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V. Summary of Factors and Threats Affecting Westslope Cutthroat Trout

The following is a discussion of the five listing factors set forth in section 4(a)(1) of the Endangered Species Act and related regulations (50 CFR Part 424), and the applicability of these factors to the WCT. Each of the five factors will be discussed by major drainage.

Oldman River Drainage

A. The Present or Threatened Destruction, Modification or Curtailment of the Species' Habitat or Range

Most lands in the Oldman drainage are in Glacier National Park. National Park Service policies protect native species like WCT, and preclude the adverse modification of WCT habitat. In other areas of the drainage, major land-use activities consist primarily of livestock grazing, although grazing does not occur within the range of extant WCT stocks.

B. Overutilization for Commercial, Sporting, Scientific or Educational Purposes

Angler harvest of WCT in the Oldman River drainage is closely regulated by the National Park Service, Glacier National Park. Collection of WCT for scientific and educational purposes, permitted by the National Park Service only for legitimate purposes, has a negligible effect on WCT stocks in the drainage.

C. Disease or Predation

Disease and predation are not known to be important factors presently affecting WCT in the Oldman River drainage.

D. Inadequacy of Existing Regulatory Mechanisms

There are no evident inadequacies in existing regulatory mechanisms that affect WCT in the Oldman River drainage.

E. Other Natural or Manmade Mechanisms

Stocking of nonnative rainbow trout and Yellowstone cutthroat trout in the Oldman River drainage, primarily during the first half of this century, has led to interbreeding and the loss of genetically pure WCT in many parts of the drainage (Marnell 1988). Where genetically pure WCT stocks persist, they may be threatened by interbreeding with these nonnative species.

Missouri River Headwaters Drainage

A. The Present or Threatened Destruction, Modification or Curtailment of the Species' Habitat or Range

Major land-use activities in the Missouri River Headwaters drainage that may adversely affect WCT include livestock grazing and other agricultural practices, mining, and forestry practices. The Montana Department of Environmental Quality (MTDEQ) lists 37 streams in the Lower Missouri River drainage as being water-quality impaired as the result of forestry practices, 171 impaired by agricultural practices, 107 impaired by water withdrawals, 60 impaired by roads, and 50 impaired by mining (MTDEQ 1998; Appendix Table 5). Many of these streams are impaired by more than one activity. Information on the possible occurrence of WCT in these streams is presently unavailable, however.

B. Overutilization for Commercial, Sporting, Scientific or Educational Purposes

Although angler harvest of WCT may have negatively affected some stocks of this subspecies earlier in this century, angler harvest is now closely regulated in the Missouri River Headwaters drainage and is not considered a threat to the subspecies (MTFWP, in litt. 1999). In all of the waters in the Missouri River Headwaters drainage, fishing for WCT is restricted to catch-and-release. Collection of WCT for scientific and educational purposes, permitted by Montana Fish, Wildlife and Parks only for legitimate purposes, has a negligible effect on the WCT population (MTFWP, in litt. 1999).

C. Disease or Predation

Whirling disease, caused by a protozoan parasite that requires an oligochaete (an aquatic earthworm) as its intermediate host, was discovered in rainbow trout in Montana in 1994. Whirling disease has been detected in all the major rivers the Missouri River Headwaters drainage (Gustafson 1996). Extensive research is being conducted to determine the distribution of whirling disease in Montana, the susceptibility of WCT (a close relative of rainbow trout) to whirling disease, and possible control measures. Research suggests that WCT in headwater streams will not be affected by whirling disease because these streams are not suitable for colonization by the intermediate host for the whirling disease organism. Moreover, current research suggests that, although the whirling disease organism may be present in streams, low levels of the organism are unlikely to result in deleterious infections in fish, including cutthroat trout. Consequently, whirling disease is not considered an important threat to extant WCT stocks in the Missouri River Headwaters drainage.

D. Inadequacy of Existing Regulatory Mechanisms

There are no evident, inherent inadequacies in existing federal, state or local regulatory mechanisms that affect WCT in the drainage. However, effective implementation of the various regulatory mechanisms (see VI. Ongoing Regulatory and Conservation Actions) that potentially affect WCT depends largely upon the appropriation of adequate funding and, ultimately, commitment on the part of the management or regulatory agencies to fulfill their respective responsibilities. Where these responsibilities are not being fulfilled, WCT may be threatened by ongoing or planned, adverse changes in their habitat or by chronic, adverse effects that remain unabated.

E. Other Natural or Manmade Mechanisms

Nonnative fish species were extensively stocked in many areas of the Missouri River Headwaters drainage, beginning in the 1890s, with substantial federal government support (e.g., hatchery fish provided by the U.S. Fish Commission). As a result, nonnative brook trout, brown trout and rainbow trout became established long ago in many streams and lakes throughout the drainage (MTFWP, in litt. 1999). Although such stocking has not occurred in Montana for more than two decades, the nonnative fishes that became established probably constitute the greatest contemporary threat to the maintenance and restoration of WCT in the drainage.

Lower Missouri River Drainage

A. The Present or Threatened Destruction, Modification or Curtailment of the Species' Habitat or Range

Major land-use activities in the Lower Missouri River drainage that may adversely affect WCT include livestock grazing and other agricultural practices, mining, and forestry practices. The Montana Department of Environmental Quality (MTDEQ) lists 14 streams in the Lower Missouri River drainage as being water-quality impaired as the result of forestry practices, 100 impaired by agricultural practices, 65 impaired by water withdrawals, 24 impaired by roads, and 54 impaired by mining (MTDEQ 1998; Appendix Table 5). Many of these streams are impaired by more than one activity. Information on the possible occurrence of WCT in these streams is presently unavailable, however.

B. Overutilization for Commercial, Sporting, Scientific or Educational Purposes

Although angler harvest of WCT may have caused appreciable declines in some stocks of this subspecies earlier in this century, angler harvest is now closely regulated in the Lower Missouri River drainage and is not considered a threat to the subspecies (MTFWP, in litt. 1999). In all of the waters in the Lower Missouri River drainage, fishing for WCT is restricted to catch-and-release.

C. Disease or Predation

In the Lower Missouri River drainage, whirling disease has been detected in the mainstem Missouri River and several tributaries (Gustafson 1996). Extensive research is being conducted to determine the distribution of whirling disease in Montana, the susceptibility of WCT (a close relative of rainbow trout) to whirling disease, and possible control measures. Research suggests that WCT in headwater streams will not be affected by whirling disease because these streams are not suitable for colonization by the intermediate host for the whirling disease organism. Moreover, current research suggests that, although the whirling disease organism may be present in streams, low levels of the organism are unlikely to result in deleterious infections in fish, including cutthroat trout. Consequently, whirling disease is not considered an important threat to extant WCT stocks in the Lower Missouri River drainage.

D. Inadequacy of Existing Regulatory Mechanisms

There are no evident, inherent inadequacies in existing federal, state or local regulatory mechanisms that affect WCT in the drainage. However, effective implementation of the various regulatory mechanisms (see VI. Ongoing Regulatory and Conservation Actions) that potentially affect WCT depends largely upon the appropriation of adequate funding and, ultimately, commitment on the part of the management or regulatory agencies to fulfill their respective responsibilities. Where these responsibilities are not being fulfilled, WCT may be threatened by ongoing or planned, adverse changes in their habitat or by chronic, adverse effects that remain unabated.

E. Other Natural or Manmade Mechanisms

Although stocking of nonnative fish species has not occurred in the drainage for more than two decades, the nonnative fishes that have become established there probably constitute the greatest contemporary threat to the maintenance and restoration of WCT in the drainage.

Kootenai River Drainage, Montana

A. The Present or Threatened Destruction, Modification or Curtailment of the Species' Habitat or Range

Timber management is the dominant land use in the Kootenai River drainage, and an extensive road system to support forestry practices and other forest uses exists throughout the drainage. Forestry practices have had adverse effects on the habitats of WCT in some areas of the drainage. Seven streams (95 miles) in the upper Kootenai River drainage, 5 streams (124 miles) in the middle Kootenai River drainage, and one stream (7 miles) in the lower Kootenai River drainage are considered water-quality impaired as a result of forestry practices (MDHES 1994). The Montana Department of Environmental Quality (MTDEQ) lists 23 streams in the Kootenai River drainage as being water-quality impaired as the result of forestry practices, nine impaired by agricultural practices, and 18 impaired by water withdrawals; additional impairments result from other land-use practices (MTDEQ 1998; Appendix Table 5). Many of these streams are water-quality impaired by more than one activity. Information on the possible occurrence of WCT in these streams is presently unavailable, however.

B. Overutilization for Commercial, Sporting, Scientific or Educational Purposes

Although angler harvest of WCT may have caused appreciable declines in some westslope stocks earlier in this century, angler harvest is now closely regulated in Montana and is not considered a threat to the subspecies (MTFWP, in litt. 1999). In many waters in the Kootenai River drainage, fishing for WCT is restricted to catch-and-release. Elsewhere in the drainage, harvest is greatly restricted.

C. Disease or Predation

Whirling disease has not been found in the Kootenai River drainage (Gustafson 1996). We are aware of no other diseases or predators than pose threats to WCT in the drainage.

D. Inadequacy of Existing Regulatory Mechanisms

There are no evident, inherent inadequacies in existing federal, state or local regulatory mechanisms that affect WCT in the drainage. However, effective implementation of the various regulatory mechanisms (see VI. Ongoing Regulatory and Conservation Actions) that potentially affect WCT depends largely upon the appropriation of adequate funding and, ultimately, commitment on the part of the management or regulatory agencies to fulfill their respective responsibilities. Where these responsibilities are not being fulfilled, WCT may be threatened by ongoing or planned, adverse changes in their habitat or by chronic, adverse effects that remain unabated.

E. Other Natural or Manmade Mechanisms

As the result of stocking for recreational purposes, nonnative brook trout, brown trout and rainbow trout became established long ago in many streams and lakes throughout the Kootenai River drainage. Although such stocking has not occurred for more than two decades, the nonnative fishes that became established probably constitute the greatest contemporary threat to the maintenance and restoration of WCT in the state (MTFWP, in litt. 1999).

Clark Fork River Drainage

A. The Present or Threatened Destruction, Modification or Curtailment of the Species' Habitat or Range

Major land-use activities in the Clark Fork River drainage that may adversely affect WCT include forestry practices, mining, livestock grazing and other agricultural practices, and urbanization. The Montana Department of Environmental Quality (MTDEQ) lists 77 streams in the Clark Fork River drainage as being water-quality impaired as the result of forestry practices, 143 impaired by agricultural practices, 99 impaired by water withdrawals, 71 impaired by roads, and 73 impaired by mining (MTDEQ 1998; Appendix Table 5). Many of these streams are impaired by more than one activity. Information on the possible occurrence of WCT in these streams is presently unavailable, however.

The Montana Bull Trout Scientific Group ranked mining in the Blackfoot River watershed as a high risk to bull trout restoration (MBTSG 1995C). Mining of gold, silver, lead, and copper has occurred in Blackfoot River headwaters during the past century, and effluents from the mines continue to result in the loss of habitat for bull trout (MBTSG 1995C). Altogether, 153 miles of streams in the Middle Clark Fork River watershed are water-quality impaired because of mining (MDHES 1994).

Most of the large tributaries in the northern region of the Bitterroot River watershed are diverted for irrigation (MBTSG 1995B). Nearly 65 miles of stream in the Bitterroot River and at least 18 of its tributaries experience chronic low-flow conditions during the irrigation season (MBTSG 1995B). Intensive livestock grazing, particularly in the Deerlodge valley, Flint Creek valley, and parts of the Rock Creek valley, has adversely affected water quality and fisheries habitat in those areas of the Upper Clark Fork watershed (MBTSG 1995A).

The human population and associated rural residential development have been increasing rapidly in the Bitterroot Valley (MBTSG 1995B). Development can lead to alteration of stream and riparian habitats. The lower Bitterroot River is a major non-point source of nutrient pollution, primarily from sewage effluents and land development (U.S. EPA 1993 in MBTSG 1995B).

B. Overutilization for Commercial, Sporting, Scientific or Educational Purposes

Angler harvest is closely regulated in the Clark Fork River drainage and is not considered a threat to WCT (MTFWP, in litt. 1999). In many waters in the drainage, fishing for WCT is restricted to catch-and-release.

C. Disease or Predation

In the Clark Fork River drainage, whirling disease has been detected in the Blackfoot River watershed, the Flint Creek-Rock Creek watershed, and the upper Clark Fork River watershed (Gustafson 1996). Extensive research is being conducted to determine the distribution of whirling disease in Montana, the susceptibility of WCT (a close relative of rainbow trout) to whirling disease, and possible control measures. Research suggests that WCT in headwater streams will not be affected by whirling disease because these streams are not suitable for colonization by the intermediate host for the whirling disease organism. Moreover, current research suggests that, although the whirling disease organism may be present in streams, low levels of the organism are unlikely to result in deleterious infections in fish, including cutthroat trout. Consequently, whirling disease is not considered an important threat to extant WCT stocks in the Clark Fork River drainage.

Predation on WCT by nonnative predatory fishes poses a threat to WCT in a few localized areas. The highly predacious northern pike Esox lucius, for example, was illegally introduced into the Clearwater River system (MFWP 1997).

D. Inadequacy of Existing Regulatory Mechanisms

Existing regulatory mechanisms failed to prevent the illegal stocking of northern pike into the Clearwater River system. There are no other evident, inherent inadequacies in existing federal, state or local regulatory mechanisms that affect WCT in the drainage. However, effective implementation of the various regulatory mechanisms (see VI. Ongoing Regulatory and Conservation Actions) that potentially affect WCT depends largely upon the appropriation of adequate funding and, ultimately, commitment on the part of the management or regulatory agencies to fulfill their respective responsibilities. Where these responsibilities are not being fulfilled, WCT may be threatened by ongoing or planned, adverse changes in their habitat or by chronic, adverse effects that remain unabated.

E. Other Natural or Manmade Mechanisms

Stocking of nonnative fish species in Clark Fork River drainage began in the1890s and, with substantial federal government support (e.g., hatchery fish provided by the U.S. Fish Commission), soon became the principal fisheries management tool of the state game and fish agency. As a result, nonnative brook trout, brown trout and rainbow trout became established long ago in many streams and lakes throughout Montana (MTFWP, in litt. 1999). Although such stocking has not occurred in the drainage for more than two decades, the nonnative fishes that became established probably constitute the greatest contemporary threat to the maintenance and restoration of WCT in the drainage.

Many people in the Bitterroot River watershed are building private fish ponds on their property and stocking them with brook trout, leading to concern that these introduced fish could spread into tributaries where they do not already exist (MBTSG 1995B). In addition, the genetic integrity of WCT can be threatened by interbreeding with nonnative rainbow trout and Yellowstone cutthroat trout (MTFWP, in litt. 1999).

Flathead River Drainage

A. The Present or Threatened Destruction, Modification or Curtailment of the Species' Habitat or Range

Timber management is the dominant land use in the Flathead River drainage, where an extensive road system to support forestry practices and other forest uses exists. In addition, rural residential development is increasing, particularly in the Flathead Lake area; resulting domestic sewage and human-caused changes to stream morphology are considered threats to water quality (MBTSG 1995D). The Montana Department of Environmental Quality (MTDEQ) lists 17 streams in the Flathead River drainage as being water-quality impaired as the result of forestry practices and 16 streams impaired by agricultural practices; additional impairments result from other land-use practices (MTDEQ 1998; Appendix Table 5). Many of these streams are water-quality impaired by more than one activity. Information on the possible occurrence of WCT in these streams is presently unavailable, however.

B. Overutilization for Commercial, Sporting, Scientific or Educational Purposes

Angler harvest of WCT is closely regulated in Montana and not considered a threat to the subspecies in the Flathead River drainage (MTFWP, in litt. 1999). In many WCT waters in the drainage, fishing for WCT is restricted to catch-and-release. Elsewhere in the drainage, only limited harvest of WCT is allowed.

C. Disease or Predation

Whirling disease has been detected in trout in the Swan River watershed of the Flathead River drainage (Gustafson 1996). Where WCT coexist with both the protozoan that causes the disease and the protozoan's intermediate host, whirling disease poses a threat to WCT. However, extensive research is being conducted to determine the distribution of whirling disease in Montana, the susceptibility of WCT (a close relative of rainbow trout) to whirling disease, and possible control measures. Research suggests that WCT in headwater streams will not be affected by whirling disease because these streams are not suitable for colonization by the intermediate host for the whirling disease organism. Moreover, current research suggests that, although the whirling disease organism may be present in streams, low levels of the organism are unlikely to result in deleterious infections in fish, including cutthroat trout. Consequently, whirling disease is not considered an important threat to most extant WCT stocks in the Flathead River drainage.

Predation on WCT by nonnative predatory fishes poses a threat to WCT in a few localized areas. In the Flathead Lake basin, there are 13 introduced, nonnative species of fish with which WCT must coexist (MBTSG 1995D). Among these is lake trout Salvelinus namaycush, which has become the dominant species in Flathead Lake. Juvenile lake trout have also been found in major tributaries to the lake (MBTSG 1995D). Hungry Horse Dam protects native fishes in the South Fork Flathead River watershed, the most intact native fish assemblage in western Montana, by preventing the upstream movement of nonnative fishes, particularly lake trout, into the watershed (MBTSG 1995E). Bigfork Dam has benefitted the Swan River watershed because the dam prevents the upstream movement of nonnative fishes, particularly lake trout, into the Swan drainage (MBTSG 1996A). Over 100 illegal fish introductions have been documented in northwest Montana during the past 20 years (MBTSG 1995E). Montana FWP does not stock nonnative predatory fishes into waters harboring genetically pure WCT and aggressively prosecutes anyone caught illegally transferring live fish or attempting to do so (MTFWP, in litt. 1999).

