arthur carhart national wilderness...

2015 BTNF_Mystery/Dime MRDG

MRDG Step 1: Determination 1

ARTHUR CARHART NATIONAL WILDERNESS TRAINING CENTER

MINIMUM REQUIREMENTS DECISION GUIDE

WORKBOOK “…except as necessary to meet minimum requirements for the administration of the area for the purpose of this Act…”

-- The Wilderness Act of 1964

MRDG Step 1: Determination

Determine if Administrative Action is Necessary

The Wyoming Game and Fish Department (WGFD), in cooperation with the Bridger-Teton National Forest (BTNF), is working on a proposed restoration project for Dime Lake and a portion of Dime Creek, approximately 41 miles north of Jackson, Wyoming and Mystery Lake and a portion of Mystery Creek, approximately 60 miles northeast of Jackson, Wyoming. The proposed restoration project would enhance native Columbia spotted frog populations, remove a threat to the native cutthroat trout in the Snake River drainage, and re-establish native Yellowstone cutthroat trout populations in Mystery Lake. Both lakes are in the Teton Wilderness. Yellowstone cutthroat trout (YCT; Oncorhynchus clarkii bouvieri;) historically occupied 17,721 miles of habitat in the western United States. Yellowstone cutthroat trout currently occupy 7,528 miles (43%) of their historic habitats. Only 3,000 miles (17%) of these historic streams contain genetically unaltered YCT. Yellowstone cutthroat trout were petitioned for listing under the Endangered Species Act (ESA) and a determination of not warranted was issued by the U.S. Fish and Wildlife Service (FWS). The Federal Register notice of the FWS finding on the YCT listing petition appeared on February 21, 2006. The finding explicitly stated that the FWS considered the large-spotted (Yellowstone) and fine-spotted (Snake River) cutthroat trout (SRC: Oncorhynchus clarkii ssp) form as a single entity, as petitioned. The consideration of the fine-spotted Snake River cutthroat trout as distinct from the Yellowstone cutthroat trout is based primarily on morphology, in particular the much smaller size and larger numbers of spots on the fine-spotted variety (Van Kirk et al 2006). Wyoming Game and Fish Department manages

Project Title: Dime and Mystery Lake Restoration Project

Description of the Situation What is the situation that may prompt administrative action?



Yellowstone and Snake River cutthroat trout as two distinct subspecies. For this project, YCT and SRC will be considered together and abbreviated as YCT. The Columbia spotted frog is on the Intermountain Regional Forester’s list of Sensitive Species due to viability concerns and because it is only found within rare habitats. It is also on the WGFD’s list of species of greatest conservation need. Columbia spotted frogs are also on the sensitive species list of the Wyoming Natural Heritage Program, and the statewide population is at moderate risk of extinction. Yellowstone cutthroat trout and Columbia spotted frog (Rana luteiventris) are native species that are also Management Indicator Species (MIS) on the BTNF and designated Sensitive Species in Region 4 of the United States Forest Service (USDA Forest Service 2013). The WGFD considers YCT and Columbia spotted frog as species of greatest conservation need in the state due to declining range-wide populations. Threats to the species include disease, habitat loss, competition and, for YCT, hybridization with non-native trout (Range-wide YCT Conservation Team 2009). The presence of previously stocked brook trout and rainbow trout in Dime and Mystery lakes and creeks has the potential to compromise the integrity of native YCT populations throughout the Buffalo Fork and Snake River drainages. Currently, Dime Lake and Dime Creek above the lake hold a large population of brook trout ranging in size from 3-9 inches. As a tributary to the Snake River, this brook trout population is a potential source of brook trout to the main stem Snake River and its other tributaries above Jackson Lake. The problems associated with brook trout presence in cutthroat trout waters are well documented, mostly consisting of displacement of the cutthroat trout due to competition. The removal of a source brook trout population may significantly reduce the opportunity for brook trout to become a problem in the Snake River headwaters. In addition, Dime Creek above Dime Lake is home to a healthy population of Columbia spotted frogs. Trout are known predators to amphibians during several life stages. Mystery Lake currently contains rainbow trout and brook trout that were introduced through stocking in the 1950’s. Mystery Lake is located in the upper Buffalo Fork drainage and is a potential headwaters source for rainbow trout throughout the Snake River drainage. Rainbow trout up to 20 inches and brook trout up to 16 inches have been caught during gill netting. Rainbow trout are a close relative to cutthroat trout that competes with and are also able to hybridize with cutthroat trout. Non-native trout displace native cutthroat trout due to competition. Non-native trout are the biggest threat to the persistence of cutthroat trout. Mystery Lake is one of a few waters in the Snake River headwaters that have a self-sustaining population of rainbow trout. Mystery Lake and Creek are tributaries to Cub Creek. A drainage survey of Cub Creek indicates rainbow trout have not spread throughout the drainage yet; however, as environmental conditions change, so does the potential for rainbow trout to expand and become an increased threat to native YCT.



☐ YES STOP – DO NOT TAKE ACTION IN WILDERNESS

☒ NO EXPLAIN AND COMPLETE STEP 1 OF THE MRDG Explain: Dime and Mystery Lakes and Dime and Mystery creeks are situated in the Teton Wilderness making the option of an alternative action outside wilderness not possible. Removal of rainbow and brook trout from Mystery Lake and Creek and brook trout from Dime Lake and Creek would help protect pure population of YCT throughout the Snake River drainage. Competition and hybridization with non-native trout are threats to the persistence of pure populations of YCT. Dime Lake, Dime Creek, Mystery Lake, and Mystery Creek are some of the few locations where chemical treatment to remove non-native trout to benefit native trout and amphibians is feasible in the Snake River headwaters. A steep canyon below Dime Lake will not allow for any fish species to re-colonize the lake and no post-treatment fish stocking is planned, which will benefit the Columbia spotted frog population. Mystery Lake and Mystery Creek (above the lake) contain rainbow trout and brook trout that were introduced through stocking in the 1950’s. There is no source for rainbow trout to re-colonize Mystery Lake after removal.

