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Buffalo Creek: Our Side of the Story

Ted Williams has been a respected friend and colleague for over 40 years. I appreciate his writing because he is fearless in challenging the environmental shibboleths, sanctities and hypocrisies that reverberate throughout our woke world. His recently posted blog from his grays Sporting Journal article has engendered considerable comment. With due regard to differing opinions and well researched perspectives, we are posting Bob Mallard’s rebuttal from Native Fish Coalition (NFC). From my personal perspective I think Williams and NFC folk have much to agree upon and the problem child  with Buffalo Creek opponents lies with organizations such as Wilderness Watch. After 20 years of massive forest fires desecrating our western forests might our Wilderness toadies recognize that forest management and management of exotic fish are needed to restore native fish population?.

As National Board members for Native Fish Coalition, we feel compelled to respond to some misleading statements about the organization and our positions pertaining to wild refuges and the proposed Buffalo Creek project put forth in an article, “Noah’s Arks for Imperiled Salmonids,” written by Ted Williams and published on your blog.  

Native Fish Coalition is a 501(c)(3) founded in 2017 to provide an absolute focus on wild native fish conservation.  NFC’s focus is not limited to salmonids, nor even gamefish, and includes all wild native fish species.  Originally incorporated as Native Fish Coalition of Maine, NFC now has chapters in 17 contiguous states from Maine to Alabama.       

By definition, wild refuges involve using surrogate waters to house at-risk fish that are not native to the water, including waters that were historically fishless.  This is notably different than what is referred to as restoration or reintroduction which involves the recovery of species that were historically present, or native, to the respective water. 

                While Ted quotes NFC’s position in regard to introducing fish to historically fishless water as, “We…do not support introducing [trout] to previously troutless, or fishless waters,” what our formal and publicly available policy in regard to wild refuges actually says, and has said since we finalized it months ago is as follows:

“As a rule, NFC is opposed to the introduction of nonnative fish as they compete with wild native fish and other lifeforms for food and space, can prey on them, and disrupt or suppress natural reproduction.  This includes historically fishless waters… While NFC is generally opposed to wild refuges involving nonnative fish, our position is not absolute, and we will look at things on a case-by-case basis.”

-NFC Online FAQ

As for Buffalo Creek, NFC was unaware of the project until we were contacted by a member who had read an article by Ted in support of the project that appeared in Grays Sporting Journal.  We were asked if Ted was speaking for NFC in regard to his endorsement of the project.  Unfamiliar with either the project or the article, we told the person that we would look into it and get back to them.   

As a relatively new organization, NFC is setting policy as we go.  In the case of Buffalo Creek, we were faced with our first issue involving wild refuges.  Having formal and published policies on everything from stocking to chemical reclamation to recreational angling, it was clear that we needed to develop a general policy on wild refuges before taking a position on any specific projects.

                NFC’s policy in regard to wild refuges was developed by members of our National Board with input from two founders and officers most responsible for daily operations, as well as several state chairs that sit on the board who chose to opine.  Several board members declined to participate due to a lack of understanding of the issues.  

                NFC did not ally with anyone in regard to wild refuges.  We developed our policy on wild refuges sans any influence from outside parties or specific projects.  There was nothing “irresponsible” nor any “hubris” in not talking to those involved in the Buffalo Creek project as we were working on a general policy, not a position on a specific project at that time.  Had we taken a formal position on the Buffalo Creek project, we would have reached out to those involved for clarification if needed.    

                 Seeing it as an important issue, NFC Executive Director Bob Mallard wrote about wild refuges in his conservation guest column in MidCurrent.  NFC blogged the article as well, and while generic references were made in regard to certain components of the proposal, in neither case was Buffalo Creek mentioned by name.  What NFC did, was to present a fair and balanced position in regard to wild refuges that asked as many questions as it did provide answers.     

“The problem [with wild refuges] is at the micro not macro level.  I believe this needs to be dealt with on a case-by-case basis and with open, frank, and fair discussion along with a willingness to compromise when challenges arise.  An all-or-nothing position is not good for fish or fish conservation.”

   -Bob Mallard – MidCurrent, September 27, 2022

“Bob does not claim to have all the answers in regard to wild refuges, nor should anyone else, as it’s just not that simple.  This needs to be looked at on a case-by-case basis, with everyone willing to listen and concede ground when concession is prudent and needed.”

