Watershed Bull Trout

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Joseph Tomelleri

Upper Malheur

Watershed Bull Trout

Conservation Strategy

Malheur River Bull Trout Technical Advisory Committee - Prepared with

assistance provided by QW Consulting, LLC

Table of Contents

Table of Contents .......................................................................................................................... 1

Part I – Strategy Background ...................................................................................................... 5

A. Contributing Agencies and Participants ..................................................................................... 5

B. Purpose ....................................................................................................................................... 5

C. Background and Problem Statement .......................................................................................... 6

C.1 Bull Trout Recovery Chronology............................................................................................. 6

C.2 Malheur River Bull Trout Technical Advisory Committee Chronology ................................. 7

C.3 Upper Malheur River Bull Trout Status and Trends ................................................................ 7

C.4 Bull Trout Timing and Movement in the Upper Fork Malheur River ..................................... 8

C.5 Brook Trout/Bull Trout Interactions in the Upper Malheur River ........................................... 9

C.5.1 Brook Trout Introductions ..................................................................................................... 9

C.5.2 High Lake and Upper Lake Creek: Brook Trout Seed Sources ............................................ 9

C.5.3 Big Creek............................................................................................................................. 11

C.5.4 Bull Trout and Brook Trout Interactions: Hybridization .................................................... 11

C.5.5 Bull Trout and Brook Trout Interactions: Competitive Advantages ................................... 12

C.6 Genetics and Small Populations ............................................................................................. 12

C.7 Environmental Variations ...................................................................................................... 13

C.8 Timeline of Past Brook Trout Removal Efforts ..................................................................... 13

C.9 Climate Change Resilience and Habitat Restoration ............................................................. 14

D. Proposed Action ....................................................................................................................... 14

D.1 General Summary of Precedent Projects ............................................................................... 17

D.2 General Summary of Relevant Policies ................................................................................. 17

D.3 Action Areas .......................................................................................................................... 18

D.3.1 Upper Action Area .............................................................................................................. 19

D.3.2 Middle Action Area ............................................................................................................ 19

D.3.3 Lower Action Area.............................................................................................................. 20

D.4 Effects to Other Species and Native Salvages ....................................................................... 20

D.4.1 Amphibians ......................................................................................................................... 20

D.4.2 Benthic Macroinvertebrates ................................................................................................ 21

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D.4.3 Native Fish Salvage ............................................................................................................ 25

D.5 Upper Malheur Species Presence/Absence ............................................................................ 25

E. Alternative Actions Considered ............................................................................................... 25

E.1 No Action ............................................................................................................................... 25

E.2 Mechanical Removal .............................................................................................................. 26

E.3 Biological Control .................................................................................................................. 27

E.4 Chemical Control.................................................................................................................... 27

E.4.1 Antimycin ............................................................................................................................ 27

E.4.2 Rotenone .............................................................................................................................. 27

F. Outreach and Education ............................................................................................................ 28

F.1 Public Outreach ...................................................................................................................... 28

F.2 Communication and Education............................................................................................... 29

G. 10-year Implementation Plan (Upper Action Area) ................................................................. 30

H. Monitoring & Recovery Actions.............................................................................................. 30

H.1 Short-term Monitoring (<10 years) ........................................................................................ 30

H.2 Long-term Monitoring (>10 years) ........................................................................................ 31

H.3 Habitat Restoration ................................................................................................................ 31

I. Temporary Barriers and Fish Passage for Migratory Native Fish ............................................. 31

I.1 Temporary Barriers.................................................................................................................. 32

I.2 Permanent Fish Traps at Barrier Sites ..................................................................................... 32

I.3 Trap and Haul .......................................................................................................................... 32

J. References ................................................................................................................................. 34

K. Acronyms ................................................................................................................................. 40

Appendix A ................................................................................................................................... 41

Appendix B ................................................................................................................................... 43

Part II – Supplement 1 ............................................................................................................... 44

A. Contributing Agencies and Participants ................................................................................... 44

B. Introduction .............................................................................................................................. 44

C. Planning Assumptions .............................................................................................................. 44

D. Probability of Success .............................................................................................................. 46

E. Application of Rotenone........................................................................................................... 47

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E.1 Rotenone Project Phases......................................................................................................... 47

E.1.1 Pre-Treatment Phase ............................................................................................................ 47

E.1.2 Treatment Phase .................................................................................................................. 48

E.1.3 Post-Treatment Phase .......................................................................................................... 48

E.1.3.1 Short-term Monitoring (<10 years) .................................................................................. 48

E.1.3.2 Long-term Monitoring (>10 years) .................................................................................. 49

F. References................................................................................................................................. 50

G. Acronyms ................................................................................................................................. 50

Part III – Supplement 2 .............................................................................................................. 51

A. Contributing Agencies and Participants ................................................................................... 51

B. Rotenone Project Planning Stages............................................................................................ 51

B.1 Stage 1 - Internal Review and Approval ................................................................................ 51

B.1.1 Internal Review and Approval ............................................................................................ 51

B.2 Stage 2 - Preliminary Planning and Public Involvement ....................................................... 52

B.2.1 Initial Public Meeting(s)...................................................................................................... 52

B.2.2 Preliminary Treatment and Public Involvement Plans ........................................................ 52

B.2.3 Public Education Meetings.................................................................................................. 53

B.3 Stage 3 - Intermediate Planning and Public Involvement ...................................................... 53

B.4 Stage 4 - Project Implementation and Evaluation .................................................................. 53

C. Project Planning and Public Involvement ................................................................................ 53

C.1 Stage 1 - Project Internal Review and Approval .................................................................... 53

C.1.1 Internal Review and Approval Template ............................................................................ 54

C.2 Stage 2 - Preliminary Treatment and Public Involvement Plan ............................................. 55

C.2.1 Initial Public Meeting (non-NEPA related) ........................................................................ 55

C.2.2 Project Public Meeting Briefing Template.......................................................................... 56

C.2.3 Preliminary Treatment Plan ................................................................................................ 57

C.2.4 Preliminary Treatment Plan Template ................................................................................ 57

C.2.5 Public Involvement Plan ..................................................................................................... 59

C.2.6 Public Involvement Plan Template ..................................................................................... 59

C.2.7 Public Educational Meetings (non-NEPA related) ............................................................. 60

D. Intermediate Planning and Public Involvement Procedures .................................................... 61

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D.1 Intermediate Planning and Public Involvement Proposal Template ...................................... 61

D.2 Public Scoping Meetings (during NEPA process) ................................................................. 64

E. Project Implementation and Evaluation ................................................................................... 64

E.1 Project Implementation .......................................................................................................... 64

E.2 Project Evaluation .................................................................................................................. 65

E.3 Project Evaluation Report Template ...................................................................................... 65

F. References................................................................................................................................. 67

G. Acronyms ................................................................................................................................. 67

Part IV – Supplement 3 .............................................................................................................. 68

A. Contributing Agencies and Participants ................................................................................... 68

B. Introduction .............................................................................................................................. 68

C. Affected Environment and Potential Concerns ........................................................................ 68

C.1 Physical Environment ............................................................................................................ 70

C.1.1 Land Resources ................................................................................................................... 70

C.1.2 Water Resources .................................................................................................................. 71

C.2 Biological Environment ......................................................................................................... 73

C.2.1 Air Resources ...................................................................................................................... 73

C.2.2 Vegetation ........................................................................................................................... 74

C.2.3 Fish and Wildlife ................................................................................................................. 74

C.3 Human Environment .............................................................................................................. 78

C.3.1 Recreational and Land Use ................................................................................................. 78

C.3.2 Public and Worker Safety and Health ................................................................................. 78

C.3.3 Aesthetics and Recreation ................................................................................................... 80

C.3.4 Evaluation of Significance .................................................................................................. 81

D. References ................................................................................................................................ 82

F. Acronyms .................................................................................................................................. 84

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Part I – Strategy Background

Upper Malheur Watershed

Bull Trout Conservation Strategy

Malheur River Bull Trout Technical Advisory Committee

A. Contributing Agencies and Participants

Burns Paiute Tribe (BPT) - Erica Maltz, Kristopher Crowley, and Brandon Haslick

Oregon Department of Fish and Wildlife (ODFW) - David Banks and Benji Ramirez

U.S. Forest Service (USFS) - Steve Namitz, Kate Olsen, and Hazel Owens

U.S. Fish and Wildlife Service (USFWS) - Chris Allen, Suzanne Anderson, and Justin Martens

Bureau of Reclamation (BOR) - Dmitri Vidergar

B. Purpose

Goal: Restore and protect native fish populations in the Upper Malheur River Watershed while

using native fish to provide angling opportunities in High Lake.

Objective: Remove non-native Brook Trout (Salvelinus fontinalis) from up to 10 waterways in

the Upper Malheur River Watershed from 2018 to 2028.

Objective: Restore rehabilitated waterways with native species sourced from existing

populations in the Upper Malheur River Watershed.

Objective: Establish angling opportunities for native Redband Trout (Oncorhynchus mykiss

gairdneri) and Bull Trout (S. confluentus) in High Lake by 2020.

This conservation strategy identifies geographic areas and actions to support recovery of Bull

Trout in the Upper Malheur River Watershed (Figure 1). The actions are intended to address the

primary threat of Brook Trout as identified in the USFWS’s Recovery Plan for the Coterminous

United States Population of Bull Trout (Salvelinus confluentus) (Recovery Plan) (USFWS 2015).

This document serves as a foundation for the Malheur River Bull Trout Technical Advisory

Committee’s (TAC) effort to develop site-specific conservation strategies for the eradication of

Brook Trout. Agencies participating in the TAC are also working independently to further Bull

Trout restoration by addressing additional threats.

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Figure 1. Map of the Upper Malheur River Watershed where the Malheur River Bull Trout Technical Advisory

Committee plans to implement a Bull Trout conservation strategy.

C. Background and Problem Statement

C.1 Bull Trout Recovery Chronology

The coterminous United States population of Bull Trout was listed as threatened on November 1,

1999 (USFWS 1999). Following the listing, draft recovery plans were completed in 2002

(USFWS 2002) and 2004 (USFWS 2004); however the plans were never finalized. In 2008, a 5year review (USFWS 2008) was released reaffirming the species status as threatened. On

October 18, 2010, the USFWS published a final Critical Habitat designation (USFWS 2010), for

the coterminous United States population of Bull Trout, followed by the release of the Recovery

Plan in 2015.

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Although the 2002 and 2004 draft recovery plans were not finalized, they laid the foundation for

the Recovery Plan. At the core of the Recovery Plan are six geographically defined recovery unit

implementation plans (RUIP) that identify conservation actions to address threats (e.g., loss of

habitat connectivity and passage barriers, effects of poor land-management practices, non-native

fish introgression, competition, and predation). To achieve recovery, the Recovery Plan requires

management of primary threats identified in the RUIP. This conservation strategy includes

proposed actions to address threats associated with Brook Trout introgression, competition, and

predation occurring in the Upper Malheur River Core Area.

C.2 Malheur River Bull Trout Technical Advisory Committee Chronology

In an effort to annually convene federal and state agencies to present Malheur River-oriented

Bull Trout recovery work and to coordinate multi-agency monitoring activities, the Malheur

River Bull Trout Forum was initiated in 1997 through the BPT’s Bonneville Power

Administration (BPA)-funded resident fish Project 1997-019-00. Because the annual meetings

were not adequate for developing collaborative actions, particularly those associated with Brook

Trout removal, the USFS, ODFW, USFWS, BOR, and BPT formed the TAC in 2013.

C.3 Upper Malheur River Bull Trout Status and Trends

The Upper Malheur River Bull Trout Core Area represents one of two core areas in the Malheur

River Watershed and includes all possible Bull Trout life history forms (i.e., resident, fluvial, and

adfluvial) (USFWS 2015). Redd count surveys (Perkins 2000-2009) conducted in spawning

tributaries suggest population trends are declining for the migratory life history form. Compared

to other native and non-native species, the relative abundance of Bull Trout is also declining.

Furthermore, introgression with Brook Trout and legacy effects of degraded land use,

exacerbated by changing climate conditions, will likely affect Bull Trout population stability and

growth in the future.

From data collected in 1991 and 1992 during multiple pass removal sampling, ODFW estimated

the population of age-1+ Bull Trout was 4,132 individuals in the North Fork Malheur River

(Buchanan et al. 1997). In the North Fork Malheur River, the USFWS (2002) estimated adult

abundance was between 250 and 300 individuals based on observed spawner-to-redd ratios.

Developing accurate adult Bull Trout abundance estimates for the Upper Fork Malheur River is

problematic. In 1993 and 1994, ODFW estimated the population of age-1+ Bull Trout was 3,554

individuals (Buchanan et al. 1997). Due to the presence of Brook Trout, Bull Trout redds cannot

be distinguished from those of Brook Trout in the Upper Fork Malheur River (USFWS 2002).

Subsequently, inferences have been made based on a calendar date. Perkins (2000-2009)

identified redds observed before September 15th as being constructed by Bull Trout.

The TAC recognizes the population estimates for the North and Upper forks of the Malheur

River as suspect since they are outdated and do not reflect population changes that may be a

result of the prolonged drought that the region experienced.

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C.4 Bull Trout Timing and Movement in the Upper Fork Malheur River

Through BPA Project 1997-019-00, the BPT has identified the timing and spatial extent (Figure

2) of seasonal movements for adult and sub-adult Bull Trout in the Upper Fork Malheur River

Watershed (Schwabe 2000; Fenton and Schwabe 2003; Fenton 2004; Fenton 2005). Studies

(Fenton and Schwabe 2003; Perkins 1999-2009) have shown that fluvial Bull Trout in the Upper

Malheur River Watershed migrate into headwater areas from May to July/August, hold until

spawning in late-August to mid-September, and migrate downstream into overwintering habitat

by the end of September. Overwintering of adult migratory Bull Trout is thought to occur

between river mile (RM) 170-187 (Fenton and Schwabe 2003). The majority of downstream

Figure 2. Spatial extent of adult and sub-adult Bull Trout movements observed during a telemetry study in the Upper

Malheur River Watershed.

migration appears to occur prior to December; however, telemetry data suggest downstream

migration continues to occur throughout the winter months.

Fluvial migration into Big Creek and Meadow Fork Big Creek has been documented; however,

migratory movement into Lake Creek appears to be limited, potentially due to thermal barriers

(Fenton and Schwabe 2003; DeHaan et al. 2010a). Suppositions of thermal impediments are

supported by recorded mean monthly maximums of 69.8-75.2° F in the lower stretches of Lake

Creek from June to August (BPT, unpublished data).

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To date, there have been no investigations to evaluate the relative dominance of the fluvial or

resident life history strategies. The TAC believes the adfluvial form does not exist in the Upper

Malheur River Watershed due to proximity of the headwaters to the Warm Springs Reservoir and

based on results from the BPT’s 2000-2005 telemetry study in which no individuals were

documented using the reservoir. Based on limited observations during the 2000-2005 telemetry

study, the predominant life history appears to be the resident form, likely due to unsuitable

thermal conditions downstream from Lake Creek; however, the TAC believes the fluvial and

resident life histories may be expressed by Bull Trout in other Upper Malheur River creeks.