D. Inadequacy of Existing Regulatory Mechanisms

Existing regulatory mechanisms failed to prevent the more than 100 illegal fish introductions that have been documented in northwest Montana during the past 20 years. There are no other evident, inherent inadequacies in existing federal, state or local regulatory mechanisms that affect WCT in the drainage. However, effective implementation of the various regulatory mechanisms (see VI. Ongoing Regulatory and Conservation Actions) that potentially affect WCT depends largely upon the appropriation of adequate funding and, ultimately, commitment on the part of the management or regulatory agencies to fulfill their respective responsibilities. Where these responsibilities are not being fulfilled, WCT may be threatened by ongoing or planned, adverse changes in their habitat or by chronic, adverse effects that remain unabated.

E. Other Natural or Manmade Mechanisms

Although authorized stocking of nonnative fish species has not occurred in for more than two decades, the nonnative fishes that became established probably constitute the greatest contemporary threat to the maintenance and restoration of WCT in the drainage. Nonnative fish species that have become established in the drainage include lake trout, kokanee salmon, northern pike, and largemouth bass Micropterus salmoides (MBTSG 1996A).

Pend Oreille Drainage, Idaho

A. The present or threatened destruction, modification, or curtailment of the species' habitat or range

The WCT in Pend Oreille drainage, Idaho, have been negatively affected by habitat fragmentation resulting from mainstem dams constructed without fish passage facilities. These dams, constructed at Albeni Falls (1952) and Cabinet Gorge (1951), contributed to habitat fragmentation for fluvial and adfluvial bull trout populations and are likely associated with WCT declines as well (Mauser et al. 1988). The construction of Cabinet Gorge and other dams eliminated 90 % of the available spawning and rearing habitat for Pend Oreille Lake migratory fish using the Clark Fork River and tributaries (Irving 1986 in Hoelscher and Bjornn 1989; Mauser et al. 1988). The estimated harvest levels for both WCT (8000+) and bull trout (5000+) peaked in 1953 and experienced dramatic declines by the 1960s (Pratt 1985, Bowler et al. 1978). With less than 1000 WCT (in most years) being harvest annually (by 1966), this was an even more dramatic decrease than observed with bull trout. Albani Falls Dam, completed in 1952, may also have contributed to these abrupt declines in abundance and harvest.

The construction and operation of these dams has probably had the greatest influence on habitat of migratory WCT in the Pend Oreille River portion of this drainage. This along with other development activities have changed the physico-chemical and aquatic biota of the river to be less suitable for salmonid survival (Horner 1989 in Bennett and DuPont 1993). Daily average water temperatures >21 oC (39 days in 1991 and 48 days in 1992), substrate dominated by silt (67 %) and sand (19.5 %), low water velocities (generally between 0-18 cm/s) allowing for fine sediment deposition, and lack of a thermocline for coolwater sanctuary are several elements influencing the Pend Oreille River to be unsuitable for salmonids (Bennett and DuPont 1993). Bennett and DuPont (1993) also noted that improperly placed culverts restricted salmonids from accessing tributary streams, and land-use practices has degraded spawning and rearing habitat for salmonids in accessible tributaries.

Forest management practices including timber harvest and road construction, both past and current, are major factors in degraded watershed conditions and aquatic habitats in the Pend Oreille Lake watershed managed by the Idaho Panhandle National Forests (Cross and Kasun, USFS, pers. comm. 1993). Within the Priest Lake and Pend Oreille watershed there is a trend toward degraded stream conditions which is now a constraint to the management of about 70 % of National Forest lands (Kasun, USFS, in litt. 1992a; USFS, in litt. 1994a).

The development of road systems in the Pend Oreille drainage have contributed to extensive sediment input and poor channel conditions throughout the drainage. Road densities have been used to correlate the probability of a stream to support bull trout populations (Lee et al. 1997 in USFS, in litt. 1998e). Meaning, the higher the road densities, the lower the probability of finding strong bull trout populations. Baseline environmental conditions for road densities were considered good if densities were less than 0.7 m/m2, moderate if densities were between 0.7 m/m2 and 1.7 m/m2, and poor if densities were greater than 1.7 m/m2 (Lee et al. 1997 in USFS, in litt. 1998e). While these determinations were made for bull trout, they too can be used for assessing threats to WCT. It was determined that within the 19 HUCs the USFS and the Service are conducting bull trout consultation on in the Pend Oreille Lake and River watersheds, road densities are considered poor in 11, moderate in 6, and good in 2 (USFS, in litt. 1998e). The range of road densities in these HUCs is 0.6-4.5 m/m2. Within the Priest Lake watershed, it was determined that within the 16 HUCs the USFS and the Service are conducting bull trout consultation, road densities are considered poor in 13, moderate in 2, and good in 1 (USFS, in litt. 1998e). The range of road densities in these HUCs is 0.0-6.2 m/m2. Until road densities are reduced significantly in this drainage, threats to WCT are considerable.

Within the Pend Oreille Lake and river watersheds, the U.S. Forest Service (52) and Bureau of Land Management (15) have identified ongoing or proposed actions for which bull trout consultation is occurring. Within the Priest Lake watershed, the U.S. Forest Service has identified 71 ongoing or proposed actions in 16 watersheds for which bull trout consultation is occurring. This does not include proposed or ongoing actions in HUCs in the Pend Oreille Lake (11) and Priest Lake (3) watersheds where bull trout are thought to be absent and consultation on actions does not occur, or include proposed actions that are being completed through the streamlining process (USFS, in litt. 1998e; S. Audet, USFWS, pers. comm. 1999). In addition, there is approximately 204,406 acres of State endowment land that encompass approximately 15 HUCs in this Priest Lake watershed that are administered by IDL where consultation does not occur.

In recent years, the Halfway, Silverleaf, and Packsaddle timber sales resulted in additional logging and roading in Gold Creek drainage. There was a local working group guided by State authorities attempting to develop best practices to restore Gold Creek, but it was abolished in 1996. On June 13, 1997, the record of decision was signed for the Packsaddle timber sale. This project includes logging in unstable soils of Kickbush Gulch, tributary to Gold Creek, and more logging in unstable soils in North Gold Creek drainage (Sedler, in litt. 1997). The Forest Service is also proposing to harvest timber from more than 1,000 acres during the West Gold Project (USFS, in litt. 1998f). The U.S. Forest Service has adopted the Gold Creek complex as a focal watershed to provide for a high probability of maintaining native fish communities. Focal watersheds as outlined by the Aquatic Ecosystem Strategy (USFS, in litt. 1994) are watersheds where restoration efforts will improve the current stream channel and fish habitat conditions. Thus far, there have been no active restoration efforts to the stream channel and fish habitat except those associated with ongoing actions.

Major hydrologic changes are ongoing in much of the Lightning Creek system, where, in some reaches, channel changes annually, and it appears as if a "giant cat [tractor] with a ripper went through it" (Nelson, IDFG, pers. comm. 1993). Roads in Rattle and Lightning Creek washed out again in February 1996 attesting to the instability watershed conditions in this drainage (Chatel, USFS, pers. comm. 1997).

As in Lightning Creek, visible changes have occurred during recent years in Trestle Creek, including new channels, channel broadening, heavy bed load movement and log jams (Nelson, IDFG, pers. comm. 1993).

During 1993, the Forest Service determined riffle stability indices for 25 sites in Trestle Creek, with a range of 49 to 83, mean 67 (Cross, USFS, in litt. 1993, from bull trout admin. record). Indices between 50 and 99 are regarded as a continuum of stream aggradation. Index numbers less than 70 are considered to represent dynamic equilibrium and to be generally supportive of fish habitat needs. Index values greater than 90 are out of equilibrium (Kappesser 1993). Of the 25 indices from Trestle Creek, 10 were greater than 70.

There have been attempts to rectify recently observed habitat degradation and potential intermittency in Trestle Creek. Based on State and Federal Clean Water Act antidegradation regulations and the State Forest Practices Act, a local working committee was established to develop best management practices to protect Trestle Creek because it is very important as bull trout spawning and rearing habitat (Corsi, IDFG, pers. comm. 1994). This program was abolished in 1996. The U.S. Forest Service identified Trestle Creek a focal area for sustaining strong native fish populations (USFS, in litt. 1994b). Independently, the Forest Service has completed watershed analysis and hands-on restoration on the public lands portions of Trestle Creek (USFS, in litt. 1995b). Ongoing monitoring will evaluate effectiveness of this work (Chatel, USFS, pers. comm. 1997).

The Forest Service determined riffle stability indices ranging from 67 to 95 (mean 82) at five sites on Gold Creek within spawning areas (Kasun, in litt. 1992b). This is a strong indication of disequilibrium, channel aggradation and aquatic habitat loss in Gold Creek (Kappesser 1993). These findings were verified when the Idaho Division of Environmental Quality estimated the riffle stability in this same stream to be 84 (Hoelscher, in litt. 1993, from bull trout admin. record). The U.S. Forest Service identified Gold Creek a focal area for sustaining strong native fish populations (USFS, in litt. 1994b). This stream is considered to be water quality limited in regard to attainment of beneficial uses from sediments released through a combination of forest management, roading, and mining.

In excess of 100,000 cubic yards of mining wastes have been deposited and continue to be redistributed into the Gold Creek system. Problems in Gold Creek are being addressed under Clean Water Act antidegradation regulations by the State of Idaho, in part because of redistribution of fine-grained materials released from mining activities (B. Hoelscher, IDEQ, pers. comm. 1994). Several large landslides in recent years have contributed fine materials to the stream adding to the degraded condition of the stream channel.

Similarly, instability was observed with heavy bed load deposition and channel realignment in lower Granite Creek. This is attributed to latent effects of older timber sales and roading (Chatel, USFS, pers. comm. 1997). In recent years, excessive bed load aggradation has formed a barrier (seasonal) with approximately 100 meters of stream going sub-surface just above Sullivan Springs in Granite Creek (Chatel, USFS, pers. comm. 1997; D. Vidergar, U. of Idaho, pers. comm. 1998).

During the winter of 1996-97, snow, ice, and wind, damaged or blew over trees throughout the Priest Lake watershed which provided ideal breeding conditions for the douglas-fir bark beetles (USFS, in litt. 1999c). This resulted in an outbreak for which approximately 15,300 acres of mature Douglas-fir trees were killed. The U.S. Forest Service is currently developing the Douglas-fir Beetle Project for the purpose of harvesting trees in stands infested with bark beetle. The proposed action would harvest approximately 5,271 acres, of which approximately 3,167 acres are proposed for regeneration harvests. Regeneration harvests would likely retain less than 30 % of the stand basal area and some openings will exceed 40 acres. In addition, 14.3 miles of temporary roads will be constructed and 83.7 miles of roads will be reconstructed. The intent of the action is to harvest trees in stands infested with bark beetle that may then provide funding for vegetation and aquatic restoration. Extensive road maintenance, stream crossing removal and improvements, and road obliteration are proposed (USFS, in litt. 1999d).

In the Granite Creek subwatershed (Priest Lake), three actions (road repair, earthen barrier, and the Stimson access road) have been identified as a threat "likely to adversely affect" bull trout because the actions contribute sediments to the stream and contributed to channel instability that delay recovery. Westslope cutthroat trout have been identified as present in Granite Creek and are expected to be adversely affected as well (USFS, in litt. 1998g; IDFG, in litt. 1998a).

B. Overutilization for commercial, recreational, scientific, or educational purposes

Within Pend Oreille Lake, Pend Oreille River, and the Clark Fork River, restrictive harvest regulations for WCT have been implemented. The Gold, North Gold, and Trestle Creek tributaries have been closed to all fishing, while other tributaries in the drainage have restrictive regulations allowing the harvest of two trout from the Saturday of Memorial Day weekend to August 31. The harvest of four trout (excluding bull trout) is permitted year-round in Pend Oreille Lake and from the Saturday of Memorial Day weekend to August 31, in the Clark Fork River (IDFG, in litt. 1998b). While these regulations have been implemented to protect native species, WCT are vulnerable to angling and relatively low fishing effort can produce high levels of exploitation, which in turn could prevent WCT from recovering even under special regulations (Rieman and Apperson 1989). Although sport fishing harvest levels have not been monitored for the lake since 1991, the State of Idaho believes that annual harvest levels today are similar to that in 1991 of approximately 750 WCT (Horner, IDFG, pers. comm. 1999).

Within the Priest Lake watershed, restrictive fishing regulations established in 1982 closed fishing in major tributary streams that were used by WCT for rearing, and implemented a harvest minimum size limit of 38 cm for Priest and Upper Priest Lake. However, lake trout predation remained a limiting factor to increasing WCT numbers and in 1988 the consumptive fishery was closed (Mauser et al. 1988). Prior to that time, harvest by anglers was identified as one reason for their decline.

Another activity believed to contribute to the decline of WCT in the Priest Lake watershed was spawn taking. During the late 1930s and the 1940s, WCT spawners in Granite and Gold Creeks were collected at traps and stripped of eggs and milt. Spawn taking was eliminated in 1947, that year 1,660 spawners were caught at the Granite Creek trap. Approximately 30 % of the eggs collected from WCT at these locations were distributed to waters other than the Priest Lake watershed (USFS, in. litt.1998g)

C. Disease or predation

In Priest Lake, once lake trout became abundant after opossum shrimp were established, the WCT fishery declined dramatically. This is considered to be a major factor limiting WCT numbers, and is believed to be the primary reason for the failure of WCT enhancement (Mauser et al. 1988; Mauser et al. 1988 in Rieman and Apperson 1989). Predation of WCT is known to occur by numerous native (bull trout and northern pikeminnow) and introduced species (lake trout) and is an important source of mortality to WCT, and can act as a destabilizing force when habitat loss and overexploitation is experienced (Rieman and Apperson 1989).

There was no known lake trout harvest in Lake Pend Oreille during the early 1980s (Pratt 1984b). Lake trout did not appear in the 1985 creel census reports but 25 fish were reported in 1990. During 1991, creel checkers observed 43 lake trout harvested and many more were reported to have been harvested by anglers targeting this species (Paragamian and Ellis 1993). This is a potential threat (predation) to WCT in Lake Pend Oreille because there is no established remedy should lake trout become a dominant fish species. In nearby Priest Lake, once lake trout became abundant after opossum shrimp were established, the WCT fishery declined dramatically and is believed to be the primary reason for failure of cutthroat enhancement (Mauser et al. 1988; Mauser et al. 1988 in Rieman and Apperson 1989).

The water source (Spring Creek) for the Clark Fork Hatchery is inhabited by brook trout that have Infectious Pancreatic Necrosis (IPN). The broodstock fish (including rainbow trout and WCT) from the Clark Fork Hatchery that are used for stocking lakes, rivers, and streams in this drainage (and all of Idaho Panhandle region) are known to be infected with IPN (Horner, IDFG, pers. comm. 1999). This is a contagious virus that effects young fish, generally 80-90 mm in length and may cause large losses (Van Duijn 1967; Horner, IDFG, pers. comm. 1999). The extent of this threat in this drainage is unknown. However, because Spring Creek is also used as a water source for the town of Clark Fork, Idaho, treating the brook trout and the stream to rid it of IPN is unlikely, and fish from the Clark Fork Hatchery with IPN will continue to be propagated in this drainage (Horner, IDFG, pers. comm. 1999). Available information does not identify any other disease threats in this drainage.

In 1998, bull trout conservation efforts by IDFG resulted in the removal of 912 lake trout from Upper Priest Lake. However, increasing catch rates during the latter part of the project (Oct. and Nov.), combined with information from tagged fish, indicated that immigration from Priest Lake is occurring (Fredericks 1999). The IDFG is currently evaluating the feasibility of preventing lake trout immigration to Upper Priest Lake with fish passage barriers in the Thorofare. It is uncertain whether or not IDFG is willing to accept the political consequences of lake trout population control throughout the Priest Lake watershed, thus controlling the threat. The IDFG also removed brook trout in three Upper Priest Lake streams (Rock, Ruby, and Trapper Creeks). It was determined based on depletion estimates that over 90 % of brook trout from Rock and Trapper Creeks and approximately 50 % of the brook trout were removed from Ruby Creek (Fredericks 1999). While these projects were completed with primary emphasis on bull trout conservation, WCT are also expected to benefit from the work completed by IDFG.

D. The inadequacy of existing regulatory mechanisms

The Forest Service INFISH strategy has amended the Idaho Panhandle National Forests plan to allow no new net-loss of native trout habitat (USFS 1995). Overall, INFISH has worked to maintain degraded aquatic habitat and needs to be upgraded to restore degraded habitats (B. Roper, USFS, pers. comm. 1999). On the Idaho Panhandle National Forests, about 97 % of all actions are in compliance with INFISH.

The AES adopted by the Idaho Panhandle National Forests is viewed as affirmative direction to conduct watershed restoration and maintain native fish communities (USFS, in litt. 1994b). The AES is directed primarily to bull trout spawning and juvenile rearing areas, with a considerable amount of WCT not addressed. The application of the AES takes a "passive" approach in watersheds that are designated as "Focal" watersheds, in that the Forest Service tends to avoid management action in these areas that would degrade habitat (USFS, in litt. 1994b; Roper, USFS, pers. comm. 1999). In other watersheds, the application of the AES is meant to take an "active" approach at restoring degraded habitat. However, restoration is not occurring as fast as it should because of funding constraints (Roper, USFS, pers. comm. 1999).

