December 25, 2015
Steve Spangle, Field Supervisor
Arizona Ecological Services Office
2321 West Royal Palm Road
Phoenix, Arizona 85021
602/242-0210, x-244
Comment on Gila Chub Draft Recovery Plan, FR Doc No: 2015-27259
sent by email to Steve_Spangle@fws.gov
ISSUE: The recovery plan proposes to use demographic criteria as the sole measure of threats based
criteria. This is exactly what the Recovery Planning Guidance says the Service must NOT do. The
following excerpts are from page v of the recovery plan (bold added).
Threats-based Criteria:
A-3. All available remnant populations and their replicates are protected against nonnative fish
predation and competition, as measured by the achievement of the demographic criteria
(A-1.i, A-1.ii, and A-2.i).
A-4. The recruitment and survival rates described in criteria A-1.i., A-1.ii., and A-2.i. will be
used to determine when significant threats to remnant and replicate populations (e.g.,
water availability, habitat alteration, and fragmentation) are controlled to manageable
levels such that the threats do not pose imminent or chronic downward pressures on population
sizes.
The issue of objective criteria is so critical that the Recovery Planning Guidance quotes from a court
decision, this is under Monitoring (bold added):
“Congress has spoken in clarion terms: the objective, measurable criteria must be directed
towards the goal of removing the endangered or threatened species from the list. Since the same
five statutory factors must be considered in delisting as in listing, 16 U.S.C. § 1533 (a), (b), (c),
the Court necessarily concludes that the FWS, in designing objective, measurable criteria,
must address each of the five statutory delisting factors and measure whether threats to
the [species] have been ameliorated.” (see Fund for Animals v. Babbitt, 903 F. Supp. 96
(D.D.C 1995), Appendix B).
Then the RPG says this (bold added):
We anticipate that recovery plans will also include demographic criteria (abundance,
distribution etc.), and that these appear separately from the “threats-based” criteria.
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The term “threats based criteria” appears multiple times in the plan, and in each one the measurement is
the same demographic criteria. Here it is at page 41 and 42 (bold added):
Threats-based Criteria:
A-3. All available remnant populations and their replicates are protected against
nonnative fish predation and competition, as measured by the achievement of the
demographic criteria (A-1.i, A-1.ii, and A-2.i).
A-4. The recruitment and survival rates described in criteria A-1.i., A-1.ii., and A-2.i.
will be used to determine when significant threats to remnant and replicate
populations (e.g., water availability, habitat alteration, and fragmentation) are
controlled to manageable levels such that the threats do not pose imminent or chronic
downward pressures on population sizes (addresses Listing Factors A, C, D, and E).
Under the proposed methodology the Service would guess and make assumptions (rather than prove)
whether any specific threat is improving. Problems (or improvements) due to one threat could be
mistakenly attributed to another threat. This not only fails to provide the answers the Service needs for
effective management, it could easily provide wrong answers. The Service would not know which actions
are more or less effective (or not effective at all), because they would not be able to connect actions to
results.
The Service did not rank the threats or describe the relationships between them, as directed by the
Recovery Planning Guidance. The Service did not identify thresholds, or measurable goals for the
threats. There is not way to comply with the directive on threats based criteria unless the Service does
this work. It must establish units by which to rationally judge if a threats is truly being reduced (e.g. more
gallons per minute of stream flow and deeper water would show improved water availability).
Measuring the status of the threats themselves is even more critical, since the Service doesn’t know if the
chub populations are increasing or decreasing under the current conditions. This statement is at page 13
of the recovery plan: (bold added)
Also, in most cases we do not have adequate population trend data to determine if a
population is stable, increasing, or decreasing in abundance.
The Recovery Planning Guidance speaks to importance of identifying causes and effects. Under
Monitoring, in 5.1.9.3 Recovery Action Narrative, is this; (bold added):
Three basic types of monitoring are conducted in the recovery program as follows: (1)
implementation (compliance) monitoring, which is used to see whether the plan is being
implemented fully (Did we do what we said we could do in the recovery plan?); (2) status and
trend monitoring, which determines whether a population or threat is increasing or
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decreasing (What is happening to our population right now? To what extent has the threat been
controlled? Is the population increasing over time and what can we predict for the future?); and
(3) cause and effect monitoring, which tests hypotheses and determines (via research)
whether an action is effective and should be continued (Is the dam hindering fish migration?
Is our management action causing the population to increase?).
The description of monitoring shows that monitoring for population status and trend (2) is NOT the same
thing as determining cause and effect (3). In other words, population demographics do NOT determine if
your management actions are effective. Population data alone cannot take the place of needed research.
But that is exactly what the recovery plan proposes to do.
.Also under Monitoring is this statement (bold added):
The keys to adaptive management include the following: (1) appropriate monitoring of an action,
(2) agreed upon criteria to determine whether an action is effective, and (3) agreed-upon
actions to take as a necessary step for a research action or for a management action if the
effectiveness threshold is not reached during the agreed upon timeframe.
The recovery plan must (and has not) provide the appropriate “agreed upon criteria” that determine if a
management action is effective. Example, for the goal to remove and block nonnative species,
management actions include piscicides and fish barriers. The Service must determine what the
effectiveness threshold is for its proposed management actions.
REMEDY: Rewrite the criteria so threats themselves are being measured, as well as the chub. Separate
the demographic criteria from the threats based criteria. Provide objectives for each threat that are
phrased in units that have a rational relationship to the threat. Establish thresholds by which to measure
effectiveness of the actions. The Service must address its information gap, and determine if the chub are
increasing, stable or decreasing.
Thank you for the opportunity to comment,
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