Summary and Response to Upper Missouri River Reservoir Fisheries Management Plan 2010-2019 Public Comments

Canyon Ferry Walleye The Upper Missouri River Reservoirs Management Plan proposes to manage Canyon Ferry Reservoir as a multi-species fishery with an emphasis on walleye and rainbow trout while recognizing the importance of yellow perch as a sport and forage fish. The management strategy seeks to achieve and maintain a quality walleye fishery while maintaining a balance between walleye abundance and prey availability. If management of walleye population abundance and their predation on desirable sport and forage species is not maintained in a proper balance, all fish populations will suffer and provide diminished angler satisfaction. This balance is particularly difficult to maintain on waters such as Canyon Ferry Reservoir where natural reproduction can be virtually unlimited. Angler harvest regulations are the most cost-effective management tool available to maintain this balance and to increase numbers of desirable sized walleye; however, limits above standard regulations for the Central Fishing District for walleye (5 daily and 10 in possession) are essential to maintain a suitable forage base that will provide growth of walleye into large size groups. Three management alternatives for regulations were proposed by FWP and the Citizen Workgroup for Canyon Ferry to manage the walleye population to attain this goal:

Alternative 1: Reduce bag limit to 10 fish daily, 20 in possession with only one fish greater than 28-inches. Maintain 10 fish limit for three years in order to evaluate any changes to walleye population structure. o This alternative will reduce overall angler exploitation of walleye, while continuing to actively manage walleye to reduce predation of other desirable sport fish species. FWP data show that high bag limits may limit the number of fish that recruit to larger size groups. Reducing the bag limit also reduces overall exploitation, which is designed to recruit more fish into more desirable size classes. By limiting harvest to only one fish greater than 28-inches maintains a trophy component to the fishery. Adaptive management strategies allow changes to the bag limit as walleye abundance changes. FWP strives to maintain fishing regulations that achieve management goals and are as clear and simple as possible.

Public Comment  Support – 8 (includes the Pat Barnes Chapter Trout Unlimited)  Original Support in Initial Public Comment Period – 12

Alternative 2: Reduce bag limit to 10 fish daily, 20 in possession with only 4 fish greater than 16-inches and one fish greater than 28-inches. o This alternative further reduces angler exploitation with additional restrictions to angler harvest. Having only 4 fish greater than 16-inches will reduce harvest of larger sized fish while only one fish greater than 28-inches will maintain a trophy component. Additional protection of larger-sized fish offered by this alternative may conflict with management strategies for other sport fish species and increase the risk to the forage base. Creel data demonstrates that few anglers harvest more than 4 fish greater than 16-inches, which reduces that value of this alternative. This alternative proposes more complex regulations to achieve what might be attained by a simpler overall reduction in harvest (i.e., Alternative 1).

Public Comment  Support – 423 (includes Walleyes Forever and Walleyes Unlimited)  Original Support in Initial Public Comment Period – 53

1 Alternative 3: Maintain current bag limit of 20 fish daily, 40 in possession. o This alternative will continue to maximize angler harvest to manage the walleye population. Maximizing angler harvest reduces walleye numbers, which in turn reduces predation of other species in the reservoir and offers the most conservative approach to maintain the predator/forage balance. Data suggests that high harvest also may limit recruitment to larger size groups, further limiting predation by reducing average size of fish. Numbers of other desirable species (i.e., yellow perch and rainbow trout) may be increased through decreased predation by walleye.

Public Comment  Support – 7 (includes Montana Wildlife Federation)  Original Support in Initial Public Comment Period – 12

Miscellaneous Comments: Other comments include proposals for other modified bag limits, management of the Missouri River sections and Hauser and Holter Reservoirs, forage fish, management of other species in the system, and general comments on the Management Plan. Please see Summary Response to Substantive Public Comments below for FWP responses to substantive comments received.

 Total Miscellaneous Comments – 27

2 Summary Response to Substantive Public Comments Below is a summary response to comments received regarding the Upper Missouri River Reservoir Fisheries Management Plan 2010-2019. Although the FWP Commission requested public comment specifically on all three Canyon Ferry walleye management alternatives that were proposed in the draft management plan released for public comment in October, 2009, public comment was requested for all aspects of the plan.

Canyon Ferry Walleye Alternatives Alternatives

Alternative 1: Reduce bag limit to 10 fish daily, 20 in possession with only one fish greater than 28-inches. Maintain 10 fish limit for three years in order to evaluate any changes to walleye population structure. Alternative 2: Reduce bag limit to 10 fish daily, 20 in possession with only 4 fish greater than 16-inches and one fish greater than 28-inches. Alternative 3: Maintain current bag limit of 20 fish daily, 40 in possession.

