1

Document Title : GCMRC Response to TWG Comments

Document Date: Sept. 18, 2009 (updated : January 15, 2010)

Authors: Matthew Andersen and Kara Hilwig

#

Pa

ge

Line Reviewer 

Name

Affiliation Reviewer Comments Identify 

Action 

Requested

Response 

Requested

GCMRC

Response/Action Taken

GENERAL COMMENTS

Ge

ner

al

Dave 

Speas and 

Dennis 

Kubly et 

seq.

BOR We find the GCMRC draft plan to be oriented largely 

toward the research (and monitoring) of nonnative (and 

native) fish, with limited attention to management. There is 

insufficient integration of these activities, and management 

seems largely to be a byproduct of, rather than a driver of, 

research and monitoring. By our count, 40 of the 49 pages 

in the main body of text primarily address research and 

monitoring.

Respond Written We believe that the length of the 

various sections in the document 

reflects information needs and 

availability. We tried to be 

succinct and not count pages as a 

measure of quality of the 

document. We think that the

research and management 

presented will support 

development of management 

actions and/or mgmt. needs.

Managers need to provide input on 

desired future conditions, desired 

management actions, management 

priorities, etc.

Ge

ner

al

BOR We think the next draft of the plan will need to again be 

reviewed by the Science Advisors. In our review, we found 

that concerns of the Science Advisors were still not 

sufficiently addressed. We expect that the next version of 

the plan will contain sufficient changes to warrant this 

review.

Respond Written The SAs have commented that 

they found the document 

responsive to their review of the 

previous iteration. If the TWG 

doesn‘t agree then it seems more 

appropriate to have GCMRC work 

out concerns with TWG rather 

than confounding the discussion 

with the continued input of a 3rd

party.

12 46 1732

-

1733

BOR I would think prevention would be the ―ultimate‖ key to 

nonnative fish control as well.

Clarify 

role of 

prevention 

in this plan

Section clarified. Please see 

Contingency Section.
2

7 239 Bill 

Persons

AZGFD Statement that recommendations for nonnative fish 

management approaches and priorities may change as new 

information is evaluated from annual nonnative fish 

workshops, literature reviews...etc. raises the possibility that 

control efforts may change from year to year, depending on 

the outcome of nonnative fish workshops. I urge caution in 

this approach of changing priorities every year. I had hoped 

for a nonnative control plan that includes control activities 

and necessary monitoring spanning several years (long term 

plan) to assess any control methods implemented. If annual 

meetings are to be used to guide a nonnative control 

program, they need to be well structured, include the right 

people, and produce recommendations.

Link 

monitoring 

to control 

efforts for 

the period 

through 

2012.

Changes in control activities will 

be carefully evaluated with close 

attention to data from annual 

monitoring and research programs. 

Changes in priorities will be 

evaluated before implementation 

and will be reviewed with 

scientists and managers during 

annual nonnative fish workshops 

as well as the AMP program. 

Importance of the link between 

monitoring and control programs 

has been emphasized. Please see 

specifically revised 

Recommendations/ Annual 

Nonnative Fish Workshop and 

Implementation and Contingency 

Sections.

47 Bill 

Persons

AZGFD Summary Monitoring, Removal, Research, and Other 

Management Strategies. I think this section needs to be 

carefully reviewed and revised based upon more objective 

criteria.

Revise or 

move to 

implementa

tion plan?

Yes Because a number of reviewers 

have requested defined criteria we 

will work on adding process and 

criteria information to the 

document. However, we believe it 

is important to not become 

consumed by process and criteria, 

remaining attuned to the data for 

evaluating important studies 

and/or actions that are needed. It 

will also be important to recognize 

that quantification of priorities will 

still represent a subjective 

analysis. Please see 

Implementation Section.

8 na na LaGory WAPA The ―Summary and Integration of Fish Sampling‖ section 

contains little if any integration.

Rewrite Y Our intent was to summarize fish 

projects that have been conducted 

by the GCDAMP for the past 

several years. Section title was 

changed. Please see Summary of 

Fish Projects.
3

7 na na LaGory WAPA The report is very repetitive treating the same topics several 

times at about the same level in the ―Review of Recent Fish 

Sampling Activities‖ and the ―Recommendations‖ sections. 

The recommendations section does not need to repeat the 

history of past efforts.

Rewrite Y Realizing that many readers of this 

document will focus their attention 

to limited sections, we attempted 

to write each section to  ̳stand 

alone‘. To do this, important 

sections of text have been inserted 

in multiple sections of the 

document. The revised 

Recommendations Sections 

include sentences to justify the 

recommendation are more fully 

developed elsewhere. 

12 na na LaGory WAPA The report should receive a thorough technical edit. There 

are numerous misspellings, omissions, and formatting 

problems.

Edit N Document formatting errors and 

misspellings we identified were 

corrected. We appreciate specific 

editorial comments.

22 8 278 Capron WAPA There are 250 information needs in the strategic plan – this 

is too unwieldy. A more limited list for the program to 

focus on might be more effective.

N We agree that 250 INs is 

cumbersome. Although we 

continue to selectively cite the 

INs, we believe the Strategic 

Science Questions are much more 

useful and so we cite these, as 

well. The interested reader can 

find a crosswalk between INs and 

SSQs at the end of the Monitoring 

and Research Plan approved in 

2008 (or we can provide, if 

desired).

23 8 283-

321

Capron WAPA This is the typical approach in GCMRC documents, to list 

the SSQs, but nowhere does the document discuss our 

ability to answer the current ones and describe the missing 

information or how we plan to answer these. The current 

approach here, in the work plan, and other science plans to 

merely list the SSQs that a project relates to is of little 

utility to the program. A better approach is to list the SSQs, 

describe our knowledge and research pertaining to each 

one, and how the proposed work will add to our ability to 

respond to each SSQ. How will information be synthesized 

and analyzed to answer the questions?

Modify Y GCMRC strives to demonstrate 

the relevance of our work to the 

published TWG and SA guidance. 

The space required to list each 

SSQ and describe our work 

pertaining to each one would 

unnecessarily increase the length 

of this document. The 2009 

Annual Reports GCMRC is 

preparing for January will follow 

suggested format.
4

38 29 1029 Capron WAPA It is beneficial to clearly articulate assumptions, however, I 

fail to see how these assumptions are being tested, how 

much of an assumption they are, or whether we have any 

information which would inform these assumptions?

Y We agree with the importance of 

articulating assumptions and thus 

included them in the document. 

Testing of assumptions is implicit 

through the implementation of 

recommendations. If we observe

an unexpected result, then we 

disprove the assumption. For 

example, if nonnative fish are 

removed and we do not observe a 

positive response in native fish 

communities, then we recognize 

that our assumptions may need 

specific testing through focused 

experimentation. In order to be as 

succinct as possible, we embedded 

the assumptions within the 

Recommendations Section.

45 35 1284 Capron WAPA Why is a literature search recommended? It seems this 

report draws on a literature search already.

Modify Y A literature search associated with 

historic stocking locations within 

the watershed, State sport fish 

stocking plans, and nonnative fish 

captures on tribal lands will assist

in evaluating sources of nonnative 

fish into Grand Canyon. Text 

clarified in Sources, Literature 

Review Section.

35 1287 Bill 

Persons

AZGFD A more complete literature review needs to be done. I had 

hoped that this would be part of the planning.

We agree literature reviews take 

time. Studies relating to sources of 

nonnative fish have been initiated 

but not completed. 

48 44 1690 Capron WAPA Annual workshops might be too often for this program, 

maybe every other year?

Modify N Nonnative fish issues can arise in a 

very short time frame (detection of 

a new species, evidence of large 

recruitment events). We feel, 

given the dynamic nature of 

organisms, that it is important to 

review annual monitoring 

information to quickly identify and 

formulate responses to nonnative 

fish problems. Participation in the 

annual workshop is voluntary.

8 245 Bill 

Persons

AZGFD Section on Efforts to protect Grand Canyon Fish should 

include references to previous projects; suggest keeping 

References Yes References to previous projects are 

explicit in the Introduction 
5

description of GCDAMP separate. Section. The intent here is to link 

native fish protection efforts with 

the AMP. See revised section title: 

Native Fish Protection and the 

GCDAMP

14 Bill 

Persons

AZGFD Mainstem HBC Aggregation Monitoring was discontinued 

several years ago. I understand that aggregations will be 

sampled during 2010, but details are still not clear.

Revise 

table

Yes Revised table. Mainstem HBC 

aggregation sampling is scheduled 

for 2010 and 2011.

17 549 Bill 

Persons

AZGFD Nonnative fish control program = nonnative fish control 

experiment. Objective was not just to reduce nonnatives, 

but to learn if the method would provide benefit to native 

fishes to direct future management efforts. I think that

concept of learning by doing is at the heart of Active 

Adaptive Management.

Yes Agree with comments, and so have 

maintained monitoring of natives 

in work plans to evaluate impacts 

of control.

RISK ASSESSMENT

1 na na Capron/La

Gory

WAPA Risk Assessment. The main component missing from this 

plan is a risk assessment similar to Johnson et. al. (2008). 

This is articulated as a priority effort to be completed after 

this plan is approved. This should have already been 

completed during this planning process. Without the risk 

assessment the plan is little more than a literature review. 

The plan is a helpful document, provides good background, 

and describes the tasks that generally need to be done, but 

little can be completed or meaningful decisions made 

without the risk assessment. That isn‘t to say that efforts 

can‘t be made to move forward, but knowing where the 

most benefit (or greatest risk lies) is critical to making good 

decisions. For example, the AMP is embarking on 

nonnative removal of trout in the LCR reach of the 

mainstem with little scientific rationale for the intended 

target (90% reduction) and without a fisheries perspective 

on the effort necessary to maintain those reductions. There 

is no discussion of when those reductions would be most 

effective (spring, fall, winter?), or how effort should be 

spread out throughout the year (e.g., quarterly removal 

trips). If immigration rates are high and movement occurs 

mostly in the spring/summer, then late winter removal trips 

might have little impact on HBC environment and might 

have little impact on predation rates. A risk assessment is 

needed to help elucidate these connections and help us 

target our efforts. Before any of the recommendations are 

implemented, performance of a risk assessment is needed to 

Discussion 

needed

Y We have not completed a risk 

assessment because we have been 

writing this plan. Since delivering 

the draft document for review we 

have been able to make progress 

on modeling which we intend will 

be the heart of the risk assessment. 