C.5 Brook Trout/Bull Trout Interactions in the Upper Malheur River

C.5.1 Brook Trout Introductions

Non-native Brook Trout currently exist in high numbers throughout the Upper Malheur River

and its tributaries. The source of Brook Trout in the Upper Malheur River is understood to be

from authorized stockings in High Lake from as early as the 1930s as well as authorized and

unauthorized stockings throughout the basin prior to the 1990s (Bowers et al. 1993). These

stockings have led to a Brook Trout distribution in the Upper Malheur River Watershed (Figure

3) that completely overlaps that of native Bull Trout (Figure 4) and Redband Trout. Although the

historic presence or absence of native fish cannot be proven, the TAC believes High Lake was

fishless prior to the stocking efforts.

C.5.2 High Lake and Upper Lake Creek: Brook Trout Seed Sources

High Lake is a 5.8-acre lake located in the Strawberry Mountain Wilderness at an elevation of

7,500 feet (Figure 1). Except for a spring that delivers a small amount of perennial water, all

stream flow into High Lake is ephemeral. The breeding population of Brook Trout in High Lake

is a recognized source for downstream recruitment to Brook Trout clusters found in Bull Trout

habitat located in the middle reaches of Lake Creek (Fenn 2004b; DeHaan et al. 2010a).

Lake Creek, High Lake’s outflow, flows approximately 12.5 miles from High Lake to its

confluence with Big Creek where the two form the Upper Malheur River (Figure 1). Located at

RM 11 in Lake Creek is Lake Creek Falls which functions as a complete barrier to upstream fish

passage. Much of the approximately 1.5 stream miles above Lake Creek Falls (Upper Lake

Creek) are characterized by channel widths of 3.2-6.6 feet and moderate gradients (2-5%) with

intermittent steep reaches (15-20%) that may prevent upstream fish passage. Lake Creek is

joined by two small perennial streams within one mile of High Lake. Brook Trout are the only

fish species present above Lake Creek Falls.

Brook Trout are found in abundance in High Lake and throughout Bull Trout spawning habitat

downstream of Lake Creek Falls to Logan Valley (Table 1). Despite recent removal efforts, High

Lake and Upper Lake Creek remain exclusively Brook Trout strongholds (Crowley 2016).

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Figure 3. Known distribution of non-native Brook Trout in the Upper Malheur River Watershed.

Figure 4. Known distribution of Bull Trout in the Upper Malheur River Watershed.

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Table 1. - Brook Trout population estimates for the Upper Malheur River Watershed.

Number of Brook Trout removed

Year

Lake Creek

Lake Creek

High Lake

weir

electrofishing

gillnetting

2010

2,206

2011

322

266

807

2012

139

1,386

711

2013

56

2,640

0

2014

901

1,782

2015

1,606

0

Total

7,316

5,506

a

11,797, 95% confidence interval: 9,362-14,232 (Harper 2013)

b

3,477, 95% confidence interval: 2,598-4,766 (Crowley 2014)

Population estimates

Lake Creek

11,797a

High Lake

6,621

3,965

1,802

3,477b

In systems where Brook Trout and Bull Trout are sympatric, Bull Trout typically occupy

headwater reaches while Brook Trout disperse further downstream (Paul and Post 2001).

However, Adams et al. (2001) found that when Brook Trout are introduced into headwater lakes,

they may be more widely distributed. Fenn (2003a) suggested that the type of distribution

described by Adams et al. (2001) resembles that exhibited by Brook Trout in Lake Creek (i.e.,

High Lake and Upper Lake Creek are recognized as seed sources for recruitment of Brook Trout

downstream into Bull Trout habitat in Lower Lake Creek and adjacent tributaries).

C.5.3 Big Creek

Brook Trout are also found in abundance in Big Creek (Fenn 2004a, 2004b), a known area of

Bull Trout migration and rearing (Fenton and Schwabe 2003; Fenton 2004; Fenton 2005), as

well as spawning (Perkins 1999-2009). Because Lake Creek is thought to have seasonal thermal

barriers that may isolate the resident Bull Trout population (DeHaan et al. 2010a), the threat of

Brook Trout in Big Creek is not as dire as in Lake Creek, as the distribution is consistent with

patterns typical of streams lacking an upstream seed source (Paul and Post 2001). Regardless,

limiting factors exist relative to Bull Trout spawning in Big Creek. Seasonally high stream

temperatures may create thermal barriers to out-migrants (Abel 2008) and hybridization with

Brook Trout has been documented (DeHaan et al. 2010a). The most common spawning area for

Bull Trout in the Upper Malheur River Watershed is considered to be the Meadow Fork tributary

of Big Creek (Perkins 1999-2009).

C.5.4 Bull Trout and Brook Trout Interactions: Hybridization

Hybridization between Brook Trout and Bull Trout has been documented in other basins (Leary

and Allendorf 1991; Kanda et al. 2002); however, Leary et al. (1993) suggested occurrence

beyond the F1 generation is believed to be uncommon. In contrast, mitochondrial DNA analyses

have shown hybridization is occurring in the Upper Malheur River Watershed with involvement

from both sexes of each species beyond the F1 generation and with incidences of reciprocal

backcrossing (DeHaan et al. 2010a). In the Upper Malheur River Watershed, occurrence of

hybridization is highest in Lake Creek, with a lower degree of hybridization found in Big Creek

and its tributaries (DeHaan et al. 2010a), likely due to downstream recruitment from the High

Lake population (DeHaan et al. 2010a).

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Two factors may be contributing to the hybridization events. Even with introgressive

hybridization, as is suggested to be occurring based on evidence provided for the Malheur and

other basins (DeHaan et al. 2010a; Kanda et al. 2002), the problem has often been contextualized

in terms of wasted reproductive effort on the part of female Bull Trout (Allendorf et al. 2001;

Kanda et al. 2002). Additionally, earlier maturation among Brook Trout females may be

exacerbating the rate of hybridization and competition over time (Leary et al. 1993; Gunckel et

al. 2002; Adams 1999; Kennedy et al. 2003; McMahon et al. 2007).

C.5.5 Bull Trout and Brook Trout Interactions: Competitive Advantages

Competitive advantages of Brook Trout over Bull Trout have been documented (Gunckel et al.

2002; McMahon et al. 2007); however, habitat pressure and population level effects of Brook

Trout presence on Bull Trout can be highly variable (Rieman et al. 2006). Rieman et al. (2006)

theorized that Brook Trout may limit areas that Bull Trout occupy and ultimately displace

remnant Bull Trout populations into headwater areas. Gunckel et al. (2002) found that Bull

Trout, in the presence of Brook Trout, exhibited no shifts in feeding behavior after examining

microhabitat in the Malheur and Powder rivers, and that Brook Trout exhibited competitive

advantages through dominance and higher growth rates. Gunckel et al. (2002) and McMahon et

al. (2007) found that Brook Trout were more aggressive than Bull Trout in areas of sympatric

distribution. McMahon et al. (2007) found that at temperatures >57.7°F, Brook Trout exhibited

growth advantages over Bull Trout and greater metabolic efficiency at 60.8-68°F. Competitive

advantages for Bull Trout were not documented in cooler temperatures.

C.6 Genetics and Small Populations

Bull Trout spawning populations in the Upper Malheur River Watershed do not exist in isolation

from each other. Other than Lake Creek Falls which blocks upstream migrations in the

uppermost section of the Upper Malheur River Watershed, barriers to spawning habitat are

absent elsewhere in the watershed. The belief that gene flow could be occurring among the

populations is supported by the findings of Spruell et al. (2003), through which variation in

Meadows Fork Big Creek (HS = 0.359) was found to be high compared to the mean HS (0.186)

for 65 Bull Trout populations surveyed throughout the species range of distribution.

Whiteley et al. (2006) suggested that an understanding of existing genetic differentiation is

important “to avoid mismanagement based on the assumption that fine-scale genetic

differentiation is homogenous within distinct regions across a species range.” The TAC

recognizes caution must be exercised relative to interpreting the results from Spruell et al.

(2003), as a limited number of populations and loci were screened. The limited understanding of

the genetic population structure in the Upper Malheur River Watershed warrants a conservative

management approach, as other studies have identified genetic differentiation among Bull Trout

populations in close proximity (e.g., Leary et al. 1993; Spruell et al. 1999; Costello et al. 2003;

Whiteley et al. 2006). Spruell et al. (2003) suggested local populations in close proximity

typically are genetically distinct.

Multiple Bull Trout life history forms, including migratory forms, exist in the Upper Malheur

River Watershed. Rieman and Dunham (2000) suggested maintaining such life history forms is

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important for Bull Trout persistence. Throughout the species range, the development of barriers

that prevent passage of migratory fish or facilitate dispersal among tributaries has led to reduced

gene flow and the loss of genetic diversity (Nerass and Spruell 2001; Costello et al. 2003;

Whiteley et al. 2006; DeHaan et al. 2007; DeHaan and Hawkins 2009; DeHaan et al. 2010b).

To successfully implement the rotenone project (detailed discussion about rotenone application

provided in Section D), temporary barriers must be installed to prevent Brook Trout from

reentering treated areas. Although the barriers are intended to be temporary, the time periods for

which the barrier will be functioning are unknown and the potential disruption of migratory

corridors for Bull Trout must be addressed to conserve the existing life history forms. Because

smaller Bull Trout populations (e.g., less than 100 spawning adults) may be prone to extinction if

they are isolated (Rieman and McIntyre 1993; Dunham and Rieman 1999), actions will be

implemented to avoid isolation and protect genetic variation and maintain the existing life

history forms that exist within and among the populations.

To avoid an isolation scenario that could restrict gene flow and affect genetic variation and the

expression of migratory life histories, the TAC intends to operate traps at each barrier. The traps

will allow for fish to be successfully transferred during periods of migration.

C.7 Environmental Variations

Environmental variation affects the entire population and includes the biological and physical

environment. Biological environment includes birth, death (i.e., population demographics), intraand inter-species competition, food resources, and disease. Physical environment includes

temperature, stream flow, migratory corridors and suitable habitat. Stable, predictable

environments require fewer individuals in a population to persist over time than do highly

variable environments. In general, the combination of the loss of genetic diversity and

environmental fluctuations pose survival risks for small populations.

C.8 Timeline of Past Brook Trout Removal Efforts

Through BPA Project 1997-019-00 and funding provided by the BOR Native Affairs, the BPT

began to mechanically remove Brook Trout in 2010 (limited to electrofishing in Lake Creek and

gillnetting in High Lake). In 2012, the Northwest Power and Conservation Council approved the

BPT to implement a five-year Brook Trout removal effort using electrofishing, gillnetting, and

weir operations with a targeted 50% reduction in adult/sub-adult Brook Trout. Through the

effort, the BPT found that mechanical removal was not an effective method in Lake Creek due to

stream channel complexity, instream vegetation/woody material, and yearly Brook Trout

spawning success (Crowley 2016). Data indicate gillnetting in High Lake moderately controls

Brook Trout populations if conducted annually; however, wildfires made consistency

unattainable. From 2011-2013, a weir was operated seasonally in Lake Creek to capture

migrating individuals. This effort was discontinued due to low capture numbers relative to

staffing requirements as well as the potential of disrupting Bull Trout movements.

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C.9 Climate Change Resilience and Habitat Restoration

In addition to habitat degradation resulting from land management practices, rivers and streams

throughout the Pacific Northwest are threatened by the effects of climate change. The Rocky

Mountain Research Station in Boise, Idaho has modeled stream temperatures throughout the

region and determined that only the highest elevation headwater streams, like the headwaters in

the Upper Malheur River Watershed, will provide suitable or near-suitable temperatures for

salmonids (Figure 5) (NorWeST 2015).

Warming air temperatures associated with climate change will lead to warmer water

temperatures. The extent to which air temperature influences water temperature is a result of not

only the degree of warming, but also local and linear environmental variables. Specifically, the

quality of riparian habitat directly influences water temperature through shading of solar

radiation, storage of water in the floodplain, effect on channel geometry and other factors.

Wondzell (2016) found that the potential for riparian restoration to buffer the impacts of climate

change on streams is high (Figure 6). Initial results indicated that riparian restoration may have

the potential to improve in-stream habitat to levels that will counter the projected impacts of

climate change in the most extreme examples. Although climate change will improve the

competitive advantage that Brook Trout hold over Bull Trout, the Upper Malheur River

Watershed will retain some areas of refuge for Bull Trout as this system is groundwater-based.

Although the potential impacts of climate change are projected to lead to a more impaired Upper

Malheur River Watershed, habitat restoration actions would combat or minimize negative

impacts of climate change on water temperatures. In addition, cold groundwater inputs will

likely provide a natural buffer.

D. Proposed Action

As an interagency effort, the TAC proposes to salvage native fish from sections of the Upper

Malheur River Watershed (Figure 7) and to treat the area with rotenone to eradicate Brook Trout.

Efforts to eradicate Brook Trout will be completed through a 10-year effort during which an

initial group of barriers will be installed to prevent the invasion of Brook Trout into treated areas

(Figure 7).

Depending on the type of holding area used, monitoring fish for survival may be necessary. The

TAC has high confidence that this will be successfully accomplished by holding fish in nearby

streams, streamside holding tanks, or hatcheries. If deemed necessary, the TAC may choose to

hold native fish in multiple locations to minimize the risk of total loss. When conditions permit,

Bull Trout and other native fish will be returned to the treated reaches. Treatment of other action

areas will occur at a later date and be dependent on the success of the initial effort.

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Figure 5. Projected Upper Malheur River Watershed stream temperatures for 2080 (NorWeST 2015).

Figure 6. Results of model simulations using HeatSource calibrated to a base-year of 2002. Projections for 2040 are

shown as colored boxes and represent ensembles of model runs with a single riparian vegetation scenario. Each box

includes projections for high, current, and low discharge. The height of each box reflects the influence of ± 30%

changes in discharge (Wondzell 2016).

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Figure 7. Action Area (Upper Action Area) in the Upper Malheur River Watershed that may be treated with

rotenone to eradicate Brook Trout and potential sites, designated with triangles, at which barriers may be installed.

The following views contributed to the development of this strategy:

1) Brook Trout are a primary threat to the persistence of Bull Trout in the Upper Malheur River

Watershed.

2) While other primary threats exist to Bull Trout in the Upper Malheur River Watershed, the

reduction/removal/suppression of Brook Trout in conjunction with habitat restoration are the

highest priority recovery actions in the watershed.

3) The eradication of Brook Trout from treated reaches, habitat restoration, and establishment/

maintenance of barriers are determined to be feasible actions with moderate to high chances of

success in the reestablishment and persistence of Bull Trout and other native fish.

4) Brook Trout removal and habitat improvements must be addressed in tandem.

5) A solution will require interagency cooperation.

6) Watershed strategy for Brook Trout removal and habitat restoration is needed for success.

7) Education and outreach are needed to spread awareness of the problem and increase success

of the project.

8) Removal treatments must incorporate the use of rotenone to maximize the chance of success.

16

9) Monitoring the response of Bull Trout following the removal of Brook Trout and habitat

restoration will be essential to evaluate success, guide adaptive management actions, and direct

similar efforts in the future. A committed effort prior to project implementation will ensure an

appropriate level of monitoring has been identified.

D.1 General Summary of Precedent Projects

Table 2. Examples of rotenone efforts by ODFW, in Oregon, to eradicate non-native fish.

