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Arc Lake Restoration Project: Environmental Assessment Alaska Department of Fish and Game Division of Sport Fish 43961 K-Beach Road, Suite B Soldotna, AK 99669 TABLE OF CONTENTS PAGE LETTER TO THE U.S. FISH AND WILDLIFE SERVICE ..............................................................................................I PART I: PROPOSED ACTION DESCRIPTION...............................................................................................................1 A. Type of Proposed Action ........................................................................................................................................1 B. Agency Authority for the Proposed Action ...........................................................................................................1 C. Estimated Commencement Date ............................................................................................................................1 D. Name and Location of the Project..........................................................................................................................1 E. Project Size ..............................................................................................................................................................1 Figure 1. The Kenai Peninsula, Alaska...........................................................................................................................2 Figure 2. Aerial image of Arc Lake and City of Soldonta. ...........................................................................................3 Figure 3. Bathymetric map of Arc Lake.........................................................................................................................4 F. Summary and Purpose of the Proposed Action .....................................................................................................5 Background.......................................................................................................................................................................5 Purpose..............................................................................................................................................................................5 Proposed Activities ..........................................................................................................................................................5 PART II. ENVIRONMENTAL REVIEW AND COMMENTS .......................................................................................7 A. NATURAL ENVIRONMENT ..................................................................................................................................7 1. Land Resources ........................................................................................................................................................7 2. Water.........................................................................................................................................................................8 3. Air ...........................................................................................................................................................................12 4. Vegetation...............................................................................................................................................................13 5. Fish and Wildlife....................................................................................................................................................14 B. HUMAN ENVIRONMENT.....................................................................................................................................17 6. Noise/Electrical Effects .........................................................................................................................................17 7. Land Use.................................................................................................................................................................18 8. Risk/Health Hazards ..............................................................................................................................................18 9. Community Impact ................................................................................................................................................21 10. Public Services/Taxes/Utilities ...........................................................................................................................21 11. Aesthetics/Recreation ..........................................................................................................................................22 12. Cultural/Historical Resources .............................................................................................................................23 13. Summary Evaluation of Significance .................................................................................................................23 PART III. ALTERNATIVES........................................................................................................................................25 Alternative 1. No Action............................................................................................................................................25 Alternative 2 - Rotenone treatment and rainbow trout or salmon stocking (Proposed Action)............................25 Alternative 3 - Mechanical Removal ........................................................................................................................25 PART IV. ENVIRONMENTAL