Columbia spotted frog by Chloe and Trevor Van Loon via iNaturalist

Speak up by April 11 to keep poison out of the Strawberry Mountain Wilderness

We need you to speak up for the Strawberry Mountain Wilderness in eastern Oregon to stop yet another project that would poison a lake and a few miles of streams with rotenone! This rugged, high elevation Wilderness was one of the original 54 Wilderness areas designated by the 1964 Wilderness Act. Today, its 69,350 acres protect alpine lakes, headwater streams, and countless native species.

The U.S. Forest Service has released a Minimum Requirements Decision Guide (MRDG) on a plan to poison High Lake and 1.5 miles of Lake Creek above Lake Creek Falls within the Strawberry Mountain Wilderness. And, rather than undertake the required environmental analysis and fulfill its obligation to properly administer this Wilderness, the Forest Service has passed the decision on to the Bonneville Power Administration, an agency with zero Wilderness expertise. We need you to speak up by April 11.

The original project proposal called for aerially spraying rotenone—a pesticide, insecticide, and piscicide—from a helicopter, in addition to drip station applications of the poison to eradicate brook trout in historically fishless waters and “replace the fishery with sterile rainbow trout” that “will be actively managed.”

While we appreciate that the agency has dropped the use of a helicopter to carry out this activity, it has ignored our calls to reject the proposal outright. Instead, an inflatable motorboat and a gas pump, both prohibited by the Wilderness Act, would be used to poison High Lake over the course of anywhere from one to three years, with the area closed to the public for two weeks a year. Wilderness Watch objects to both the use of poison in Wilderness along with the methods of application.

The project’s purported purpose is to kill brook trout, which compete and hybridize with native bull trout residing downstream. But rotenone will poison and kill other aquatic life, including possibly tadpoles of Columbian spotted frogs, a candidate species for Endangered Species Act listing. And rotenone’s broader impacts on the environment are not fully understood. Further, the section to be poisoned is above bull trout habitat, and the lower reaches also contain nonnative fish.

Additionally, it is unclear from the latest proposal whether the naturally fishless waters will be will be restocked with fish as originally called for.

The Strawberry Mountain Wilderness is no place for poisons or motorboats, nor is it a place for managers to play God with species and habitat manipulation. The Wilderness Act was passed precisely to rein in the propensity of managers to want to control nature.

Destroying native species and damaging Wilderness ecosystems isn’t the answer for protecting native trout. Moreover, intensive intervention and manipulation projects like this are fundamentally at odds with the Forest Service’s mandate to preserve wilderness character. The appropriate wilderness response to previously introduced fish in these waters is to let nature take its course as the Wilderness Act prescribes, but if fish are to be removed, it must be done without motors and poisons. And, under no conditions should other fish be stocked in these historically fishless waters.

These activities could not be more antithetical to the concept of Wilderness. And unfortunately, this poisoning project in the Strawberry Mountain Wilderness is just one of an increasing number of proposed projects around the country where managers want to create their desired conditions rather than protect wild nature. Please speak up by April 11!

The Bonneville Power Administration is accepting public comments here: https://publiccomments.bpa.gov/CommentEntry.aspx?ID=507


Please write in your own words, and personalize your comments if you can, but try to include the following points:

I oppose the Upper Malheur Brook Trout Removal Project, which impacts the Strawberry Mountain Wilderness.

The Forest Service needs to fulfill its obligation to properly administer this Wilderness by completing a wilderness-specific environmental impact statement (EIS) rather than passing the decision to the Bonneville Power Administration—an agency without wilderness expertise or a statutory mandate to preserve wilderness. The EIS must demonstrate Wilderness Act compliance, analyze impacts to the entire aquatic ecosystem, and rigorously explore alternatives to this ecosystem manipulation and motorized use plan, including a no-action alternative reviewed through a Wilderness Act lens.

High Lake and Lake Creek are rich aquatic ecosystems filled with life. Rotenone will poison and kill other aquatic life, including possibly tadpoles of Columbian spotted frogs, a candidate species for Endangered Species Act listing, and rotenone’s broader impacts on the environment are not fully understood. Further, rotenone poisoning poses risks to downstream bull trout habitat, and the lower reaches also contain nonnative fish that will continue to compete with bull trout even if fish are successfully eradicated from upstream wilderness waters.

The plan includes activities prohibited by the Wilderness Act, including a motorboat and a gas pump for poisoning the lake. These activities could continue for anywhere from one to three years, and include yearly two-week closures.

I urge Bonneville Power and the Forest Service to say NO to this proposal to degrade the Strawberry Mountain Wilderness with motorboats and poison. The appropriate wilderness response to the presence of fish that were introduced a century ago is to let nature takes its course as the Wilderness Act prescribes. If efforts are made to remove the fish, they must be done without motors and poisons. Under no conditions should other fish be placed in this historically fishless area, and if the agencies know this is being considered, it must be disclosed to the public.

Thank you for considering my comments.

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Photo: Columbia spotted frog by Chloe and Trevor Van Loon via iNaturalist 

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