From: To: Cc: Subject: Date: Joe Miller FS-comments-southwestern-coconino-mogollon; Haessig, Polly A -FS Andi Rogers; mselig@nationalforests.org; Steve LaFalce; jam@prairietriz.com Cragin Watershed Protection Project (CWPP) Friday, March 25, 2016 9:04:58 PM To: Attention: From: Mogollon Rim Ranger District, Coconino National Forest Polly Haessig, Project Manager, Cragin Watershed Protection Project Gila Trout Chapter 530, Trout Unlimited, Inc. Arizona Council of Trout Unlimited, Inc. Subject: Cragin Watershed Protection Project 3-25-2016 Dear Ms/Sirs: The proposed project area for the Cragin Watershed Protection Project, with its included Reservoir, streams, watersheds, wildlife, and fish, is of great value to us in the Gila Trout Chapter 530 of Trout Unlimited, Inc, operating in the Mogollon Rim area and the White Mountains areas of Arizona, and to the Arizona Council of Trout Unlimited, Inc, a Council of all the Trout Unlimited Chapters in Arizona and representing some 1800 members within the state, and associated with some 155,000 members of Trout Unlimited throughout the United States. This area is of great importance, especially to those of us living in the Payson area, because of the grave danger to the CC Cragin Reservoir if major wildfires were too occur, potentially destroying the future primary source of water for the town. Moreover, the project area is also important to all members of Trout Unlimited especially within the state due to its closeness to a major portion of the original range of the Gila Trout, a Listed Species under the ESA, and to the long term Salt River Project plans for water from the CC Cragin reservoir to help replenish waters in the East Verde and Verde River systems, which originally contained those trout, and are expected to again in the future. The Gila Trout Chapter 530 of Trout Unlimited and the Arizona Game and Fish Department have already invested many thousands of dollars in planning for stream restoration work on the East Verde River, together with the Tonto National Forest and its Payson Ranger District; that planned restoration work will depend on an adequate supply of water from the CC Cragin Reservoir for its full potential for recreational fishing, a valuable economic benefit for the area and the state. The long term recovery efforts for these native fish, as well as recreational fishing in general, are so important to our collective organizations that we in Trout Unlimited have recently re-focused them and launched a Southwest Native Trout Initiative, one of Trout Unlimited s Top Five Key Strategic Initiatives. We are joined in that initiative by a number of federal and state agencies. That initiative points out: The native trout of the Southwest are America s most imperiled trout. Many people do not associate the arid Southwest with trout habitat. Most are not aware of the pristine high mountain meadows, remote wilderness and verdant pine forests found there. But these streams and small rivers are the lifeblood of the Southwest. A significant population of native trout once flourished in these streams, but this once vibrant population has dwindled precipitously. Apache trout occur only on streams draining Mount Baldy in east-central Arizona. Gila trout are less well known and their native range stretched from the Upper Gila River in New Mexico through the Blue and San Francisco Rivers along the Arizona-New Mexico border and west to the Verde River in Arizona...
A more extensive write-up of the Trout Unlimited Southwest Native Trout Initiative is included as an appendix of these comments. That write-up describes all the species included, shows the regional map, includes high level goals and objectives of the Initiative, and highlights some of the work already done by just some of the many organizations involved, including the USNFS and including the National Forests that make up the 4 Forest Restoration Initiative, of which we are an active participant and Stakeholder. The regional map included shows that the Cragin Watershed Protection Project is immediately adjacent to the original Gila Trout Range; wildfire impact on the CWPP area could well have negative effects on that range. We gladly recognize and acknowledge the extensive works already done by the Coconino National Forest, just for example by participating in the recent Gila Trout Stocking project on the West Fork of Oak Creek, as well as in other adjacent areas of the Coconino NF. These efforts are a significant basis and enabling mechanism for the very design of the SWNTI. So we value and support this proposed effort in anticipation of the full implementation of the planned future Rim Country 4FRI Forest Restoration Project and in hope of the full achievement of Coconino NF Forest Management Plan Desired Conditions with priority treatments for watersheds and native aquatic communities. We believe these pre-emptive treatments under the Healthy Forest Restoration Act before the greatly overgrown stands in the project area can contribute to more severe ground and entire watershed impacting fires are vital. We hope and understand that by carefully managing various mechanical treatments and focused burn segments and vegetation specific treatments the greater area will be protected from higher intensity fires. We do ask that these specific treatments protect and preserve the streams, stream beds and riparian areas, and the intact watersheds to the greatest extent possible as they are planned and conducted. One of our members has already submitted individual comments on this project. We are in full accord with those comments, and include them again here to lend our weight to them: Additional roads together with the many existing roads and trails, increases the opportunity for access to the project area for off-road vehicles after completion of treatments and the mitigation measures have been employed. Although you have indicated several mitigation measures proposed for roads and trails in the area, these can be quickly negated if sufficient enforcement measures are not used. This could lead to the very problems your mitigation measures are intended to prevent, e.g., erosion of soils and deposition into Cragin Reservoir, wildlife habitat disturbances, etc. Timing of tree removals and prescribed burns no doubt will overlap critical nesting periods for MSOs. It would seem that winter activities when sufficient snow is available may be the best time to conduct such operations as this would avoid their nesting period and reduce erosion potential. Obviously, monitoring of nest sites before, during and after operations is a critical action. The intensity of prescribed burns must be a consideration. Too many ground fires over small areas may result in excessive ash that could be washed into the reservoir. We assume the prescribed ground fires will be spaced out, spatially and temporally, to avoid this potential problem.