A. Valid Existing Rights or Special Provisions of Wilderness Legislation

Is action necessary to satisfy valid existing rights or a special provision in wilderness legislation (the Wilderness Act of 1964 or subsequent wilderness laws) that requires action? Cite law and section.

☐ YES ☒ NO Explain: Section 4d (8) of the Wilderness Act recognizes the role of state fish and wildlife agencies in management of populations in wilderness. Management actions within wilderness may be conducted to re-establish or perpetuate an indigenous species. .

B. Requirements of Other Legislation Is action necessary to meet the requirements of other federal laws? Cite law and section.

Options Outside of Wilderness Can action be taken outside of wilderness that adequately addresses the situation?

Criteria for Determining Necessity Is action necessary to meet any of the criteria below?



☐ YES ☒ NO Explain: There are no requirements from other federal laws.

C. Wilderness Character Is action necessary to preserve one or more of the qualities of wilderness character, including: Untrammeled, Undeveloped, Natural, Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation, or Other Features of Value? UNTRAMMELED

☐ YES ☒ NO Explain: Although this action is not necessary to preserve the “Untrammeled” wilderness character, it proposes to correct past intentional human caused manipulation of “the earth and its community of life”. This intentional human caused manipulation was the stocking of non-native brook trout and rainbow trout into Dime and Mystery lakes and creeks, creating a source of displacement through competition from both brook and rainbow trout and hybridization with rainbow trout on native trout. UNDEVELOPED

☐ YES ☒ NO Explain: Action is not necessary to preserve the undeveloped character of the Teton Wilderness. NATURAL

☒ YES ☐ NO Explain: Action is needed to preserve the “Natural” wilderness character. The natural quality has been degraded by the introduction of non-native trout into Dime and Mystery lakes and creeks. The presence of non-native trout presents a threat to native trout and represents a continued potential adverse effect to the ecological system of the Snake River drainage inside wilderness and downstream outside wilderness.



SOLITUDE OR PRIMITIVE & UNCONFINED RECREATION

☐ YES ☒ NO Explain: Action is not necessary to preserve the “outstanding opportunities for solitude or a primitive and unconfined type of recreation” character. However, restoring native fish populations will improve primitive and unconfined recreation for fishing. OTHER FEATURES OF VALUE

☒ YES ☐ NO Explain: Action is necessary to preserve a “unique component” of the Teton wilderness. Snake River cutthroat trout are a unique component of the Teton Wilderness and the upper Snake River system because the region contains the core of the historic population. Furthermore, the Columbia spotted frog is only found within rare habitats (including the upper Snake River system) and is on a list of species of greatest conservation need. Yellowstone cutthroat trout also historically occupied the Upper Snake River system. Restoring native fish and fauna in the Greater Yellowstone Ecosystem is a goal of the Bridger-Teton NF (USDA Forest Service 1990, pg. 118) and a priority for the WGFD.

Decision Criteria

A. Existing Rights or Special Provisions ☐ YES ☒ NO

B. Requirements of Other Legislation ☐ YES ☒ NO

C. Wilderness Character

Untrammeled ☐ YES ☒ NO

Undeveloped ☐ YES ☒ NO

Natural ☒ YES ☐ NO

Outstanding Opportunities ☐ YES ☒ NO

Other Features of Value ☒ YES ☐ NO Is administrative action necessary in wilderness?

Step 1 Decision Is administrative action necessary in wilderness?



☒ YES EXPLAIN AND PROCEED TO STEP 2 OF THE MRDG

☐ NO STOP – DO NOT TAKE ACTION IN WILDERNESS Explain: Action is necessary in the Teton wilderness to preserve and enhance the natural character and a unique component of the Teton wilderness. The natural quality has been degraded by the introduction of non-native trout into Dime and Mystery lakes and creeks and the presence of the non-native trout threatens natives and presents a continued potential adverse effect to the ecological system of the Snake River drainage. Furthermore, the Teton wilderness possesses a unique component as it holds populations of Snake River cutthroat trout, Yellowstone Cutthroat trout, and Columbia Spotted Frog. The populations of these unique species are threatened by the presence of non-native trout. The removal of a source brook trout population may significantly reduce the opportunity for brook trout to become a problem in the Upper Snake River. By removing the brook trout population from Dime Lake, the Columbia spotted frog population may be able to increase its numbers. A steep canyon below Dime Lake will not allow for re-colonization of the lake by other fish species, including non-native species. Non-native trout are the greatest threat to the persistence of cutthroat trout in Mystery Lake. Rainbow trout, a close relative, competes with but also readily hybridizes with cutthroat trout. Removing the rainbow trout population would eliminate a threat to the persistence of cutthroat trout throughout the Snake River drainage.

