Noxon Warm Water Fisheries Association
Comments and Position on the Suppression of Walleyes in Noxon Rapids Reservoir as proposed
by Montana Fish Wildlife and Parks
History of Lower Clark Fork Fisheries Management (Excerpts from MT-FWP Draft Position
Paper on Fish Passage – 3/30/12)
Past fisheries management activities in the reservoirs shape what we know about both the
tributaries and the main stem habitat, and their ability to sustain different species. Past attempts
to establish trout fisheries within the reservoirs clearly show that habitat conditions within the
Cabinet Gorge and Noxon Rapids reservoirs are not conducive to producing fishable numbers of
salmonids. This historical perspective is important to set the context for the management
possibilities, or lack thereof, within the reservoirs. Highlights of this management include:

The Cabinet Gorge and Noxon Rapids Dams were completed in 1952 and 1958 respectively, and
subsequently filled in 1953 and 1959 (Huston 1985). Prior to dam closure at Cabinet Gorge, the
Lower Clark Fork River (LCF) was free flowing from Thompson Falls Dam (built in 1915) to Lake Pend
Oreille (LPO), providing an open travel corridor and its tributaries provided spawning habitat for
salmonid fishes from LPO. Surveys showed that native, non-game fish dominated the river’s
resident fish community (Huston1985).

Upon filling of Cabinet Gorge Reservoir, extensive fish stocking aimed at building a self-sustaining
coldwater fishery began. Yellowstone cutthroat trout (Oncorhynchus clarki bouveri), kokanee (O.
nerka) and coho salmon (O. kisutch) were all planted in Cabinet Gorge Reservoir in the mid-1950’s.
Plantings were generally unsuccessful, with little angler return in creel surveys (Huston 1985).

In 1958, prior to the completion of Noxon Rapids Dam, a major rotenone treatment was applied to
the LCF from Thompson Falls Dam through Cabinet Gorge Reservoir to remove non-game fish and
prepare for introduction of rainbow trout (O. mykiss). In the late 1950’s millions of rainbow trout
fingerlings were stocked into both reservoirs, and success was observed in the form of angler
captures of adult-sized fish for a few years (Huston 1985). This success did not last. A tagging
study in the mid 1960’s showed that many of the stocked rainbow trout moved downstream
through the dams with most tag returns from Lake Pend Oreille, and maintenance of a rainbow
trout fishery was determined to be unlikely. Approximately 750,000 cutthroat were also planted
during this period.

Afterwards, management emphasis shifted to promoting brown trout (Salmo trutta) and westslope
cutthroat trout (O. c. lewisi). The focus shifted from stocking fingerlings into the reservoirs, to
stocking eggs and fry into tributaries. In the late 1960’s these efforts were made on behalf of
brown trout, and from the 1940s through the late 1970’s westslope cutthroat trout were stocked
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into most major tributaries (Huston 1985). As with previous coldwater fish stockings, there was
little success in establishing significant reservoir coldwater stocks. However, some adfluvial fish
remain to this day and stream resident populations (especially brown trout and cutthroat) have
been established in the larger tributaries to the reservoirs. Stream resident trout spend their entire
life cycle in streams. Adfluvial fish are hatched and rear as juveniles in streams but migrate down to
a lake or reservoir to mature and then return to their natal or home stream to spawn.

In 1971 several hundred burbot (Lota lota) were transferred from Canyon Ferry Reservoir to Noxon
Reservoir. In the late 1980’s a larger effort brought approximately 2,000 burbot from Red Rocks
Lakes to both reservoirs and Triangle Pond. Few were ever recaptured in the reservoirs and the
only population remaining today resides in Triangle Pond, a sub-impoundment of Cabinet Gorge
Reservoir without direct connection.

In the early 1970’s northern pike (Esox lucius) were first captured in Noxon and Cabinet Gorge
Reservoirs, as well as LPO. These fish arrived (presumably) from upstream populations illegally
introduced in the 1950’s. No management activities to promote pike were ever undertaken, but
the fish population is established and provides recreational angling.