State

Waterbody

Target Species

Oregon

Summit Gravel Pond

Smallmouth Bass and crayfish

Oregon

McDermott Creek

Rainbow Trout

Oregon

Diamond Lake

Tui Chub

Oregon

Sun Creek

Brook Trout

Oregon

Diamond Lake

Tui Chub

Oregon

Walton Lake

Brown Bullhead

Oregon

South Twin Reservoir

Brown Bullhead

Oregon

Antelope Flat Reservoir Brown Bullhead

Oregon

Crane Prairie Pond

Brown Bullhead

Oregon

Lofton Reservoir

Tui Chub

Oregon

Beck-Kiwanis Pond

Carp and Goldfish

Oregon

North Twin Reservoir

Brown Bullhead

Oregon

Sun Creek

Brook Trout

Oregon

McDermitt Creek

Rainbow Trout, Brook Trout, Brown Trout

Oregon

Sage Creek

Rainbow Trout and Brook Trout

a

Effort unsuccessful due to illegal releases following treatments

Successful

Yes

Noa

Noa

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

D.2 General Summary of Relevant Policies

ODFW Native Fish Conservation Policy - The purpose of this policy is to ensure the

conservation and recovery of native fish in Oregon. The policy is implemented through

conservation plans, developed in collaboration with management partners and the public,

that identify the desired and existing status of native fish, key limiting factors, and

management options, and monitoring required to evaluate success.

BPT Tribal Council - The BPT staff has multiple mandates to restore native fish

populations within the boundaries of the former reservation. These include Tribal Council

resolutions and broad sense goals for the Malheur River. Additionally, the BPT manages

8,000 acres of land including 14 miles of stream. The BPT also manages one BPA

Resident Fish project that has provided a primary source of funding and coordination

since its inception in 1997. The interest and commitment to the health of the native

species of the Malheur River is demonstrated by these policies of the Tribal Council as

well as the longevity of presence of BPT work in the Malheur River. The BPT manages

its 8,000 acres consistent with best available conservation measures for fish and wildlife.

USFS - In regards to managing wilderness, the Forest Service Manual (FSM), guides the

USFS “to protect known populations of federally listed threatened or endangered species

where necessary for their perpetuation and aid in their recovery in areas of previous

habitation (FSM 2323.32)”, identifying chemical treatment as a method for completing

this goal. Although chemical treatment requires a Regional Forester signature, it “may be

17

used to prepare waters for reestablishment of indigenous, threatened or endangered, or

native species, or to correct undesirable conditions caused by human influence (FSM

2323.34f)”. Restocking of fish prioritizes federally listed indigenous as a priority,

followed by indigenous species, and under the circumstance that stocking is occurring in

barren waters “only after determining that the scientific and research values of such

barren waters will not be eliminated from a wilderness and documenting the desirability

of such action in the forest plan (FSM 2323.34c)”. In this case, restocking will only occur

in a limited number of high elevation lakes that have been barren, retaining this

characteristic in other locations. The Malheur National Forest Land and Resource

Management Plan (USDA 1990) identifies numerous goals that will be achieved by these

actions, including but not limited to the following:

Fish and Wildlife (IV-2):

 15. Assist in the identification, protection and recovery of threatened, endangered

and sensitive species.

 16. Coordinate fish and wildlife management activities with other agencies and

organizations to achieve mutual resource goals and utilize project cost share

opportunities.

 18. Provide for improved habitat conditions to support increased populations of

anadromous and resident fish.

 19. Provide a diversity of habitat sufficient to maintain viable populations of all

species.

The following guidance also exists in the FSM and is related to ODFW’s involvement in

activities on USFS land:

FSM 2600 (Exhibit 5) – The USFS shall recognize ODFW as being responsible

for the management of all fish and wildlife species over which it has jurisdiction

in the State of Oregon.

FSM 2323.32 – Recognize that states have jurisdiction and responsibilities for the

protection and management of wildlife and fish populations in wilderness.

FSM 2323.34f – Chemical treatment may be used to prepare waters for

establishment of indigenous, threatened, or endangered, or native species, or to

correct undesirable conditions caused by human influence.

FSM 2323.34 – Emphasize quality and naturalness in managing fisheries in

wilderness.

D.3 Action Areas

To guide the development of sequential treatment strategies, the TAC has identified tributaries

that are priorities for Brook Trout removal in the Upper Malheur River Watershed (Table 3 and

Figure 7). Pending the success of the efforts in the initial tributaries, the TAC envisions treating

middle and lower areas of the Upper Malheur River Watershed.

18

D.3.1 Upper Action Area

The Upper Action Area consists of tributaries that have a high conservation value for Bull Trout

spawning and rearing, as well as being feasible for immediate treatment over a 10- year period.

As the 10-year threshold is approached, the TAC will evaluate treatment options for additional

downstream locations.

Table 3. Tributaries located in the Upper Action Area of the Upper Malheur River Watershed that are priorities for

habitat restoration and Brook Trout removal.

Action area

Upper

Stream

Frazier Creek

Bosonberg Creek

Corral Basin Creek

Big Creek

Snowshoe Creek

Meadow Fork Big Creek

Crooked Creek

McCoy Creek

Lake Creek

Subtotal

Miles

4.2

9.3

3.6

1.3

2.4

4.6

9.8

6.9

1.5

43.6

The downstream terminus of the Upper Action Area is at the confluence of Bosonberg Creek

with the Malheur River. To create treatment sections that are of a manageable size, several

barriers will be installed upstream of the terminus. The terminus was selected due to the potential

to install a barrier at this location. Maintenance of a barrier at the Bosonberg Creek crossing (the

lowest barrier on the mainstem in place in perpetuity) would facilitate the eventual removal of

upstream barriers following the verification that downstream treatments were successful at

removing Brook Trout and that Brook Trout are prohibited from migrating upstream into the

treated areas.

The Bosonberg Creek crossing barrier will have to be maintained for native fish (i.e., Redband

Trout, Mountain Whitefish (Prosopium williamsoni), and Bull Trout) passage to retain fluvial

life history strategies. The angling value of Brook Trout in the Upper Action Area is deemed low

relative to more popular areas such as Lower Summit Creek, which was excluded. Upper

portions of Summit Creek that may provide habitat suitable for Bull Trout (not currently

occupied) and are located above partial passage barrier culverts (which may be easily modified

to be passage barriers) could potentially be treated separately.

D.3.2 Middle Action Area

The Middle Action Area is located downstream of a putative barrier placement at the confluence

of Bosonberg Creek and the Mainstem Malheur River to Malheur Ford (below the confluence

with Summit Creek). This area includes Summit Creek with the possible exception of its

headwaters. The action area is a migratory corridor for Bull Trout, connecting overwintering

habitat downstream to upstream spawning grounds; however, limited data supports the idea that

Bull Trout use this area during the summer. Treating this section would allow resident and

migratory meta-populations to be connected and to use habitat recovery areas like those in

19

Summit Creek. Work in this area would occur following the initial 10-year effort in the Upper

Action Area.

D.3.3 Lower Action Area

The Lower Action Area includes the Mainstem Malheur River downstream of Malheur Ford to

below the confluence with Bluebucket Creek. Although this area is feasible to treat from an

implementation perspective, the associated cost would be significant. Work in this area would

occur following the initial 10-year effort in the Upper Action Area.

D.4 Effects to Other Species and Native Salvages

D.4.1 Amphibians

Results from amphibian surveys (Haslick 2016b and unpublished data) conducted in High Lake

and Lake Creek Meadow (984 feet downstream from High Lake) are presented in Table 4.

During the 2-year study, only one Pacific Tree Frog (Pseudacris regilla) was collected from

Lake Creek Meadow. Although vulnerable (state classification) Western Toads (Anaxyrus

boreas) were not captured in High Lake in 2016, more than 1,500 tadpoles (multiple Gosner life

stages) were captured in 2014. Adult Western Toads and Pacific Tree frogs were also observed

while setting traps. The disparity in capture numbers, between the two years, highlights the

importance of allowing for flexible rotenone treatment schedules to limit larval mortality.

Additional surveys using cover boards, pitfall traps, and/or visual observation are likely required

at nearby vernal pools to assess the presence of additional species. If additional species are

identified, respective life history information will be used to guide treatment planning.

(Supplement 3 provides additional discussions)

In 2015 and 2016, visual encounter surveys were conducted for Big, Lake, and McCoy creeks

during which multiple life stages (i.e., egg mass, tadpole, and adult) of Columbia Spotted Frog

(Rana luteiventris) were identified. Future surveys of these creeks may include the use of cover

boards, pitfall traps, and/or visual encounter surveys at nearby vernal pools.

Due to the susceptibility of larval amphibians to rotenone applications (Lindahl and Oberg

1961), treatments will be conducted when that life stage is not present or substantially reduced. If

factors do not allow for flexible treatment schedules to protect amphibians, results from studies

(e.g., Billman et al. 2012) have shown amphibian populations are capable of recovering rapidly

following treatments. Because rotenone is rapidly broken down by organic matter, sunlight,

hydro turbulence, and other natural processes (Dawson et al. 1991; Brown and Zale 2012), direct

effects on subsequent generations of amphibians are not expected. (Supplement 3 provides

additional discussions)

To evaluate amphibian recovery in High Lake, larval specimens will be trapped, marked, and

recaptured prior to treatment to determine estimated population sizes for each species. Following

treatment, population estimates will be conducted annually. Recovery will not be considered

20

complete until species assemblages and population estimates equal or exceed pre-treatment

levels. If necessary, amphibian recovery will be monitored in other treatment reaches.

Table 4. Presence of amphibian species in Upper Malheur River Watershed areas proposed for rotenone treatments.

High Lake/Upper Lake Creek

Species

Anurans

American

Bullfrog

Columbia

Spotted Frog

Pacific Tree

Frog

Western

Toad

Great Basin

Spadefoot

Toad

Salamander

Long-toed

Easter Tiger

Confirmed

presenta

Reproduction

observed2

Likelihood

of

occurrence3

Upper Middle Fork Malheur tributaries

(Big/Snowshoe to Bluebucket)

Likelihood

Confirmed

Reproduction

of

presenta

observedb

occurrencec

No

Low

No

No

High

Yes (visually

and audibly)

Yes (visually

and audibly)

Yes

(visually

and

audibly)

Yes

(visually

and audibly

No

Yes

Yes

Origin

Conservation

status

Introduced

Not listed

Yes

Native

No

Native

Vulnerable

(state)

Not listed

Low

No

High

Native

Vulnerable

(state)

High

No

High

Native

Not listed

No

High

No

Native

Not listed

No

Low

No

Medium

high

Low

Likely both

Not listed

a

Based on BPT visual encounter, minnow trapping, and incidental surveys from 2015 and 2016.

b

Includes egg mass, tadpole, aquatic larvae, and/or metamorph visual confirmation. Tadpole and salamander larvae lethal

susceptibility to chemical treatment stresses and importance of treatment timings to minimize tadpole exposure, if possible.

c

Based on a combination of habitat needs, occurrence records, life history, and population dynamics.

D.4.2 Benthic Macroinvertebrates

Similar to amphibians, benthic macroinvertebrates are vulnerable to rotenone. Impacts of

rotenone to benthic macroinvertebrate species are variable and depend on factors including

concentration and duration, habitat use variability, and life history differences. Depending on the

availability of upstream population sources and individual dispersal capabilities, benthic

macroinvertebrate populations have been shown to recolonize and recover quickly following

treatments (Magnum and Madrigal 1999; Hamilton et al. 2009; Vinson et al. 2010)). To monitor

the impacts of the rotenone treatments, the BPT will sample benthic macroinvertebrates in Upper

Lake Creek and other reaches after the treatments have been completed. Data will be compared

to pre-treatment results to monitor progress towards achieving the goal of realizing posttreatment taxa diversity and population numbers that approximate pre-treatment estimates.

A total of 79 unique benthic macroinvertebrate taxa have been identified between High Lake and

Lake Creek Falls (stream length of 1.5 miles), with the majority of the representatives being

members of the order Arthropoda (classes Insecta, Arachnida, and Ostracoda); however,

Mollusca, Annelida, Nemata, and Platyhelminthes were also present (Haslick 2016a). To

compare benthic macroinvertebrate abundance along the 1.5 mile section of Lake Creek, the

21

creek was partitioned into sampling reaches of .25 miles. The orders Ephemeroptera, Diptera,

and Plecoptera were typically the most abundant in each reach (Figures 8-12).

Figure 8. Lake Creek Reach 1 benthic macroinvertebrate percent abundance (Haslick 2016a).

Figure 9. Lake Creek Reach 2 benthic macroinvertebrate percent abundance (Haslick 2016a).

22

Figure 10. Lake Creek Reach 3 benthic macroinvertebrate percent abundance (Haslick 2016a).

Figure 11. Lake Creek Reach 4 benthic macroinvertebrate percent abundance (Haslick 2016a).

Figure 12. Lake Creek Reach 5 benthic macroinvertebrate percent abundance (Haslick 2016a).

23

Multiple feeding groups of benthic macroinvertebrates (i.e., predators, omnivores, parasites,

collectors, shredders, and scrapers) have been identified in each reach between High Lake and

Lake Creek Falls (Haslick 2016). Specimens collected from the high-elevation stream (6,6007,450 feet) represented taxa characterized as having thermal preferences for cooler temperatures.

Results indicated that sensitive and intolerant taxa exceeded tolerant taxa suggesting the aquatic

ecosystem above Lake Creek Falls is relatively void of human disturbance. Results from Benthic

Invertebrate Index of Biological Integrity tests (Table 5) classified each reach as ‘high biological

integrity’ except Reach 5 which scored moderate (Haslick 2016a). Predator, scraper, and

shredder richness, as well as percent collector and Chironomidae were limiting factors

preventing many of the Lake Creek reach sites from being classified as ‘high biological

integrity.’ Despite the limiting factors, all reach sites scored relatively highly when the additional

parameters were included in the analyses.

Table 5. Benthic Invertebrate Index of Biological Integrity (BIBI) a,b and community composition results from

sampling conducted in five reaches of Lake Creek (between Lake Creek Falls and High Lake) on 12 September

2014. Metric scores of 1, 3, and 5 represent ratings of low, moderate, and high, respectively.

Lake Creek Reach

1

Metric

Total number of taxa

Number of Ephemerotera

taxa

Number of Plecoptera taxa

Number of Trocoptera taxa

Number of long-lived taxa

Number of intolerant taxa

Percentage of tolerant taxa

Percentage of predators

Number of clinger taxa

Percentage dominance (3

taxa)

2

3

4

5

Value

Score

Value

Score

Value

Score

Value

Score

Value

Score

53

11

5

5

50

12

5

5

59

11

5

5

51

6

5

3

40

6

3

3

14

9

16

22

0.8

22

27

24

5

3

5

5

5

5

5

5

8

6

11

18

2.8

8.5

23

47

5

3

5

5

5

1

5

5

14

10

18

23

0.2

14

31

38

5

5

5

5

5

3

5

5

11

10

18

21

0.2

10

26

39

5

5

5

5

5

3

5

5

9

5

10

15

0

9.8

19

52

5

3

5

5

5

1

3

3

48

Total score

44

48

46

36

Total abundance (m2)

EPT taxa richness

Predator richness

Scraper richness

Shredder richness

Percentage of intolerant taxa

Percentage of collectors

Percentage of parasites

Percentage of Oligochaeta

Number of tolerant taxa

Percentage of Simuliidae

2057

34

15

8

9

30

47

2.1

2.9

0

0

1644

26

8

8

8

64

45

3.8

1.4

3

0.4

2625

35

19

8

9

36

62

1

0.8

1

0

4502

27

14

3

7

32

72

1.2

0.2

1

0.4

6305

20

9

2

7

21

72

1.3

0.3

0

0.2

Percentage of Chironomidae

37

21

46

56

46

a

The BIBI is based on average/summation of three replicates, not an individual replicate

b

Red cells represent BIBI scores between 0 and 24, yellow cells 25 to 39, and green cells represent scores >40

Results from (Haslick 2016a) suggest upper Lake Creek represents a healthy aquatic ecosystem

for which impacts from rotenone treatments will be temporary. Numerous studies (e.g., Hamilton

24

et al. 2009; Vinson et al. 2010) have shown benthic macroinvertebrates recover rapidly following

rotenone treatments. Regardless, rigorous post-treatment monitoring and analyses will be

implemented to ensure population numbers and taxa assemblages have recovered.

