In a case of massive overreaction, NPS, Montana FWP, and the equivalent Wyoming agencies are planning to apply rotenone to Soda Butte Creek from its headwaters all the way to Ice Box Canyon in order to clear out a tiny population of invasive brook trout. If you've ever fished this section of Soda Butte, you should know it holds easily 50 to 1 cutthroats to brookies, and rotenone won't distinguish between the two and will completely destroy this fishery for years. It will also have serious negative consequences on lower Soda Butte (the famous section) because it takes a while for rotenone to dissipate. I suggest readers familiar with Soda Butte comment on this proposed plan.

They claim that electrofishing has failed to accomplish their goals. I don't buy it. I've never seen an electrofishing crew up there and I used to guide up there all the time.

Here is the News Release: http://www.nps.gov/yell/learn/news/y...utte-creek.htm

Here is the comment form: https://parkplanning.nps.gov/documen...cumentID=66094

Here are my comments:

To Whom:

While I am in favor of the removal of brook trout from upper Soda Butte Creek, I am STRONGLY opposed to the use of piscicides rather than more-precise methods of fish removal, in this instance probably meaning electrofishing. There are several reasons why I believe piscicides are a terrible idea in this case:

1.) The trout population in upper Soda Butte Creek, at least from Warm Creek downstream to Ice Box Canyon, is overwhelmingly composed of unhybridized cutthroat trout. I have been fishing this water since the 1990s and guiding on it since 2001, with my most recent guiding excursions on this section of stream happening last September. My own fishing and guiding experience has shown that very few cutthroats show any sign of hybridization with rainbows, probably due to the cascades in Ice Box Canyon. Moreover, my clients and I have caught fewer than ten brook trout between Warm Creek and Ice Box Canyon, and literally thousands of cutthroats. We have caught zero brook trout downstream of the closest road bridge to the NE Entrance to the park. While these experiences are not scientific, I do believe they are representative of the real distribution of brook trout in this portion of Soda Butte.

2.) By applying piscicides upstream of Ice Box Canyon, large numbers of cutthroat trout downstream will also be killed before the rotenone dissipates, regardless of what chemicals are used in an attempt to dissipate the chemical. Most of these will be juvenile cutthroat trout that hatch in Ice Box Canyon and eventually down-migrate into the downstream meadows. Thus the application of piscicide upstream of Ice Box Canyon will have negative impacts on fish populations downstream.

I believe the preferred alternative is to use a selective means of removing brook trout. Between the YNP boundary and Ice Box Canyon Soda Butte Creek lacks substantial tributaries that could serve as brook trout refuges. Therefore, systematic electroshocking would be an excellent tool at removing brook trout without much unintended cutthroat mortality. Moreover, brook trout and cutthroats are visually distinct, much more so than cutthroats and rainbows, so removal of shocked brook trout would require only cursory visual inspection and thus be efficient.

If initial shocking surveys suggest extreme numbers of brook trout upstream of Warm Creek, small-scale piscicide application in these areas (particularly in tributaries of Soda Butte Creek near Cooke City) might be required, but I STRONGLY encourage NPS, FWP, and other agencies to attempt brook trout removal throughout upper Soda Butte Creek via a selective method first.