Prior to 1979 no water level restrictions were in place on Noxon Reservoir, and annual drawdowns
of 30+ feet were common. In 1979 an operations change was implemented, with winter
drawdown reduced significantly. This measure was voluntary on the part of Washington Water
Power, now Avista, and on two occasions significant drawdown occurred when extra electricity had
to be produced (Huston 1985). This reservoir control measure was formalized in 1985, but could
still be exceeded if necessity dictated. In 1999, during project re-licensing, the drawdown was
further restricted to a maximum of ten feet during any period and only four feet from May through
September. Stabilization of water levels in Noxon Reservoir has resulted in improved spawning and
survival of warmwater fish species.

In 1982 smallmouth bass (Micropterus dolomieu) were experimentally stocked in Noxon Reservoir.
Two years later they were observed throughout both Noxon and Cabinet Gorge reservoirs in good
numbers. Both smallmouth and largemouth bass (M. salmoides) were stocked periodically from
the mid 1980’s through mid 1990’s. Survival and natural reproduction of bass benefited from
reduced reservoir drawdown. Today, bass are the most popular recreational fishery on the
reservoirs. Stabilization of reservoir levels allowed increased growth of macrophytes (aquatic
plants) and also enhanced survival of northern pike.

Through the 1980’s brown trout, rainbow trout and kokanee were periodically stocked into both
reservoirs. These generally produced one good year of angling for small individuals, and then the
2
fish would disappear. Major efforts were made to promote tributary spawning by brown trout
(similar to 1960’s work), which resulted in short-term success.

(Insert: Note that subsequent to the rotenone treatment in 1958, which was intended to remove all
fish from the Thompson Falls Dam downstream including all of Noxon Rapids Reservoir through
Cabinet Gorge, almost all of the fish stocking undertaken was of non-native species.)

In the early to mid 1990’s Washington Water Power (WWP) undertook an intensive fisheries and
limnological survey of the two reservoirs and their tributaries as a precursor to renewal of dam
operating licenses. A major discovery of this survey was the presence of walleye (Sander vitreus) in
Noxon Reservoir (WWP 1996). These fish were illegally introduced, with origins unknown. After
several apparent illegal introductions walleye have established a self-sustaining population in
Noxon Reservoir that is increasing. The status of the Cabinet Gorge walleye population remains
unknown. (Note: Walleye decreased in Noxon in 2012 per FWP net surveys)

In 1998 bull trout were officially listed as threatened under the Endangered Species Act by the US
Fish and Wildlife Service. This coincided with WWP, now Avista Corp., relicensing and ushered in
the current era of reservoir fish management. Bull trout recovery and native species management
became the priority, and stocking and support of non-native fish species has halted.

Since re-licensing of the Avista hydroelectric projects, very little management activity to promote
reservoir fisheries has occurred. Most activities have been fisheries monitoring with some
orientation towards potential impacts to bull trout recovery. Mitigation responsibilities from Avista
are geared toward native species but also include a measure to improve and protect recreational
fisheries. The mitigation measures often conflict with each other as ESA bull trout issues
overshadowed the relicensing negotiations and the recreational fisheries enhancement program is
essentially not allowed to be utilized to enhance non-native sport fisheries in the reservoirs due to
the potential to conflict with bull trout.
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NWWFA –Comments and Position
Funding:

FWP should provide details of funding represented in the Environmental Assessment (EA) as
primarily from Avista Utilities Appendix B of the Clark Fork Settlement Agreement. We request the
release to the public of a full and complete copy of the agreement and also complete details on the
full scope of project expenses over the six year duration and identification of all funding source(s).
In particular, we demand details on the funding arrangement between Avista and FWP that may be
impacted or withdrawn as threatened in the EA and subsequent press releases. We have concerns
that the genesis of this project is related to the perception or reality that FWP is required to create
a project of this nature in order to secure or protect existing funding.
Authority:

The public should be allowed to review any elements of the Montana Code Annotated (MCA) not
only for authority but also other requirements of procedure related to EA and the proposed
suppression for compliance issues or conflicts on obligations of FWP including policies cited (EA)
and also all policy for conflicts with proposed action. FWP has declined requests to deliver
complete copies of internal policy documents not part of MCA driving this decision and is
representing that they will only respond if an official request is filed and fees paid pursuant to FWP
“Public Records Request Policy 6/27/12. NWWFA respectfully argues that all policy and law should
be readily available to the public. It is also reasonable that internal communications and work
product be made easily available for consideration and comment. If providing documentations in a
timely manner is the issue, then an extension of the time period for comment and consideration
should be granted.