Forest practices on state and private lands are subject to minimum standards set forth in the Idaho Forest Practices Act (FPA). These standards are administered and enforced by and the Idaho Department of Lands (IDL) and compliance in general is high (J. DuPont, IDL, pers. comm. 1999; Corsi, IDFG, pers. comm. 1998). There is approximately 247,878 acres of endowment land in this drainage that are administered by IDL. When determined to be inadequate to protect beneficial uses, standards in the FPA are amended (DuPont, in litt. 1998). A recent addition to the FPA is the Cumulative Watershed Effects process developed to ensure that cumulative impacts from two or more logging operations will not impair water quality (DuPont, in litt. 1998).

Standards set forth in the FPA for state and private lands are generally less than those on federal lands and in some cases are inadequate (Corsi, IDFG, pers. comm. 1998; Roper, USFS, pers. comm. 1999). While the FPA affords adequate standards to keep sediment out of the streams, in some cases is inadequate in protecting the Stream Protection Zones by having minimal standards for long term large woody debris and shade retention (Corsi, IDFG, pers. comm. 1998). The FPA was also found to be inadequate when looking at road densities and the hydrologic impacts of clear cutting within rain on snow zones. While the standards set forth in the FPA are considered a step in the right direction, there are still holes that need to be addressed for protecting beneficial uses of streams administered by IDL (Corsi, IDFG, pers. comm. 1998).

On July 10, 1998, the Columbia River population of bull trout were listed as threatened under the Endangered Species Act. Section 7 (a) (2) of the ESA requires that any actions with Federal involvement that may affect bull trout go through the consultation process with the U.S. Fish and Wildlife Service. Where bull trout and WCT have overlapping ranges, consultation to minimize or eliminate adverse affects of the action on bull trout could be expected to minimize effects to WCT as well. However, within the Pend Oreille Lake drainage there are many tributary streams where bull trout are thought to be absent and consultation on actions has not occurred. Using data generated by ICBEMP for the Pend Oreille Lake watershed, 51 HUCs compose this drainage of which bull trout are known or predicted present in 21 HUCs, and known or predicted absent in 30 HUCs. The ICBEMP data indicates that WCT are known or predicted present in 49 of these HUCs, and known or predicted absent in two HUCs. Therefore, in 30 HUCs, WCT may not receive adequate protection from ongoing and future actions as a secondary benefit of protecting bull trout. Within the Priest Lake watershed, 36 HUCs compose the drainage, of which bull trout are known or predicted present in 13 HUCs, and known or predicted absent in 23 HUCs. The ICBEMP data indicates that WCT are known or predicted present in 35 of these watersheds, and known or predicted absent in one HUC. Therefore, in 22 HUCs, WCT may not receive adequate protection from ongoing and future actions as a secondary benefit of protecting bull trout.

Seventeen stream segments totaling 194.51 miles identified as occupied by WCT are now designated among the water quality limited streams under section 303 (d) of the Clean Water Act of which none have been restored (IDEQ, in litt. 1998). Sediment and temperature are identified as the primary pollutants responsible for designation on the list. Forest management and roads are the primary impact to these tributaries and associated watersheds.

E. Other natural or manmade factors affecting the species' continued existence

Stocking records dating back to 1925 from the IDFG indicates that numerous species of nonnative salmonids and various other exotic fishes have been stocked within the Lake Pend Oreille drainage (IDFG, in litt. 1998c). In this time frame, there has been thousands of separate stockings of various amounts ranging from a few fish to several hundred thousand. With the introduction of exotic fish species, competition, predation, and hybridization has increased (Rieman and Apperson 1989). Additional stocking of nonnative fishes occurred prior to 1925 by IDFG, sportsman groups, and private individuals (B. Hutchinson, IDFG, pers. comm. 1999).

Rieman and Apperson (1989) summarized that while competition between WCT and nonnative fish is minimized in streams by habitat segregation, the loss of suitable WCT habitat has allowed for nonnative fishes to expand into altered habitats. Brook trout tend to replace WCT where they have declined, whereas rainbow trout (once established and naturally reproducing) can displace WCT where the two overlap. The coexistence of rainbow trout and WCT likely results in extensive hybridization (Rieman and Apperson 1989). These threats are occurring in the Pend Oreille drainage with rainbow trout and brook trout observed in 70 % and 45 %, respectively of tributary streams surveyed (Hoelscher 1993; Pratt 1984b). These threats have also been documented in the Priest Lake watershed with brook trout and rainbow trout observed in many of the tributary streams surveyed. The stocking of hatchery trout may not directly displace WCT, but create increased fishing pressure and aggravate the overexploitation of WCT in the same waters (Rieman and Apperson 1989). In addition, fishing pressure may increase with the wide distribution and abundance of wild nonnative species, which may as well aggravate the exploitation of WCT in the same waters.

Brook trout were introduced into many tributaries of Priest Lake prior to the 1920s and have replaced WCT in many tributaries and reduced rearing habitat by an estimated 50 % (Mauser et al. 1988; Bjornn 1957 in Mauser et al. 1988). Westslope cutthroat trout were heavily stocked on top of established brook trout populations but failed to displace them and did not improve WCT survival (Rieman and Apperson 1989).

Pend Oreille Drainage, Washington

A. The present or threatened destruction, modification, or curtailment of the species' habitat or range

Dams for hydroelectric development and flood control, such as Boundary, Box Canyon, Calispell Creek, Albeni Falls, Ione Municipal, Mill Pond, and Sullivan Lake form barriers that have isolated WCT in the Pend Oreille River drainage (Schneider, USDI, in litt. 1997; Shuhda, USFS, pers. comm. 1999).

"From the dam site (Box Canyon) upstream for approximately 25 miles is found the majority of riffle and fishable pool area in the entire Pend Oreille River...When Box Canyon Dam is built at least 75 % of the best water in the Pend Oreille will be destroyed as trout and whitefish habitat" (Earnest 1952, WDG, in Ashe and Scholz 1992).

Since impoundment in 1955 at Box Canyon Dam, the Pend Oreille River has become a seasonally warm, slow moving reservoir, unfavorable to salmonids (including fluvial WCT), and favorable to the exotic species that now dominate (Ashe and Scholz 1992). In general, decreased habitat diversity, increased water temperatures, and lower food availability were the result of dam construction. During the months of July, August and the first week of September 1997, the water quality criteria of 20 oC was exceeded daily throughout the reservoir (Cascade Environmental Services, Inc. and Duke Engineering & Services, Inc. 1998).

Habitat conditions in the reservoirs are marginal for WCT with water temperatures reaching 73 oF (approx. 23 oC) in Box Canyon and 72 oF (approx. 22 oC) in Boundary Reservoirs (Shuhda, USFS, pers. comm. 1999). Optimal water temperature for WCT is 11 oC to 15.5 oC (Hickman and Raleigh 1982 in Ashe and Scholz 1992). Water temperatures in this range are being tolerated by nonnative fish species such as brown and rainbow trout (Bennett and Liter 1991). Within the 55 mile section of Box Canyon Reservoir, only three areas had a substrate composed of something other than sand and silt (Shuhda, USFS, pers. comm. 1999). Now only about 8 miles (approximately 15 %) of the Box Canyon reach are considered as riverine habitat that trout species prefer (Ashe and Scholz 1992).

Ashe and Scholz (1992) indicate that even if the Pend Oreille River could support a healthy trout population it appears that the tributaries to the Box Canyon Reservoir have only limited potential to produce large numbers of trout that could be recruited into the fishery in the reservoir. They found that where spawning habitat was of good quality, the tributaries are typically unproductive with food availability limiting trout production.

Threats to WCT in tributaries throughout this drainage include increased water temperature, sediment loading from surface erosion, bank erosion, and habitat degradation from logging, road system deficiencies, and grazing (Ashe and Scholz 1992; C. Vail, WDFW, pers. comm. 1997; KNRD and WDFW 1995). LeClerc Creek drainage is heavily entered for timber harvest and there has been excessive grazing by livestock in riparian habitats. In addition railroads were built in some creek bottoms, and in the 1920s, flumes and splash dams were commonly used (Shuhda, USFS, pers. comm. 1997) These practices have resulted in water temperature greater than 60 oF and movement of granitic sediments. On the West Branch of LeClerc Creek, a splash dam (Diamond Match) has created a migration barrier approximately 15 feet in height which has trapped a significant amount of fine sediment behind it. The stability of this structure is of concern and if it fails will be devastating to the stream. Westslope cutthroat trout are present below this structure (Maroney, KNRD, pers. comm. 1999).

Land-use practices within the Pend Oreille River drainage has degraded both habitat and community dynamics of native WCT. The degraded conditions have been conducive to the nonnative fish communities (KNRD and WDFW 1995). It was found that within two snorkeling reaches on Mill Creek that had higher quality habitat, the density of WCT was high, however, the abundance of brook trout within these reaches was far greater.

Analysis of habitat data from seven tributary streams (Mill, Fourth of July, Cee Cee Ah, Cedar, Mineral, Whiteman, and Indian Creeks) indicated that high rates of sedimentation and lack of overwintering habitat are of concern (KNRD and WDFW 1995). Six of the seven streams surveyed (except Cedar Creek) during the "Kalispell Resident Fish Project" (1995) exhibited high rates of embeddedness (mean = 72.4 % +/- 12.8) and low habitat diversity with limited pools. Physical instream inventory data for five tributary streams in the LeClerc watershed indicated that in all reaches (33) surveyed, INFISH Riparian Management Objectives for pools/mile (range 0-24) and water temperature in the summer months were not met (USFS, in litt. 1997b). Within six perennial, fish bearing streams in the Lost Ruby watershed, all are experiencing high levels of embeddedness (USFS-Lost Ruby, in litt. 1995).

B. Overutilization for commercial, recreational, scientific, or educational purposes

The harvest of two WCT is allowed in the Pend Oreille River year around, and in tributaries from June 1 to October 31 (WDFW, in litt. 1998b). Since WCT are vulnerable to angling, even relatively low fishing effort can produce high levels of exploitation (Rieman and Apperson 1989). The total estimated catch of WCT in the Pend Oreille River in 1989 was 91 with 86 harvested (Barber et al. 1989 in Ashe and Scholz 1992). The resident form of WCT found in the upper most reaches of tributaries are less susceptible to harvest because of difficulty in accessing the stream and because they are generally of small size and not selected by anglers (WDFW, in litt. 1998a).

C. Disease or predation

Predation of WCT is known to occur by numerous native and introduced species and is an important source of mortality to WCT and can act as a destabilizing force when habitat loss and overexploitation is experienced (Rieman and Apperson 1989). It was determined that 63 % of the fish community (such as northern pikeminnow, largemouth bass, yellow perch, brown trout, and rainbow trout) in Box Canyon Reservoir were potential predators to young of the year salmonids (Bennett and Liter 1991 in Bennett and Garrett 1994). Approximately 150,000 large mouth bass are stocked annually into Box Canyon Reservoir by the KNRD (Maroney, KNRD, pers. comm. 1999)

The operation of a weir in Skookum and Tacoma Creeks indicated that a majority of various trout species that recruit to the reservoir annually are subyearlings (25-50 mm) and are probably subject to heavy predation (Bennett and Garrett 1994). However, most of these were brown trout and very few were WCT. Eighteen WCT (46-440 mm) were captured migrating downstream (in traps) in seven tributaries (Mill, Middle, E. Branch LeClerc, W. Branch LeClerc, Cedar, Ruby, and Indian Creeks) in 1998 (KNRD, in litt. 1999; FERC 1999). Regardless of the level of WCT recruitment from these tributaries during the studies, it is assumed that WCT recruit from tributaries throughout the drainage, and if they recruit as subyearlings, they too would be subject to heavy predation. Available information does not identify any disease problems in this drainage.

D. The inadequacy of existing regulatory mechanisms

The Forest Service INFISH strategy has amended the Colville National Forest Plan to allow no new net-loss of native trout habitat (USFS 1995). Overall, INFISH has been a good tool for fisheries resource managers in this drainage with respect to having clearer direction and influence regarding timber sales and grazing management. However, INFISH works to maintain degraded aquatic habitat because it doesn't give direction to restore degraded aquatic habitat. INFISH was originally designed as an interim policy and lacks funding to monitor projects to determine if they are within standards (Shuhda, USFS, pers. comm. 1999). Most streams in the New Moon Ecosystem Analyses area fail to meet the INFISH Riparian Management Objectives for width to depth ratio and pool frequency (USFS, in litt. 1996a; 1996b).

In tributaries that have multiple ownership where private lands are found above federal lands in the watershed, degradation of aquatic habitat on federal lands may continue even when INFISH standards are met. This is expected because the Washington Forest Practices Act has had insufficient standards in type 3, 4, and 5 streams to protect aquatic habitat and detrimental effects on channel dynamics downstream continues (Maroney, KNRD, pers. comm. 1999). Emergency Rules established by the Forest Practices Board for bull trout and suitable habitat amend the Forest Practices Act and provide new standards that will better protect riparian areas on state and private land where applied. However, these standards are only applied to forest practices that are initiated after the November 18, 1998, effective date and do not apply to ongoing projects nor does it do anything to enhance past indiscretions (M. Eames, USFWS, pers. comm. 1999).

On July 10, 1998, the Columbia River population of bull trout were listed as threatened under the Endangered Species Act. Section 7 (a) (2) of the ESA requires that any actions with Federal involvement that may affect bull trout go through the consultation process with the U.S. Fish and Wildlife Service. Where bull trout and WCT have overlapping ranges, consultation to minimize or eliminate adverse affects of the action on bull trout could be expected to minimize effects to WCT as well. However, within the Pend Oreille River drainage there are many tributary streams where bull trout are thought to be absent and consultation on actions has not occurred. Using data generated by ICBEMP for the Pend Oreille River drainage, 40 HUCs compose this drainage of which bull trout are known or predicted present in 25 HUCs, and known or predicted absent in 15 HUCs. The ICBEMP data indicates that WCT are known or predicted present in 38 of these watersheds, and known or predicted absent in two HUCs. Therefore, in 13 HUCs, WCT may not receive adequate protection from ongoing and future actions as a secondary benefit of protecting bull trout.

The Pend Oreille River and three tributary streams that WCT are known to occupy are designated as water quality limited streams under section 303 (d) of the Clean Water Act in this drainage (WDE, in litt. 1999). Water temperature was identified as the parameter exceeding established criteria for the Pend Oreille River, Lost Creek, and Ione Creek, while Skookum Creek exceeded criteria for fecal coliform. No TMDLs have been established in this drainage and these threats continue.

Conservation efforts to enhance habitat and populations of native WCT and bull trout have begun in tributaries to Box Canyon Reservoir in recent years. In 1995, the Kalispel Natural Resource Department (KNRD) in conjunction with WDFW initiated the Kalispel Resident Fish Project. Enhancement projects began in 1996 have accomplished riparian fencing and vegetation planting, created instream habitat, and removed a beaver dam that was a migration barrier and created new spawning habitat with its removal. This stream enhancement work has been completed in Whitman, Mineral, Middle Branch LeClerc, Forth of July, Mill, Cee Cee Ah, Browns, Skookum, and Indian Creeks (KNRD 1998, draft). The Colville National Forest has also been completing enhancement projects in LeClerc Creek that includes riparian planting and fencing (Shuhda, USFS, pers. comm. 1999). However, few habitat enhancement projects have been completed in tributaries to Boundary Reservoir.

A settlement between the Pend Oreille County PUD and numerous parties (Department of Interior, BIA, Kalispel Tribe of Indians, USFS, and WDFW) was reached in May 1998. The settlement ($6.3 million) was for compensation of environmental damages caused by illegal innundation of non-project lands by the PUD's Box Canyon Hydroelectric Project. The settlement will be used for environmental mitigation and enhancement. Tributary assessment and enhancement projects ($870,000) to benefit cold water fishery resources has been identified as terms of the agreement (USFWS, in litt. 1998). Stream assessments in Cee Cee Ah, LeClerc, Middle Creek, Ruby, Skookum and Calispell Creek watersheds will be completed over three years beginning in 1999 (KNRD, in litt. 1999). The settlement agreement also identified terms for: erosion control measures ($200,000), Habitat Evaluation Procedures ($238,000), habitat acquisition, restoration, and/or enhancement ($2.5 million) based on results of the Habitat Evaluation Procedures, and for erosion control and fish and wildlife projects ($900,000) on the Colville National Forest (USFWS, in litt. 1998). Enhancement work will begin in 1999 and continue for 4 years (H. Browers, USFWS, pers. comm. 1999).

E. Other natural or manmade factors affecting the species' continued existence

Rieman and Apperson (1989) summarized that while competition between WCT and nonnative fish is minimized in streams by habitat segregation, the loss of suitable WCT habitat has allowed nonnative fishes to expand into altered habitats. Brook trout tend to replace WCT where they have declined, whereas rainbow trout (once established and naturally reproducing) can displace WCT where the two overlap. Other nonnative fish species such as brown trout can influence WCT through competition and predation. Although the distribution and abundance of rainbow trout in tributary streams in Box Canyon reservoir is limited, they are more abundant in Boundary Reservoir. Rainbow trout and WCT were found to prefer the same type of habitat in the Sullivan Creek watershed and where the two coexist, hybridization is likely. These threats occur in the Pend Oreille River drainage with brown, brook, and/or rainbow trout observed in most of the tributary streams surveyed. In addition, the wide distribution and abundance of nonnative species increases fishing pressure which may aggravate the exploitation of WCT in the same waters.