Labeling the plan ―little more than 

a literature review‖ is insulting, 

condescending, and inaccurate. 

For example, a pure literature 

review would not attempt to 

develop recommendations based 

on the information presented. We 

have pushed ourselves to make all 

of the recommendations to 

managers that we think are 

scientifically/technically supported 

at this time. Stating that the risk 

assessment should already be 

complete demonstrates 

unfamiliarity with what is needed 

to develop a bioenergetic-based 

assessment. We agree with the 

reviewers that a risk assessment is 

needed and therefore are 

increasing our efforts. The 
6

determine what species and areas should be targeted. reviewers‘ recommendation that 

nothing take place until the risk 

assessment is completed is 

inconsistent with their comments 

elsewhere, e.g., that efforts to 

remove rainbow trout should be 

increased because of potential 

immigration into the LCR reach.

We think that the risks of doing 

nothing outweigh the risk 

associated with pursuing the 

highest priority recommendations 

in the near term, but that could be 

reviewed in consultation with the 

TWG. Professional judgment is 

currently used in this plan and by 

the AMP, as it is elsewhere (e.g., 

UCCRIP, San Juan RIP) to guide 

nonnative control efforts. We hope 

to build on this with the conduct of 

a risk assessment.

17 202-

243

BOR In their review of the NNF plan, the Science Advisors wrote 

(page 2, bottom) ―Although much of the information 

necessary for an effective control plan exists in the 

document, it does not have appropriate context, 

organization and balance. Of particular importance is the 

omission of a general strategy for this program of work that 

speaks to its overall goal, processes for determining the key 

problems to address, areas of priority focus, balance of 

management and science required, integration with other 

ongoing programs, etc. As noted above and proposed by 

the authors, it is drafted more as a research and monitoring 

plan, rather than a Non-Native Fish Control Plan supported 

by research and monitoring activities.‖

While we (Reclamation) believe that many of the 

ingredients for a strategy have been presented, they are not 

integrated into a strategic format. In their revision to 

include SA comments the authors included a section on a strategy at the onset of the document (Page 7 of NNF plan, 

"Overall nonnative fish management strategy"). However, 

the strategy appears to be one of many lists of activities 

without any associated timeline, breakdown of subtasks, 

order of implementation, appropriate management agencies, 

etc. A way to fix this might be to integrate the monitoring, 

1. Work 

with 

manageme

nt agencies 

to develop 

an 

implementa

tion 

strategy

that 

integrates 

monitoring, 

control and 

research 

priorities 

under each 

strategy 

bullet (page 

7, NNF 

plan).

2. Review 

revised risk 

assessment 

We believe the reviewers‘ 2 

requested action items are 

constructive and we will 

incorporate as appropriate. We 

believe the annual nonnative 

meetings provide a regular forum 

for monitoring progress on an 

implementation strategy, and stand 

ready to participate in additional 

meetings with management 

agencies on this topic. We will add 

an implementation section to the 

plan to help frame 

implementation, though 

completing it will take input from 

management agencies. We 

received the revised risk 

assessment written by Valdez and 

Speas on 1 Sep. 2009. We will review and incorporate as 

appropriate. 

Based on these comments and 

others we see that we have not 

repeated our description of the 
7

control and research priorities under each strategy bullet 

(page 7, NNF plan), and do so in the form of an 

implementation timeline with management input. This 

would simultaneously satisfy at least four SA concerns, i.e., 

the need for formal strategy development, collaboration 

with managers, science and management integration, and 

development of a ten year strategy (first, second, fifth and 

eighth bulleted recommendations from SA comments, 

pages 3-4). Certainly some activities have to happen before 

others, some can be initiated concurrently with others, and 

linkages between science and management could also be 

more explicitly called out in this format as well. As they 

stand now, monitoring, control and research activities 

appear as disjunctive lists in the executive summary and 

could benefit by integration via an implementation 

framework. For example, development of remote PIT tag 

antennae and pheromone research are recommended as a 

means to learn more about carp for control actions, yet 

control of carp doesn‘t appear as priority under the control 

actions list (lines 44-51 of the draft plan, despite SA 

recommendations to do so); however it is implied later that 

carp control would take place in the LCR (lines 1140-

1150). To avoid the need to flip back and forth between the 

various sections of the document, the relationships between 

research, monitoring and control actions should be 

explicitly defined at some point in the document, especially 

in terms of the 5-10 timeframe recommended by the SAs. 

Roles and responsibilities of the management agencies 

should also be identified therein. 

Finally, Reclamation has completed a revised risk 

assessment (Valdez and Speas) which addresses comments 

and concerns provided by GCMRC on September 25, 2007. 

We originally thought that this project would be referenced 

in more detail in the nonnative fish plan (see notes from 

2006 NNF workshop), but that is not the case. Still, we 

hope that this document will still be of some use in 

characterizing the relative risk of nonnative fish 

proliferation in response to altered thermal regimes and will 

make it available for the final revision along with responses 

to GCMRC review comments.

When completed, also, Reclamation will make available its 

hydroacoustic assessment of the Glen Canyon Dam forebay 

fish community to aid in the evaluation of entrainment risk 

(Valdez 

and Speas) 

and 

summarize/

reference in 

plan as 

appropriate

prioritization of recommendations 

in all of the appropriate places in 

the plan; we will rectify in the next 

iteration. Prioritization of the most 

immediate needs is reflected in the 

AMP/BOR/GCMRC work plan 

for 2010-11. We have also 

prepared and distributed a table 

showing how high priority 

recommendations have been 

incorporated into the 2010-11 

work plan.
8

(line 1297). 

Ge

ner

al

BOR Although the plan uses the word ―strategic‖ often, we do 

not think there is sufficient emphasis placed on a strategic 

approach to nonnative fish management. The implied 

strategy appears to be one of many lists of activities without 

any associated timeline, breakdown of subtasks, order of 

implementation, appropriate management agencies, etc. 

We encourage greater attention to species prioritization, 

risk assessment, source of threats, authority to address 

threats both inside and outside of Grand Canyon National 

Park, and temporal and spatial application of control 

mechanisms, including dam operations. As is too often the 

case with other aspects of nonnative control, the GCMRC 

section on dam operations provides a review and then 

delays new hypotheses, experiments, or management 

activities in lieu of ―a comprehensive review of native and 

nonnative life history.‖ There is insufficient recognition that 

managers sometimes have to make decisions and take 

actions with limited information, which reinforces the 

notion of assessing the risk of different actions early in the 

development of control mechanisms.

Respond Written We are currently working on a 

bioenergetic risk assessment 

which we think will be responsive 

to many of these comments. We 

do not intend to assign agency authorities to addressing threats; 

that would be beyond our 

authority. We will specifically 

mention the need of managers to 

act on the best available 

information. Please see 

Implementation Section.

4M

ulti

ple

BOR The SAs commented (page 6 of their review) that, 

―Specification of the overall problem or problems by 

GCMRC and TWG. What is to be accomplished by 

scientists, and managers, both in collaboration and, 

individually. What native (s) are most threatened, what age 

classes, where? What non-natives are the greatest threat, 

where?‖ 

We do not believe that the problem of nonnative fish has 

been adequately characterized in the revised plan. 

Considerable attention has been paid to distribution of 

nonnative fish (although much of it is relegated to the 

appendix) and their vulnerability capture, etc., but explicit 

comparisons of NNF distribution to that of native fish and 

occurrence in relation to physical habitat gradients in Grand 

Canyon (mainly temperature) have not been made. Like 

many other recommendations from the SAs, this risk 

assessment has been deferred, which effectively extends the 

planning period through 2010 or beyond. We share their 

concerns about the length of time it has taken to complete 

this plan.

Information 

on 

distribution 

and relative 

abundance 

of native 

and 

nonnative 

fishes, 

source 

populations

, etc. 

should be 

integrated 

to identify 

areas where 

native fish 

are most at 

risk to 

predation 

by 

Information on species distribution 

and composition is presented in 

new figures within the Review of 

Fish Captures in Grand Canyon.

Other information included in new 

figures includes land ownership, 

reach and HBC aggregation 

designations, and tributary streams 

of Grand Canyon.
9

(which?) 

nonnative 

species. 

Authors 

could 

consider a 

graphical 

approach 

similar to 

figure 11 of 

the revised 

risk 

assessment 

(Valdez 

and Speas 

2009).

1 23 Bill 

Persons

AZGFD We are concerned that a risk assessment and control 

methods are not more fully developed. 

Explain We are working on risk 

assessment now; development of 

this plan and conduct of the 2008 

HFE were deemed to be higher 

priorities and so they were 

completed first. 

1 24 Bill 

Persons

AZGFD Will the Valdez and Speas risk assessment be included in a 

later draft? 

Explain Yes We received this document 1 Sep. 

‘09. We‘ll review and include as 

appropriate.

37 29 1015

-

1019

LaGory WAPA The text here describing the risk assessment by Valdez and 

Speas may confuse a reader that does not recognize that that 

effort looked specifically at the risk of installing and 

operating a selective withdrawal system rather than the risk 

of various nonnative fish populations.

Modify Y We agree with importance of 

distinguishing the purpose of the 

Valdez and Speas 2008 

assessment. Text clarified in

Recommendations/Risk 

Assessment Section

7 20 659 BOR The SA‘s wrote on page 9 of their review that, ―The key in 

this assessment is to begin to focus on what would be 

considered to be your predator fish of highest risk and 

habitats of highest risk. Of these what fish and habitat areas 

create highest threat to HBC? We assume this objective 

process was followed to identify catfish as a target species.‖ 

Line 659 of the NNF plan says that catfish are ―generally 

agreed to be one of the nonnative fish species posing risk to 

native fish in Grand Canyon‖, but the criteria or process for 

this determination was not given. How much risk do 

catfish pose in relation to other nonnative fish species, 

including species occurring in the immediate watershed but 

Clarify 

process for 

determinin

g risk

As has been stated in a few 

previous forums, such as TWG 

meetings, channel catfish were 

deemed to be a risk because: 1. 

