MEMORANDUM 

TO: Mr. Glen Knowles, U.S. Fish and Wildlife Service, Phoenix Field Office 

DATE: 6 June 2005 

FROM: Grand Canyon Wildlands Council, Inc. 

RE: Comments on the draft USFWS HBC Genetics Management Plan 

Thank you for requesting feedback on the U.S. Fish and Wildlife Service (Service) draft 

humpback chub (HBC) genetics management plan. The endangered HBC (Gila cypha) 

has become a conservation umbrella species for the Colorado River. Grand Canyon 

Wildlands Council, Inc. has consistently required of the AMWG that a scientifically 

credible HBC genetics management plan be developed prior to launching numerous 

costly, and questionably effective, conservation actions in Grand Canyon. Such a 

document is needed for general and specific guidance on fish conservation, and should 

help the AMWG propose actions and prioritize its activities. 

Towards that end, the Service’s Upper Colorado River Basin Endangered Fish Recovery 

Program has revised its 1999 revised genetics management plan. The present plan 

incorporates the results of considerable time and effort in assessing HBC distribution and 

declining status in the Upper Basin, but not actual genetics information. Below we list 

our general and specific comments about this draft document, with the hope that these 

comments will lead to a more rigorous and credible effort 

 

GENERAL COMMENTS 

1. We were disappointed in the low level of scientific integrity of this document. We 

are presented with policy and contradictory recommendations, modest reference 

to the scientific literature, and a bibliography restricted to HBC and conspicuously 

not to other endangered species’ case studies that follow the successful 

application of genetics management planning and implementation. 

2. While we appreciate the efforts expended by the Upper Colorado River 

Endangered Fisheries Recovery Program on this report, it was disappointing to 

learn how little integrated basin-wide planning has taken place. The role of the 

Grand Canyon HBC population in relation to Upper Basin populations appears to 

be much larger than the plan depicts. Most or all of the Upper Basin’s HBC 

populations appear to be declining, some of them in unregulated reaches, and for 

reasons that are loosely ascribed to climate and non-native species. That not much 

is confidently stated about present HBC status there is alarming, as the Upper 

Basin program has the lead on protection of this species. Conservation of the 

Grand Canyon HBC population is likely to be a much larger issue than is credited 

in the document, because of an effective monitoring program and the use of clear 

scientific experiments to determine causalities. Conservation of this species is a 

high priority and should not be subsumed by Service turf wars. 

3. After nearly three decades of concern for this species, we still do not know the 

genetic relatedness of the five major HBC populations. How much longer must 

we wait for completion and publication of believable data on the genetic 

constitution of this species. Will the long-promised report be scientifically 
credible? Many of this report’s recommendations may need to be revisited if the 

results indicate high levels of inter-population differentiation. With >$100 million 

expended on this fish (with indication of continuing decline), why has the Service 

not made an appropriately large effort to resolve this overridingly critical issue? 

4. We are puzzled by the recommendation on the top half of p. 5 against controlled 

propagation, and the several recommendations on p. 6 on establishing hatchery 

populations. We request that the Service more clearly explain its policies in 

relation to conservation actions, and provide a step-down into this plan that 

embraces both the Upper Basin and Grand Canyon HBC populations. 

5. We expected, but did not find, this document would reference other, similar 

genetics management plans and their successes and failures, reflecting upon those 

as case studies, and demonstrating that the author(s) are well informed of how 

genetics management plans have provided guidance on species conservation. 

6. We expect this plan to provide establish a plan for how the information it provides 

is to guide species and habitat conservation. 

SPECIFIC COMMENTS 

P. 1, HBC Species Status: Are the upper basin HBC populations healthy or declining? 

All Upper Basin data in Table 1 appear to indicate declining populations. 

P.3, 2nd paragr: The causality of HBC decline is weakly worded and convinces the reader 

that the enormous amounts of money spent on this species have failed to indicate causal 

relationships of environmental variables and HBC population health. Strengthen this 

section. 

P. 3, last paragr.: HBC is the only fish species with enough remaining wild individuals to 

allow FWS to learn from, and on which conservation actions may be effective to protect 

fish in the wild. All other fish species are in serious decline or are functionally extinct in 

the wild. We suggest the Service consider revising and upgrading its view of the HBC as 

a species that may, with some attention, become a wild, self-sustaining population. In 

contrast, the other endangered native fish populations may exist in number that are too 

small to be self-sustaining. 

P. 4: Please describe how the Grand Canyon HBC population fits into the overall species 

matrix, remembering that this document will likely guide conservation actions in Grand 

Canyon for the foreseeable future. 

P. 4, 3rd paragr. first line: “policy with U.S. Fish and Wildlife Service and National...” 

typo. 

P.4, 4th paragr.: We expect the Service has standard operating protocols the management 

of captive, endangered fish. and that 

P. 5, paragr. 1: Note should be made of the on-going, large-scale experiment in Grand 

Canyon to suppress non-native salmonids. 
P. 5, paragr. 2: Although the Service apparently has not made fast rules as to the levels a 

population must fall before it is brought into captivity, there must be several case studies 

to determine what population levels have triggered those decisions. It would be useful to 

learn from those case studies whether the trigger levels were sufficient to save the target 

species. Presumably, the Service would be consistent with its previous actions in the 

decision to bring endangered Colorado River fish into captivity. 

P. 5, paragr. 3: “Status of Captive Propagation...”: We expected this section to include a 

summary of the history of captive endangered fish propagation, including both the 

successes and the failures, to help guide HBC propagation efforts. Also, the first criterion 

governing the decision to engage in captive propagation is untenable. If it is used only 

when all other reasonable measures have failed, it will be too late to rescue, or perhaps 

even find, most endangered species. Waiting too long to develop a captive breeding 

program means that insufficient time will be available for learning how to propagate the 

species, much less maintain appropriate levels of genetic diversity. 

P. 5, Recommendations: The statement that “a controlled propagation program does not 

appear prudent” seems inconsistent with the statements on P. 6 “Alternatives for Upper 

Basin HBC”, Recommendation 4 “Move yoy to a refuge, i.e., a hatchery... and add yoy 

on an annual basis...” ), and repeated as Recommendation 3 under P. 6 “Alternatives for 

the Grand Canyon HBC population.” 

CONCLUSIONS 

In summary, we urge the Service to realize: 1) the HBC is a species facing dire 

challenges in the Colorado River system, and there may actually be little time to develop 

and implement a coherent, scientifically credible conservation strategy for it; 2) many 

uncertainties exist about this species life history, interactions, and habitat needs, and 

answering these uncertainties will require a captive population that can be used for both 

conservation and scientific experimentation; 3) a captive propagation program is just one 

of numerous measures that needs to be implemented in the near term to conserve this 

species; and 4) the key to success in conserving this species is to act promptly and in a 

scientifically credible fashion to protect against both catastrophic or gradual loss of this 

species and its habitat. A scientifically credible genetics management plan is essential to 

guide this conservation effort, and that plan is needed as soon as possible. 

We will be honored to review the next draft of this plan, and urge the Service to complete 

that draft as soon as possible.