ASSESSMENT CONCLUSION SECTION..............................................................27 A) Is an EIS required?................................................................................................................................................27 B) Public Involvement (revised on 9/8/2008). .........................................................................................................27 C) Duration of the comment period ..........................................................................................................................28 E. Contact Person Responsible for Preparing the EA Document ...........................................................................28 REFERENCES CITED.......................................................................................................................................................29 i APPENDIX .........................................................................................................................................................................33 Appendix 1. Molecular structure of rotenone...............................................................................................................33 Appendix 2. Copy of the ADEC Pesticide Use Permit for the Arc Lake Restoration Project.................................34 Appendix 3. Copy of the letter of consent by the ADF&G Board of Fisheries for treating Arc Lake and Cheney Lake with rotenone.........................................................................................................................................................36 Appendix 4. Copy of the ADEC determination that a Project Coastal Management Program Review is not required for the Arc lake Restoration Project...............................................................................................................37 Appendix 5. Synopsis of Arc lake project proposal.....................................................................................................38 Appendix 6. Copy of the ADF&G news release announcing the public commenting periods for the Arc Lake and Cheney Lake environmental assessments and pesticide use permits were open. ......................................................40 Appendix 7. Comments received during the public commenting periods for the Arc Lake Restoration Project Environmental Assessment and ADEC Pesticide Use Application public and ADF&G responses. .......................42 Appendix 8. Letter from the Kenai Peninsula Borough Land Management Division sent to ADEC commenting on the ADF&G pesticide use application to treat Arc Lake with a piscicide..................................................................43 ii LETTER TO THE U.S. FISH AND WILDLIFE SERVICE Date: 7/11/2008 TO: United State Fish and Wildlife Service (USFWS) The Alaska Department of Fish and Game has developed an Environmental Assessment (EA) that proposes eradicating illegally introduced northern pike population in Arc Lake using the piscicide rotenone. The northern pike population has decimated the stocked coho salmon fishery in Arc Lake. In addition, the proximity of these pike to critical wild salmon and trout fisheries exposes these fisheries to an increased risk from further illegal northern pike introductions. The objectives of this treatment are to completely remove the northern pike population and restock Arc Lake with coho salmon or rainbow trout. This will restore a quality angling opportunity for the public while helping to protect critical wild fisheries. Arc Lake is a 16 surface-acre natural pothole lake. It is located approximately two miles south of Soldotna near the Soldotna landfill. The EA is available for viewing online at: http://www.sf.adfg.state.ak.us/region2/pike/ Please contact Rob Massengill at (907) 262-9368 if you would like a copy or have questions. Please submit any comments related to this project to the address or email below by August 25 2008. Arc Lake Restoration Project: Environmental Assessment Alaska Department of Fish and Game 43961 K-Beach Road, Suite B Soldotna, AK 99669 or email at: robert.massengill@alaska.gov Sincerely, Rob Massengill - Fisheries Biologist i ALASKA DEPARTMENT OF FISH AND GAME DIVISION OF SPORT FISH Environmental Assessment of the proposed rotenone treatment of Arc Lake for the purpose of invasive northern pike eradication and the restoration of the coho salmon or rainbow trout fishery PART I: PROPOSED ACTION DESCRIPTION A. Type of Proposed Action: Remove the northern pike population that has decimated the stocked coho salmon fishery in Arc Lake, so that this fishery can be restored. Eradicating the northern pike population will also reduce the threat that they could be introduced into nearby wild salmon and trout habitats. B. Agency Authority for the Proposed Action: By consent of the Alaska Board of Fisheries, the Alaska Department of Fish and Game is authorized to perform such acts per Alaska Statue (AS 16.35.200). C. Estimated Commencement Date: October 2008 D. Name and Location of the Project: Arc Lake Restoration Project - removal of an invasive northern pike population through the application of rotenone, a naturally occurring botanical piscicide. Arc Lake is located in T04N R11W Sec. 12 near the Soldotna landfill, approximately two miles south of Soldotna and is a natural lake (Figure 1 and Figure 2). The land surrounding Arc Lake is publicly owned (City of Soldotna, Kenai Peninsula Borough and State of Alaska (DOT)). E. Project Size (acres affected) 1. 2. 3. 4. 5. 6. 7. 8. 