They are already present in the 

system 2. their numbers can be 

high around the LCR 3. they can 

be very fecund 4. they are known

voracious piscivores 5. we know 

that few, if any, of our current 

methods capture the species 

effectively. GCMRC and 

cooperating agencies have not 
10

haven‘t invaded the mainchannel yet? identified any other species posing 

greater risks with the exception of 

rainbow and brown trout. Relative 

risk from various species is being 

investigated with the developing 

risk assessment.

6 163 Bill 

Persons

AZGFD Question the statement that RBT ―is the fish thought to pose 

the greatest risk to humpback chub, and, as a result, it has

been the primary, though not sole, target of nonnative 

control efforts to date.‖ In the next sentence you state that a 

risk assessment has not been completed. As I recall a 

decision was made to use rainbow trout removal as an 

experimental treatment based primarily on 2 factors: 1) it 

was thought possible to control RBT with available 

electrofishing techniques and 2) there was a low risk of 

unintended consequences from removal activity compared 

to other actions such as a temperature control device or 

modifications to flow regimes. I had hoped this plan would 

devote more time to a risk assessment and complete 

consideration of warmwater nonnative risks to HBC.

Change 

language to 

explain 

uncertainty 

and low 

risk to 

other 

resources 

as reasons 

for 

mechanical 

removal 

experiment.

Yes While we agree that testing 

methods and low collateral risk 

were reasons to consider the 

experimental removal, certainly 

the nonnative fish were removed 

because it was anticipated there 

would be a benefit to native fishes. 

We can include the additional 

considerations in our discussion.

Risk assessment being developed.

Work by Yard et al. (in prep.; 

presented to TWG in ‘08) 

demonstrates that trout diets near 

LCR include native fish.

9 12, 

29, 

34

430, 

1015

, 

1265

,

The science advisors remarked at several points (page 14 of 

their review, in particular) that ―The authors might also 

benefit from interactions with authors who have conducted 

at least informal risk assessments of some of these species 

i.e., Valdez and Speas (2007).‖ 

We (BOR and consultants) interacted with the authors to 

some extent via attendance of the 2005, 2006, 2007 and 

2008 nonnative fish workshops. The draft risk assessment 

which became Valdez and Speas (2007) had been 

mentioned in the meeting notes from the 2006 and 2007 

workshops, but we were never contacted to assist with 

integration of the findings into the present work plan, and 

reference to the risk assessment in this revision is scant 

despite several SA comments to discuss the findings in 

more detail. Also, the authors say on line 1265 that the 

Valdez risk assessment is a justification for moving forward 

with a bioenergetics/ecosystem model, yet there is no 

summary of the risk assessment findings to base this on. 

We have received comments from GCMRC on the risk 

assessment in September of 2007, however, and have 

revised the document to address those comments. We can 

make it available to the NNF plan authors and are willing to 

assist in integrating elements of it into the final version of 

the plan.

Reference

risk 

assessment 

conclusions 

to support 

statements 

made at 

line 1265; 

Work with 

risk 

assessment 

authors to 

determine 

how much 

of it can be 

used in 

future 

planning or 

prioritizatio

n 

processes. 

We received the Valdez and Speas 

risk assessment 1 Sep. ‘09. We‘ll 

review and work with authors to 

include as appropriate and 

requested.
11

24 10 340 Capron WAPA The risk assessment map in the unpublished Valdez and 

Speas report (BOR) is a helpful way of showing the 

information in the table. Perhaps that work could be

completed or incorporated in this plan? In the GCMRC 

responses to the Science Advisors, this is rejected, but I 

agree with the SAs that it should be referenced as an 

unfinished document. It is much further along than the risk 

assessment GCMRC is working on.

Modify N We received the Valdez and Speas 

risk assessment 1 Sep. ‘09. We‘ll 

review and work with authors to 

include as appropriate and 

requested.

CONTROL/IMPLEMENTATION STRATEGY

5 M

ulti

ple

BOR The SA‘s wrote on page 8 of their review that, ―It is 

presumed AMWG directed a collaborative GCMRC/TWG 

approach to incorporate all ongoing and planned activities 

of both managers and scientists regarding non-native fishes, 

and selected native fishes. Yet, there is limited 

specification of management controls and discussion of the 

collaborative efforts with TWG and resource managers to 

define the needed controls. We are aware that managers 

and scientists are collaborating in the Non-Native Fish Ad 

Hoc Group and important recommendations and planning 

are formulated in the group. Also, very critical non-native 

control activities proposed by the Humpback Chub 

Comprehensive Plan Ad Hoc Group are considered in these 

discussions. However, these management/scientist 

discussions are not documented as potential management 

controls for implementation. Management planning and 

management controls are not made an explicit part of the 

plan in balance with science proposals.‖ 

We believe that the latter two items have not been 

adequately addressed in the revision. There is referenced to 

a series of ―three workshops‖ on line 1013 of the NNF plan, 

but proceedings from these workshops are not discussed or 

referenced herein; In the case of the proceedings from the 

2005 workshop and the initial draft outline for this plan, for 

instance, there was supposed to be included in the plan a 

―risk analysis. Initiate in 2006. AMP funded. Incorporate 

BOR study as appropriate. Deliver draft report early 2007‖; 

additionally, it also called for a ―policy review of nonnative 

control. AZGF conducts with GCMRC input as requested, 

reports back to AMP‖. If these assignments were 

completed, they should be included in this plan, as they 

Work with 

manageme

nt agencies 

to integrate 

their roles 

and 

responsibili

ties in 

implementa

tion of the 

plan.

We intend to revise plan by 

including an implementation 

section. However, we cannot 

assign tasks to other agencies as 

that is beyond our authority. We 

stand ready to work with other 

agencies to develop strategies to 

implement actions.

We believe it is important to 

recognize that we are not dealing 

with a static system. One standing 

recommendation is unlikely to be 

useful for all future applications. 

That is why we recommend an 

annual meeting to review current 

data. We have been remiss in not 

distributing more notes from the 

annual meetings to date but plan to 

do so in the future. We do not 

anticipate preparing full, published 

proceedings of these meetings as 

they are expected to be less formal 

working meetings.

We are not aware of any recent 

activity of the nonnative fish ad 

hoc group.
12

should form the basis for the strategy. 

Ge

ner

al

BOR We think, in retrospect, that the assignment given to 

GCMRC by the AMWG to develop a nonnative control 

plan should have enjoined the management agencies in the 

effort. We appreciate that GCMRC has been the leader in 

developing the science necessary to undertake adaptive 

management of Colorado River resources below Glen 

Canyon Dam. The GCDAMP has matured sufficiently and 

knowledge has increased to the point where the roles of the 

science institution and the management agencies need to be 

better integrated. The development and implementation of 

this nonnative fish plan is an excellent place for that 

integration to ensue. USGS is not a management agency, 

and it seems inappropriate for them independently to 

develop a management plan directed at fish and wildlife 

species. This shortcoming was previously recognized by the 

Science Advisors. In looking forward, we believe this 

shortcoming needs to be rectified by greater involvement of 

the management agencies in both planning and 

implementation of nonnative fish management. For 

example, the proposed workshops on nonnative fish 

management should be jointly developed by 

USGS/GCMRC and the management agencies. We include 

Reclamation in that group because of our environmental 

compliance responsibilities and as the agency that operates 

Glen Canyon Dam.

Respond Written If the AMP wishes to have an 

independent review of the 

activities needed to support 

nonnative control, one good way 

to prepare that is to assign it to 

GCMRC as was done by the 

AMWG. A multi-agency 

document is more likely to include 

a number of agency agendas, if it 

could be completed at all, given 

the contentious nature of this 

subject.

2 46-

49

Mult

iple

BOR The SA‘s wrote on page 3 of their comments that ―The plan 

lacks specific discussion of resource needs, especially 

budget needs. Information is necessary for transition of 

science application to management control actions, who is 

likely to complete control actions, external budget needs, 

and all contingency and anticipated new GCMRC research 

and monitoring needs.‖

We feel that this concern has not been addressed 

adequately. While it is true that cost estimation is difficult 

(page 49, NNF plan), it is apparent that there are some 

activities that will almost certainly happen (risk assessment, 

trout control, etc), and others that may happen (contingency 

funds, page 46, NNF plan). Placeholders for these tasks 

should be identified in an implementation timeline (again, a 

more robust strategy would aid in this) so that the needs can 

Work with 

manageme

nt agencies 

to develop 

an 

implementa

tion 

strategy 

that 

integrates 

monitoring, 

control and 

research 

priorities 

under each 

strategy 

Please see GCMRC response to 

BOR general comments above. 

Revisions of Cost Section 

incorporate information on 2010 

and 2011 fiscal planning. Also see

Implementation Section.
13

at least be identified in the planning phase, more accurate 

budget planning can take place. Roles and responsibilities 

of implementing management agencies need still to be 

identified. 

bullet (page 

7, NNF 

plan). 

3 44-

46

1720

-

1788

BOR The SAs wrote in their comments (page ―Inclusion of the 

contingency plan is an important element of the document. 

The SAs agree with GCMRC in its review request that this 

element needs more development. The approach needs 

leadership of management agencies and tribes to craft 

appropriate public relations, rapid response control, triage, 

and monitoring assessments.‖

We agree with the Science Advisors (TWG call, 7/22/09) 

that this element is still largely unchanged from earlier 

versions and should be revised to address SA concerns. 

Work with 

manageme

nt agencies 

to improve 

this section.

We agree with the SA comment 

regarding the need for leadership 

from management agencies. We 

have emphasized this discussion in 

the Implementation Section of this 

document. We anticipate 

management roles and 

responsibilities for implementation 

of nonnative control and rapid 

responses to be further refined 

during discussions at the annual 

nonnative fish workshops.

7 202 Bill 

Persons

AZGFD Overall Nonnative Fish Management Strategy section 

suggests that this plan is a strategic plan to develop control 

methods. It reads as a plan to develop a plan. I had hoped 

to have a control plan more fully developed at this stage of 

the project. Where do we go from here? 