Comments a) Comment: Dropping the limit to 10 fish doesn’t go far enough. We need a 5 or 6 fish limit, 10 in possession and a protective slot.

Response: Reducing daily limits to 5 or 6 fish daily with a protective slot would jeopardize the goal of maintaining a multi-species fishery. FWP data suggests that lowering the walleye limit to 6 fish with a protective slot could increase forage consumption by the walleye population by over 40%. Canyon Ferry is forage limited and such increases in consumption by walleye could collapse the forage base, which in turn would have negative effects to all sport fish in the reservoir, including walleye. Analysis of data also shows that a protective slot would not be an effective tool for improving size distribution of walleye in the reservoir.

b) Comment: Alternative 2 is the only way the small fish can grow up. One fish over 28-inches doesn’t get it done.

Response: Biological data suggests that allowing harvest of only 4 fish greater than 16 inches would have little effect on the walleye population size structure. FWP creel data from 2007-2009 show 23% of anglers harvest more than 4 fish per trip and 7.5% of walleye harvested are greater than 16-inches. Over the same period, 0.2% of harvest is of walleye greater than 30-inches. Implementing a regulation with 10 fish, only 4 greater than 16-inches and one greater than 28-inches would reduce overall walleye harvest by 1.7% beyond what a 10 fish daily bag limit would reduce harvest.

c) Comment: (The FWP Biologist) informed us that alternative 1 and alternative 2 will have the same effect, so let’s go with science and have a slot.

Response: Biological data suggest that alternative 2 would have little beneficial effect to walleye population structure (see Comment b above), therefore, it may be interpreted that the two alternatives would have the same effect. FWP strives to maintain regulations that achieve stated biological goals but are as simple and clear as possible, which would result in alternative 1 identified as the best science. Also, proposed alternative 2 is not technically considered to be a slot limit.

d) Comment: I prefer (alternative) 2 because harvest of breeding sized fish needs to be limited.

3 Response: FWP data suggests that angler harvest of spawning sized fish is not a significant limiting factor to the Canyon Ferry walleye population (see Comment b above). Data also suggests that the reproductive potential of the population in Canyon Ferry Reservoir is not limited by angler harvest of spawning-sized adults.

e) Comment: The problem I have with (alternative) 1 is if it doesn’t work to improve the overall age class of fish it will be close to 7 years before (alternative) 2 is fully implemented.

Response: The three walleye alternatives for Canyon Ferry Reservoir identified in the plan were proposed as starting points. Regardless of which alternative is adopted at the onset of the management plan, the management plan is adaptive in that progressive management actions may be taken based upon management “triggers” in order to obtain balanced multi-species fisheries. If management triggers are met within the first three years of plan implementation, management action may be deferred to allow strategies outlined in the management plan to take effect, providing the risk to the fisheries resource are minimal. After that three year period, new management strategies will be implemented as soon as possible when population levels reach high or low trigger points. The strategies that would be developed would depend on the triggers reached and would include, but not be limited to those original alternatives.

f) Comment: If chosen, alternative 2 will be reviewed, along with the entire plan, after 3 years and 6 years.

Response: The management plan will be reviewed annually. Progressive management actions will be implemented if/when population triggers are reached. If triggers are exceeded within the first three-years following plan implementation, management action may be deferred to allow evaluation of new management strategies recommended in the plan. However, if conditions change dramatically, adaptive strategies may be considered for implementation.

g) Comment: Leave the walleye limits as (is). The more walleyes you get out of there the better, so we can get our good trout and perch fishing back.

Response: FWP data suggest that the 20 fish limit may be effective at limiting walleye population growth through high rates of harvest which limit recruitment to larger size groups. However, it is desired by many anglers to improve the size distribution of the walleye population. FWP data suggests that reducing the limit from 20 to 10 may allow more walleye to grow into larger size groups, and still take advantage of periods of high harvest to actively manage walleye abundance with catch limits that are above Central Fishing District standards. If evaluation shows the effects of a regulation change are threatening other sport fish populations and triggers are reached, appropriate regulation changes will be proposed. Existing angler trout catch rates are high and yellow perch fishing may never return to levels before the walleye population expansion.

Other Canyon Ferry Walleye Comments Comments a) Comment: There should be a minimum length limit, such as no harvest of fish less than 14-inches.

Response: Biological data suggests that minimum length limits would have little benefit to the walleye population at this time. Minimum length limits for walleye populations are most likely to benefit fisheries with low reproductive success, good growth, low natural mortality, and high angling mortality. Although the Canyon Ferry walleye population now exhibits average growth and low natural mortality, reproductive success and recruitment of young fish remains at high levels. Angling mortality may be

4 high at certain periods; however angling mortality is quite low throughout much of the year, especially during the winter months. b) Comment: A better slot would be 20 under 16-inches and one over 16-inches.

