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A FISH CONSUMPTION SURVEY of the SHOSHONE-BANNOCK TRIBES December 2016

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A FISH CONSUMPTION SURVEY of the SHOSHONE-BANNOCK TRIBES December 2016 A FISH CONSUMPTION SURVEY OF THE SHOSHONE-BANNOCK TRIBES December 2016 United States Environmental Protection Agency A Fish Consumption Survey of the Shoshone-Bannock Tribes Final Report This final report was prepared under EPA Contract EP W14 020 Task Order 10 and Contract EP W09 011 Task Order 125 with SRA International. Nayak L Polissar, PhDa Anthony Salisburyb Callie Ridolfi, MS, MBAc Kristin Callahan, MSc Moni Neradilek, MSa Daniel S Hippe, MSa William H Beckley, MSc aThe Mountain-Whisper-Light Statistics bPacific Market Research cRidolfi Inc. December 31, 2016 Contents Preface to Volumes I-III Foreword to Volumes I-III (Authored by the Shoshone-Bannock Tribes and EPA) Foreword to Volumes I-III (Authored by the Shoshone-Bannock Tribes) Volume I—Heritage Fish Consumption Rates of the Shoshone-Bannock Tribes Volume II—Current Fish Consumption Survey Volume III—Appendices to Current Fish Consumption Survey PREFACE TO VOLUMES I-III This report culminates two years of work—preceded by years of discussion—to characterize the current and heritage fish consumption rates and fishing-related activities of the Shoshone- Bannock Tribes. The report contains three volumes in one document. Volume I is concerned with heritage rates and the methods used to estimate the rates; Volume II describes the methods and results of a current fish consumption survey; Volume III is a technical appendix to Volume II. A foreword to Volumes I-III has been authored by the Shoshone-Bannock Tribes and EPA. The Shoshone-Bannock Tribes have also authored a second foreword to Volumes I-III and the ‘Background’ section of Volume I. All other sections of this report have been authored by the members of the contractor team listed on the title page preceding Volume I. FOREWORD TO VOLUMES I-III (AUTHORED BY THE SHOSHONE-BANNOCK TRIBES AND EPA) The Native American tribal governments in the State of Idaho collaborated with the U.S. Environmental Protection Agency (EPA) Region 10, and tribal consortia to gather data on tribal fish consumption rates (FCRs) in Idaho. One objective of this effort was to assess the risks posed by contaminants in fish for populations who consume large quantities of fish in the State of Idaho and among the Idaho tribes. More generally, this effort was intended to enhance tribal environmental capacity in the area of water quality. The tribes and EPA met with the State of Idaho to develop tribal surveys that supported Idaho’s efforts to develop ambient water quality criteria (AWQC) protective of high fish consumers. This report presents survey methodology and results, specifically FCRs, for the Shoshone-Bannock Tribes. The survey is focused on both current and heritage rates. Heritage rates are tribal FCRs that existed prior to modern environmental and social interferences with historic tribal fishing and fish consumption practices. Within this report, current rates are discussed in Volume II, with supporting material provided in Volume III. Heritage rates are discussed in Volume I. For tribes and tribal members, fish1 are an important food and economic resource. The harvest and consumption of fish also figure significantly in tribal culture and spirituality. Because of water quality’s effects on fish and fisheries, water quality is of great importance to the Native American tribes in Idaho. Water quality affects the health of fish populations, the level of contaminants in fish and the consequent health risks posed by these contaminants to tribal members when they consume fish. Water quality also impacts fishing and fish consumption related aspects of tribal culture and spirituality. This report shows that a substantial portion of the diet of the Shoshone-Bannock Tribes consists of fish and shellfish, which research has shown acquire contaminants (e.g. PCBs, mercury, dioxins, etc.) from water. This report’s results are consistent with findings that Puget Sound and Columbia River Basin tribes have much higher FCRs than the general U.S. population (CRITFC, 1994, Toy et al, 1996, Suquamish Tribe, 2000, Polissar et al, 20142). As a result of higher tribal fish consumption relative to the general population, tribal people suffer disproportionate exposure and risks associated with contaminants in fish. Generally, contaminant levels in water and fish are linked. Therefore, as the FCRs for populations consuming fish increase, the water must become cleaner in order to keep human exposures to toxic chemicals in fish at acceptable levels. EPA Region 10 is supporting Idaho’s tribal governments in identifying appropriate FCRs to use in protecting the health of Idaho tribal members. Current FCR statistics (i.e., averages and percentiles) included in Volume II of this report are reported in terms of usual consumption: the average daily grams of the edible mass of uncooked fish and shellfish consumed by a tribal member. A fish consumption study fits into a larger context. There are three eras of importance for such a study: the past, the present, and the future. Considering the past, over an extended period of time the Shoshone-Bannock Tribes have experienced a suppression of consumption due to environmental and social changes that have reduced fish abundance, access to fish, safety of fish consumption, and fish consumption itself. Suppressed fish consumption threatens tribal culture 1 Hereafter, “fish” will refer to fish and shellfish. 