Since the early 1900s, stocking programs have introduced nonnative trout and other exotic species into the Pend Oreille River watershed (Bennett and Liter 1991; Ashe and Scholz 1992). The introduction of rainbow, brown, and brook trout has greatly increased the risk of competition, predation, and hybridization. The last stocking of brook trout in this drainage was in 1992 and rainbow trout in 1993 (Shuhda, USFS, pers. comm. 1999). Limited genetic analysis on salmonids has been conducted in this drainage. Fish from lower Sullivan Creek were shown to be pure rainbow trout likely derived from coastal stocks and fish from Sand Creek are hybrid swarms with redband trout and coastal rainbow trout contributing (93 %) most of the genetic material and native WCT genes comprising the remaining material (Leary, in litt. 1997; Kanda and Leary, in litt. 1998).

Recent studies found that brown trout (8 of 13 streams sampled) and brook trout (12 of 13 streams sampled) are the most widely distributed and abundant trout species in tributaries to Box Canyon Reservoir. Brown trout were found to be the most abundant in downstream reaches and brook trout were highest in upstream reaches (Ashe and Scholz 1992; Bennett and Liter 1991). Rainbow trout were found to have limited distribution and abundance during these studies. When more than one nonnative salmonid is present within a tributary, the native WCT are found in low densities ranging from 0.1-13.2 fish/100 m2 or are absent altogether (KNRD and WDFW 1995). Recent monitoring conducted by the KNRD found that in only two tributaries (of 10 surveyed), WCT had higher densities than brook trout (KNRD, in litt. 1999). Within the Lost Ruby and Gardin-Taco Analysis Areas, brook trout are replacing or have a competitive advantage over WCT in most stream reaches because of habitat degradation (USFS, in litt. 1995; USFS, in litt. 1998h).

In 1997, snorkeling surveys conducted in five tributary streams (Slate, Sullivan, Flume, Sweet, and Sand Creeks) to Boundary Reservoir identified that nonnative species (rainbow, brook and brown trout) were most abundant comprising 74 % of the fish observed (R2 Resource Consultants, Inc. 1998). Westslope cutthroat trout accounted for only 16 % of the fish observed and WCT x rainbow trout hybrids accounted for another 5 %. Of the nonnative species present, rainbow trout were the most abundant comprising 60 % of all fish observed. As indicated above, rainbow trout from Sullivan Creek are of coastal origin and those fish from Sand Creek are hybrid swarms of coastal rainbow, redband, and WCT.

The construction of Box Canyon Dam has created sloughs at the mouths of many tributaries where they enter the reservoir. These sloughs have areas of low or no flow and may act as thermal or migration barriers between the tributaries and the reservoir. This type of habitat is utilized by numerous fish species ( native and nonnative) and a predator trap is created (Kalispel Tribe of Indians, in litt. 1997).

Spokane River Drainage

A. The present or threatened destruction, modification, or curtailment of the species' habitat or range

Forest management practices including timber harvest and road construction, both past and current, are major contributors to degraded watershed conditions and aquatic habitats on public lands in the Spokane River drainage managed by the Idaho Panhandle National Forests (Cross and Kasun, USFS, pers. comm. 1993; Isaacson 1994; Cross and Everest 1995).

During the winter of 1996-97, snow, ice, and wind, damaged or blew over trees throughout the Spokane River drainage which provided ideal breeding conditions for the douglas-fir bark beetles (USFS, in litt. 1999c). This resulted in an outbreak for which approximately 6,578 acres of mature Douglas-fir trees were killed. The U.S. Forest Service is currently developing the Douglas-fir Beetle Project for the purpose of harvesting trees in stands infested with bark beetle. The proposed action would harvest approximately 10,785 acres, of which approximately 1,053 acres are proposed for regeneration harvest. Regeneration harvests would likely retain less than 30 % of the stand basal area and some openings will exceed 40 acres (range 5-85 acres). Within the project area, 1,170 feet of riparian vegetation will be removed, 8.7 miles of temporary roads constructed, and 24.9 miles of roads reconstructed. The intent of the action is to harvest trees in stands infested with bark beetle that may then provide funding for vegetation and aquatic restoration. Extensive road maintenance, stream crossing removal and improvements, and road obliteration are proposed (USFS, in litt. 1999d). The Service and Forest Service are currently consulting on this project minimize adverse effects on fish and aquatic habitat.

Within the Spokane River drainage, the U.S. Forest Service and Bureau of Land Management have identified 1,573 and 48, respectively, ongoing or proposed actions for which bull trout consultation is occurring. This does not include proposed or ongoing actions in the entire South Fork Coeur d'Alene River drainage HUCs where bull trout are thought to be absent and consultation on actions does not occur or proposed actions that are being completed through the streamlining process (USFS, in litt. 1998i; Audet, USFWS, pers. comm. 1999).

Anthropogenic changes within the St. Joe River watershed have added to environmental disturbances in terms of magnitude and frequency that are far beyond the historic range of natural variability causing the biotic system to be compromised (USFS, in litt. 1998j). The most profound disturbances are from roads and road networks which have created extensive mass wasting. From Gold Creek downstream, tributary fish habitat is in an impaired condition and on a downward trend.

Development of road systems in the Spokane River drainage has contributed to extensive sediment input and poor channel conditions throughout the drainage. Road densities have been used to correlate the probability of a stream to support bull trout populations (Lee et al. 1997b in USFS, in litt. 1998e). Meaning, the higher the road densities, the lower the probability of finding strong bull trout populations. Baseline environmental conditions for road densities were considered good if densities were less than 0.7 m/m2, moderate if densities were between 0.7 m/m2 and 1.7 m/m2, and poor if densities were greater than 1.7 m/m2 (Lee et al. 1997b in USFS, in litt. 1998e). While these determinations were made for bull trout, they too can be used for assessing threats to WCT. It was determined that within the 58 HUCs the USFS and the Service are conducting bull trout consultation, road densities are considered poor in 33, moderate in 16, and good in nine (USFS, in litt. 1998i; 1998j). The range of road densities in these HUCs is 0.0-9.7 m/m2. The nine HUCs that have good road densities are all located in the upper portion of the St. Joe River watershed and until road densities are reduced significantly in the remainder of the drainage, threats to WCT are considerable.

The mean residual pool volume in managed watersheds are significantly reduced as compared to unmanaged watersheds. Changes in quality and frequency of pool habitat as a result of channel destabilization has had a negative influence on the carrying capacity of WCT (Cross and Everest 1995). Dunnigan (1997) determined that the lowest WCT densities in the Coeur d'Alene River watershed coincided with watersheds that had the most intense forest practices within the past 30 years and the lowest pool frequencies. Bedload accumulation has filled many pools and turned them into riffles or glides in the North Fork Coeur d'Alene River (Davis et al. 1997 in draft). The mainstem St. Joe River pool habitat conditions are important for long term viability of WCT, as they utilize this area as over-wintering habitat. Juvenile WCT typically enter the substrate for cover in the winter and the larger fish congregate in pools, often in large numbers (McIntyre and Rieman 1995; Peters 1988 and Lewinsky 1986 in McIntyre and Rieman 1995). Habitat conditions from Gold Creek downstream have been and continue to be a major concern due to bedload inputs from tributary streams (USFS, in litt. 1998j).

Surveys using a Riffle Stability Index (RSI) provided a direct measurement of sediment aggradation, or sediment accumulation in stream riffles. The RSI numbers can range from less than 50 to 100, where 100 represents a riffle that is entirely aggraded. Values between 40 and 60 indicate riffles that are in dynamic equilibrium. Disequilibrium occurs progressively with values between 70 and 90. Twenty nine sites in unmanaged watersheds in the Coeur d'Alene and St. Joe drainages had a mean on RSI of 51, while the RSI for 268 sites in managed watersheds had an average of 79.5, indicating a trend toward disequilibrium (Kappesser 1993). The RSI at Prichard, on the North Fork Coeur d'Alene River was 60 in 1967, but by 1991 had increased to 98 (Kappesser 1993; Barnes 1967 in Kappesser 1993). In the past 25 years, a combination of road construction, timber harvest, and mining have driven this system to disequilibrium. The elevation of the channel bottom has raised more than two feet since 1967 (Kappesser 1993). The observed differences in the relative abundance of pools and riffles between managed and unmanaged watersheds suggested that sediments scoured from roaded and harvested headwater channels were aggrading in lower reaches (Cross and Everest 1995). Existing conditions are the result of cumulative impacts of more than 100 years.

Evaluation of watershed conditions in the Spokane River drainage has indicated that about 61 % of the Forest Service managed watersheds do not meet Forest Plan standards, and that this is a continuing negative trend (Kasun, USFS, in litt. 1992a). Streams in the most degraded condition have habitat loss, stream morphology changes, cobble embeddedness, and temperature increases. Westslope cutthroat trout distribution and abundance in the lower St. Joe and St. Maries Rivers have declined greatly due to management activities. Within the St. Maries River watershed, poor water quality from grazing has increased water temperatures, sediment affecting spawning gravels, and nutrient levels, which were identified as a limiting factor to all life stages of WCT (Owen, USFS, pers. comm. 1998; USFS, in litt. 1998j).

Vulnerability of aquatic habitats to sedimentation was illustrated during a recurrent rain-on-snow event in the St. Joe River watershed in February 1996. Large quantities of sediments, hundreds of thousands of cubic yards, were released into streams from well over 290 sites involving road slumps, landslides, extensive stream bank erosion and debris torrents in areas generally below 4,000 feet in elevation (Patten, USFS, in litt. 1996, from bull trout admin. record). The majority of the sites releasing sediment resulted from past land management activities, primarily timber harvest and associated roads (Owen, USFS, in litt.1996, from bull trout admin. record). The resulting damages to fish habitat are expected to be long-lasting (Patten, USFS, in litt. 1996, from bull trout admin. record).

Watershed restoration work enabled Cougar Creek, the Autumn-Martin area in the headwaters of Steamboat Creek, and Picnic Creek, all Coeur d'Alene River watershed tributaries to withstand the February 1996 floods, although there was extensive loss of roads and sedimentation elsewhere in the watershed (Lider, USFS, pers. comm. 1997). In the St. Joe watershed, some recent watershed restoration work on timber sale sites, road obliterations, and check dams worked as designed in controlling sediment loading during this event (Hallisey, USFS, in litt. 1997, from bull trout admin. record).

Consistent with the Idaho Panhandle National Forests AES, watershed restoration work is proceeding in habitats in Gold Creek (Owen, USFS, pers. comm. 1997). In 1994 about 30 miles of roads were closed in Gold Creek watershed, tributary to the upper St. Joe River, and 6 miles of road are to be obliterated in 1997, as a timber sale condition. However, Gold Creek sub-drainage will remain heavily roaded. In nearby Simmons Creek, a watershed restoration project involving 50 miles of road obliteration and 15 miles of road closures leaving only the road prism was completed in 1997 (Owen, USFS, pers. comm. 1997).

Mining heavily negatively affected large portions of the Spokane River drainage. Impacts include discharge of massive quantities of waste materials, roading, stream diversion and alteration, watershed degradation from airborne emissions, and the release into the South Fork Coeur d'Alene River of 72 million tons of hazardous mine wastes laden with heavy metals such as lead, zinc and cadmium (Coeur d'Alene Tribe of Idaho et al. 1991).

During the early 1930s, the South Fork Coeur d'Alene River and about 20 miles of the lower Coeur d'Alene River were considered devoid of aquatic life due to heavy mining waste discharge (Ellis 1940). Some aquatic species have returned to the river. About 85 % of the bottom of 31,000 acre Lake Coeur d'Alene is contaminated with metals and the population and diversity of macroinvertebrates are greatly reduced (Woods, USGS, pers. comm. 1993, from bull trout admin. record). For more than a century, placer mining has altered aquatic habitats occupied by WCT. Heller and Sherlock Creeks, upper St. Joe River tributaries were heavily placer mined early in this century. There was an unauthorized suction dredge operation in the Heller Creek in 1995 (Owen, USFS, pers. comm. 1997).

About 45 miles of the lower Coeur d'Alene, St. Joe, and St. Maries Rivers have been channelized and diked for a combination of agriculture, protection, and navigation. This action may have reduced habitat structure, and forage base productivity and diversity relative to natural conditions. During 1997, the Economic Development Administration, without prior section 7 consultation, funded and began the removal of large cottonwoods from about 5.9 miles of levees along the St. Joe River. This is anticipated to elevate water temperatures and further limit the seasonal use of this area by migratory WCT.

B. Overutilization for commercial, recreational, scientific, or educational purposes

Recreational fishing throughout the Spokane River drainage has caused the abundance and size of WCT to decline and is still believed to be a threat (Hunt and Bjornn 1995; Owen, USFS, pers. comm. 1998; Maclay 1940; Thurow and Bjornn 1978; Dunnigan and Bennett 1995; McIntyre and Rieman 1995; Davis et al. 1997). Within the catch and keep portion of the St. Joe River, the absence of larger fish (> 330 mm) may indicate that once WCT attain lengths near the minimum harvest size limit, anglers reduce them to possession (Horner et al. 1987). Until more restrictive angling regulations were implemented starting in 1970, WCT were reduced to remnant levels throughout the drainage and in some areas remain low (Bowler 1974 in Hunt and Bjornn 1995; Hunt and Bjornn 1995; Dunnigan and Bennett 1995). In the upper St. Joe River and portions of the Coeur d'Alene River, densities of WCT increased with more restrictive fishing regulations (Hunt and Bjornn 1995; Thurow and Bjornn 1978). However, these increased densities of WCT have greatly increased fishing pressure particularly in the catch-and-release section. When catch levels of 25,000 to 50,000 fish (St. Joe River), and 12,000 to 18,000 fish (Coeur d'Alene River) are experienced, high numbers of handling related mortality is likely. This is considered an ongoing threat which is expected to continue as the popularity of these rivers and fly fishing increases.

C. Disease or predation

Whirling disease has been documented in brook trout from Big Creek, a tributary to the South Fork Coeur d'Alene River and in white fish from the North Fork Coeur d'Alene River (University of Idaho, in litt. 1998). Juvenile WCT from the St. Joe River tested positive for whirling disease (University of Idaho, in litt. 1998).

Predation of WCT is known to occur by numerous native (bull trout and northern pikeminnow) and introduced species (lake trout, Gerrard rainbow trout, chinook salmon, and several centrarchids and ictalurids) and is an important source of mortality to WCT. Predation can act as a destabilizing force when habitat loss and overexploitation is experienced, and may make recovery extremely difficult or impossible (Rieman and Apperson 1989).

The water source (Spring Creek) for the Clark Fork Hatchery is inhabited by brook trout that have Infectious Pancreatic Necrosis (IPN). The broodstock fish (including rainbow trout and WCT) from the Clark Fork Hatchery that are used for stocking lakes, rivers, and streams in this drainage (and all of Idaho Panhandle region) are known to be infected with IPN (Horner, IDFG, pers. comm. 1999). This is a contagious virus that effects young fish, generally 80-90 mm in length and may cause large losses (Van Duijn 1967; Horner, IDFG, pers. comm. 1999). The extent of this threat in this drainage is unknown. However, because Spring Creek is also used as a water source for the town of Clark Fork, Idaho, treating the brook trout and the stream to rid it of IPN is unlikely, and fish from the Clark Fork Hatchery with IPN will continue to be propagated in this drainage (Horner, IDFG, pers. comm. 1999).

D. The inadequacy of existing regulatory mechanisms

The Forest Service INFISH strategy has amended the Idaho Panhandle National Forests plan to allow no new net-loss of native trout habitat (USFS 1995). Overall INFISH has worked to maintain degraded aquatic habitat and needs to be upgraded to restore degraded habitats (Roper, USFS, pers. comm. 1999). On the Idaho Panhandle Forest, about 97 % of all actions are in compliance with INFISH .

In the Coeur d'Alene River watershed, INFISH has been used to oversize replacement culverts to both assure fish passage and reduce the probability of additional sediment loading or debris torrents resulting from repeat culvert failures. There have been no objective tests of INFISH's effectiveness involving unentered drainages (Horner and Corsi, IDFG, pers. comm. 1997).

There have been exceptions to INFISH standards. Under local and Congressional political pressure, exceptions to INFISH were granted in the Coeur d'Alene River watershed to repair Forest Service roads following the February 1996 floods (Cross, USFS, in litt. 1996, from bull trout admin. record; Owen and Lider, USFS, pers. comm. 1997; Corsi, IDFG, pers. comm. 1997).

The AES adopted by the Idaho Panhandle National Forests is viewed as affirmative direction to conduct watershed restoration and maintain native fish communities (USFS, in litt. 1994b). The AES is directed primarily to bull trout spawning and juvenile rearing areas, with a considerable amount of WCT not addressed. The application of the AES takes a "passive" approach in watersheds that are designated as "Focal" watersheds, in that the Forest Service tends to avoid management action in these areas that would degrade habitat (USFS, in litt. 1994b; Roper, USFS, pers. comm. 1999). In other watersheds, the application of the AES is meant to take an "active" approach at restoring degraded habitat. However, restoration is not occurring as fast as it should because of funding constraints (Roper, USFS, pers. comm. 1999).

Forest practices on state and private lands are subject to minimum standards set forth in the Idaho Forest Practices Act (FPA). These standards are administered and enforced by the IDL and compliance in general is high (DuPont IDL, pers. comm. 1999; Corsi, IDFG, pers. comm. 1999). There are approximately 114,191 acres of endowment land in this drainage that are administered by IDL. When determined to be inadequate to protect beneficial uses, standards in the FPA are amended (DuPont, in litt. 1998). A recent addition to the FPA is the Cumulative Watershed Effects process developed to ensure that cumulative impacts from two or more logging operations will not impair water quality (DuPont, in litt. 1998).

