl)-4-nitrophenol in aquatic
environments. Environ. Sci. Technol. 15(11):1335-1340.
Twohey, M.B., Heinrich, J.W., Seelye, J.G., Fredricks, K.T., Bergstedt, R.A., Kaye, C.A., Scholefield,
R.J., McDonald, R.B., and Christie, G.C. 2003. The Sterile-Male- Release-Technique in Great
Lakes Sea Lamprey Management. J. Great Lakes Res. 29 (Suppl.1): 410-423.

22

U.S. Fish and Wildlife Service (USFWS). 2022. Sea Lamprey Management Program (SLMP)
Database.
Waller, D.L., Bills, T.D. Boogard, M.A. and T.C.J. Doolittle. 2003. Effects of lampricide exposure
on the survival, growth and behavior Unionid mussels Elliptio complanta and Pyganadon
cataracta. J. Great Lakes Res. 29 (Supplement 1) 542-551.
Velez-Espino, L. A., McLauglin, R. A., and Pratt, T. C. 2008. Management inferences from a
demographic analysis of sea lamprey (Petromyzon marinu) in the Laurentian Great Lakes.
Can. J. Fish. Aquat. Sci. 65 227-244.
Vue, C., Bernardy, J.A., Hubert, T.D., Gingerich, W.H., and Stehly, G.R. 2002. Relatively rapid
loss of lampricide residues from fillet tissue of fish after routine treatment. J. Agric. Food
Chem. 50: 6786-6789.
Young, R. J. 2005. Integrating heterogenous survey data to characterize the success of the Lake
Huron sea lamprey (Petromyzon marinus) control program. Dissertation, Michigan State
University.

23

Appendices
Appendix 1.
Bad River adult sea lamprey trap catch and estimated populations in the Bad River and Lake
Superior from 1986-2022. Data are collected by the Service and GLIFWC.
Year

Bad River
Total Catch

1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2008
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
2021
2022

184
439
972
684
465
121
236
NA
110
237
313
272
460
607
283
536
1,039
1,372
811
1,090
1,603
1,987
2,111
1,203
964
256
732
286
642
55
129
731
710
318
NA
719
174
1

74
1
817
1

Bad River
Spawner PE
NA
22,212
35,143
22,787
13,980
2,960
NA
36,037
10,728
15,535
23,307
21,771
17,507
41,973
22,750
39,036
60,793
41,709
57,805
78,611
116,186
59,888
80,156
26,211
40,298
NA
98,837
27,678
63,304
NA
14,407
37,217
52,435
20,105
NA
54,404
8,431

Lake Superior
Spawner PE
108,593
59,927
73,364
77,582
53,902
46,853
NA
1993
28,699
47,355
45,089
54,882
65,750
236,728
146,313
100,048
161,286
69,725
114,529
181,591
188,741
138,091
142,499
57,702
76,154
75,001
217,918
200,098
155,482
158,790
181,675
304,356
271,289
60,939
NA
126,085
89,612

24

Appendix 2.
Memorandum of Stipulations
Among the Bad River Band of Lake Superior Tribe of Chippewa Indians, Great Lakes Fishery
Commission, and U.S. Fish and Wildlife Service

This Memorandum of Stipulations among the Bad River Band of Lake Superior Tribe of Chippewa Indians
(Band), the Great Lakes Fishery Commission (Commission), and the U.S. Fish and Wildlife Service
(Service) as agent for the Commission, is intended to facilitate efforts to control sea lamprey
(Petromyzon marinus) in waters within the Bad River Reservation and to address concerns of the Band.

