# Watershed Bull Trout

> Briefs, arguments, decisions, and more.

URL: https://www.frixlaw.com/law-library/documents/tribal%3Aburns_paiute%3A968bb9c8945397aa

## Record

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

## Text

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).

8

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).

9

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
12

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).

15

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

J. References
Abel, C. 2008. Synopsis of 2000-2008 stream temperature monitoring with implications for Bull
Trout recovery in the Upper Malheur. Pages 2-1 – 2-20 in Chapter 2 -Evaluate the life history of
native salmonids in the Malheur Subbasin. Burns Paiute Tribe Annual Report FY2008. Prepared
for Bonneville Power Administration.
Adams, S. 1999. Mechanisms limiting vertebrate invasion: Brook Trout in mountain streams of
the northwestern U.S.A. Doctoral dissertation. University of Montana, Missoula.
Adams, S., C. Frissel, B. Rieman. 2001. Geography of invasion in mountain streams:
Consequences of headwater lake fish introductions. Ecosystems 4(4):296-307.
Billman, H. G., C. G. Kruse, S. St-Hilaire, T. M. Koel, J. L. Arnold, and C. R. Peterson. 2012.
Effects of rotenone on Columbia Spotted Frogs Rana luteiventris during field applications in
lentic habitats of southwestern Montana. North American Journal of Fisheries Management
32:781-789.
Bowers, W.L., P.A. Dupree, M.L. Hanson, and R.R. Perkins. 1993. Bull Trout population
summary Malheur River Basin. Oregon Department of Fish and Wildlife. Hines, OR.
Unpublished report.
Brown, P. J., and A. V. Zale. 2012. Rotenone persistence model for montane streams.
Transactions of the American Fisheries Society 141:560-569.
Buchanan, D., M. L. Hanson, and R. M. Hooton. 1997. Status Of Oregon's Bull Trout,
distribution, life history, limiting factors, management considerations, and status, 1997 Technical
Report, Report to Bonneville Power Administration, Contract No. 1994BI34342. Project
Number. 1995-054-00. 185 electronic p. (BPA Report DOE/BP-34342-5).
Costello, A. B., T. E. Down, S. M. Pollard, C.J., Pacas, and E. B. Taylor. 2003. The influence of
history and contemporary stream hydrology on the evolution of genetic diversity within species;
an examination of microsatellite DNA variation in bull trout, Salvelinus confluentus (Pisces:
Salmonidae). Evolution 57(2):328-344.
Crowley, K. 2014. Selective removal of Brook Trout (Salvelinus fontinalis) in Lake Creek,
Upper Malheur River, Oregon. Chapter 1in Evaluate the Life History of Native Salmonids in the
Malheur River Basin. Burns Paiute Tribe FY2013 Annual Report. Project Number 1997-019-00.
(BPA Report BOE/BP- 00006313-5).
Crowley, K. 2016. Selective removal of Brook Trout (Salvelinus fontinalis) in Lake Creek,
Upper Malheur River, Oregon. Chapter 1 in Evaluate the Life History of Native Salmonids in the
Malheur Subbasin. Burns Paiute Tribe FY2015 Annual Report. Project No. 1997-019-00. (BPA
Report BOE/BP- 00006313-5).