Response: This regulation would be appropriate to reduce the number of smaller-sized fish and may reduce abundance of smaller-sized fish to a level appropriate for the available forage. However, data suggests that such a limit may also limit recruitment of fish to size groups greater than 16-inches. Data also suggests that harvest of fish greater than 16-inches is not a significant limiting factor for the Canyon Ferry walleye population (see Comment b under Canyon Ferry Walleye Alternatives above). c) Comment: 20 fish (walleye) limit on Canyon Ferry for walleye allowing only 3 over 15-inches to maintain pressure on smaller fish and allow some fish to recruit to larger sizes.

Response: Much like the limit proposed in alternative 2, this regulation would have little effect to improve the population size structure of Canyon Ferry walleye. In summer 2009, 2.6% of anglers harvested more than 3 fish and 5.4% of the fish harvested were greater than 15-inches. d) Comment: The size of walleye has diminished over time. We would love to preserve the fish for future generations.

Response: FWP has documented decreased growth rates of Canyon Ferry walleye in recent years. This is common in new fish populations, which often exhibit “boom and bust” cycles, where a population exploits unlimited resources early during population expansion then declines substantially once resources become depleted. Although size and growth of walleye has declined in the past four years, growth rates for Canyon Ferry walleye still equal or exceed growth in most other walleye waters in Montana. Also contributing to the perception of diminished growth of the walleye population are weak age classes, which results in low numbers of fish currently available to recruit into desirable sizes.

One of the primary goals of the management plan is to manage Canyon Ferry as a cost-effective, multi- species fishery that maintains high levels of angler use. Attaining and maintaining this goal will preserve the fishery for future generations. e) Comment: The overharvest of walleyes which has gone on for the past 10 years has ruined the size and age distribution of walleyes in this water. There are about 8 year classes missing.

Response: Data suggests that the 20 fish limit may be an effective tool at limiting population expansion by high exploitation and limiting recruitment of fish to larger size groups. This is why FWP proposed reducing the walleye limit from 20 fish to 10 fish daily. The current size structure of the walleye population is skewed toward smaller fish as a result of strong year-classes of younger aged fish, diminished growth rates, and potentially by high rates of angler harvest. Annual population monitoring shows survival of fish among multiple age groups. From 2009 population monitoring, only age 8 and age 9 fish were not represented in age groups 1-10 and 18% of the walleye sampled were age 6 and age 7 and will likely recruit to older age classes, as there are typically high rates of recruitment of Canyon Ferry walleye age 5 and older. Also, if survival for all year classes was high, Canyon Ferry would soon become overpopulated and have adverse effects on the forage base. f) Comment: There should be a yearly limit of one walleye over 30-inches. This could be accomplished by using special tags similar to paddlefish tags.

5 Response: Biological data suggests that angler harvest of walleye greater than 30-inches is not a significant limiting factor for the Canyon Ferry walleye population. g) Comment: We need stocking of walleye in Canyon Ferry.

Response: Walleye populations in the entire reservoir system are currently maintained through natural reproduction. Walleye growth is already limited due to low forage abundance. Stocking more walleye would add more pressure to the already limited forage base and provide negative impacts to all sport fisheries in the system, including walleye. h) Comment: FWP (ought) to pull their heads out of their (buttocks) and realize how much money walleye fishermen spend in the Canyon Ferry area.

Response: The latest economic data shows substantial expenditures by anglers on Canyon Ferry. In the 2007 license year, FWP estimates that anglers spent $1.5 million to fish for walleye in Canyon Ferry. Anglers also spent an estimated $1.6 million to fish for rainbow trout. i) Comment: You need to manage (Canyon Ferry) for species other than trout—no matter what the trout fisherman in the game commission want.

Response: Canyon Ferry is managed as a multi-species fishery and the new management plan implements strategies that emphasize trout and walleye while recognizing yellow perch as an important game and forage species. Active management of the walleye fishery in Canyon Ferry takes substantially more staff time and resources than trout management on the reservoir. j) Comment: The (walleye) limits/restrictions should be the same on all three reservoirs. So much easier for enforcement and clarification.