MRDG Step 2 7

MRDG Step 2 Determine the Minimum Activity

☒ YES DESCRIBE OTHER DIRECTION BELOW

☐ NO SKIP AHEAD TO TIME CONSTRAINTS BELOW Describe Other Direction: Species of greatest conservation need in the state and USFS Sensitive Species require management to prevent listing under ESA. Conservation actions to preclude listing include maintaining genetic integrity, habitat and population expansion and protection. This project is designed to meet these conservation actions. In addition, State law 78 Stat. 896 (8) describes state jurisdiction in managing fish and wildlife in national forest wilderness in cooperation with the U.S. Forest Service. Moreover, the Bridger-Teton National Forest Plan (USDA Forest Service 1990) sensitive species management standard states that the Forest Service will cooperate with the Wyoming Game and Fish on management programs when needed to maintain population objectives of these species, especially with species which have been identified as needing immediate attention and active management to ensure a significant decline in breeding populations do not occur. Furthermore, the proposed project conforms to direction in the Policies and Guidelines for Fish and Wildlife Management in National Forest Wilderness Manual, Chapter 2323.32 (USDA Forest Service 2007). Guidelines for fish and wildlife management in USFS administered wilderness areas specify that chemical treatment may be necessary to prepare waters for the reestablishment of indigenous fish consistent with approved wilderness management plans, to conserve or recover federally listed threatened or endangered species, or to correct undesirable conditions resulting from human activity. Proposals for chemical treatment will be considered and may be authorized by the Federal administering agency through application of the Minimum Requirements Decision Process (MRDP) as outlined in Section E., General Policy. Any use of chemical treatments in wilderness requires prior approval by the Federal administering agency. Guidelines for Chemical Treatment

Other Direction Is there “special provisions” language in legislation (or other Congressional direction) that explicitly allows consideration of a use otherwise prohibited by Section 4(c)?

AND/OR

Has the issue been addressed in agency policy, management plans, species recovery plans, or agreements with other agencies or partners?


MRDG Step 2 8

a) Use only registered pesticides according to label directions. b) In selecting pesticides, give preference to those that will have the least impact on

non-target species and on the wilderness environment. c) Schedule chemical treatments during periods of low human use, insofar as

possible. Immediately dispose of fish removed in a manner agreed to by the Federal administering agency and the State agency. FSM 2323.34 emphasizes the quality and naturalness in managing fisheries in wilderness. FSM 2323.34f states that chemical treatment may be used to prepare waters for reestablishment of indigenous, threatened or endangered, or native species, or to correct undesirable conditions caused by human influence. The Regional Forester approves all proposed uses of chemicals in wilderness according to Forest Service Manual 2150 (USDA Forest Service 2014). Region 4 of the Forest Service is a signatory to a conservation agreement for YCT in the States of Idaho, Montana, Nevada, Utah and Wyoming (Gresswell 2009). Pursuant to the conservation agreement the Forest Service has agreed to the following pertaining to this project: Goal: Ensure the persistence of the YCT subspecies (including SRC) within its historic range. Manage YCT to preserve genetic integrity and provide adequate numbers and populations to provide for protection and maintenance of intrinsic and recreational values associated with this fish. The cooperators envision a future where threats to wild YCT are either eliminated or reduced to the greatest extent possible.

• Objective 2. Secure and enhance conservation populations including suppression or eradication of non-native fish species that are adversely affecting native YCT.

Secure and if necessary enhance all known and suspected genetically pure YCT populations of all life history forms. These efforts might include suppression or eradication of non-native fish species that are adversely affecting native YCT.

• Objective3. Restore populations within their native range. Increase the number of populations by restoring YCT within their broad historic range. Local restoration goals and approaches will be developed to meet this objective, but the typical approaches will likely include: eliminating non-native fish and reintroducing native fish.

• Objective 5: Public outreach


MRDG Step 2 9

Develop and implement a public outreach effort specifically addressing YCT conservation. Specific outreach may focus on impacts associated with non-native fish introductions and the need and importance of non-native removal projects.

• Objective 6: Data sharing Continue to build and maintain the YCT database so that information can readily be shared between and among jurisdictions.

• Objective 7: Coordination Maximize effectiveness of YCT conservation efforts by coordinating signatory efforts toward achieving the aforementioned goals and objectives. The Wyoming Game and Fish Commission has entered into a Memorandum of Understanding (MOU) with the Forest Service, United States Department of Agriculture Rocky Mountain Region and Intermountain Region for Fish, Wildlife and Habitat Management within National Forest Wilderness in Wyoming (Wyoming Game and Fish Commission; USDA Forest Service 2010). The MOU directs the Forest Service to “Recognize that registered piscicide applications to remove unwanted aquatic species on NFS lands in Wyoming, consistent with label requirements, are a state action to be conducted by the Wyoming Game and Fish. The Forest Service will work with the Wyoming Game and Fish to complete the minimum requirements analysis to protect wilderness values, and if determined the minimum necessary, authorize those activities and complete the appropriate level of NEPA. The WGFD will “Participate with the Forest Service in developing the MRDG for projects that require Forest Service approval, especially those that trigger a NEPA decision and an agency action. Where it is determined mutually beneficial the Wyoming Game and Fish project manager may complete an initial MRDG for the development of a proposed action for the NEPA process.” In addition the WGFD will “Notify and coordinate with the Forest Service on any piscicide application proposal to remove unwanted aquatic species within wilderness in Wyoming. Provide sufficient lead-time to accomplish the analysis/authorization process associated with piscicide applications within wilderness.”

If chemical treatment is selected, it would be applied in late summer for one work week at each lake to ensure complete removal of the target fish species. This would be the most effective treatment in terms of ensuring non-native fish removal and other organisms. It would have short-term impacts on non-target aquatic organisms and gill-breathing invertebrates. Aquatic invertebrates are expected to re-colonize the treated areas within one year through downstream drift and aerial dispersion. Impacts to amphibian populations would be reduced

Time Constraints What, if any, are the time constraints that may affect the action?


