Brenda Burman, Secretary’s Designee July 16, 2008 

Glen Canyon Dam Adaptive Management Program 

Department of the Interior, MS-6640 MIB 

1849 C Street NW 

Washington DC 20240 

RE: Technical Work Group Minority Report regarding FY09 Budget line item, 

BIO 2.R16.09 “Mainstem Coldwater Fish Control – New Initiative”. 

Dear Ms. Burman, 

This report is on behalf of Anglers and Angling Interests who oppose a “New 

Initiative” at this time to kill coldwater sport fish (Trout) in the Grand Canyon. 

This report is not intended to indiscriminately or generally disparage the 

intentions or the motivations of GCDAMP stakeholders, USGS scientists, private 

contracting collaborating scientists, NPS bureaucrats, Reclamation bureaucrats or 

others who support government projects killing trout in the Grand Canyon. 

This report is a list of reasons for opposition to the new initiative and includes 

observations, concerns, trout killing consequences (intended and unintended), 

precedent consequences, NEPA inadequacies, all related to the new initiative and 

to the similar experiment of killing trout in 2003-2006. 

1- The “New Initiative” is falsely labeled as “Cold Water Fish Control”. The 

only goals listed are to “Calculate the abundance of Rainbow Trout” and 

to “Reduce the abundance of Rainbow Trout” “in the mainstem Colorado 

River in the reach of the confluence of the Little Colorado River”. This 

project as written in the budget and the workplan is blatantly 

discriminatory against trout even though in implementation other nonnative fish will be killed as they were also killed in the similar project 

during 2003-2006. If this new project was a straight forward general 

project to eliminate ALL non-native fish in a limited area designated for 

native fish, this project would be less offensive. 

2- Anglers and the general public were told that the original trout killing 

project from 2003-2006 would be done for four years and then stopped for 

four years for analysis. This was a promise now broken. 

3- The original trout killing was initiated primarily due to a lot of false 

information, inaccurate science and hyperbole generated by various 

government agencies and spread by environmental groups including false 

statements that humpback chubs had declined to as low as 1,000 

individuals in the Grand Canyon (USGS data) when the chubs likely were 

stable at 4 or 5,000. Also it was stated falsely by USGS that chubs had 
declined from over 15,000 in the 1980s when actually they were less than 

10,000 in the 1980s (FWS data, Czapla). The number of trout in the Grand 

Canyon was grossly overstated by USGS to be “Over a Million”, a number 

spread nation wide by the Grand Canyon Trust in newspaper articles. The 

USGS predicted that there were 70,000 trout in the ten mile area of the 

Colorado River where they planned to kill them. Even with a stated 

killing efficiency of 90%, USGS only killed 20,000 trout in four years and 

24 trout killing trips. Less than 1% of Rainbow Trout stomachs contained 

fish (mostly not chubs) even though scientists had predicted since 1995 or 

earlier that trout “consumed over 500,000 young chubs per year” (Rich 

Valdez). If chubs actually did decline since the 1980s, there are many 

possible explanations including the 1990-91 experimental flows for 

sediment studies that repeatedly destroyed the aquatic plants and insects 

that chubs and trout rely upon. Trout populations and the Marble 

Canyon/Lees Ferry area economy declined catastrophically in 1991. The 

government Trout killing has resulted in Trout becoming a fall guy for 

bureaucrats to use to “do something” and also a fund raising/law suit 

opportunity for environmental groups. 

4- The NEPA compliance for the “New Initiative” was grossly inadequate 

and was buried as a part of the compliance done for the recent High Flow 

Test and included only a 15 day public comment period. Recent fish 

monitoring literature cited in the High Flow Test EA and BA has not been 

made available even when requested from Reclamation and USGS. 

5- The precedent created by killing trout in the Colorado River around the 

confluence with the Little Colorado River has led to NPS and Reclamation 

proposals to kill trout elsewhere including Bright Angel Creek and other 

creeks that are too cold for chubs. They have presented no evidence that 

trout from those areas migrate to the Little Colorado River area. 

6- Chubs are a warm water fish living mainly in the spring fed warm water 

of the Little Colorado River. Trout do not enter the Little Colorado River. 

Killing trout will open a niche that could become occupied by fish such as 

carp, catfish, bass and others that would enter the Little Colorado River, 

competing and preying on chubs in their warm water home. 

7- Killing trout around the Little Colorado River led to the presumably 

unforeseen consequence of several environmental groups threatening to 

sue the Arizona Game Fish if they stocked any trout to support the Lees 

Ferry Trout Fishery. The FWS and the NPS have also created impediments 

to Arizona Game and Fish management of the Lees Ferry Trout Fishery. 

Sincerely, 

Mark Steffen, Federation of Fly Fishers, AMWG/TWG recreation stakeholder, 

Glen Canyon Dam Adaptive Management Program