Response: Angling pressure trends and potential walleye carrying capacity are quite different between Canyon Ferry, Hauser and Holter Reservoirs. Canyon Ferry essentially has unlimited spawning potential for walleye, while Hauser and Holter is habitat limited for walleye spawning. Angler pressure on Canyon Ferry averages 2.6 angler days per acre while Hauser averages 15.4 angler days per acre and Holter averages 12.6 angler days per acre. In the past, due to limited spawning habitat and relatively high concentrations of angler pressure, more conservative limits maintained the viability of the Hauser and Holter walleye populations. This plan proposes lower daily limits on Canyon Ferry in an effort to improve the size structure of the walleye population. Higher daily limits are proposed on Hauser and Holter to increase harvest of walleye to prevent deterioration of desirable size structure of the Hauser and Holter Lake walleye populations. The adaptive nature of the plan may result in FWP recommending the same limits/restriction all on all three reservoirs if biological data suggests it would improve the quality of the fisheries. k) Comment: (The FWP Biologist) stated that a 20 walleye per day limit was necessary in order to control the 1996 and 1997 year class (of) walleye so that they would not over run the lake and decimate the trout population. (The Biologist’s) doom and gloom theory did not happen.

Response: Since the walleye expansion in Canyon Ferry during 1996 and 1997, major irreversible changes have been documented. Yellow perch abundance has declined to record-low levels collapsing what was once a destination winter yellow perch fishery. Additionally, the cost of stocking rainbow trout to maintain a quality trout fishery has increased 7-fold in order to raise and stock larger fish to reduce predation by walleye. Due to flushing from Canyon Ferry, walleye abundance in Hauser

6 reservoir has increased 1,700%, outstripping the forage base of that reservoir, and angler use on Canyon Ferry has declined 30.5% since 1999. l) Comment: I only pray that it is not too late to recoup the genetics of the older age class walleye that would have made Canyon Ferry Lake a renowned world class fishery.

Response: Although minimal information exists regarding the genetic diversity of the Canyon Ferry walleye population, it is a relatively young population and the genetic composition of the population is likely very similar to when it was first discovered in the late-1980s. The renowned world class fishery mentioned is likely a result of a newly expanded fish population, which often exhibits “boom and bust” cycles, where the population can exploit an unlimited forage resource early during population expansion but then declines substantially once resources become depleted. m) Comment: The tag returns a few years ago for fish that had been tagged was over 60%. There is not a system in the country that can sustain that level of harvest.

Response: FWP conducted a reward tagging study in 2007 and 2008 to better determine levels of angler catch rates and harvest (exploitation). Over the two years, 187 walleye were tagged with reward tags, 122 of which were recaptured (65%). Using scientific techniques established in literature and similar studies, FWP calculated an exploitation rate near 40%. Fisheries quality may be compromised with this level of exploitation; however, most North American walleye fisheries can likely sustain with exploitation rates at 50% or lower. n) Comment: When Lake Oahe lost their smelt and they ended up with a lot of smaller fish—they increased the limit on smaller fish but only allowed a limited number of fish over 15”. Once the system improved they changed the limits the next year and adjusted.

Response: North Dakota Game and Fish implemented a one-over 18-inch regulation on Lake Oahe from 1999-2002 in response to a forage crash in the late 1990s. Walleye size structure was small, with only 10% of the population greater than 15-inches. This regulation did not improve the size structure as intended and Game and Fish removed the one-over regulation after they discovered that natural reproduction was possible without protecting the spawning-sized fish. o) Comment: I wonder if the model that was used takes into account angler preference. By this I mean, if the quality of fishery is improved so that people are able to catch and keep some 16-18” fish to eat, more people will go there to fish—which would likely increase angler harvest.

Response: FWP uses a statistical package (Fisheries Analysis and Simulation Tools, or FAST) that is commonly used to scientifically evaluate population statistics, including yield, growth, survival, mortality, and exploitation, which is angler harvest. This program was used to model many population statistics for Canyon Ferry and evaluate the impacts of regulation changes to the population. This program does not incorporate angler preferences; however, the model, FWP creel data and scientific literature show that angler harvest would not likely increase if more restrictive regulations were implemented. Literature also shows that anglers are more likely to fish a water with less restrictive regulations, rather than a water in the same area with better fishing (calculated by angler catch rates) but with more restrictive harvest regulations. The model did demonstrate regulations recommended by FWP to improve the quality of the fishery. p) Comment: We suggest that you look at the management plan on Lake Oahe for walleye. We go there and catch walleye, white bass, smallmouth bass, cisco. The slot on that lake manages the numbers nicely and the walleye have a chance to get big.

7 Response: Although faced with many similar fisheries management challenges, Lake Oahe is much different than Canyon Ferry since it is much more productive due to warm water temperatures and much larger nutrient loads, which provide the capability of supporting a much more diverse suite of species. Not only are there more sport fishing opportunities on Lake Oahe, there is also a substantially more diverse forage base capable of supporting higher predator densities and additional predator species. Bag limits for Lake Oahe in South Dakota are 4 daily, 8 in possession; only one in the daily limit may be 20- inches or longer. In North Dakota the limits are 5 fish daily, 10 in possession.

q) Comment: I would like to see the Commission consider allowing live minnows on the three Helena area reservoirs. This would increase the (walleye) harvest during the ice fishing season which should help with the small sized fish. Without the live bait, it is very difficult to catch walleyes from any of these lakes when they are iced up.

