INFISH FIELD REVIEW
Lolo National Forest and BLM
Missoula Field Office,
Mike Crouse, BLM OR/WA, Team Leader
October 4-7, 1999
Summary Conclusion
The Lolo National Forest and
BLM Missoula Field Office staff and managers clearly understand the INFISH BO requirements
and are committed to properly applying them on the ground. Both agencies are not viewing INFISH
direction as a mere recipe to follow, but are actually working as a team of
resource specialists and managers to address some difficult, complicated
issues.
General Comments and
Recommendations
The team recognized that the
field units are looking beyond the point problems for the restoration projects
and looking at the bigger picture, wanting to take a ecosystem approach (EAWS)
to management but limited by funding, time, and resources.
The watershed councils being
formed in Montana and elsewhere offer a unique and productive opportunity for
BLM and the Forest Service to work across ownership boundaries to improve
watershed/fish conditions.
The Team recognize and
encourage the use of the Section 10(a)(1) authorization on restoration projects
because for FWS and potential faster turnaround for restoration/recovery
related projects.
The units are encouraged to
place a high priority on the completion of the watershed BAs prior to the May
2000 deadline. These broader
assessments provide the opportunity for increased efficiency, context setting,
and prioritization of future actions.
The team recognizes that
Level 1 team staffing, particularly for the FWS, is a major impediment to
implementation of streamlining consultation.
The units needs to establish
an active Level 2 team, and present the draft Level 1 recommendations to this
group for resolution. The team
recognizes the need for a forum for addressing technical issues related to BO
implementation and will carry these forward to the IIT. However, the Level 1 team is encouraged to
continue to work at the local level for consensus on technical issues.
Feedback to the IIT Team
Communication regarding IIT
products is very important and needs to be improved. Line officers need to be more involved.
There are a lot of efforts
underway to meet the needs of aquatic species.
In many cases these are unconnected.
We need to do better at communicating and establishing the links between
these efforts.
Expectation to complete EAWS
is not realistic given the declining budgets and personnel.
The IIT sub-teams need to
coordinate with field units to make sure that the work they are doing will be
useful and doable. Without sufficient
field input, region-wide efforts and requirements (e.g., Grazing Module) have the potential to undo focused,
important efforts at the local level.
The field units emphasized
the importance of consistency within the Level 1 team in determining what to
include in the baseline bulltrout area and in making may affect
determinations. The IIT was asked to
examine this issue in more detail and provide guidance to the field.
INFISH FIELD
REVIEW
Lolo National Forest and BLM Missoula Field Office
October 4-7, 1999
Field Review Team
Mike
Crouse, Team Leader, BLM Oregon State Office, Portland OR
Susan
Martin, FWS, Idaho State Office, Boise ID
Steve
Grabowski, BLM Washington Office, Boise ID
Scott
Russell, Nez Perce National Forest, Graingeville, ID
Tom
Wawro, BLM Oregon State Office, Portland OR
Lew
Brown, BLM, Coeur d=Alene ID
Fred
Bower, FS Region 1, Missoula, MT
Gordon
Haugen, FS Region 6, Portland OR (Thursday only)
Field Review Objectives
C
Assess how well
PACFISH/INFISH and associated biological opinion (BOs) requirements are
understood and applied.
C
Provide a feedback loop
between field managers and staff and the Interagency Implementation Team (IIT)
on issues and concerns relative to implementation of PACFISH/INFISH and associated
BOs.
Acknowledgments and
General Observations
The IIT Field Review Team
(the Team) wishes to thanks the BLM and Forest Service staff and managers for
the excellent logistics planning and support.
We recognized you have many ongoing priorities and we very much
appreciated everyone=s time involved in the field review.
The prework prepared by field
offices for the review was very thorough and helpful.
The participation by both
technical specialists and managers throughout the field review was noted and
appreciated.
The projects selected for
review were not just the success
stories, but illustrated a wide range of project types, management issues, and
complications. This greatly increased
the Team=s understanding of the issues the field units are
facing. The field units= staffs were genuinely interested in feedback and
assistance on how to handle the difficult projects.
It was apparent to the Team
that both agencies are taking the implementation of INFISH, and associated BOs
seriously. Field technical staff are
not applying INFISH direction as a mere recipe to follow, but using their own
heads and common sense. For example,
the Level 1 team had done a tremendous amount of work pulling together existing
information to develop specific Riparian Management Objectives (RMOs). By assuming extensive bull trout presence
and distribution, the MT Level 1 team has positioned themselves to pro-actively
meet their Sec 7 (a)(1) (species recovery) responsibilities. In addition, both field managers and staff
exhibited a broad understanding of INFISH BO requirements that was the obvious
result of a lot of previous dialogue.
Participation by permittees,
partners, and Level 1 team members was much appreciated and very valuable to
the review.
Project Specific Comments
and Suggestions (see attached project
descriptions prepared by the field units).