34

Dawson, V. K., W, H, Gingerich, R. A., and P. A. Gilderhus. 1991. Rotenone persistence in
freshwater ponds: effects of temperature and sediment absorption. North American Journal of
Fisheries Management 11:226-231.
DeHaan, P. W., C. A. Barfoot, and W. R. Arden. 2007. Genetic analysis of bull trout populations
on the Flathead Indian Reservation, Montana. Pages 145-153 in Carline, R. F. and C. LoSapio,
eds. Sustaining Wild Trout in a Changing World: Proceedings of the Wild Trout Symposium IX.
October 9-12, 2007. West Yellowstone, Montana. 308 pages.
DeHaan, P. W. and D. K. Hawkins. 2009. Rapid response genetic identification of geographic
origin of bull trout captured at Clark River dams. Annual Report for Calendar Year 2008
submitted to Avista Corporation. March 16, 2009. 41 pages.
DeHaan, P., L. Schwabe, and W. Arden. 2010a. Spatial patterns of hybridization between Bull
Trout, Salvelinus confluentus, and Brook Trout, Salvelinus fontinalis in an Oregon stream
network. Conservation Genetics 11(3):935-949.
DeHaan, P., L. Godfrey, D. Peterson, and D. Brewer. 2010b. Bull trout population genetic
structure and entrainment in Warm Springs Creek, Montana.
Fang, N., J. C. Rowlands, and J. E. Casida. 1997. Anomalous structure- activity relationships of
13-homo-13-oxarotenoids and -0xadehyd- rorotenoids. Chemical Research in Toxicology. 10:
853-858.
Fang, N., and J. E. Casida. 1999. Cube resin insecticide: identification and biological activity of
29 rotenoid constituents. Journal Agricultural and Food Chemistry 47: 2130-2136.
Fenn, K. 2003a. Use of a backpack electrofisher to determine population size and distribution of
Brook Trout above the waterfall barrier on Lake Creek, Oregon and use of gillnets to determine
species presence in High Lake, Oregon. Pages 3-1 – 3-15 in Evaluate the life history of native
salmonids in the Malheur Subbasin. Burns Paiute Tribe FY2003 Annual Report. Prepared for
Bonneville Power Administration. Project Number 1997-019-00.
Fenn, K. 2003b. Selective removal of Brook Trout (Salvelinus fontinalis) using pheromone
baiting with sexually mature male brook trout in hoop nets. Pages 4-1 – 4-12 in Chapter 4 Evaluate the life history of native salmonids in the Malheur Subbasin. Burns Paiute Tribe
FY2003 Annual Report. Prepared for Bonneville Power Administration. Project Number 1997019-00.
Fenn, K. 2004a. Use of a backpack electrofisher to determine the distribution of fish species in
Big Creek and Corral Basin and population size of trout species in Corral Basin. Pages 2-1 – 217 in Evaluate the life history of native salmonids in the Malheur Subbasin. Burns Paiute Tribe
FY2002 Annual Report. Prepared for Bonneville Power Administration. Project Number 1997019-00.

35

Fenn, K. 2004b. Use of a backpack electrofisher to determine changes in distribution and species
composition of fish species in Meadow Fork and Lake Creek. Pages 3-1 – 3-33 in - Evaluate the
life history of native salmonids in the Malheur Subbasin. Burns Paiute Tribe FY2004 Annual
Report. Prepared for Bonneville Power Administration. Project Number 1997-019-00.
Fenn, K, and L. Schwabe. 2003. Use of a backpack electrofisher to determine the distribution of
Brook Trout (Salvelinus fontinalis), Bull Trout (Salvelinus confluentus), and potential hybrids of
Brook and Bull Trout in Lake Creek and Meadow Fork Big Creek, Oregon. Evaluate the life
history of native salmonids in the Malheur Subbasin. Burns Paiute Tribe FY2003 Annual Report.
Prepared for Bonneville Power Administration. Project Number 1997-019-00. (BPA Report
BOE/BP-00006313-5).
Fenton, J. 2004. Use of radio telemetry to document the movements of Bull Trout in the Upper
Malheur River, Oregon. Pages 1-22 in Evaluate the life history of native salmonids in the
Malheur Subbasin. Burns Paiute Tribe FY2004 Annual Report. Prepared for Bonneville Power
Administration. Project Number 1997-019-00.
Fenton, J. 2005. Use of radio telemetry to document the movements of Bull Trout in the Upper
Malheur River, Oregon. Chapter 1 in Evaluate the life history of native salmonids in the Malheur
Subbasin. Burns Paiute Tribe FY2005 Annual Report. Prepared for Bonneville Power
Administration. Project No. 1997-019-00.
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.
Gunckel, S., A. Hemmingsen, and J. Li. 2002. Effect of Bull Trout and Brook Trout interactions
on foraging, habitat, feeding and growth. Transactions of the American Fisheries Society
131:1119-1130.
Hamilton, B. T., S. E. Moore, T. B. Williams, N. Darby, and M. R. Vinson. 2009. Comparative
effects of rotenone on macroinvertebrate density in two streams in Great Basin National Park,
Nevada. North American Journal of Fisheries Management 29:1620-1635.
Harper, D. 2013. Selective removal and abundance estimation of Brook Trout Salvelinus
fontinalis in Lake Creek, Upper Malheur River, Oregon. Chapter1 in Evaluate the Life History of
Native Salmonids in the Malheur Subbasin. Burns Paiute Tribe FY 2012 Annual Report. Project
Number 1997- 019-00 (BPA Report BOE/BP-00006313-5).
Haslick, B. 2016a. Benthic macroinvertebrate sampling in the Upper Malheur River, Oregon in
conjunction with a proposed piscicide treatment. Chapter 4 in Evaluate the life history of native
salmonids in the Malheur Subbasin. Burns Paiute Tribe FY2015 Annual Report. Project Number
1997-019-00 (BPA Report BOE/BP-00006313-5).
Haslick, B. 2016b. 2015 Amphibian surveying in the Upper Malheur River: Logan Valley
Wildlife Mitigation Property, Oregon. Chapter 3 in Evaluate the Life History of Native
36

