1

MEMORANDUM 

September 18, 2009 

To: Glen Canyon Dam Adaptive Management Program - Technical Work Group 

From: Matthew E. Andersen, Biology Program Manager 

Subject: Review of Nonnative Fish Control Plan 

We are in receipt of comments on the subject plan provided by three agencies. The comments 

were extensive and detailed, suggesting that the reviewers put substantial effort into preparing 

their comments. We are indebted to them for their efforts in providing a thorough review that in 

most examples is very helpful. 

Most of the comments received were constructive because they gave us the reviewer’s 

perspective and asked for a distinct or specific change to the document. In most cases we 

accepted these comments, making the requested change, or a similar change. We have responded 

to the submitted comments using our tabular format, attached. Components of the document that 

will be significantly revised based on constructive TWG review include 1) the addition of an 

Implementation of Recommendations section, 2) the addition of an appendix describing historic 

nonnative fish distribution in Grand Canyon, 3) supporting graphics to demonstrate this 

distribution, and 4) discussion of the importance of defining agency roles and responsibilities in 

nonnative fish management in Grand Canyon. 

The reviewers have provided a number of comments asking us to further prescribe the 

integration of science and management activities. Following some follow up conversations we 

better understand how we might meet this recommendation and we have attempted to do so. We 

think it is important to note that we will not, as the independent science provider to the 

GCDAMP, be able to give assignments to individual agencies as this is beyond our authority. It 

is our hope that this document can serve as a springboard to conversations among stakeholders, 

and perhaps additional parties, in which members volunteer to take on specific tasks toward the 

accomplishment of larger goals. We have already been working with some stakeholders to 

further such conversations. We believe that the annual nonnative meeting described in the plan 

will help provide technical information on which stakeholders can base management decisions, 

whether within or outside of the GCDAMP. 

United States Department of the Interior 

U.S. GEOLOGICAL SURVEY

SOUTHWEST BIOLOGICAL SCIENCE CENTER

GRAND CANYON MONITORING AND RESEARCH CENTER

2255 NORTH GEMINI DRIVE, MS-9394 

FLAGSTAFF, ARIZONA 86001

928 556-7094 Telephone

928 556-7092 Fax
2

We received a number of comments calling for a completed risk assessment. We agree that this 

is needed. It is not complete as of this writing because we have been focusing efforts on this 

plan. However, assuming that we can receive support from TWG to complete review of this plan, 

the modeling we propose in support of the risk assessment is our highest priority. In fact, work 

on this model has been initiated when we are not engaged in review and editing of this plan. We 

received a revised version of the Valdez and Speas risk assessment based on water temperatures 

on September 1, 2009. We intend to incorporate that document as appropriate. It took those 

authors a few years to complete this effort. We offer that observation not to be critical but rather 

to illustrate how such large efforts can take some time to complete, and we therefore ask the 

TWG’s patience and support as we try to complete a risk assessment as fast as possible. 

We received a small number of comments we found derogatory and insulting. Perhaps prime 

among these was the comment that the document we have submitted for review is “little more 

than a literature review”. Such condescending comments do not improve the document, are not 

true, and only serve to foster animosity. We suggest that such broad, sweeping, inaccurate 

comments are out of place in a review and that they should not be submitted in the future unless 

absolutely necessary. 

Finally, some of the reviewers asked that a revised document be submitted to the GCDAMP 

Science Advisors for a second review by that body. We disagree with this approach. The Science 

Advisors have reported that they found the most recent iteration of the plan to be responsive to 

their early 2009 review. If the TWG disagrees with this evaluation and believes that more items 

remain to be addressed then we think it would be more practical and effective for GCMRC and 

the TWG to debate what changes remain to be made rather than drawing a third party back into 

the review process. It is our intent to be as responsive to the TWG comments as we can in the 

next iteration. We hope that the TWG will agree and will find the next iteration to be acceptable 

so that the GCDAMP can move forward with nonnative fish control as well as all their other 

tasks. 

Again, our thanks go out to those reviewers who expended considerable effort in providing a 

thoughtful review. We appreciate those efforts and hope that they find the revision responsive. 
Nonnative Fish Plan TWG Response Table Final Document Title: GCMRC Response to TWG Comments Document Date: Sept. 18, 2009 Authors: Matthew Andersen and Kara Hilwig 

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Name 

Affiliation Reviewer Comments Identify 

Action Requested 

Response Requested 

GCMRC Response

GENERAL COMMENTS 

General 

Dave Speas and Dennis Kubly et seq. 

BOR We find the GCMRC draft plan to be oriented largely 

toward the research (and monitoring) of nonnative (and native) fish, with limited attention to management. There is insufficient integration of these activities, and management seems largely to be a byproduct of, rather than a driver of, research and monitoring. By our count, 40 of the 49 pages in the main body of text primarily address research and monitoring. 

Respond Written We believ

sections iinformatitried to be as a measWe think managemdevelopmand/or mgprovide inconditionmanagem

General 

BOR We think the next draft of the plan will need to again be 

reviewed by the Science Advisors. In our review, we found that concerns of the Science Advisors were still not sufficiently addressed. We expect that the next version of the plan will contain sufficient changes to warrant this review. 

Respond Written The SAs 

found the review of 

TWG doeappropriaconcerns confoundcontinued 

12 46 1732

-1733 

BOR I would think prevention would be the “ultimate” key to 

nonnative fish control as well. 

Clarify role of prevention in this plan 

Section cContinge
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GCMRC Response

7 239 Bill 

Persons 

AZGFD Statement that recommendations for nonnative fish 

management approaches and priorities may change as new information is evaluated from annual nonnative fish workshops, literature reviews...etc. raises the possibility that control efforts may change from year to year, depending on the outcome of nonnative fish workshops. I urge caution in this approach of changing priorities every year. I had hoped for a nonnative control plan that includes control activities and necessary monitoring spanning several years (long term plan) to assess any control methods implemented. If annual meetings are to be used to guide a nonnative control program, they need to be well structured, include the right people, and produce recommendations. 

Link monitoring to control efforts for the period through 2012. 

Changes carefully to data froresearch pwill be evand will bmanagers workshopImportanmonitorinbeen emprevised RNonnativImplemenSections. 

47 Bill 

Persons 

AZGFD Summary Monitoring, Removal, Research, and Other 

Management Strategies. I think this section needs to be carefully reviewed and revised based upon more objective criteria. 

Revise or move to implementation plan? 

