Monday is the final day to submit comments on the U.S Fish and Wildlife Service’s draft bull trout recovery implementation plan.

Bull trout in the lower 48 states were listed as threatened under the Endangered Species Act in 1998. Two draft plans were put forth in 2002 and 2004 but were never finalized.

In June, the agency released its draft implementation plan that provides the management portion of the draft recovery plan released in September 2014. It would eliminate demographic requirements for gauging the species’ recovery, focusing instead on identifying and managing threats to individual population segments, including invasive species, habitat degradation and climate change.

Wade Fredenberg, a Kalispell-based bull trout coordinator with the federal agency, said the previous population-based recovery plan fell short of offering a long-term solution to the most imminent threat to bull trout in the Flathead Lake drainage: competition from non-native fish.

“It’s difficult to count something like bull trout accurately, and a lot of folks felt like the numbers incorporated into the old plan were unrealistic and unachievable,” he said. “Basically what we were advocating in terms of recovery was aiming at pristine conditions.”

However, the Montana wildlife agency has been sharply skeptical of the Fish and Wildlife Service’s new approach. Mark Deleray, regional fisheries manager with Montana Fish, Wildlife and Parks, said he believes that without tying the plan to a measurable goal, judging success will be difficult if not impossible.

“It’s really nebulous and makes it difficult to prioritize recovery efforts. And it could potentially lead to misdirected resources,” Deleray said. “Our concern is that it [should be] clear and based on demographics that are quantifiable, not subjective and not based on potentially unattainable goals.”

Stopping short of using the term “flexible,” Fredenberg said he believes that the new plan would allow management agencies to work together to focus those resources where the net impact would be greater.

Using the example of logging projects, which are required to incorporate protections and mitigation measures for threatened species, he said that replacing culverts or fixing a road aren’t necessarily going to benefit bull trout if the immediate tributaries produce few of them or might benefit a competitor species like brook trout.

Michael Garrity, executive director of the Alliance for the Wild Rockies, said he wants to see more specific actions to address threats identified in the new recovery plan. He said many of the implementation plan’s actions are too vague to be effective and also objected to a lack of population standards to ensure bull trout numbers continue to increase.

“It doesn’t deal with specific threats, like logging roads, grazing or mining,” he said.

Fredenberg argued that the proposed recovery plan will allow management agencies to focus more attention and resources on the threats specific to individual drainages and population segments.

“The habitat in the Flathead system is the best we have for bull trout anywhere,” Fredenberg said. “If the habitat is already at a 9.5 on a scale of 1 to 10, putting all your resources into making the habitat a 9.6 isn’t necessarily going to produce the desired result when the non-native problem is at a 1.”

For Northwest Montana, that could mean increased suppression of invasive species such as lake trout, which have grown exponentially since mysis shrimp were introduced into the Flathead River drainage, ultimately making their way into Flathead Lake in the 1980s. The shrimp were more available to lake trout, allowing the non-native fish to surge in size and numbers. As a result, lake trout began outcompeting and preying on bull trout and other native species.

By the early 1990s, redd counts — nest  surveys used to estimate spawning populations — showed the region’s bull trout population down to less than a quarter of historic levels. The population appears to have stabilized at about half of the historic numbers, but only after most bull trout fisheries were closed and other measures, such as lake trout suppression in Flathead Lake, were put in place.

While acknowledging the importance of ongoing lake trout suppression work in upstream waters such as Swan, Logging and Quartz lakes, Fredenberg said the recovery plan will allow resource managers to hone in on the “big picture” — suppressing lake trout in Flathead Lake.

“Flathead and [Lake] Pend Oreille are essentially the heart of bull trout habitat. Those two lakes have the largest, most robust populations of fish,” he said. “With over a million lake trout on Flathead Lake, it’s hard to envision how those numbers are going to decline if we don’t put some effort into reducing them. ... For now we’ve got to use the tools we have.”

Management options for controlling invasive species are fairly limited. Fredenberg said using electricity to kill lake trout eggs during the spawning season is showing promise but hasn’t yet proven itself as an effective strategy.

“We’re basically stuck using gill nets, which are not popular with the public, very time-consuming and expensive,” Fredenberg said. “As a professor at MSU said, it’s basically the same technology that Jesus used.”

In April 2014, Montana-based conservation groups Friends of the Wild Swan and Alliance for the Wild Rockies sued the Fish and Wildlife Service, demanding they finalize the conservation plans begun more than a decade ago. That said, Garrity hasn’t been impressed with the agency’s efforts to do so.

The plan defines six separate recovery units covering Montana, Idaho, Washington and Oregon, along with an isolated population in northern Nevada. The Columbia Headwaters Recovery Unit extends westward from the Continental Divide in Montana through most of the Idaho Panhandle and into parts of Eastern Washington. Of the Columbia headwaters unit’s 35 “core areas” that house distinct bull trout populations, the Flathead drainage contains 19.

Garrity said he was particularly alarmed by a provision in the plan that allows the federal agency to initiate delisting of the species once threats are deemed “effectively managed” in 75 percent of each recovery unit’s core areas. For Garrity, that begs the question: What about the other 25 percent?

“It allows an arbitrary 25 percent of bull trout populations to go extinct, without acknowledging that these populations are essential to the recovery of bull trout,” he said. “I think it’s an extinction plan rather than a recovery plan.”

Steve Duke, a senior biologist with the Fish and Wildlife Service’s regional office in Boise, acknowledged that the plan would allow for the loss of some of those populations, but countered that it also requires threat management for all of the core areas in each recovery unit.

“It’s not like things are just going to stop. What we believe is [with] the 75 percent threshold, we can still have wide-ranging, well-distributed bull trout within that recovery unit,” Duke said. “If we’ve effectively controlled lake trout to the extent that we believe bull trout will persist and we need periodic lake trout control, we need to see assurances that that will continue in the future.”

In comments submitted last December, Montana Fish, Wildlife and Parks agreed that “recovery criteria should not be based on the need to conserve bull trout in all areas they currently persist,” but questioned how threats would be assessed and which fish populations would be given priority.

Given the species’ relative stability over the past decade, Deleray doesn’t believe the region’s bull trout are in danger of extirpation and acknowledged that the federal agency is tasked with overseeing far weaker bull trout populations farther west alongside the comparatively robust numbers in Northwest Montana and Idaho.

Yet he remains worried that the proposed plan won’t result in a successful delisting, arguing that successful recovery requires measurable data: population numbers, distribution and growth, along with habitat monitoring.

“It’s important to have a clear plan laid out,” he said. “And that’s currently not the case with the threat-based approach.”

The comment deadline for the proposed implementation plan is Monday, July 20.

To view the plan, visit www.fws.gov/pacific/ecoservices/BullTroutRUIPs.htm. Comments can be emailed to fw1bulltroutrecoveryplan@fws.gov.

Reporter Samuel Wilson can be reached at 758-4407 or by email at swilson@dailyinterlake.com.