FWP represents that Montana Law requires management practices that adhere to the Endanger
Species Act. Then, FWP repeated states that walleye expansion will lead to a collapse of the bass,
perch and northern fishery, none of which are endangered. We are concerned this is a tactic to
gain support for suppression from fishermen targeting other species or to keep them silent on the
issue.

Need for action:
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
FWP defends its Noxon Reservoir walleye suppression plan because of the Department’s policy
against Illegal and Unauthorized Introduction of Aquatic Wildlife, adopted May 22, 2002. The FWP
website page regarding walleye states that there is no record of walleyes being native to Montana.
Montana has thriving walleye fisheries in Fort Peck Lake, Canyon Ferry Reservoir, Tiber Reservoir,
Bighorn Lake, Cooney Reservoir, Yellowstone River, Holter Reservoir, Nelson Reservoir, the lower
Missouri River, Tongue River Reservoir, and Fresno Reservoir that were not authorized by FWP, yet
FWP is making no effort to suppress those fisheries of unknown and unauthorized origins. We are
one state. If eastern Montana can enjoy local walleye fisheries of unknown origins, it is unfair for
western Montanans to not enjoy the same benefits.

Anecdotal evidence and accounts suggests that walleye may have been accidentally or incidentally
transplanted by FWP during stocking of bass as early as the mid-1980s. At that time, walleye
introduction was not a concern and reports indicate that fish other than bass were observed during
visual monitoring and sorting of bass being introduced. This may not be an isolated event
according to verbal reports. FWP should investigate and respond to these reports and provide any
documentation of events that might have led to walleye being included with bass transplants.

FWP representation that illegal stocking events occurred should be validated by release of details
of the alleged events, the subsequent investigation and presentation of all evidence including the
basis for not pursuing the case. Much of the justification for suppression is based on the alleged
“illegal” introduction.

Walleye presence was first documented in 1991 (likely introduction was in the mid 1980’s) and
department policy dictates “removal at the earliest possible date.” We question why FWP waited
for 22 years to address the alleged illegal introduction. We would also point to the fact that the
reservoir is predominantly populated by warm water species that co-exist well with walleye and
were in large part planted and/or supported in the reservoir by FWP over the course of many
decades.

The FWP policy of “no walleye west of the continental divide” was adopted by FWP on August 9,
1989 (almost 24 years ago but possibly after introduction in Noxon). Much has changed in the
fisheries during the last 24 years. There is now a walleye fishery in Noxon Reservoir in NW
Montana. There are also walleye in nearby Lake Pend Oreille and the Pend Oreille River in Idaho.
Idaho boasts many waters with walleye fisheries. Further west, Washington State has thriving
walleye fisheries in the Columbia River reservoirs from FDR Reservoir downstream to near the
mouth of the Columbia, in Banks Lake, Moses Lake, Potholes Reservoir and many other waters.
5

Removing walleyes is unlikely to be successful and will be expensive, although the costs and
financial details have not been shared with the public at this time. The spring conditions in the
river during spawning and the areas that walleye spawn will make it difficult and even dangerous
for FWP to engage in certain elements of the eradication effort or seriously interfere with the
naturally occurring spawning.

Continued scientific sampling of mature, catchable walleye on their spawning grounds to gather
length, weight, and age information (under the “no action alternative” is an unacceptable waste of
fish. Those same data can be gathered with creel censuses at less cost and without killing and
removing from the water the same fish that fishermen buy licenses to fish for. FWP doesn’t kill
deer and elk to gather biological data for those species; they conduct hunter check stations.

Based on information obtained by NWWFA, the total cost of the proposed 6-year project would be
about $402,000. The program would be funded by Avista through their fisheries mitigation
program. The annual proposed budget is $67,000. If approved, the actual first year cost would be
less due to a delayed start and the unknown nature and extent of first year work. Under FWP’s
contract with Avista, they are billed only for work accomplished. This is a large monetary cost to
electrical customers for the purpose of depriving local fisherman of a fishery which the public
wants to keep. We have not been able to obtain information to support FWP representations that
$5 million in Avista funding may be lost due to the presence of walleye.