Yes Because a 

requested on adding informatiwe believconsumed remaining evaluatinactions thimportant quantificarepresent see Imple

8 na na LaGory WAPA The “Summary and Integration of Fish Sampling” 

section contains little if any integration. 

Rewrite Y Our inten

projects tGCDAMSection tiSummary 

7 na na LaGory WAPA The report is very repetitive treating the same topics 

several times at about the same level in the “Review of Recent Fish Sampling Activities” and the “Recommendations” sections. The recommendations section does not need to repeat the history of past efforts. 

Rewrite Y Realizing 

documenlimited seeach sectiimportant inserted idocumenRecommesentences are more 
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12 na na LaGory WAPA The report should receive a thorough technical edit. 

There are numerous misspellings, omissions, and formatting problems. 

Edit N Documen

misspellincorrectededitorial c

22 8 278 Capron WAPA There are 250 information needs in the strategic plan – 

this is too unwieldy. A more limited list for the program to focus on might be more effective. 

N We agree 

Although the INs, wQuestionwe cite threader can and SSQs and Resewe can pr

23 8 283-

321 

Capron WAPA This is the typical approach in GCMRC documents, to 

list the SSQs, but nowhere does the document discuss our ability to answer the current ones and describe the missing information or how we plan to answer these. The current approach here, in the work plan, and other science plans to merely list the SSQs that a project relates to is of little utility to the program. A better approach is to list the SSQs, describe our knowledge and research 

pertaining to each one, and how the proposed work will add to our ability to respond to each SSQ. How will information be synthesized and analyzed to answer the questions? 

Modify Y GCMRC 

relevance TWG and required tour work unnecessadocumenGCMRC follow su

38 29 1029 Capron WAPA It is beneficial to clearly articulate assumptions, however, 

I fail to see how these assumptions are being tested, how much of an assumption they are, or whether we have any information which would inform these assumptions? 

Y We agree 

articulatinincluded of assumpimplemenwe observwe disproexample, and we do response then we rmay need focused eas succincthe assumRecomme
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Action Requested 

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45 35 1284 Capron WAPA Why is a literature search recommended? It seems this 

report draws on a literature search already. 

Modify Y A literatu

historic stwatershedplans, and tribal landsources oCanyon. TLiterature 

35 1287 Bill 

Persons 

AZGFD A more complete literature review needs to be done. I 

had hoped that this would be part of the planning. 

We agree Studies refish have complete

48 44 1690 Capron WAPA Annual workshops might be too often for this program, 

maybe every other year? 

Modify N Nonnativ

short time species, eevents). Wnature of to review to quickly responses Participatvoluntary

8 245 Bill 

Persons 

AZGFD Section on Efforts to protect Grand Canyon Fish should 

include references to previous projects; suggest keeping 

description of GCDAMP separate. 

References Yes Reference

explicit in intent herprotection revised seProtection 

14 Bill 

Persons 

AZGFD Mainstem HBC Aggregation Monitoring was 

discontinued several years ago. I understand that aggregations will be sampled during 2010, but details are still not clear. 

Revise table 

Yes Revised t

aggregati2010 and 

17 549 Bill 

Persons 

AZGFD Nonnative fish control program = nonnative fish control 

experiment. Objective was not just to reduce nonnatives, 

but to learn if the method would provide benefit to native fishes to direct future management efforts. I think that concept of learning by doing is at the heart of Active Adaptive Management. 

Yes Agree wi

maintainework plancontrol. 

RISK ASSESSMENT 

1 na na Capron/La

Gory 

WAPA Risk Assessment. The main component missing from 

this plan is a risk assessment similar to Johnson et. al. (2008). This is articulated as a priority effort to be completed after this plan is approved. This should have 

Discussion needed 

Y We have 

assessmewriting thdraft docu
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already been completed during this planning process. Without the risk assessment the plan is little more than a literature review. The plan is a helpful document, provides good background, and describes the tasks that generally need to be done, but little can be completed or meaningful decisions made without the risk assessment. That isn’t to say that efforts can’t be made to move forward, but knowing where the most benefit (or greatest risk lies) is critical to making good decisions. For example, the AMP is embarking on nonnative removal of trout in the LCR reach of the mainstem with little scientific rationale for the intended target (90% reduction) and without a fisheries perspective on the effort necessary to maintain those reductions. There is no discussion of when those reductions would be most effective (spring, fall, winter?), or how effort should be spread out throughout the year (e.g., quarterly removal trips). If immigration rates are high and movement occurs mostly in the spring/summer, then late winter removal trips might have little impact on HBC environment and might have little impact on predation rates. A risk assessment is needed to help elucidate these connections and help us target our efforts. Before any of the recommendations are implemented, performance of a risk assessment is needed to determine what species and areas should be targeted. 

able to mwhich we risk assesmore than insulting, inaccuratreview wrecommeinformatiourselves recommethink are supported risk assescomplete with whabioenergeagree witassessmeincreasing recommeuntil the rinconsisteelsewhererainbow tbecause othe LCR of doing nassociated priority reterm, but consultatijudgment and by thUCCRIPnonnative build on tassessme

1 7 202-

243 

BOR In their review of the NNF plan, the Science Advisors 

wrote (page 2, bottom) “Although much of the information necessary for an effective control plan exists in the document, it does not have appropriate context, 

organization and balance. Of particular importance is the omission of a general strategy for this program of work that speaks to its overall goal, processes for determining the key problems to address, areas of priority focus, 

1. Work with management agencies to develop an implementation 

We believaction iteincorporathe annuaregular foon an impready to pmeetings 
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balance of management and science required, integration with other ongoing programs, etc. As noted above and proposed by the authors, it is drafted more as a research and monitoring plan, rather than a Non-Native Fish Control Plan supported by research and monitoring activities.” While we (Reclamation) believe that many of the ingredients for a strategy have been presented, they are not integrated into a strategic format. In their revision to include SA comments the authors included a section on a strategy at the onset of the document (Page 7 of NNF plan, "Overall nonnative fish management strategy"). However, the strategy appears to be one of many lists of activities without any associated timeline, breakdown of subtasks, order of implementation, appropriate management agencies, etc. A way to fix this might be to integrate the monitoring, control and research priorities under each strategy bullet (page 7, NNF plan), and do so in the form of an implementation timeline with management input. This would simultaneously satisfy at least four SA concerns, i.e., the need for formal strategy development, collaboration with managers, science and management integration, and development of a ten year strategy (first, second, fifth and eighth bulleted recommendations from SA comments, pages 3-4). Certainly some activities have to happen before others, some can be initiated concurrently with others, and linkages between science and management could also be more explicitly called out in this format as well. As they stand now, monitoring, control and research activities appear as disjunctive lists in the executive summary and could benefit by integration via an implementation framework. For example, development of remote PIT tag antennae and pheromone research are recommended as a means to learn more about carp for control actions, yet control of carp doesn’t appear as priority under the control actions list (lines 44-51 of the draft plan, despite SA recommendations to do so); however it is implied later that carp control would take place in the LCR (lines 1140-1150). To avoid the need to flip back and forth between the various sections of the document, the relationships between research, monitoring and control actions should be explicitly defined at some point in the document, especially in terms of the 5-10 timeframe recommended by the SAs. Roles and responsibilities of 