D.4.3 Native Fish Salvage

Prior to initiating rotenone treatments in the Upper Malheur River Subbasin, native fish salvage

will occur by means of electrofishing, snorkeling, minnow traps, and/or other net-types. Because

fish salvaged from the proposed treatment sites will be relocated to areas in the Upper Malheur

River Watershed that are not being treated concurrently, multiple streams will be treated during

the first year and repopulated when monitoring results indicate Brook Trout have been

successfully removed.

D.5 Upper Malheur Species Presence/Absence

Known fish assemblages for the Upper Malheur River (Table 6) are largely based on BPT

sampling efforts that have been focused on salmonid species; however, other species

encountered were identified and recorded.

E. Alternative Actions Considered

The Recovery Plan lists Brook Trout as a primary threat to Bull Trout in the Upper Malheur

River Core Area. Brook Trout are widely distributed throughout the Core Area, inhabiting an

estimated 94 stream miles. Due to staffing, funding, and logistic requirements, it is not feasible

to singly treat the entire area occupied by Bull Trout.

Without partitioning the areas that are to be treated, the likelihood of success is low for

treatments of this size. Temporary barriers will be installed to segment the affected area into

sizes that can be feasibly treated and are consistent with known use by Bull Trout. Barriers will

remain in place if Brook Trout continue to exist in adjacent reaches or are known to seasonally

access the treated reach. The treatments will be comprehensive to avoid assumptions that Brook

Trout are not present in some areas.

Alternative management actions that have been considered include: no action, mechanical

removal, biological control, and other chemicals.

E.1 No Action

No action will result in status quo of nearly ubiquitous Brook Trout with continued hybridization

and no progress towards Bull Trout recovery within the Upper Malheur Core Area. With no

action, hybridization and competition for limited resources will lead to declines in Bull Trout

abundance and eventually extirpation.

25

E.2 Mechanical Removal

Electrofishing, gillnets, trammel nets, and trap nets are used extensively in fisheries to capture

fish. Although the equipment is effective for sampling fish for the purpose of acquiring

biological data, the gear is inefficient for use in long-term population suppression projects due to

staffing/financial needs, gear biases, and environmental characteristics. Staffing needs (requires

at least two staffers), annual effort in perpetuity, and financial costs render mechanical removal

an ineffective approach to remove fish on a long-term basis (Table 7). Regarding gear biases,

incorrect net mesh size can lead to smaller size classes not being captured. The effectiveness of

mechanical methods can also be affected by lake bathymetry, channel complexity, substrate, and

vegetation.

Since 2010, the BPT has been deploying gillnets in High Lake. Positive results were observed

when the lake was sampled extensively and annually; however, wildfires resulted in the

cancellation of sampling during 2013 and 2015. Crowley (2014) found missed annual sampling,

Table 6. Fish collected from the Upper Malheur River Watershed during sampling efforts.a

Species

Waterbody

Brook

Trout

Bull

Trout

Redband

Trout

Sculpin

Redside

Shiner

Speckled

Dace

Lake

Big

Meadow

Fork

Summit

Snowshoe

McCoy

Crooked

Bosonberg

Tureman

Black

Canyon

Skookum

Lee

Bluebucket

Wolf

Corral

Basin

Pine

Mainstem

Malheur

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

a

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Long

Nose

Dace

X

X

X

Bridge

Lip

Sucker

X

X

X

Large

Scale

Sucker

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

X

Mountain

Whitefish

Northern

Pikeminnow

X

X

X

X

X

X

X

X

X

X

The list should not be viewed as a definitive measure of species presence or absence or inclusive of all tributaries.

Table 7. Examples of costs associated with mechanical removal projects to suppress non-native fish in Oregon.

Waterbody

East Lake

Target species

Tui Chub

Treatment type

Trap net

Years

2010-2011

East, Paulina, and

Lava lakes

Tui Chub

Trap net

2012-2013

Investment

446 staff hours/year and 319

volunteer hours/year

$15,000

Diamond Lake

High Lake

Golden Shiner

Brook Trout

Electrofishing

Gillnet

2008-2013

2010-2016

45 staff hours/year

240 staff hours/year

26

during the years affected by the wildfires, led to the population expanding to near pre-removal

abundance due in part to Brook Trout quickly reaching sexual maturity.

The BPT and ODFW have suggested that mechanical removal is not a viable or cost-effective

option, respectively, to eradicate Brook Trout from High Lake. Given the environmental

conditions (i.e., drought and wildfires), the BPT believes yearly sampling is neither sustainable

nor a viable solution to eradicate Brook Trout. The ODFW has indicated that it likely is not

possible to annually remove 50% of the Brook Trout with mechanical methods and that costs

would outweigh benefits.

E.3 Biological Control

For a biological control to effectively reduce or eliminate unwanted species, it must remove the

unwanted species faster than the species can reproduce. Sterile fish (i.e., tiger trout (Brown Trout

Salmo trutta x Brook Trout), tiger musky (Muskellunge Esox masquinongy x Northern Pike E.

lucius), and hybrid striped bass (Striped Bass Morone saxatilis x M. chrysops) were the only

biological controls considered for High Lake. The potential biological controls are the only

sterile fish currently used by ODFW; however, the fish are unacceptable for several reasons.

Tiger trout are not appropriate because their metabolism is too slow to effectively reduce Brook

Trout numbers. Tiger musky and hybrid striped bass are not acceptable because they are nonnative fish that do not meet ODFW’s Native Fish Conservation Policy, Wild Fish Policy, and the

Malheur Basin Plan. Furthermore, they are not biologically appropriate or suitable for the Upper

Malheur River Watershed.

E.4 Chemical Control

Antimycin and rotenone have been used extensively by fisheries managers to remove undesirable

species, restore native fish populations, removing genetic threats, and eradicate habitat altering

fish species (Krueger and May 1991; McClay 2000, 2005).

E.4.1 Antimycin

Antimycin is an antibiotic that kills gill-breathing organisms by inhibiting respiration in the

cell. Antimycin is effective at extremely low concentrations (parts per billion) and is not

detectable by fish, preventing an avoidance response. The antibiotic is effective with short

exposure time and has little impact on invertebrates. It biodegrades when exposed to high sun

exposure, high water turbulence; and is ineffective in water with high alkalinity and at pH above

8.7. Antimycin is more expensive than rotenone and recently produced formulations have been

found to be defective. Currently, antimycin is not available.

E.4.2 Rotenone

Rotenone is a botanical product found in the roots, seeds, and leaves of various plants that are

members of the bean family Leguminosae found in Australia, Southern Asia, and South America

(Finlayson et al. 2010). Rotenoid is a general term for processed plants containing rotenone,

degulin, rotenolone, and tephorsin and up to 25 other rotenone-like compounds in end-use

27

rotenone products (Fang and Casida 1999). However, most of the toxicity is due to rotenone

(Fang et al. 1997).

Rotenone is absorbed through gills when applied to water and kills organisms by inhibiting

respiration in the cell. Rotenone is readily available, stable in the environment, and does not

degrade as rapidly as antimycin.

Due to acute inhalation and acute oral and aquatic toxicity, rotenone is classified as a Registered

Use Pesticide. The sale of the product is regulated by the U.S. Environmental Protection Agency

under the Federal Insecticide, Fungicide, and Rodenticide and Federal Food, Drug, and Cosmetic

acts. To purchase rotenone in Oregon, a public pesticide applicators (PPA) license must be

obtained from the Oregon Department of Agriculture (ODA). The PPA is issued by ODA after

applicants have successfully passed federal/state laws and safety requirements and have

demonstrated competency for use in aquatic habitats.

F. Outreach and Education

The success of a rotenone project extends beyond the application of the chemical. An intensive

outreach and education campaign is mandatory prior to implementing any components of the

project. Recognizing and addressing political and social concerns are essential to the project’s

long- and short-term success. The most common factor noted in the success or failure of

rotenone projects has been the level of public understanding of the problem, transparency about

the solution, and engagement throughout the process. Education and outreach are crucial for

success in terms of the completion of regulatory processes, application of rotenone, and

maintaining Brook Trout-free streams following the treatments.

The TAC recognizes that for anglers to accept the rotenone project, recreational fishing

opportunities must be available in high-use areas following the removal of Brook Trout. Because

illegal stockings by anglers commonly occurs after rotenone projects and subsequently

contributes to project failure (Table 2), the TAC recognizes the importance of informing anglers

that the treated areas will be restocked with Bull Trout and Redband Trout, ensuring that fishing

opportunities will continue to exist.

F.1 Public Outreach

Public acceptance of management actions to benefit Bull Trout is crucial for recovery to occur.

Understanding recreation interests in the treatment zone will help identify the respective

demographics. Success of rotenone treatments, as defined by the continued absence of Brook

Trout in a treated reach, is dependent on education and outreach. Numerous streams within the

Malheur National Forest wilderness are paralleled by trails that are frequently used by hikers,

backpackers, hunters, anglers, and horseback riders. Such a network of trails exists around High

Lake which is located in the Strawberry Mountain Wilderness Area. High Lake is a destination

for hiking, backpacking, angling, horseback riding, viewing wildlife, exploring the outdoors, and

enjoying the wilderness. The most common access point to the lake is from the Roads End

Trailhead; however, many trailheads located across the wilderness provide access to High Lake.

Access to the trailhead is dependent on spring snowmelt which can occur as early as May/June or

as late as July. Most visitors are day users, though overnight and multi-day use does

28

occur. Although there are no developed campgrounds near the lake, camping is a popular activity

in this area. Peak use occurs from July to November.

Similarly, logging, ranching, and farming interests will be considered, as well as Grant and

Harney County which serve communities such as John Day, Prairie City, Canyon City, Izee,

Seneca, Juntura, Drewsey, and Burns-Hines. Outreach needs will also include non-governmental

conservation organizations.

To achieve the public outreach goal of developing an understanding and support for the rotenone

project, a neutral third-party will help the TAC implement the outreach strategy. Public

involvement during the planning process will be crucial for creating public support for the

project. Attention will be directed to factors that influence public support including: 1) concerns

about chemical use, 2) comprehension of project goals, 3) concerns about environmental tradeoffs, 4) concerns about management decisions, and 5) disagreement with fish management posttreatment. Keys to developing public support for the project will be: 1) identification, 2)

outreach, 3) communication, and 4) resolution.

The TAC has identified general public groups (Table 8) that will likely have an interest in the

project. Individuals can be exclusive to one group (e.g., fishing) or multiple groups (e.g., hunting

and ranching). Priority should be given to groups and organizations that have influential

participants that interact with multiple groups within their communities. This overlap will have

synergistic effects and reduce TAC efforts to spread the message and maintain activity within the

communities, groups, and organizations.

Outreach objectives associated with groups and individuals listed in Table 8 are to: 1) make the

group or individuals aware of the desire for a rotenone project, 2) build relationships of trust, 3)

gage interest in participation during the public process, and 4) identify potential issues/concerns.

Table 8. Examples of groups that will be included in public outreach/education efforts.

Public

Agricultural

Anglers

ATV/UTV

Campers

Grant County Court

Harney County Court

Hikers

Horseback/trail riders

Hunters

Logging

Native Fish Society

Location

John Day, Hines, and Drewsey

John Day and Hines

John Day and Hines

John Day and Hines

John Day

Burns

Various

John Day and Hines

Various

John Day

Portland and Salem

F.2 Communication and Education

Broad communication and education to communities and outside groups will be accomplished

through school groups, angling/hunting organizations, conservation groups, newspapers, radio,

social media (e.g., Facebook and Twitter) and during public meetings. Communication

objectives will be to: 1) inform the public about the current status of Bull Trout, 2) inform the

public about beneficial management actions, and 3) identify the TAC as experts that can address

29

the Bull Trout issue. Information to communicate about the current status of Bull Trout includes:

1) when they were listed, 2) why they were listed, and 3) recovery status, primary threats, and

actions identified in the species Recovery Plan.

The education component of this project will focus on facts about Bull Trout and Brook Trout

including basic life history, hybridization tendencies, habitat requirements, results and costs

associated with illegal introductions, restoration efforts, and focus areas. Information presented

to the public, regarding beneficial actions for Bull Trout, should include past management

actions to recover populations and possible actions that can be implemented. Specific expertise

of the TAC should be highlighted during these discussions. Linking key actions that will help

Bull Trout recover to the groups and individuals connected to this resource will be essential to

securing public acceptance of proposed management actions. Political space for implementing

Bull Trout restoration activities will be created as the TAC is able to connect communities,

organizations, commercial interests, and governments with the concept that restoring Bull Trout

will result in positive economic, commercial, and biological outcomes.

Resource connection is recognized as the key to securing public acceptance of the proposed

management actions.

G. 10-year Implementation Plan (Upper Action Area)

See Part II – Supplement 1 for a detailed description.

H. Monitoring & Recovery Actions

Monitoring objectives will be defined by the TAC and implemented by each agency. Methods

specific to each task will be defined in individual work plans or study plans and reviewed by the

TAC when the long-term monitoring stage begins. The most appropriate agency, for each task,

will take the lead and coordinate a review of the study plan with the TAC. Funding for

monitoring efforts will not be provided from the TAC to accomplish the work. Instead, each

agency will implement the monitoring within the scope of existing budgets and study plans.

H.1 Short-term Monitoring (<10 years)

Short-term monitoring results will be used to guide future annual project implementation. Per

Finlayson et al. (2010), the following post-treatment attributes will be monitored: 1)

effectiveness of the treatments, 2) macroinvertebrate colonization, 3) effects to amphibian

populations, and 4) effects on non-target fish species. In addition, the barriers will be evaluated

for their effectiveness in preventing the immigration of Brook Trout. If monitoring indicates lowrisk implementation is successful, higher levels of risk would be considered for future years.

30

H.2 Long-term Monitoring (>10 years)

A rigorous long-term monitoring program will be an essential component of the Bull Trout

restoration efforts in the Upper Malheur River Watershed. Data collected through the project will

inform each phase of implementation. The long-term monitoring strategy will include:

 Status of treated reaches - Treated reaches will be monitored for absence of Brook Trout.