The capture methods (especially gill netting) will kill other valuable and possibly protected fish
through incidental by-catch. FWP should release capture details for the efforts made last spring
including the numbers and species of all fish captured and harmed. We also request full details and
results on methods referred to in other FWP documents but not mentioned in the E.A. known as
Hoop/Fyke nets, shock-and-block electrofishing, boat seine netting, mobile probe electrofishing
and hook-and-line capture. Incidental by-catch and potential mortality to non-target species is of
great concern. We also recognize that electro-fishing has been found to be harmful to large
salmonids and trust the FWP will consider potential impacts on mature bull trout.

FWP should release complete net survey data that includes the capture of bull trout and other
salmonids for all of the years they have been surveying. Early surveys (Huston) show that FWP
used to routinely log salmonid capture in the annual gill net surveys. Recent survey results do not
list salmonids in the capture data.
6

There are better uses for the resources that will be expended and alternatives should be
considered and presented for protecting resources within the system. The EA only presents two
options; other alternatives exist and are required to be developed and investigated. The Montana
Environmental Policy Act requires broad consideration of alternatives.

The entire Clark Fork System and in fact all state water is threatened by the possibility of
infestation by harmful invasive species, in addition to the already present and poorly controlled
Eurasian Milfoil in Noxon Reservoir. Other western waters have recently been invaded by both
zebra and quagga mussels. FWP is not inspecting vessels at the borders of Montana or educating
the public regarding these serious threats. This action would be welcomed and long-term would be
a much more prudent and productive use of resources.

In the current Statewide Fisheries Management Plan (SFMP), recently adopted (December 2012),
mention of the suppression effort was limited and the nature and extent of the currently proposed
action were completely absent. On page 184 of the SFMP, it is stated “Expanding walleye
populations pose a significant predation threat to native and sport fisheries…and future
management actions will focus on this species”. Later, in the spreadsheet portion of the
document, on page 188, the plan states “Water: Lower Clark Fork River – Confluence with
Flathead River to Idaho Border” with the exception of Bull trout “All other species” management
direction shall be “Continue to monitor distribution and status throughout drainage”. There is no
specific mention of walleye suppression, gill-netting, electro-fishing, trapping or eradication. It is
not until later on page 194 that the SFMP states, in direct conflict with the preceding
representations, that management direction for walleye will be “Suppress illegally introduced
walleye from the reservoir as possible”. There are no further details in the SFMP and whether by
oversight or a deliberate effort to obfuscate the intentions of FWP to eradicate the species, we
would argue that all actions to suppress walleye should be immediately and indefinitely suspended
due to the conflicting and misleading representations stated in the plan and for violation of
procedural and legal requirements that are a matter of law and policy in the State of Montana.

If FWP persists in pursuing suppression of walleye, we would argue that the relevant portion of the
Statewide Fisheries Management Plan should be declared void and unenforceable.

If FWP persists in pursuing suppression of Walleye, we would argue and hereby request that new
and complete public meetings are required to inform the public and allow for public verbal
comment.
7

Written public comment should be made readily available to the public for review in its entirety.
In the process of collecting and responding to comments on the recently approved SFMP, public
comment submissions and statements were edited and condensed by FWP, which we believe is
inappropriate and violates the intent of “public” comment requirements.

On the matter of meetings, NWWFA would like to comment on the press release announcing the
March 19th, 2012 meeting in Thompson Falls. While we agree that a public meeting should be held
and is likely required by Montana Law, we believe that open verbal comment should be allowed
and again, is likely required. We object to the no verbal comment rule for this meeting. We also
object to the tone and content of the notice which we view as incomplete, inaccurate,
inflammatory, exaggerated and divisive. We request that the notice and its content be reviewed by
senior FWP administration officials and that steps be considered to prevent future offensive notices
and tactics. If warranted, we believe discipline for the party(s) responsible for this notice would be
appropriate.

