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 NATIVE FISH WORK GROUP: 

 AN APPROACH TO REMOVAL OF JEOPARDY FROM NATIVE FISHES IN GRAND CANYON

 Bureau of Reclamation 

 Salt Lake City, Utah 

INTRODUCTION

The Adaptive Management Program (AMP), as a construct for planning, investigation, and 

recommendations leading to decision-making, opens the door for a new approach to resolving 

conflict, removing jeopardy, and contributing to prevention of the need for further federal listing 

under the Endangered Species Act. Since issuance of the first biological opinion on operation of 

Glen Canyon Dam (GCD) more than 20 years ago (U.S. Fish and Wildlife Service [Service] 1978), 

Bureau of Reclamation (Reclamation) and the Service have been in a reactive and defensive, rather 

than proactive, mode with respect to removal of jeopardy from native fish of the Colorado River in 

Glen and Grand canyons (hereafter Grand Canyon region). We believe that this reactive approach has 

contributed to a growing perception that the environmental compliance tail wags the adaptive 

management dog, and that much time and funding is being wasted in the process. 

In this document, we briefly outline the proposed approach with respect to native fish. We 

concentrate on native fish because this group of species is deemed to be most affected by GCD 

operations. Two of the remaining five natives in the Grand Canyon region are considered by the 

Service (1994) to be in jeopardy under environmental conditions created by operations under the 

preferred alternative of the GCD Environmental Impact Statement (Reclamation 1995). We note that 

these native fish also are negatively impacted by other important environmental factors, that these 

factors will have to be addressed in our proposed approach, and that addressing these factors will 

require AMP participants, in addition to Reclamation, to invoke their authorities (and 

responsibilities) for this approach to be successful. The past approach to addressing these 

environmental factors largely has been piecemeal, rather than holistic, and this approach persists with 

independent, rather than integrated, proposals to conduct experimental flows, modify release 

temperatures, and conduct nonnative control activities. 

GOAL

Removal of jeopardy from federally listed fish in Grand Canyon is the goal of this effort. We believe 

that attainment of this goal also will contribute to recovery of the listed species and benefit as yet 

unlisted native fish and, if done using precepts of adaptive management, will facilitate due 

consideration of other ecosystem components and goals. 
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BACKGROUND 

In their function as the agency primarily charged with protection of federally listed species, the 

Service (1994) has set down a Reasonable and Prudent Alternative (RPA) as part of their biological 

opinion on the operation of Glen Canyon Dam. Language from the RPA helps to better define our 

goal: 

the Service believes, that to prevent jeopardy to the endangered fish of Grand Canyon, 

restoration of the aquatic ecosystem by reducing, to the extent possible, known limiting 

factors and conducting appropriate research to identify and reduce suspected limiting factors 

will be necessary and can be accomplished with cooperation, innovative approaches, and 

elements of the following reasonable and prudent alternative. 

 The Service goes on to identify that: 

(t)he reasonable and prudent alternative will be accomplished when all elements of the 

selected alternative have been effected and studies confirm compatibility between these 

species requirements and the operation of Glen Canyon Dam. 

This language makes clear the Service=s belief that a program of management actions, aimed at 

ecosystem restoration, and associated research and monitoring will be necessary to make the 

determination of whether the referenced compatibility is demonstrated once all elements of the RPA 

have been instituted. 

It is clear from the Service=s position that a danger will remain when all elements of their RPA have 

been accomplished; that danger is persistence of the incompatibility between the listed fish and 

operation of Glen Canyon Dam. There is, of course, a parallel explanation, which is that a 

combination of other factors, not responsive to or controlled by dam operations, exerts too much 

negative impact on these populations to force this compatibility through modifying dam operations. 

Here is where we believe the true power of adaptive management can be put into effect. Because of 

restrictions on participation in development of biological opinions, the Service often is forced to 

reach conclusions in the absence of involvement by individuals having considerable expertise with 

the species and ecosystems of interest. It is understandable, therefore, that the Service would hold 

out the possibility that jeopardy might not be removed even when all elements of their RPA have 

been accomplished. One way of diminishing the uncertainty faced by the Service is to create an 

advisory body, ancillary to the adaptive management process, that allows the agency to take 

advantage of available expertise in a proactive mode, not under the shadow of Section 7 

consultations. 
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PROPOSAL

Our proposal for resolving conflict, removing jeopardy, and contributing to recovery and prevention 

of need for further listing calls for the creation of a Native Fish Work Group (NFWG) as part of the 

adaptive management process. This group would be made up of a core group of resource managers 

(sensu Nyberg 1998), who would be complemented by researchers from the academic and consulting 

professions. The NFWG would collectively have the education, experience, and expertise to analyze 

the existing status of native fish in the Grand Canyon region and to develop a proactive plan for 

removal of jeopardy from listed fish (RJP), with its attendant contributions to recovery and 

prevention of future listings. 

