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IFFF Conservation Action Report
March 21, 2016
The following conservation actions were taken either in the form of a signed letter over IFFF letterhead or endorsement with signature on collaborative comments provided by organizations with whom we are formal partners. The IFFF can have stronger influence regarding agency management and/or regulatory actions in some cases when issues relate specifically to fishes and/or their habitats. But, in many cases the issues may be broader than fish and wetland and speak more too broadly to land and wildlife management and protection issues in ways that include fish and their habitats. The IFFF often can have much more effective impact in these cases by collaborating through partnerships that have professional staff whose total responsibilities are monitoring and speaking on behalf of natural resources and our partners. All documents are retained on file and available for review.
Re-authorization of the Water Resource Protection Act:
The Water Protection Network made a request of the IFFF to provide signature endorsement with other partners to congress regarding reauthorization of the Water Resource Protection Act with six specific reforms to language in the act as additional guidance to the US Corps of Engineers for how the agency reviews and evaluates projects that may adversely affect waters of the US under provisions of the National Environmental Policy Act. We agreed with the submittal, found language and recommendations in the document consistent with previous endorsements and provided signature support and endorsement of the letter.
Crevice Mining Group, LLC Application:
IFFF was made aware of an application to the Montana Department of Environment Quality (DEQ) for permit authorization to mine gold on private property northeast of Gardiner and adjacent to the Yellowstone National Park and Absaroka Beartooth Wilderness. A letter was submitted to the DEQ expressing concern for likelihood of adverse effects of the proposed activity on wildlife and wetlands, with specific bases for concern and requesting that the application and proposed activity be fully evaluated through preparation of an Environmental Impact Statement in accordance with applicable Montana Law that is administered by the DEQ.
Illegal Fish Introductions in Montana:
The Montana Wildlife Federation contacted the IFFF soliciting partnership support of a petition and plan of action to request the Montana Fish, Wildlife and Parks take additional regulatory steps to bring about an end to the illegal introduction of fish species that continues in Montana. The plan of action was reviewed and found to be comprehensive and warranted. Signature support was provided with intent to monitor progress and provide additional comment when and if appropriate.
Beaverhead River Hydroelectric Project:
It was brought to IFFF attention that the Federal Energy Regulatory Commission (FERC) had received an application for permit authorization from the Clark Canyon Hydro, LLC, proposing to modify the existing Clark Canyon Hydroelectric Facility at Clark Canyon Dam and that the FERC proposed to process the application under an expedited review. The IFFF chose, in this case, to support partners by submitting comments on IFFF letterhead. Comments generally pointed out that impacts to downstream water quality, fisheries and recreation had already occurred as result of the existing facility and that the proposed activity would be more appropriately reviewed through preparation of an Environmental Impact Statement that would require best available scientific, social and economic data to evaluate existing impacts, necessary solutions and likely further adverse effects that may result from the new proposed activity.
Smallmouth Bass Study:
The US Geological Survey is partnering with Montana Fish, Wildlife and Parks; Montana State University and the Joe Brooks Chapter of Trout Unlimited on a study of smallmouth bass impacts in the Yellowstone River. The IFFF has been asked, at the recommendation of Orvis Company to partner on the project as the lead non-profit organization to both support the project but also to administer a $25K grant from Orvis for the project. Orvis, by policy, does not provide grants to government agencies and if provided to the University, substantial administrative overhead would be subtracted from the grant amount before any dollars went towards the study. Among other project support, IFFF has been asked to receive the grant and administer the grant to the agencies and university to both solve the Orvis policy issue and to maximize use of the grant amount for the study. IFFF may charge a minimal percentage for administration of the grant, but this will be another unique opportunity for IFFF to play a vital role as a conservation partner on behalf of our members.
Prepared by: Tom H. Logan
Senior Conservation Advisor