Response: Walleye contribute very little to the winter fishery on Canyon Ferry, and do provide a small component of the Hauser and Holter winter fisheries. Strategies in the management plan prevent the introduction of new species by prohibiting use of live minnows in the system unless investigations demonstrate the potential for allowing species already in the system to be used safely.

r) Comment: The walleye population would be protected if there was more law enforcement.

Response: Two Helena area FWP Game Wardens and one Townsend area Game Warden provide year- round patrols at Canyon Ferry. Game Wardens often patrol “under cover” and often attempt to blend in among anglers without their knowledge. A review of FWP’s 1-800-TIP-MONT database, which allows the public to report game violations, revealed few reports of angler over-harvests at all of Southwestern Montana’s lakes or reservoirs. This suggests reports of over harvest may not be substantive problems.

Other General Canyon Ferry Comments Comments a) Comment: I would like to see another species introduced, like crappie or bluegill.

Response: Environmental variables for many other pan fish (such as crappie or bluegill) are at the extreme end for survival in Canyon Ferry. These species would likely be temperature and habitat limited in Canyon Ferry, diminishing the opportunity for viable populations to become established. Bluegill have been documented by FWP in Canyon Ferry, however their abundance is expected to remain at low levels. b) Comment: We need to stock another forage fish or bait fish.

Response: FWP is opposed to any introduction of new species in the Upper Missouri River Reservoir system. Often times the unintended adverse consequences of forage introductions outweigh the benefits. Introducing new fish species could have negative effects on the trophic dynamics not only in the reservoirs, but also within the entire Missouri River system from Toston to Great Falls. An initial review of the potential species that may be appropriate for introduction showed that most species would provide little or no benefit to walleye. Depending upon the species, there is great potential that forage fish would have negative effects to the species it was stocked to benefit. Changes to the food web and trophic dynamics within the system could jeopardize natural reproductive success of walleye and perch and make the put-take rainbow fishery unsustainable.

c) Comment: FWP needs to be more careful when regulating water depth in the reservoir.

8 Response: Water use and management is generally controlled by the U.S. Bureau of Reclamation and in some cases by the US Army Corps of Engineers. Flood control, irrigation, power generation, and recreation are the primary water uses for Canyon Ferry. As a result, water management that would maximize additional benefits to the reservoir fisheries is limited due to adverse impacts to other uses; consequently most fisheries benefits from water operations are realized in the river downstream of Canyon Ferry. When operational flexibility is possible, FWP will evaluate and provide advice to the Bureau of Reclamation regarding the risks and benefits of reservoir manipulations to enhance river and reservoir fisheries on a case-by-case basis. FWP would advocate for reservoir management that benefits reservoir fisheries when risks to downstream fisheries are minimal. d) Comment: Creel numbers are not right. I have been fishing on Canyon Ferry for years and have never seen a creel person. It is evident that walleye fishing is the species of choice for the majority of anglers.

Response: Canyon Ferry’s partial creel census has been conducted annually during the summer and winter ice fishing season since 1986. The creel census uses a scientifically based approach to sample the angler creel and through a random process subsamples anglers on all parts of the reservoir. This may result in anglers who frequent the water never being contacted by a creel clerk. For the 2007 license year (including the summer and winter fishing seasons), we estimated that 26,469 anglers targeted only rainbow and 24,630 targeted only walleye. Angler pressure estimates for 2009 are not available at this time, but 2009 creel surveys for the summer season show 33% anglers targeted only trout while 33% targeted only walleye.

e) Comment: (Northern) pike should be opened to no limit to prevent the Seeley Swan infestation in SW Montana.

Response: The management plan proposes a management direction for liberal harvest regulations in the reservoir system, which includes no daily limit for northern pike from Three Forks to Holter Dam. Fishing regulations changes will be proposed through the fishing regulation setting process scheduled to begin in summer 2010.

f) Comment: Nothing was mentioned about the carp that overrun Canyon Ferry Lake. While they may or may not eat other fish, they do eat the forage and so starve other fish. What can you do to control the amount of carp in Canyon Ferry?

Response: FWP data shows that carp abundance in Canyon Ferry has remained relatively static over the past 30 years. Prior attempts have been made to commercially fish for carp in Canyon Ferry, but proprietors were unable to find or develop a market for their catch. Commercial opportunities for Canyon Ferry carp will be encouraged by FWP. It is unknown if carp adversely affect forage by predation.

g) Comment: If there’s no limit on northern pike, has there been any thought to making it legal to spear pike through the ice?