Review and 

explain 

next steps 

in 

nonnative 

control.

Yes Development of a strategic plan to 

implement nonnative fish control 

requires definition of agency roles 

and responsibilities as well as 

definition of experimental versus 

control actions. These discussions 

have been initiated among 

management agencies and during 

AMWG meetings. We emphasize 

this need in the Implementation 

Section.

2 40 Bill 

Persons

AZGFD What process was followed in deciding relative importance 

of different monitoring strategies, control strategies, and 

research strategies? Criteria developed by the Upper Basin 

(technical feasibility; time to implement; cost; and 

effectiveness) and their process to prioritize projects seem 

to provide a good model. I believe that document (memo to 

Biology Committee) was distributed at the 2008 nonnative 

fish workshop.

Identify 

process 

used, or 

suggest 

options for 

use in 

future. 

Yes Within the Implementation 

section, we have suggested at least 

two methods for scientists and 

managers to prioritize 

recommendations within this 

document and others brought forth 

by participants in the annual 

nonnative fish workshops. We 

have included the memo cited here 

as an Appendix to this document.

6 191 Bill 

Persons

AZGFD The section on Integration of Science and Management is 

unclear and incomplete. Any nonnative control efforts need 

to be well integrated with other research and monitoring 

activities, and any management efforts that may fall outside 

of the AMP also should be closely coordinated with the 

AMP programs. 

Rewrite Yes Not sure what the reviewer intends 

here. Because we are the science 

provider to the AMP providing 

documentation of non-AMP 

activities is beyond our charge. 

We believe that the ongoing AMP 
14

work plan demonstrates what 

projects will be implemented in a 

given year, and so some sense of 

integration can be gained from 

reading that document. For 

example, nonnative removal from 

the LCR reach is planned for 

2010, as is monitoring of native 

fish in this reach, so if there is a 

response to removal we are 

positioned to capture those data.

4 na na Capron WAPA Scientific Approach. What generally seems missing from 

GCMRC science plans is a scientific approach to 

hypothesis testing. For example, this plan provides 

background information on nonnative catches, nonnative 

control efforts, and then talks about potential strategies. It 

may be beneficial for GCMRC to replace Coggins with a 

biometrician that would be available to construct science 

plans that are designed more around hypothesis testing and 

designing plans to answer these critical questions, illustrate 

how that will be done, and how information will be 

synthesized and what analytical techniques will be used to 

do that. This issue is more evident in the Fall Steady Flow 

science plan but is here as well.

Discussion 

needed

Y This is a plan for nonnative 

control, not an experimental plan, 

so the request for hypothesis 

testing does not seem appropriate. 

Further, we design few 

experiments (an exception would 

be the HFE; HFE Science Plan did 

include hypotheses). It is 

particularly difficult to describe 

and defend hypotheses when one 

does not design the experiment.

These broad comments that 

denigrate GCMRC work in 

general and critique other 

documents specifically don‘t 

contribute to refinement of the 

document in question, the 

nonnative plan.

5 na na LaGory WAPA The approach outlined in this plan is not sufficiently 

targeted or prioritized given the limited resources available. 

The plan does not describe a coherent monitoring and 

control strategy.

RewriteY Prioritization of recommendations 

clarified. Please see 

Implementation Section.

9 na na LaGory WAPA The ―Summary of Monitoring, Removal, Research, and 

other Management Strategies‖ section is a laundry list of 

activities. There is no prioritization, no sequencing, and 

considerable overlap. For example, would you really do 

sonic telemetry and remote PIT tag detection at the mouth 

of the Little Colorado River to determine nonnative and 

native fish movements? Both are listed as 

recommendations.

RewriteY Prioritization of recommendations 

clarified. Please see 

Implementation Section. Remote 

Pit tag technology can be used to 

compare large scale movement patterns and Sonic technology can 

be used to compare habitat overlap 

of known size classes of fish.

Please see revised 

Recommendations/ Remote PIT 

tag and Sonic Telemetry Sections.
15

10 na na LaGory WAPA The ―Nonnative Fish Removal Recommendations‖ section 

should describe the overall strategy including priorities, 

sequence of activities, the level of effort, and adaptive 

nature of the program.

Rewrite Y Implementation recommendations 

clarified. Please see 

Implementation Section. The 

adaptive nature of implementing 

nonnative fish control is 

exemplified in the 

recommendation for annual 

workshops and in the revised 

Contingency Section.

56 48 1863 Capron WAPA It would be helpful to have a prioritized list of activities 

here. For example, the development of a bioenergetics 

model to estimate the potential population level impacts of 

the trout removal project on HBC should be a high priority. 

This isn‘t evident here with this list of seemingly unprioritized recommendations. The GCMRC responses to the 

SA comments was that this was prioritized, but that is 

unclear to the reader.

Modify/clar

ify

Y Prioritization of recommendations 

clarified. Please see 

Implementation and revised 

Recommendations Sections.

30 1082 Bill 

Persons

AZGFD Recommendation to start monitoring program in tributaries 

needs to be further considered following a more complete 

literature review and review of the GCMRC fish database. 

How was this priority arrived at? How does it fit in with 

the rest of the AMP?

Yes Monitoring in tributaries is 

recommended to track sources of 

nonnative fish into Grand Canyon 

which may negatively impact 

HBC. Control of new invaders 

entering through the tributaries is 

potentially more effective than 

trying to control them once they 

reach the mainstem. 

Recommendation will be further 

considered in future discussions 

with GCDAMP scientists and 

managers. Text clarified in 

Recommendation/Fish Monitoring 

in GC Tribs section.

34 1250 Bill 

Persons

AZGFD

What criteria were used to recommend renovation of 

tributaries over other projects?

Explain 

prioritizatio

n process, 

or develop 

one to be 

used in the 

future.

Yes Stream renovation is a tool that 

has demonstrated success in 

removing nonnative species and 

sources of nonnative fish in many 

areas, including within National 

Parks. The risk of stream 

renovations unintentionally 

harming native fish should be fully 

assessed. Please see 

Recommendations for 

prioritization process used and 

Implementation Section for 
16

suggested methods of 

prioritization.

UPPER BASIN NNF CONTROL SUMMARY

2 na na Capron WAPA Nonnative control efforts in the upper basin. The plan 

should include a more comprehensive review of the 

nonnative control efforts from the upper basin, including 

lessons learned, methods used (as described in the Science 

Advisor comment). For example, one lesson learned from 

the upper basin is that programs must move quickly to 

suppress invasive species in order to have success in 

controlling them. This supports an argument for the 

contingency fund, however this concept is not very well 

understood without a discussion of the efforts in the upper 

basin.

Add 

discussion

Y This document is not intended to 

be a comprehensive review of any 

other nonnative fish control 

program. We realize that each 

program has species and habitat 

distinctions different from that of 

Grand Canyon. We have cited 

several projects and approaches 

within this document that we 

believe can be applied to Grand 

Canyon. If there are specific 

projects we fail to reference, 

please provide specific references.

Please see comment below.

8 6 158 BOR Also on page 9 of the SA review, they state ―This document 

could be strengthened by acknowledging nonnative fish 

control problems and control efforts in the upper basin, 

where fish control has progressed from strategic planning to 

site specific actions. It would help the rewrite of this 

document to evaluate a process that has already occurred in 

the basin with the same fish species. 

The first strategy in the upper basin was to identify the 

major nonnative fish issues and problems, and then 

consider management controls, science strategies, potential 

problems and conflicts in each area, and resolution in each 

instance. Also, all known and potential non-native predator 

fishes were evaluated for how they might threaten the 

existence of each native fish, to identify high priority areas 

for implementing control areas, etc (Tyus and Saunders, 

1996).‖ This recommendation has not been addressed. 

References to nonnative control strategies and their relative 

levels of success in areas outside of the Grand Canyon are 

few, and references to programmatic processes for 

development of strategies are not included. 

The authors 

needn‘t 

expand the 

scope of 

the 

document 

to provide a 

rigorous 

review but 

rather 

provide a 

summary to 

address the 

concerns 

identified 

by the SA‘s 

(overall 

program 

effectivene

ss, 

obstacles, 

etc. and 

how that 

might 

affect 

efforts in 

Summary of the over all approach 

to nonnative fish control with 

examples from the Upper Basin 

included in the Implementation 

Section. Major nonnative fish 

issues in GC are identified and we 

make recommendations to pursue 

control, improve monitoring and 

specific research recommendations 

to address the issues identified. 

While GCMRC completes the risk 

assessment, this information is the 

best available upon which to move 

forward with nonnative fish 

control in Grand Canyon. Please 

see Implementation and revised 

Recommendations Sections.
17

GC).

6 na na LaGory WAPA The report does not draw sufficiently on experience in 

nonnative fish monitoring and control in the Upper 

Colorado River Basin. That program has an existing 

monitoring program in place, has extensive annual control 

efforts, and has studies to examine the response of native 

fish species to nonnative fish controls.

Rewrite Y We are communicating with the 

Upper Basin Program to gain 

additional insights from their 

efforts, though we have been 

doing this to date. Based on our 

interactions to date we believe that 

program has only recently 

implemented studies to evaluate 

the effectiveness of nonnative 

removal.

14 2 59 Capron WAPA This approach was attempted in the upper basin, Johnson et. 

al. (2008) looking at smallmouth bass, channel catfish and 

other predators on native fish. But Johnson et. al. (2008) is 

not cited in this document. A broader look at efforts in other 

regions is necessary.

Modify text N Manuscript has been reviewed and 

included in revised Research 

Recs/Risk Assessment Section.

19 6 165 Capron WAPA You should cite Johnson et. al. (2008) bioenergetics paper 

from the upper basin as a possible approach, are there 

others out there?

Modify N Manuscript has been reviewed and 

included in revised Research 

Recs/Risk Assessment Section.

44 34 1260 Capron WAPA Should cite Johnson et.al. (2008), bioenergetics paper from 

upper basin.

Edit N Manuscript has been reviewed and 

included in Research Rec/Risk 

Assessment Section.