Standards set forth in the FPA for state and private lands are generally less than those on federal lands and in some cases are inadequate (Corsi, IDFG, pers. comm. 1998; Roper, USFS, pers. comm. 1999). While the FPA affords adequate standards to keep sediment out of the streams, in some cases is inadequate in protecting the Stream Protection Zones by having minimal standards for long-term large woody debris and shade retention (Corsi, IDFG, pers. comm. 1998). The FPA was also found to be inadequate when looking at road densities and the hydrologic impacts of clear cutting within rain on snow zones. While the standards set forth in the FPA are considered a step in the right direction, there are still holes that need to be addressed for protecting beneficial uses of streams administered by IDL (Corsi, IDFG, pers. comm. 1998).

On July 10, 1998, the Columbia River population of bull trout were listed as threatened under the Endangered Species Act. Section 7 (a) (2) of the ESA requires that any actions with Federal involvement that may affect bull trout go through the consultation process with the U.S. Fish and Wildlife Service. Where bull trout and WCT have overlapping ranges, consultation to minimize or eliminate adverse affects of the action on bull trout could be expected to minimize effects to WCT as well. Bull trout within the Coeur d'Alene River watershed are considered to be functionally extinct, with only occasional individuals documented within the drainage. Because of this, most Federal actions within the Coeur d'Alene River watershed have underdone informal consultation, as opposed to formal consultation. Through the informal consultation process, the Service can only provide conservation recommendations, implementation of which are voluntary on the part of the Federal agency involved. By contrast, formal consultation often yields reasonable alternatives to reduce or eliminate adverse effects on the species.

Within the St. Joe River watershed, formal consultation affords added protection to WCT where bull trout spawning and rearing occurs. However, in tributaries where bull trout have not been documented in many years because of habitat alterations and anthropogenic influences, actions that would otherwise likely adversely affect bull trout are still occurring. Using data generated by ICBEMP for the Spokane River drainage, 166 HUCs compose this drainage of which bull trout are known or predicted present in 50 HUCs, and known or predicted absent in 116 HUCs. The ICBEMP data indicates that WCT are known or predicted present in all 166 of these watersheds. Therefore, in 116 HUCs, WCT may not receive adequate protection from ongoing and future actions as a secondary benefit of protecting bull trout.

The Comprehensive Environmental, Response, Compensation and Liability Act (1980), or superfund, has not been applied to restore large portions of the negatively affected Coeur d'Alene River or Lake Coeur d'Alene. Thus, heavy metals remain a threat in this system. In 1998, EPA declared the entire lower Coeur d'Alene River as part of the facility to be restored.

Seventy seven stream segments totaling 555.41 miles identified as occupied by WCT (roughly 36 % of total stream miles) are now designated among the water-quality-limited streams under section 303 (d) of the Clean Water Act (IDEQ, in litt. 1998). Sediment, temperature, habitat alteration, and metals are identified as some of the various pollutants responsible for designation on the list. Forest management and roads are the primary impact to these tributaries and associated watersheds. None of these stream segments has been remedied to date. Although there has been a limited amount of genetic analysis of WCT in this drainage, 4 stream segments (Alder Creek, Lake Creek, Copper Creek and the upper Little North Fork Coeur d'Alene River) that are on the 303 (d) list, have pure WCT documented within them (Kanda and Leary, in litt. 1998; Leary, in litt. 1995; Spruell et al., in litt. 1999).

Annually, IDFG collects trend information through transect monitoring and are currently attempting to identify critical habitat using radio telemetry (Horner, in litt. 1998). The stocking of catchable rainbow trout has been reduced and IDFG has developed a plan to construct four catch-out ponds in the Coeur d'Alene River drainage to be stocked with catchable rainbow trout (Horner, IDFG, pers. comm. 1999). While this would enable IDFG to eliminate the stocking program and manage for wild trout in the Coeur d'Alene River, funding constraints keeps this plan from being realized. Additional plans to enhance WCT in this drainage are not realized because of budget constraints (Horner, IDFG, pers. comm. 1999).

E. Other natural or manmade factors affecting the species' continued existence

Stocking records dating back to 1925 from the Idaho Department of Fish and Game indicates that numerous species of nonnative salmonids and various other exotic fishes have been stocked within the Spokane River drainage (IDFG, in litt. 1998c). In this time frame, there have been thousands of separate stockings of various amounts ranging from a few fish to several hundred thousand. With the introduction of exotic fish species, competition, predation, and hybridization has increased (Rieman and Apperson 1989). Additional stocking of nonnative fishes occurred prior to 1925 by IDFG, sportsman groups, and private individuals (Hutchinson, IDFG, pers. comm. 1999).

Rieman and Apperson (1989) summarized that while competition between WCT and nonnative fish is minimized in streams by habitat segregation, the loss of suitable WCT habitat has allowed for nonnative fishes to expand into altered habitats. Brook trout tend to replace WCT where they have declined, whereas rainbow trout (once established and naturally reproducing) can displace WCT where the two overlap. The coexistence of rainbow trout and WCT likely results in hybridization. These threats have been observed in the Spokane River drainage with rainbow trout and brook trout observed in many of the tributary streams surveyed. In addition, the stocking of catchable rainbow trout does not tend to displace WCT, but creates increased fishing pressure, which, along with the wide distribution and abundance of wild nonnative species, may aggravate the exploitation of WCT in the same waters (Rieman and Apperson 1989).

The presence of naturally occurring nonnative "wild" rainbow trout has been documented in the North Fork Coeur d'Alene River as far upstream as Tepee Creek and in the St. Joe River as far upstream as Ruby Creek. Naturally occurring rainbow have also been documented in the Little North Fork Coeur d'Alene River (Davis et al. 1997 in draft). These naturally occurring rainbows are within areas determined to be strongholds for WCT. Hybridization of WCT with rainbow trout has been documented within the drainage and is expected to continue with the increased distribution of rainbow trout.

Eutrophication of the 31,500 acre Lake Coeur d'Alene may be adversely impacting the remaining adfluvial WCT in the Spokane River drainage. Deoxygenation of the hypolimnion down to 30 % of saturation has been reported (Woods, USGS, pers. comm. 1993). The primary cause of the oxygen depletion is nutrient loading, particularly phosphorus released from forest management, agriculture, and sewage discharge. In addition, the benthic invertebrate component is absent, or greatly reduced, from large portions of the bottom of Lake Coeur d'Alene because of toxic concentrations of lead, cadmium, zinc, and copper in pore water and surficial lake bed sediments, adversely impacting the forage base for WCT.

Recent modeling indicates that in 10 to 20 years, eutrophication could become a self-sustaining process with large-scale release of nutrients and contaminants from lake sediments into the water column. The lake could then become uninhabitable by fish because of dissolved oxygen levels approaching zero on a regular basis (Woods, USGS, pers. comm. 1993). Non-point and point-source programs are now being considered to minimize nutrients loading and prevent this possibility.

Kootenai River Drainage, Idaho

A. The present or threatened destruction, modification, or curtailment of the species' habitat or range

Forest management practices, including timber harvest and road construction, both past and current, are major contributors to degraded watershed conditions and aquatic habitats on public lands in Idaho (Cross and Kasun, USFS, pers. comm. 1993).

Most (72 %) of the National Forest watershed area in Kootenai River drainage does not meet forest plan standards (Kasun, in litt. 1992a; USFS, in litt. 1994a), indicating a loss of physical habitat, and degraded water quality. Baseline data on watershed conditions throughout this drainage are not available to precisely quantify the rates of change. However, in recent years the proportion of watersheds in the Idaho Panhandle National Forests, including the Kootenai River drainage, not meeting forest plan standards has increased (Kasun, USFS, pers. comm. 1993).

Many of the tributary stream watersheds are considered "highly degraded" or "watersheds at risk" (USFS, in litt. 1998b). In the last 100 years, the drainage has seen a significant and different set of influencing factors with the rapid development of the area by man. These influences are in the form of large scale vegetative pattern changes and from physical stresses on the inherent stabilizing structures and functions of the watershed (USFS, in litt. 1998b).

Within the Kootenai River drainage, the U.S. Forest Service and Bureau of Land Management have identified 100 and eight, respectively, ongoing or proposed actions for which bull trout consultation is occurring. This does not include proposed or ongoing actions in HUCs (20) where bull trout are thought to be absent and consultation on actions does not occur or proposed actions that are being completed through the streamlining process (USFS, in litt. 1998b; Audet, USFWS, pers. comm. 1999). In the Grass Creek watershed, the Ripati grazing allotment has been identified as a threat "likely to adversely affect" bull trout because cattle have contributed to channel instability and riparian damage that delay recovery. Westslope cutthroat trout have been identified as present in Grass Creek and are expected to be adversely affected as well (USFS, in litt. 1998b; IDFG, in litt. 1998a).

The proposed Bluegrass Bound project, also in the Grass Creek watershed, contains 2,500+ acres of various silvicultural treatments that includes 10 units of regeneration type harvest that exceed 40 acres (range from 44 to 322 acres) in size and 1.1 miles of new road construction (USFS, in litt. 1998k). Within the Bluegrass Bound Environmental Assessment, it is indicated that the channel in the mid- and upper reaches of Grass Creek are out of dynamic equilibrium from past grazing, logging, and road activities, and display the greatest sensitivity to flood damage (USFS, in litt. 1998k). There is concern that these large regeneration cuts will potentially increase peak flows, which could result from rain-on-snow or rapid spring melt, and adversely impact the stream channel and fish habitat (IDFG, in litt. 1998d). The Bluegrass Bound project also proposes to incorporate 97 miles of road decommissioning, including installation of earthen barriers, removal of culverts, and restoration of streambeds to original grade, and 5 miles of road obliteration that involves the complete elimination of the road prism. These features are expected to improve conditions in the long-term.

The development of road systems in the Kootenai River drainage have contributed to extensive sediment input and poor channel conditions throughout the drainage. Road densities have been used to correlate the probability of a stream to support bull trout populations (Lee et al. 1997b in USFS, in litt. 1998e). Meaning, the higher the road densities, the lower the probability of finding strong bull trout populations. Baseline environmental conditions for road densities were considered good if densities were less than 0.7 m/m2, moderate if densities were between 0.7 m/m2 and 1.7 m/m2, and poor if densities were greater than 1.7 m/m2 (Lee et al. 1997b in USFS, in litt. 1998e). While these determinations were made for bull trout, they too can be used for assessing threats to WCT. It was determined that within the 16 HUCs the USFS and the Service are conducting bull trout consultation, road densities are considered poor all in 16 (USFS, in litt. 1998b). The range of road densities in these HUCs is 2.0-6.0 m/m2. Until road densities are reduced significantly in this drainage, threats to WCT are considerable.

On December 10, 1998, the Federal Energy Regulatory Commission accepted the preliminary permit application for the Boundary Creek Water Power Project, FERC No. 11634 (FERC, in litt. 1998). The proposed "run of the river" project will be located on Boundary Creek and consist of a new diversion structure approximately 8 feet in height and 75 feet in length at elevation 3,080 MSL. Water will be diverted through a 60-inch-diameter steel penstock for approximately 26,900 feet (or 5.1 miles) into a powerhouse located at 1,780 MSL (Application for Preliminary Permit, Continental Lands, Inc., in litt. 1998). Westslope cutthroat trout are documented present in Boundary Creek and numerous tributaries to Boundary Creek. The U.S. Fish Wildlife Service, as well as the U.S. Forest Service and IDFG, have expressed concerns that the construction and operation of the project has the potential to create migration barriers, and destroy or degrade habitats of WCT, bull trout (listed threatened), interior redband trout, south arm (Kootenay Lake) kokanee, and burbot (USFWS, in litt. 1999; USFS, in litt. 1999e; IDFG, in litt. 1999).

The mainstem Kootenai River habitat has had dramatic changes beginning in the late 1800s. Attempts at diking began as early as 1892 in order to claim land for agricultural purposes (Northcote 1973 in Paragamian 1995). Today, approximately 30 miles of the Kootenai River have been diked. In 1966, construction of Libby Dam in Montana was initiated and impoundment of Lake Koocanusa and regulation of downstream flows began in 1972. From 1972 to the fall of 1975, while the turbine installation was being completed, water discharge was through the sluiceways or spillways (Partridge 1983) . The main purpose of Libby Dam is flood control; hydropower and recreation are secondary benefits. The annual flow regime of the Kootenai River has changed dramatically due to the operation of Libby Dam, and water temperatures have increased (Partridge 1983; Paragamian 1995). The river is now subject to highly variable peaking flows for power generation, resulting in daily fluctuations in water depth of one to several feet.

Following closure of Duncan Dam, Canada, in 1968 and Libby Dam in 1975, nutrients became limiting in Kootenay Lake. Based on limnological studies of Kootenay Lake, BC, Canada, Daley et al. (1981) concluded that Libby Reservoir is functioning as a nutrient sink that may adversely affect the forage base(s) for fish, thus reducing the carrying capacity for fish in the lower Kootenai River and Kootenay Lake.

B. Overutilization for commercial, recreational, scientific, or educational purposes

The harvest of WCT is allowed year around in the Kootenai River and most tributaries have a Memorial Day weekend opener (last weekend in May) and November 30, season closure (IDFG, in litt. 1998b). A 6-fish bag limit is allowed in most streams with the exception of a section of the Moyie River (2-fish bag limit). In many river drainages in northern Idaho, tributary streams and migratory corridors are closed to fishing until July 1, to prevent WCT harvest during spawning and post-spawning, and in early September to protect WCT that concentrate downstream during low-flow conditions. This protection is not afforded to WCT in this drainage and since WCT are vulnerable to angling, even relatively low fishing effort can produce high levels of exploitation (Rieman and Apperson 1989).

C.  Disease or predation

Predation of WCT is known to occur by numerous native and introduced species, is an important source of mortality to WCT, and can act as a destabilizing force when habitat loss and overexploitation is experienced (Rieman and Apperson 1989).

The water source (Spring Creek) for the Clark Fork Hatchery is inhabited by brook trout that have Infectious Pancreatic Necrosis (IPN). The broodstock fish (including rainbow trout and WCT) from the Clark Fork Hatchery that are used for stocking lakes, rivers, and streams in this drainage (and all of the Idaho Panhandle region) are known to be infected with IPN (Horner, IDFG, pers. comm. 1999). This is a contagious virus that affects young fish, generally 80-90 mm in length, and may cause large losses (Van Duijn 1967; Horner, IDFG, pers. comm. 1999). The extent of this threat in this drainage is unknown. However, because Spring Creek is also used as a water source for the town of Clark Fork, Idaho, treating the brook trout and the stream to rid it of IPN is unlikely, and fish from the Clark Fork Hatchery with IPN will continue to be propagated in parts of this drainage (Horner, IDFG, pers. comm. 1999). Available information does not identify any other disease threats in this drainage.

D. The inadequacy of existing regulatory mechanisms

The Forest Service INFISH strategy has amended the Idaho Panhandle National Forests plan to allow no new net-loss of native trout habitat (USFS 1995). Overall, INFISH has worked to maintain degraded aquatic habitat and needs to be upgraded to restore degraded habitats (Roper, USFS, pers. comm. 1999). On the Idaho Panhandle National Forests, about 97 % of all actions are in compliance with INFISH.

The Aquatic Ecosystem Strategy (AES) adopted by the Idaho Panhandle National Forests is viewed as an affirmative direction to conduct watershed restoration and maintain native fish communities (USFS, in litt. 1994b). The AES is directed primarily to bull trout spawning and juvenile rearing areas, with a considerable amount of WCT not addressed. The application of the AES takes a "passive" approach in watersheds that are designated as "Focal" watersheds, in that the Forest Service tends to avoid management action in these areas that would degrade habitat (USFS, in litt. 1994b; Roper, USFS, pers. comm. 1999). In other watersheds, application of the AES is meant to take an "active" approach at restoring degraded habitat. However, restoration is not occurring as fast as it should because of funding constraints (Roper, USFS, pers. comm. 1999).

Forest practices on state and private lands are subject to minimum standards set forth in the Idaho Forest Practices Act (FPA). These standards are administered and enforced by the Idaho Department of Lands (IDL) and compliance in general is high (DuPont, IDL, pers. comm. 1999; Corsi, IDFG, pers. comm. 1998). There are approximately 24,076 acres of endowment land in this drainage administered by IDL. When determined to be inadequate to protect beneficial uses, standards in the FPA are amended (DuPont, in litt. 1998). A recent addition to the FPA is the Cumulative Watershed Effects process developed to ensure that cumulative impacts from two or more logging operations will not impair water quality (DuPont, in litt. 1998).

Standards set forth in the FPA for state and private lands are generally less than those on federal lands and in some cases are inadequate (Corsi, IDFG, pers. comm. 1998; Roper, USFS, pers. comm. 1999). While the FPA affords adequate standards to keep sediment out of the streams, in some cases it is inadequate in protecting the Stream Protection Zones by having minimal standards for long-term large woody debris and shade retention (Corsi, IDFG, pers. comm. 1998). The FPA was also found to be inadequate when considering road densities and the hydrologic impacts of clear cutting within rain-on-snow zones. While the standards set forth in the FPA are considered a step in the right direction, there are still holes that need to be addressed for protecting (Cleanwater Water Act) beneficial uses of streams administered by IDL (Corsi, IDFG, pers. comm. 1998).