 Index of Bull Trout trends - Yearly spawning surveys will be conducted to evaluate Bull

Trout populations in the Upper Malheur River Watershed. Surveys will allow for the

evaluation of Bull Trout recovery while minimizing impacts associated with intrusive

sampling efforts.

 Presence and distribution of Brook Trout, Bull Trout, and/or other native species - Use

eDNA to detect the presence of Brook Trout while minimizing the impact of sampling

activities on restoration efforts. Although electrofishing is an intensive sampling tool, its

use will be necessary to evaluate the presence/absence of Brook Trout following the

treatments. Electrofishing will likely occur every year; however, adaptive monitoring will

dictate its use in streams or stream sections that are to be sampled. Streams or stream

sections may be put into a rotational sampling strategy that would prevent them from

being heavily sampled each year while still having the capacity to evaluate changes in the

native fish populations. Snorkel surveys may be used to assess native fish populations

while minimizing the impact to these populations. Long-term monitoring efforts in the

Upper Malheur River Watershed will take an adaptive management approach that allows

for changes to be made as new data and tools become available.

 Genetics - Genetic studies will be conducted to investigate genetic purity of Bull Trout

populations. When enough reaches have been treated, analyses will be conducted to

assess the genetic diversity of all native species.

H.3 Habitat Restoration

Habitat degradation resulting from land management practices is a primary threat identified in

the Recovery Plan. Management activities such as grazing, timber harvest, road construction,

beaver trapping, and water withdrawals have altered stream and riparian conditions and reduced

the quality of habitat to support Bull Trout in the Upper Malheur River Watershed.

Restoring habitat would reduce the competitive advantage of Brook Trout over Bull Trout. To

address the primary threat, the USFS plans to work with its partners to implement habitat

restoration activities to improve habitat for Bull Trout in Upper Malheur River Watershed

streams (e.g., Summit Creek, Bosenberg Creek, Lake Creek, Big Creek, McCoy Creek, Crooked

Creek, Corral Basin Creek, and the Malheur River). Implementation of activities listed in

Appendix B will occur in coordination with non-native fish removals.

I. Temporary Barriers and Fish Passage for Migratory Native Fish

The highest level of uncertainty, from a technical standpoint, is the need to protect treated areas

with temporary barriers following treatments. As a proactive measure, barriers will be installed

prior to the treatments to prevent Brook Trout invasions. Intensive monitoring protocols will be

31

implemented to evaluate the barriers’ effectiveness relative to restricting Brook Trout passage

and whether barriers are restricting access of migratory native fish to spawning areas,

subsequently limiting the expression of life histories and gene flow. Without allowing

immigration into these areas, genetic bottlenecks and low resiliency will have high likelihoods of

occurring. Because of these potential challenges, adaptive management will be a key postimplementation component.

I.1 Temporary Barriers

Over 25 locations have been identified as potential sites for temporary barriers. The lowermost

site, located below the Bluebucket Creek confluence, would be the only permanent barrier in the

system. Attempts will be made to minimize the total number of barriers installed, with

considerations to logistic feasibility and minimizing the footprint. An array of scenarios and

potential locations (Figure 7) are being assessed.

Ensuring rapid recovery of native fish populations within the treated reaches is considered

paramount for success. Maintaining access for native species to treated areas post-treatment will

ensure an opportunity for populations to be robust and subsequently more resilient to stochastic

events. In order to maintain the ability of native fish to migrate within the upper Malheur River,

consideration will be given to designs that incorporate selective fish passage and are capable of

functioning during high-water events. In addition, other approaches such as permanent traps and

trap and haul operations will be considered. Temporary barriers are assumed to last 5 to 20 years

depending on baseline hydrology, seasonal weather events, and construction materials.

I.2 Permanent Fish Traps at Barrier Sites

In areas where it is highly likely that a large migratory population component will exist, the

installation of fish traps at the barrier is the most feasible solution. These areas will require the

assistance from TAC agencies to pass fish, within a reasonable time, during peak migration

seasons. Design would include the ability to close the trap while maintaining a 100% barrier

during winter months and times when migration is likely to be low. The Big Creek and Meadow

Fork drainages are most appropriate for such a design and monitoring scheme as Bull Trout are

most likely to utilize a migratory life history strategy in these streams based on the availability of

suitable spawning habitat. In these reaches, peak upstream migration for Bull Trout occurs from

June to August. Subsequently, June to August is recognized as the minimum period during which

fish traps should be operated.

Permanent traps will require maintenance to assure effectiveness. Maintenance will be performed

by the TAC agencies under the guidance of the lead agency for each individual barrier.

I.3 Trap and Haul

In consideration of the high level of agency commitment associated with operating traps at

barriers, areas with lower migratory expression may suffice to have less intensive approaches.

For areas where barriers are necessary for project success and migration may be a lower

probability among native fish, trap and haul methodologies are most appropriate. In such

streams, electrofishing or other collection methods will be used, below barrier sites, to collect

32

fish. Captured native fish will be released upstream of the barrier site. This methodology will

provide the opportunity for immigration into isolated populations. The use of this methodology

will differ depending on the stream and determined need based on captures below barriers.

Using monitoring results, the TAC will address the need to modify barrier design, adjust fish

passage efforts, and/or decommission barriers. The need for barriers will be continually

evaluated as eradication efforts precede throughout the Upper Malheur River Watershed.

33

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change_summary.pdf

39

K. Acronyms

BIBI - Benthic Invertebrate Index of Biological Integrity

BLM - Bureau of Land Management

BOR - Bureau of Reclamation

BPA - Bonneville Power Administration

BPT - Burns Paiute Tribe

CDFW - California Department of Fish and Wildlife

FSM - Forest Service Manual

NPS - National Park Service

ODA - Oregon Department of Agriculture

ODFW - Oregon Department of Fish and Wildlife

PPA - Public Pesticide Applicators

Recovery Plan - Recovery Plan for the Coterminous United States Population of Bull Trout

(Salvelinus confluentus)

RM - River Mile

RUIP - Recovery Unit Implementation Plan

RUP - Registered Use Pesticide

TAC - Technical Advisory Committee

USDA - U. S. Department of Agriculture

USFS - U. S. Forest Service

USFWS - U. S. Fish and Wildlife Service

USGS - U. S. Geological Survey

40

Appendix A

Table 1. Summary of aquatic habitat surveys completed in the Upper Malheur River Watershed since 2013. Cells

highlighted in yellow represent reaches that meet standards for in-stream habitat, while the reds cells represent

reaches that have substandard habitat conditions.

Reach

Wetted width

Large wood

source

Bankful W:D

Pools per mile

% fines

LWM per mile

(LM:S)

Bank stability (%)

July shade

a

Meadow hardwood

b

Mixed conifer

c

Undetermined

Lee Creek

Waterbody

Skookum

Creek

Malheur River – Below Ford

Black

Canyon

Creek

1

3

Bluebucket

Creek

1

4

1

4

1

5

1

2

3

MHWa

MHW

MCb

MC

MC

MC

MC

UD

UD

UD

NA

NA

X

UDc

UD

Table 2. Summary of aquatic habitat surveys completed in the Upper Malheur River Watershed since 2013. Cells

highlighted in yellow represent reaches that meet standards for in-stream habitat, while the reds cells represent

reaches that have substandard habitat conditions.

Waterbody

Reach

Wetted width

Large wood

source

Bankful W:D

Pools per mile

% fines

LWM per mile

(LM:S)

Bank stability (%)

July shade

a

Conifer Lodgepole

b

Undetermined

c

Meadow hardwood

d

Mixed conifer

2

8

Bosenberg Creek

3

4

15

7

5

6

2

4

West Summit

3

3

4

3

CLa

UDb

CL

MHWc

MHW

MCd

CL

UD

UD

NA

UD

UD

UD

UD

NA

UD

UD

41

Table 3. Summary of aquatic habitat surveys completed in the Upper Malheur River Watershed since 2013. Cells

highlighted in yellow represent reaches that meet standards for in-stream habitat, while the reds cells represent

reaches that have substandard habitat conditions.

Reach

1

Wetted

13

width

Large wood

MCa

source

MCBankful

W:D

Pools per

mile

% fines

LWM per

mile

(LM:S)

Bank

stability

(%)

July shade

a

Mixed conifer

b

Conifer Ponderosa

c

Conifer Lodgepole

d

Meadow hardwood

2

3

4

5

Waterbody

Summit

6

11

12

10

9

9

8

4

5

5

6

CPb

CP

CLc

CL

CL

CL

CL

MHWd

MC

MC

10

9

7

8

10

7

42

7

8

9

10

11

Appendix B

Table 1. Restoration activities the USFS plans to implement with its partners in the Upper Malheur River Watershed

to improve habitat conditions for Bull Trout (S. Namitz, USFS, personal communication).

Habitat restoration activity

Enhance native hardwood riparian

vegetation in Bull Trout spawning, rearing

and migration areas

Implement channel restoration projects in

degraded stream reaches of designated

Critical Habitat

Implement meadow restoration projects in

degraded wet meadows within the Upper

Malheur River Watershed

Remove connectivity barriers within in Bull

Trout spawning, rearing and migration areas

Install appropriate fish screens, where

needed, in Bull Trout spawning, rearing and

migration areas

Improve and secure instream flows affecting

Critical Habitat streams

Reduce grazing impacts along Critical

Habitat streams

Reduce the density of forest roads within

riparian areas, where appropriate, within the

Upper Malheur Watershed

Objective

Increase canopy and riparian cover

Provide a reliable source of large hardwood beaver forage

Maintain or improve effective shade

Reduce stream temperatures

Improve thermal connectivity across the Malheur stream network

Improve habitat to support biodiversity

Enhance resiliency to natural disturbance(s) and climate change

Increase large wood

Increase habitat complexity

Increase floodplain connectivity

Enhance resiliency to natural disturbance(s) and climate change

Increase cool water storage in the floodplain

Increase floodplain connectivity

Reduce stream temperatures

Enhance hydric vegetation and groundwater-dependent ecosystems

Improve thermal connectivity across the Malheur stream network

Enhance resiliency to natural disturbance(s) and climate change

Fix/restore passage barriers on forest service roads (e.g. culverts)

Improve connectivity across the Malheur stream network

Enhance resiliency to natural disturbance(s) and climate change

Reduce entrainment

Improve connectivity across the Malheur stream network

Restore connectivity and opportunities for migration

Increase base flows to moderate stream temperature changes and

increase habitat availability

Reduce grazing pressure on riparian areas and stream to support

habitat recovery

Reduce chronic sediment delivery from roads

Enhance vegetation recovery on compacted surfaces to increase

stream shade

Increase floodplain connectivity

43

Part II – Supplement 1

Brook Trout Removal Planning

10-Year Perspective

Malheur River Bull Trout Technical Advisory Committee

A. Contributing Agencies and Participants

Burns Paiute Tribe (BPT) - Erica Maltz, Kristopher Crowley, and Brandon Haslick

Oregon Department of Fish and Wildlife (ODFW) - David Banks and Benji Ramirez

U.S. Forest Service (USFS) - Steve Namitz, Kate Olsen, and Hazel Owens

U.S. Fish and Wildlife Service (USFWS) - Chris Allen, Suzanne Anderson, and Justin Martens

Bureau of Reclamation (BOR) - Dmitri Vidergar

B. Introduction

This strategic plan introduces actions to remove or reduce Brook Trout numbers within

prioritized areas of the Upper Malheur River Basin Core Area (Table 1). The TAC believes the

10-year perspective provides an adequate timescale for prioritizing actions that will affect Brook

Trout eradication. The strategy addresses the array of variables affecting the length of time

required to successfully eradicate Brook Trout in any stream segment, let alone multiple

segments within a stream combined with the reconnection of multiple streams. Other variables

that have been considered include funding, staff availability, and differing work priorities among

the participating agencies.

C. Planning Assumptions

The following assumptions were used to develop the 10-year plan for removing Brook Trout

from the Upper Malheur River Basin Bull Trout Core Area:

The proposed 10-year period will be from 2018 to 2028.

All stream reaches will be extensively surveyed prior to treatment to identify any springs,

seeps, tributaries, or other variables that may affect the treatment logistics.

Temporary barriers (Figure 1) will be used to partition the streams into logistically

treatable stream segments.

44

Table 1. Sites listed in prioritized treatment order for a 10-year period. Segment lengths are based on single channels

and do not account for stream braiding and other variables so actual stream mileage per treatment reach is expected

to be larger. The size of High Lake was estimated based on maps and Google Earth and the Burns Paiute Tribe.

Treatment

Segment length

order

Site

Segment

(miles)

Barrier construction required

1a

High Lake

High Lake

40.6 Acre Feet None needed if treated in

(volume)

conjunction with 1b

1b

Lake Creek

High Lake to natural barrier

1.65

None needed due to natural

barrier

2

Lake Creek

Natural barrier to 1648 rd

4.25

Barrier constructed at 1648 rd

3

Meadow Fork Natural barrier to 021 rd

3.09

Barrier constructed at the 021 rd

of Big Creek

bridge

bridge

4

Bosonberg

Headwaters to railroad

3.16*

None needed if railroad grade is a

Creek

grade barrier

complete barrier

5

Big Creek/

Natural Barrier to

Big = 2.59

Barrier constructed just below

Snowshoe

Big/Snowshoe confluence

Snowshoe =

Big and Snowshoe Creeks

Creek

and all of Snowshoe Creek

1.84a

confluence

6

Summit,

TBD

TBD

TBD

Crooked,

Corral or

McCoy

Creeks

a

Stream length for Bosonberg and Snowshoe creeks are estimates. The actual stream mileage will be decided prior to

treatment after locating upstream boundaries for fish presence.

Figure 1. Potential locations of barriers (yellow triangles) for the 10-year rotenone treatment to remove Brook Trout

from sections of the Upper Malheur River Watershed.

45

o National Environmental Policy Act, Endangered Species Act, fill removal

(Department State Lands), MRDG, and any other requirements or permits will be

completed prior to construction of any barriers.

o Temporary is a relative term concerning barrier construction and could entail

some barriers remaining in place for 5 to 30 years.

o Barriers will be removed from treated stream segments once downstream barriers

are capable of preventing reinvasion by Brook Trout

o The TAC will work to facilitate passage for native species above barriers as staff

time and funding are available and as specific needs arise.

Streams will be treated once each year with treatments for each segment of stream

occurring consecutively for two years.

The ODFW will be the lead for all rotenone treatments with assistance from TAC

members.

A variety of sampling techniques will be used to remove pure Bull Trout from stream

segments prior to treatment. Pure Bull Trout will be translocated to streams that have

already been treated and in sections above barriers that will effectively prevent reinvasion

by Brook Trout.

o Pure Bull Trout will be identified by trained staff using peer reviewed methods.

o The initial treatments in some streams will coincide with second-year treatments

in other reaches.

o A staggered approach will allow movement of salvaged Bull Trout into streams

that have already been treated.

o Lake Creek has a small pure Bull Trout population so initializing treatments in

that system will create fishless segments of stream to transfer salvaged Bull Trout

from other streams prior to their treatments.

The TAC members will work to mimic connected Bull Trout populations while barriers

are in place to reduce the likelihood of reduced genetic variability.