Salmonids in the Malheur Subbasin. Burns Paiute Tribe FY2015 Annual Report. Project Number
1997-019-00 (BPA Report BOE/BP-00006313-5).
Kanda, N., R. F. Leary, and F. Allendorf. 2002. Evidence of introgressive hybridization between
Bull Trout and Brook Trout. Transactions of the American Fisheries Society 131: 772-782.
Kennedy, B., D. Peterson, and K. Fausch. 2003. Different life histories of Brook Trout
populations invading mid-elevation and high-elevation Cutthroat streams in Colorado. Western
North American Naturalist 63(2):215-223.
Krueger and May 1991. Ecological and genetic consequences of salmonid introductions in North
America. Canadian Journal of Fisheries and Aquatic Sciences, 48(Supplement 1): 66-77.
Leary, R. and F. Allendorf. 1991. Population structure of Bull Trout in the Columbia and Upper
Klamath River Drainages. Lewis and Clark Conservation Laboratory Report 91/2.
Leary, R., F. Allendorf, and S. Forbes. 1993. Conservation genetics of Bull Trout in Columbia
and Klamath River drainages. Conservation Biology 7:856-865.
Lindahl, P. E., and K. E. Oberg. 1961. The effect of rotenone on respiration and its point of
attack. Experimental Cell Research 23:228-237.
Magnum, F.A., and J.L. Madrigal. 1999. Rotenone effects on aquatic macroinvertebrates of the
Strawberry River, Utah: a five-year summary. Journal of Freshwater Ecology 14:125-135.
McClay, W. 2000. Rotenone use in North America (1988-1997). Fisheries 20(5):15-21.
McClay, W. 2005. Rotenone use in North America (1988-2002). Fisheries 30(4):29-31.
McMahon, T., A. Zale, F. Barrows, J. Selong, and R. Danehy. 2007. Temperature and
competition between Bull Trout and Brook Trout: A test of the elevation refuge hypothesis.
Transactions of the American Fisheries Society 136:1313-1326.
Nerass, L. P., and P. Spruell. 2001. Fragmentation of riverine systems: the genetic effects of
dams on bull trout (Salvelinus confluentus) in the Clark Fork River system. Molecular Ecology
10:1153-1164.
NorWeST. 2015. NorWest Project Area. https://www.sciencebase.gov/gisviewer/NorWeST/.
Paul, A., and J. Post. 2001. Spatial distribution of native and nonnative salmonids in streams of
the eastern slopes of the Canadian Rocky Mountains. Transactions of the American Fisheries
Society 130:417-430.
Perkins, R. 1999-2009. Bull trout spawning survey report. In Evaluate the Life History of Native
Salmonids in the Malheur Subbasin. Burns Paiute Tribe FY1999-2008 Annual Reports. Prepared
for Bonneville Power Administration. Project No. 1997-019-00.
37