Big Creek Bank
Stabilization Project This project was a cooperative effort with a
local land owner and watershed group to stabilize severely eroding stream banks. The Superior Ranger District staff and
managers candidly explained that the project developed from somewhat of an
emergency situation and was not necessarily their highest restoration priority
in the watershed. In the future, they
intend to base restoration projects on a watershed assessment that factors in
upstream and downstream conditions. The
team recognized that it was still important to cooperate in the project because
it established a working relationship with the local watershed group and served
as an example for future restoration efforts.
The District and team both recognized complications related to the
design and implementation of the project, particularly the revegetation plan. The District is encouraged to continue to
work on the revegetation plan for this project. The Forest and District are encouraged to continue to work with
other watershed councils on restoration projects, guided by a watershed
analysis that identifies restoration needs and priorities within the watershed
as a whole.
Savenac Creek Restoration
Project This was a well thought-out, designed and implemented project
(e.g., channel meander, profile and shape was replicated, and flow to the ponds
was maintained), especially considering it opened up 11 miles of bull trout habitat
and restored the connection to the river for $10,000. The team observed a large
number of non-native plant species present at the site, and the District is
encouraged to implement their plan for addressing this problem. The District is encouraged to consider
whether additional willow plantings are needed to complete the project. The District should also consider additional
screening of the diversion head gate to avoid entrainment of fish. This project is a good example of where the Section 10(a)(1) ESA authorization
procedure could be used to reduce FWS workload and BO turnaround for
restoration/recovery related projects..
Cedar Creek Road
Maintenance This site demonstrated how mitigating measures such as berms
along forest roads had resulted in downgrading affects determination of the
road maintenance from likely to adversely affect (LAA) to not likely to
adversely affect (NLAA). The Forest
and District are encouraged to attempt to mitigate the adverse effects of road
maintenance projects elsewhere if possible by including these types of
mitigation measures in the project design.
However, making a LAA call should not necessarily be viewed as a
problem, and should not be avoided when it
is the appropriate determination.
The LAA determination only becomes a problem when due to limited
staffing the FWS is unable to complete a BO in a timely manner in response to
these formal consultation needs. The
team recognizes that this staffing limitation may also cause delays and
frustration related to road special use permit requests. The road permit issue is not unique to this
Forest. It has been elevated to the
national level but remains unresolved.
The road maintenance issue is an example where a functioning Level 2
team could have validated the Level 1 priorities for consultation to relieve
some of the pressure on the field biologists.
The Forest is encouraged to complete a programmatic Biological
Assessment (BA) that includes all their road maintenance activities (including
LAAs). There will be a need to maintain coordination with the IIT Roads Team to
ensure there is not a duplication of effort.
Re-initiation of consultation may be a useful tool to incorporate the
results of the sub-team when these are complete. In addition, completion of watershed BAs should help put the
issues of road maintenance, road location, and road density into context in
terms of overall impacts to listed aquatic species in a watershed. The Forest can then develop an approach for
addressing overall road issues in a watershed.
One approach may include development of a transportation management plan
for the Forest which addresses all these aspects, and prioritizes actions to
deal with them.
Cedar Creek Mining Sites These sites
illustrated a situation where the mining claimants were not able to operate
this field season because a biological opinion had not been issued by the
FWS. The Team and field units
recognized that the INFISH standards and guides for mineral management are
easily met and additional mitigation measures were added through the biological
assessment. The Forest was interested
in input from the Team about the validity of their LAA determination. The Team felt that peer review of this call
was more appropriately received from the Level 1 team. As in the case of road maintenance, the root
of the problem is the inability of FWS to respond in a timely manner due to
staffing limitations. It was a concern
to the Team that three of these Plan of Operations do not include an expiration
date and will make consultation more difficult. However, going to a annual POO authorization schedule may also
present problems in terms of timing and workload. The Team appreciated visiting the claimants on the site during
the review. Their presence and
personality added a great deal to the visit.
Also the District staff are to be commended for their professional and
courteous manner of interacting with the claimants during an obviously
difficult situation.
Sluice Gulch Allotment This field
site illustrated the increased attention the BLM Missoula Field Office staff
has put on riparian conditions as a result of the bull trout listing and the
implementation of BLM=s Healthy Rangeland Standards and Guides. The BLM is doing an excellent job of
working with private landowners to achieve improvements on both the public and
private ground, especially given their limited and fragmented land ownership
pattern. The Clarks (permitees) are
also commended for their efforts and willingness to work with the BLM. Their presence during the review, along with
the County Commissioner and Extension Agent, added a great deal to the
discussion. The BLM is encouraged to
consider the planting of shrubs along the fenced section of Sluice Gulch to facilitate
the restoration effort, recognizing the problems associated with browsing of
streamside shrubs by wildlife. Projects
like Sluice Gulch have the potential to serve as examples of pro-active
partnership restoration efforts that may expand to other private lands.
