Thank you for the opportunity to serve as a peer reviewer for the downlisting of
Oregon chub (Oregonichthys crameri) from endangered to threatened. I am
supportive of the downlisting and think it is appropriate given the current status of
the species and the continuing but reduced threats to its recovery. Below I provide
some comments on specifics of the analysis presented in the Federal Register
notice, (50 CFR Part 17; Vol. 74, No 93, May 15, 2009); clarify implications of
inclusion of species on Oregon Department of Game and Inland Fisheries’
(ODFW) sensitive species list; and recommend future work and assessment.
While the current status of Oregon chub populations does not completely meet all
downlisting criteria, (i.e., only two of the recommended three populations meet
criteria in the Santiam sub-basin), overall population numbers and trends across
the range of the species are such that the level of stability needed to qualify for
threatened status have been met. Thresholds established by other criteria in the
other two sub-basins have been surpassed. There are nineteen populations of 500
or more adults throughout the range. The downlisting “threshold” was ten. Sixteen
of these nineteen populations have stable or increasing trends. These are
distributed as such: the mainstem Willamette sub-basin (including the McKenzie
and Coast Fork) has six, the Middle Fork Willamette sub-basin has eight, and, as
mentioned above, the Santiam sub-basin has two.
Continued recovery of Oregon chub is jeopardized by a variety of factors. The
most significant threats currently are predation by non-native fish species and
habitat degradation. These threats are in part related in that habitat alterations
such as damming to create reservoirs and channelization have created situations
that benefit non-native predators. In addition, there are sites connected to flowing
water such as backwater sloughs and side channels that contain excellent habitat
for Oregon chub. However, chub are frequently absent from these habitats when
non-natives are present.
Predation by non-natives is one of the biggest concerns for long-term recovery and
maintenance of Oregon chub populations. Reconnection and restoration of
historical back channels and sloughs to provide for movement between
populations is essential to full recovery. However, introducing and maintaining
Oregon chub populations in these habitats will be difficult with predatory non-
natives present. Currently, Oregon chub populations are most successful in
isolated ponds.
Downlisting is warranted but before delisting can be considered, rigorous studies
and experimentation should be completed that evaluate the possibility of
establishing stable chub populations in reconnected habitats. Most of the extant
populations of Oregon chub are isolated with no natural genetic exchange. These
isolated populations should be monitored for evidence of genetic drift or
inbreeding, and a plan developed to address these issues should they arise.
Providing natural genetic exchange through habitat connection is the most
desirable outcome but may not be possible pending the outcome of studies
mentioned above and in the Willamette Biological Opinion. These issues should
continue to be a focus of the Service and the Oregon Chub Working Group
In addition to predation, non-native species potentially pose threats to Oregon
chub through competition and the introduction of diseases and parasites. It is
uncertain whether these threats are realized and if so, the extent of their impact.
This area is worthy of study.
Several state and federal agencies have implemented strategies to improve habitat
quality for Oregon chub. These strategies should be commended and encouraged
to continue and expand. Currently under consideration is a programmatic Safe
Harbor Agreement which would streamline the process to enroll willing landowners
into an agreement to introduce chub on their property. To date, introductions of
Oregon chub into off-channel and isolated ponds have been very successful. This
programmatic SHA would allow the ODFW to continue and perhaps increase the
number of successful introductions.
Despite all of these efforts, threats to habitat quality continue and should be
monitored. Habitat threats include spills and run-off from nearby roads and
railroads, siltation from land use practices including agriculture, development and
logging; and nutrient enrichment resulting in eutrophication and anoxic conditions.
The Federal Register notice indicated that the Service and the U.S. Environmental
Protection Agency are coordinating through the Section 7 consultation process to
evaluate effects of various pollutants on Oregon chub and assess the adequacy of
current water quality standards. This coordination is important to the success of
Oregon chub as many of the extant populations and potential future introductions
are or will be in altered landscapes, largely agricultural. A thorough understanding
of the effects of widely used fertilizers, herbicides, and pesticides is essential.
Another relatively recent development was the issuance of the Biological Opinion
for the U.S. Army Corps of Engineers’ Willamette Project. Successful
implementation of the measures outlined in the Opinion should maintain and
improve habitat for chub and provide answers to some important research
questions. Adequate funding must be provided for this to come to fruition.
In regards to the overall condition of habitat for Oregon chub, I agree with the
conclusion that the species is not in imminent danger of extinction. However,
without continued protections of threatened status under the Endangered Species
Act, it could slip back to endangered status.
Current regulations would not likely provide the Oregon chub with the protections
necessary to avoid serious decline should the species be removed from the
Service’s threatened and endangered species list. However, moving the species to
threatened status would result in continued protection and not affect continued
efforts at recovery.
I would like to clarify the implications of a species inclusion on the ODFW
Sensitive Species List. While within the Oregon Department of Fish and Wildlife
the list has limited regulatory consequences, several other state agencies refer to
the Sensitive Species List when making regulatory decisions. These include the
Oregon Department of State Lands, the Water Resources Department, and the
Oregon State Marine Board. The Oregon chub continues to be included on the
Sensitive Species List as a sensitive-critical species and is thus afforded
protection under these rules and regulations.
The Service assessed the issue of whether the downlisting should apply across
the range of Oregon chub or if portions of the range should be listed separately. I
agree with the assessment that each of the sub-basins represents a significant
portion of the range of the species in that each significantly contributes to
representation, resiliency, or redundancy of the species. It is also reasonable to
consider the threats to be evenly distributed across the range of Oregon chub.
Therefore, based on these analyses, downlisting the Oregon chub throughout its
range is appropriate. However, efforts to target recovery actions in the Santiam
sub-basin where downlisting criteria have not been met should be encouraged and
supported.
In summary, recovery activities to date have substantially improved the status of
Oregon chub to a level which merits downlisting to threatened by the U.S. Fish
and Wildlife Service. Success in reaching future recovery goals to de-list Oregon
chub will require continued support and cooperation among natural resource
partners. This can be facilitated through continued activity of the Oregon Chub
Working Group. Research is needed into questions of restoring chub in connected
habitats, establishing genetic exchange between populations, and responses of
chub to changes in hydrology. In addition, more targeted conservation actions in
the Santiam sub-basin are needed to bring the populations in that recovery area
up to the level of recovery seen in the other sub-basins and provide redundancy
and resiliency to the species.
Thank you for the opportunity to review this proposal.
Comment on FR Doc # E9-11322
This is comment on Proposed Rule
Endangered and Threatened Wildlife and Plants; Proposed Rule To Reclassify the Oregon Chub (Oregonichthys crameri) From Endangered to Threatened
View Comment
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