strategy that integrates monitoring, control and research priorities under each strategy bullet (page 7, NNF plan). 2. Review revised risk assessment (Valdez and Speas) and summarize/reference in plan as appropriate

this topicimplemenhelp framcompletinmanagemrevised riValdez anwill revieappropriaBased on see that wdescriptiorecommeappropriarectify in of the moin the AMfor 2010-distributepriority reincorpora
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the management agencies should also be identified therein. Finally, Reclamation has completed a revised risk assessment (Valdez and Speas) which addresses comments and concerns provided by GCMRC on September 25, 2007. We originally thought that this project would be referenced in more detail in the nonnative fish plan (see notes from 2006 NNF workshop), but that is not the case. Still, we hope that this document will still be of some use in characterizing the relative risk of nonnative fish proliferation in response to altered thermal regimes and will make it available for the final revision along with responses to GCMRC review comments. When completed, also, Reclamation will make available its hydroacoustic assessment of the Glen Canyon Dam forebay fish community to aid in the evaluation of entrainment risk (line 1297). 

General 

BOR Although the plan uses the word “strategic” often, we do 

not think there is sufficient emphasis placed on a strategic approach to nonnative fish management. The implied strategy appears to be one of many lists of activities without any associated timeline, breakdown of subtasks, order of implementation, appropriate management agencies, etc. We encourage greater attention to species prioritization, risk assessment, source of threats, authority to address threats both inside and outside of Grand Canyon National Park, and temporal and spatial application of control mechanisms, including dam operations. As is too often the case with other aspects of nonnative control, the GCMRC section on dam operations provides a review and then delays new hypotheses, experiments, or management activities in lieu of “a comprehensive review of native and nonnative life history.” There is insufficient recognition that managers sometimes have to make decisions and take actions with limited information, which reinforces the notion of assessing the risk of different actions early in the development of control mechanisms. 

Respond Written We are cu

bioenergethink will these comassign agthreats; thauthoritythe need oavailable Implemen

4 Mult

iple 

BOR The SAs commented (page 6 of their review) that, 

“Specification of the overall problem or problems by GCMRC and TWG. What is to be accomplished by 

Information on distribution 

Informaticompositwithin the 
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scientists, and managers, both in collaboration and, individually. What native (s) are most threatened, what age classes, where? What non-natives are the greatest threat, where?” We do not believe that the problem of nonnative fish has been adequately characterized in the revised plan. Considerable attention has been paid to distribution of nonnative fish (although much of it is relegated to the appendix) and their vulnerability capture, etc., but explicit comparisons of NNF distribution to that of native fish and occurrence in relation to physical habitat gradients in Grand Canyon (mainly temperature) have not been made. Like many other recommendations from the SAs, this risk assessment has been deferred, which effectively extends the planning period through 2010 or beyond. We share their concerns about the length of time it has taken to complete this plan. 

and relative abundance of native and nonnative fishes, source populations, etc. should be integrated to identify areas where native fish are most at risk to predation by (which?) nonnative species. Authors could consider a graphical approach similar to figure 11 of the revised risk assessment (Valdez and Speas 2009). 

Grand Caincluded ownershidesignatioGrand Ca

1 23 Bill 

Persons 

AZGFD We are concerned that a risk assessment and control 

methods are not more fully developed. 

Explain We are w

developmthe 2008 priorities first. 

1 24 Bill 

Persons 

AZGFD Will the Valdez and Speas risk assessment be included in 

a later draft? 

Explain Yes We receiv

We’ll rev

37 29 1015

-1019 

LaGory WAPA The text here describing the risk assessment by Valdez 

and Speas may confuse a reader that does not recognize that that effort looked specifically at the risk of installing and operating a selective withdrawal system rather than the risk of various nonnative fish populations. 

Modify Y We agree 

distinguisand Speaclarified iAssessme
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7 20 659 BOR The SA’s wrote on page 9 of their review that, “The key 

in this assessment is to begin to focus on what would be considered to be your predator fish of highest risk and habitats of highest risk. Of these what fish and habitat areas create highest threat to HBC? We assume this objective process was followed to identify catfish as a target species.” Line 659 of the NNF plan says that catfish are “generally agreed to be one of the nonnative fish species posing risk to native fish in Grand Canyon”, but the criteria or process for this determination was not given. How much risk do catfish pose in relation to other nonnative fish species, including species occurring in the immediate watershed but haven’t invaded the mainchannel yet? 

Clarify process for determining risk 

As has beforums, scatfish webecause: the system around thfecund 4. piscivoreof our curspecies efcooperatiany other with the ebrown trospecies is developin

6 163 Bill 

Persons 

AZGFD Question the statement that RBT “is the fish thought to 

pose the greatest risk to humpback chub, and, as a result, 

it has been the primary, though not sole, target of nonnative control efforts to date.” In the next sentence you state that a risk assessment has not been completed. As I recall a decision was made to use rainbow trout 

removal as an experimental treatment based primarily on 2 factors: 1) it was thought possible to control RBT with available electrofishing techniques and 2) there was a low risk of unintended consequences from removal activity compared to other actions such as a temperature control device or modifications to flow regimes. I had hoped this plan would devote more time to a risk assessment and complete consideration of warmwater nonnative risks to HBC. 

Change language to explain uncertainty and low risk to other resources as reasons for mechanical removal experiment. 