Concern 1. Need to identify and utilize only the best available batch of TFM.
Response: A very minute amount of a dioxin-like compound was discovered in TFM as a contaminant in
the 1980s. Once discovered, the manufacturer redesigned their process to eliminate the dioxin-like
contaminant from the TFM. The Bad River Natural Resource Department, now referred to as
Mashkiiziibii Natural Resource Department (MNRD), listed the contaminant as a concern for past
treatments occurring in 1995, 1998, 2002, 2005, 2008, 2011, and 2017. TFM was tested prior to
treatment in these years and the dioxin-like compound was not present so it appears that the
manufacturer was successful in removing this compound from the TFM manufacturing process. Testing
for dioxin-like impurities is an expensive process and the parties have agreed that TFM only needs to be
tested every other treatment or when the manufacturing process or manufacturer is changed. This
agreement to test TFM every other treatment occurred during 2011. TFM was tested during 2017 prior
to treatment to satisfy the requirements of testing every other treatment. No dioxin-like compounds
were present. Testing for these compounds is not scheduled to be conducted during 2021.

Concern 2. Need to identify and implement a custody process to ensure that the integrity of best
available batch is not compromised during storage, transportation, and/or application.
Response: The Service provided a revised copy of its "Standard Operating Procedures for Application of
Lampricides in the Great Lakes Fishery Commission Integrated Management of Sea Lamprey
(Petromyzon marinus) Control Program" to the MNRD. The quality control protocol for the safe handling
and storage of lampricide will be followed and is included in that document under AOP: 008.0.

25

Concern 3. Need to identify a process and funding mechanism for tribal participation, including the
fisheries specialist, throughout preliminary studies, bioassay procedures, application of TFM and
observations for non-target mortality.
Response: The Commission, through the Service and based on the availability of funds, will provide
$6,000.00 under a cooperative agreement to the MNRD to secure the temporary services of three tribal
employees to assist with larval sea lamprey surveys and observing and documenting non-target
mortality during the TFM treatment of the Bad River. The MNRD will provide the Service with a written
report documenting non-target mortality observed during the treatment.

Concern 4. Need to provide an annual summary report describing all treatment and assessment
activities on the Bad River Reservation and all related sampling, inventory, and bioassay procedures
to the MNRD by December 31of each year.
Response: The Service will provide an annual summary report of treatment and assessment activities
on the Bad River Reservation to the MNRD by December 31 of each year.

Concern 5. Work towards the goal of continuing to reduce and eventually eliminate TFM use within
the Bad River needs to continue.
Response: The Commission and the Service have coordinated with the MNRD and the Bad River Tribal
Council to develop the "Integrated Management Plan for Controlling Sea Lampreys in the Bad River"
which recommends methods to investigate the feasibility and implementation of all alternative methods
to block, capture and remove sea lampreys in the Bad River and its tributaries.

Concern 6. Treatment shall not be permitted prior to the completion of the wild rice harvest within
the Bad River System.
Response: The Commission and the Service agree to not initiate a sea lamprey control treatment in the
Bad River system prior to September 11, 2021.

Concern 7. If permission is granted for the application of TFM by the Bad River Tribal Council, the
Commission, Service and the MNRD shall hold a public information meeting prior to the treatment to
discuss the treatment plans.
Response: The Commission and the Service agree to participate with the MNRD in a public information
meeting that shall be conducted prior to the treatment.

26

Concern 8. Need to verify that all treatments will be conducted according to the "Standard Operating
Procedures for Application of Lampricides in the Great Lakes Fishery Commission Integrated
Management of Sea Lamprey Control Program," which include strict procedures designed to protect
non-target fish species.
Response: The Commission and the Service affirm that all treatment activities on the Bad River will be
conducted according to the "Standard Operating Procedures for Application of Lampricides in the Great
Lakes Fishery Commission Integrated Management of Sea Lamprey (Petromyzon marinus) Control
Program.” http://www.glfc.org/sop.php

Concern 9. Assurance of application of best available science and control methods after the
“Integrated Management Plan for Controlling Sea Lampreys in the Bad River” is completed. This
includes exploring the feasibility, implementation, and evaluation of all alternative (non-lampricide)
techniques identified in the plan.
Response: The Commission and the Service support the concept of "application of best available science
and control methods" as identified in the "Integrated Management Plan for Controlling Sea Lampreys in
the Bad River." This applies to implementation and evaluation of all alternative sea lamprey control
techniques identified in the plan.

---

Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Abad_river_chippewa%3Afecdb4f61109d0d6. Public record. Not legal advice.