We recognize that the AMP has a commitment to ecosystem management, which includes native fish 

management, and thus there is a need to integrate the RJP with other actions proposed to better 

manage the ecosystem. Fortunately, there is available to the NFWG a good basis in past and ongoing 

management actions, both proposed and initiated, that have directed attention to the needs of native 

fish in the Grand Canyon region (see e.g., Service 1990, Minckley and Deacon 1991, Clarkson and 

others 1994, Reclamation 1999, Valdez and others 1999). Furthermore, in recent years scientists 

have begun to look carefully at different restoration strategies and their potential effects on various 

resources in the ecosystem. Their findings and recommendations (Marzolf and others 1998, Schmidt 

and others 1998) also are available to the NFWG and to other scientists and resource managers 

involved in the AMP. 

In the six steps of the adaptive management process (Nyberg 1998), the NFWG would concentrate 

primarily on the first three steps: (1) problem assessment, (2) project design, and (3) implementation, 

to achieve the desired goal. There would be less emphasis and involvement in development and 

implementation of research and monitoring plans. This step would be vested largely in the Grand 

Canyon Monitoring and Research Center (GCMRC) and in work groups formed by GCMRC, such as 

the recently proposed Fish Long-term Monitoring Workgroup (FLMW; Ralston and Gold 1999). The 

primary charge of the FLMW will be to: 

(1) collate and analyze existing fish data, 

(2) design a long-term fish monitoring plan, and 

(3) propose how the baseline monitoring plan would be modified and expanded to collect 

additional data around proposed actions such as beach-habitat building flows, habitat 

maintenance flows, experimental low flows, a temperature control device, and exotic species 

control. 

The NFWG and the FLMW would collaborate to strengthen their respective efforts. Both groups 

would need access to fish data and reports generated from analyses of those data for contribution to 

steps 5 and 6 of the adaptive management process (evaluation and adjustment of future decisions 

[Nyberg 1998]). Thus, the FLMW would share results of their analysis of existing fish data with the 

NFWG to ensure they were working from a current knowledge base. The NFWG, in turn would 
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identify proposed actions to remove jeopardy so that the FLMW could use that information in 

developing its long-term monitoring plan and other data gathering activities. 

We propose several levels of interactions for the NFWG, which will retain their center of attention 

on the RJP, but expose them to broader management needs in the adaptive management process. The 

first level of interaction for the NFWG would be with other scientists and resource managers 

engaged in study and management of physical resources, other biological resources, and cultural 

resources. This interaction is expected to occur both during formulation of the RJP and in ensuing 

reviews to determine how best to integrate native fish needs in an ecosystem management program. 

The second level of interaction for the NFWG, and for review of the RJP, would be by the Technical 

Work Group (TWG). The TWG is comprised of technical representatives from the various 

stakeholders on the Adaptive Management Work Group (AMWG). The TWG performs those tasks 

charged to them by the AMWG. Additional responsibilities of the TWG are to develop criteria and 

standards for monitoring and research programs and provide periodic reviews and updates, develop 

resource management questions for the design of monitoring and research by or under the direction 

of the GCMRC, and provide information as necessary for preparing annual resource reports and 

other reports as required for the AMWG. 

TWG members have sufficient expertise to provide a level of scientific review for proposed 

management actions, and they are tasked to use that expertise as technical representatives of their 

stakeholders on the AMWG. Most TWG members do not have the level of expertise that would be 

expected of members of the NFWG, however, and therefore the collective role of the TWG would be 

to serve as reviewers of the draft RJP. This is not to say that some TWG members would not be 

members of the NFWG; clearly there are TWG members who have been directly involved in 

research, monitoring, and management of native fishes in the Colorado River. 

Review of the RJP preferably would be iterative to provide feedback loops during development of 

the plan. This could be accomplished by workshops or by progress reports during regular meetings of 

the TWG (see schedule below). Iterative review and feedback is a significant construct in adaptive 

management. It ensures communication among scientists and between scientists and managers as 

products are being developed, rather than upon their submission in draft form for review. We believe 

the first product developed by the NFWG for review should be a charter and goal statements. 

Success of the NFWG will be to a significant extent determined by acceptance of their charter and 

goals by other levels with which they interact in the AMP. In the same respect, constructive and 

objective review of NFWG products will be enhanced with early concurrence by other scientists and 

managers on the charter and goals. 