Yes While we 

low collaconsider tcertainly removed would be can incluin our disdevelopedprep.; predemonstrinclude n

9 12, 

29, 34 

430, 1015, 1265, 

The science advisors remarked at several points (page 14 of their review, in particular) that “The authors might also benefit from interactions with authors who have conducted at least informal risk assessments of some of these species i.e., Valdez and Speas (2007).” We (BOR and consultants) interacted with the authors to some extent via attendance of the 2005, 2006, 2007 and 2008 nonnative fish workshops. The draft risk assessment which became Valdez and Speas (2007) had been mentioned in the meeting notes from the 2006 and 2007 workshops, but we were never contacted to assist with integration of the findings into the present work plan, and reference to the risk assessment in this revision is scant despite several SA comments to discuss the 

Reference risk assessment conclusions to support statements made at line 1265; Work with risk assessment authors to determine how much of it can be 

We receivassessmework with appropria
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Action Requested 

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GCMRC Response

findings in more detail. Also, the authors say on line 1265 that the Valdez risk assessment is a justification for moving forward with a bioenergetics/ecosystem model, yet there is no summary of the risk assessment findings to base this on. We have received comments from GCMRC on the risk assessment in September of 2007, however, and have revised the document to address those comments. We can make it available to the NNF plan authors and are willing to assist in integrating elements of it into the final version of the plan. 

used in future planning or prioritization processes. 

24 10 340 Capron WAPA The risk assessment map in the unpublished Valdez and 

Speas report (BOR) is a helpful way of showing the information in the table. Perhaps that work could be completed or incorporated in this plan? In the GCMRC responses to the Science Advisors, this is rejected, but I agree with the SAs that it should be referenced as an unfinished document. It is much further along than the risk assessment GCMRC is working on. 

Modify N We receiv

assessmework with appropria

CONTROL/IMPLEMENTATION STRATEGY 

5 Mult

iple 

BOR The SA’s wrote on page 8 of their review that, “It is 

presumed AMWG directed a collaborative GCMRC/TWG approach to incorporate all ongoing and planned activities of both managers and scientists regarding non-native fishes, and selected native fishes. Yet, there is limited specification of management controls and discussion of the collaborative efforts with TWG and resource managers to define the needed controls. We are aware that managers and scientists are collaborating in the Non-Native Fish Ad Hoc Group and important recommendations and planning are formulated in the group. Also, very critical non-native control activities proposed by the Humpback Chub Comprehensive Plan Ad Hoc Group are considered in these discussions. However, these management/scientist discussions are not documented as potential management controls for implementation. Management planning and 

management controls are not made an explicit part of the plan in balance with science proposals.” We believe that the latter two items have not been adequately addressed in the revision. There is referenced to a series of “three workshops” on line 1013 of the NNF plan, but proceedings from these workshops are not discussed or referenced herein; In the case of the 

Work with management agencies to integrate their roles and responsibilities in implementation of the plan. 

We intenimplemen

cannot asthat is beyready to wdevelop s

We believthat we arsystem. Ois unlikelapplicatioan annual data. We distributinmeetings future. Wfull, publmeetings formal wWe are noof the non
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proceedings from the 2005 workshop and the initial draft outline for this plan, for instance, there was supposed to be included in the plan a “risk analysis. Initiate in 2006. AMP funded. Incorporate BOR study as appropriate. Deliver draft report early 2007”; additionally, it also called for a “policy review of nonnative control. AZGF conducts with GCMRC input as requested, reports back to AMP”. If these assignments were completed, they should be included in this plan, as they should form the basis for the strategy. 

General 

BOR We think, in retrospect, that the assignment given to 

GCMRC by the AMWG to develop a nonnative control plan should have enjoined the management agencies in the effort. We appreciate that GCMRC has been the leader in developing the science necessary to undertake adaptive management of Colorado River resources below Glen Canyon Dam. The GCDAMP has matured sufficiently and knowledge has increased to the point where the roles of the science institution and the management agencies need to be better integrated. The development and implementation of this nonnative fish plan is an excellent place for that integration to ensue. USGS is not a management agency, and it seems inappropriate for them independently to develop a management plan directed at fish and wildlife species. This shortcoming was previously recognized by the Science Advisors. In looking forward, we believe this shortcoming needs to be rectified by greater involvement of the management agencies in both planning and implementation of nonnative fish management. For example, the proposed workshops on nonnative fish management should be jointly developed by USGS/GCMRC and the management agencies. We include Reclamation in that group because of our environmental compliance responsibilities and as the agency that operates Glen Canyon Dam. 

Respond Written If the AM

independneeded to good way to GCMRA multi-ato include if it could 

contentio

2 46-

49 

Multiple 

BOR The SA’s wrote on page 3 of their comments that “The 

plan lacks specific discussion of resource needs, especially budget needs. Information is necessary for transition of science application to management control actions, who is likely to complete control actions, external budget needs, and all contingency and anticipated new GCMRC research and monitoring needs.” 

Work with management agencies to develop an implementation strategy that 

Please segeneral coCost Sect2010 and Implemen
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We feel that this concern has not been addressed adequately. While it is true that cost estimation is difficult (page 49, NNF plan), it is apparent that there are some activities that will almost certainly happen (risk assessment, trout control, etc), and others that may happen (contingency funds, page 46, NNF plan). Placeholders for these tasks should be identified in an implementation timeline (again, a more robust strategy would aid in this) so that the needs can at least be identified in the planning phase, more accurate budget planning can take place. Roles and responsibilities of implementing management agencies need still to be identified. 

integrates monitoring, control and research priorities under each strategy bullet (page 7, NNF plan). 

3 44-

46 

1720-1788 

BOR The SAs wrote in their comments (page “Inclusion of the 

contingency plan is an important element of the document. The SAs agree with GCMRC in its review request that this element needs more development. The approach needs leadership of management agencies and tribes to craft appropriate public relations, rapid response control, triage, and monitoring assessments.” We agree with the Science Advisors (TWG call, 7/22/09) that this element is still largely unchanged from earlier versions and should be revised to address SA concerns. 

Work with management agencies to improve this section. 

We agree regarding managememphasizImplemendocumenroles and implemenrapid respduring dinonnative 

7 202 Bill 

Persons 

AZGFD Overall Nonnative Fish Management Strategy section 

suggests that this plan is a strategic plan to develop control methods. It reads as a plan to develop a plan. I had hoped to have a control plan more fully developed at this stage of the project. Where do we go from here? 

Review and explain next steps in nonnative control. 

Yes Developm

implemenrequires dresponsibexperime

These disamong mAMWG mneed in th

2 40 Bill 

Persons 

AZGFD What process was followed in deciding relative 

importance of different monitoring strategies, control strategies, and research strategies? Criteria developed by the Upper Basin (technical feasibility; time to implement; cost; and effectiveness) and their process to prioritize projects seem to provide a good model. I believe that 

document (memo to Biology Committee) was distributed 

at the 2008 nonnative fish workshop. 

