Expanded Non-Native Aquatic

Species Management Plan

Environmental Assessment

U.S. Department of the Interior

National Park Service

Grand Canyon National Park

Glen Canyon National Recreation Area

Intermountain Region

Expanded Non-Native 

Aquatic Species 

Management Plan below 

Glen Canyon Dam

March, 2018

Presenters: Rob Billerbeck, Ken Hyde

Project Team: Rob Billerbeck, Ken Hyde, Erin Janicki, 

Jan Balsom, Brian Healy, Bob Schelly, Melissa 

Trammell

Project Exec Team: Billy Shott, Chris Lehnertz, 

David Jacob, Pat Walsh
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Background

• Increasing threats from potentially harmful non-native species

– Green Sunfish and Brown Trout documented as increasing since 2014, 

more significantly since 2016).

– Walleye, striped bass, and smallmouth bass are periodically caught in 

the river below the dam

• This EA identifies new tools and a tiered management approach 

to control non-native fish and other aquatic organisms, in 

addition to the LTEMP and CFMP tools, in order to protect native 

fish in Glen and Grand Canyon and recreational trout fishery in 

the Glen Canyon Reach 

2

2013 CFMP

Green sunfish found 2016 LTEMP

below dam 2015–2018 

Brown Trout currently 

spawning in Lees Ferry Reach

Smallmouth bass - very 

high threat
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Cooperating Agencies

• Arizona Game and Fish Department

• Bureau of Reclamation

• Colorado River Board of California

• Colorado River Commission of Nevada

• Pueblo of Zuni

• Southern Nevada Water Authority

• Upper Colorado River Commission

• U.S. Fish and Wildlife Service

• Utah Associated Municipal Power Systems

• Western Area Power Administration

3
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Balancing Major Issues

Concerns from Cooperators, Tribes and Public

• One side: Flexibility and Responsiveness to protect native species & endangered fish

• Other side: Tribal concerns about the taking of life and angler concerns about 

incidental effects to the Glen Canyon Reach rainbow trout fishery

1. Incentivized Harvest

2. Mechanical Removal

3. Sloughs at RM -12

4. Live Transport/Relocation

5. Chemical Treatment

6. Biological Control – YY males

Other tools: 

Invasive plant removal options, small scale temperature alterations in streams, acoustic 

fish guidance systems, quagga mussel repellants, etc.

4
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Proposed Action – Adaptive Tiered Approach

Control actions applied stepwise according to tiers

• Tier 1 Actions

– Less management intensive actions first

– Incentives, respectful harvesting, and beneficial use address Taking of Life conce

• Tier 2 Actions

– Moderate management intensity (includes beneficial use)

– Applied only after Tier 1 actions are determined to be ineffective as stand-alone

• Tier 3 & 4 Actions

– More management intensive 

(still includes beneficial use) 

– May include modifications of 

habitat or registered piscicides 

– “Last resorts” applied only after 

lower tiers ineffective 

rns 

5
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Ranking of Potentially Harmful Non-Native Aquatic Species

6

Species Category Threat Level

Brown Trout

Smallmouth Bass (Micropterus dolomieu)

Fish

Fish

1-Very High

1- Very High

Walleye (Sander vitreous) Fish 1-Very High

Northern Pike (Esox lucius) Fish 2-High

Striped Bass (Morone saxatilis) Fish 2-High

Gizzard Shad (Dorosoma cepedianum) Fish 6-Low

Green sunfish found in 

2015 - 2018

8 walleye collected by 

AZGFD in both 2015 & 2016 

at base of dam

Brown Trout currently 

spawning in Lees Ferry Reach

Smallmouth bass - very 

high threat

Northern Pike in Lake Powell & Upper Colorado
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Completion of Consultations for ESA and 106

ESA section 7 consultation (IMR lead)

• We worked closely with USFWS throughout the project

• The BA concluded:

• Not likely to adversely affect 5 listed birds (MSO, Condors, SWFL, Ridgway’s Rail, Cuckoo)

• Likely to adversely affect 2 listed fish (humpback chub and razorback sucker) – (USFW providing 

incidental take estimates and permit with BO)

• No effect on other species 

• There are extensive conservation measures, but these were expected and are consistent with past 

projects (CFMP and LTEMP) and they were discussed in great detail with resource and planning staff at 

GRCA and GLCA

• BO being finalized, expected very soon

• NHPA section 106 consultation (GLCA lead)

• We worked closely with Tribes throughout the project

• NPS prepared a Programmatic Agreement (PA) that incorporates and combines the NPS responsibilities 

from the CFMP with the NNAS into one PA while staying consistent with the LTEMP PA. 