MRDG Step 2 10

or avoided by treating the lakes in late summer or early fall when tadpoles metamorphose into adults that are no longer gill dependent. If mechanical removal is selected, treatment would be between July and September (depending on when the ice melts off the lake) and would be treated for multiple years for multiple weeks at a time.

Component X: Example: Transportation of personnel to the project site

Component 1: Transportation of personnel to the project site

Component 2: Transportation of equipment

Component 3: Tools used at the project sites

Component 4: Ground disturbance at the lake access

Component 5: Disposal of dead fish following the treatment

Component 6: Condition of the site following the treatment

Component 7: Restocking Mystery Lake following the treatment

Component 8:

Component 9:

Proceed to the alternatives.

Refer to the MRDG Instructions regarding alternatives and the effects to each of the comparison criteria.

Components of the Action What are the discrete components or phases of the action?

http://www.wilderness.net/MRDG/documents/MRDG_instructions.pdf


MRDG Step 2: Alternative 1 11

MRDG Step 2: Alternatives Alternative 1: Chemical Removal

Dime Lake and Creek and Mystery Lake and Creek would be treated with the piscicide rotenone to remove non-native brook and rainbow trout. Potassium permanganate would be used to detoxify the outflow of both lakes and would be applied within one week post treatment. Liquid rotenone would be applied using containers with a metered outflow to achieve a specific concentration in the targeted lakes and streams. Potassium permanganate would be applied as a powder in an amount necessary to detoxify the rotenone applied to the lakes and streams. Treated fish would be allowed to decompose in the lakes and streams naturally providing nutrients and help reestablish aquatic richness. Treated/dead fish would be collected, the air bladders deflated, and placed in the deepest area of the lakes to decompose. Proper permits for chemical treatment would be obtained and applied in order to meet the direction and intent of the Federal Water Pollution Act (Clean Water Act). The state would provide certified applicators and would strictly adhere to application and direction guidance. The piscicide would be transported to the job site by pack stock and applied by hand. Both lakes would be closed to the public for two weeks for camping and fishing. Mystery Lake will be stocked with SRC one year after the chemical treatment. Dime Lake will not be stocked with fish. Dime Lake should become prime habitat for expansion of the population of Columbia spotted frogs. Logistics for Dime Lake: Approximately 15 people will be needed for the project. Pack stock would transport equipment and gear. Approximately four head of stock would take two trips in to deliver gear and two trips out to remove gear. Five people would be camped at the lake for the week and ten would be day hiking back and forth to the project site. Crews would camp at either Sheffield Campground or Flagg Ranch. There is not a system trail to the lake. Logistics for Mystery Lake: Approximately 10 people will be needed for the project. Pack stock would transport equipment and gear. Approximately four head of stock would take four trips in and four trips out to deliver and remove gear. Crews would be camped at sites close to Morgan Lake. Initially the crews would be travelling on a system trail, but then would travel to the lake on a non-system trail from Cub creek.

Component of the Action Activity for this Alternative

X Example: Transportation of personnel to the project site

Example: Personnel will travel by horseback

1 Transportation of personnel to the project Personnel will travel by horseback or on

Description of the Alternative What are the details of this alternative? When, where, and how will the action occur? What mitigation measures will be taken?

Component Activities How will each of the components of the action be performed under this alternative?



site foot.

2 Transportation of chemical and equipment used for application that would include non-motorized small boats, safety equipment (gloves, goggles, etc.) and personal gear.

Packstock will transport the bulk of the equipment used for the alternative and small items will be packed in by personnel.

3 Tools used at the project sites Using hand sprayers, drip containers, and small kayaks or rafts.

4 Chemical used at the project sites Application of rotenone.

5 Ground disturbance at the lake access Daily travel to and from project site by horses and personnel during the treatment.

6 Disposal of dead fish following the treatment

Personnel will collect dead fish following the treatment, puncture air bladders, and dispose of fish in deepest part of lake.

7 Condition of the site following the treatment Clean up of treatment area and camping sites.

8 Restocking Mystery Lake following the treatment

Mystery Lake will be stocked with SRC carried in by horseback one year after the chemical treatment.

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UNTRAMMELED Component Activity for this Alternative Positive Negative No Effect

X Example: Personnel will travel by horseback ☐ ☐ ☒

1 Personnel will travel by horseback or on foot. ☐ ☐ ☒

2 Packstock will transport the bulk of the equipment used for the alternative and small items will be packed in by personnel.

☐ ☐ ☒

3 Using hand sprayers, drip containers, and small kayaks or rafts.

☐ ☐ ☒

4 Rotenone used at project site ☐ ☒ ☐

5 Daily travel to and from project site by horses and personnel during the treatment.

☐ ☐ ☒

Wilderness Character What is the effect of each component activity on the qualities of wilderness character? What mitigation measures will be taken?



6 Personnel will collect dead fish following the treatment, puncture air bladders, and dispose of fish in deepest part of lake.

☐ ☒ ☐

7 Clean up of treatment area and camping sites. ☐ ☐ ☒

8 Mystery Lake will be stocked with SRC carried in by horseback one year after the chemical treatment.

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Total Number of Effects +1 -3 NE

Untrammeled Total Rating -2 Explain: Using packstock and tools does not affect the untrammeled character; however applying rotenone, collecting fish, and restocking will negatively affect the untrammeled character because that action manipulates the components of the ecological system. The presence of non-native trout shows previous trammeling and restoring the lakes to native systems will require trammeling, but the effect will also be positive once the systems are restored to native populations.