Identify process used, or suggest options for use in future. 

Yes Within th

have suggscientists recommeand otherin the annWe have as an App

6 191 Bill 

Persons 

AZGFD The section on Integration of Science and Management is 

unclear and incomplete. Any nonnative control efforts need to be well integrated with other research and 

Rewrite Yes Not sure 

Because wthe AMP 
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monitoring activities, and any management efforts that may fall outside of the AMP also should be closely coordinated with the AMP programs. 

non-AMP charge. WAMP worprojects wyear, and can be gadocumenremoval ffor 2010, in this rearemoval wthose data

4 na na Capron WAPA Scientific Approach. What generally seems missing 

from GCMRC science plans is a scientific approach to hypothesis testing. For example, this plan provides background information on nonnative catches, nonnative control efforts, and then talks about potential strategies. It may be beneficial for GCMRC to replace Coggins with a 

biometrician that would be available to construct science plans that are designed more around hypothesis testing and designing plans to answer these critical questions, illustrate how that will be done, and how information will be synthesized and what analytical techniques will be used to do that. This issue is more evident in the Fall Steady Flow science plan but is here as well. 

Discussion needed 

Y This is a p

an experihypothesiappropriaexperimeHFE; HFhypothese

describe aone does These broGCMRC other doccontribute in questio

5 na na LaGory WAPA The approach outlined in this plan is not sufficiently 

targeted or prioritized given the limited resources available. The plan does not describe a coherent monitoring and control strategy. 

Rewrite Y Prioritiza

clarified. Section. 

9 na na LaGory WAPA The “Summary of Monitoring, Removal, Research, and 

other Management Strategies” section is a laundry list of activities. There is no prioritization, no sequencing, and considerable overlap. For example, would you really do sonic telemetry and remote PIT tag detection at the mouth of the Little Colorado River to determine nonnative and native fish movements? Both are listed as recommendations. 

Rewrite Y Prioritiza

clarified. Section. Rbe used to movementechnologhabitat ovfish. PleaRecommeSonic Tel

10 na na LaGory WAPA The “Nonnative Fish Removal Recommendations” 

section should describe the overall strategy including 

priorities, sequence of activities, the level of effort, and adaptive nature of the program. 

Rewrite Y Implemen

clarified. Section. Timplemenexemplifiannual w
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Continge

56 48 1863 Capron WAPA It would be helpful to have a prioritized list of activities 

here. For example, the development of a bioenergetics model to estimate the potential population level impacts of the trout removal project on HBC should be a high priority. This isn’t evident here with this list of seemingly un-prioritized recommendations. The GCMRC responses to the SA comments was that this was prioritized, but that is unclear to the reader. 

Modify/clarify 

Y Prioritiza

clarified. revised R

30 1082 Bill 

Persons 

AZGFD Recommendation to start monitoring program in 

tributaries needs to be further considered following a more complete literature review and review of the GCMRC fish database. How was this priority arrived at? How does it fit in with the rest of the AMP? 

Yes Monitorin

recommenonnative may neganew invatributariethan tryinreach the will be fudiscussioand manaRecommeGC Tribs 

34 1250 Bill 

Persons 

AZGFD 

What criteria were used to recommend renovation of tributaries over other projects? 

Explain prioritization process, or develop one to be used in the future. 

Yes Stream re

demonstrnonnative nonnative within Nastream reharming nassessed. for prioritImplemenmethods 

UPPER BASIN NNF CONTROL SUMMARY 

2 na na Capron WAPA Nonnative control efforts in the upper basin. The plan 

should include a more comprehensive review of the nonnative control efforts from the upper basin, including lessons learned, methods used (as described in the 

Science Advisor comment). For example, one lesson learned from the upper basin is that programs must move quickly to suppress invasive species in order to have success in controlling them. This supports an argument for the contingency fund, however this concept is not 

Add discussion 

Y This docu

comprehenonnative realize thand habitthat of Grseveral prthis docu

applied to 
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very well understood without a discussion of the efforts in the upper basin. 

specific pplease proPlease see 

8 6 158 BOR Also on page 9 of the SA review, they state “This 

document could be strengthened by acknowledging nonnative fish control problems and control efforts in the upper basin, where fish control has progressed from strategic planning to site specific actions. It would help the rewrite of this document to evaluate a process that has already occurred in the basin with the same fish species. The first strategy in the upper basin was to identify the major nonnative fish issues and problems, and then consider management controls, science strategies, potential problems and conflicts in each area, and resolution in each instance. Also, all known and potential non-native predator fishes were evaluated for how they might threaten the existence of each native fish, to identify high priority areas for implementing control areas, etc (Tyus and Saunders, 1996).” This recommendation has not been addressed. References to nonnative control strategies and their relative levels of 

success in areas outside of the Grand Canyon are few, and references to programmatic processes for development of strategies are not included. 

The authors needn’t expand the scope of the document to provide a rigorous review but rather provide a summary to address the concerns identified by the SA’s (overall program effectiveness, obstacles, etc. and how that might affect efforts in GC). 

Summary nonnative from the Implemennonnative identified recommeimprove mresearch rissues idecompleteinformatiwhich to fish contrImplemenRecomme

6 na na LaGory WAPA The report does not draw sufficiently on experience in 

nonnative fish monitoring and control in the Upper Colorado River Basin. That program has an existing monitoring program in place, has extensive annual control efforts, and has studies to examine the response of native fish species to nonnative fish controls. 

Rewrite Y We are co

Basin Proinsights fhave been our interaprogram hstudies to nonnative 

14 2 59 Capron WAPA This approach was attempted in the upper basin, Johnson 

et. al. (2008) looking at smallmouth bass, channel catfish and other predators on native fish. But Johnson et. al. (2008) is not cited in this document. A broader look at efforts in other regions is necessary. 

Modify text N Manuscri

included Assessme

19 6 165 Capron WAPA You should cite Johnson et. al. (2008) bioenergetics 

paper from the upper basin as a possible approach, are 

Modify N Manuscri

included 
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there others out there? Assessme

44 34 1260 Capron WAPA Should cite Johnson et.al. (2008), bioenergetics paper 

from upper basin. 

Edit N Manuscri

included Assessme

20 7 201 Capron WAPA The upper basin nonnative control efforts were not cited 

in this section, and it is noticeably lacking. We agree with the Science Advisors comment that further discussion, and reflection, from the upper basin is needed in this document. 