20 7 201 Capron WAPA The upper basin nonnative control efforts were not cited in 

this section, and it is noticeably lacking. We agree with the 

Science Advisors comment that further discussion, and 

reflection, from the upper basin is needed in this document.

Modify N Please see GCMRC response to 

LaGory comment # 6 above.

40 30 1056

-

1067

LaGory WAPA This discussion of monitoring efficacy of various gear types 

should reference and draw on the experience gained in the 

Upper Basin.

Modify Y We have learned much from the 

Upper Basin and many other 

programs, however, we focus 

discussions in this document on 

gears and methods most 

appropriate for safe and effective 

application to Grand Canyon.

MECHANICAL REMOVAL

17 3 101 Capron WAPA This section should be completely rewritten. First, based on 

the current removal data, and some estimates of 

immigration, it could easily take 4 trips per year (similar to 

effort in  ̳03/04) to result in abundance estimates of 600-800 

trout in the LCR reach. Second, the cost estimate here for 

what would go into the contingency fund makes no sense as 

this money is going to be used each year to fund the trips, 

thus no money will be built up. In years that the AMP does 

Modify Y We will revise this section to 

describe the relationship between 

number of removal trips, 

suspected immigration rates, and 

modeled trout abundance to assist 

with determining the level of 

effort required to achieve trout 

control goals. Please see revised 
18

not implement removals it would make sense to build up a 

fund. If the program concludes that nonnative fish 

abundances are a concern, then the AMP should consider a 

funding approach similar to the experimental fund in which 

substantial funds are set aside each year.

Recommendations/Mechanical 

Removal Section and table within.

18 6 163 Capron WAPA Is there a citation for this statement? What is this based on? 

Yard unpublished results? Have we integrated the predation 

rates with abundance estimates and had this integrated with 

the ASMR model to evaluate what level of population level 

impacts that we might expect? Or are there compensatory 

mechanisms which might ameliorate any removal 

activities? Elaborate on whatever efforts may be underway 

with Dr. Carl Walters using bioenergetics modeling.

Modify Y Yard and others, in prep cited 

within statement.

29 17 548 LaGory WAPA This section on ―Mechanical Removal‖ seems out of place 

in a section on sampling.

Modify Y Headings changed to clarify 

section content. Please see revised 

Review of Fish Projects in GC. 

30 17 569-

576

Capron WAPA This paragraph is technically correct but may be misleading 

to the casual reader. It is true that electrofishing is probably 

an effective removal method. However, that doesn‘t mean 

the activity is effective at either reducing abundance over 

the long term (multiple years) or at having a population 

level impact on the HBC population. Immigration rates may 

be high enough to overcome substantial removal efforts 

over a relatively short time scale, especially if recent yearclass strength is high as it has been in Lees Ferry recently –

this could result in more emigration from the Lees Ferry 

reach. These issues are discussed somewhat in the next 

paragraph but additional language is needed here to clarify 

this for the reader.

Modify N Agree with need for clarification

of  ̳effective‘ removal techniques. 

Text added to Review of Fish 

Projects/Mechanical Removal 

Section.

49 46 1807 Capron WAPA My analyses of the available data doesn‘t agree with these 

statements that only two trips are needed per year to 

maintain 10-20% of January 2003 levels. I don‘t think this 

is consistent with Makinster‘s presentation at the AMWG 

either.

Modify Y Please see GCMRC response to 

Capron comment # 17 above.

50 47 1844 Capron WAPA You should state the actual abundance value, 20% of 

January 2003 is 1290 trout in the removal reach to be 

reduced to 645 fish to reach the 10% threshold.

Modify Y Actual abundance levels inserted 

in Nonnative Fish Removal 

Recommendations and 

Responding to Perceived 

Nonnative Threats Sections.

6 163 Bill 

Persons

AZGFD Question the statement that RBT ―is the fish thought to pose 

the greatest risk to humpback chub, and, as a result, it has 

been the primary, though not sole, target of nonnative 

control efforts to date.‖ In the next sentence you state that a 

risk assessment has not been completed. As I recall a 

Change 

language to 

explain 

uncertainty 

and low 

Yes Decision criteria cited by reviewer 

added to Review of Fish Projects/ 

Mechanical Removal Section
19

decision was made to use rainbow trout removal as an 

experimental treatment based primarily on 2 factors: 1) it 

was thought possible to control RBT with available 

electrofishing techniques and 2) there was a low risk of 

unintended consequences from removal activity compared 

to other actions such as a temperature control device or 

modifications to flow regimes. I had hoped this plan would 

devote more time to a risk assessment and complete 

consideration of warmwater nonnative risks to HBC.

risk to 

other 

resources 

as reasons 

for 

mechanical 

removal 

experiment.

COSTS

49 Bill 

Persons

AZGFD Cost estimates section is inadequate. Revise Please see comment below as well 

as Implementation and revised 

Cost Estimates Sections.

11 na na LaGory WAPA The ―Cost Estimates‖ section describes the high cost of 

implementing programs in the Grand Canyon. As this 

section closes the report and follows immediately after a 

long list of obviously very expensive programs, it calls into 

question the recommendations made in the report.

Rewrite Y Cost estimates for monitoring and 

research components GCMRC 

will be implementing in 2010 and 

2011 have been included in the 

Table within the Cost Estimates 

Section. Costs for control projects 

will be more accurately developed 

as agency roles and 

responsibilities are defined in the 

near future.

TARGETS

3 na na Capron WAPA Rationale for 90% reduction in nonnative species. 

Melissa Trammel provided some background to GCMRC 

on this issue from a March 7, 2005 memo. At the Upper 

Colorado River Basin Recovery Program Nonnative Fish 

Removal Workshop held in December 2004, Gordon 

Mueller stated that a 90% reduction in nonnative fish 

abundance is necessary to induce a positive population 

response by native fishes. The workshop was followed by a 

Biology Committee (upper basin) meeting where achieving 

target densities of nonnative fishes was discussed as a 

possible criterion for successful nonnative removal efforts. 

On request, Gordon Mueller provided several citations to 

support his suggested target of a 90% reduction. Melissa 

Trammel summarized those six citations in her memo. Yet, 

none of this information is used in this document with 

regard to the proposal of the 90% reduction target for trout 

in the LCR reach. What is GCMRC‘s scientific rationale for 

proposing the 90% reduction target? I don‘t disagree that it 

Add 

discussion

Y Thank you for providing this 

information. Excerpts from these 

manuscripts have been included in 

the Recommendations/Mechanical 

Removal Section. GCMRC will 

continue to evaluate removal 

targets.
20

is reasonable, but further work is necessary to support that 

proposal. (2005 memo is attached to this comment)

13 2 44 Capron WAPA This is the first place that a target for trout removals have 

come up in an official AMP document. This should be a 

well reasoned proposal that AMWG can adopt. What is the 

process for approving this with FWS, informal 

consultation? Is this an annual target, as measured every 

few years? There needs to be a recognition that abundance 

fluctuates around these targets, and consideration of the 

general issues described above in comment #3.

Modify text 

to form a 

cohesive 

argument 

for targets

Y We will try to address comment in 

our revisions to specify the levels 

of effort required to achieve 

various levels of certainty. The 

level of certainty required by 

managers to initiate control efforts 

is not clear and should be 

discussed during the annual 

nonnative fish workshops. We will 

recommend conducting annual 

trout abundance monitoring in the 

LCR reach.

16 3 89 Capron WAPA This plan suggests establishing triggers for nonnative fish 

control. This should be followed up with a clear 

management discussion for AMWG consideration. This 

document poses the question, but further discussion is 

needed at TWG/AMWG. What process does GCMRC 

envision for this discussion?

N In this document we suggest that

the process for evaluating triggers

to initiating nonnative control 

should involve discussions among 

scientists and managers during the 

annual nonnative fish workshop. 

Here, scientists will present their 

most recent findings related to 

nonnative fish monitoring and 

research. This information should 

form the basis of discussions 

regarding whether or not to initiate 

nonnative control actions.

43 31 1094

-

1136

Capron WAPA This section doesn‘t help the program move forward, it 

merely reiterates our question again, how do we set goals 

for nonnative removal?

N Goals for nonnative removal 

should be based on our evaluation 

of the potential benefits to native 

fish. Goals for nonnative fish 

management will also require 

coordination of management 

agencies and their respective 

management objectives. Goals for 

nonnative fish management will be 

refined at annual nonnative fish 

workshops. Please see 

Implementation Section for 

clarification.

SPECIFIC COMMENTS
21

10 16 516-

528

BOR In these sections you say that electrofishing may be 

adequate for smallmouth bass and walleye because of their 

vulnerability to the method, citing unpublished AG&F data. 

But earlier you state that capture probability for the two 

species are unknown. 

Clarify. Text clarified to exemplify the 

unknown efficiency of capturing 

species that occur in Grand 

Canyon in low abundance. Please 

see revised Review of Fish 

Projects/Mainstem Sampling

11 33 1214 BOR I believe the the primary gear type used in Elverud (2008) 

was electrofishing, not angling

Check/cor

rect

Report reviewed and statement 

amended appropriately.

6 10, 

58-

71

Tabl

e 1, 

App

endi

x A

The SAs recommended on page 9 of their review that ―In 

this document Table 1 lists "dominant" nonnative predator 

fish by reach. Thirteen potential nonnative predator fish 

have been identified in the CRE, but all are not addressed 

here. Only 7 are presented in Appendix A. Projected future 

changes in water temperatures or flows in Grand Canyon 

might allow one or several of these other non-natives to 

proliferate rapidly.‖ There are still only 7 descriptions in 

Appendix A; see also comment 4, above.

We recognize that a long list of 

species are potentially of concern 

but don‘t believe that means every 

conceivable species needs to be 

included in the appendix. The 

material in the appendix is 

relatively easy to obtain from the 

scientific literature.

15 3 81 Capron WAPA Change ―list‖ to ―listed‖ edit N Edited

21 7 208-

231

LaGory WAPA There is a fair amount of redundancy in this list (e.g., 

bullets 2 and 4). Eliminate bullet 8.