D. Probability of Success

Risk and uncertainty are inherent in nearly all natural resource related projects and subsequently

must be weighed and considered prior to implementation. The TAC has been diligent in seeking

to discover the level of risk and uncertainty inherent in each aspect of this conservation strategy.

The TAC concludes that this plan has a moderate to high probability of both short-term and longterm success in the eradication of Brook Trout from treated streams. This conclusion is based on

extensive research of similar projects throughout the West, including efforts in Oregon (Table 2),

the TAC members combined experience with such projects, and the vetting of this plan through a

panel of fisheries and rotenone project design experts. To further ensure the highest likelihood of

success, the use of rotenone will follow the American Fisheries Society’s Planning and Standard

Operating Procedures Manual for the Use of Rotenone in Fish Management (Finlayson et al.

2010).

46

Table 2. Examples of rotenone efforts by ODFW, in Oregon, to eradicate non-native fish.

State

Waterbody

Target Species

Oregon

Summit Gravel Pond

Smallmouth Bass and crayfish

Oregon

McDermott Creek

Rainbow Trout

Oregon

Diamond Lake

Tui Chub

Oregon

Sun Creek

Brook Trout

Oregon

Diamond Lake

Tui Chub

Oregon

Walton Lake

Brown Bullhead

Oregon

South Twin Reservoir

Brown Bullhead

Oregon

Antelope Flat Reservoir Brown Bullhead

Oregon

Crane Prairie Pond

Brown Bullhead

Oregon

Lofton Reservoir

Tui Chub

Oregon

Beck-Kiwanis Pond

Carp and Goldfish

Oregon

North Twin Reservoir

Brown Bullhead

Oregon

Sun Creek

Brook Trout

Oregon

McDermitt Creek

Rainbow Trout, Brook Trout, Brown Trout

Oregon

Sage Creek

Rainbow Trout and Brook Trout

a

Effort unsuccessful due to illegal releases following treatments

Successful

Yes

Noa

Noa

Yes

No

Yes

Yes

Yes

Yes

Yes

Yes

Yes

No

Yes

E. Application of Rotenone

The application procedure for rotenone is straightforward and generally highly successful when

label instructions are closely followed, including the detoxification of rotenone appropriately at

the end of the treatment area. In many streams, native fish salvage may also be necessary prior to

treatment. Depending on the type of holding area used, monitoring fish for survival may be

necessary. The TAC has high confidence that this will be successfully accomplished by holding

fish in nearby streams, streamside holding tanks, or hatcheries. If deemed necessary, the TAC

may choose to hold native fish in multiple locations to minimize the risk of total loss.

E.1 Rotenone Project Phases

Any rotenone project has three phases; pre-treatment, treatment, and post-treatment. Pretreatment, treatment, and post-treatment activities for rotenone projects in the Upper Malheur

River Watershed Phase 1 Area will be similar across streams within this area.

E.1.1 Pre-Treatment Phase

Pre-treatment activities will include: 1) determination of treatment area and project area, 2)

obtain permits/authorization for treatment in the wilderness, 3) identification of drip can

locations, 4) streamflow measurements, 5) stream travel-time using fluorescein dye, 6) native

fish salvage, 7) placement of sentinel fish throughout the treatment area, 8) preliminary and final

calculations of rotenone and potassium permanganate, 9) ordering rotenone and potassium

permanganate, 10) determination of personnel needs, 11) personnel assignments for the

treatment, 12) signing (restricted access) at access points, 13) area closures as needed (work with

USFS), 14) project implementation review, and 15) safety meeting (day before). Pre-treatment

activities for High Lake will be similar to streams, but will include the calculation of lake area

volume, staging a boat (helicopter), pump, fuel, backpack sprayers, and liquid rotenone.

47

E.1.2 Treatment Phase

Treatment activities will occur in stages proceeding from High Lake downstream to two hours of

flow travel-time below the detoxification station/waterfall barrier. High Lake will be treated

during the stream treatment and vice versa. High Lake will require a three- or four-person team

(Table 3), two on the boat (use of a helicopter is the prefererd technique) dispersing rotenone

into the lake and one or two walking the perimeter of the lake spraying the edges. The backpack

crew will spray until they have treated the entire perimeter of High Lake. The boat crew will

apply rotenone into High Lake until all rotenone is gone. The stream team will consist of two to

four personnel (Table 3) starting and monitoring drip stations at as few as five and as many as

eight locations. Drips will occur over a four-hour period and drip flow rates will be monitored

hourly. The detoxification station and check station will require two individuals (Table 3). One

person will be stationed at the detoxification station while the other will monitor sentinel fish at

various flow times below the detoxification station. One to three individuals will be used to

distribute sand mixed with rotenone to springs and stagnant water areas within the treatment

area. Treatments are planned to occur for two years, with one each July. Projected costs for the

project are listed in Table 4.

Table 3. Staffing and time requirements for rotenone treatments in the Upper Malheur River Watershed.

Treatment area

High Lake

Lake Creek (High Lake to

Lake Creek Falls)

Crew

Boata

Spray

Drip station

Number of personnel

2

2

3

Detoxification station

1

Detoxification check

1

station

Equipment runner/

1

miscelaneous

Sand crew

3

a

Use of a helicopter is the prefererd technique for application of rotenone in High Lake

Number of days

1

1

1

2 to 10

1

1

1

E.1.3 Post-Treatment Phase

E.1.3.1 Short-term Monitoring (<10 years)

Short-term monitoring results will be used to guide future annual project implementation. Per

Finlayson et al. (2010), the following post-treatment attributes will be monitored: 1)

effectiveness of the treatments, 2) macroinvertebrate colonization, 3) effects to amphibian

populations, and 4) effects on non-target fish species. In addition, the barriers will be evaluated

for their effectiveness in preventing the immigration of Brook Trout. If monitoring indicates lowrisk implementation is successful, higher levels of risk would be considered for future years.

48

E.1.3.2 Long-term Monitoring (>10 years)

A rigorous long-term monitoring program will be an essential component of the Bull Trout

restoration efforts in the Upper Malheur River Watershed. Data collected through the project will

inform each phase of implementation. The long-term monitoring strategy will include:

 Status of treated reaches - Treated reaches will be monitored for absence of Brook Trout.

 Index of Bull Trout trends - Yearly spawning surveys will be conducted to evaluate Bull

Trout populations in the Upper Malheur River Watershed. Surveys will allow for the

evaluation of Bull Trout recovery while minimizing impacts associated with intrusive

sampling efforts.

 Presence and distribution of Brook Trout, Bull Trout, and/or other native species - Use

eDNA to detect the presence of Brook Trout while minimizing the impact of sampling

activities on restoration efforts. Although electrofishing is an intensive sampling tool, its

use will be necessary to evaluate the presence/absence of Brook Trout following the

treatments. Electrofishing will likely occur every year; however, adaptive monitoring will

dictate its use in streams or stream sections that are to be sampled. Streams or stream

sections may be put into a rotational sampling strategy that would prevent them from

being heavily sampled each year while still having the capacity to evaluate changes in the

native fish populations. Snorkel surveys may be used to assess native fish populations

while minimizing the impact to these populations. Long-term monitoring efforts in the

Upper Malheur River Watershed will take an adaptive management approach that allows

for changes to be made as new data and tools become available.

 Genetics - Genetic studies will be conducted to investigate genetic purity of Bull Trout

populations. When enough reaches have been treated, analyses will be conducted to

assess the genetic diversity of all native species.

Table 4. Projected 10-year costs and probability of success for efforts associated with the Upper Malheur River

Watershed rotenone project.

Project

Probability of scuccess

component/concern

Costa

(high, moderate, low)b

Mitigation or actions

Public education and

$50,000

Moderate

TAC agencies as well as third party

outreach

facilitator participate in activity engaging the

public, demonstarting the problem, and

addressing concerns

Native fish

$50,000

Moderate-high

Fish may be stored in hatcheries, in

salvage/holding

streamside holding tanks, or in Brook Troutfree streams reaches

Rotenone

$250,000

High

ODFW rotenone application team oversee

application/Brook Trout

application

eradication

Barrier design/installation

$500,000

Moderate

Include design components that restrict fish

passage under all foreseeable environmental

conditions and Incorporate components that

will allow for selective fish passage

Barrier maintenance/fish

$50,000

Moderate

Adaptively manage barriers based on

passage

effectiveness and native fish population

concerns

Post-implementation

$250,000

High

Monitor fish, macroinvertebrates, and

monitoring

amphibian populations post-treatment to

ensure native species re-establishment

a

Total cost for each effort may exceed the listed value due to cost-shares or the continuation of existing work

b

Probability of success determined based on results from other rotenone projects in the Western United States

49

F. References

Finlayson, B., R. Schnick, D. Skaar, J. Anderson, L. Demong, D. Duffield, W. Horton, and J.

Steinkjer. 2010. Planning and standard operating procedures for the use of rotenone in fish

management—rotenone SOP manual. American Fisheries Society, Bethesda, Maryland.

G. Acronyms

BOR - Bureau of Reclamation

BPT - Burns Paiute Tribe

ODFW - Oregon Department of Fish and Wildlife

TAC - Technical Advisory Committee

USFWS - U. S. Fish and Wildlife Service

USFS - U. S. Forest Service

50

Part III – Supplement 2

Public Outreach and Rotenone

Treatment Planning

Malheur River Bull Trout Technical Advisory Committee

A. Contributing Agencies and Participants

Burns Paiute Tribe (BPT) - Erica Maltz, Kristopher Crowley, and Brandon Haslick

Oregon Department of Fish and Wildlife (ODFW) - David Banks and Benji Ramirez

U.S. Forest Service (USFS) - Steve Namitz, Kate Olsen, and Hazel Owens

U.S. Fish and Wildlife Service (USFWS) - Chris Allen, Suzanne Anderson, and Justin Martens

Bureau of Reclamation (BOR) - Dmitri Vidergar

B. Rotenone Project Planning Stages

The TAC will follow the Planning and Standard Operating Procedures for the Use of Rotenone

in Fish Management – Rotenone SOP Manual (SOP) (Finlayson et al. 2010) as the minimum

mandatory standard for the planning and implementation of the Upper Malheur River Watershed

rotenone project. The proposed planning and implementation processes (Figure 1) associated

with the TAC’s rotenone project were adapted from the Arizona Game and Fish Department’s

(AGFD) Piscicide Treatment Planning and Procedures Manual (AGFD 2012), and comply with

the SOP, product labels, and applicable laws and regulations.

B.1 Stage 1 - Internal Review and Approval

B.1.1 Internal Review and Approval

The project will receive internal review and approval by the appropriate Executives of each TAC

member prior to convening the initial public meeting. Executives will be sent a briefing upon

approval.

51

STAGE 1

Step 1- Conduct internal review and approval

Step 2- Submit briefing to Executives for review and approval

STAGE 2

Step 1- Convene initial public meeting(s)

Step 2- Submit briefing to Executives for review and approval

Step 3- Develop Preliminary Treatment and Public Involvement plans

Step 4- Submit briefing to Executives for review and approval

Step 5- Convene public education meeting(s) and develop briefing (nonNEPA)

Step 6- Submit briefing to Executives for review and approval

STAGE 3

Step 1- Intermediate planning and public involvement procedures

Step 2- Convene NEPA public meeting(s) and develop briefing

Step 3- Submit briefing to Executives for review and approval

STAGE 4

Step 1- Initiate and complete project implementation and evaluation

Figure 1. Stages associated with the proposed planning and implementation processes for the use of rotenone to

eradicate non-native Brook Trout from the Bull Trout Upper Malheur River Core Area located in the Upper Malheur

River Watershed, Oregon. Process adapted from AGFD (2012).

B.2 Stage 2 - Preliminary Planning and Public Involvement

B.2.1 Initial Public Meeting(s)

An initial public meeting will be convened prior to developing the Preliminary Treatment Plan

(PTP) and Public Involvement Plan (PIP). If controversy results from the initial meeting,

additional meetings may be necessary before submitting the Public Meeting Briefing (briefing)

for approval. Following the initial public meeting, and any additional meeting, a briefing will be

approved by the Executives prior to the development of the PTP and PIP.

B.2.2 Preliminary Treatment and Public Involvement Plans

The PTP and PIP will be initiated after the following criteria are met: 1) the Internal Review and

Approval Form is approved and 2) the initial public meeting is convened and the briefing has

52

been approved. Once completed, the PTP and PIP will be submitted to the Executives for

approval prior to initiating intermediate planning. Environmental compliance will be initiated

upon approval.

B.2.3 Public Education Meetings

Once the PTP and PIP are approved, at least one non-National Environmental Policy Act

(NEPA) related public meeting will be convened before initiating intermediate planning. If

controversy results from the meeting, additional meetings will be convened before initiating the

project. A briefing describing the level of support or opposition for the project will be provided

to the Executives for approval before starting the Intermediate Planning Stage.

B.3 Stage 3 - Intermediate Planning and Public Involvement

The Intermediate Planning Stage will be initiated when the Executives have approved the: 1)

PTP, 2) PIP, and 3) the briefing for all public education meetings held during the Preliminary

Treatment and Public Involvement Planning Stage. During this stage, all necessary

environmental compliance will be completed to further define the treatment plan. Public

meetings convened during this stage will be NEPA-oriented. Once NEPA and all associated

environmental compliance is completed (including Finding of no Significant Impact (FONSI),

Endangered Species Act (ESA), Environmental Assessment (EA), and National Pollution

Discharge Elimination System (NPDES) compliance), the Intermediate Planning and Public

Involvement Proposal (IPPIP) will be reviewed by at least two individuals with applicator

experience. Following the applicators’ reviews, the IPPIP and briefing will be submitted to the

Executives for review and approval at least two months prior to treatment.

B.4 Stage 4 - Project Implementation and Evaluation

The project will be implemented per the IPPIP once all applicable state and federal compliance

activities are completed and the IPPIP is approved. The post-treatment evaluation is a critical

part of the treatments and will assist the TAC in improving planning and implementation of

future projects. A Project Evaluation Report and documentation will be submitted to the

Executives within 60 days following the final treatment.

C. Project Planning and Public Involvement

C.1 Stage 1 - Project Internal Review and Approval

The proposed project will receive internal review, input, and approval before seeking public

input (following SOP, page 15).

53

C.1.1 Internal Review and Approval Template

The Internal Review and Approval Stage will be completed and approved by the Executives

before initiating the next stage. The Executives will be provided a briefing that includes the

following information:

1. Project supervisor (this will be the primary contact for the project and will submit all

documents identified in this planning guide).

2. Project location (including description of proposed treatment area).

3. Project timeline (month and year; although this is pre-NEPA, will provide best estimate).

4. Statement of purpose (will include threat of target species on surrounding waters).

5. Target species for removal.

6. List of conflicts with management objectives, recovery plans, etc.

7. Sensitive, endemic, and listed species that may be potentially impacted by the project.

8. Fish removal alternatives attempted and/or justification/explanation of why alternatives were

not considered as viable fish removal options.

9. Proposed piscicide that will be used and method of application (will include neutralization

chemical and application method).

10. Land ownership.

11. Current use of the water body (will include a description of angling, recreational, and

agricultural use) and water uses potentially affected by the project.

