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Final EIS Responses to Comments 1-40

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Final EIS Responses to Comments 1-40 Table 1-2. Responses to Comments Comment Response Comment/Response Number Number 1.1 The lakes in question are in our main camp area. We have operated in this area for thirty years and probably know more about the fish in these lakes than anyone associated with this ridiculous plan. These lakes have provided unequalled fishing to our guests and all others that have fished them. 1.1 This project is designed to preserve this stronghold for native westslope cutthroat trout. This project proposes to re-establish WCT populations in all treated lakes, which will maintain angling opportunities. 1.2 We feel that his plan goes against all that is held sacred in a wilderness area. … We believe the "Wilderness Act" should be respected and these areas should not be tampered with. 1.2 Native westslope cutthroat trout are considered a wilderness value. This project is designed to maintain and conserve that value. 1.3 Why should anyone be allowed to tamper with these healthy fish in order to obtain a genetically pure strain of fish? 1.3 It is the responsibility of MFWP to ensure that this species is conserved and maintained so the public of Montana can continue to use and enjoy it. The species has been at risk of hybridization for some time. MFWP has taken measures to reduce and eliminate the threats (see Section 1.2 of the DEIS). The species has been proposed for ESA listing (see Section 1.4.1 and Appendix B of the DEIS). MFWP is mandated to keep this from happening so the public does not lose the opportunity to use and enjoy WCT (see page 1-8 of the DEIS). 1.4 The plan also flirts with the use of helicopters to carry out the fish kill and poison the lakes. Helicopters are only to be used in the "wilderness" for emergency reasons. Is this an emergency? 1.4 Both the Wilderness Act and the Fish and Wildlife Management Framework Document for the BMWC provide provisions for using motorized equipment. The Act states specifically states: …(c) Except as specifically provided for in this Act, and subject to existing private rights, there shall be no commercial enterprise and no permanent road within any wilderness area designated by this Act and, except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act (including 177 178 Table 1-2. Responses to Comments Comment Response Comment/Response Number Number measures required in emergencies involving the health and safety of persons within the area), there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, no landing of aircraft, no other form of mechanical transport, and no structure or installation within any such area…(Section 4(c) of the Wilderness Act). The Forest Service Manual allows approval of motorized equipment and mechanical transport in the wilderness. (FSM 2326.04). Additionally, the agencies that are involved in this project believe that under the Wilderness Act and the Forest Service’s directives implementing it allow the Forest Service to authorize the use of motorized equipment and aircraft to implement this project. The DEIS further explains this in Sections 3.6.3.3 and 3.6.1. The DEIS notes that “[t]he Forest Supervisor may authorize use of motorized equipment or livestock as deemed necessary for the administration of the area and its resources.” The agencies believe that the intensity of the wilderness disturbance from the use of motorized equipment and mechanical transport would be very low. There would be no more than 2 of the wilderness lakes or wilderness lake complexes treated in a given year. See Section 2.4.4 of the DEIS. The Fish, Wildlife and Habitat Framework for the Bob Marshall Wilderness Complex goes on: The emphasis is on the management of the BMWC as opposed to the management of a particular resource. This language is viewed as discretion that all management activities within the wilderness be done without motor vehicles, motorized equipment, or mechanical transport, unless truly necessary to administer the area or specifically permitted by other provisions in the Act. It means than any such use should be rare and temporary; that no roads can be built; and that wilderness managers must determine such use is the minimum necessary to accomplish the task. Additionally in Section 15 “Use of Motorized Equipment” it states Guideline: (a) Any use of motorized equipment or mechanical transport requires advance approval through the USFS Forest Supervisor for any management proposal. It is important to include an alternative that does not use motorized equipment. Where there are choices among management options, wilderness values should dominate over other considerations. Managers Table 1-2. Responses to Comments Comment Response Comment/Response Number Number should also consider safety and length of time of disturbance to visitors in preparing management options. As per this directive, the DEIS considered alternatives to using motorized and mechanized equipment in the wilderness potion of the project area. Section 3.6.5 of the DEIS provides the draft Minimum Tool Analysis that was developed to aid in making decisions about the preferred alternative. 1.5 If anything at all were proposed to eliminate the thriving, healthy fish in these lakes, saturation of the lakes with westslope cutthroats would be the most viable answer. But again, why kill healthy, viable fish only for genetic reasons. We believe this to be true in any location, but especially true in the wilderness which established areas to remain as they are. If fish are allowed to be tampered with in the wilderness, what next? 1.5 Section 1.2 (pages 1-7, and 1-8) and Section 2.6.4 (page 2-35) of the DEIS addresses this issue. 1.6 These thriving, healthy, big, fat fish [currently in alpine lakes] should not be killed for purely genetic reasons. These fish pose no threat whatsoever to pure westslope cutthroat. 1.6 It has been known for many years that hybrid trout pose a threat to the remaining pure WCT populations in the SF drainage. See Section 1.2 of the DEIS. 1.7 The plan also flirts with the use of airplanes and powerboats to carry out the fish kill and poison the lakes. Airplanes are only to be used in the "Wilderness" for emergency reasons. Is this an emergency? 1.7 See response to Comment 1.4. 1.8 What effect on bears etc, eating poisoned fish 179 180 Table 1-2. Responses to Comments Comment Response Comment/Response Number Number 1.8 See page 3-22 of the DEIS. Appendix D of the DEIS also provide information on the effects of rotenone on mammals. Page 3-56 of the DEIS provides information on human health threats from exposure to antimycin. Much of the information used to derive the values for humans were determined from studies conducted on rats (Stillmeadow 2001). The Schnick (1974a) paper that is cited on page 3-57 of the DEIS reported that guinea pigs and mice have also been used to determine the effects on mammals. The Ritter and Strong (1966) paper that is cited on page 3-57 concluded that mammals suffered no ill effects from eating fish killed with antimycin. On this basis, we would expect the same results with other mammals, including bears, which might consume antimycin-killed fish. 1.9 Another arm of the government obtaining $ for ridiculous purposes. 1.9 Comment noted. 2.1 To kill off what you call non-native trout and grayling is the same as killing people because they are not the correct race. 2.1 Comment noted. 2.2 My family and many of my friends and their families have fished Handkerchief Lake for more than 10 years for the grayling. We make several trips a year to camp and fish for the usually large grayling in the lake. We fly fish in float tubes and release all the fish we catch so we can to continue to experience great grayling fishing. This lake up to last year held the state record for grayling. 2.2 MFWP would remove as many grayling from Handkerchief Lake using Merwin and Fyke traps and maintain them in a floating net pen in Graves Creek Bay during the treatment of the lake. After the lake is detoxified, these fish would be replaced in Handkerchief Lake. 3.1 It is a good fishery already. Table 1-2. Responses to Comments Comment Response Comment/Response Number Number 3.1 Thank you for your comment and interest in the SF WCT Conservation Program. 3.2 I think if we get involved in it, we will screw up more of the river than just the lakes. 3.2 Thank you for your comment and interest in the SF WCT Conservation Program. 4.1 We have a healthy fishery right now. We like that the Westslope Cutthroat is a very strong strain and that is pure in the lava areas. 4.1 Thank you for your comment and interest in the SF WCT Conservation Program. 4.2 It seems like when the fish and game get involved in one of these processes it always takes longer than they think it is going to and usually there is more messes up there than improvements. So we don't want you to fund that process. However, we would like to see you contribute to grade the roads so people can come out to access the national forests. A lot of times these people tear up their vehicles driving up these roads that don't have any funding to go fishing.
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