UNDEVELOPED Component Activity for this Alternative Positive Negative No Effect




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4 Rotenone used at project site ☐ ☐ ☒


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Total Number of Effects 0 0 NE

Undeveloped Total Rating 0 Explain: Utilizing stock, temporary use of non-motorized and non-mechanized tools are not developments.

NATURAL Component Activity for this Alternative Positive Negative No Effect




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4 Rotenone used at project site ☒ ☒ ☐


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Natural Total Rating 0 Explain: The use of packstock and tools does not affect the natural quality. Application of rotenone has both positive and negative effects as it will kill non-native fish as well as native fish, gill-breathing invertebrates, and other aquatic organisms. Restocking with native trout will improve the natural quality of wilderness character. Project design features, such as fall application, would reduce impacts to non-target aquatic organisms.



SOLITUDE OR PRIMITIVE & UNCONFINED RECREATION Component Activity for this Alternative Positive Negative No Effect




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4 Rotenone used at project site ☐ ☒ ☐


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Solitude or Primitive & Unconfined Rec. Total Rating 0 Explain: Encountering packstock and personnel for one week will have a minimal effect on visitor recreation experiences. Stocking with native trout will be positive for primitive and unconfined recreation for fishing experiences. The lakes will be closed to the public for camping and fishing for two weeks because of the rotenone; however there is no system trail to either lake and neither is used heavily by the public.

OTHER FEATURES OF VALUE Component Activity for this Alternative Positive Negative No Effect



2 Packstock will transport the bulk of the equipment ☐ ☐ ☒



used for the alternative and small items will be packed in by personnel.


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4 Rotenone used at project site ☒ ☐ ☐


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Total Number of Effects +2 0 NE

Other Features of Value Total Rating +2 Explain: Restoring native fish populations will improve ecological conditions, protect a historical fish population, and provide habitat for Columbia spotted frogs.

TRADITIONAL SKILLS Component Activity for this Alternative Positive Negative No Effect


1 Personnel will travel by horseback or on foot. ☒ ☐ ☐


☒ ☐ ☐


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4 Rotenone used at project site ☐ ☐ ☒

Traditional Skills What is the effect of each component activity on traditional skills?




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Traditional Skills Total Rating +5 Explain: Traditional skills are maintained by the use of packstock for transporting personnel, gear, and equipment. There is no use of mechanized or motorized tools.

COST Component Activity for this Alternative Estimated Cost

X Example: Personnel will travel by horseback $1,900

1 Personnel will travel by horseback or on foot. $3,000


$26,000


4 Rotenone used at project site $6,500



7 Clean up of treatment area and camping sites.


$3,000

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Economics What is the estimated cost of each component activity?



Total Estimated Cost $38,500 Explain: The main costs associated with this alternative include horse rental ($3000x2), personnel costs, and chemicals ($6500). Other gear, including tools to apply chemicals, chemicals for the treatment, and camping gear, is already available. Personnel costs include time (~$22,000) and food (~$4,000).

RISK ASSESSMENT Probability of Accident

Severity of Accident Frequent Likely Common Unlikely Rare

Catastrophic: Death or permanent disability 1 ☐ 1 ☐ 2 ☐ 2 ☐ 3 ☒ Critical: Permanent partial disability or temporary total disability 1 ☐ 2 ☐ 2 ☐ 3 ☐ 4 ☒ Marginal: Compensable injury or illness, treatment, lost work 2 ☐ 3 ☐ 3 ☐ 4 ☐ 4 ☒ Negligible: Superficial injury or illness, first aid only, no lost work 3 ☐ 4 ☐ 4 ☐ 4 ☒ 4 ☐ Risk Assessment Low risk

Risk Assessment Code

1 = Extremely High Risk 2 = High Risk 3 = Moderate Risk 4 = Low Risk Explain: Although unlikely there are risks to backcountry travel using horses or on foot. All personnel will be qualified, attend necessary training, wear PPE, and use best management practices. All necessary safety precautions will be followed according to the chemical safety labels for application of rotenone.

Wilderness Character

Untrammeled -2

Undeveloped 0

Safety of Visitors & Workers What is the risk of this alternative to the safety of visitors and workers? What mitigation measures will be taken?

Summary Ratings for Alternative 1



Natural 0

Solitude or Primitive & Unconfined Recreation 0

Other Features of Value +2

Wilderness Character Summary Rating 0

Traditional Skills

Traditional Skills +5

Economics

Cost $38,500

Safety

Risk Assessment Low risk



MRDG Step 2: Alternatives Alternative 2: Mechanical Removal

Dime Lake and Creek and Mystery Lake and Creek would be treated with mechanical removal of rainbow and brook trout. Under the mechanical removal alternative, teams of workers would use battery powered backpack electrofishers, traps, and gill netting to remove non-native fish from the treatment area. No toxicants would be used. Treated fish would be allowed to decompose in the lakes and streams naturally providing nutrients and help reestablish aquatic richness. Treated/dead fish would be collected, the air bladders deflated, and placed in the deepest area of the lakes to decompose. There would be no closure to public use. Mystery Lake will be stocked with SRC one year after treatments are concluded. Dime Lake will not be stocked with fish. Dime Lake should become prime habitat for expansion of the population of Columbia spotted frogs. Logistics for both Mystery and Dime Lake Approximately 2-3 people would be needed at one time per site. Personnel would camp at the lakes for approximately 4 weeks per summer for 3+ years and then one week for restocking fish. Approximately four packstock would be needed and a minimum of 15 trips per lake.




