In September 2014 the U.S. Fish and Wildlife Service (USFWS) released a long-awaited draft recovery plan for the threatened bull trout—a requirement under the Endangered Species Act (ESA).
It’s been a process.
According to the ESA, this guidance document must include “objective, measurable criteria which, when met, would result in a determination, in accordance with the ESA, that the species be removed from the list.” In other words, a plan that will help bull trout recover to the point that they no longer need special protection under the ESA.
To date, the USFWS has completed two draft bull trout recovery plans—one in 2002, and another in 2004. Neither was adopted. The current draft plan came in response to a lawsuit filed by two Montana conservation groups that have been litigating to protect the bull trout for a decade.
The 2014 draft plan takes a radically different approach to recovery planning than we’ve seen in the previous efforts. Conversations we’ve had with fisheries biologists have us concerned that the USFWS hasn’t incorporated the best available science to give bull trout the highest chance of recovery. In fact, we see several weaknesses with the plan:
- it removes demographic targets from the list of recovery criteria and replaces those with the management of yet-to-be-identified, site-specific threats;
- it asserts that up to 25% of local bull trout populations in 4 of the 6 recovery units, including the unit encompassing the Clark Fork, could be lost with no effect to the overall recovery of the species; and
- it establishes no habitat standards and makes no correlation between the threats to be managed and the physical and biological features essential to bull trout conservation.
If this plan contains “objective, measurable criteria” to determine when the bull trout is recovered, we’re not seeing it.
Why does this matter? Bull trout have strict habitat requirements. So the presence of a healthy bull trout population means our watershed is healthy and resilient. Bull trout require the “5 C’s” for survival: clean, cold, complex, connected, and comprehensive habitat. Working toward bull trout recovery, then, is about working toward a healthier Clark Fork. It’s hard to see how we’ll make things better for bull trout when habitat standards aren’t considered, when we swap solid recovery targets with vague management language, and when we write off 25% of local populations.
Please join us in submitting comments to USFWS outlining the concerns above and telling them we expect more for our bull trout. Comments are due Wednesday, Dec. 3. Stay tuned as we continue to track this issue in 2015. For more information contact CFC Legal Director, Barbara Chillcott, at 406-542-0539 x211 or .
→ View CFC’s comments here (382k PDF file)
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