On July 10, 1998, the Columbia River population of bull trout were listed as threatened under the Endangered Species Act. Section 7 (a) (2) of the ESA requires that any actions with Federal involvement that may affect bull trout go through the consultation process with the U.S. Fish and Wildlife Service. Where bull trout and WCT have overlapping ranges, consultation to minimize or eliminate adverse affects of the action on bull trout could be expected to minimize effects to WCT as well. However, within the Kootenai River drainage there are many tributary streams where bull trout are thought to be absent or individuals are most likely absent in most years and consultation on actions has not occurred. Using data generated by ICBEMP for the Kootenai River drainage, 43 HUCs compose this drainage, of which bull trout are known or predicted present in 17 HUCs, known or predicted absent in 22 HUCs, and unclassified in three HUCs. The ICBEMP data indicate that WCT are known or predicted present in 41 of these watersheds and unclassified in two HUCs. Therefore, in 22 HUCs, WCT may not receive adequate protection from ongoing and future actions as a secondary benefit of protecting bull trout.

Heavy metals released from past mining activities have been documented in the lower Kootenai River. Of those identified, copper appears to be the greatest concern biologically. Copper was found to have accumulated in oocytes of Kootenai River white sturgeon, water, and sediments from the lower Kootenai River (Apperson and Anders 1991, p. 22 and 52). Although sturgeon appeared to hatch normally, potential impacts to other aquatic biota have not been evaluated. Metals, including copper, accumulated in food chain items in the Clark Fork River have resulted in reduced growth, deformity and death in juvenile cutthroat trout (Woodward 1993). Water-quality monitoring conducted on the Kootenai River and several tributary streams by the Kootenai Tribe of Idaho showed that mercury, lead, and selenium violated EPA aquatic criteria at several sites and that arsenic, copper, and lead were found in the river sediment (USFS, in litt. 1998b).

Six streams in the Kootenai River drainage, Idaho, that have segments totaling 62.04 miles are now designated among the water-quality limited streams under section 303 (d) of the Clean Water Act, of which none has been restored (IDEQ, in litt. 1998). Sediment is identified as the primary pollutant responsible for designation on the list. Westslope cutthroat trout have been documented within all of the tributaries of these stream segments. Forest management and roads are the primary impact to these tributaries and associated watersheds.

E. Other natural or manmade factors affecting the species' continued existence

Stocking records dating back to 1925 from the IDFG indicate that numerous species of nonnative salmonids and various other exotic fishes have been stocked within the Kootenai River drainage (IDFG, in litt. 1998c). In this time frame, there have been thousands of separate stockings of various amounts ranging from a few fish to several hundred thousand. With the introduction of exotic fish species, competition, predation, and hybridization has increased (Rieman and Apperson 1989). Additional stocking of nonnative fishes occurred prior to 1925 by IDFG, sportsman groups, and private individuals (Hutchinson, IDFG, pers. comm. 1999).

Hybridization with coastal rainbow trout and interior redband trout continues to threaten WCT in the Kootenai River drainage of Idaho. Stocking of coastal rainbow trout and Yellowstone cutthroat trout in a majority of the streams and lakes in the Kootenai River drainage was common in the past and rainbow trout stockings still occurs to a lesser extent today (IDFG, in litt. 1998c). Where pure populations of WCT occupy headwater streams and hybrids or stocked nonnative fish occupy the lower portion of the same stream, if no migration barrier exists to prevent the movement upstream, the threat of hybridization to pure WCT stream populations is great (Perkinson, USFS, pers. comm. 1998). Compounding this threat is the stocking of high-mountain lakes. Even where upstream migration barriers exist to prevent hybridization, if high-mountain lakes are stocked with nonnative trout species, downstream migration from the lake is possible and hybridization may then be incurred throughout the stream.

Rieman and Apperson (1989) summarized that while competition between WCT and nonnative fish is minimized in streams by habitat segregation, the loss of suitable WCT habitat has allowed for nonnative fishes to expand into altered habitats. Brook trout tend to replace WCT where WCT have declined, whereas rainbow trout (once established and naturally reproducing) can displace WCT where the two overlap. The coexistence of rainbow trout and WCT likely results in extensive hybridization. These threats occur in the Kootenai River drainage, where rainbow trout and brook trout have been observed in many of the tributary streams surveyed. In addition, the stocking of catchable rainbow trout does not tend to displace WCT, but creates increased fishing pressure. This, along with the wide distribution and abundance of wild nonnative species, may aggravate the exploitation of WCT in the same waters.

Upper Columbia River Drainage, Washington

Methow River Watershed

A. The present or threatened destruction, modification, or curtailment of the species' habitat or range

In portions of the mainstem Methow River, habitat has been and continues to be adversely modified. Channelization or stream alteration has occurred along 35 miles, 22 % of the Methow River (Mullan et al. 1992). Sediment delivery is estimated to be about 10 % greater than natural background loading (Mullan et al. 1992). About 60 % of the private bottomlands in the Methow Valley are grazed and have erosion problems. The greatest rates of stream bank sloughing and cutting occur in these grazed areas (PNBRC 1977, in Mullan et al. 1992). Agricultural dewatering in the mainstem Methow River between RM 27 and RM 67 decreases natural average flows between 28 % in August and 79 % in October (Mullan et al. 1992). During 1987, Mullan observed salmonids isolated in pools in a 10-mile reach in the upper Methow River between September 1 and mid-September (Mullan et al. 1992). By November the pools had dried and the fish had died. Sediment loading from a huge fire in the Chewuck River drainage in 1929 is believed to have filled pools (fish habitat) in the lower Methow River (Molesworth, USFS, pers. comm. 1997). However, the extent of pools has increased in the lower Methow River in recent decades (McIntosh and Sedell 1994).

Past fires in the headwaters involving riparian habitat have exposed the stream to insolation and increased water temperatures (WDFW, in litt. 1995). Cattle grazing within wilderness remains a problem because of riparian vegetation reduction and stream bank degradation (Molesworth, USFS, pers. comm. 1997; WDFW, in litt. 1995).

The West Fork Methow River is naturally subject to flash floods and debris torrents. It is also subject to hot, relatively destructive fires. It receives some protection through designation as a Scenic Recreational Area and by inclusion as late successional reserve under the Northwest Forest Plan (Molesworth, USFS, pers. comm. 1997). Since 31 % of the fires in the Okanogan National Forest are man-caused, this land use management increases the area's vulnerability to fire, runoff rates and sedimentation (Mullan et al. 1992). The R. D. Merrill, Arrow Leaf Resort and destination community is planning to develop the mouth of West Fork Methow River, resulting in increased levels of human use of all types (Molesworth, USFS, pers. comm. 1997).

Presently, the reach of Lost River occupied by WCT is considered secure from man caused habitat alternation within the Pasayten Wilderness. The lower mile of the Lost River has been altered but connectivity with the Methow River remains (Molesworth, USFS, pers. comm. 1997). This lower reach has been partially channelized, and urbanization is occurring, but there are no significant water withdrawals.

The old-growth timber in the Early Winters drainage is vulnerable to high-intensity fire, with subsequent sediment loading and/or debris torrents (Molesworth, USFS, pers. comm. 1997). The upper drainage of Early Winter Creek is protected as a Scenic Recreational Corridor and as late successional reserve under the Northwest Forest Plan (Molesworth, USFS, pers. comm. 1997). However, the lower 0.5 to one mile of Early Winters Creek has been channelized and large woody debris removed. It has been targeted for development as a planned community of 600 homes, stores and a golf course in the flood plain spanning both banks near the mouth.

Goat Creek experienced extremely heavy timber harvest including logging in riparian zones, heavy roading, and log skidding in the stream during the 8 million board-feet (MBF) Panther sale that was to be completed in 1997. This sale involved clear-cuts in old growth and would not be allowed under current guidelines (Molesworth, USFS, pers. comm. 1997). The Forest Service recently awarded contract on a 3 MBF fire salvage sale in this drainage. A portion of this drainage, including a newly logged area thought to be fire resistant, recently burned (Molesworth, USFS, pers. comm. 1997) . Most of the stream banks in the Goat Creek drainage have been logged, exposing the waters to insolation and increasing temperature, but a small patch of intact riparian habitat remains above river mile 10 where logging did not occur on the stream banks (Molesworth, USFS, pers. comm. 1997; WDFW 1997; WDFW, in litt. 1995).

Fish passage is seasonally blocked where Goat Creek enters and submerges into an alluvial fan at its mouth from late July to October (Molesworth, USFS, pers. comm. 1997; WDFW 1997). Extreme timber harvest and roading may contribute increased bedload, alluvial fan formation, and reduced summer/fall flows.

Westslope cutthroat trout of the Methow River watershed are isolated in fragmented habitats created by natural barrier and/or habitat modifications (Molesworth, USFS, pers. comm. 1999). This presents an elevated risk to their survival in these tributaries in the instance of catastrophic events.

B. Overutilization for commercial, recreational, scientific, or educational purposes

Overutilization of resident WCT is not considered a notable threat in this drainage. Most WCT throughout the historic and introduced range occupy habitat that is not easily accessible to anglers and in general, the WCT are very small and not selected for by anglers (WDFW, in litt. 1998b). Near campsites and other recreation sites in downstream reaches, WCT may reach larger sizes, and harvest may increase. This as well is not considered to be a serious threat to WCT because recruitment from surrounding areas may be sufficient to resist over-exploitation. However, WCT are known to be susceptible to harvest and even low harvest levels can attenuate densities when habitat loss and competition are encountered (Rieman and Apperson 1989).

The fluvial WCT form occurs in very low numbers in the mainstem Methow River and is believed to have been decimated in the past from multi-species fisheries (WDFW, in litt. 1998a; Molesworth, USFS, pers. comm. 1999). In recent years, according to angler reports, the fluvial WCT have shown a positive response to selective gear rules, and regulations that closed waters to fishing for bull trout and steelhead (Williams, WDFW, pers. comm. 1999). Nonetheless, densities are still very low. However, 2 WCT over 12 inches can be harvested in the Methow, Chewuck, Lost, and Twisp Rivers, and 2 fish over 8 inches from tributaries beginning June 1 (WDFW, in litt. 1998b). This may leave post-spawn WCT that are still in or migrating out of tributary spawning areas susceptible to harvest.

C. Disease or predation

Predation of WCT is known to occur by numerous native and introduced species, is an important source of mortality to WCT, and can act as a destabilizing force when habitat loss and overexploitation are experienced (Rieman and Apperson 1989). Available information does not identify any disease problems in this drainage.

D. The inadequacy of existing regulatory mechanisms

The Northwest Forest Plan applies in the mainstem and west side tributaries of the Methow River and in the mainstem and west side tributaries of the Chewuck River, and PACFISH or INFISH applies in the remainder of the Methow River watershed. Both are viewed as no-net-loss of aquatic habitat guidance rather than affirmative and funded habitat restoration (recovery) direction (Molesworth, USFS, pers. comm. 1997). However, there has been a small net reduction in roads in the areas covered by the Northwest Forest Plan (Molesworth, USFS, pers. comm. 1997). State water law may provide a basis to evade installation of a fish screen on Wolf Creek in which WCT currently occupy. Some diversions are exempt from state regulation because of "grandfathering" provisions.

On July 10, 1998, the Columbia River population of bull trout was listed as threatened under the Endangered Species Act. The ESA requires that any actions with Federal involvement that affect bull trout go through the consultation process with the U.S. Fish and Wildlife Service. Where bull trout and WCT have overlapping ranges and consultation to eliminate adverse effects of the action on bull trout is completed, beneficial effects are expected for WCT. Within the Methow River watershed, WCT were believed to historically occupy 30.7 miles of habitat for spawning and early rearing, of which they currently utilize 22.7 miles. Bull trout are believed to currently occupy portions of the same habitats or occur in the same HUC, therefore WCT may receive adequate protection from ongoing and future actions as a secondary benefit of protecting bull trout. In addition, on March 24, 1999, spring chinook salmon were listed as an endangered species in the Methow River by the National Marine Fisheries Service, and summer steelhead were previously listed by the National Marine Fisheries Service. Measures implemented for the protection of these species are expected to benefit WCT as they occur in the same HUCs (G. Knott, USFS, pers. comm. 1999).

The following are Clean Water Act Section 303(d) water quality limited streams where WCT occupy some portion of the drainage: Methow River, Chewuck River, Wolf Creek, Early Winters Creek (WDE, in litt. 1999). All are limited by low instream flows. The Methow River is also temperature-limited. The Service is aware of no ongoing program that is now specifically removing these listed limitations. Some limitations involving agricultural water diversions may be exempt from regulation through "grandfathering" provisions. No TMDLs have ever been completed in the Methow drainage.

E. Other natural or manmade factors affecting the species' continued existence

Since the early 1900s, stocking programs have introduced nonnative trout into the Methow River watershed (WDFW, in litt. 1998a). The introduction of rainbow and brook trout has greatly increased the risk of competition, predation, and hybridization.

Rieman and Apperson (1989) summarized that while competition between WCT and nonnative fish is minimized in streams by habitat segregation, the loss of suitable WCT habitat has allowed nonnative fishes to expand into altered habitats. Brook trout tend to replace WCT where WCT have declined, whereas rainbow trout (once established and naturally reproducing) can displace WCT where the two overlap. These threats occur in the Methow River watershed with brook and rainbow trout observed in many of the tributary streams surveyed. Brook trout have replaced WCT in Eightmile Creek and the stocking of rainbow trout in tributaries that WCT occupy has resulted in some degree of introgression in almost all tributaries in this drainage (WDFW, in litt. 1998a; Williams, WDFW, pers. comm. 1998; Proebstel et al. 1997; USFS, in litt. 1998l). In addition, the wide distribution and abundance of nonnative species increases fishing pressure, which may aggravate the exploitation of WCT in the same waters (Rieman and Apperson 1989).

Lake Chelan Watershed

A. The present or threatened destruction, modification, or curtailment of the species' habitat or range

The construction of Lake Chelan Dam in 1928 raised the water level of the lake by 24 feet and inundated potentially important spawning habitat of adfluvial WCT at the mouths of tributary streams (USFS, in litt. 1999f; Brown 1984). Additional effects from dam construction include changes in the composition of materials deposited in stream deltas; riparian vegetation; and quality and quantity of water at these sites (USFS, in litt. 1999b).

Within the North Shore Watershed Analyses area, many riparian areas are lacking large trees, snags, and large woody debris that moderate water temperatures, and provide stability and habitat within the stream. The limiting factors for the lack of large woody debris are many, with management history such as logging, natural geomorphologic variables, and natural disturbances such as fire, having an impact on wood input (USFS, in litt. 1998d). Flood plains, particularly in the dissected mountain slope zone are no longer functioning properly because down cutting of the channel has dewatered the riparian area resulting in decreased levels of nutrient and woody debris being delivered to the stream channel during annual flood events (USFS, in litt. 1998d). In general, the resource use along the north shore has been moderate to intense with many alterations to the environment as a result of irrigation diversions, logging, grazing, orchard, residential and urban development, along with the compounding effects of fire suppression leading to larger and more damaging fires. These changes have occurred in an incremental fashion, building upon previous changes and alterations (USFS, in litt. 1998d).

Stream surveys of eight north shore tributaries from 1990-1993 indicated that none of the streams conformed to expected pool frequencies or the Forest Plan Standard for pools. Fine-sediment deposition in pools and embeddedness > 35 % was identified as a problem in many (6 of 8) of these tributaries. The amount of large woody debris (4 of 8 tributaries) and water temperature (3 of 8 tributaries) was also determined to not meet Forest Plan Standards in numerous tributaries (USFS, in litt. 1998d).

Early in the century, increased grazing by sheep and cattle was not well regulated and created watershed concerns. By the 1930s grazing began to decline, but continues today. Following wildfires in 1968 and 1970, cattle grazing increased to take advantage of abundant forage created by the fires (USFS, in litt. 1998d). These wildfires were large and severe. Recovery was observed to be swift, with the regrowth of shrubs and grasses occurring within a few months in areas that received little or no management. However, in areas that received increased levels of grazing and salvage logging, combined with high spring flows, the results were devastating. Extensive rehabilitation 20 years after the disturbance was required and it is estimated that it will take 50-100 years to restore the natural function of the system. High-intensity fires continue to be a be a threat in this drainage because of current vegetation and fuel conditions, combined with weather patterns and land type (USFS, in litt. 1998d).

B. Overutilization for commercial, recreational, scientific, or educational purposes

In about 1903, the State of Washington began operating a WCT fish hatchery at Stehekin, into which, until 1923, were taking 0.5 to1.5 million eggs annually (Buckner, in litt. 1977; WDFW., in litt. 1998). Adult WCT were captured in 13 traps located in the sloughs on both sides of the Stehekin River (Buckner, in litt. 1977; Brown 1984) . In 1916, 1,697 female WCT were trapped and, in most years until 1923, between 500 to 1,300 females were taken for eggs. In 1927, only 9 female WCT were captured at the trap (Brown 1984). Very few of the eggs were returned to Lake Chelan or its tributaries but were planted elsewhere in the state. This level of egg take was not sustained for long and by 1927 the hatchery was closed because adult WCT were depleted and only 6,000 eggs were obtained (Buckner, in litt. 1977; Brown 1984).

Overutilization of resident WCT by anglers is not considered a threat in this drainage (WDFW, in litt. 1998a). Most WCT occupy habitat that is not easily accessible to anglers and, in general, the WCT are very small and not selected for by anglers. Near campsites and other recreation sites in downstream reaches, WCT may reach larger sizes, and harvest may increase. This as well is not considered to be a serious threat to WCT because recruitment from upper reaches is high. Overutilization of adfluvial WCT by anglers early in this century was significant, and while the current level of harvest is much less, it continues to contribute to the depressed status of WCT in this drainage, and even the slightest angling mortality could significantly affect escapement and recruitment of naturally produced fish (Brown 1984; USFS, in litt. 1998d). Westslope cutthroat trout are known to be susceptible to harvest, and even low harvest levels can attenuate densities when habitat loss and competition is encountered (Rieman and Apperson 1989).

