NPS Rapid Response Compliance

High risk Invasive Fish Concerns 

at Glen Canyon Dam in 2022

National Park Service

U.S. Department of the Interior

Colorado River Program
Rapid Response: Shared Management Concern

• Defining roles and responsibilities

o Shared management responsibilities between federal 

agencies and AGFD

o Increasing Coordination: 

• Started weekly meetings among federal agencies

• Beginning joint meetings with AGFD

• Communication, Coordination and Consultation with Tribes 
Efficiency of Responses to Invasion

 Prevention and proactive action preferable to waiting to respond

 Maintain reservoir higher (DROA/annual volume changes)

 Reduce summer temperatures below ideal breeding levels

 Investigate or pursue reducing fish pass-through (Reclamation study)

 For responses to new invasions, studies elsewhere have documented:

 Responding rapidly, especially prior to breeding is much more efficient and 

involve much lower numbers for lethal control than waiting.

 On-going control over time

 Likely requires multiple methods to be applied to be the most effective (in 

other locations that has meant on-going mechanical removals, barriers, flowbased approaches)
NPS Compliance for Rapid Response

 NPS Federal Compliance: NEPA, ESA and NHPA 106 

 2013 NPS Comprehensive Fish Management Plan (CFMP) EA/FONSI

 2019 NPS Expanded Non-Native Plan EA/FONSI

 Actions available include mechanical, physical, biological and 

chemical

 Invasive species were ranked, with top High-Risk species: 

Smallmouth bass, Walleye, Green Sunfish and Striped bass 

 Specific actions are tied to risk levels

 Depending on the actions, additional: 

 coordination may be needed

 plans/permits may be sought through the state

 consultation with tribes or USFWS may be needed
Status of Non-native Fish Establishment

 High risk fish have not yet been captured in large enough numbers 

to start a rapid response

 Concerned this could occur in next few months

 Reports of gizzard shad passing through in mid March as we 

reached 3525’; may indicate high risk fish also passing

 Summer release temperatures may be suitable for SMB and GSF 

 Anticipating need for rapid response actions this summer
Tools that might apply to rapid response

 CFMP:

 Incidental removal during monitoring

 Emergency rapid response (via electrofishing, nets, barriers) in 

GRCA/GLCA

 Expanded Non-Native:

 Larger/ongoing Mechanical removal – electrofishing/nets/barriers in 

GRCA or in GLCA sloughs – tier 1

 Larger/ongoing mechanical removal in GLCA (outside sloughs) – tier 2

 Consultation required, but would happen after rapid response period

 Chemical treatment for rapid response – tier 3

 Consultation required, but action may need to start within 30-45 days

 Status caveats: we have not reached a trigger for rapid response, we are 

not yet planning specific actions, we are discussing what is available in 

compliance should we need to use it at this time.
Tribal Communication, Collaboration & 

Consultation

 NPS acknowledges that we have had many consultations and 

correspondences with tribes, particularly Pueblo of Zuni, that 

document that some fish control actions will be viewed as an 

adverse effect to the documented Traditional Cultural Property 

(fish are considered a component of the TCP)

 Following coordination with AGFD, NPS plans to send a letter to 

tribes to offer formal consultation for those actions that may 

require consultation that may be considered for rapid responses.

 NPS is committed to continuing existing mitigations and continuing 

dialog to find new mitigations
Logistics Concerns

 Additional coordination and role definition in progress

 Currently NPS does not have sufficient equipment or personnel 

alone to conduct these operations for larger/on-going responses

 Larger mechanical removal response requires multiple boats with 

electrofishing rigs and staffing

 Chemical treatments involve consultation with tribes, seeking 

permits, drafting plans, working with licensed applicators and the 

right gear and equipment

 If we want a contract rapid response, we need additional funding

 NPS investigating funding opportunities within NPS and partners –

we hoped for new appropriations this year but didn’t receive them 
Colorado River Program Staff

Rob Billerbeck

Colorado River Coordinator

National Park Service

Rob_p_billerbeck@nps.gov

303-987-6789