12. Interested parties potentially affected by the project.

13. Downstream areas potentially affected by project.

14. Likely supporting and opposing groups and individuals.

15. Supporting and regulatory agencies affected.

16. Determination of applicable laws and regulations the project will require (will identify if

environmental compliance issues exist).

17. Chance of success to meet management objectives and number of treatments/years required

for success.

18. Signature page for Executives.

54

C.2 Stage 2 - Preliminary Treatment and Public Involvement Plan

C.2.1 Initial Public Meeting (non-NEPA related)

The initial public meeting will be convened when the internal review and approval are

completed. If controversy exists during the public meeting, additional meetings may be required

to inform and resolve the issues before developing the PTP and PIP. The need for additional

initial public meetings will be determined by the TAC.

The purpose of the initial public meeting is to acquaint the public and elected officials, in the

proposed project area, with the proposed project and to explain the: 1) background, 2)

management objectives for the Upper Malheur River Watershed, 3) desired conditions, 4)

problem, 5) alternatives considered, 6) major issues, and 7) process to the public to ensure they

understand how they will be involved in the decision making process. The purpose will also be

to identify public concerns/issues and consider how to address them. The outcome of the initial

public meeting will help guide development of the PIP.

Following the initial public meeting, a briefing will be submitted to the Executives for approval

before initiating the Preliminary Treatment and Public Involvement Planning Stage. If multiple

meetings are convened, one briefing will be submitted summarizing the outcome of the multiple

meetings.

When planning the initial public meeting, the following items will be considered/presented:

1. The meeting will be convened after the proposed project received internal review and

approval. The meeting will occur prior to developing the PTP and PIP.

a. Input received during the meeting will be used to develop the PIP.

2. Information will be provided regarding the alternatives, rotenone and their associated impacts

(nontechnical at this stage), and anticipated benefits to the resource and the public. Opportunities

will be provided for interaction between stakeholders and the TAC.

3. Public input will be solicited relative to alternatives considered. This is a proposed project and

it will be conveyed to the public as such.

4. The meeting will be of an informal open-house style that uses displays, handouts, maps, and

other materials designed to expose the public to the project information and ideas. The meeting

will provide a chance for the public to react and express feedback in oral or written form. The

following will be completed:

a. Educate the public by using language easily understood by laypersons.

55

b. Public participation that is meaningful to the public (incorporate awareness, education,

input, and decision-making).

c. Document comments in the meeting minutes.

d. Encourage attendance by angling groups, agencies, and other partners.

e. Incorporate feedback and response from initial public meeting(s) into the PIP.

5. At any of the public meetings, the following information will be presented:

a. Description of the current problem and the desired condition for the Upper Malheur

River Watershed.

b. Description of the project as it relates to fisheries management objectives.

c. Alternatives for consideration.

d. Description of potential benefits if the project moves forward.

e. Description of the geographic area.

f. Identification of recreational activities/interests in the Upper Malheur River Watershed.

g. An identification of water uses in the project area (includes agriculture/ranching).

h. Description of prior public participation activities undertaken in developing the

project.

i. Identification of partners.

j. Description of the steps and general timeframe for the project.

C.2.2 Project Public Meeting Briefing Template

The briefing template will be used to describe the outcome of all public meetings to the

Executives. The following information will be included in every briefing:

1. Date, time, and location of the meeting.

2. Number of participants.

3. Stakeholders invited and the method of publication notification of the meeting.

4. Brief description of the meeting format and information presented.

5. Documentation of the public, staff, landowner, permittee, and downstream user support,

opposition, concerns, and/or feedback from the meeting. Also included in the briefing will be:

56

a. A tally of the number of previous public meetings held in association with the project.

b. Feedback from previous meetings as a comparison to feedback from the current

meeting (if required).

c. Explanations describing whether more public meetings are or are not necessary.

d. Documentation of stakeholders that chose not to become involved at the meeting, or

did not show up at a meeting. If additional public meetings are necessary, an updated

meeting and/or communication strategy will be provided to ensure better stakeholder

engagement.

6. Brief justification why the project is ready to enter the next stage, or why more public

meetings may be necessary before initiating the next stage.

7. Signature page for Executives.

C.2.3 Preliminary Treatment Plan

The PTP will be initiated after the following criteria are met: 1) the Project Internal Review and

Approval Form is approved and 2) the initial public meeting is held and the briefing has been

approved by the Executives.

C.2.4 Preliminary Treatment Plan Template

Prior to submitting the PTP for approval, it will be reviewed by at least two individuals with

rotenone application experience. The PTP will be submitted with the PIP and approved by the

Executives before moving forward with an additional public meeting (non-NEPA) and

intermediate planning. Applicable environmental compliance (e.g., NEPA) will be initiated once

the PTP and PIP are approved.

The following detail will be provided in the PTP:

1. Project supervisor(s).

2. Treatment location and project area (SOP, pages 65-66) in the Upper Malheur River

Watershed including a map highlighting these areas.

3. Physical and chemical characteristics of the Upper Malheur River Watershed (SOP,

page 15) including a map highlighting these characteristics in the treatment areas.

4. Barriers, ownership, and obstructions in the Upper Malheur River Watershed (SOP,

pages 15-16). Included will be a description of the barriers/obstructions to fish

(hydrological) and human movement (topographical and legal). A map of the Upper

57

Malheur River Watershed will be provided highlighting these characteristics in the

treatment areas.

5. Rotenone and neutralization (mandatory because the treatment is associated with

flowing water) formulations that will be used and how concentrations will be determined

(SOP and product labels).

6. Identification of public and commercial interests of those that use the Upper Malheur

River Watershed (SOP, page 16). Land ownership of land surrounding the treatment

areas will be documented and mapped.

a. Permittees/landowners/water users within treatment area will be documented as

will the owners of domestic wells or ponds within treatment area (SOP, page 29).

7. Interagency responsibilities (SOP, page 16).

8. Determination of applicable laws and regulations the project will require (these will

likely be the same for most treatments; identify potential environmental compliance

issues; SOP, page 15).

9. Protocols and monitoring plan for groundwater or surface water connections to

treatment areas (SOP, pages 121-123).

10. Logistics:

a. Methods associated with rotenone application (SOP, chapters 5-14) and

neutralization. Planned methods of application (e.g., drip station, spray unit) and

where each method will be included.

b. Staff needs.

c. Equipment needs.

d. Required permits and approvals.

e. Biological and chemical monitoring required; lab(s) that will conduct analyses,

if applicable (SOP, pages 115-117).

11. Description of the restocking plan including the monitoring that will occur to

determine when conditions are best for restocking.

12. Project budget including costs for equipment, staff, environmental compliance,

chemical, etc.

13. Signature page for the Executives.

58

C.2.5 Public Involvement Plan

The PIP will be initiated after the following criteria are met: 1) the Project Internal Review and

Approval Form is approved; and 2) the initial public meeting is held and the associated briefing

has been approved.

The purpose of the PIP is to create public awareness relative to the project goals, objectives, and

process, while providing opportunities for public participation in decisions relating to wildlife

management, human health, and the environment in reference to the proposed project. In general,

it is the TAC’s goal to generate awareness, consensus, and support for the proposed project. To

do so, results from the initial public meeting will be considered when developing the PIP.

C.2.6 Public Involvement Plan Template

The PIP must be submitted for approval by the Executives before convening additional public

meetings and prior to initiating intermediate planning.

The following information will be included in the PIP:

1. Description of the proposed project.

2. Identification of the PIP objectives.

3. Public involvement team roster (including roles and responsibilities) to identify opportunities

for public engagement.

4. Description of the level of public concern or interest. The following will be considered:

a. What was the public feedback from the initial public meeting?

b. What is the anticipated level of conflict, controversy, opportunity or concern about the

proposed project or rotenone use?

c. How much do the major stakeholders care about the issues or project?

d. What is the potential for public impact on the potential decision or project?

5. Determination and description of the level of public participation. The number of public

meetings will be dependent on perceived public opinions of the project.

6. Identification of stakeholders:

a. Key individuals, groups, stakeholders, area public officials, and agencies will be

identified. Securing a broad representation of public interests will extend beyond just

inviting the general public. Subsequently, a diverse and broad group of stakeholders will

be targeted to ensure the process is not dominated by any single interest group.

59

7. Description of public involvement tools (e.g., meeting type – open-house style, large

meetings, and neighborhood meetings). Additional outreach methods will be identified for

audiences that are not engaged in public networks.

8. Schedule of public participation activities.

9. Signature page for Executives.

C.2.7 Public Educational Meetings (non-NEPA related)

Public educational meetings will be held once the PTP and PIP are approved. The purpose of

meetings during this stage will be to inform the public that the use of rotenone is the preferred

alternative for the project, disclose information about rotenone, seek public input, and answer

questions or concerns raised by the public. These meetings are not associated with the NEPA

process (i.e., they are not public scoping meetings held in conformance with NEPA). When

significant controversy exists during a meeting, more public meetings will be convened to inform

and resolve the issues before moving forward to the intermediate planning stage. The need for

additional meetings will be determined by the TAC.

Following a meeting, a briefing will be submitted to the Executives for approval before initiating

intermediate planning. This briefing can be used to summarize the outcome of multiple meetings.

At each meeting, the following items will be included and/or considered:

1. Description of the current problem and the desired condition/objective.

2. Description of the project as it relates to fisheries management objectives.

3. Discussion of the alternatives that have been considered and why a rotenone

application is preferred as the fish removal method.

4. Discussion about the impacts of rotenone and neutralization to humans, the

environment, and non-target organisms.

5. Description of potential benefits if the project moves forward.

6. Description of the geographic area.

7. Identification of recreational activities and interests in the watershed.

8. Identification of water uses in the project area (including agriculture/ranching).

9. Identification of partners.

10. Description of the steps and general timeframe for the project.

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11. Opportunities for questions and answers.

D. Intermediate Planning and Public Involvement Procedures

The intermediate planning stage will be initiated after the following criteria are met: 1) PTP and

PIP have been approved and 2) the briefing for any public meeting held during the preliminary

planning stage has been approved by the Executives.

Prior to submitting the IPPIP for approval, it will be reviewed by at least two individuals with

rotenone application experience.

D.1 Intermediate Planning and Public Involvement Proposal Template

The IPPIP must be reviewed and approved by Executives at least two months prior to the start of

treatment. For any public meeting held during the Intermediate Planning Stage, a briefing will be

submitted to the Executives with the IPPIP. There will be at least one NEPA related public

meeting during this planning stage and others if determined necessary.

The SOP and product label for guidance will be consulted and sufficient detail will be provided

for each step.

The following will be included in the IPPIP:

1. Project supervisor(s) and crew leader responsibilities and training (will include contact

information). Project supervisor(s) and crew leader(s) will have the appropriate training

(SOP, pages 33-36).

2. Map identifying the location of the project location, including descriptions and stream

length of the treatment areas. For High Lake, the volume of water will be provided. Also

included will be descriptions of land ownership (SOP, pages 65-66).

3. Project background, intended outcome, and statement of purpose (will include threat of

targeted species (SOP, page 14).

4. Project species:

a. Target fish species for removal.

b. Target fish species for reintroduction.

c. List the non-target species within treatment area (include aquatic and terrestrial

species that may be impacted by the treatment).

5. Fisheries management objectives and Bull Trout Recovery Plan (description of how

project ties into management objectives and recovery plan).

61

6. Project partners, primary roles, and contact information:

a. Description of meetings that have occurred among partners related to the

project (will include dates and outcomes).

7. Alternative methods/tools evaluated and why rotenone application is the preferred

method for fish removal.

8. Project Internal Review and Approval Form, PIP, and briefing.

9. Rotenone application plan that will include:

a. Application rates for rotenone and potassium permanganate and how these were

determined. Calculations will be provide for estimated site volumes, surface

acres, and water flows and methods for measuring flows, water volumes, travel

times, and for calibrating neutralization equipment to achieve effective

concentrations of potassium permanganate. In addition, the estimated total

volume of rotenone and permanganate required for the project will also be

provided. Criteria will be provided that is used to determine when neutralization

can be safely discontinued. Labels from the rotenone and neutralization products

labels will be included.

b. Proposed treatment dates and duration.

c. Estimated crew size and logistics description.

10. Site safety plan will include:

a. Details on the planned hazard communication briefing to those involved in

rotenone treatment (SOP, pages 37-39), as well as the identification of the

individuals involved in presenting the briefings and how MSDS will be

posted/distributed.

i. Description of the personal protective equipment that will be required,

per product labels, that will be distributed to the treatment staff.

ii. All training requirements will be included in the briefing (SOP, page

40.

b. A spill contingency plan (SOP, pages 56-57).

11. Communications/site security plan (SOP, pages 29-31) will include:

a. Information on notification and monitoring requirements when a hydrologic

connection between treatment water and domestic wells may exist (product labels

and SOP, pages 121-122).

62

b. Information on proposed area closures and notification plans for treatment area

closures.

12. Fish removal and disposal plan (SOP, pages 119-120).

13. Crisis management plan (SOP, page 22).

14. Description of post-treatment monitoring and evaluation (SOP, pages 23-24) to

determine project success and methods for critique. The post-treatment evaluation report

will be submitted no later than 60 days after the final treatment.

15. Applicable laws and regulations:

a. State of Oregon Department of Environmental Quality Permit 2300-A.

i. Prepare and attach Notice of Intent (NOI) and Pesticide Discharge

Management Plan (PDMP) (if applicable; may develop the draft NOI and

PDMP during this planning stage).

b. NEPA analysis:

i. Project scoping notice description, dates, and outcome. Describe public

concerns, support, and/or opposition to the proposed project.

ii. Biological Assessment, Environmental Assessment (EA), and Pesticide

Use Plan (describe process, list meeting dates, attach when completed):

1) Ensure sufficient public outreach during public comment on

draft EA; ensure local informative meeting(s); ensure public

comments are addressed and the final EA is accurate (describe;

attach final EA).

2) FWS Biological Opinion (BO) – ensure the BO supports the

best EA alternative (describe and provide issuance date; attach).

3) Finding of No Significant Impact (FONSI) or Record of

Decision (ROD)(if Environmental Impact Statement) – ensure the

FONSI or ROD supports the best EA alternative (describe and

provide decision date; attach).

4) Public notice on final EA, BO, and FONSI/ROD – ensure

sufficient public notice on finalization of environmental documents

(describe and provide dates; attach).

63

5) If there is a formal request for an appeal, conform with appeal

comment period in cooperation with federal action agency

(describe and provide dates).

a. FWS Section 7 approval (provide signature date; attach if applicable).

17. Issue media releases and publish planned action decision (e.g., FONSI) (describe and

provide dates). Guidance on media release subject content will follow SOP, page 29.

18. List the names of at least two individuals with rotenone application experience that

reviewed the intermediate plan.

19. Signature for the Executives.

D.2 Public Scoping Meetings (during NEPA process)

When preparing an EA, the federal agency has discretion as to the level of public involvement

required and time period for review. For many rotenone projects, the agencies have to provide

the public, at a minimum, a 30-day review period pre-decisional EA. Persons who offer oral or

written comments on the EA or who otherwise express an interest in the project will have the

right to appeal a subsequent decision on its implementation following a published legal notice of

the decision. Public scoping meetings may also be held to solicit input on the proposed project

and alternatives.