• Provided to Tribes and SHPO for two rounds of comments

• Consultations occurred in person with Zuni and Hopi in spring/summer of 2018

• Final consultations scheduled with Zuni, Hopi, Navajo Nation within the new few weeks to discuss PA.

7
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

The TOOLBOX

8

Action Numbers

in NNAP

Tier of 

Use

Description of Tool/Action

Chemical

C1 3 Overwhelm ecosystem-cycling capabilities (ammonia, oxygen, 

CO2, pH, etc.)

C2 3 Rapid response application of piscicides 

C3 4 Application of 

species

registered piscicides for high/very high threat 

C4 2 Application of piscicide for native fishery renovation

C5 1 Application of herbicides on nonnative plants

C6 1 Application of 

paints

mollusk repellants and non-toxic anti-fouling 

Harvest

H1, 1 Incentivized harvest

Mechanical

M1, 2 Mechanical disruption of early life stages

M2 1 Mechanical Removal

M2 2, 3 Mechanical Removal

M3 1 Acoustic guiding devices 

M4 1 Mechanical harvesting of nonnative aquatic plants

Physical

P1 1 Short-term dewatering using high volume pumps

P2 1 Placement of Selective Weirs

P3 1 Placement of non-selective barriers to Exclude Aquatic Species

P4 4 Dredging at RM -12 to connect sloughs and install water control 

structure

P5 Experim

ental

Experimental Only 

tributaries

- Small scale temperature changes in small 

Biological

B1 Experim

ental

Experimental Only 

control

– Introduction of YY males as population 
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Incentivized Harvest 3-Pronged Approach on Researching 

the use of this Tool

1. Arrange for up to 10 youth and 2 Tribal Elders to participate in 1-day 

guided angling trips for Brown Trout. (Nov. – Feb.) 

2. Schedule 1-2 Angling Tournaments focused on removing Brown 

Trout. Some funding for awards and logistics.

3. “Restoration Rewards” program for Anglers turning in brown trout. 

Will operate for 4 to 12 months depending on success of program. 

Rewards will be between $25 & $50. Possibility of doing monthly 

drawings for “gift card prizes” to increase participation.

*Current AGFD reg’s for Lees Ferry: No limit on Brown’s, artificial flies & 

lures only, barbless hooks – all in place to protect rainbow fishery

9
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Next Steps

• Completion of 106 process

– Consultations meetings with Pueblo of Zuni, Hopi Tribe and Navajo Nation

– Hoping to complete and sign Programmatic Agreement

• Signature and Release of FONSI

• Possibly meet with AGFD Commission to “Introduce” Incentivized 

Harvest Program as united partners (AGFD – Angling Groups – NPS)

• Implement the Tiered process starting with Incentivized Harvest for 

Brown Trout in Fall of 2019 or 2020. 

• Address any Green Sunfish issues.

10
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Questions?

Rob Billerbeck

EA Project Manger (NEPA, ESA)

rob_p_Billerbeck@nps.gov

Ken Hyde

106 lead and Implementation lead

ken_hyde@nps.gov

11
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Public and Cooperator Responses to Sept EA

Public Meetings & Comments

• Public attendance at the meetings in Sept 2018 for the EA release were much lower than at scoping 

(from 69 at scoping down to 18 for EA). 

• The number of letters received for Sept 2018 was also much lower than for scoping (from 428 at 

scoping to 59 for EA). 

• This may mean that we were at least somewhat successful in working through concerns with 

cooperators, tribes and stakeholders.

12
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Public and Cooperator Responses to Sept EA

• AGFD – raised a number of concerns in EA comments – we have met with them several 

times since then and believe we have worked through all the major concerns. We will 

Continue to work with AGFD on their key role in implementing the Incentivized Harvest 

tools and educating the angling community so that they can help with addressing the 

brown trout issues so that the higher tiered intensive fish removal by government 

agencies does not need to be implemented.

• Angler Groups – generally their reception of the EA was significantly better than the 

scoping material. Their concerns were primarily about three things: 1. concerns 

mechanical removal could impact the rainbow trout fishery, concern that treatment of 

the spawning beds for brown trout could impact rainbow trout, and that we were 

underestimating the potential economic impact. We believe many are supportive of 

incentivized harvest.

• Tribes – Zuni and Hopi tribes have expressed concerns regarding the lethal 

management of non-native species. We consulted in person with both last summer 

and have meetings scheduled within the next month with them to work through 

concerns on a PA. Navajo Nation has also requested consultation.