The third level of interaction for the NFWG would be with the Science Advisory Board or with a 

Program Evaluation Panel. The panel would review the RJP, preferably in conjunction with review 

of the Long-term Monitoring Plan and any other research and monitoring plans necessary to measure 

the effects of management actions on the ecology of native fishes in the Grand Canyon region. Since 

the RJP is being formulated not just as a native fish plan, but as a component of a program of 
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ecosystem management, the review process would necessarily also consider effects on other 

ecosystem components and the research and monitoring efforts directed at those resources. 

COMPOSITION OF THE NFWG 

There are three areas of qualification that we believe should govern the composition of the NFWG. 

Not all members will necessarily meet all areas of qualification, but the group as a whole must be 

well founded in these areas. As indicated above, it is important that members have a combination of 

education, experience, and expertise on the ecology of native fish to make them productive 

contributors. By inserting ecology, we mean to imply knowledge of the fish, their habitat needs, their 

predators and competitors, their diseases and parasites, etc. A second area of importance is the 

knowledge of responsibilities and authorities held by the different government entities that would 

either undertake the proposed management actions or oversee them through permitting. The third 

area of importance is that of compliance with the National Environmental Policy Act and the 

Endangered Species Act. Although the formation and use of the NFWG is designed to be proactive, 

and to ultimately result in some remission of the conventional Section 7 consultation process, it will 

be necessary for members to be advised of legal restrictions or impediments to proposed actions as 

these actions are being considered, rather than after the RJP is formulated. 

Given these areas of qualification, we perceive the membership of the NFWG core group being 

primarily agency biologists. Representation by the Service, Reclamation, National Park Service, 

GCMRC, and Arizona Game and Fish Department is imperative because of their authorities and 

responsibilities for resources and their roles in compliance, permitting, and logistics. The Navajo 

Nation and Hualapai Nation might well be represented for the same reasons. 

Involvement in the NFWG by consultants and university personnel is highly desirable for the high 

level of education, experience, and expertise on native fish ecology that they would bring to the 

group. We anticipate that most individuals in the latter group would have extensive knowledge of 

Grand Canyon fishes, but it undoubtedly would be desirable to enlist others from this same arena 

with knowledge of these fish in waters outside the canyon region. These individuals would be drawn 

from a pool of experts who have responded to a solicitation of their interest in contributing to 

removal of jeopardy from Grand Canyon fishes. 

ADMINISTRATION

Administration and responsibility for meeting deadlines and delivering products will be assumed by 

Reclamation. We advocate that the NFWG should elect a chairperson who would chair meetings and 

act as point of contact for the work group. This individual would have to work closely with 

Reclamation staff to ensure good communication and meeting deadlines. The work group will also 

need to have one or more individuals trained as facilitators, to ensure that all viewpoints are 

addressed and that meetings proceed according to schedule. 
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SCHEDULE

The NFWG should be convened as soon as possible in calendar year 2000. The schedule would best 

be commensurate with that proposed by Ralston and Gold (1999) for development of the FLMW, 

given the expected interaction that will occur between the two groups. There also are important 

potential management actions to be considered during the year 2000, such as a beach/habitatbuilding flow and/or experimental flows, for which input from the NFWG would be most valuable. 

We view the NFWG as a long-standing group, whereas it is anticipated that the FLMW will dissolve 

when their tasks have been completed. Members of the NFWG would remain available to review 

results of management actions as they are undertaken, and to make recommendations for 

modification or adjustment as necessary in the fashion of adaptive management. 

We think the task of developing a RJP, including reviews by the tiers described above, will require 

15 months in the calendar years 2000-2001, after the NFWG is convened, as defined by the schedule 

proposed below. 

2000

January Contact potential NFWG members to determine availability 

March First meeting of NFWG 

Elect chairperson and facilitator(s) 

Develop draft charter, goals and objectives, and operational rules 

Receive background documents for review 

Receive assignments for next meeting 

Transmit charter, goals and objectives, and operational rules to other 

scientists and resource managers, including TWG and FLMW members; 

solicit review and response 

May Second meeting 

Develop draft strategic plan 

Identify potential actions, target taxa, and anticipated responses 

Identify potential conflicts and effects on nontarget taxa 

Identify authorities and responsibilities associated with proposed actions 

Receive assignments for next meeting 

Transmit progress report to other scientists and resource managers, including 

TWG and FLMW members; solicit review and response 

June Third meeting (combined NFWG and FLMW) 

Receive information from analysis of existing data from FLMW 

NFWG to share thoughts with FLMW on removal of jeopardy actions 
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July Fourth meeting 