2 References for these reports can be found in the reference section of Volume II. and rights, as well as the health of individual tribal members. The Tribes are seeking to improve fish availability, reduce contamination of fish, and increase fish consumption in the future. (These goals were expressed to the contractors multiple times during meetings with tribal staff.) Thus, current consumption does not reflect the Tribes’ past nor their goals. Assessing consumption through a current cross-sectional survey will provide relatively precise information about current consumption only. A complete understanding of tribal fish consumption issues thus requires not only consideration of current fish consumption rates, but should also consider tribal goals and heritage fish consumption. Assessing past consumption involves review of historical materials and, potentially, interviews with some older individuals whose memories span a long lifetime (and whose memories may carry stories passed down from earlier generations).3 Assessment of past consumption is likely not as precise as that of current surveys because derivation of heritage rates does not employ the same methodology as modern surveys of current fish consumption, and involves longer-term recall and unknown quality and completeness of past documentation. Further, heritage surveys can only provide estimates of average fish consumption as opposed to distributions of fish consumption rates that can be obtained by current fish consumption survey methodologies. Nonetheless, heritage rates are valid data that have been developed with defensible, rational, and accepted research methods (e.g. ethnographic observation, caloric intake, etc.). There have been many studies of historic rates and suppression of fish consumption in the past, but their isolation from a report on current rates may have denied them the attention they deserve. Multiple studies using different methods have demonstrated that heritage FCRs exceeded current FCRs. Shoshone-Bannock heritage and current FCRs documented in Volumes I and II of this report are consistent with these findings. In other words, current FCRs are reduced or suppressed4 relative to heritage FCRs. Tribes are concerned that development of water quality criteria based on suppressed fish consumption rates may not allow restoration of water quality to support safe consumption of fish at the higher rates tribes’ desire, rates informed by treaties between tribes and the U.S. government that guaranteed tribal rights to practice subsistence fishing. The rates and supporting materials generated by this study will be used to protect the health of members of the Shoshone-Bannock Tribes and other Idaho residents who consume large quantities of fish. The strength of the current rates is that they are derived by a technically defensible methodology, and these rates can be compared to those of other populations. The strength of the heritage rates is their relevance to the goals of the Tribes. The website of the Shoshone-Bannock Fish and Wildlife Department states, “The mission of the Shoshone-Bannock Tribes Fish & Wildlife Department is to protect, restore, and enhance fish and wildlife related resources in accordance with the Tribes’ unique interests and vested rights in such resources and their habitats, including the inherent, aboriginal and treaty protected rights of Tribal members to fair process and 5 the priority rights to harvest pursuant to the Fort Bridger Treaty of July 3, 1868.” 3 It should be noted that suppressed fish consumption has likely occurred prior to the birth of almost all tribal elders alive today, and hence no firsthand accounts of unsuppressed consumption are possible. 4 For an in depth discussion of the concept of suppression, see: National Environmental Justice Advisory Council (NEJAC). Fish Consumption and Environmental Justice: A Report Developed from the National Environmental Justice Advisory Council Meeting of December 3−6, 2001. 2002. https://www.epa.gov/sites/production/files/2015-02/documents/fish-consump-report_1102.pdf 5 http://www.shoshonebannocktribes.com/shoshone-bannock-fish-and-wildlife.html, accessed September
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