FWP did conduct an informational open house at the Thompson Falls Fire Hall on March 19, 2013, from 4-7
p.m. At that open house, they indicated that they were going to kill walleye starting in about 30 days. That
was very poorly received by the attending public. Paul Fielder, (retired F&W biologist and FWP Citizens
Advisory Council representative from Sanders County) conducted an “exit poll” as people left that
information open house to gauge the public’s support for or against the walleye suppression plan. The
results of the poll were overwhelmingly against the plan (52 people opposed the walleye suppression plan, 2
people supported the plan, and 3 people offered no opinion).

The May 2011 issue of the FWP magazine, Montana Outdoors, had an article about Montana’s
“wonderful walleye fishing”. The FWP article discussed the good walleye fishing in Fort Peck Lake,
Canyon Ferry Reservoir, Tiber Reservoir, Bighorn Lake, Cooney Reservoir, Yellowstone River, Holter
Reservoir, Nelson Reservoir, the lower Missouri River, Tongue River Reservoir, and Fresno
Reservoir. All of these walleye waters are east of the continental divide. With walleye fisheries
east of the continental divide in Montana and walleye fisheries west of the Montana-Idaho border,
does FWP really need to destroy an established walleye fishery in Noxon Reservoir simply to
adhere to a 24 year old policy? It is time for FWP to change that old policy.

The FWP website states: if each Montana fish had its own fan club, the walleye fan club would have
the most members; walleyes are found across much of Montana; there is no record of walleyes
being native to Montana; once walleyes grow to 12-14 inches, anglers become very interested in
catching them; there are few fish in Montana that taste better than walleye; walleyes are popular
fish for tournaments in Montana; no wonder so many people like walleyes. We question why does
FWP desire to deprive Sanders County of the benefits of an already existing walleye fishery in
Noxon Reservoir when the public so strongly supports this walleye fishery?
8

If FWP persists in pursuing suppression of walleye, we would argue and hereby request that a
complete Environmental Impact Statement is required.

While there has been a slow and upward trend in walleye numbers, with the notable exception of
last year (2012) in which there was a decline according to FWP survey results, there is no valid
argument that valuable resources should be expended suppressing walleye in Noxon to prevent
transfer of walleyes to downstream bodies of water. Bass, Northern Pike and Walleye are already
present in waters below Noxon Reservoir and have been for years. While FWP may claim there is
no successful reproduction in Cabinet Gorge Reservoir (CGR), that is merely an assumption and
arguably doubtful. Lake Pend Oreille (LPO) already does have independent successful walleye
reproduction (Idaho F&G) and it is not clear that the walleye in Noxon populated LPO. We would
argue that further evidence or study and monitoring is required to make a determination.

Noxon Rapids differs in its current trophic nature from many ‘typical” western reservoirs and FWP
fails to consider this element in making comparisons and predicting ominous and negative
outcomes. Noxon has matured significantly over the 55 years of its existence and the positive
impacts of more stable water level management, particularly the 4 foot draft requirement Avista
adheres to today, have allowed healthy and sustainable populations of vegetation and cover to
develop. This protects both forage species and the young of other desirable species, such as Bass
and Perch. Stable levels have also contributed greatly to successful spawning of all species. FWP
should continue to study and monitor impacts that may develop but until the predator-prey
relationships within this complex system are better understood, it is premature to attempt to
eradicate a species as desirable as walleye. The forage base in Noxon is extensive and is
replenished naturally within the reservoir and from waters upstream. Efforts at salmonid stocking
have consistently proved unsuccessful and Noxon will likely never support a strong salmonid
fishery. Native species are particularly impacted by the Rainbow, Brown and Lake Trout that exist
in the system due to previous FWP plantings. Walleye and salmonids populations occupy different
areas and depths (Avista Life Study, 2009) within the system (limited overlap) and Idaho F&G as
well as others (McMahon) have concluded that conflict between the two is limited.