For all meetings held during the Intermediate Planning Stage that are held during the NEPA

process, a briefing will be submitted to the Executives with the IPPIP. This briefing may

summarize the outcome of multiple meetings.

E. Project Implementation and Evaluation

E.1 Project Implementation

1. Finalize project logistics, staff needs, treatment dates, and alternative dates.

2. Issue general press release(s) to media outlets within the Upper Malheur River

Watershed and adjoining areas a maximum of three weeks and a minimum of one week

in advance to treatment (SOP, page 29, information will be included in press release).

3. Notify known users of domestic wells within the treatment area (including

neutralization zone) of impending treatment at least 7 to 14 days prior to treatment (SOP,

64

pages 2, 121-122). Notification and/or communication records and dates will be included

in the Project Evaluation Report.

4. Adequately notify permittees and landowners within treatment area (including

neutralization zone) of impending treatment at least 7-14 days prior to treatment.

Notification and/or communication records and dates will be included in the Project

Evaluation Report.

5. Implement project per treatment plan.

E.2 Project Evaluation

The post-treatment evaluation will be a critical part of the project to determine success of the

treatment, plan for additional renovations if the treatment was not successful, plan for restoration

of fish and other aquatic organisms if the treatment was successful, and to help the TAC’s plan

and implement future projects. Evaluations will be led by the TAC who will assign individual

tasks to the appropriate agency.

E.3 Project Evaluation Report Template

The Project Evaluation Report will be completed and submitted to the Executives no later than

60 days after the final treatment. The evaluation report will be prepared when the project is

completed, not following each treatment.

The Project Evaluation Report will include the following components per the SOP, pages 23-24:

1. Description of signage posted, closures, notification of domestic well users (if

applicable), notification of permittees and landowners within treatment area (if

applicable), and public contact that occurred in the treatment area during treatment.

2. For the post-treatment summary, the following will be included:

a. Dates of treatments and length of time area was closed to the public.

b. Names of project manager and crew leaders, as well as the number of

participants.

c. Description of treatment and neutralization (will include duration of

treatment/neutralization, amount of rotenone and oxidizer used, and

concentrations applied).

d. Conditions at the time of the project, explanation of problems encountered,

recommendations for future treatments, and observations noted by the

65

participants, as well as any changes to the treatment plan and the explanation

(e.g., due to changes in weather, environmental conditions).

e. Description of post-treatment monitoring (including water quality tests) and

treatment success.

3. Report findings, as required, to involved parties.

66

F. References

Arizona Game and Fish Department. 2012. Piscicide Treatment Planning and Procedures Manual

– May 2012.

Finlayson, B., R. Schnick, D. Skaar, J. Anderson, L. Demong, D. Duffield, W. Horton, and J.

Steinkjer. 2010. Planning and standard operating procedures for the use of rotenone in fish

management – rotenone SOP manual. American Fisheries Society, Bethesda, Maryland.

G. Acronyms

AGFD - Arizona Game and Fish Department

BO – Biological Opinion

BOR - Bureau of Reclamation

BPT- Burns Paiute Tribe

EA - Environmental Assessment

ESA - Endangered Species Act

FONSI - Finding of No Significant Impact

IPPIP - Intermediate Planning and Public Involvement Proposal

NEPA - National Environmental Policy Act

NOI - Notice of Intent

NPDES - National Pollution Discharge Elimination System

ODFW - Oregon Department of Fish and Wildlife

PIP - Public Involvement Plan

PTP - Preliminary Treatment Plan

SOP - Standard Operating Procedures

TAC - Technical Advisory Committee

USFWS - U. S. Fish and Wildlife Service

USFS - U. S. Forest Service

67

Part IV – Supplement 3

Potential Effects of Rotenone Treatments

Malheur River Bull Trout Technical Advisory Committee

A. Contributing Agencies and Participants

Burns Paiute Tribe (BPT) - Erica Maltz, Kristopher Crowley, and Brandon Haslick

Oregon Department of Fish and Wildlife (ODFW) - David Banks and Benji Ramirez

U.S. Forest Service (USFS) - Steve Namitz, Kate Olsen, and Hazel Owens

U.S. Fish and Wildlife Service (USFWS) - Chris Allen, Suzanne Anderson, and Justin Martens

Bureau of Reclamation (BOR) - Dmitri Vidergar

B. Introduction

The Malheur River Bull Trout Technical Advisory Committee (TAC) compiled the information

presented in this document to serve as a source to: 1) complete the planning stages described in

Supplement 2 (i.e., Public Outreach and Rotenone Treatment Planning) and 2) assist with

completing future assessments. This review provides an initial analysis of potential effects

associated with treating multiple sites in the Upper Malheur River Watershed (Figure 1 and

Table 1) with rotenone to remove non-native Brook Trout (Salvelinus fontinalis) in an effort to

protect threatened Bull Trout (S. confluentus). Eradicating Brook Trout would eliminate their

impacts (i.e., predation, competition, and hybridization) on Bull Trout in the Upper Malheur

River Core Area and help with recovery efforts, as the Upper Malheur River Watershed has been

designated as critical habitat for Bull Trout.

C. Affected Environment and Potential Concerns

This section identifies and describes potential ecological and human health impacts of the

proposed rotenone treatments. Potential impacts have been organized into the following subject

areas: 1) physical environment, 2) biological environment, and 3) human health.

The following definitions relate to the perceived threat-level associated with potential impacts.

Unknown - It cannot be determined at this time whether or not there will be impacts, positive or

negative, to the specified resources.

68

None - There will be no impacts, positive or negative, to the specified resources. Generally, this

means the specified resource will not be exposed to the action and its environmental

consequences.

Minor - The effects are beneficial, insignificant, or discountable. Beneficial effects have

contemporaneous positive effects without any adverse effects to the specified resource.

Insignificant effects relate to the size of the impact and include those effects that are

undetectable, not measurable, or cannot be evaluated. Discountable effects are those extremely

unlikely to occur.

Potentially Significant - The specified resource is likely to be exposed to the action or its

environmental consequences and has the potential to respond in a negative manner to the

exposure.

Figure 1. Potential treatment barrier locations (yellow triangles) for the 10-year rotenone treatment to remove Brook

Trout from sections of the Upper Malheur River Watershed.

69

Table 1. Sites listed in prioritized treatment order for a 10-year period. Segment lengths are based on single channels

and do not account for stream braiding and other variables so actual stream mileage per treatment reach is expected

to be larger. The size of High Lake was estimated based on maps and Google Earth.

Treatment

Segment length

order

Site

Segment

(miles)

Barrier construction required

1a

High Lake

High Lake

40.6 Acre Feet

None needed if treated in

(volume)

conjunction with 1b

1b

Lake Creek

High Lake to natural

1.65

None needed due to natural

barrier

barrier

2

Lake Creek

Natural barrier to

4.25

Barrier constructed at 1648 road

1648 road

3

Meadow Fork Natural barrier to

3.09

Barrier constructed at the

of Big Creek

021 road bridge

021 road bridge

4

Bosonberg

Headwaters to railroad

3.16*

None needed if railroad grade is a

Creek

grade barrier

complete barrier

5

Big Creek/

Natural Barrier to

Big = 2.59

Barrier constructed just below

Snowshoe

Big/Snowshoe

Snowshoe = 1.841 Big and Snowshoe Creeks

Creek

confluence and all of

confluence

Snowshoe Creek

6

Summit,

TBD

TBD

TBD

Crooked,

Corral or

McCoy

Creeks

1

Stream length for Bosonberg and Snowshoe creeks are estimates. The actual stream mileage will be decided prior

to treatment after locating upstream boundaries for fish presence.

C.1 Physical Environment

C.1.1 Land Resources

Will the proposed action result in:

a. Soil instability or changes in geologic

substructure?

b. Disruption, displacement, erosion,

compaction, moisture loss, or over-covering

of soil which could reduce productivity or

fertility?

c. Destruction, covering, or modification of

any unique geologic or physical features?

d. Changes in siltation, deposition, or erosion

patterns that may modify the channel of a

river or stream or the bed or shore of a lake?

Unknown

None

X

X

X

X

70

Minor

Potentially

significant

Can

impact be

mitigated

C.1.2 Water Resources

Will the proposed action result in:

a. Discharge into, or any alteration of, surface

water quality including but not limited to

temperature, dissolved oxygen, or turbidity?

b. Changes in drainage patterns or rate and

amount of surface runoff?

c. Alteration of the course or magnitude of

flood water or other flows?

d. Changes in the amount of surface water in

any water body or creation of a new water

body?

e. Exposure of people or property to water

related hazards such as flooding?

f. Changes in the quality of groundwater?

g. Changes in the quantity of groundwater?

h. Increase in risk of contamination of surface

or groundwater?

i. Effects on any existing water right or

reservation?

j. Effects on other water users as a result of

any alteration in surface or groundwater

quality?

k. Will the project affect a designated

floodplain?

l. Will the project result in any discharge that

will affect federal or state water quality

regulations?

Unknown

None

Minor

Potentially

significant

Can

impact be

mitigated

X

X

C.1.2a

X

X

X

X

C.1.2e

X

X

C.1.2f

X

X

C.1.2a,

C.1.2f

X

X

C.1.2a,

C.1.2l

X

X

X

Comment C.1.2a - Rotenone treatments would result in short-term effects to water quality. Three

ways in which rotenone can be detoxified include: 1) basic dilution, 2) detoxification, and 3)

natural breakdown. Basic dilution, by fresh water, is accomplished by fresh groundwater or

surface water flowing into the waterways, whereas detoxification involves the application of an

oxidizing agent (i.e., potassium permanganate). The most common method is to allow rotenone

to naturally breakdown, as rotenone is susceptible to natural detoxification through mechanisms

such as water chemistry and temperature, organic load, and exposure to oxygen and sunlight

(Loeb and Engstrom-Heg 1971; Engstrom-Heg 1972; Gilderhus et a1. 1986; Ware 2002; ODFW

2008).

High Lake Treatments

Because High Lake does not have a significant surface water inlet to detoxify the lake water and

groundwater recharge rates are unknown, the preferred detoxification method will be to allow the

rotenone to degrade naturally over time. With colder temperatures, toxic effects associated with

rotenone can last 4 to 5 weeks; however, since the treatment is planned for July, the TAC

anticipates that all rotenone in High Lake would detoxify over a shorter period of time.

71

Following the rotenone treatments, there may be a substantial quantity of dead Brook Trout

carcasses in High Lake. Project personnel will recover and dispose of all surfacing dead fish, at

regular intervals, until no dead fish are observed.

A secondary effect of the treatment would be a temporary increase in the nutrient input to the

lake as a result of decomposing fish. Following the treatment, an algae bloom may occur, an

event Bradbury (1986) observed for 9 of 11 Washington waterways treated with rotenone.

Bradbury (1986) suggested approximately 70% of the phosphorus in the dead fish would be

released into the lakes through bacterial decay, a process that UDWR (2007) suggested as a

benefit to stimulate plankton growth. The changes or impacts to the water quality may last for

approximately two weeks, during which the nutrients would be rapidly assimilated by aquatic

macroinvertebrate populations.

Project Stream Treatments

For Lake Creek (below Lake Creek Falls), Meadow Fork of Big Creek, Bosonberg Creek, Big

Creek, Snowshoe Creek Summit Creek, Crooked Creek, and Corral/McCoy creeks (Project

Streams), direct effects should be short-term, as rotenone naturally detoxifies in flowing waters

relatively quickly (often within 24 hours) due to dilution and increased rates of hydrolysis and

photolysis (Finlayson et al. 2000). Detoxification stations (potassium permanganate) will be

installed at the end of each treatment section to prevent rotenone from affecting downstream

resources. At the concentrations used, the potassium permanganate will degrade to nontoxic,

common compounds or elements shortly after application. The neutralization is not immediate in

space, but requires a short mixing zone where the potassium permanganate is in contact with and

oxidizes the rotenone. Downstream of this mixing zone, both fish and aquatic macroinvertebrates

would not be affected.

Comment C.2.2e – Studies indicate acute exposure to rotenone is not harmful to humans at

concentrations used to eradicate fish. Sousa et al. (1987) suggested a 132-pound human would

have to consume, at one sitting, over 15.85 gallons of treated water for the dose to be lethal.

Extensive testing has not shown rotenone to be carcinogenic (Bradbury 1986).

Comment C.1.2f - No contamination of groundwater is anticipated to result from the treatments.

Rotenone binds readily to sediments and is broken down in soil and water (Engstrom-Heg 1971;

Engstrom-Heg 1976; Skaar 2001; Ware 2002). Because rotenone binds strongly to organic

matter, its mobility through soil is low. With a leaching distance of approximately 1 inch in most

types of soil, it is unlikely rotenone would enter the groundwater. Case studies in Montana have

concluded that rotenone movement through groundwater does not occur (MFWP 2008). In

addition, rotenone breaks down rapidly into temporary residues that would not persist as

pollutants of groundwater (Turner et al. 2007). Ultimately, rotenone breaks down into carbon

dioxide and water. Regardless, there are no known groundwater wells in close proximity to High

Lake and the Project Streams that will be treated. The nearest groundwater wells to the project

72

site are located approximately 14 miles to the northwest (Dean Creek), 17 miles to the westsouthwest (Seneca), and 22 miles south (Wolf Creek).

Comment C.1.2l - Treatments will be confined to High Lake and Project Streams. Detoxification

stations will be installed to prevent discharge of treated water beyond the treatment area. As

required by state regulation, the TAC will submit a 2300-A pesticide general permit application

to the Oregon Department of Environmental Quality which must be approved prior to treating

High Lake and Project Streams with rotenone.

C.2 Biological Environment

C.2.1 Air Resources

Will the proposed action result in:

a. Emission of air pollution or deterioration of

ambient air quality?

b. Creation of odors?

c. Alteration of air movement, moisture, or

temperature patterns or any change in

climate, either locally or regionally?

d. Adverse effects on vegetation, including

crops, due to increase emissions of

pollutants?

e. Will the project result in any discharge

which will conflict with federal or state air

quality regulations?

Unknown

None

Minor

Potentially

significant

Can

impact be

mitigated

X

X

C.2.1b

X

X

X

Comment C.2.1a - Finlayson et al. (2000) indicated the EPA found that the use of rotenone for

fish control does not present a risk of unreasonable adverse effects to humans. Relative to air

quality, the EPA noted no public health effects had been reported relative to the use of rotenone

as a piscicide.

Comment C.2.1b - Impacts caused by odors would be short-term and minor. Rotenone contains

solvents that make it soluble in water. The odor from these solvents can last from several hours

to several days, depending on air conditions. Rotenone consists of relatively "heavy" organic

solvent compounds that tend to sink or remain close to the ground and move downwind. Newer

rotenone formulations are virtually odor-free, as a number of solvents have been removed. The

California Department of Pesticide Regulation (CDPR 1998, cited in Finlayson et al. 2000)

found no health effects from odors from rotenone formulations that consisted of greater solvent

concentrations than that found in the products that will be used in this project. Applicators would

have the greatest potential contact with odors; however, per product label guidelines, they will

wear respirators for protection. The Brook Trout carcasses from this project may cause odors.

73

Collecting and/or sinking dead fish in the lake will help mitigate this, making the effects from

these odors short-term and minor.

C.2.2

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This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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