1 Transportation of personnel to the project site

Personnel will travel by horseback or on foot.

2 Transportation of equipment used includes gill nets, small boats, backpack electro-fishing units, spare batteries, dip nets safety equipment (gloves, waders, etc.) and personal gear.

Packstock will transport the bulk of the equipment used for the alternative and small items will be packed in by personnel.

3 Tools used at the project sites Electrofishers and gill nets will be used to remove non-native trout.

4 Ground disturbance at the lake access Travel to and from project site by horses





and personnel during the removal of non-native trout.

5 Disposal of dead fish following the removal efforts.

Personnel will puncture air bladders of collected fish and dispose of fish.

6 Condition of the site following the removal efforts

Clean up of treatment area and camping sites.

7 Restocking Mystery Lake following the removal efforts.

Mystery Lake will be stocked with SRC carried in by horseback one year after the non-native trout removal is complete.

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3 Electrofishers and gill nets will be used to remove non-native trout.

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4 Travel to and from project site by horses and personnel during the removal of non-native trout.

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5 Personnel will puncture air bladders of collected fish and dispose of fish.

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7 Mystery Lake will be stocked with SRC carried in by horseback one year after the non-native trout removal is complete.

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Untrammeled Total Rating -2 Explain: Using packstock and non-mechanized tools does not affect the untrammeled character; however using mechanized tools, collecting fish, and restocking will negatively affect the untrammeled character because that action manipulates the components of the ecological system. Restocking fish is also a trammeling action, but the effect will also be positive once the systems are restored to native populations.





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Total Number of Effects 0 -1 NE

Undeveloped Total Rating -1 Explain: Utilizing stock, temporary use of tools are not developments. Using mechanized equipment is a development.



NATURAL Component Activity for this Alternative Positive Negative No Effect




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Natural Total Rating 0 Explain: The use of packstock and tools does not affect the natural quality. Using electrofishers and gill nets has both positive and negative effects as it will kill non-native fish as well as native fish. Restocking with native trout will improve the natural quality of wilderness character.





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3 Electrofishers and gill nets will be used to remove ☐ ☒ ☐



non-native trout.


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8 ☐ ☐ ☐

9 ☐ ☐ ☐


Solitude or Primitive & Unconfined Rec. Total Rating 0 Explain: Encountering packstock and personnel for one week will have a minimal effect on visitor recreation experiences. Stocking with native trout will be positive for primitive and unconfined recreation for fishing experiences.





☐ ☐ ☒


☒ ☐ ☐


☐ ☐ ☒


☐ ☐ ☒


7 Mystery Lake will be stocked with SRC carried in by horseback one year after the non-native trout removal

☒ ☐ ☐



is complete.

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Other Features of Value Total Rating +2 Explain: Restoring native fish populations will improve ecological conditions and protect a historical fish population.



1 Personnel will travel by horseback or on foot. ☒ ☐ ☐


☒ ☐ ☐


☐ ☒ ☐


☒ ☐ ☐


☐ ☐ ☒



☒ ☐ ☐

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Traditional Skills Total Rating +3




Explain: Traditional skills are maintained by the use of packstock for transporting personnel, gear, and equipment. Traditional skills are eroded by the use of electrofishers.



1 Personnel will travel by horseback or on foot. $9,000


$44,400




6 Clean up of treatment area and camping sites.


$3,000

8

9

Total Estimated Cost $56,400 Explain: The main costs associated with this alternative include horse rental ($3,000x4) and personnel costs. Other gear, including electrofishers, gill nets, small rafts, and camping gear, is already available. The overall costs are difficult to estimate as it is unknown how many years of effort are required for complete removal of non-native trout. Personnel costs include time (~$38,400) and food (~$6,000). Three years was used for this estimate.






Catastrophic: Death or permanent disability 1 ☐ 1 ☐ 2 ☐ 2 ☒ 3

Critical: Permanent partial disability or temporary total disability 1 ☐ 2 ☐ 2 ☐ 3 ☒ 4

Marginal: Compensable injury or illness, treatment, lost work 2 ☐ 3 ☐ 3 ☐ 4 ☒ 4

Negligible: Superficial injury or illness, first aid only, no lost work 3 ☐ 4 ☐ 4 ☒ 4 ☐ 4

Risk Assessment Low risk Risk Assessment Code

1 = Extremely High Risk 2 = High Risk 3 = Moderate Risk 4 = Low Risk Explain: Although unlikely there are risks to backcountry travel using horses or on foot. Many trips over multiple years would be required with this alternative, increasing those risks.


Untrammeled -2

Undeveloped -1

Natural 0

Solitude or Primitive & Unconfined Recreation 0

Other Features of Value +2

Wilderness Character Summary Rating -1

Traditional Skills

Traditional Skills +3

Economics





Cost $56,400

Safety




MRDG Step 2: Alternatives

Alternative 3: No-Action

The non-native fish species would not be removed from Dime and Mystery lakes and no-action would occur in wilderness.




1 No action would occur in wilderness No action would occur in wilderness

2

3

4

5

6

7

8

9








1 No action would occur in wilderness ☐ ☒ ☐

2 ☐ ☐ ☐

3 ☐ ☐ ☐

4 ☐ ☐ ☐

5 ☐ ☐ ☐

6 ☐ ☐ ☐

7 ☐ ☐ ☐

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Untrammeled Total Rating -1 Explain: Previous trammeling of the wilderness through the introduction of non-native fish species would continue to have adverse impacts on native species.