There is presently no significant salmonid fishery within the reservoir and there is no clear evidence
that this limited fishery will benefit from walleye suppression. The large fish that are occasionally
captured at the Thompson Falls Dam ladder are too large to be walleye prey and spawning occurs
in tributaries. Arguably, walleye preying on the top current predator, the Northern Pike Minnow
(NPM), and reducing the number of this low value and voracious predator fish will benefit
recruitment and survival of all desirable species within the reservoir. It is also important to note
that walleye fishermen in particular capture many NPM during their efforts to catch walleyes. The
9
two species share habitat areas and the NPM often interfere with angling for walleye. FWP should
consider a bounty on the NPM such as other western states have established but even in the
absence of a bounty, fishermen as a rule generally “sink” the NPM they catch. This suggests that
one reason NPM numbers are reduced in recent surveys is due to interaction with walleye
fishermen in addition to direct predation by Walleye. Walleye presence in Noxon may be beneficial
to the perch fishery by reducing over-abundance and increasing the relative size and desirability of
the remaining population. (Tholl and Kreiner, August 2012) Perhaps a few more years of this
interaction and further research will allow FWP and the fishing public to make a well informed
decision.

FWP claims walleye introductions harm fisheries “throughout” the west. They cite selected cases
and fail to provide complete copies of supporting literature. FWP state that factors contributing to
prey depletion and “crashes” include wide water levels fluctuation affecting prey abundance.
Avista no longer fluctuates reservoir levels severely which is a primary reason the current fish
populations are stable and diverse due to increased spawning success. Lack of cover is stated to be
an issue that increases prey vulnerability. Again, with the stabilization of levels, Noxon has
developed extensive and diverse weed beds that provide protection for prey species and forage.
At the same time, high flushing rates within Noxon Reservoir will keep walleye densities low and
recruitment should be limited most years. In productive years, walleye fry will be predated on
heavily by other fish in the system. There have been reports of caught smallmouth commonly
disgorging walleye minnows in the upper reservoir areas in recent years.

Many anglers and their families do travel to the area providing valuable economic benefits and a
stable controlled walleye fishery will increase the number of anglers and spread the interest of
existing anglers over a wider array of species. This will reduce pressure on the historical targets in
the reservoir. In addition to Northern Pike and Perch, Walleye also will become a target species
during the winter months augmenting angler interest and satisfaction during that important
period. FWP expresses great concern that walleyes will result in declines of desirable species. We
would suggest that the public be allowed to weigh in on what species they view as desirable and of
benefit in the reservoir. We also would argue that the successful management of walleye would
benefit the public, the economy and the other desirable and important species in the fishery.
Spring fishing for walleye beginning in late March is already a significant benefit.

Review of the Bull Trout Recovery Plan (BTRP), Clark Fork River Recovery Chapter reveals that the
single most important component affecting bull trout is the presence of dams, both large and
small, that impact migration, water levels, quality and temperature. Perhaps the resources for
suppression should be redirected towards promoting bull trout migration around Noxon Rapids
10
Dam and other impoundments but hopefully not to the point of excluding support for species the
fishing public desires.

While FWP argues that walleye preying on salmonid fry may be significant, it remains to be proven.
It is more reasonable to argue that the huge number of NPM in Noxon and other impoundments
have a much more significant impact on juvenile fish of all species. Horn’s 2009 study did show
limited walleye congregations near tributaries but there is no direct evidence that they are there to
prey on bull trout. The NPM stay in those areas year-round as the walleyes move downstream
after the spring spawn. Horn’s study most often found walleyes at depths of 25 feet or more
during the majority of the year and walleye presence at the mouths of a few salmonid tributaries
for relatively short periods may be more coincidental than by design. The bottom contours are
affected by the streams and the walleye are attracted to that element of structure and are most
often situated upstream of the actual tributary mouth and are ambushing prey drifting down in the
current of the main stem of the river. This observation is based on fishing experience, the use of
electronic sonar and underwater cameras.

Further review of the BTRP reveals that “of particular concern is the expansion of congeneric lake
trout and brook population”. The plan goes on to list forestry practices, agricultural impacts,
transportation systems, mining and other human activities as items of the most concern. We
would argue that control of lake and brook should have priority over concerns for other less
threatening species that actually thrive naturally (reproduce successfully) in the reservoir including
bass, perch, northern pike and walleye.