Modify N Bullet 2 addresses prevention of 

fish from invading GC. Bullet 4 

addresses detecting fish that DO 

invade GC. Bullet 8 not 

eliminated. With this bullet, we 

are stressing the importance of 

maintaining monitoring programs 

to evaluate the effectiveness of 

control programs. Please see 

Implementation Section.

25 12 428 Capron WAPA A Korman et. al. final report to GCMRC is cited here, are 

these available to TWG/AMWG? Perhaps a better citation 

is the Korman et. al. 2005 paper?

Modify as 

appropriate

Y Citation maintained as final report 

to GCMRC to cite specific 

statement.

26 13 LaGory WAPA The text of ―Review of Recent Fish Sampling Activities in 

Grand Canyon‖ does not map closely with the summary 

Table 2. Some activities are included, but some are not. 

Also, the discussion of removal efforts in this section seems 

odd since the topic is sampling.

Modify Y Section headings changed to better 

reflect content. Table and text 

updated to address comment. See 

revised Review of Recent Fish 

Projects Section

27 15 469 LaGory WAPA Table 2 shows this effort as occurring twice annually, but 

the text describes an annual effort.

Modify Y Table and text updated

28 15 473-

474

Capron WAPA This information is somewhat dated, should be brought up 

to date with recent trips, through 2009?

Modify N Information updated. See Review 

of Fish Projects/Mainstem 

Electrofishing.
22

31 18 585 Capron WAPA The word ―protocol‖ is used twice. Edit N Word removed

32 19 595 Capron WAPA Update through 2009. Edit N Figures intended to demonstrate 

trout abundance declines and 

temperatures concurrent with 

mechanical removal. For updated 

catch rate information, please see 

2007 and 2008 mainstem 

monitoring annual report. For 

Updated temperature information, 

please contact Bill Vernieu, 

GCMRC.

33 19 613 Capron WAPA Hunt is not in the literature cited section, I‘m not sure what 

2008 is, Theresa‘s draft thesis?

Edit N Completed Hunt thesis cited.

34 26 869 Capron WAPA This unit is installed already right? update. Edit N Updated. See revised Other Fish 

Projects/Remote PIT Tag 

Detectors Section.

35 27 940-

941

LaGory WAPA The statement that ―Monitoring activities should initially be 

conducted in proximity to humpback chub aggregations and 

tributary inflows‖ seems particularly important, but is 

buried in this section and does not even appear in the 

summary of recommendations.

Modify Y Statement emphasized. See revised 

Recommendation Section.

36 28 969-

970

LaGory WAPA The statement ―electrofishing to reduce mainstem trout 

abundance and potentially smallmouth bass due to their 

susceptibility to this method‖ contradicts earlier and later 

statements regarding the lack of susceptibility of 

smallmouth bass.

Modify Y Efficiency and susceptibility 

clarified. See Summary of Fish 

Projects and Review of Fish 

Projects.

39 29 1040 Capron WAPA The term ―jeopardy‖ should not be used here. First, the 

recent biop was ―no-jeopardy‖, and second it is an ESA 

term of art. ―status‖ might be a better term.

Edit N Word removed.

41 30 1089

-

1090

LaGory WAPA Why is a ―centralized and accessible database‖ only 

recommended for this topic? It seems appropriate for all of 

the nonnative fish work.

Modify Y A centralized database is already 

in place for mainstem and Little 

Colorado River sampling data. 

Sentence clarified; please see 

revised Fish Monitoring in Grand 

Canyon Tribs.

42 30 1091 LaGory WAPA Although a monitoring program is recommended here, the 

approach to be used is not mentioned.

Modify Y Development of monitoring 

protocols will be discussed among 

participants of the annual 

nonnative fish workshops as 

priorities and implementation 

strategies become more clearly 

defined.
23

46 35 1315 LaGory WAPA ―Identification of continued and new sources of nonnative 

fish into Grand Canyon‖ is recommended, but how that 

would be done is not described. Why are ―tributary and 

watershed inputs‖ mentioned here but not described? Only 

dam passage is described and yet this seems to be a much 

less important, even negligible, source of nonnative fish to 

the river.

Modify Y See comment above. Tributary 

inputs have been described in the 

text and in a new figure. Please 

see revised Research Recommend/ 

Source Identification Section.

47 37 1370

-

1390

LaGory WAPA This section on remote PIT tag detectors is very general. 

What species would be targeted? Would this only work for 

large fish?

Modify Y Text inserted to clarify size class 

and species that could be targeted, 

to include channel catfish, 

common carp, and bullhead spps. 

51 47 1849 LaGory WAPA ―Expansion‖ of the mainstem monitoring program is not 

mentioned in the recommendations on page 30, yet it 

appears in the summary of recommendations here. What is 

the recommended expansion--more frequent monitoring or 

more coverage?

Modify Y The term  ̳expansion‘ inserted into 

text for clarification. Please see 

revised Monitoring 

Recommendations/ Mainstem 

Monitoring Section.

52 47 1851 LaGory WAPA Which tributary and confluence areas should be monitored 

long-term?

Modify Y Information added. Please see 

Review of Fish Projects/ Trib 

Sampling, and Monitoring Recom/ 

Fish Monitoring in GC Tribs

Sections.

53 47 1854 Capron WAPA Update, this event occurred, listed here as ―scheduled‖ Edit N  ̳Scheduled for 2009‘ removed 

from text.

54 47 1861 LaGory WAPA Are you recommending implementing chemical renovation 

and barrier construction or just a feasibility study?

Modify Y The literature indicates that it is 

feasible to implement stream 

renovation and barrier 

construction to control nonnative 

fish. We are recommending this 

tool be evaluated for use in 

meeting the program‘s nonnative 

fish management objectives.

55 48 1864 Capron WAPA Maybe identify the Johnson et al. 2008 paper here as an 

example?

Edit N Johnson and others 2008 

appropriately cited in revised 

Research Recommendations/ Risk 

Assessment Section.

57 48 1871

-

1872

LaGory WAPA What is the purpose of this ―research‖ project—determine 

habitat use, distribution, abundance, age-structure?

Modify Y Purpose developed in body of 

document. Please see revised 

Research Recommendations/ 

Small-Bodied and YoY Nonnative 

Species Section.

58 48 1873

-

1878

LaGory WAPA The PIT tag and sonic telemetry studies seem duplicative. 

What is the purpose of these studies and why would you do 

both? Are you recommending feasibility studies or 

implementation?

Modify Y Purpose developed in body of 

document. Please see revised 

Research Recommendations/ 

Remote PIT tag Detection and 
24

Sonic Telemetry. We are currently 

implementing a remote PIT tag 

project and researching the 

feasibility of using sonic telemetry 

(Nearshore Ecol)

59 48 1881

-

1883

LaGory WAPA What would the flow and temperature manipulations be 

based on? Are experiments planned?

Modify Y Basis developed in body of 

document. Please see revised 

Research Recommendations/ 

Targeted Manipulation of Dam 

Releases. No experiments are 

planned.

60 48 1884 LaGory WAPA The Williams Carp Cage does not sound practical based on 

the description on page 41 and 42.

Clarify Y Practicality of novel methods will 

be discussed among scientists and 

managers during annual nonnative 

fish workshops. Input from 

interested parties is encouraged.

1 13 Bill 

Persons

AZGFD Change ―promote the Lees Ferry trout fishery‖ to ―maintain

a naturally reproducing population of rainbow trout above 

the Paria River, to the extent practicable and consistent with 

the maintenance of viable populations of native fish.

Revise Yes Change made.

6 185 Bill 

Persons

AZGFD Does ―(supported with modeling)‖ refer to determining the 

presence of new invasive species? Unclear

Clarify Yes Terms removed.

10 346 Bill 

Persons

AZGFD Table 1. Descriptions of dominant nonnative species do not 

look correct. For example, I believe the reach from RM 

56.1-68.6 is dominated by rainbow trout, not carp. The 

column of other nonnative species captured is incomplete. 

Revise Yes Table removed and new figures 

revised to reflect most recent 

monitoring data.

11 363 Bill 

Persons

AZGFD ―Little is known about the importance of tributary streams 

to native and nonnative fish in the mainstem in relation to 

source and sink population dynamics‖. Unclear. Why  ̳in 

relation to source and sink population dynamics‘. Much is 

known of use of tributary streams by natives and nonnatives 

(see esp. Maddux and others 1987), and much can be 

inferred about sources of nonnatives from those tributaries 

based on close to 20 years of mainstem Colorado River 

sampling..

Revise Yes Source/sink changed to indicate 

the unknown importance of 

tributaries to fish spawning and 

recruitment. Many fish species 

have been captured in tributaries;

however, their importance for 

spawning and recruitment of these 

species is not clear. Please see 

revised Review of Nonnative Fish 

captures in GC. Maddux and 

others included in text. 

11 368 Bill 

Persons

AZGFD Proofread and spell check paragraph. Errors edited.

11 381 Bill 

Persons

AZGFD Title of section seems redundant with page 8 line 245 Section titles revised. See Native 

Fish Protection and the GCDAMP 

and Review of GCDAMP NNF 

Control efforts in GC.
25

12 425 Bill 

Persons

AZGFD ―inconclusive results‖ Results were that baited 1-m 

diameter large mesh hoop nets captured larger sizes of 

catfish than other methods. Can you cite this as a 

presentation to the TWG or do you need a reviewed 

document? 

Revise Yes In discussing this project with the 

authors of the TWG presentation, 

the authors suggested that the 

results were interesting but 

warranted further study due to a 

small sample size. If other 

information is available, we would 

insert it into this section as 

appropriate.

14 Bill 

Persons

AZGFD Mainstem electrofishing – I would suggest ―target‖ species 

are native and nonnative fish vulnerable to boat 

electrofishing. The target species you list are the species 

most commonly encountered, which may not be the same 

thing. We target the entire fish community that is 

vulnerable to the gear we are using. That could include 

species such as smallmouth and largemouth bass if they 

become more common.

Revise Yes We agree with the need for 

clarifying target species for 

monitoring. Text revised as 

suggested. See Review of Fish 

Projects/Mainstem Electrofishing 

and Little Colorado River

23 747 Bill 

Persons

AZGFD Target species for lower 1200 m nets are native and 

nonnative fishes rather than humpback chub, again we 

sample the entire fish community, and are not targeting one 

species.