The hardened crossing planned
for the Papoose Gulch allotment is another good example of an innovative
solution to balancing multiple objectives, combining efficiency, low cost and
low maintenance. Construction of the
hardened crossing should be done consistent with the existing channel profile.
The Rock Creek allotment isn=t scheduled for
immediate fencing in order to pursue a cooperative partnership with the Montana
Fish and Wildlife Department that would achieve a project of greater
benefits. The Garnet Resource Area is
encouraged to pursue the partnership project, recognizing that they may need to
complete fencing of the BLM ground if the larger project doesn=t develop as anticipated.
The Upper Willow allotment is another example of restoration potential and
should be pursued when the private land ownership situation is resolved.
In summary, the BLM projects
have the potential to improve bull trout habitat not only on public lands, but
can serve as a demonstration area for cooperative efforts with other private
land owners in the basin.
General Comments &
Suggestions
The team recognized that the
field units are looking beyond the point problems for the restoration projects
and looking at the bigger picture, wanting to take a ecosystem approach (EAWS)
to management but limited by funding, time, and resources.
The watershed councils being
formed in Montana and elsewhere offer a unique and productive opportunity for
BLM and the Forest Service to work across ownership boundaries to improve
watershed/fish conditions. We need to
put special emphasis on working with these groups since they have influence and
funding. Use of Wyden Amendment
authority is one mechanism to cooperate in restoration projects on private land
that benefit fish and wildlife resources on public lands. In addition to funding, BLM and the Forest
Service can provide technical assistance and help identify restoration
priorities through watershed assessments.
The Team recognize and
encourage the use of the Section 10(a)(1) authorization on restoration projects
because for FWS and potential faster turnaround for restoration/recovery
related projects. .
The Forest and Field Office
are encouraged to incorporate monitoring components into project design and
implementation.
The units are encouraged to
place a high priority on the completion of the watershed BAs prior to the May
2000 deadline. These broader
assessments provide the opportunity for increased efficiency, context setting,
and prioritization of future actions.
The team recognizes that
Level 1 team staffing, particularly for the FWS, is a major impediment to
implementation of streamlining consultation.
This issue will be elevated to the regional executives in our final
report.
The units needs to establish
an active Level 2 team, and present the draft Level 1 recommendations to this
group for resolution. The team
recognizes the need for a forum for addressing technical issues related to BO
implementation and will carry these forward to the IIT. However, the Level 1 team is encouraged to
continue to work at the local level for consensus on technical issues.
Feedback to the IIT Team
The field units provided
written feedback on IIT products and processes (see attached). In addition, the team heard the following
concerns during the field review closeout:
1. Grazing Implementation Monitoring Module:
Regarding possible increases
in grazing implementation monitoring requirements, there seems to have been a
misunderstanding about the potential increase in sample size (from 20% of
allotments to 100%). The team will
carry to the IIT the field units concerns regarding monitoring and their
ability to implement these requirements.
2. Review Format:
A clearer description of the
review=s objectives and structure would have been helpful and
avoided unnecessary effort. The
projects= specific review questions were not particularly
useful to the team or field units in assessing compliance with INFISH BO
requirements. Establishing a firm date
for the review earlier in the process may have permitted more line officer
participation.
3. Selection of field projects for review:
The review team should have
been more involved in the project selection, perhaps through a random process
or by giving more specific criteria to the field units to direct their project selection
(i.e., activity in the RHCA).
4. Communication:
Communication regarding IIT
products is very important and needs to be improved. Line officers need to be more involved.
5. Linkage among ongoing efforts:
There are a lot of efforts
underway to meet the needs of aquatic species.
In many cases these are unconnected.
We need to do better at communicating and establishing the links between
these efforts.
6. Completion of EAWS:
Expectation to complete EAWS
is not realistic given the declining budgets and personnel.
7. Field input and coordination:
The IIT sub-teams need to
coordinate with field units to make sure that the work they are doing will be
useful and doable. Without sufficient
field input, region-wide efforts and requirements (e.g., Grazing Module) have the potential to undo focused,
important efforts at the local
level.
8. Consistency:
The field units emphasized
the importance of consistency within the Level 1 team in determining what to
include in the baseline bulltrout area and in making may affect
determinations. The IIT was asked to
examine this issue in more detail and provide guidance to the field.
Conclusion
The Lolo National Forest and
BLM Missoula Field Office staff and managers clearly understand the INFISH BO requirements
and are committed to properly applying them on the ground. Both agencies are not viewing INFISH
direction as a mere recipe to follow, but are actually working as a team of
resource specialists and managers to address some difficult, complicated
issues.
The projects selected for
review illustrated a wide range of project types, management issues, and
complications. This greatly increased
the Team=s understanding of the issues the field units are
facing. This review and the feedback
provided by the field units on IIT products and processes will be very valuable
as the IIT assesses regional compliance with the PACFISH/INFISH BOs
requirements and establishes priorities for interagency efforts in the future.