The U.S. Fish and Wildlife Service caused a stir when it proposed setting up mechanical gear in a wilderness area within the Red Rock Lakes National Wildlife Refuge east of Lima.
The service received thousands of comments after releasing a draft environmental assessment aimed at aiding a small population of Arctic grayling in the remote refuge by supplementing dissolved oxygen in a shallow lake where the fish winter under ice.
Kevin Proescholdt, conservation director for Wilderness Watch, slammed the proposed project in an 11-page March 28 letter to Elizabeth Tsang of the Fish and Wildlife Service.
“This proposal is brazen in its conflict with the Wilderness and the Wilderness Act,” he wrote. “All the action alternatives would turn the Red Rock Lakes Wilderness into a fish farm via a permanent infrastructure that is prohibited by law.”
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Proescholdt insisted the Fish and Wildlife Service is obligated to complete a more comprehensive environmental impact statement.
The stir intensified after it emerged recently that the Fish and Wildlife Service had already deployed air diffusers in Upper Red Rock Lake to study their effectiveness.
The service said it added the diffusers during the winter of 2023 as part of a pilot project. It said it already had information about other potentially oxygen-boosting alternatives described in the environmental assessment but needed a sense of the diffusers’ potential to increase dissolved oxygen.
“It was important to conduct the pilot project to test the effectiveness of this alternative in development of the final environmental assessment,” said Jessica Sutt, a spokeswoman for the Fish and Wildlife Service.
“The pilot project included temporarily adding air diffusers into the lake and adding associated infrastructure in the campground outside of wilderness,” she said.
Michael Garrity, executive director of the Alliance for the Wild Rockies, objected to both the pilot project and the proposed activities in a wilderness area.
NEPA violation?
“The Fish and Wildlife Service violated the National Environmental Policy Act by putting mechanical equipment in Red Rock Lakes National Wildlife Refuge to add more oxygen into the water without taking public comment,” Garrity said. “The purpose of the National Environmental Policy Act is to look before you leap. Apparently Martha Williams’ Fish and Wildlife Service thinks federal laws don’t apply to them.”
Williams is director of the service and served previously as director of Montana Fish, Wildlife and Parks.
Garrity said taking public comment before installing the diffusers could have provided a forum during which a host of questions could have been raised.
Among them: Will diffusers work? Is cattle grazing on the refuge and related manure a source of nutrients accelerating eutrophication of Upper Red Rock Lake, where the grayling winter? How is grazing affecting streams where grayling spawn? How will mechanical diffusers affect waterfowl that rely on the refuge habitat?
The controversy surfaced swiftly, like an Arctic grayling to an artificial lure, after the Fish and Wildlife Service released a draft environmental assessment on Feb. 28 for proposed actions in Upper Red Rock Lake, a comparatively shallow lake that ices over in winter.
The fish of concern are “adfluvial” Arctic grayling as opposed to the “fluvial” or river dwelling grayling whose dwindling numbers in the Big Hole River have caused decades of contention.
According to one definition, “adfluvial” fish spawn in tributary streams where the young rear from 1 to 4 years before migrating to a lake system, where they grow to maturity.
The EA released in February described six alternatives, with five meant to enhance winter habitat for the grayling by increasing dissolved oxygen levels in deeper portions of Upper Red Rock Lake. The sixth was a no action alternative.
‘A shocking array’
The public comment period on the EA ended March 28.
George Ochenski, a longtime environmental activist in Montana, submitted seven pages of comments.
He raised a host of concerns.
Ochenski wrote that the alternatives proposed in the environmental assessment describe “a rather shocking array of ‘alternatives’ that apparently ignore the fact that Upper Red Rock Lake is in a Wilderness Area protected by the Wilderness Act of 1964, with very strict legal sidebars on activities within Wilderness Area boundaries.”
He noted too that two species with listed status under the Endangered Species Act – grizzly bears and the Canada lynx – are present on the Red Rock Lakes National Wildlife Refuge and could be negatively affected by “intrusive mechanical actions.”
Like Garrity, Ochenski wondered about the upstream input of nutrients that could lead to plant growth and decomposition affecting dissolved oxygen in Upper Red Rock Lake.
