Final EIS Comments

Les Evarts, Fisheries Program Manager, NRD, CSKT
P.O. Box 278
Pablo, MT 59855

Dear Les,

Thank you for the opportunity to comment on the Final EIS: Proposed Strategies to Benefit Native Species by Reducing the Abundance of Lake Trout, Flathead Lake, Montana. The Flathead Valley Chapter of Trout Unlimited has followed the progress and lack of progress in this process closely for many years and we would like to commend the Confederated Salish and Kootenai Tribes for moving forward with plans to implement further suppression of lake trout as outlined in the 2001 to 2010 Flathead Lake and River Fisheries Co-management Plan.

As you know, in the early 1980s, abundant kokanee salmon in Flathead Lake as well as a good mix of other fish species made Flathead Lake the #1 lake angling destination in Montana with more than 100,000 angler days annually. Mysis shrimp were first noted in Flathead Lake in the early 1980s. The appearance of Mysis resulted in a huge advantage to the lake trout population by presenting the bottom-dwelling juvenile fish with a new and abundant food source. The result was a boom in the lake trout population. In just a few years, more than 15 million kokanee were entirely wiped out by lake trout predation and competition. Other fish species were in rapid decline. Native bull trout and westslope cutthroats declined by more than 50%. Attempts to control the over-abundant lake trout population through recreational angling have thus far failed to accomplish suppression goals as outlined in the Co-management Plan. Our chapter has advocated for more aggressive suppression options as outlined in the Plan under Strategy 5.

The Crown of the Continent and the transboundary Flathead remain one of the most treasured and diverse ecosystems in the world. They are currently protected by international agreements between British Columbia and Montana as well as by U.S. and Montana legislation. Further loss of native species within this ecosystem as we move forward is simply not an option. It is finally time to move from extremely low, “stable and secure” numbers of threatened bull trout in the Flathead to a population that is able to face upcoming threats from global climate changes and we believe that measures outlined in the FEIS can provide those protections. We support the goal of recovering bull trout so they are no longer listed as threatened under the Endangered Species Act.

Flathead Valley TU applauds the actions in the FEIS to achieve the goals of the Co-management Plan as well as the goals of the Montana Bull Trout Restoration Plan and other guidance documents. We supported Alternative D in the Draft EIS to remove up to 75% of the adult lake trout population over the long term and we will continue to advocate for scientifically-valid and effective methods to reduce the lake trout population to protect our native species. We also applaud the actions of the Flathead Reservation Fish and Wildlife Board, the CKST Tribal Council and the support of the many other agencies, scientists and organizations that have contributed to, and advanced the concept and design of the FEIS.
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We encourage CSKT to proceed with design and execution of an Implementation Plan toward rigorous implementation of the goals and targets set forth in the FEIS. We advise extreme caution in the early stages of implementation and fully support your adaptive approach in pursuing the ultimate goal of benefiting our native fish populations. Our small population of threatened bull trout is very fragile, vitally important and an abundance of caution is warranted as you move forward with planning and suppression efforts.

We also request that the CSKT continue to explore additional tools such as electro-shocking of lake trout spawning redds as well as bounties to encourage additional sport fishing opportunities that help build public support for the suppression effort.

Once again we express our gratitude to CSKT and the entire team that put together the FEIS and we will continue to support efforts that will benefit our wild, native fish and protect the values and resources of this very important ecosystem.

Thank you again for this opportunity to comment and support this important document.

Sincerely,

Larry Timchak

President
Flathead Valley Trout Unlimited