In 1981 and 1982, creel census surveys estimated that anglers harvested 352 and 334 WCT, respectively. However, the effort in 1982 was almost double that in 1981. The WCT harvested in both years consisted primarily of females, with 43 of 54 that were identified to sex being females (Brown 1984).

C. Disease or predation

Predation on WCT is known to occur by numerous native (bull trout and northern pikeminnow) and introduced species (lake trout, rainbow trout, chinook salmon, and smallmouth bass). Predation is an important source of mortality in WCT, and can act as a destabilizing force when habitat loss and overexploitation occur (Rieman and Apperson 1989). Lake trout, first stocked in Lake Chelan in 1980, have established a naturally reproducing population and are known to be a significant predator to WCT (Mauser et al. 1988). Nonnative species continue to be stocked, with approximately 500,000 rainbow trout, 75,000 lake trout, and 200,000 chinook salmon propagated annually (Archibald, USFS, pers. comm. 1999).

Available information does not identify any disease problems confronting WCT in this drainage. However, in 1951, large numbers of sick and dying bull trout with a gray slime or fungus growth were observed along the shores near Stehekin. Few bull trout were observed after that time and were last documented in 1958 (USFS, in litt. 1999f).

D. The inadequacy of existing regulatory mechanisms

In 1994, the Northwest Forest plan amended the Wenatchee Land and Resource Management Plan, which had been signed in 1990 (USFS, in litt. 1998d). These plans are providing adequate protection to aquatic habitat and give preference to native species (Archibald, USFS, pers. comm. 1999). Habitat-restoration efforts have occurred in numerous tributaries but are limited in this drainage. The most profound restoration efforts have occurred in Mitchell Creek, where in 1970 a large fire in combination with high flows and excessive management had devastating affects on aquatic habitat and WCT were eliminated. The Forest Service has done considerable road work, riparian restoration, vegetation planting, upslope repair, and erosion-control efforts in this drainage to stabilize the system. Recent water-temperature data indicated that Mitchell Creek now is one of the only streams that does not exceed the 61 F maximum water-quality criterion. This, along with improved physical habitat from restoration efforts, now makes Mitchell Creek capable of supporting WCT (Archibald, USFS, pers. comm. 1999). Culvert repair has also occurred in several tributaries and no new road systems have been built in this drainage. Road obliteration is occurring annually, with approximately 20 miles of the Grade Creek road restored since 1990.

On July 10, 1998, the Columbia River population of bull trout was listed as threatened under the Endangered Species Act. Section 7 (a) (2) of the ESA requires that any actions that involve federal agencies and may affect bull trout go through the consultation process with the U.S. Fish and Wildlife Service. Where bull trout and WCT have overlapping ranges, consultation to minimize or eliminate the adverse effects of the action on bull trout could be expected to minimize such effects on WCT as well. However, within the Lake Chelan watershed, bull trout are thought to be extirpated and consultation on actions does not occur. Therefore, the benefit of bull trout consultation does not apply in this drainage.

Lake Chelan and five tributary streams in this drainage appear on the 303 (d) list of the Clean Water Act (WDE, in litt. 1996). Westslope cutthroat trout are known to occur in Lake Chelan and within four of the tributaries on the list. Parameters for listing these streams include elevated levels of arsenic, pH, and pesticides. To date, none has been addressed through TMDLs.

E.  Other natural or manmade factors affecting the species' continued existence

Since the early 1900s and continuing today, hatchery stocking programs have introduced nonnative trout and other exotic species (rainbow trout, kokanee, lake trout, chinook salmon, brook trout, and small mouth bass) into the Lake Chelan watershed (WDFW, in litt. 1998a, USFS, in litt. 1998d; Brown 1984). These introductions have greatly increased the risk of competition, predation, and hybridization. Lake trout, which are known to be a significant predator to WCT, were first stocked into the lake in 1980, have established a naturally reproducing population. Where WCT and rainbow trout occur together in this drainage, rainbow trout densities were reported to be 7.3 times greater than WCT (Brown 1984 in USFS, in litt. 1999b). Lake trout, rainbow trout, chinook salmon, and kokanee are the emphasis of the nonnative fishery in the lake (USFS, in litt. 1999b; 1998d). In addition to nonnative fish species, mysid shrimp were introduced into Lake Chelan as a food source for kokanee in 1967, and were established by 1975 (Brown 1984).

Up to 700,000 Yellowstone cutthroat trout eggs were received at the Chelan State Fish Hatchery between 1930 and 1941 (Varley 1979 in Proebstel et al. in draft). Most stockings of Yellowstone cutthroat trout occurred in high-mountain lakes, where successful establishment of reproducing populations was limited (Williams, WDFW, pers. comm. 1999). Another stocking program in Washington, starting around 1912, propagated WCT X rainbow trout hybrids from Dumphkey Lake (Behnke 1992; Brown 1984). These hybrids, a result of young steelhead stocked in 1904 and WCT from Lake Chelan in 1906, were used in an egg-taking operation and eventually stocked in many streams in Washington. However, stocking records do not exist for these operations and distribution of this fish is unknown (Crawford 1979 in Behnke 1992; Cranford 1912 in Behnke 1992).

Rieman and Apperson (1989) summarized that while competition between WCT and nonnative fish is minimized in streams by habitat segregation, the loss of suitable WCT habitat has allowed for nonnative fishes to expand into altered habitats. Brook trout tend to replace WCT where WCT have declined, whereas rainbow trout (once established and naturally reproducing) can displace WCT where the two overlap. Other nonnative fish species, such as chinook salmon, kokanee, and lake trout, can affect WCT through competition and predation. These threats occur in the Lake Chelan watershed, where rainbow trout have been observed in many of the tributary streams surveyed. The wide distribution and abundance of rainbow trout in this drainage has likely resulted in hybridization and genetic dilution where they coexist with WCT (Brown 1984;). In addition, the stocking of catchable trout does not tend to displace WCT but creates increased fishing pressure. This, along with the wide distribution and abundance of wild nonnative species, may aggravate the exploitation of WCT in the same waters (Rieman and Apperson 1989). Brown (1984) postulated that while WCT are highly desired by anglers, the WCT fishery is mostly incidental to kokanee and rainbow trout angling.

Clearwater River Drainage

A. The present or threatened destruction, modification, or curtailment of WCT habitat or range

Timber management and grazing are the primary land uses occurring in the Clearwater River drainage. Most of the WCT habitat in the drainage is under the management jurisdiction of the Clearwater National Forest and the Nez Perce National Forest. Land management on these National Forests may have adversely affected WCT habitat in the past. For example, Jones and Espinosa (1992) determined that 71 percent of the stream or watershed areas in the managed portion of the Clearwater National Forest did not meet Land Resource Management Plans (LRMP) standards. However, this figure is apparently outdated (Bosworth, USFS, in litt. 1998). Similarly, 67 percent of the non-wilderness portion of the Nez Perce National Forest did not meet LRMP standards, and streams in the most degraded category increased 12 percent over a five year period between 1987 and 1992 (Gloss and Gerhardt 1992). Davis and Horner (1995), however, did not find an association between timber harvest or stream habitat and cutthroat trout density in six stream in the Little North Fork Clearwater River watershed.

Much of the Selway River and Lochsa River watersheds are within the boundaries of the Selway-Bitteroot Wilderness Area, and aquatic habitat is largely unaltered by timber management. In addition, large, unaltered roadless tracts occur in the upper North Fork Clearwater River and Lochsa River watersheds, which have been proposed for wilderness inclusion since the late 1980s.

In addition to the mainstem Clearwater River, several tributaries to the South Fork Clearwater River have been affected by road construction, dredge mining, logging, grazing and stream channel alterations in the past (CBBTTAT 1998c). Tailing piles from dredge mining activities between 1920 and 1950 are a common occurrence in parts of the Newsome Creek, American River, and Crooked River flood plains (Gearhardt, pers. comm. 1997). Moynan and Paradis (1996) recognized the need for restoration in this drainage since the early 1980s, and demonstrated how BPA, Nez Perce National Forest, other agencies, and concerned user groups have been coordinating efforts since that time to restore aquatic habitat. They also recognized that many of the negative effects, primarily those associated with mining and up-slope management remain problematic. The loss of riparian function and vegetation is chronic in areas where past dredge mining activities have inundated the flood plains with dredge tailing piles, but past efforts to rehabilitate these sites have been obstructed by the preservation of the tailing piles as a culturally significant resource (Gearhardt, pers. comm. 1997). The effects from past land management in this drainage is expected to continue for many years to come.

In the lower Clearwater River watershed, the Clearwater Basin Bull Trout Technical Advisory Team (CBBTTAT 1998a) reported threats to bull trout (which may also be applicable to WCT) that included legacy effects of timber harvest, roads, agriculture and livestock grazing, ongoing mining, and urbanization. In the North Fork Clearwater River and South Fork Clearwater River watersheds, the CBBTTAT (1998b; 1998c) reported threats to bull trout resulting from ongoing timber harvest, roads, agriculture and livestock grazing, and mining, and, in the North Fork Clearwater River watershed, legacy effects of intense fire. In the Lochsa River watershed, the CBBTTAT (1998d) reported that Highway 12 has encroached on the main river, roads in the Squaw Creek area are a constant source of sediments and a culvert is an impassable barrier to WCT. Although some logging and road construction have been conducted in the Selway River watershed, much of the watershed is in a designed wilderness area. A culvert on Boyd Creek and dam on Johnson Creek may be barriers to fish movement (CBBTTAT 1998d).

B. Overutilization for commercial, recreational, scientific, or educational purposes

Angling regulations for westslope cutthroat trout in the Clearwater River basin currently specify catch-and-release or, in areas open to harvest, two fish per day with a 14-inch size limit (IDFG, in litt. 1998a). Hunt and Bjornn (1991) found higher densities of cutthroat in the North Fork Clearwater River watershed and Lochsa River watershed in areas open to catch-and-release angling than areas open to harvest. However, the response of westslope cutthroat trout to fishing regulations may be dependent on stream habitat conditions (IDFG, in litt. 1998a). The CBBTTAT (1998d) reported that fishing pressure is high at accessible areas in the Selway River watershed.

C. Disease or predation

Whirling disease, caused by a protozoan parasite that requires an oligochaete as its intermediate host, has been documented in Idaho. Whirling disease may pose a threat to WCT where WCT coexist with both the protozoan and its intermediate host. In the Clearwater River basin, adult rainbow trout infected with the parasite were detected in the American River (University of Idaho, in litt. 1998).

Predation on WCT by native species (e.g., bull trout and northern pikeminnow) and introduced species is a source of mortality to WCT, and the effects of predation can be exacerbated for WCT that are over-exploited or inhabit degraded habitats (Rieman and Apperson 1989). We are unaware of the degree of threat disease and predation poses to WCT in the Clearwater River basin.

D. The inadequacy of existing regulatory mechanisms

A variety of state and federal laws and regulations, if properly administered, protect aquatic habitats and reduce threats to WCT in the Clearwater River drainage. For example, Idaho has adopted a Forest Practice Act (FPA) consisting of rules and regulations addressing forest management. In general, the legislation establishes best management practices (BMPs) to be implemented on forests, such as regulations for activities allowed in riparian areas, restrictions on harvest adjacent to streams, and location of road construction. Although audits show that compliance with BMPs is high in Idaho (Malany, Idaho Forest Practice Act Advisory Committee Member, in litt. 1997), the Service is not aware of specific evaluations of various BMPs relative to the protection of WCT habitat and processes affecting water quality, such as water temperature, recruitment of woody debris, and bank stability. In Idaho, half of timber sales audited resulted in contributions of sediment to streams, largely from inadequately maintained roads (Zaroban et al. 1997). Even with high implementation rates, Idaho's forestry BMPs have been ineffective at maintaining beneficial uses, including coldwater biota (McIntyre 1993). In addition to the Idaho FPA, the Stream Channel Protection Act and Idaho Code 36-906 require unrestricted fish passage at road crossings on fish-bearing streams.

Federal regulations that protect WCT habitat include the Clean Water Act (including sections 401 and 404 permits), which regulates discharge or placement of dredge or fill material in to U.S. waters. However, several bodies of water in the Clearwater River basin were identified on the 1996 303(d) list for not fully supporting beneficial uses. These included 41 in the lower Clearwater River (CBBTTAT 1998a), 41 in the North Fork Clearwater River (CBBTTAT 1998b), 56 in the South Fork Clearwater River (CBBTTAT 1998c), and 13 and 25 for the Selway and Lochsa rivers, respectively (CBBTTAT 1998d). Sediment was the most common reason for water bodies to appear on the list. A cursory inspection of the draft 1998 303(d) list indicated that at least 14 listed water bodies correspond to streams inhabited by WCT.

Numerous management programs and other actions are being implemented to eliminate or ameliorate the adverse effects on WCT of past, present, and proposed forestry practices in the Clearwater River basin. The Interim Strategies for managing Anadromous Fish-producing Watersheds in Eastern Oregon and Washington, Idaho and Portions of California, known as PACFISH, and INFISH, both of which include riparian and stream habitat management guidance, are being applied to federal lands in the Clearwater River basin. Because WCT distribution overlaps with listed fish species (e.g., chinook salmon, steelhead, and bull trout) in the basin, consultations conducted under section 7 of the ESA will likely afford benefits to WCT.

On private lands in the Clearwater River basin, Plum Creek Timber Company is developing a Native Fish Habitat Conservation Plan that includes provisions for the conservation of WCT on their lands (M. Jostrom, Plum Creek Timber Company, in litt. 1998). Applicable areas are primarily in the Lochsa River drainage. The Potlatch Corporation has recently contacted the Service about their work to develop a Stewardship Plan for WCT on their lands, which include 675,000 acres in the Clearwater River and St. Joe River basins (T. Cundy, Potlatch Corporation, pers. comm. 1999).

E. Other natural or manmade factors affecting the continued existence of WCT

Habitats in streams in the Clearwater River basin were adversely affected by high-flow events during 1995-1996, which triggered land slides. Many slides were associated with high densities of logging roads (McLaud, Idaho Conservation League, in litt. 1997). The continued existence of these roads will cause a chronic sediment source to habitats and may affect survival of early life-history stages of WCT.

Hybridization, introgression, and interactions with introduced fishes poses a threat to WCT. Cochnauer et al. (1996) reported abundant brook trout populations in two lakes and natural reproduction of stocked rainbow trout in another lake, all in the North Fork Clearwater watershed, and stocking of catchable rainbow trout in tributaries of the lower Clearwater River and South Fork Clearwater River. The CBBTTAT (1998a; b) reported that 15 species of fish have been introduced in Dworshak reservoir (North Fork Clearwater River watershed) and may occur downstream in the lower Clearwater River, and that 10,000 lbs. of rainbow trout are stocked annually into the reservoir. The CBBTTAT (1998c; d) reported that brook trout occur in the South Fork Clearwater, Lochsa, and Selway rivers.

Salmon River Drainage

A. The present or threatened destruction, modification, or curtailment of WCT habitat or range

The majority of the Salmon River drainage is in Federal ownership under the jurisdiction of six National Forests and the Bureau of Land Management. The Frank Church-River of No Return and Gospel Hump wilderness areas encompass over 2.3 million acres along the mainstem Salmon, lower reaches of the South Fork Salmon, and almost all of the Middle Fork Salmon River basins. Aquatic habitats in these areas are protected from the effects of many activities. However, activities occurring higher in the drainage (e.g., in the South Fork Salmon River, Bear Valley Creek, Panther Creek, and the upper Salmon River watershed, including the Pahsimeroi and Lemhi rivers) may affect habitat in designated wilderness areas downstream. Evidence from upstream activities has been observed in the designated wilderness from mining (Thurow 1985), irrigation withdrawals in the Lemhi River (Dorratcaque 1986), timber harvest in the South Fork Salmon River (Chapman et al. 1991), and livestock grazing in Bear Valley (Thurow 1985).

In the Little Salmon River watershed, livestock grazing in riparian areas adjacent to Rapid River was identified as a potential problem, and in 1993, the Payette National Forest proposed to modify those grazing allotments associated with the Rapid River (NMFS 1993). The proposed grazing allotment changes were implemented in 1994, along with modifications of several other allotments to benefit chinook salmon (Uberagua, pers. comm. 1997) . In Boulder Creek drainage, near Rapid River, land management is more intensive than that occurring in the Rapid River drainage, and as a result, habitats are in poorer condition. Past timber management activities have harvested riparian stands in addition to reducing in-stream large woody debris, and the effects from this are still evident (Overton et al. 1993). Additional activities in Boulder Creek include roading, grazing, water diversion, recreation, and fuelwood gathering (Overton et al. 1993). The Yantis Ditch diverts a substantial amount of water (estimated at 80-90 % of the main flow of Boulder Creek) out of the Little Salmon watershed, and into the Wieser River watershed (Overton et al. 1993; NMFS 1993).

Several diversions near the mouth of Thompson Creek in the upper mainstem Salmon drainage dewater the creek during irrigation season (SBBTTAT 1998). Water diversion also affects habitat in other areas of the Salmon River basin, such as in the Pahsimeroi and Lemhi rivers (SBBTTAT 1998). Recent actions, however, have been undertaken by the Bureau of Reclamation for water conservation at irrigation diversions in the mainstem Salmon and Lemhi rivers (McClendon, in litt. 1997).

Most of central and north-central Idaho, including the Salmon River drainage, is in a geographic region known as the Idaho Batholith. This area is typically characterized as a granitic soil composition with extremely high erosion potential and poor slope stability. Recovery potential of disturbed sites is poor due to thin organic horizons. Salvage logging of fire-damaged trees in the South Fork Salmon watershed from the 1940s to 1960s caused mass movements of unstable soils, and long-term damage to aquatic habitat (Thurow 1987). Logging activities continue today in the watershed.