Response: The management plan states that additional management methods may be necessary to reduce pike populations, including but not limited to spearing, commercial fishing, or required harvest during tournaments. Regulation proposals to reduce or control northern pike populations will be submitted to the Commission based on need based on field sampling results.

h) Comment: Can we see about implementing a 1 trophy brown trout over 25” (in Canyon Ferry). There’s a state record swimming in this water and under the current plan, if caught you would have to immediately release unless someone 14 years or younger catches the fish.

9 Response: FWP proposed changing brown trout limits to catch and release only in Canyon Ferry and in the Missouri River from Toston to Townsend. This change would make brown trout regulations consistent throughout the reservoir system. Brown trout abundance in Canyon Ferry and in the Missouri River from Toston to Canyon Ferry has continued to decline over the past 10 years and more conservative management action may be warranted.

i) Comment: I would like to see another species like salmon added to the lake to see if they can sustain a fishery.

Response: Kokanee salmon were planted in Canyon Ferry from 1966 to 1970 and did not develop a self-sustaining population. Given the current fish community today, it is doubtful that a self-sustaining population could be established or maintained with the high predation rate by walleye. An attempt to establish a kokanee salmon fishery could only be maintained by a substantial annual stocking effort, which would adversely affect other planted waters since hatcheries are already running at full capacity.

Management Plan Comments Comments a) Comment: I am deeply concerned that a lot of folks put in a ton of volunteer hours working on this plan to have their input (for Canyon Ferry walleye) totally ignored.

Response: Canyon Ferry walleye management is only one of numerous issues considered by the 18 member Citizen Workgroup appointed by FWP. Through 8 meetings lasting one day each, the Workgroup was tasked with considering FWP data from Canyon Ferry, Hauser, and Holter Reservoirs as well as two Missouri River sections and using that information to help develop management alternatives for the management plan. Although consensus was not a required end result, agreement was reached on many issues. To suggest that FWP totally ignored the input of the Citizen Workgroup because of one alternative is an injustice to those who dedicated their time to this collaborative process.

b) Comment: I would like to see if the plan can be implemented without having to wait an entire year— i.e. changing the limits at Canyon Ferry. I don’t know what the criteria are for an emergency order, but we are at that point for me.

Response: Implementation of an emergency regulation would be unenforceable, since the regulation change would not be available in the 2010 Montana Fishing Regulations and addendums to the regulation booklets are not adequately distributed, lost or simply not adhered to. FWP notified the Citizen Workgroup the timeline for fishing regulation implementations several times during the management plan development.

Hauser and Holter Reservoir Comments Comments a) Comment: In Hauser and Lake Helena you want (to) let people catch more walleye because they feed on minnows. But yet you want to commercial fish for carp which will reduce the amount of minnows that (walleye) feed on. I do know for a fact that walleye feed on carp minnows.

Response: FWP walleye diet studies on Hauser Reservoir show that carp typically comprise a small amount of the walleye diet. Commercial fishing operations in Lake Helena are not expected to impact forage availability in the system; however, FWP will closely monitor commercial fishing operations in

10 the reservoirs to minimize any impacts to the sport fisheries. On other waters in Montana, diet studies have identified carp minnows are a major forage component in some years.

b) Comment: No change in perch regulations (on Hauser and Holter). This has no biological justification.

Response: The management plan proposes dropping yellow perch limits on Hauser and Holter from 50 yellow perch daily with no possession limit, to 25 yellow perch daily with no possession limit. Although predation by walleye is likely the limiting factor for yellow perch recruitment rather than angler harvest, FWP has committed to conservative yellow perch management actions, which includes recommending a reduction in bag limits.

c) Comment: 20 fish limit for walleye on Hauser and Holter with only 3 fish over 15-inches. Consistency in regulations between reservoirs simplifies regulations and these limits will help reduce walleye populations and restore their balance with prey populations.

Response: Similar to Canyon Ferry, allowing harvest of only 3 fish greater than 15-inches would likely have little impact to the walleye size structure in Hauser and Holter Reservoirs. Such a regulation would have even less impact in Hauser, where few fish are capable of reaching 15-inches due to forage limitations. FWP feels regulations unique to each reservoir are necessary due to differences between walleye reproduction potential and angler pressure trends. However, whenever possible, FWP would recommend simplification and consistency in regulations between reservoirs if biological conditions allow.

d) Comment: We recommend that there be no further stocking of kokanee salmon in Holter reservoir.