1 No action would occur in wilderness ☐ ☐ ☒

2 ☐ ☐ ☐

3 ☐ ☐ ☐

4 ☐ ☐ ☐

5 ☐ ☐ ☐

6 ☐ ☐ ☐

7 ☐ ☐ ☐

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Undeveloped Total Rating 0



Explain:

There would be no effect on the undeveloped wilderness character NATURAL Component Activity for this Alternative Positive Negative No Effect



2 ☐ ☐ ☐

3 ☐ ☐ ☐

4 ☐ ☐ ☐

5 ☐ ☐ ☐

6 ☐ ☐ ☐

7 ☐ ☐ ☐

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Natural Total Rating -1 Explain: The presence of non-native fish in Dime and Mystery lakes are not a natural condition. Not removing non-native trout would continue to reduce the naturalness of this area. The non-native brook and rainbow trout would continue to threaten native YCT and the Columbia spotted frog.




2 ☐ ☐ ☐

3 ☐ ☐ ☐

4 ☐ ☐ ☐

5 ☐ ☐ ☐



6 ☐ ☐ ☐

7 ☐ ☐ ☐

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Solitude or Primitive & Unconfined Rec. Total Rating -1 Explain: There would be a negative effect on primitive and unconfined recreation because of the loss of native fishing opportunities




2 ☐ ☐ ☐

3 ☐ ☐ ☐

4 ☐ ☐ ☐

5 ☐ ☐ ☐

6 ☐ ☐ ☐

7 ☐ ☐ ☐

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Other Features of Value Total Rating -1 Explain: No action would increase the risk for the historical native fish population and decrease the health of the ecological system because non-native brook trout and rainbow trout would expand and reduce native cutthroat trout populations due to competition for available resources, hybridization, and direct predation.





1 No action would occur in wilderness ☐ ☐ ☒

2 ☐ ☐ ☐

3 ☐ ☐ ☐

4 ☐ ☐ ☐

5 ☐ ☐ ☐

6 ☐ ☐ ☐

7 ☐ ☐ ☐

8 ☐ ☐ ☐

9 ☐ ☐ ☐


Traditional Skills Total Rating 0 Explain: There would not be any tool use under the no-action alternative



1 No action would occur in wilderness 0

2

3

4

5





6

7

8

9

Total Estimated Cost Explain: There will be no cost associated with the no-action alternative



Catastrophic: Death or permanent disability 1 ☐ 1 ☐ 2 ☐ 2 ☐ 3 ☒ Critical: Permanent partial disability or temporary total disability 1 ☐ 2 ☐ 2 ☐ 3 ☐ 4 ☒ Marginal: Compensable injury or illness, treatment, lost work 2 ☐ 3 ☐ 3 ☐ 4 ☐ 4 ☒ Negligible: Superficial injury or illness, first aid only, no lost work 3 ☐ 4 ☐ 4 ☐ 4 ☐ 4 ☒ Risk Assessment Low risk

Risk Assessment Code

1 = Extremely High Risk 2 = High Risk 3 = Moderate Risk 4 = Low Risk Explain: There will be no risk associated with the no-action alternative


Untrammeled -1

Undeveloped 0





Natural -1

Solitude or Primitive & Unconfined Recreation -1

Other Features of Value -1

Wilderness Character Summary Rating -4

Traditional Skills

Traditional Skills 0

Economics

Cost 0

Safety



MRDG Step 2: Alternatives Not Analyzed 36

MRDG Step 2: Alternatives

MRDG Step 2: Alternatives Not Analyzed

Other alternatives not analyzed 1. Similar to alternative 1, with the exception of packing out the treated dead fish.

This alternative was not analyzed because of the undo hazard to the workers, potential grizzly bear conflicts, and the significant increase in number of personnel and time needed to accomplish the mission.

2. Similar to alternative 1, with the exception of using the piscicide Antimycin. This alternative was not analyzed in detail because antimycin is less effective and there is no known use in Wyoming.

3. Using other mechanical tools such as augers were not considered because of they do not sufficiently mix chemicals, other natural elements such as wind negatively affects the treatment, and mechanical tools negatively effect on wilderness character by degrading the opportunity for solitude and traditional skills.

Alternatives Not Analyzed What alternatives were considered but not analyzed? Why were they not analyzed?


MRDG Step 2: Alternative Comparison 37

MRDG Step 2: Alternative Comparison Alternative 1: Chemical Removal

Alternative 2: Mechanical Removal

Alternative 3: No-Action

Alternative 4:

Wilderness Character Alternative 1 Alternative 2 Alternative 3

+ - + - + - Untrammeled 1 3 1 3 0 1

Undeveloped 0 0 0 1 0 0

Natural 2 2 2 2 0 1

Solitude/Primitive/Unconfined 1 1 1 1 0 1

Other Features of Value 2 0 2 0 0 1

Total Number of Effects 6 6 6 7 0 4

Wilderness Character Rating 0 -1 -4

Traditional Skills Alternative 1 Alternative 2 Alternative 3

+ - + - + - Traditional Skills 5 0 4 1 0 0

Traditional Skills Rating +5 +3 0

Economics Alternative 1 Alternative 2 Alternative 3

Cost $38,500 $56,400 $0

Safety of Visitors & Workers Alternative 1 Alternative 2 Alternative 3

Risk Assessment Low risk Low risk Low risk



MRDG Step 2: Determination

Refer to the MRDG Instructions before identifying the selected alternative and explaining the rationale for the selection.