-NFC Blog – October 3, 2022

Once NFC had a policy in place in regard to wild refuges, we performed an extensive analysis and evaluation of the Buffalo Creek proposal, including a line-by-line review of an 84-page proposal put out by Montana Fish, Wildlife & Parks, as well as other related documents, highlighting and discussing areas of concern. 

After review, NFC concluded that while we supported parts of the project, some of what was in the Buffalo Creek proposal was in conflict with our policies, while other parts were subjective and potentially in conflict.  While those who chose to opine were unanimous in regard to supporting some parts of the Buffalo Creek proposal, we were unable to gain consensus in regard to other parts.

NFC also took into consideration the fact that we did not have a presence in Montana, and that our closest chapter was 1,500 miles away.  While NFC does get involved in issues outside of our current coverage area, this is usually at the state policy or big picture level, not the local project level. 

When NFC decided not to take position on Buffalo Creek, we opted not to publish our findings as we felt it would serve no purpose beyond making what would be a difficult project even tougher.  Unfortunately, with our credibility and professionalism publicly challenged by writer Ted Williams and Montana Fish, Wildlife & Parks biologist Carol Endicott, we are forced to release our findings in order to clarify why we took the position we did.

For background purposes, there were three options presented in the Buffalo Creek proposal:

1. Removal of rainbow trout using rotenone and establishing a secure population of Yellowstone cutthroat trout within the Buffalo Creek watershed
2. No Action
3. Removal of rainbow trout and leaving the watershed fishless

 Two other options were considered in regard to removing the nonnative rainbow trout from the stream and rejected, and rightfully so as they would be ineffective:

• Mechanical removal using electrofishing and nets
• Angling

Those involved in the project chose option #1, to remove the nonnative rainbow trout and stock Yellowstone cutthroat post reclamation.

To be clear, NFC fully supports, and has from the start, the removal of nonnative rainbow trout from Buffalo Creek that are leaking into Slough Creek and beyond, and hybridizing and competing with stressed wild native cutthroat.  This includes the use of chemical reclamation and mechanical means to support it.  This position is in line with NFC policy.  It was also identified in the proposal as the top priority and primary goal of the project:

“The primary goal of this project is to remove rainbow trout from the Buffalo Creek watershed, which would protect the genetic integrity of Yellowstone cutthroat trout in the Lamar River basin.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page ii)

“The primary goal of the proposed action is to eliminate the source of rainbow trout…”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 13)

NFC was however concerned that while Yellowstone cutthroat are admittedly stressed, the section of stream targeted for a wild refuge was said to be historically fishless, a position that is clearly documented in at least 7 places in the proposal: 

“The Buffalo Creek watershed was historically fishless upstream of a barrier waterfall near the boundary of Yellowstone National Park.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 11)

“The area would be left fishless, which was its historical state until rainbow trout were planted in Hidden Lake in 1932.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 26)

“The waterfall at the Yellowstone National Park boundary was likely a total barrier to upstream movement of fish, and these waters were likely fishless before introduction of rainbow trout.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 51)

“This project would expand the distribution of Yellowstone cutthroat trout within its historical range, but in historically unoccupied habitat.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 51)

“The project area was likely historically fishless, with the barrier falls preventing native Yellowstone cutthroat trout from colonizing these waters from downstream.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 56)

“Not removing rainbow trout and replacing them with native Yellowstone cutthroat trout in the historically fishless waters…”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 57)

“…by returning the upper watershed of Buffalo Creek to its historically fishless condition.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 58)

The position that the section of Buffalo Creek targeted for a wild refuge was historically fishless was reiterated by Montana Fish, Wildlife & Parks in a related press release dated April 14, 2022:

“While Buffalo Creek had been documented as fishless…”

-Decision Notice and Finding of No Significant Impact for the

Buffalo Creek Yellowstone Cutthroat Trout Conservation project (Page 3)

Apparently Ted has not read the Buffalo Creek proposal as he challenged the position that the stream was historically fishless in his article, while criticizing NFC for citing the lack of historical presence of cutthroat in the stream as an area of concern:

“Had [NFC Executive Director Bob Mallard] complied [with Williams’ insistence that he reach out to Ms. Endicott], he’d have learned…that the creek almost certainly sustained Yellowstone cutts in recent geologic time.”

