Over the past
year the environmental concerns subcommittee has spearheaded several subjects
through the Executive Committee, and we are proceeding with addressing several
significant environmental issues of relevance to the Society in 2004.
The principal
role of the committee is to raise the awareness in the highest level of
relevant state and/or federal government on those critical environmental
issues that may affect fish, fish habitat, and/or water quality.
Issue Overviews - In 2003, the Ad-Hoc subcommittee groups prepared position papers
on the following key issues:
Klamath Basin Water Management
Pacific Lamprey Status under the Endangered Species Act
Fire Suppression Activities
Habitat Management by the State of Alaska
Coal Bed Methane Development on BLM Lands
Pallid Sturgeon Listing under ESA
Ad-hoc sub-committee
members, past president Don McDonald, and current president of the WDAFS
Tom McMahon deserve significant credit for pushing these letters through
the committee process. A brief synopsis of each issue is provided below.
Klamath Basin
Water Management
Subcommittee
Members: David Ward, Jim Steele, and Dana McCanne
This letter
was written to the Secretary of Commerce, Don Evans, in response to the
history of water management in the Klamath Basin that resulted in the loss
of approximately 34,000 fish (including 344 adult coho) in September 2002,
and also in response to inadequacies in analysis considered in the 2002
Biological Assessment. The letter posited that the federal water management
regime was at least partially responsible for the fish kill because the
management was based on a single-species management approach. The western
division requested that the Bureau of Reclamation reevaluate water management
such that the implementation of needed river flows not be delayed for 10
years, as this delay could result in further decline of the threatened coho
stocks in the basin. The WDAFS also requested that risks from the reclassification
of water year type in the mid-summer be examined, as this approach digresses
from the action described in the biological assessment. WDAFS disagrees
with status quo management of the water budget for this basin, as substantial
evidence points to the detriment of native stocks from the current approach.
Instream flow studies initiated in response to the fish kill are inadequately
funded to determine the most appropriate water management regime, and WDAFS
requested an increase in funding for this work, in line with what was initially
proposed.
Coal-Bed Methane
Development in Western States
This letter was
written to Mr. Paul Beels, of the Bureau of Land Management, to comment on
the general state of coal bed methane development in western states, in particular
in the Powder and Tongue River basins , but also elsewhere in the states of
Montana , Wyoming and Colorado . While the WDAFS did not specifically oppose
the findings of the FEIS on CBM development in the Powder River Basin , it
made the case that many questions remain about the impacts on water quality,
aquatic biota, monitoring, mitigation and adaptive management. The WDAFS has
requested that the BLM consider thorough adaptive management practices for
the industry, at least until such time that the full impacts of the practice
can be understood.
Pacific Lamprey
Status Review
Subcommittee:
Don MacDonald and Tom McMahon
The Pacific
Lamprey Review subcommittee examined the petition for the listing of four
species of Pacific Lamprey submitted by 11 conservation groups to the USFWS.
It was the position of the WDAFS that the data supporting a full review
of the Pacific lamprey, Lampetra tridentata , was substantive and
supportive of a full status review. The WDAFS did not think that existing
data for the three other species evaluated, the Western brook lamprey (L.
richardsoni) , river lamprey (L . ayresi), and Kern's brook
lamprey (L. hubbsi) , was as supportive; however, the WDAFS supported
a full status review of all species, given the putative decline of the Pacific
lamprey as a reasonable surrogate for all four lamprey species.
Pallid Sturgeon
Independent Review of Recovery Plan
The WDAFS has
formed a subcommittee to examine the recovery plan for the pallid sturgeon
in the upper Missouri River . The pallid sturgeon was listed as endangered
in 1990 under ESA. However, recovery of the species has not been significant.
A subcommittee of 21 members of the WDAFS has been formed to conduct an
independent review of the recovery plan in order to offer constructive comments
to the USFWS on the efforts to restore the stock status of this species.
A final report for this effort should be forthcoming soon.
Fire Suppression
Actions
The Bonneville
Chapter of the WDAFS has raised issues associated with the current practices
of fire management, and the associated risks to aquatic resources. These
risks include the spread of aquatic invasive species from the indiscriminant
transfer of water for fighting fires between basins, and the use of fire
retardants widely shown to be toxic to aquatic resources. The WDAFS is in
the process of formulating a position paper on this topic that should be
finalized by June of 2004. The paper will be submitted to Forest Service
Agencies, and perhaps submitted for publication to Fisheries as a short
article.
Alaska Aquatic
Habitat Management
The WDAFS wrote
to the governor of Alaska to protest the proposed transfer of fish habitat
management activities from the Department of Fish and Game to the Department
of Natural Resources, a land management agency responsible for timber harvest
prescriptions, amongst other activities. The WDAFS position was based on a
history of similar actions in other western states that ultimately marginalilzed
habitat management actions for fisheries, by placing them in direct competition
for another extractive resource.
In
the past year, we received no requests for AFS peer reviews, so there is
no activity to report for ECC in the past year. The last review I coordinated
for the Western Division ECC was in fall 2000, commenting on the biological
opinion for operation of the Columbia River hydropower system. I provided
a report on that review for last year's Western Division meeting, so I guess
there's nothing new to report for this meeting.
I
understand there is interest in a Western Division review of the Klamath
flow situation, and this may be discussed at the upcoming meeting in Spokane.
I'll be on leave the week of the Spokane meeting, however, so I won't be
attending, but I'm sure Eric will contact me if something develops and we'll
go from there.