Revise Yes Agree, see comment above.

15 458 Bill 

Persons

AZGFD ―Two parameters can be used to evaluate the effectiveness 

of current nonnative fish monitoring

efforts and monitoring gears as removal methodologies: the 

coefficient of variation (CV) and the capture probability.‖ 

I think cost and time are also important parameters to 

evaluate effectiveness of monitoring efforts. That said, I‘m 

not sure if this paragraph even belongs here in the 

document.

Revise Yes Use of CV and capture probability 

is clarified for the context of 

evaluating program effectiveness. 

See revised Review of Fish 

Sampling/ Mainstem Monitoring

and Implementation Section.

15 482-

484

Bill 

Persons

AZGFD ―intensive sampling...exemplifies effort necessary to detect 

localized annual trends‖ is unclear. Were local trends 

estimated with  ̳intensive sampling‘?

Clarify Yes Term  ̳intensive‘ was specifically 

used in the report from which 

information was cited. Term 

edited to clarify  ̳increased effort‘ 

required. Please see revised 

Review of Fish Projects/ 

Mainstem Electrofishing.

19 595 Bill 

Persons

AZGFD Figure 2 does not match figure title. Revise Yes Figure formatting corrected.

22 734 Bill 

Persons

AZGFD Oral commun. 2007. Are you not able to cite our annual 

reports?

Yes Oral commun moved to reflect 

portion of text not included in 

annual report. Please see revised 

Review of Fish Projects/ Little 

Colorado River.
26

24 786-

788

Bill 

Persons

AZGFD ―This suggests that the brown trout composition may have 

been reduced by removal of brown trout during periodic 

operation of the weir in combination with backpack 

electrofishing.‖ The statement is a stretch, and change in 

percent composition of the catch does not support the 

statement. Were there changes in catch rates that might be 

used to support this?

Revise Yes Catch rate information for the 

initial phase of this project has 

been requested, however, we have 

not received it.

24 810 Bill 

Persons

AZGFD Delete  ̳potential‘ source of brown trout, BA Creek is a 

clear source of brown trout.

Revise Yes Term deleted.

25 836 Bill 

Persons

AZGFD Recommendation to continue studying effficacy of 

backpack electrofishing in Shinumo creek does not consider

recent translocation of humpback chub into the creek. 

Seems to me that efforts in Shinumo might be better 

directed at other methods, esp. in light of recent data 

(angling > shocking).

Revise Yes Section updated to reflect HBC 

translocation. Please see revised 

Review of Fish Projects/ Shinumo 

Creek.

28 978 Bill 

Persons

AZGFD

What 

novel strategies are proposed? Suggest delete.

Revise Yes Sentence revised. Please see 

revised Summary of Fish Projects

31 1132 Bill 

Persons

AZGFD 10 percent should read 10 to 20 percent (see line 1122). Revise Yes Revised

31 1133 Bill 

Persons

AZGFD ―There is the potential that mechanical removal above the 

Little Colorado River reach of the Colorado River could 

achieve this target abundance‖. 

I would remove this statement until after further discussion 

and consideration. Think it is premature at this point.

Revise Yes Statement revised to reflect 

GCDAMP consideration of tribal 

concerns. Please see revised 

Nonnative Fish Removal 

Recommendations/Mechanical 

Removal

31 1138 Bill 

Persons

AZGFD Can you provide citations for the ―many researchers that 

recommended nonnative fish reduction in three Grand 

Canyon tributaries‖?

Provide 

citations

Yes Sentence revised. Please see 

revised Nonnative Fish Removal 

Recommendations/ Nonnative 

Fish Removal in Tribs

32 1170 Bill 

Persons

What is the suggestion that backpack electrofishing in 

Shinumo creek to remove rainbow trout be continued based 

on? Benefit to native fish in the mainstem? Does it 

consider time and cost of these operations? Periodic 

electrofishing in Shinumo creek to reduce contribution of 

rainbow trout to the mainstem will not be expected to have 

a substantial population level effect on rainbow trout in the 

mainstem. Please don‘t ―sell‖ the project as such. Shinumo 

seems like an excellent candidate for chemical renovation if 

desired by NPS because it has a natural barrier in place. 

Revise Yes Section revised to emphasize 

acknowledged unknown 

contributions of RBT to the 

mainstem, and recommendation 

for the use of a combination of 

several gears. Please see revised 

Nonnative Fish Removal Recom/ 

Shinumo Creek and Chemical 

Renovation and Barrier 

Construction Sections.

33 1225 Bill 

Persons

AZGFD I don‘t disagree with the statement that chemical 

renovations have benefited T&E species. There is a wealth 

of literature available. Can you offer a more complete 

coverage of the topic with citations?

Yes Other citations included in 

coverage of topic. Please see

revised Nonnative Fish Removal 

Recommendations/ Chemical 
27

Renovation and Barrier 

Construction Section.

33 1226 Bill 

Persons

AZGFD Change ―can be combined with a physical barrier‖ to 

―MUST BE‖ combined with a physical barrier (see 

previous comment about literature review of barriers and 

renovations for native fish repatriations) 

Revise Yes Term edited.

36 1353 Bill 

Persons

AZGFD Occupancy modeling may be a useful method to analyze 

data, especially for presence/absence of rare nonnative 

species. I don‘t believe the ASMR is an example of 

occupancy modeling as stated. Can you provide some other 

citations for occupancy modeling approach?

Revise Yes Occupancy modeling description 

revised. Please see Research 

Recommendation/ Occupancy 

Modeling for Improving 

Nonnative Fish Monitoring and 

Detection.

36 1364 Bill 

Persons

AZGFD The statement ―Implementing a long-term monitoring 

protocol to detect changes in nonnative fish abundance and 

distribution using the occupancy framework is 

recommended‖ seems premature. 

There are a lot of recommendations in this plan. The 

authors should pare them down to a workable set, with an 

explanation of how and why priorities were established.

Statement revised to indicate 

importance of evaluating the 

potential utility of an occupancy 

model. Please see revised 

Research Recom/ Occupancy 

Modeling for Improving 

Nonnative Fish Monitoring and 

Detection

TWG COMMENTS FROM JANUARY 5, 2010

Larry 

Stevens

Wildlands 

Council

Use of lab studies to infer ecological processes is very 

questionable

Need to explore innovative fish capture techniques

Risk assessment is a priority

Please see Experimental Stream 

Study Section: Although 

laboratory settings do not exactly 

emulate field conditions, test 

results can be useful in evaluating 

these mechanisms and devising 

management strategies to limit 

potentially negative interactions.

Agree with need to explore 

innovative fish capture techniques. 

We anticipate that new techniques 

will be brought forth and 

evaluated during the nonnative 

fish workshops. Please see 

Research Recommendations

Agree that risk assessment is a 

priority. Please see Risk 

Assessment section, note that this 

item is listed as top priority.
28

Bill Davis EcoPlan 

and Assoc.

Need to determine which life stages of native fish are most 

vulnerable as part of risk assessment. Role of small bodied 

and predatory nonnative fish must also be developed.

Within the ecopath model 

construct, FHM, four length 

categories of HBC, and two length 

categories of other native fish are 

identified as individual stanzas. 

Once the model is fully developed, 

scientists will evaluate the impact 

of simulated invasions of 

predatory nonnatives, both small 

and large bodied. This is 

preliminary information that will 

not be included in the nonnative 

fish document but will be 

developed in the risk assessment.

Norm 

Henderson

NPS Need risk assessment before plan is finalized

Is this document a management plan?

Agree, the development of a risk 

assessment is a top priority for 

GCMRC once this nonnative fish 

document is finalized. 

Development of a risk assessment 

will take time. During the 

upcoming nonnative fish 

workshop, scientists wish to repeat 

the poll developed by the 

Nonnative Ad hoc committee in 

2003 to assist in the identification 

of the species thought to pose the 

greatest risk by scientists and 

managers. This would provide a 

starting point while a more 

scientifically rigorous approach is 

developed.

After discussions DOI and TWG 

have had, this document has been 

modified to represent the technical 

foundation upon which 

management agencies will develop 

a nonnative fish management plan 

(in the strictest sense of the word) 

for Grand Canyon. 

Dave 

Garrett

Science 

Advisor

Nonnative fish workshop is critical in allowing annual 

amendments to the approach taken with nonnative fish 

management. Consider scheduling workshop after April 

Ecopath workshop.

Agree with the importance of 

nonnative fish workshop. 

Scheduling of the workshop 

should be early in the year to 

allow for immediate review of 

annual monitoring data and 
29

development of annual workplans. 

Delaying the meeting this year 

will reduce the availability of 

scientists who will have already 

begun the field season.

Bill Werner Is this plan responsive to AMWG motion? Text added, Please see Preface

Bill Davis EcoPlan 

and Assoc.

Document should articulate how to approach issues 

presented in the document that fall outside the 

responsibility AMP like the contingency fund.

Should evaluate the cost effectiveness of control methods.

Agree. Please see new Preface and 

text added in Implementation 

section.

Agree, this document proposes a 

prioritization exercise to evaluate 

cost effectiveness and other 

criteria that drive project 

prioritization. This exercise will be 

part of the upcoming nonnative 

fish workshop. Please see 

Implementation Section and Appx. 

C.

Cliff 

Barrett

Utah 

Associated 

Municipal 

Power 

Systems

Move forward with the plan, implementation is a policy 

issue for TWG/AMWG to address.

Agree, Please see new Preface

Bill Davis EcoPlan 

and Assoc.

Supports the basis for using flow and temperature to 

disadvantage nonnatives, should articulate the use to benefit 

natives as well.

Supports use of pheromones and genetics.

Agree, text clarified. Please see 

Manipulation of Dam Releases.

Steve 

Martin

NPS Change title to : "summary of available non-native control 

methods and proposal for research/monitoring, a "white 

paper."

Title changed: Nonnative Fish in 

Grand Canyon – Summary of 

Available Nonnative Fish Control 

Options and Proposed Monitoring 

and Research Recommendations. 

We do not believe this document 

constitutes a white paper. 