Finalize draft strategic plan 

Review and revise potential actions, target taxa, and anticipated responses 

Review and revise potential conflicts and effects on nontarget taxa 

Review and revise authorities and responsibilities associated with proposed 

actions 

Receive assignments for next meeting 

Transmit progress report to other scientists and resource managers, including 

TWG and FLMW members; solicit review and response 

August Fifth meeting (combined NFWG and FLMW) 

Information sharing and feedback 

September Sixth meeting 

Integration of data syntheses from FLMW 

Finalize potential actions, target taxa, and anticipated responses 

Finalize potential conflicts and effects on nontarget taxa 

Finalize authorities and responsibilities associated with proposed actions 

Develop proposed schedule of actions within and among years as related to 

environmental factors and other limiting conditions 

Receive assignments for next meeting 

Transmit progress report with draft strategic plan to other scientists and 

resource managers, including TWG and FLMW members; solicit review and 

response 

November Seventh meeting (one-day combined NFWG and FLMW) 

Writing of draft RJP 

2001

January Convene workshop for review of draft RJP; involve Science Advisory Board or 

Program Evaluation Panel 

March Release draft RJP for AMWG/TWG review 

May Finalize RJP 
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LITERATURE CITED

Bureau of Reclamation. 1995. Operation of Glen Canyon Dam final environmental impact 

statement. U.S. Department of Interior, Bureau of Reclamation, Salt Lake City, Utah. 

Bureau of Reclamation. 1999. Glen Canyon Dam modifications to control downstream temperatures 

plan and draft environmental assessment. Bureau of Reclamation, Salt Lake City, Utah. 58 p. 

Clarkson, R.W., O.T. Gorman, D.M. Kubly, P.C. Marsh, and R.A. Valdez. 1994. Management of 

discharge, temperature, and sediment in Grand Canyon for native fishes. Issue paper 

provided to Glen Canyon Environmental Studies, Flagstaff, Arizona. 

Marzolf, R.G., R.A. Valdez, J.C. Schmidt, and R.H. Webb. 1998. Perspectives on river restoration in 

the Grand Canyon. Bulletin of the Ecological Society of America 79(4):250-254. 

Minckley, W.L. and J.E. Deacon (editors). 1991. Battle against extinction: native fish management 

in the American West. The University of Arizona Press, Tucson. 

Nyberg, J.B. 1998. Statistics and the practice of adaptive management. Pages 1-7 in V. Sit and B. 

Taylor (editors) Statistical methods for adaptive management studies. Research Branch, 

British Columbia Ministry of Forests, Land Management Handbook 42 [online] 

http://www.for.gov.bc.ca/hfd/pubs/docs/lmh/lmh42.htm. 

Ralston, B. and B.D. Gold. 1999. Proposal for accelerating the development of a long-term 

monitoring plan for native and non-native fish in the Colorado River ecosystem below Lees 

Ferry. December 6, 1999, memo to Glen Canyon Adaptive Management Program Technical 

Work Group. Grand Canyon Monitoring and Research Center, Flagstaff, Arizona. 

Schmidt, J.C., R.H. Webb, R.A. Valdez, G.R. Marzolf, and L.E. Stevens. 1998. Science and values 

in river restoration in the Grand Canyon. BioScience 48(9):735-747. 

U.S. Fish and Wildlife Service. 1978. Biological opinion of the effects of Glen Canyon Dam on the 

Colorado River as it affects endangered species. Memorandum from Regional Director, U.S. 

Fish and Wildlife Service, Albuquerque, New Mexico, to Acting Regional Director Harl 

Noble, Bureau of Reclamation, Salt Lake City, Utah. 

U.S. Fish and Wildlife Service. 1990. Humpback chub recovery plan. U.S. Fish and Wildlife 

Service, Denver, Colorado. 

U.S. Fish and Wildlife Service. 1994. Final biological opinion on operation of Glen Canyon Dam as 

the modified low fluctuating flow alternative of the Draft Environmental Impact Statement 
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on the operation of Glen Canyon Dam. Ecological Services, Arizona State Office, U.S. Fish 

and Wildlife Service, Phoenix. 59 p. 

Valdez, R.A., J.P. Shannon, and D.W. Blinn. 1999. Biological implications of the 1996 controlled 

flood. Pages 343-350 in R.H. Webb, J.C. Schmidt, G.R. Marzolf, and R.A. Valdez (editors). 

The controlled flood in Grand Canyon. American Geophysical Union Monograph 110. 

American Geophysical Union, Washington D.C.