Response: The management plan proposes maintaining a low level kokanee fishery in Holter by stocking surplus kokanee salmon when available. During the peak kokanee years in the 1980’s and 1990’s there were concerns that high kokanee abundance was limiting brown trout production in the river by superimposition of spawning redds and increasing the incidence of fungal infections in brown trout. Stocking of surplus kokanee in Holter is expected to maintain a low level of kokanee abundance in the reservoir and is not expected to negatively affect brown trout in the Missouri River reach below Hauser Dam; however if brown trout abundance below Hauser Dam falls below 100 fish per mile, stocking of surplus kokanee will be reduced or eliminated. Monitoring brown trout spawning would also be used to prevent adverse impacts to the wild brown trout population.

Missouri River from Toston to Canyon Ferry Comments Comments a) Comment: In the fall and the spring when the trout move up the Missouri (above Canyon Ferry) to spawn it is great fishing. There were days in the late 70s and early 80s that it was hard to find a parking spot near the mouth of the lake for all the people fishing. It truly boosted the economy of the area.

Response: Domesticated strains of rainbow trout stocked in Canyon Ferry in the 1970’s and throughout the 1980s produced a significant run of fall spawning fish in the Missouri River near Townsend. For reasons not totally understood, recruitment of the domesticated strains declined in the late 1980’s. Following extensive research and strain evaluation, FWP began stocking exclusively wild-strains of rainbow trout in the reservoir in the early 1990’s. This greatly improved survival of stocked fish in the reservoir, but it reduced the fall rainbow run up the Missouri to a fraction of what it once was. Currently, approximately two-thirds of the rainbow trout planted in Canyon Ferry are wild-strains and the other one-third are domesticated.

11 Missouri River below Hauser Dam (Hauser Tailrace) Comments Comments a) Comment: Hauser tailwater motorize access: I am not in support of a no-wake zone. I think that motorized access should be controlled by use of a 5 mph speed limit.

Response: Following public comment on the Draft Management Plan, FWP changed its preferred alternative from eliminating motorized access from Hauser Dam to Beaver Creek to maintaining the no wake zone from Beaver Creek to Hauser Dam. Proponents of motorized use on this river section largely supported maintaining the no-wake zone. The no-wake zone was established by legislation and cannot be modified or eliminated by Commission Rule.

b) Comment: Rules should be enacted (in the Missouri River below Hauser Dam) to control the amount of boat traffic dropping anchor and dragging through the spawning beds. Additional restrictions should go into effect if native fish fall below a specified number by FWP.

Response: Population surveys conducted bi-annually show trout population abundance and recruitment are relatively stable, which suggests fishing from boats or from shore have little effect on the spawning success of trout in the Hauser tailrace. If fishing pressure continues to increase and trout abundance declines, seasonal closures may need to be considered. Seasonal closures to protect brown trout redds could potentially extend from October to April and for rainbow trout, from early March until early June, resulting in closures a significant portion of the year. Spawning area closures for rainbow and brown trout in this reach, which are relatively discrete areas, would also draw attention to those areas and could be counterproductive. Population triggers have been defined in the management plan at 1,000 rainbow trout per mile and 100 brown trout per mile during fall electrofishing surveys. If these triggers are reached, additional management strategies will be implemented.

c) Comment: Guides and outfitters need to be regulated on (the Missouri River below Hauser Dam) in order to reduce overcrowding.

Response: Regulation of guides and outfitters is an issue beyond the scope of this management plan and would require a separate process. Although overcrowding may be an important social factor, FWP data suggests that guide/outfitter use currently is not a limiting factor to rainbow and brown trout production below Hauser Dam.

d) Comment: We recommend that the walleye bag limit be increased and that the slot limit be eliminated in the Hauser tailwater. We disagree that the walleye bag limits needs to be the same in the Hauser tailwater and Holter Reservoir; certainly this isn’t the case with rainbow trout bag limits.

Response: Walleye abundance in the Hauser tailrace has increased substantially in recent years, especially following expansion of the Canyon Ferry walleye population. Walleye have represented 8.7- 12.6% of the total number of rainbow trout handled in the 1.7 mile long Hauser tailrace during fall 2007 and 2009 sampling. Back in the early 1980’s, walleye were sampled in this section only in the spring and in much lower densities than observed in this recent sampling. The management plan provides direction to increase walleye daily limits, but makes no recommendations to eliminate the slot limit. Although there are a number of resident walleye that reside in the Hauser tailrace, a majority of the walleye are migratory and move seasonally between the tailrace and the reservoir. Currently, FWP has little information about walleye harvest levels below Hauser Dam. The management plan proposes a comprehensive creel survey that assesses angler use of the Hauser tailrace, which includes angler catch rates for rainbow trout, brown trout, and walleye and angler harvest of rainbow trout and walleye.

12 Consistency of bag limits between Holter reservoir and the Hauser tailrace precludes violations among anglers who access the tailrace from Upper Holter.

Missouri River below Holter Dam Comments Comments a) Comment: I wish in your upcoming meetings you would address trout limits on the Missouri River below Holter Dam. I would like to see limits back to a 5 fish limit including one smaller brown trout.