Modify N Please se

comment 

40 30 1056

-1067 

LaGory WAPA This discussion of monitoring efficacy of various gear 

types should reference and draw on the experience gained in the Upper Basin. 

Modify Y We have 

Basin and however, documenappropriaapplicatio

MECHANICAL REMOVAL 

17 3 101 Capron WAPA This section should be completely rewritten. First, based 

on the current removal data, and some estimates of immigration, it could easily take 4 trips per year (similar to effort in ‘03/04) to result in abundance estimates of 600-800 trout in the LCR reach. Second, the cost estimate here for what would go into the contingency fund makes no sense as this money is going to be used each year to fund the trips, thus no money will be built up. In years that the AMP does not implement removals it would make sense to build up a fund. If the program concludes that nonnative fish abundances are a concern, then the AMP should consider a funding approach similar to the experimental fund in which substantial funds are set aside each year. 

Modify Y We will r

the relatioremoval trates, and assist witeffort reqgoals. PleRecommeSection a

18 6 163 Capron WAPA Is there a citation for this statement? What is this based 

on? Yard unpublished results? Have we integrated the predation rates with abundance estimates and had this integrated with the ASMR model to evaluate what level of population level impacts that we might expect? Or are there compensatory mechanisms which might ameliorate any removal activities? Elaborate on whatever efforts may be underway with Dr. Carl Walters using bioenergetics modeling. 

Modify Y Yard and 

statement

29 17 548 LaGory WAPA This section on “Mechanical Removal” seems out of 

place in a section on sampling. 

Modify Y Headings 

content. PFish Proje
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30 17 569-

576 

Capron WAPA This paragraph is technically correct but may be 

misleading to the casual reader. It is true that electrofishing is probably an effective removal method. However, that doesn’t mean the activity is effective at either reducing abundance over the long term (multiple years) or at having a population level impact on the HBC population. Immigration rates may be high enough to overcome substantial removal efforts over a relatively short time scale, especially if recent year-class strength is high as it has been in Lees Ferry recently – this could result in more emigration from the Lees Ferry reach. These issues are discussed somewhat in the next paragraph but additional language is needed here to clarify this for the reader. 

Modify N Agree wi

‘effectiveadded to Projects/M

49 46 1807 Capron WAPA My analyses of the available data doesn’t agree with 

these statements that only two trips are needed per year to maintain 10-20% of January 2003 levels. I don’t think this is consistent with Makinster’s presentation at the AMWG either. 

Modify Y Please se

comment 

50 47 1844 Capron WAPA You should state the actual abundance value, 20% of 

January 2003 is 1290 trout in the removal reach to be reduced to 645 fish to reach the 10% threshold. 

Modify Y Actual ab

NonnativRecommePerceived 

6 163 Bill 

Persons 

AZGFD Question the statement that RBT “is the fish thought to 

pose the greatest risk to humpback chub, and, as a result, 

it has been the primary, though not sole, target of nonnative control efforts to date.” In the next sentence you state that a risk assessment has not been completed. As I recall a decision was made to use rainbow trout 

removal as an experimental treatment based primarily on 2 factors: 1) it was thought possible to control RBT with available electrofishing techniques and 2) there was a low risk of unintended consequences from removal activity compared to other actions such as a temperature control device or modifications to flow regimes. I had hoped this plan would devote more time to a risk assessment and complete consideration of warmwater nonnative risks to HBC. 

Change language to explain uncertainty and low risk to other resources as reasons for mechanical removal experiment. 

Yes Decision 

to Review Removal 

COSTS 

49 Bill 

Persons 

AZGFD Cost estimates section is inadequate. Revise Please see 

ImplemenEstimates 

11 na na LaGory WAPA The “Cost Estimates” section describes the high cost of 

implementing programs in the Grand Canyon. As this section closes the report and follows immediately after a 

Rewrite Y Cost estim

research cimplemen
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long list of obviously very expensive programs, it calls into question the recommendations made in the report. 

been incluCost Estimprojects wdeveloped responsibfuture. 

TARGETS 

3 na na Capron WAPA Rationale for 90% reduction in nonnative species. 

Melissa Trammel provided some background to GCMRC on this issue from a March 7, 2005 memo. At the Upper Colorado River Basin Recovery Program Nonnative Fish Removal Workshop held in December 2004, Gordon Mueller stated that a 90% reduction in nonnative fish abundance is necessary to induce a positive population response by native fishes. The workshop was followed by a Biology Committee (upper basin) meeting where achieving target densities of nonnative fishes was discussed as a possible criterion for successful nonnative removal efforts. On request, Gordon Mueller provided several citations to support his suggested target of a 90% reduction. Melissa Trammel summarized those six citations in her memo. Yet, none of this information is used in this document with regard to the proposal of the 90% reduction target for trout in the LCR reach. What is GCMRC’s scientific rationale for proposing the 90% reduction target? I don’t disagree that it is reasonable, but further work is necessary to support that proposal. (2005 memo is attached to this comment) 

Add discussion 

Y Thank yo

informatimanuscriRecommeSection. Gevaluate r

13 2 44 Capron WAPA This is the first place that a target for trout removals have 

come up in an official AMP document. This should be a well reasoned proposal that AMWG can adopt. What is the process for approving this with FWS, informal consultation? Is this an annual target, as measured every few years? There needs to be a recognition that abundance fluctuates around these targets, and consideration of the general issues described above in comment #3. 

Modify text to form a cohesive argument for targets 

Y We will t

revisions required tcertainty. by managnot clear the annuaWe will rtrout abunreach. 

16 3 89 Capron WAPA This plan suggests establishing triggers for nonnative fish 

control. This should be followed up with a clear management discussion for AMWG consideration. This 

document poses the question, but further discussion is needed at TWG/AMWG. What process does GCMRC envision for this discussion? 

N In this do

process foinitiating involve d

managers fish workpresent th
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to nonnatresearch. the basis whether ocontrol ac

43 31 1094

-1136 

Capron WAPA This section doesn’t help the program move forward, it 

merely reiterates our question again, how do we set goals for nonnative removal? 

N Goals for 

based on benefits tnonnative require coagencies managemnonnative refined at workshopSection fo

SPECIFIC COMMENTS 

10 16 516-

528 

BOR In these sections you say that electrofishing may be 

adequate for smallmouth bass and walleye because of 

their vulnerability to the method, citing unpublished AG&F data. But earlier you state that capture probability for the two species are unknown. 