Although the area is relatively flat, there are many small channels and valleys that conduct fair volumes of water during precipitation events. Logging activities that result in yarding on the fall line into these valleys could exacerbate erosion of soils despite your efforts to mitigate this with seeding, mulching, etc. Even slight deviations from the fall line may help prevent many erosion issues. Also, these trails can, and probably will, be used by off-road vehicles after the project is completed, unless maximum effort is made to discourage and prevent it. The inventory of species in the project area needs to be examined closely for potential T/E listings or other sensitive species. Using mitigation measures that can help a group of species associated with similar habitats may be a prudent approach and one that could prevent more stringent measures being required later on. The speed at which this project can be conducted is critically important to all of us. It is necessary to involve many in conducting this project but this should not result in stagnation due to an increasing bureaucracy. Please keep your eyes on the goal and not let the need to collaborate, mediate and compromise deny all of us the urgently needed protection this project will provide. We also understand that this project area will be further analyzed and subject to further treatments with full restoration criteria as a part of the full 4Forest Restoration Initiative Rim Country EIS. We already have and will continue to participate fully in that analysis and planning as part of our responsibility as full members of the 4FRI Stakeholders Group. We also stand ready to work with the Coconino National Forest, the Mogollon Rim Ranger District, the town of Payson, the Salt River Project, and the National Forest Foundation on this Cragin Watershed Protection Project, whether in providing more detailed information on stream, riparian area, or watershed conditions, assessment criteria, and restoration guidelines, and more detailed information on plans for the native trout Gila species, providing volunteers for CNF supervised work doing on ground work projects, or any other support activities within our means. Thank you for the opportunity to submit these comments, and for your attention to them, Joe A Miller, President, Gila Trout Chapter 530 of Trout Unlimited, Inc. Secretary, Arizona Council of Trout Unlimited, Inc., an Arizona 501c3 corporation Arizona Representative, Trout Unlimited, Inc. National Leadership Council Residing at 818 N Blue Spruce Circle, Payson Arizona 85541 Phone: 928-978-1315, e-mail: jam@prairietriz.com Appendix: Trout Unlimited Southwest Native Initiative The Southwest Native Trout Initiative
Background: A Native Heritage The native trout of the Southwest are America s most imperiled trout. Many people do not associate the arid Southwest with trout habitat. Most are not aware of the pristine high mountain meadows, remote wilderness and verdant pine forests found there. But these streams and small rivers are the lifeblood of the Southwest. A significant population of native trout once flourished in these streams, but this once vibrant population has dwindled precipitously. Apache trout occur only on streams draining Mount Baldy in east-central Arizona. Gila trout are less well known and their native range stretched from the Upper Gila River in New Mexico through the Blue and San Francisco Rivers along the Arizona-New Mexico border and west to the Verde River in Arizona. The Rio Grande cutthroat trout ranged from the high mountain headwaters of the Rio Grande, Pecos and Canadian rivers in Colorado and New Mexico to small streams in the Davis and Guadalupe Mountains, making it the only trout native to Texas. Gila.Apache...Rio Grande These native trout of the Southwest Gila, Apache, and Rio Grande cutthroat are beautiful and hardy species, but they are at a critical juncture. Their status continues to decline from a combination of drought, wildfire and invasion by non-native fishes. Historically, the greatest problem for native trout in the Southwest has been the introduction and establishment of nonnative trout that compete with, prey upon, and hybridize with the native trout. With drought and warming waters, other non-native species such as smallmouth bass are also a threat. For anglers, these native trout provide abundant recreational opportunities to pursue rare and beautiful trout species found nowhere else on Earth, in landscapes of remote wildness, rugged grandeur and unsurpassed beauty. These trout are also a rich part of our region s cultural and biological heritage. They are worth protecting and preserving. The Opportunity Trout Unlimited and its partners have recognized both the compelling need and tremendous opportunity to maintain and even expand these Southwest natives through accelerated restoration, reconnection, reintroduction and monitoring efforts. TU s grassroots leaders in the Southwest are keenly interested in the recovery of these native trout and have a demonstrated history of successful projects. For decades, federal and state agencies including the U.S. Fish and Wildlife Service, Bureau of Land Management, U.S. Forest Service and the Departments of Game and Fish in New Mexico and Arizona have carried out successful restoration and protection projects they, too,