Ms. Endicott, the author of the Buffalo Creek proposal, contradicts this position as well, saying that “[NFC’s] free to make their own operational definition of ‘historically fishless’…’”  To be fair, NFC was simply acting on what she stated in the proposal multiple times, and the agency she works for reiterated in a related document. 

If the statements in the proposal in regard to the lack of historical presence of Yellowstone cutthroat in upper Buffalo Creek are incorrect, they should be retracted.  If this were the case, NFC would support the reintroduction of Yellowstone cutthroat post-reclamation as it would be fully within organization policy.

NFC was also concerned that the refuge would be open to recreational angling post reclamation.  We felt this could be seen as self-serving on the part of anglers and those focused on recreation versus conservation, and in conflict with the stated goal of creating a “refuge” for at-risk fish.

                There are numerous references to the potential loss of angling opportunities in the proposal which give the impression that pressure from anglers and/or resource managers may have influenced the decision to open the stream to fishing post reclamation:

“Stocking catchable Yellowstone cutthroat trout into Hidden Lake would mitigate for the short-term loss of angling opportunities.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page iv)

“[not restocking would] eliminate angling in an area where visitors to the Absaroka-Beartooth Wilderness have been able to catch fish since 1935..”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 26)

“However, leaving the watershed fishless would eliminate an opportunity for solitude or primitive and unconfined recreation. This fishery contributes to the enjoyment of recreationists and supports the livelihood of guides and outfitters.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 58)

“Fishing is popular in Hidden Lake, which has an

outfitter’s camp nearby…”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 61)

“…the outfitter’s camp near Hidden Lake and easy access to Buffalo Creek for those hiking or on horseback gives anglers opportunities to fish the lake and stream.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 61)

“Fishing is an existing land use in the Buffalo Creek watershed and leaving the waters fishless would eliminate this land use.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 62)

“Removal of fish using CFT Legumine would result in temporary loss of angling at Hidden Lake and in streams within the project area.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 71)

“Yellowstone cutthroat trout would be stocked in streams in the Buffalo Creek watershed. The stream-dwelling populations would take up to 5 years to provide quality angling.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 71)

A quote in the article attributed to Endicott appears to contradict that stated in the proposal when she states that the stream is “…barely fished.”  If the stream is barely fished as Endicott implies, why are we so concerned with keeping it open to fishing post reclamation? 

If, however, this is being done to lessen opposition to the proposal from the angling community, Endicott should say so, not criticize those who are questioning why a so-called “refuge” for at-risk fish would be open to recreational angling.

Ms. Endicott is also quoted as saying the following in the article.  Based on this and the statements above, it would be fair to assume that recreational fishing and concerns with regard to opposition from the angling community clearly played a role in the decision to open the refuge to fishing post reclamation:

“[The opposition] is accusing us of trying for a recreational fishery, as if that would be bad.”

Carol Endicott – Montana Fish, Wildlife & Parks

To be clear, restocking nonnative cutthroat to create a refuge post reclamation was presented as a secondary goal in the proposal.  Unfortunately, it has now taken center stage and possibly at the expense of what everyone should agree is the most important goal, the removal of nonnative rainbow trout: 

“A secondary benefit of the proposed action is that it would establish a secure population of nonhybridized Yellowstone cutthroat trout in Buffalo Creek.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page ii)

“The secondary goal of the project is to establish a secure population of nonhybridized Yellowstone cutthroat trout in an area that should remain cold enough for Yellowstone cutthroat trout into the foreseeable future.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 13)

Upper Buffalo Creek is located in a designated Wilderness Area.  The proposal acknowledges this and goes as far as to say that leaving the stream fishless post-reclamation would be in the best interest of maintaining its wilderness characteristics of the area, while reiterating the fact that the stream was historically fishless:

”The naturalness quality of wilderness character would be improved by returning the upper watershed of Buffalo Creek to its historically fishless condition.”

-Buffalo Creek Yellowstone Cutthroat Trout Conservation (Page 58)

Many groups voiced concerns about the Buffalo Creek project.  Whether you agree with them or not, most stated their positions fairly, clearly and concisely, citing laws in regard to mechanical intrusion into Wilderness Areas, concerns about chemical reclamation, precedent setting, messaging, etc. 

