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Big Hole River Foundation
P.O. Box 3894
Butte, Montana 59702

phone: 1-866-533-BHRF

CCCA Comment Letter

Mark Wilson
Doug Peterson
Arctic Grayling CCAA
U.S. Fish and Wildlife Service
100 North Park Avenue
Suite 320
Helena, MT 59601

Montana Fish, Wildlife and Parks
Fishery Division/Arctic Grayling CCAA
P.O. Box 200701
Helena, MT 59620

RE: Comments on Draft CCAA and EA for Fluvial Arctic grayling

To All Concerned,

We thank the USFWS for its great efforts in preparing the draft Candidate Conservation Agreement with Assurances (CCAA) For Fluvial Arctic grayling in the Upper Big Hole River and the accompanying draft Environmental Assessment (EA). The Big Hole River Foundation (BHRF) has since its inception in 1988 taken a special interest in the Big Hole River Watershed. With its' over 300 members we have a continuing interest and active engagement in understanding, preserving and enhancing the riparian, fishery, agricultural, economic and community health of this unique and beautiful place. We have taken a particular interest in the recovery of the Arctic grayling because the recovery of this species will lead to not only the improvement of the ecological health of the watershed, but because if done well and in cooperation with all the citizens of the watershed and region will also lead to a much improved and sustainable watershed economy as well.

For the most part the BHRF is in broad agreement with the well laid out draft CCAA and EA as sound scientifically based documents that could lead to recovery of the fluvial Arctic grayling in the upper Big Hole River if fully and quickly implemented.
The BHRF does support Alternative B of the Environmental Assessment but has several concerns with the proposed CCAA itself as described below.

The critical point for the Foundation is that time is of the essence and our strongest criticism of the draft CCAA is that it errors on the side of doing too little too late. Every effort must be made to not only have very specific timetables and mileposts for the accomplishment of this well laid out recovery plan for fluvial Arctic grayling, but also that the goals listed must be set higher and accomplished sooner if this draft plan intends to truly succeed at recovery of this species. Finally, we encourage the U.S. Fish and Wildlife Service and the partnering agencies in this agreement- Montana Fish, Wildlife and Parks, Montana Department of Natural Resources and Conservation and the USDA Natural Resources and Conservation Service- to keep the general public fully aware of progress on a regular, timely and region wide basis of accomplishment and failures as this recovery plan is implemented. Our specific comments and recommended changes to the draft CCAA are described below:

1. Management and Measurement of Irrigation Diversions- Page 25-30

"Agencies will work with Participating Landowners, in order of priority, to ensure that all irrigation diversions on enrolled lands are properly functioning and have flow measuring devices within 5 years of enrollment" (page 25)

Five years is too long to wait, this needs to be done in no longer then three years and there need to be specific short term goals. We believe you intend public reporting to make sure progress is made in a timely manner. A proposed improvement in the goal would read:

"Agencies will work with Participating Landowners, in order of priority to ensure that all irrigation diversions on enrolled lands are properly functioning and have flow measuring devices with 3 years of enrollment. Furthermore by the end of the first year of CCAA implementation, 20 % of irrigation diversions will be properly functioning and have flow measuring devices; by the end of the second year 60% of the irrigation diversions will be properly functioning and have flow measuring devices; and finally by the end of the third year of CCAA implementation 100% of the irrigation diversions will be properly functioning and have flow measuring devices" Annual public reports will be made available stating success at meeting this goal."

Finally, we would recommend that the document provide a more careful explanation of what "properly functioning" means. We understand this to mean that the diversions will be fully controllable (i.e. can be easily shut off and on), do not leak when shut, have associated measuring devices and if fish passage or entrainment is an issue that proper fish ladders and/or screens are utilized.

2. Improved Irrigation Management- page 30-31

"Within 30 months of a Participating Landowner entering into the Agreement, the NRCS will conduct a comprehensive assessment of the irrigation system and current agricultural operation of enrolled lands" (page 30)

Again, this is TOO long a time frame. NRCS needs to make a more serious commitment of resources and staff time. We can't wait 2 _ years for a plan! A proposed improvement for this goal would read:

"Within 12 months of a Participating Landowner entering into the Agreement, the NRCS will conduct a comprehensive assessment of the irrigation system and current agricultural operation of enrolled lands"

Also, the document continues to suggest that the NRCS will, as a result of this assessment, "estimate the irrigation water needed for production of hay and pasture forage" and that in turn will result in what is termed a "final maximum irrigation diversion amount".

It is critical that this "final maximum irrigation diversion amount" be determined at least within one year of enrollment. More importantly, it is not clear who will monitor and enforce that this amount is adhered to, except that there is a suggestion that water leases may be used as a tool to insure this maximum diversion of water is adhered to. THIS is a critical issue. We recommend that the U.S. Fish and Wildlife Service be designated as the agency responsible for enforcement of these diversion amounts with the assistance of all partners to the agreement. CLEAR enforcement responsibility and action when needed is absolutely critical to the success of this effort.

3. Cumulative Effect of Conservation Measures Implemented to Improve Minimum Instream Flows- page 31- 34

Table 3 on page 33 is THE most important table in the entire document. This table presents scientifically based MINIMUM FLOW targets for each of the management sections that make up the upper Big Hole watershed CCAA. These targets are given for Spring and Summer (April-June) and Fall (July-October) and are the minimum amount of flow in cubic feet per second (cfs) that will "ensure instream flows sufficient to promote recovery of grayling above their current populations". The agencies implementing the agreement also recognize that "they will strive, through implementation of the conservation measures, to provide flows that exceed the minimum flow targets presented here" (p.32)

However, even after recognizing the minimum nature of these targets the agencies then suggest the following goal:

" The Agencies estimate that after 10 years of Agreement implementation, streamflows in the Project Area will meet or exceed target values at least 75 percent of the days between April-October in years with average snowpack"
There are three major problem with this goal:

1. We cannot wait 10 years for the agencies to meet this outcome! The CCAA should provide a year by year set of targets and that set specific time frames by which to reach them. THESE ARE MINIMUM TARGETS and that means any time they are not met more Arctic grayling die and recovery is less likely. We are fearful that with such an extended time frame the pressure to meet these targets by the agencies will not be there and the species will become extinct.