9. Developed/residential - 0 acres Industrial - 0 acres Open space/Woodlands/Recreation - 0 acres Wetlands/Riparian - Arc Lake is 18 acres in size, has a maximum depth of 15 feet, and a volume of 144 acre-feet. There is no surface outlet from this lake (Figure 3). Floodplain - 0 acres Irrigated Cropland - 0 acres Dry Cropland - 0 acres Forestry- 0 acres Rangeland - 0 acres 1 ALASKA Yentna N Susitna River Wasilla Cook Inlet Little Susitna River Swanson River Kenai River Soldotna Arc Lake Cook Inlet Seward Kenai Peninsula Homer N 0 Miles 30 0 1 3 4 6 2 8 Kilometer s Gulf of Alaska Figure 1. The Kenai Peninsula, Alaska. 2 Figure 2. Aerial image of Arc Lake and City of Soldonta. 3 Figure 3. Bathymetric map of Arc Lake. Elevation: 150' Shoreline Length: 0.8 mi Volume: 144 Acre-feet. Mean Depth: 8.6' Surface Acres: 18 Acres Maximum Depth: 15' ADF&G Management Area: Northern Kenai Peninsula 4 F. Summary and Purpose of the Proposed Action Background In 1965, the Alaska Department of Fish and Game (ADF&G) treated Arc Lake with rotenone to remove a native stickleback population before stocking the lake with rainbow trout in 1966. Since stocking began, Arc Lake has provided a quality recreational angling opportunity for rainbow trout (Oncorhynchus mykiss), coho salmon (Oncorhynchus kisutch) and Chinook salmon (Oncorhynchus tshawytscha). By 1987, ADF&G stocked Arc Lake exclusively with coho salmon annually until northern pike (Esox lucius) were discovered in the fall of 2000. Although Arc Lake has no surface outlets, it is located less than two miles from the Kenai River which contains world-class wild salmon and trout fisheries. The invasive northern pike population in Arc Lake could serve as a source of fish to be illegally transported into the Kenai watershed where their impacts to native salmon and trout populations could be devastating. Purpose The proposed action is to remove all fish in Arc Lake using the piscicide CFT Legumine™ (5% liquid rotenone). Upon project completion, the lake will be restocked with hatchery produced rainbow trout or coho salmon. Proposed Activities Rotenone is a naturally occurring substance derived from the roots of tropical plants in the bean family including jewel vine (Derris spp.) and lacepod (Lonchocarpus spp.) that are found in Australia, Oceania, southern Asia, and South America (Ling 2003) (Appendix 1). Native people have utilized rotenone for centuries to capture fish for food in areas where these plants are naturally found (Quigley 1956, Bearez 1998, Robertson and Smith-Vaniz 2008). It has been used in fisheries management in North America since the 1930s (Finlayson et al. 2000). Rotenone acts by inhibiting oxygen transfer at the cellular level. The biochemical process affected by rotenone takes place within the cell mitochondria and involves blocking electron transport by inhibiting NADHubiquinone reductase, resulting in the uncoupling of the metabolic pathway oxidative phosphorylation (Singer and Ramsay 1994, USEPA 2007). Fish die from tissue anoxia due to cardiac and neurological failure (Ling 2003). It is effective at low concentrations with fish because it is readily absorbed into the bloodstream through the thin cell layer of the gills. Mammals and other non-gill breathing animals do not have this rapid absorption route into the bloodstream and can tolerate exposure to concentrations much higher than those used to kill fish. Therefore, non-target organisms that do not have gills are not negatively affected at the concentrations necessary to kill fish (Finlayson 2000, Ling 2003, NPS 2006, USEPA 2007, MFW&P 2008). The boundary for this treatment is Arc Lake itself. The waters would be treated with CFT Legumine™ (57.5% liquid rotenone), which would be contained within the lake boundaries. The label recommendations for concentrations for "normal pond use" would be followed when treating the lake. On-site assays using caged northern pike will be used to determine the appropriate concentrations needed within product label guidelines, which is estimated to be about1.0 ppm of CFT Legumine™ formulation (0.05 ppm of active rotenone) or about 1.0 mg of CFT Legumine™ per liter of water. The preferred timing of the treatment would be late fall 2008, just prior to freeze-up. This typically occurs in mid-October. Rotenone naturally degrades with light and temperature (USEPA 2007). Therefore, coldwater application of rotenone would enhance the active life of the chemical and ensure a longer exposure just prior to when dissolved oxygen levels naturally drop and when lake turnover is expected to help distribute the rotenone. The persistence of rotenone in the lake will likely last from several weeks to several months depending on water temperatures, sunlight intensity, alkalinity and organic load. Although there is no 5 domestic use of water from Arc Lake, signs would be posted to warn people not to drink or to swim until the rotenone naturally degrades and sentinel fish survive, likely by spring 2009. Materials and equipment required to complete the project would be transported to the site by truck. The rotenone would be dispersed in the lake with a small motorboat equipped with a venturi pumping system that would mix lake water with the rotenone formulation and then discharge the mixture to the surface waters into the propeller wash behind the boat. Caged sentinel rainbow trout or coho salmon would be used to measure the toxicity of the water in the lake. After the treatment, caged fish will be used to evaluate when the waters have naturally detoxified. The rotenone label specifies that once caged fish survive 24 hours in treated water, it is considered detoxified and is safe for restocking. All dead fish that surface will be collected by ADF&G staff and disposed of at the Soldotna landfill. The Washington Department of Fish and Wildlife has examined various studies that documented the percentage of dead fish