The Idaho Batholith is also rich in mineral deposits, and as a result, mining is a common land use in much of the drainage. Mining has and continues to occur in several locations, such as in the South Fork Salmon River watershed (Schuld and Apperson 1998). Mines such as the Cinnabar and Stibnite mines, located in Sugar and Meadow creeks in the East Fork of the South Fork Salmon River, may also be negatively affecting fish, including WCT, in the watershed. Efforts to rehabilitate abandoned mines have been attempted with little success except for Bear Valley Creek (Middle Fork Salmon watershed) and the Yankee Fork (tributary to the mainstem Salmon), where efforts were undertaken to improve ESA-listed chinook salmon habitat (Esch and Hallock undated).

In the Middle Fork Salmon River watershed, Grunder et al. (1990) reported that mining continues to be a major source of concern in the Big Creek drainage. Also in the Middle Fork Salmon River watershed, Idaho Department of State Lands (IDSL) et al. (1998) reported that although the watershed is almost entirely in the Frank Church River of No Return Wilderness, mining, grazing, and recreational use has locally contributed to sedimentation and bank instability. Roads have encroached on riparian areas in upper Big Creek, Smith Creek, Logan Creek, and portions of Monumental Creek. In 1983, there was a large sludge spill from a settling pond at the Dewey Mine in Mule Creek (tributary to Monumental Creek) resulting in substantial embeddedness by fine substrate, which is continuing to degrade habitat. Trampled stream banks and impaired riparian vegetation due to grazing was reported for an area of Camas Creek. Extensive placer and surface mining occurred throughout the Middle Fork watershed historically and abandoned mine waste may affect streams. Timber harvest was historically extensive in areas near mines, and treeless hillsides surround Cornish Creek near the Thunder Mountain mining areas. There is road access to only 5 % of the watershed (e.g., in Big, Loon, Monumental, Camas creeks, and Rapid River). In reviewing factors affecting bull trout in the Bear Valley watershed, Lamansky and Grunder (1998) noted that the primary legacy effects on aquatic habitat is from logging, grazing, and road construction and maintenance, and numerous culverts suspected to be barriers to fish movement are present. These same factors are likely to also be affecting WCT.

In the South Fork Salmon River watershed, Schuld and Apperson (1998) reported that high levels of fine sediment limit spawning success of bull trout in areas of all subwatersheds and embeddedness exceed forest plan objectives in many areas, including in the wilderness. Fine sediment may also affect WCT. Summer-home development within the flood plain of the Secesh River is threatening off-channel habitat in some areas. There are localized areas of elevated metal concentrations due to mining, and there is large-scale mining at Stibnite Mine and small mining claims scattered throughout the watershed. The upper East Fork Salmon River has the most severe habitat alterations due to large-scale mining and associated roads.

In the Pahsimeroi River watershed, the SBBTTAT (1998) reported that Big Creek (the primary tributary) has many water diversions and is dewatered; in the Lemhi there are many storage reservoirs on tributaries and the river has a highly altered hydrologic regime.

In the Middle Salmon River area, the IDSL reported that placer mining and roads have affected riparian habitats and there has been some channelization (IDSL et al. 1998). In addition, many streams in the Round and Stanley areas of the upper Salmon River watershed have been extensively channelized. The North Fork Salmon River watershed has several areas that were formerly placer mined. The CBBTTAT (1998e) noted the legacy effects of logging and presence of many old roads in the mid-reaches and tributaries of the main Salmon River.

B. Overutilization for commercial, recreational, scientific, or educational purposes

Angling regulations for westslope cutthroat trout in the Salmon River basin specify catch-and-release or, in areas open to harvest, two fish per day with a 14-inch size limit (IDFG, in litt. 1998a). In the Middle Fork Salmon River watershed, Liter and Lukens (1994) noted that catch-and-release regulations were instituted in 1972 for WCT; WCT numbers increased and peaked in the early to mid-1980s, and have since declined. They attributed the decline to either 7 years of drought when they sampled in the early 1990s or that fish migrating to the main Salmon River may be lost to intense catch-and-release steelhead fishing there or inadequacy of the protected area, or non-compliance of anglers. Therefore, the response of westslope cutthroat trout to fishing regulations may be dependent on stream habitat conditions (IDFG, in litt. 1998a) or other factors. Grunder et al. (1990) reported that mean length and catch rates of cutthroat increased in Big Creek, Middle Fork Salmon River watershed, after catch-and-release regulations were instituted. The IDSL et al. (1998) reported that restrictive harvest regulations implemented in 1964 had resulted in increased numbers and size of cutthroat trout in the Middle Fork Salmon River watershed.

C. Disease or predation

Whirling disease, caused by a protozoan parasite that requires an oligochaete as its intermediate host, has been documented in Idaho. Whirling disease may pose a threat to WCT where WCT coexist with both the protozoan and its intermediate host. In the Salmon River basin, fish infected with the parasite were detected at hatcheries (University of Idaho, in litt. 1998).

Predation on WCT by native species (e.g., bull trout and northern pikeminnow) and introduced species is a source of mortality to WCT, and the effects of predation can be exacerbated when WCT are over-exploited or inhabit degraded habitats (Rieman and Apperson 1989). We are unaware of the degree of threat disease and predation pose to WCT in the Salmon River basin.

D. The inadequacy of existing regulatory mechanisms

A variety of state and federal laws and regulations, if properly administered, protect aquatic habitats and reduce threats to WCT in the Salmon River basin. For example, Idaho has adopted a Forest Practice Act (FPA) consisting of rules and regulations addressing forest management. In general, the legislation establishes best management practices (BMPs) to be implemented on forests, such as regulations of activities allowed in riparian areas, restrictions on harvest adjacent to streams, and location of road construction. Although audits show that compliance with BMPs is high in Idaho (Malany, Idaho Forest Practice Act Advisory Committee Member, in litt. 1997), the Service is not aware of specific evaluations of various BMPs relative to the protection of WCT habitat and processes affecting water quality, such as water temperature, recruitment of woody debris, and bank stability. In Idaho, half of timber sales audited resulted in contributions of sediment to streams, largely from inadequately maintained roads (Zaroban et al. 1997). Even with high implementation rates, Idaho's forestry BMPs have been ineffective at maintaining beneficial uses, including coldwater biota (McIntyre 1993). In addition to the Idaho FPA, the Stream Channel Protection Act and Idaho Code 36-906 require unrestricted fish passage at road crossings on fish-bearing streams.

Federal regulations that protect WCT habitat include the Clean Water Act (including sections 401 and 404 permits), which regulates discharge or placement of dredge or fill material into U.S. waters. However, several bodies of water in the Salmon River basin were identified on the 1996 303(d) list for not fully supporting beneficial uses. Water bodies for which TMDLs have been completed or were discussed in problem assessments for bull trout, a species whose distribution overlaps with WCT, include 24 water bodies in the lower Salmon River and 8 in the Little Salmon River (CBBTTAT 1998e), and 8 in the main Salmon River (CBBTTAT 1998f). Sediment was the most common reason for water bodies to appear on the list. A cursory inspection of the draft 1998 303(d) list indicated that at least 27 listed water bodies correspond to streams inhabited by WCT.

Numerous management programs and other actions are being implemented to eliminate or ameliorate the adverse effects on WCT of past, present, and proposed forestry practices in the Salmon River basin. The Interim Strategies for managing Anadromous Fish-producing Watersheds in Eastern Oregon and Washington, Idaho and Portions of California, known as PACFISH and include riparian and stream habitat management guidance, are being applied to federal lands in the Salmon River basin. Because WCT distribution overlaps with listed fish species (e.g., chinook salmon, steelhead, and bull trout) in the basin, consultations conducted under section 7 of the ESA will likely afford benefits to WCT.

E. Other natural or manmade factors affecting the continued existence of WCT

Nonnative fishes introduced into the Salmon River basin that are most likely to negatively affect WCT include brook trout and various nonnative strains of rainbow trout. Brook trout are present in many lakes and tributaries in the basin. Brook trout were widely stocked in the upper Salmon River, Lemhi River, and Pahsimeroi River watersheds during the 1920s-1950s (SBBTTAT 1998), and they are currently found in these areas. Brook trout were the most prevalent nonnative fish in the South Fork Salmon River watershed (Schuld and Apperson 1998) and surveys found brook trout in Big and Loon creeks within the Middle Fork Salmon River watershed (IDSL et al. 1998).

Rainbow trout have also been stocked in the Salmon River basin. Fingerlings of the Kamloop strain were stocked in the upper Salmon River during 1989-1991, but this practice was discontinued due to apparent low survival. Lukens and Davis (1989) reported that about 50,000 catchable rainbow trout were stocked in five reaches of the upper river. The strains of these stockings were not given. In the South Fork Salmon River watershed, Janssen and Anderson (1994) reported that 15,000 rainbow trout were planted in Warm Lake in 1991. Rainbow-cutthroat trout hybrids were reported by the Schuld and Apperson (1998). Brown trout have been stocked in lakes within the Little Salmon River watershed (Grunder and Anderson (1991).

John Day River Drainage

A.   Present or threatened destruction, modification, or curtailment of the species' habitat or range

Upper John Day River Watershed.--Kostow (1995) reported mainstem John Day River drainage habitat modifications due to changes in stream channel structure, loss of riparian vegetation, dewatering, and changes in the hydrographs of the mainstem and major tributaries. These habitat modifications were caused by agricultural development, irrigation diversions, livestock grazing, and timber harvest. In the majority of occupied tributary streams, habitat modifications, especially on private lands, have probably shifted WCT distribution to upstream reaches, further exacerbating geographic isolation (Gray, in litt. 1998). However, in tributaries where WCT co-exist with bull trout, WCT have a greater downstream distribution, possibly indicating greater WCT tolerance than bull trout to modified habitat conditions.

Aforementioned habitat modifications have effectively isolated WCT in certain tributary systems for at least the warmer months due to warm water and low stream flows (Kostow 1995). While seasonally impassable physical barriers to WCT passage (i.e. irrigation diversion dams) often occur in the mainstem John Day River, occupied tributary streams do not exhibit WCT physical passage barriers, except for Strawberry Creek (Gray, in litt. 1998). A total of 62 water diversions with associated fish screens and passage features are present within occupied resident or migratory WCT habitat in the upper mainstem John Day River key watershed (Pence, in litt. 1998). It is unknown how many additional diversions without fish screening facilities exist in this key watershed, or how effective existing fish-screening and passage features are at allowing unhindered fish movement during periods of operation. Pence (in litt. 1998) does not indicate the existence of a fish screen/passage feature on any diversions present on Strawberry Creek, the only stream that Gray (in litt. 1998) cited as having a physical passage barrier.

WCT in the upper mainstem headwaters area (Graham, Roberts, Call, Rail, Reynolds, Deardorff creeks) exist within a "checkerboard" of public (Malheur National Forest) and private (mostly commercial timberlands, with some stream-bottom pasture lands) land ownership. Due to this land-ownership pattern, Gray (in litt. 1998) considered harvest on private timberlands to threaten WCT in this area of the watershed; however, the highly connected streams of this portion of the watershed would allow for rapid WCT recolonization.

Upper North Fork John Day River Watershed.--A dirt road parallels the lower portion of WCT occupation along Clear Creek, and a road system accesses Olive Lake on Lake Creek near the lower portion of WCT occupation. Mines and access roads are located at the headwaters of tributaries to South Fork Desolation and West Fork Clear creeks (Hirsch, in litt. 1998). No other occupied WCT reach in this drainage is readily accessible to motorized travel. A map provided by Hirsch (in litt. 1998) also indicates at least one diversion, for placer mining purposes, on East Fork Clear Creek. Two reservoirs (Olive Lake and Upper Reservoir) are located on Lake Creek; WCT distribution occurs above, between, and below these two reservoirs. No upstream passage is provided at these reservoirs. Extensive mining sites (placer and hard rock) historically and currently occur on or near several occupied tributaries. A majority of occupied WCT habitat in this drainage (85 %, approximately 20 miles) is completely surrounded by, or has one stream bank directly adjacent to, either the Vinegar Hill - Indian Rock Scenic Area or North Fork John Day Wilderness Area.

B. Overutilization for commercial, recreational, scientific, or educational purposes

Upper John Day River Watershed.--Gray (, in litt. 1998) indicates a lack of a "targeted" WCT fishery, due to a combination of small size of resident WCT and land-ownership patterns/topographic features restricting or precluding angler access. In addition, ODFW stocking programs and angling regulations are currently designed to emphasize lake and pond fisheries, further minimizing possible over harvest of exclusively stream-resident WCT.

Upper North Fork John Day River Watershed.--Granite Creek and most of its tributaries are currently closed to angling to protect chinook salmon (Hirsch, in litt. 1998). However, Lake Creek and South Fork Desolation Creek are open to angling and are managed under a 5-fish daily bag, 8-inch minimum-size limit (Gray, in litt. 1998).

C. Disease or Predation

Upper John Day River Watershed.--Due to range overlap, bull trout may prey upon smaller WCT. Hatchery rainbow trout stocking was discontinued in the upper mainstem John Day River in 1997 (Gray, in litt. 1998). Hatchery rainbow trout may have been vectors of diseases that affect WCT (Gray, in litt. 1998) .

Upper North Fork John Day River Watershed.--Introduced brook trout, found in lower South Fork Desolation Creek and below Olive Lake on Lake Creek, may be vectors of diseases that affect WCT. Other species have been introduced into Olive Lake, including at least kokanee, rainbow, and Lahontan cutthroat trout (Hirsch, in litt. 1998). Due to range overlap in South Fork Desolation Creek and Clear Creek and its tributaries, bull trout may prey upon smaller WCT.

D. The inadequacy of existing regulatory mechanisms

Upper John Day River Watershed.--All activities on National Forest lands are to be in compliance with the respective National Forest's Forest Plan, as amended by PACFISH (1995). PACFISH (1995) provides guidance to Forests regarding protection of watershed functions and properties, resulting in more environmentally compatible land-use activities. Forest practices on private lands, however, are subject to review and regulation under the Oregon Forest Practices Act (1995 amendment), which allows significantly more entry into riparian areas, including activities such as harvest, stream crossings, road building, and site restoration.

The ODFW has provided fish screens at most diversions within WCT habitat. However, Oregon State law requiring fish screening at water diversion facilities is not well enforced. Maintenance of these facilities is the responsibility of ODFW, not the private landowner.

ODFW angling regulations have recently been altered to reduce angling impacts to stream-resident fish. Current ODFW angling regulations in the upper mainstem John Day key watershed include a minimum 8-inch size limit for trout and reduced daily bag limit of five fish per day (Gray 1998, in litt.).

Sections of a total of 16 of 43 streams identified as occupied by WCT (Pence, in litt. 1998) are listed on the Oregon Department of Environmental Quality's (ODEQ) 1998 Section 303(d) list of water-quality limited (by elevated water temperatures) streams. ODEQ and Oregon Department of Agriculture are developing water-quality management plans for 303(d) listed stream segments; however, due to the magnitude of workload, plans will take time to develop and many years to implement (ODEQ 1998).

Upper North Fork John Day River Watershed.--All activities on National Forest lands are to be in compliance with the respective National Forest's Forest Plan, as amended by PACFISH (1995). PACFISH (1995) provides guidance to Forests regarding protection of watershed functions and properties, resulting in more environmentally compatible land-use activities. However, mining activities are difficult to regulate and occur within WCT occupied habitat in this watershed.

A section of one of eight streams identified as occupied by WCT (Hirsch, in litt. 1998) is listed on the Oregon Department of Environmental Quality's (ODEQ) 1998 Section 303(d) list of water quality limited (by elevated temperatures) streams. The ODEQ and Oregon Department of Agriculture are developing water-quality management plans for 303(d)-listed stream segments; however, due to the magnitude of workload, plans will take time to develop and many years to implement (ODEQ 1998).

E. Other natural or manmade factors affecting the species' continued existence

Upper John Day River Watershed.--Distributions of WCT and redband trout overlap significantly in the upper mainstem John Day River key watershed (Gray, in litt. 1998). Westslope cutthroat trout and redband trout readily hybridize; nominal genetic studies reported in Gray (in litt. 1998) and Kostow (in litt. 1998) indicate hybridization, and subsequent backcrossing, are occurring in this watershed where these native species' ranges overlap. DNA analysis of WCT samples from Dixie and Roberts creeks by Spruell (pers. comm. 1998, as cited in Hemmingsen and Gray 1999 draft) indicated predominantly pure WCT in the upper reaches of these streams, with some hybridization between WCT and redband trout in lower reaches. Behnke (pers. comm. 1990, as cited in Hemmingsen and Gray 1999 draft) found 2 of 31 WCT collected in the upper mainstem John Day River were hybridized. Kostow (in litt. 1998) indicated approximately 25 % of WCT sampled were hybrids with redband trout. During 1998, ODFW field crews began an investigation to define the "zone of sympatry" between WCT and redband trout in several upper mainstem John Day tributaries (Hemmingsen and Gray 1999 draft). Stocking of hatchery rainbow trout, a species that can hybridize with WCT, was discontinued in the upper mainstem John Day River by 1997 (Gray, in litt. 1998).

Upper North Fork John Day River Watershed.--WCT and redband trout coexist in this major drainage. The extent of hybridization that has occurred between these species is unknown. In addition, other cutthroat trout subspecies (Lahontan and possibly Yellowstone cutthroat trout) have previously been introduced into the Lake Creek and South Fork Desolation Creek watersheds.

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