2. The Agencies ought to make this target 100 percent of the days... not 75 percent.

3. The basis of taking so long to achieve a less then 100 percent level seems to be based on the agencies views that this goal is a "realistic" estimate based on historical data. However, the whole point of the CCAA is to undertake rather dramatic water saving, fishery and riparian restoration efforts all of which are NEW and without historical precedence. Therefore if these efforts are seriously made then history ought not to be repeated and the targets out to be met sooner. If these comprehensive targets aren't met sooner then there is no the point in having them because it will likely ensure extinction of the fluvial Arctic grayling.

Furthermore, the water management alternatives study recently commissioned by the Big Hole Watershed Committee which all partners to this agreement are familiar with indicated some 19 different ways to rather easily and inexpensively achieve significant water savings. We should NOT be setting goals so weak and limited as to not matter.

The BHRF supports the following replacement for the above goal:

"The Agencies will after 5 years of Agreement implementation, will meet streamflows in the Project Area that will meet or exceed target values at least 100 percent of the days between April-October in years with average snowpack" Furthermore by the end of the second year of CCAA implementation, streamflows in the Project Area will meet or exceed target values at least 70 percent of the days between April-October in years with average snowpack. By the end of the third year of CCAA implementation, streamflows in the Project Area will meet or exceed target values at least 80 percent of the days between April-October in years with average snowpack. By the end of the fourth year of CCAA implementation, streamflows in the Project Area will meet or exceed target values at least 90 percent of the days between April-October in years with average snowpack. Annual public reports will be made available stating success at meeting this goal."

4. Proposed Conservation Measures to Protect and Restore Riparian Function in the Project Area (page 41- 43)

This section sets goals for implementing "specific conservation measures" on participating land owners riparian areas. The measurement used to measure improvement is the "NRCS protocol for riparian assessment" and the guideline set for riparian condition in each of the five management areas "is set as "sustainable" with a ranking score of at least 80 percent". (p.42). While we are not experts on this scoring tool, we would suggest that the goal be set higher to 95 % ranking. The document should provide a description of this ranking tool in the appendices to the document. It is our understanding that this ranking system is not necessarily ecologically based and may not relate well to fluvial Arctic grayling. Furthermore NRCS states that it will only evaluate this condition once every 5 years for a total time frame of 15 years. Again, time is of the essence and the BHRF recommends that these assessments be done every 2 years for as long as the agreements last (expected 20 years)

5. High Stream Temperatures

Summer water temperatures routinely exceed 70°F in the upper river-a temperature known to stress grayling and other salmonids. Sometimes temperatures have exceeded the "upper incipient lethal temperature" of 77°F-a temperature known to kill grayling and other salmonids. Most temperature monitoring has occurred only in the Wisdom area. Clearly, more widespread temperature monitoring is needed throughout the CCAA target area, and the CCAA seems to emphasize that temperature data will be collected as a partial indication of success in implementing conservation measures in the target areas.

More important yet, the causes of high temperature need to be identified and remedied. The CCAA addresses these causes-primarily low flows and degraded habitat.

In addition to information already contained in the CCAA, biologists responsible for implementing the CCAA should make use of Confluence Consulting's TMDL study (still in a draft stage). This study seems to indicate that thermal loading is a critical violation of TMDL guidelines. It also proposes particular targets to ensure grayling growth (60.8°F) and survival (73.4°F) that are more specific and better validated than recommendations in the CCAA. The Confluence report also emphasizes the need to develop a flow model that accurately predicts the flow needed to maintain these temperature targets.

6. Population Monitoring

How will we know whether recovery is working? "Catch per unit effort" in electro-shocking has been shown to be without scientific basis. Tag-and-recapture methods also are not high-certainty, though at least they tend to be a standard practice. Some thought needs to be given to this issue.

One monitoring method to demonstrate recovery might be the observation of grayling spawning (or presence of grayling during spawning time) in areas of the river where grayling currently seem to be extinct. The CCAA needs to spell out methods that will document the expansion of Arctic grayling into its traditional range within the Big Hole River.

7. Reporting

Finally in a section that outlines "obligation of partners" (pp. 65-73) there is a section on "Reporting" that states that "MFWP will be responsible for completion of an annual report on Agreement implementation by May 1 each year". However at the end of this section it states that "A copy of the report will be provided to the Agencies. Participating Landowners will receive a copy of the annual report upon request". The BHRF suggests that the following changes:

Participating Landowners will receive a copy of the annual report each year.

And

"a copy of the report will be made available to the public generally, be provided to all stakeholder groups that are members of the Big Hole Watershed Committee and be placed on the MFWP website by May 15 of each year."

The implementation of this CCAA is using substantial State and Federal funds and the least the agencies can do is to make a report to participants and the public on how those funds are being expended and to what extent the actions taken are accomplishing the goals outlined!

We welcome any further questions on our comments and look forward to our continuing cooperative efforts in restoring Arctic grayling to the Big Hole River and upper Missouri watersheds. Please keep us informed of all steps taken in implementing this agreement.

Sincerely,

Jeff Schahczenski
Executive Director
For Big Hole River Foundation Board of Directors.

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