                Per Montana Fish, Wildlife & Parks, write-in opposition to the Buffalo Creel proposal outpaced support by a factor of nearly 2-to-1.  Additionally, more than 8,700 letters of opposition came in via an online campaign sponsored by a conservation organization:

“FWP received input from 74 individuals with some representing organizations. Forty comments were against the project, 24 comments were in support of the project, and 10 comments didn’t indicate their position or posed questions.”

-Decision Notice and Finding of No Significant Impact for the

Buffalo Creek Yellowstone Cutthroat Trout Conservation project (Page 2)

“FWP received approximately 8,769 form letters [opposing the project] either directly or counted by a spam filter.”

-Decision Notice and Finding of No Significant Impact for the

Buffalo Creek Yellowstone Cutthroat Trout Conservation project (Page 2)

In his article, Williams challenges 21 conservation organizations by name, including NFC, representing thousands of members in regard to their opposition to wild refuges and/or the Buffalo Creek proposal.  He criticizes 4 individuals by name, including NFC Executive Director Bob Mallard, as well as “local anglers” and the outdoor publication Outdoor Life. 

                Ted and Carol use terms such as caterwauling, apoplectic, grossly inaccurate, copious false claims, derailed, screeds, shrill, hypocritical, disingenuous, rife with falsehoods, hubris, incredibly irresponsible, fiction, falsely claiming, and groused to refer to those who are opposed to the project or have concerns.   

Rather than publicly attacking those with questions and concerns in regard to wild refuges and/or the Buffalo Creek proposal, we believe that Williams and Endicott would be better served by engaging in fair and open dialogue, including with NFC which supports the primary and most impactful part of the proposal, the removal of nonnative rainbow trout from the stream.

While the primary goal of removing nonnative rainbow trout from Buffalo Creek is sound, and something that NFC fully supports, there are issues concerning other aspects of the project that need to be discussed and resolved before NFC could endorse it in its entirety.  NFC feels the same about wild refuges in general.  What are the rules?  Who sets the rules?  When do we act? 

We really need to be careful here as we are now fighting for what we have been fighting against for decades: the introduction of nonnative fish.  We got into trouble at Buffalo Creek by introducing nonnative fish.  Now we are proposing to remove the fish we introduced and replace them with another species that is not native to that section of stream. 

Below is NFC’s formal policy in regard to wild refuges.  It can be found under the FAQ tab on our website.  We believe it is accurate, fair, science-based, and pragmatic.  And while we note our areas of concern, we do not close the door to using wild refuges to save imperiled wild native fish.  We are just not convinced that Buffalo Creek is one of those times. 

Q: WHAT IS NATIVE FISH COALITION'S POSITION IN REGARD TO STOCKING IN SUPPORT OF CREATING “WILD REFUGES” FOR AT-RISK FISH?

A:  In some cases, at-risk fish are moved to waters where they are not native, including historically fishless waters, to try to save them.  These are often referred to as wild refuges.  Wild refuges have saved a number of species, subspecies, and unique populations, including Aurora trout and greenback cutthroat.  In the case of the former it was planned; in the case of the latter, it was by accident.  As a rule, NFC is opposed to the introduction of nonnative fish as they compete with wild native fish and other lifeforms for food and space, can prey on them, and disrupt or suppress natural reproduction.  This includes historically fishless waters.  We are also very concerned with regard to messaging, as nonnative fish pose the biggest immediate threat to our wild native fish.  If we want anglers to stop moving fish around, we need to lead by example, and introducing fish into waters where they were not native, for any reason, works against that.  NFC also believes that if we do so, the surrogate water should be closed to fishing, as some will see it as self-serving.  While NFC is generally opposed to wild refuges involving nonnative fish, our position is not absolute, and we will look at things on a case-by-case basis.  NFC sees wild refuges as a last resort, and something that should not be taken lightly.  We believe that wild refuges should be reserved for species, subspecies, and unique life forms that are at imminent risk of extirpation or extinction.  Where exactly that line is drawn is subjective and open to debate.

Bob Mallard – Executive Director, Native Fish Coalition
Emily Bastian – National Chair, Native Fish Coalition
Brian Cowden – National Vice Chair North, Native Fish Coalition
Matthew Lewis – National Vice Chair Soth, Native Fish Coalition