☒ Alternative 1: Chemical Treatment

☐ Alternative 2:

☐ Alternative 3:

Explain Rationale for Selection: Alternative 1, chemical removal of rainbow and brook trout, has the least negative impact to wilderness character. WGFD feels that the Brook and Rainbow trout populations found within the Wilderness boundary pose a threat to the integrity of native fish populations in the Snake Headwaters System and action is needed to protect the system. While this action entails human manipulation of an aspect of the Wilderness resource, its intent is to correct past actions that introduced a non-native species to the ecosystem. This alternative does not apply any prohibited uses in the Wilderness Act. The benefits to wilderness character include increasing the natural quality by preventing further spread of non-native fish and by restoring YCT, SRT, and Columbia spotted frog habitat and populations. It also increases other values by protecting rare habitat for unique species, and increases unconfined recreation by providing a native fishing population source. The adverse effects to wilderness character include trammeling by manipulating an existing non-native fish population, temporary negative effects for the natural quality because of using a piscicide, and temporary effects for the unconfined recreation because of closures to the public. The temporary negative effects are outweighed by the long-term positive effects of ecological restoration of habitat and native species and preventing further spread of non-native species and decline of natural habitat. Although there are no legal requirements mandating the chemical removal, there are provisions in the Wilderness Act and other provisions that support alternative 1:

1. Section 4d (8) of the Wilderness Act recognizes the role of state fish and wildlife agencies in management of populations in wilderness

2. Species of greatest conservation need in the state and USFS Sensitive Species require management to prevent listing under ESA. Conservation actions to preclude listing include maintaining genetic integrity, habitat and population expansion and protection.

3. State law 78 Stat. 896 (8) describes state jurisdiction in managing fish and wildlife

Selected Alternative

http://www.wilderness.net/MRDG/documents/MRDG_instructions.pdf



in national forest wilderness in cooperation with the U.S. Forest Service. 4. The proposed project conforms to direction in the Policies and Guidelines for Fish

and Wildlife Management in National Forest and Bureau of Land Management Wilderness (Forest Service Manual; FSM 2323.32 #5).

5. FSM 2323.34 emphasizes the quality and naturalness in managing fisheries in wilderness.

6. FSM 2323.34f states that chemical treatment may be used to prepare waters for reestablishment of indigenous, threatened or endangered, or native species, or to correct undesirable conditions caused by human influence. The Regional Forester approves all proposed uses of chemicals in wilderness (FSM 2150).

7. Region 4 of the Forest Service is a signatory to a conservation agreement for YCT in the States of Idaho, Montana, Nevada, Utah and Wyoming (Montana Fish, Wildlife, and Parks 2009).

8. The Wyoming Game and Fish Commission has entered into a Memorandum of Understanding (MOU) with the Forest Service, United States Department of Agriculture Rocky Mountain Region and Intermountain Region for Fish, Wildlife and Habitat Management within National Forest Wilderness in Wyoming (May 7, 2010). The MOU directs the Forest Service to “Recognize that registered piscicide applications to remove unwanted aquatic species on NFS lands in Wyoming, consistent with label requirements, are a state action to be conducted by the Wyoming Game and Fish.

Other alternatives were not selected because of they have more negative effects to wilderness character than alternative 1. Alternative 2, mechanical removal, proposed a prohibited use, would be less effective and would be more costly. Alternative 3, no-action, would not restore native populations and habitat, and would further degrade the untrammeled and natural qualities. Other alternatives that were not analyzed were not selected because of safety, effectiveness, and prohibited uses.

Describe Monitoring & Reporting Requirements: WGFD is the proponent of this action. Their objective is elimination of the non-native fish populations in Dime and Mystery lakes. Restoration of the native fish population will occur in Mystery Lake one year after treatment, utilizing pack stock for transport. Dime Lake will not be stocked with fish. Dime Lake should become prime habitat for expansion of the population of Columbia spotted frogs. The Bridger-Teton NF is in the process of writing a prescription for monitoring of amphibians as a component of project approval.

Which of the prohibited uses found in Section 4(c) of the Wilderness Act are approved in the selected alternative and for what quantity?

Prohibited Use Quantity

☐ Mechanical Transport:

Approvals



Literature Cited: Gresswell, R.E. 2009. Yellowstone Cutthroat Trout (Oncorhynchus clarkii bouvieri): a technical conservation assessment. [Online]. USDA Forest Service, Rocky Mountain Region. Available: http://www.fs.fed.us/r2/projects/scp/assessments/yellowstonecutthroattrout.pdf [date of access]. Range-Wide YCT Conservation Team. 2009. Conservation agreement for Yellowstone cutthroat trout (Oncorhynchus clarkii bouvieri) in the States of Idaho, Montana, Nevada, Utah and Wyoming. Montana Fish, Wildlife & Parks. USDA Forest Service. 1990. The Bridger-Teton National Forest Plan. Bridger-Teton National Forest. USDA Forest Service. 2007. Forest Service Manual. Chapter 2320. Washington, D.C.: US Government Printing Office. USDA Forest Service. 2013. Intermountain Region (R4) Threatened, Endangered, Proposed, and Sensitive Species List. USDA Forest Service. 2014. Forest Service Manual. Chapter 2150. Washington, D.C.: US Government Printing Office. Van Kirk, R. W., J. M. Capurso, and M.A. Novak, editors. 2006. Exploring differences between fine-spotted and large-spotted Yellowstone cutthroat trout. Symposium Proceedings, Idaho Chapter American Fisheries Society, Boise, ID. Wyoming Game and Fish Commission; USDA Forest Service, Rocky Mountain and Intermountain Regions. 2010. Memorandum of Understanding. Fish, Wildlife, and Habitat Management Within National Forest Wilderness in Wyoming.

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