Rieman, B., and J. D. McIntyre. 1993. Demographic and habitat requirements for the
conservation of bull trout Salvelinus confluentus. U. S. Forest Service Intermountain Research
Station, General Technical Report INT-302, Ogden, Utah.
Rieman, B., and J. B. Dunham. 2000. Metapopulations and salmonids: a synthesis of life history
patterns and empirical observations. Ecology of Freshwater Fishes 9:51-64.
Rieman, B., J. Peterson, and D. Myers. 2006. Have Brook Trout (Salvelinus fontinalis) displaced
Bull Trout (Salvelinus confluentus) along longitudinal gradients in central Idaho streams?
Canadian Journal of Fisheries and Aquatic Sciences 63:63-78.
Schwabe, L. 2000. Evaluate the life history of native salmonids within the Malheur Subbasin.
Bonneville Power Administration. Project Number 1997-019- 00 / 1997-019-01.
Spruell, P., B. E. Rieman, K. L. Knudsen, F. M. Utter, and F. W. Allendorf. 1999. Genetic
population structure within streams: microsatellite analysis of bull trout populations. Ecology of
Freshwater Fishes 8:114-121.
Spruell, P., A. R. Hemmingsen, P, J. Howell, N Kanda, and F. W. Allendorf. 2003. Conservation
genetics of bull trout: geographic distribution of variation at microsatellite loci. Conservation
Genetics 4:17-29.
U.S. Forest Service 1990. Malheur National Forest: land and resource management plan, Volume
1. U.S. Department of Agriculture. USDA. 1990. Malheur National Forest Land and Resource
Management Plan. Malheur National Forest.
U.S. Fish and Wildlife Service. 1999. Endangered and threatened wildlife and plants;
determination of threatened status for bull trout in the conterminous United States. November 1,
1999. Federal Register 64:58910-58933.
U.S. Fish and Wildlife Service. 2002. Chapter 14, Malheur Recovery Unit, Oregon. In: U.S. Fish
and Wildlife Service. Bull Trout (Salvelinus confluentus) Draft Recovery Plan. Portland,
Oregon. 71 pages.
U.S. Fish and Wildlife Service. 2004. Designation of critical habitat for the Klamath River and
Columbia River populations of bull trout. October 6, 2004. Federal Register 69: 59996-60076.
U.S. Fish and Wildlife Service. 2008. Bull trout (Salvelinus confluentus) 5-year review:
Summary and evaluation. U.S. Fish and Wildlife Service, Portland, Oregon.
U.S. Fish and Wildlife Service. 2010. Endangered and threatened wildlife and plants; revised
designation of critical habitat for bull trout in the coterminous United States; final rule. October
18, 2010. Federal Register 75:63898-64070.

38

U.S. Fish and Wildlife Service. 2015. Recovery plan for the coterminous United States
population of bull trout (Salvelinus confluentus). Portland, Oregon. xii + 179 pages.
Vinson, M. R., E.C. Dinger, and D. K. Vinson. 2010. Piscicides and invertebrates: after 70 years,
does anyone really know? Fisheries 35(2):61-71.
Whiteley, A. R., P. Spruell, B. E. Rieman, and F. W. Allendorf. 2006. Fine-scale genetic
structure of bull trout at the southern limit of their distribution. Transactions of the American
Fisheries Society 135:1238-1253.
Wondzell, S. 2016. Restoring riparian forests as a tool to mitigate effects of future climate
change on water temperatures in salmon-spawning streams of the interior Columbia River Basin.
https://www.fs.fed.us/pnw/lwm/aem/docs/wondzell/wondzell_riparian_restoration_and_climate_
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
controver

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Aburns_paiute%3A968bb9c8945397aa. Public record. Not legal advice.