Biography: I am Bob Loucks. I am a Professional Animal Scientist and spent almost 35 years working with ranchers in Central Idaho. I have been involved in endangered species programs since 1982. I served on the Idaho Legislative Wolf Committee, the Irrigators Committee to Enhance Anadromous Fish Recovery, and the Advisory Committee to the Lemhi, Pahsimeroi, East Fork Model Watershed Program for 8 years. I have resided in the Salmon River Basin for over 33 years.
I don’t know much about the rest of the west, but I do know a lot about the Salmon River Basin, especially the Upper Basin. Based on personal knowledge, contact with state and federal fisheries biologists, and the USFWS critical habitat and recovery plan proposals, I cannot see how Bull Trout were listed as endangered in the Salmon River Basin in the first place.
Some 8958 stream miles are proposed for critical bull trout habitat in Idaho. The Salmon River Basin, with about 17 thousand miles of streams, has 4777 stream miles proposed (53% of the state total). Now, this would be understandable if we were short of bull trout in the basin. However, according to USFWS, there are two sub-populations of bull trout in the basin. “Neither population is at risk of ‘stochastic extirpation.’” I think in plain English that means bull trout are not endangered in the Salmon Basin. The “magnitude of threats is considered low in this basin.” Again, in plain English this means that bull trout are not threatened in this basin. There are 125 known local populations (many in multiple streams) in the basin. I believe that we should conduct a status review (as called for by the ESA) and delist bull trout in the Salmon Basin.
Current Status of Landowner Recovery Efforts on ESA-listed Fish
Upper Salmon Basin landowners, particularly Lemhi Basin landowners have been leaders in cooperative efforts at fish habitat restoration. Their efforts actually predate the listings of salmon, steelhead, and bull trout. Cooperation with state and most Federal agencies has been outstanding. Most of the effort over the past 11 years has been directed at anadromous species; however, there has also been a notable effort on bull trout since their listing.
The attitude of most ranchers is that if the habitat enhancement helps anadromous fish, it also helps all other resident fish.
One of the impediments to more cooperative efforts on private lands is the hurdle that Federal land management agencies put in place on grazing allotments once a species is listed. BLM and USFS throw out all the range science that they ever learned in an attempt to accommodate NOAA Fisheries (formerly NMFS) and USFWS (neither of which has any range management expertise). If a rancher is so unlucky as to have an allotment with both salmon and bull trout, there is no grazing a pasture with salmon habitat after August 15 or a pasture with bull trout habitat after September 15. We now have forage management by calendar, instead of plant phenology. So, a planned grazing system is destroyed, ranch economics are harmed since the resulting grazing season doesn’t fit the rest of the operation, and range plant health is not as good as it should be.
In Lemhi County, two-thirds of commercial cattle ranches have Federal grazing permits. Federal grazing accounts for about one-half the pasture available or about 30% of the total cattle feed requirement in the county. Even though the Federal government manages about 92% of the land in the county, probably 95% of the salmon habitat is on the 8% that is privately owned. The point that I am making is that efforts to minimize impacts to ESA listed fish on Federal lands must be dove-tailed with efforts on private lands. Otherwise, there will be more harm created on private lands than can ever be mitigated by actions on Federal lands.
Conservation Plans vs. Habitat Conservation Plans
Private landowners and organized private groups such as the Model Watershed Advisory Board, Lemhi and Custer Soil & Water Conservation Districts, Water District 74, and the Lemhi Irrigation District are almost unanimous that they would rather develop an Idaho Conservation Plan through the state than have to deal with the myriad of Federal agencies directly. The state can act as a buffer between the landowners and the Federal agencies.
A group of Lemhi Basin ranchers has been working with the Idaho Attorney General, Idaho Dept of Fish and Game, NOAA Fisheries and USFWS for almost four years to develop a conservation plan that trades high fish priority actions for ESA coverage. This conservation plan would be much easier for ranchers to accept if it is a Section 6 plan with the state in the lead than if it is a Habitat Conservation Plan. We believe that there is room for accommodation for all parties if NOAA Fisheries is serious about getting an agreement.
Recovery Goals for Bull Trout
The Salmon Basin goals listed in the USFWS bull trout recovery plan are so amorphous and subject to “adaptive management”, that it is unlikely they will ever be reached. The only two populations listed “at risk” are Lake Creek and Opal Lake. Both are dead-end drainages with no surface connectivity to any river or stream. So, the future appears to be an endless striving for recovery for fish that never should have been listed in the first place. Ranchers and private groups are willing to work to restore stream connectivity on some drainages where there is a reasonable expectation of success. That seems likely to be the only logical action that can be taken.
Thank you for inviting comment.