2008 amendment comment

These comments are submitted on behalf of the Oregon Invasive Species Council by Council Coordinator Lisa A. DeBruyckere. The Council focused its comments on sections 2 and 11 and recommends that text in brackets be added. Text in parenthesis is further clarifies text in brackets. 2. Non-Native Species Strategies Non-native invasions imperil native species in the Pacific Northwest's ecosystems through predation, competition for food, interbreeding, disease transmission, food web disruption, [reduction in biodiversity, siphoning finite financial resources from native fish and wildlife species and habitat enhancement programs to surveillance, management, and control efforts for non-native species, disruption of ecosystem services such as water filtration and nutrient cycling,] and physical habitat alteration. Specific measures addressing the effects of non-native species on native fish, wildlife, and habitat can be found in the program's subbasin and mainstem plans along with wildlife management plans. While the program recommends resident fish substitutions for lost salmon and steelhead where in-kind mitigation cannot occur, the program also includes a resident fish substitution strategy. The resident fish substitution strategy describes conditions under which non-native fish management should occur and requires an environmental-risk assessment3 prior to introduction or enhancement of non-native species. The Council supports actions that suppress non-native populations that directly or indirectly adversely affect [native fish and wildlife and their habitats, particularly those that] affect juvenile and adult salmonids. For example, the Council urges state agencies to modify fishing regulations or harvest limits as appropriate, to reduce predation on native populations. 11. Non-Native Species Evaluation and Control The Council acknowledges invasive non-native species pose direct threats to the program's fish and wildlife restoration efforts through competition, predation and habitat modification. In addition to threatening native fish and wildlife habitat, aquatic non-native species can invade and significantly threaten infrastructure at hydroelectric dams and fish passage facilities in the Columbia River Basin. Currently, the greatest known threat to the FCRPS from aquatic nuisance species is introduction into the basin of the zebra or quagga mussel, followed by [hydrilla] (replace Eurasian milfoil with hydrilla). Once established [in other locales], management actions taken (remove in other locales here) have shown little success in removing or controlling these invasive non-native species. Accordingly, the Council expects: Where aquatic non-native species pose both a direct threat to the hydropower system or to native fish [and wildlife] species, federal action agencies [will proactively adopt aggressive prevention measures and provide significant funding and staff support to] ongoing federal, state, and tribal efforts to prevent, monitor, control and minimize the spread of non-native species, including zebra or quagga mussels and [hydrilla] (replace Eurasian milfoil with hydrilla), that threaten the success of fish and wildlife program measures. The federal action agencies, states, tribes and the Council will review, evaluate and develop strategies to reduce competition from non-native species, such as shad, with juvenile and adult salmonids. Lethal take to control non-native predators or competitors consistent with state and federal law is appropriate when non-lethal methods of control are not successful and the adverse impacts are significant. Please contact me if you have any questions. Lisa DeBruyckere, Oregon Invasive Species Council Coordinator, lisad@createstrat.com