13
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Public and Cooperator Responses to Sept EA

• USFWS – some comments on modeling of YY male action and wording of 

conservation measures. We have worked through all concerns as part of section 7 

consultation.

• UCRC/Basin States – a few specific concerns about cumulative impact wording, we 

believe we addressed sufficiently.

• WAPA – raised a few specific concerns mainly about green sunfish, we believe we 

addressed sufficiently.

• Reclamation – raised a few specific concerns mainly about coordination, we 

believe we addressed sufficiently.

14
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Specific Responses to Comments

Taking of Aquatic Life Issue

• Concerns from tribes about taking of life of fish and other aquatic organisms for reasons other than human 

consumption (for mechanical and chemical tools)

• Response: NPS worked extensively on incorporating the tiered adaptive approach into the entire plan in order 

to address the taking of aquatic life and to first use tools that reduce this concern. NPS consulted with Tribes 

and SHPO and decided to use a Programmatic Agreement approach for 106. NPS also removed a tool 

particularly objectionable to the tribes, sonic concussive devices, and replaced with a non-lethal acoustic 

guidance device. NPS also added text requested by Pueblo of Zuni regarding their objections and a council 

resolution passed regarding their concerns. 

Live Transport/Relocation of Non-Native Green Sunfish from Lees Ferry to Lake Powell (part of M1)

• Concerns from tribes about taking of life of fish would be addressed by this action, but AGFD concerns about 

consistency with AIS policy and transmission of pathogens

• Response: NPS re-consulted with AGFD, and AGFD talked to Utah and we updated language to make it clear 

that NPS would apply for state permits and use state methods to test for pathogens prior to considering any 

re-location action. 

YY male biocontrol for brown trout and possibly other non-native fish (B1)

• Concerns from Basin States, CREDA, some Anglers, Tribes; support from AGFD and other anglers

• Response: NPS re-consulted with AGFD and USFWS and with researchers. Revised modeling per AGFD and 

USFWS suggestions in consultation with GCMRC. Added pilot project for YY males in tributary as a possible 

first action and added additional conservation measures, off-ramps, mitigations and communication steps.

15
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Specific Responses to Comments

Socioeconomics analysis

• Concerns from Anglers and AGFD about underestimated impacts to rainbow trout fishery 

• Response: NPS re-consulted with AGFD and GCMRC and made some revisions to the socioeconomic 

section to ensure full disclosure of all expected impacts. 

Incentivized Harvest 

• Concerns from Anglers, AGFD regarding costs, other implementation issues

• Response: NPS added text to provide a range of cost for this program and added text regarding 

continued coordination on this issue with AGFD, angling groups and Tribes. NPS has submitted 

proposals for NPS funding, has begun talks on possible BOR/AMWG funding, and is asking AGFD and 

other partners to also seek funds.

Other (Sec. Zinke Memo, Root Causes, Accuracy of Trout estimates, and Cumulative Impacts)

• Concerns about a number of other technical and policy issues

• Response: NPS re-checked issues with solicitors, GCMRC, and cooperators and made a number of 

smaller edits to address these issues.

16
Expanded Non-Native Aquatic Species Management Plan

Environmental Assessment

Specific Responses to Comments

Mechanical Disruption of Spawning (M2)

• Concerns from Anglers and AGFD about impacts to rainbow trout fishery

• Response: NPS re-consulted with GCMRC to verify impact levels but GCMRC concurred with our 

determination. Added text that NPS will plan a spawning bed disruption pilot experiment with AGFD 

and GCMRC and work with both on mapping beds and we would conduct during the time of year when 

least likely to impact rainbow trout. 

Mechanical Removal (M1)

• Concerns from Anglers and AGFD about impacts to rainbow trout fishery

• Response: NPS re-consulted with GCMRC to verify impact levels and GCMRC concurred with our 

determination regarding expected impact – suggested no further edits. Added text that NPS will try 

incentivized harvest for 3 years before considering mechanical removal for brown trout in Lees Ferry, 

has a specific trigger written in consultation with AGFD, USFWS and others, would conduct the work in 

non-peak fishing season and would use gear setting to minimize impact to non-target species like 

rainbow trout.

Chemical Controls (C1, C2, C3, C4)

• Concerns from Anglers and AGFD about impacts to rainbow trout fishery and proper permits, concerns 

from Basin States that we have too many restrictions and need to retain flexibility to use this tool

• Response: NPS will seek permits from AGFD for chemical treatment, will co-plan with AGFD for 

experimental treatments, built in a 5 year max for treatment in same location.

17