Steve 

Martin

NPS What we believe is the best alternative, though we should 

consider others, which is mechanical removal at LCR 

mouth in FY10 (to remove existing non-native population 

at mouth and meet legal obligations) and then move the 

mechanical removal upstream to Paria-Badger reach to test 

if that keeps the non-native population low at the LCR. It 

Agree, Please see additional text in 

Mechanical removal Sections
30

would be good to test this idea of moving upstream as soon 

a we can to show the tribes we are serious about their 

concerns. NPS feels that initial tests could be run in 2010 

to test equipment and beneficial use of trout, logistics etc 

and demonstrate action in 2010 to the tribal interests. This 

would require GCMRC study of other reach effectiveness.

Steve 

Martin

NPS To implement the current BO and CM, an EA covering 

2010 would be done by BOR. (The option of doing no 

removal in 2010 should also be considered, out of respect to 

tribal concerns.) If removal and a short term EA are done, it 

must be clear that a broader EA is being initiated at the 

same time to ensure other options are implemented for 2011 

and 2012. Knowing this longer view is underway, some 

tribal concerns with the 2010 action may be reduced. For 

2011-2012 BOR would be the action-initiating proponent, 

NPS would lead the NEPA, and BOR and USFWS would 

be cooperators (we will want to invite the tribes as 

cooperators also) in the NEPA process. Tribal consultation 

would be conducted within the NEPA process and other 

stakeholders (Lees Ferry fisheries) would be included in the 

public involvement process. Suitable alternatives for 2011-

2012 could be developed for the EA to consider tribal, NPS 

management policy, and USFWS fisheries concerns. BOR 

and NPS would share the costs of the 2011-2012 EA 

development.

Concerns articulate in document. 

Please see Preface, Regulatory 

Authority, Implementation, and 

Tribal concern sections. 

Consultation and compliance 

requirements should be 

coordinated by the management 

agencies.

Steve 

Martin

NPS For the long view, using the white paper document, the 

NPS would be lead (in cooperation with appropriate DOI 

family, the state of AZ, other partners and the TWG) to 

develop a comprehensive non-native fish management plan 

for the CRE within Glen Canyon and Grand Canyon 

National Park. Funding for this larger plan is a question. 

Currently we are only talking about the ―Control of cold-

and warm-water nonnative fish species in both the 

mainstem of Marble and Grand canyons and their 

tributaries‖ conservation measure from the 2008 Biological 

Opinion. There are ten major conservation measures we typically discuss with the BOR; do we need compliance 

with any of these other conservation measures? Should we 

include a comprehensive recovery plan for chub?

Please see Preface and 

Implementation Section

Steve 

Mietz

Brian 

Healy

NPS Please use term  ̳option‘ in place of  ̳recommendation‘.

Please use the term  ̳document‘ in place of  ̳plan‘.

The term  ̳option‘ has been used in 

the context of control methods in 

this document. The term 

 ̳recommendation‘ has been 

retained in the context of 
31

scientifically based research and 

monitoring recommendations 

formulated within the charge of 

GCMRC. 

The term  ̳plan‘ has been replaced 

with  ̳document‘.

Steve 

Mietz

Brian 

Healy

NPS Please clarify why Shinumo and Bright Angel Creeks were 

identified for control projects.

Articulate need to consider native fish movement if barriers 

are to be installed.

Clarify use of weirs and likely trout movement in Shinumo 

Creek

Text clarified. Please see 

Nonnative Fish Removal in 

Tributaries Section. 

Need articulated, Please see 

Chemical Renov. And Barrier 

Const. Section

Use of weirs and trout mvmt. 

articulated. Please see Nonnative 

Fish Removal in Tributaries 

Section.

Steve 

Mietz

Brian 

Healy

NPS Articulate need for strategic placement of barriers Need articulated, Please see 

Chemical Renov. And Barrier 

Const. Section

Andre 

Potochnik

Grand 

Canyon 

River 

Guides

How many young-of-year and juvenile chub have been 

found in the stomach analyses of the harvested nonnative 

fish? What is the percentage for each species? Is there a 

problem?

Text articulated to provide 

estimate of HBC consumption. 

Please see Review of Fish 

Projects/Mechanical Removal

Andre 

Potochnik

Grand 

Canyon 

River 

Guides

Do the chub eat the nonnative fish or eggs? Could this be a 

food source for the chub? How would we know this? What 

do the chub prefer to eat?

Important questions we hope to 

address with an ecosystem model. 

Please see response to Bill Davis‘s 

first comment in this section. 

Andre 

Potochnik

Grand 

Canyon 

River 

Guides

To remove nonnative fish why not use predator species 

instead of humans to do the job.

Goal #3 of the AMP Strategic Plan is to reintroduce 

extirpated native species. Has anyone thought to 

reintroduce the native Colorado pike minnow as a means to 

control nonnatives? What is the role of the pike minnow in 

the upper basin fish recovery program? Wouldn't this be 

less expensive and more parsimonious?

The nonnative fish workshop is 

the venue to present new ideas for 

addressing nonnative fish issues in 

Grand Canyon. All ideas will be 

subjected to a prioritization 

process which will help scientists 

and managers preliminarily assess 

the feasibility and potential benefit 

of implementing various ideas. 

New ideas will continually come 

up in the future and will be 

addressed in the context of the 

nonnative fish workshops. 
32

Andre 

Potochnik

Grand 

Canyon 

River 

Guides

Dam operation manipulations should also be conducted to 

benefit native species

Purpose of dam operation 

manipulations articulated to 

include benefits to native fish. 

Please see Targeted Manipulations 

of Dam Operations Section.

TRIBAL CONCERNS

Kurt 

Dongoske

Amy 

Heuslein

Loretta 

JacksonKelly 

Pueblo of 

Zuni

BIA

Hualapai 

Tribe

Plan should not be approved until tribal consultation is 

completed

Supports this statement

Supports this statement

This document contains numerous 

recommendations and options

based on the review of technical 

information. The implementation 

of the options presented will be 

subject to consultation 

requirements of NEPA, ESA, 

NHPA, and other legal mandates. 

This document represents the 

technical foundation for the 

development of a multiagency 

nonnative fish management plan. 

We feel that it is his plan, 

developed cooperatively among 

the management agencies and the 

Tribes, that should meet all 

consultation and compliance 

requirements.

Kurt 

Dongoske

Michael 

Yeatts

Loretta

JacksonKelly

Pueblo of 

Zuni

Hopi Tribe

Hualapai 

Tribe

DOI must identify the lead agency for initiating and 

conducting tribal consultation.

Supports this statement

Supports this statement

Agree, definition of roles and 

responsibilities of the various 

management agencies is identified 

as a need in this document. We 

provide an example of a rapid 

response plan that could assist in 

defining roles in the broad context 

of consultation requirements.

Arden 

Kucate

Pueblo of 

Zuni

There is confusion about the scope of the plan. Scope clarified. Please see text 

inserted in Preface, Tribal 

Concerns, Mechanical Removal, 

and Implementation Sections. 

Also, please see response below.

Michael 

Yeatts

Hopi Tribe It is premature to finalize the management components of 

the plan.

At the request of NPS, this 

document now presents control 

options. Development of a 
33

management plan and its 

implementation is considered the 

responsibility of the management 

agencies. Please see response to 

Kurt Dongoske‘s first comment in 

this section of the table.

Michael 

Yeatts

Hopi Tribe Benefits of trout removal questionable Likely benefits and uncertainties 

of trout removal articulated. Please 

see Review of Fish Projects/ 

Mech. Remov. And Control 

Options/ Mech. Remov.

Kurt 

Dongoske

Pueblo of 

Zuni

I realize that the agreed to plan during the conference call is 

to generate a section to be inserted in the Nonnative Fish 

Control Plan that addresses the participating tribes' 

perspectives on aspects of the plan that may be culturally 

sensitive and present a means for carrying out consultation 

associated with any effort to implement an aspect of this 

plan. However, having said that, I feel that the tribal issues 

and areas of cultural value conflict or sensitivity should 

permeate the entire document in addition to having one 

section on tribal issues.

GCMRC invited comments from 

tribal representatives to develop 

participating tribes‘ perspectives 

on this document. We received the 

responses contained in this row of 

the table through to the end. We 

inserted test throughout the 

document to identify tribal 

concerns within Control Options, 

Mechanical Removal, Regulatory 

Authority, Tribal Concerns, and 

the Implementation Sections.

Kurt 

Dongoske

Pueblo of 

Zuni

We do not support  ̳after the fact‘ consultation with the 

Tribes because this does not recognize or respect the 

conflicts with nonnative fish control and cultural values the 

Tribes have expressed. Past consultation with the Tribes has 

not been successful. Regulatory Authority Section does not 

recognize these conflicts.

Text regarding tribal consultation 

requirements and recognition of 

tribal concerns has been inserted 

into this document. Text in Reg. 

Authority section added to 

recognize conflicts. Text has been 

added to articulate the 

requirements for Tribal 

consultation.

Kurt 

Dongoske

Pueblo of 

Zuni

I would like to see the plan not only recognize the need to 

consult with the five tribes early in the stages of planning an 

aspect of the nonnative control, but also advocate for true 

collaboration with the participating tribes which involves 

engaging tribal people at the outset of research so they are 

actively involved in the forming of research questions and 

topics; a genuine respecting of cultural values and interests 

in designing and carrying out research/management actions; 

involving tribal members (students, elders, and others 

interested) in analysis, and dissemination of results. True 

collaboration occurs early in planning, project execution, 

and dissemination of results.

We specifically utilized your text 

to articulate tribal concerns in the 

Tribal Concern Section.
34

This process needs to be a two-way communication 

network between GCMRC scientists and the five 

participating tribes; embedded in this two-way network 

should be a feedback loop for tribes to provide culturallysensitive perspectives to the scientists. Additionally, this 

opening of communication will hopefully open the door for 

tribal knowledge of the ecosystem to inform on how the 

ecosystem is evaluated and treated and reduce the overly 

possessive need to understand the Colorado River 

ecosystem and its biological resources (which are also 

cultural resources to the tribes) through only the lens of 

Western science.
35