Information obtained from Jerry Shively (Thompson Falls), concerning the spawning requirements
of the bull trout, show that bull trout and brown trout spawn in the same river structure (e.g.,
Graves Creek), but at a 2 degree water temperature difference. He has observed brown trout
spawning on top of and flushing the bull trout eggs out of the redd's, as the brown trout lay their
own eggs, two weeks after the bull trout. This may be a factor in the population levels and ESA
listing of bull trout. The brown trout were a legal and authorized introduction to Noxon Reservoir
by FWP.

Walleye abundance is low in the reservoir and 2012 net surveys and angler information indicates
that the numbers may actually be decreasing. Spawning interference occurs naturally some years
and because spawning is largely limited to one compact area, the existing population is unlikely to
“explode”. There is not a stable or significant area for walleyes to be consistently successful at
spawning. No alternative sites have been identified. This may explain why it has taken 25 years for
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expansion to the modest existing population. It is purely speculative to suggest that walleye are
reaching a threshold of rapid expansion.

FWP raises the issue of Canyon Ferry Reservoir as an example of negative walleye impact. Today,
Canyon Ferry hosts the state’s largest Walleye tournament, the Canyon Ferry Walleye Festival, and
two other family non-profit walleye tournaments, Broadwater Rod & Gun Walleye Derby and the
Camp Mak-A-Dream Derby, which were initially opposed and denied approval by FWP. These great
events bring in critical dollars to the surrounding economy and are huge family and social occasions
with vacations and reunions centered on the events. Changes in stocking policy and regulations
also allow a healthy and popular trout fishery. The economic and social value of the fishery is
critical to Townsend and the surrounding area. We would argue that an earlier adjustment of
policy at Canyon Ferry and responsiveness to local wishes would have allowed this great fishery to
stabilize and prosper sooner. We would also request that the opportunity for families and friends
to enjoy the recreational benefits of walleye fishing not be denied by FWP, Avista or the US Fish &
Wildlife Service. FWP has the talent to achieve the same success in Noxon Rapids Reservoir.

NWWFA believes strongly that the existing desirable warm water species in Noxon Reservoir
deserve to be again supported by FWP. It is our understanding that no planting of bass or
development of structure has been undertaken since before 1998. Jim Vashro has stated that it
takes 10 to 15 years for a largemouth bass to reach trophy size in Noxon and we do not think it is a
coincidence that big bass seem to be diminishing 15 years after FWP stopped planting fish. We
request that FWP investigate and develop a plan for immediately resuming support of the longexisting and valuable bass fishery. We believe the public interest will be much better served by
resuming support of largemouth than by attempting to eradicate walleye. We question where, for
the past 15 years, the funds have been used that once were designated for support of the bass
fishery.

NWWFA further believes that FWP size and limit regulations for bass are largely unenforced and
that the fishing public is sometimes unaware and otherwise often abuses the fishery. A review of
the enforcement patrol records for Noxon and Cabinet for the 5 years of 2008-2012 reveals that a
total of 2 citations and approximately 4 warnings were issued for possession violations of bass. We
believe enforcement needs to be dramatically increased and the local bass clubs have told us that
they agree.

We have also noted that due to late spawning, bass are consistently and persistently disrupted and
we suggest that the regulations be reviewed and modified to protect spawning bass later in the
season. We believe the bass professionals and tournament operators can be helpful to the FWP
12
and should be consulted to establish adjustments that will better protect the fish and the resource
even if it requires some modification to derby formats.

Finally, we as a group want to assure FWP and the public that we strongly believe Noxon Reservoir
is a remarkable asset that deserves the utmost care and consideration. The recreational and
sporting opportunities that Noxon offers are invaluable to local residents and visitors. We ask that
our FWP people access and apply the talent and knowledge necessary to promote a stable and
prosperous walleye fishery and reinvest in the other warm water species that co-exist in the
reservoir.
Respectively submitted on March 27, 2013
Noxon Warm Water Fisheries Association, a Montana Corporation
PO Box 8599, Missoula, MT 59807
nwwfa@montana.com
Paul O. Rossignol, President
John L. Wozniak, Vice President
Arlyn F. Lemer, Treasurer
Scott M. Muller, Secretary
Mark Weed, Membership Coordinator
Robert H. Hickey, Jr., Director
References, sources and citations available upon request.
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