“We know there are significant nutrient inputs from upstream land uses – primarily grazing, but including housing and irrigation,” he observed.
Yet none of those inputs were quantified or explained in the environmental assessment, Ochenski wrote.
Sutt responded to concerns raised about grazing, nutrients and oxygen.
“Grazing factors have not been identified as significantly impacting dissolved oxygen in Upper Red Rock Lake,” she said.
Sutt said concerns about grazing impacts expressed during the EA comment period will be addressed in the final environmental assessment.
Former refuge manager weighs in
Bill West once managed the Red Rock Lakes National Wildlife Refuge for the Fish and Wildlife Service.
“Any portion of the refuge grazed - a grazing unit - is only grazed one year in four,” West said. “Cattle only graze a unit six to seven weeks in a high intensity short duration model thought to replicate historic bison impact.
“Cows are kept off until after ground nesting bird hatch (July 10),” he said. “Fences are wildlife friendly and are only raised and lowered for the six to seven weeks in a four-year rotation. Grayling evolved in that watershed and have sustained, with beaver dams and with great numbers of bison.”
West said he does not believe water quality is an issue for grayling in the refuge, but added, “I do agree that since I left in May of 2019 the cattle have had more access to stream banks.”
The grayling population in the refuge is shrinking. The Fish and Wildlife Service estimated in 2022 that there was a spawning population of only 73 grayling.
West cites another potential contributor to the precipitous drop in numbers – angling in Red Rock Creek.
He said a grayling census in May 2016 showed the population had crashed, going from about 1,131 fish to about 220.
“I and the refuge biologist suspected the fishing regulations FWP implemented in 2013 were so liberal that they had become a detriment to grayling egg hatching and (had led to repeated) hooking of adult grayling that remained in the creek,” West wrote in comments for the EA.
He added that grayling eggs and gametes are vulnerable during the spawning run to sediment kicked up by anglers in the stream.
“Stopping angler disturbance to sedimentation and hooking (of) the same adult individuals repetitively during the summer may be more important than addressing oxygen in Upper Red Rock Lake,” West observed.
“FWP still resists or even scoffs at this hypothesis,” he wrote. “We don’t know that Upper Red Rock Lake grayling die due to hypoxia (lack of oxygen). There is no direct data that show grayling are dying in Upper Red Rock Lake.”
Sutt did not disagree.
“Refuge management does not have documentation of dead grayling due to hypoxia in Upper Red Rock Lake,” she said.
West said he believes it is premature to build infrastructure in wilderness. Instead, he suggested a closure of angling in Red Rock Creek for the next few years.
FWP spokesman Greg Lemon provided information that seemed to differ with West’s observations.
“Restrictive angling regulations were put in place on Red Rock Creek and timed specifically to protect spawning grayling and their incubating embryos,” Lemon reported.
He said regulations closing Red Rock Creek during spawning, between May 15 and June 15, were put in place in 2013 “to eliminate the potential for angler trampling of embryos and reduce the likelihood of anglers catching spawning grayling.”
In 2022, the closure was extended to begin May 1, Lemon said, “to be more protective of fish cued to make earlier spawning runs in warmer years with earlier runoff.”
Lemon added that angler surveys do not support the theory that angler use is a population driver for Arctic grayling in the refuge.
Sense of urgency
The Red Rocks National Wildlife Refuge covers more than 53,000 acres, of which 32,350 acres were designated as wilderness in 1976. Upper Red Rock Lake is entirely within designated wilderness.
David Brooks is executive director of Montana Trout Unlimited, a non-profit organization worried about the future of the Arctic grayling population in the Centennial Valley.
Brooks said part of the mission of the Red Rocks National Wildlife Refuge is to keep Arctic grayling and other imperiled species on the landscape. Comparatively modest and temporary disturbances in service of the grayling seem warranted, he said.
The EA described a sense of urgency: “It is imperative to take immediate action to mitigate winter habitat in the Upper Red Rock Lake for grayling to prevent further loss of genetic diversity and reduce the risk of extirpation (complete loss) due to critically low population.”
Sutt said the Fish and Wildlife Service “is working toward a decision and a final EA for late spring, early summer 2023.”
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