recognize the urgency of action and the potential to have a larger impact by working together. These agencies, as well as the staffs at New Mexico State University and the University of Arizona, are eager to more strongly engage and coordinate with TU in work on native trout. There is also a strong push from political and agency leaders for large-scale restoration work. TU has demonstrated the ability to coordinate large-scale restoration efforts in the Southwest and multiple foundations active in the region could help support new projects. The Goal The native trout of the Southwest are essential components of its riparian ecosystems playing an important role in its culture and history. Our goal is that Apache, Gila and Rio Grande trout will be fully recovered in the Southwest, resilient to climate change, well distributed and with abundant, fishable populations. Key Attributes of Success
1. Significantly contribute to the recovery of native Southwest trout through Protect, Reconnect, Restore and Sustain work. Actively participate in Federal Land Management planning efforts (4FRI, Carson, Santa Fe, Gila, Lincoln, Tonto NF s) to ensure recovery of the SW native trout. Advocate for improved management practices for responding to wildfires for native trout in the Southwest. Develop restoration, riparian management and forest management practices to minimize impacts from wildfires, droughts and floods for southwestern trout. Develop improved restoration practices, including beavers and grazing modifications for southwestern streams. 2. Increase resilience to climate change impacts, particularly warming, drought and wildfire. Restore large, interconnected populations (Apache, Gila, and RGCT) Establish at least one new large interconnected populations of Rio Grande cutthroat trout in the Pecos, Upper Rio Grande, and Lower Rio Grande basins Repatriate Rio Grande cutthroat trout to Texas. Reestablish two interconnected metapopulations of Apache trout within their native range in Arizona and New Mexico. Reestablish three interconnected metapopulations of Gila trout within their native range in Arizona and New Mexico 3. Improve the awareness of the plight of these fishes and the needs and opportunities for improvement Continue and expand visibility of Arizona Native and Wild Trout Workshops Develop video and print materials that highlight the situation with native trout in the Southwest Develop and implement a comprehensive media campaign Work with National Geographic or other national publications to help develop interest in the both the plight and opportunity for SW native trout. 4. Facilitate and contribute to our improved understanding of threats and recovery needs through research and assessments Increase cooperative studies with NMSU and UofA
5. Increase the role of our membership base and volunteers in actions to restore and monitor these fishes Establish a stream flow and temperature monitoring network for Rio Grande cutthroat trout throughout their range Establish a stream flow and temperature monitoring network for historical habitat of Gila and Apache trout in Arizona and New Mexico Establish a Edna sampling program in cooperation with USFS 6. Highlight good work that is already underway Work with partners to develop a comprehensive set of information detailing the current progress being accomplished Utilize this information in media plan to highlight progress Celebrate successes with awards and visible recognition 7. Expand on successful partnerships and coordination with state and federal agencies, recovery teams, tribes, and other NGOs in the above efforts Participate with other partner organizations to build and effective coalition committed to recovery of the SW native trout Help lead fund raising efforts accomplish the planned recovery work Develop adequate staffing to ensure that the coalitions goals are achieved 8. Increase fishing opportunity and angler engagement Develop active partnerships within the angler community to gain their support Working closely with State game and fish agencies expand angling opportunities through the recovery of SW native trout End.