Clarify. Text clari

efficiency in Grand Please see Projects/M

11 33 1214 BOR I believe the the primary gear type used in Elverud 

(2008) was electrofishing, not angling

Check/correct 

Report reappropria

6 10, 

58-71 

Table 1, Appendix A 

The SAs recommended on page 9 of their review that “In this document Table 1 lists "dominant" nonnative predator fish by reach. Thirteen potential nonnative predator fish have been identified in the CRE, but all are not addressed here. Only 7 are presented in Appendix A. Projected future changes in water temperatures or flows in Grand Canyon might allow one or several of these other non-natives to proliferate rapidly.” There are still only 7 descriptions in Appendix A; see also comment 4, above. 

We recogare potenbelieve thspecies neappendixis relativescientific 

15 3 81 Capron WAPA Change “list” to “listed” edit N Edited 21 7 208-

231 

LaGory WAPA There is a fair amount of redundancy in this list (e.g., 

bullets 2 and 4). Eliminate bullet 8. 

Modify N Bullet 2 a

from invadetecting Bullet 8 nwe are strmaintainievaluate t
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programsSection. 

25 12 428 Capron WAPA A Korman et. al. final report to GCMRC is cited here, are 

these available to TWG/AMWG? Perhaps a better citation is the Korman et. al. 2005 paper? 

Modify as appropriate 

Y Citation m

GCMRC 

26 13 LaGory WAPA The text of “Review of Recent Fish Sampling Activities 

in Grand Canyon” does not map closely with the summary Table 2. Some activities are included, but some are not. Also, the discussion of removal efforts in this section seems odd since the topic is sampling. 

Modify Y Section h

reflect coaddress cRecent Fi

27 15 469 LaGory WAPA Table 2 shows this effort as occurring twice annually, but 

the text describes an annual effort. 

Modify Y Table and 

28 15 473-

474 

Capron WAPA This information is somewhat dated, should be brought 

up to date with recent trips, through 2009? 

Modify N Informati

Fish Proje

31 18 585 Capron WAPA The word “protocol” is used twice. Edit N Word rem32 19 595 Capron WAPA Update through 2009. Edit N Figures in

abundancconcurrenFor updatplease see monitorintemperatuBill Vern

33 19 613 Capron WAPA Hunt is not in the literature cited section, I’m not sure 

what 2008 is, Theresa’s draft thesis? 

Edit N Complete

34 26 869 Capron WAPA This unit is installed already right? update. Edit N Updated. 

Projects/RSection. 

35 27 940-

941 

LaGory WAPA The statement that “Monitoring activities should initially 

be conducted in proximity to humpback chub aggregations and tributary inflows” seems particularly important, but is buried in this section and does not even appear in the summary of recommendations. 

Modify Y Statemen

Recomme

36 28 969-

970 

LaGory WAPA The statement “electrofishing to reduce mainstem trout 

abundance and potentially smallmouth bass due to their susceptibility to this method” contradicts earlier and later statements regarding the lack of susceptibility of smallmouth bass. 

Modify Y Efficienc

See SummReview o

39 29 1040 Capron WAPA The term “jeopardy” should not be used here. First, the 

recent biop was “no-jeopardy”, and second it is an ESA term of art. “status” might be a better term. 

Edit N Word rem

41 30 1089

-

LaGory WAPA Why is a “centralized and accessible database” only 

recommended for this topic? It seems appropriate for all 

Modify Y A central

place for 
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1090 of the nonnative fish work. River sam

please see Grand Ca

42 30 1091 LaGory WAPA Although a monitoring program is recommended here, 

the approach to be used is not mentioned. 

Modify Y Developm

will be dithe annuapriorities become m

46 35 1315 LaGory WAPA “Identification of continued and new sources of 

nonnative fish into Grand Canyon” is recommended, but how that would be done is not described. Why are “tributary and watershed inputs” mentioned here but not described? Only dam passage is described and yet this seems to be a much less important, even negligible, source of nonnative fish to the river. 

Modify Y See comm

have been new figur

RecommeSection. 

47 37 1370

-1390 

LaGory WAPA This section on remote PIT tag detectors is very general. 

What species would be targeted? Would this only work for large fish? 

Modify Y Text inse

species thchannel cbullhead 

51 47 1849 LaGory WAPA “Expansion” of the mainstem monitoring program is not 

mentioned in the recommendations on page 30, yet it appears in the summary of recommendations here. What is the recommended expansion--more frequent monitoring or more coverage? 

Modify Y The term 

for clarifiMonitorinMainstem 

52 47 1851 LaGory WAPA Which tributary and confluence areas should be 

monitored long-term? 

Modify Y Informati

Fish ProjeMonitorinGC Tribs 

53 47 1854 Capron WAPA Update, this event occurred, listed here as “scheduled” Edit N ‘Schedule54 47 1861 LaGory WAPA Are you recommending implementing chemical 

renovation and barrier construction or just a feasibility study? 

Modify Y The litera

to implembarrier cofish. We evaluated program’objective

55 48 1864 Capron WAPA Maybe identify the Johnson et al. 2008 paper here as an 

example? 

Edit N Johnson a

cited in reRecommeSection. 

57 48 1871

-1872 

LaGory WAPA What is the purpose of this “research” project—

determine habitat use, distribution, abundance, agestructure? 

Modify Y Purpose d

Please see RecommeYoY Non
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58 48 1873

-1878 

LaGory WAPA The PIT tag and sonic telemetry studies seem duplicative. 

What is the purpose of these studies and why would you do both? Are you recommending feasibility studies or implementation? 

Modify Y Purpose d

Please see RecommeDetection currently project anusing son

59 48 1881

-1883 

LaGory WAPA What would the flow and temperature manipulations be 

based on? Are experiments planned? 

Modify Y Basis dev

Please see RecommeManipulaexperime

60 48 1884 LaGory WAPA The Williams Carp Cage does not sound practical based 

on the description on page 41 and 42. 

Clarify Y Practicali

discussed managers workshopis encour

1 13 Bill 

Persons 

AZGFD Change “promote the Lees Ferry trout fishery” to 

“maintain a naturally reproducing population of rainbow 

trout above the Paria River, to the extent practicable and consistent with the maintenance of viable populations of native fish. 

Revise Yes Change m

6 185 Bill 

Persons 

AZGFD Does “(supported with modeling)” refer to determining 

the presence of new invasive species? Unclear 

Clarify Yes Terms rem

10 346 Bill 

Persons 

AZGFD Table 1. Descriptions of dominant nonnative species do 

not look correct. For example, I believe the reach from RM 56.1-68.6 is dominated by rainbow trout, not carp. The column of other nonnative species captured is incomplete. 