Response: The Missouri River below Holter Dam is outside of the scope of this management plan. The current combined trout limit from Holter Dam to the mouth of the Dearborn River is 1 rainbow trout (any size) daily and in possession and 1 brown trout (22-inch minimum) daily and in possession. Public comments on general fishing regulation changes will be accepted for the 2012 regulation setting process, which begins August 2011.

b) Comment: Trout Unlimited recommends three immediate actions by the Commission and Department: 1) Reclassify the stretch of river below Holter Dam as a trout fishery and not as a multispecies fishery. This allows for walleye suppression measures. 2) Aggressively undertake walleye suppression measures (below Holter Dam). 3) Undertake systematic, long-term walleye population census data collections (below Holter Dam).

Response: Since this management plan covers the Missouri River reservoir system from Toston Dam downstream only to Holter Dam, management strategies for this stretch of river were not included in this plan. The Missouri River below Holter Dam is currently managed as a cold-water fishery and no substantive changes to the fisheries management are currently proposed or planned for this stretch of river. Fisheries management biologists believe that current densities of walleye do not pose a threat to the trout fishery below Holter Dam and have not proposed any plans to actively remove walleye from the Missouri River. FWP data shows that increases in walleye abundance below Holter Dam is strongly correlated to high flows and flushing from Canyon Ferry Reservoir. The frequency of small walleye and low abundance of young of the year fish indicate a low level resident population of walleye. While data collected in the 5.6 mile long Craig section since 1982 shows substantial walleye increases in the late 1990’s and from 2007-2009 (see graph below), these increases never represented more than a maximum of 3.4% and 2.7% of the brown and rainbow trout, respectively, handled during estimate work. While the average number of brown trout handled in the spring has been 1,587 fish, the maximum walleye ever handled was 43; for fall work, an average of 3,841 rainbow trout have been handled and the maximum number of walleye sampled is 71, which occurred in 2008. The highest percentage of walleye handled compared to brown trout was obtained in 1983. Additionally, seasonal movements of larger walleye show use of the entire 90-mile reach of river from Holter Dam to Great Falls and movements likely follow a forage base that is not trout. Should monitoring show changes that pose a risk to trout populations, active management strategies for walleye would be considered for implementation.

13 Walleye Captured - Craig Section - 5.6 Miles

75 70 Craig spring 65 Craig fall 60 55 50 45 40 35 30 25 Number of Walleye 20 15 10 5 0

2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 0 1 2 3 4 5 6 7 8 9 8 8 8 8 8 8 8 8 9 9 9 9 9 9 9 9 9 9 0 0 0 0 0 0 0 0 0 0 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 19 20 20 20 20 20 20 20 20 20 20 Year

In addition to the Craig section, FWP has conducted electrofishing surveys below Holter Dam in the Holter section on even-numbered years since 2006 and much further downstream in the Cascade Section near Pelican Point Fishing Access Site. FWP with assistance from PPL Montana plans the continuation of surveys in these sections to monitor fish populations and to collect catch per unit effort data for walleye and other species where numbers are so low that population estimates are not attainable. As shown in the table below, in the 2.5 mile long Holter Section, walleye represented 1.8-5.7% of the total number of rainbow trout handled in 2006 and 2008. Although the 2008 ratio of walleye to rainbow (5.7%) is higher than in the Craig section, FWP believes harvest rates are high in the river reach below Holter Dam.

Year Rainbow trout % Hatchery Rainbows Walleye Walleye (% of Rainbow) Holter Tailrace 2006 782 1.3 14 1.8 2008 999 9.7 57 5.7

Fish-eating Bird Comments Comments a) Comment: I do not believe the finding that cormorant populations have stabilized. In my observation the population continues to grow significantly.

Response: FWP Wildlife staff conducts nest counts annually at the Canyon Ferry Wildlife Management Area. This data shows an increase in cormorant nesting pairs throughout the 1990’s and early 2000’s, peaking at 838 nesting pairs in 2003. Since that time, cormorant numbers have generally declined, ranging between 372 and 557 nesting pairs.

14 b) Comment: We find the following provision on American white pelicans and Double-crested cormorants troubling: “Consider active bird management strategies if research shows significant impacts to fish populations.”

Response: FWP data suggests that American white pelican impacts to the reservoir sport fisheries are likely insignificant, while Double-crested cormorants may have some effect to stocked rainbow trout. FWP data is incomplete in that bird diet data is collected only while fledgling birds are still on the nest. Much more information would be needed to determine whether population control measures would be warranted or necessary. Additionally, FWP would be required to obtain proper permitting and undertake a MEPA process including public comment if attempts were made to implement active any potential bird management strategies.

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