Revise Yes Table rem

to reflect 

11 363 Bill 

Persons 

AZGFD “Little is known about the importance of tributary 

streams to native and nonnative fish in the mainstem in relation to source and sink population dynamics”. Unclear. Why ‘in relation to source and sink population dynamics’. Much is known of use of tributary streams by natives and nonnatives (see esp. Maddux and others 1987), and much can be inferred about sources of nonnatives from those tributaries based on close to 20 years of mainstem Colorado River sampling.. 

Revise Yes Source/si

unknown fish spawfish specitributariefor spawnspecies is Review oGC. Mad

11 368 Bill 

Persons 

AZGFD Proofread and spell check paragraph. Errors ed

11 381 Bill 

Persons 

AZGFD Title of section seems redundant with page 8 line 245 Section ti

Protection Review oefforts in 
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12 425 Bill 

Persons 

AZGFD “inconclusive results” Results were that baited 1-m 

diameter large mesh hoop nets captured larger sizes of catfish than other methods. Can you cite this as a presentation to the TWG or do you need a reviewed document? 

Revise Yes In discuss

authors oauthors suinterestindue to a sinformatiit into thi

14 Bill 

Persons 

AZGFD Mainstem electrofishing – I would suggest “target” 

species are native and nonnative fish vulnerable to boat electrofishing. The target species you list are the species most commonly encountered, which may not be the same thing. We target the entire fish community that is vulnerable to the gear we are using. That could include species such as smallmouth and largemouth bass if they become more common. 

Revise Yes We agree 

target sperevised as Fish Projeand Little 

23 747 Bill 

Persons 

AZGFD Target species for lower 1200 m nets are native and 

nonnative fishes rather than humpback chub, again we sample the entire fish community, and are not targeting one species. 

Revise Yes Agree, se

15 458 Bill 

Persons 

AZGFD “Two parameters can be used to evaluate the 

effectiveness of current nonnative fish monitoring efforts and monitoring gears as removal methodologies: the coefficient of variation (CV) and the capture probability.” I think cost and time are also important parameters to evaluate effectiveness of monitoring efforts. That said, I’m not sure if this paragraph even belongs here in the document. 

Revise Yes Use of CV 

clarified fprogram Review oMonitorin

15 482-

484 

Bill Persons 

AZGFD “intensive sampling...exemplifies effort necessary to 

detect localized annual trends” is unclear. Were local trends estimated with ‘intensive sampling’? 

Clarify Yes Term ‘int

in the repwas cited‘increased 

revised RMainstem 

19 595 Bill 

Persons 

AZGFD Figure 2 does not match figure title. Revise Yes Figure fo

22 734 Bill 

Persons 

AZGFD Oral commun. 2007. Are you not able to cite our annual 

reports? 

Yes Oral com

of text noPlease see Projects/ 

24 786-

788 

Bill Persons 

AZGFD “This suggests that the brown trout composition may 

have been reduced by removal of brown trout during periodic operation of the weir in combination with backpack electrofishing.” The statement is a stretch, and change in percent composition of the catch does not 

Revise Yes Catch rat

phase of thowever, 
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support the statement. Were there changes in catch rates that might be used to support this? 

24 810 Bill 

Persons 

AZGFD Delete ‘potential’ source of brown trout, BA Creek is a 

clear source of brown trout. 

Revise Yes Term del

25 836 Bill 

Persons 

AZGFD Recommendation to continue studying effficacy of 

backpack electrofishing in Shinumo creek does not consider recent translocation of humpback chub into the creek. Seems to me that efforts in Shinumo might be better directed at other methods, esp. in light of recent 

data (angling > shocking). 

Revise Yes Section u

translocatof Fish Pr

28 978 Bill 

Persons 

AZGFD “This demands continued testing of novel control 

strategies through pilot projects conducted in Grand Canyon” What novel strategies are proposed? Suggest delete. 

Revise Yes Sentence 

Summary 

31 1132 Bill 

Persons 

AZGFD 10 percent should read 10 to 20 percent (see line 1122). Revise Yes Revised 

31 1133 Bill 

Persons 

AZGFD “There is the potential that mechanical removal above the 

Little Colorado River reach of the Colorado River could achieve this target abundance”. I would remove this statement until after further discussion and consideration. Think it is premature at this point. 

Revise Yes Statemen

considerasee reviseRecomme

31 1138 Bill 

Persons 

AZGFD Can you provide citations for the “many researchers that 

recommended nonnative fish reduction in three Grand Canyon tributaries”? 

Provide citations 

Yes Sentence 

NonnativRecommeRemoval 

32 1170 Bill 

Persons 

What is the suggestion that backpack electrofishing in Shinumo creek to remove rainbow trout be continued based on? Benefit to native fish in the mainstem? Does it consider time and cost of these operations? Periodic electrofishing in Shinumo creek to reduce contribution of rainbow trout to the mainstem will not be expected to have a substantial population level effect on rainbow trout in the mainstem. Please don’t “sell” the project as such. Shinumo seems like an excellent candidate for chemical renovation if desired by NPS because it has a natural barrier in place. 

Revise Yes Section re

acknowleRBT to threcommecombinatrevised NRecom/ SRenovatioSections. 

33 1225 Bill 

Persons 

AZGFD I don’t disagree with the statement that chemical 

renovations have benefited T&E species. There is a wealth of literature available. Can you offer a more complete coverage of the topic with citations? 

Yes Other cita

topic. PleRemoval RenovatioSection. 
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33 1226 Bill 

Persons 

AZGFD Change “can be combined with a physical barrier” to 

“MUST BE” combined with a physical barrier (see previous comment about literature review of barriers and 

renovations for native fish repatriations) 

Revise Yes Term edit

36 1353 Bill 

Persons 

AZGFD Occupancy modeling may be a useful method to analyze 

data, especially for presence/absence of rare nonnative species. I don’t believe the ASMR is an example of occupancy modeling as stated. Can you provide some other citations for occupancy modeling approach? 

Revise Yes Occupanc

revised. PRecommefor ImproMonitorin

36 1364 Bill 

Persons 

AZGFD The statement “Implementing a long-term monitoring 

protocol to detect changes in nonnative fish abundance and distribution using the occupancy framework is recommended” seems premature. There are a lot of recommendations in this plan. The authors should pare them down to a workable set, with an explanation of how and why priorities were established. 

Statemenof evaluaoccupancResearch for ImproMonitorin
26