that float to the water surface after rotenone treatment. They estimated that approximately 70% of rotenone-killed fish sink to the bottom in water varying in temperature from 44° to 81° F and that most carcasses that surface will do so within 24 hours after treatment (Bradbury 1986). Dead fish stimulate plankton growth and aid in the recovery of zooplankton and aquatic insect populations (UDWR 2007). Gillnet sampling would commence within several days of the treatment to determine the effectiveness of the rotenone treatment, and if no pike are found, the lake would be sampled again with gillnets in spring 2009 to confirm eradication. The gillnetting effort planned to detect pike survival in Arc Lake after treatment would include 12 gill nets, each 120 ft long, 6 ft deep, with 6 panels of mesh (one each of 1/2 in, 5/8 in, ! in, 1 in, 11/2 in, and 2 in). Gillnetting would occur for three days and occur only during daylight hours. To ensure compliance with the Migratory Bird Treaty Act, gillnets will be monitored frequently (several times a day) to minimize the potential for the unauthorized “take” of loons and other birds that might become entangled in the gillnets. Owl decoys will be positioned near the set gillnets to discourage other birds, particularly waterfowl. If live northern pike are detected after the treatment, a second treatment would be planned for that winter (2008-2009) and applied as an under-ice treatment. Under ice treatment is accomplished by drilling multiple holes in the lake ice and pumping in the piscicide directly into the lake. In the unlikely event that live northern pike are detected after a second treatment, a third treatment similar to the fall 2008 treatment would be conducted in fall 2009. Monitoring is a major component of this type of management activity. Pre-treatment baseline data collection will include water quality (i.e., temperature, dissolved oxygen, pH, specific conductance and alkalinity), water and sediment chemical sampling (to determine if any background rotenone-based compounds or volatile organic compounds are present), and sampling for predominant macroinvertebrate taxa. Water quality and macroinvertebrates will be monitored for at least 2 years after treatment (2009 and 2010) to document biological recovery and maintenance of water quality. Chemical analysis of water and sediment samples will be conducted by a laboratory immediately before and periodically after treatment until background levels are realized. The environmental fate of rotenone in an under-ice environment in Alaska is undocumented; therefore, the time sufficient to monitor the complete degradation of rotenone is unknown. Interestingly, a small unnamed Kenai Peninsula lake was treated with rotenone by ADF&G during late September 2000 to eradicate illegally introduced yellow perch (Perca flavescens). Immediately following the treatment, water samples were tested indicating the rotenone concentration had attained 0.15 ppm, after 1 week rotenone concentrations dropped to 0.05 ppm, and after 2 weeks rotenone was not detectable. No rotenone was detected from any sediment samples including those taken immediately after treatment (ADF&G Unpublished). Arc Lake will likely be stocked with fish in summer 2010. Approximately 3,200 coho salmon fingerlings were 6 stocked annually before the discovery of pike, and a similar stocking level is anticipated after northern pike are eradicated. Funding The proposed action would be primarily federally funded through allocations to ADF&G from the U.S. Fish and Wildlife Service, Aquatic Nuisance Species Program. ADF&G Region II personnel will provide all manpower required to complete the project. PART II. ENVIRONMENTAL REVIEW AND COMMENTS A. NATURAL ENVIRONMENT 1. Land Resources Will the proposed action result in: Impact Unknown None X a. Soil instability or changes in geologic substructure? X b. Disruption, displacement, erosion, compaction, moisture loss, or over-covering of soil which would reduce productivity or fertility? X c. Destruction, covering or modification of any and unique geologic or physical features? X d Changes in siltation, deposition or erosion patterns that my modify the channel of a river or stream or the bed or shore of a lake? X e. Exposure of people of property to earthquakes, landslides, ground failure, or other natural hazard? 7 Minor Potentially significant Can impact be mitigated 2. Water Impact Unknown Will the proposed action result in: None a. Discharge into surface water or any alteration of surface water quality including but not limited to temperature, dissolved oxygen or turbidity? b. Changes in drainage patterns or rate and amount of surface runoff? X c. Alteration of the course or magnitude of flood water or other flows? X d. Changes in the amount of surface water in any water body or creation of a new water body? X e. Exposure of people or property to water related hazards such as flooding? X f. Changes in the quality of groundwater? X g. Changes in the quantity of groundwater? X h. Increase in risk of contamination of surface or groundwater? X j. Effects on other water users as a result of any alteration in surface or groundwater quality? X k. Effects on other users as a result of any alteration in surface or groundwater quality? project affect a Potentially significant Can impact be mitigated X YES 2a 2f X i. Effects on any existing water right or reservation? 1. Will the floodplain? Minor YES see 2a,f 2j X designated X m. Will the project result in any discharge that will affect federal or state water quality regulations? (Also see 2a) X YES 2m Comment 2a. This project would intentionally introduce a pisicide to surface water to kill invasive fish. It is anticipated the impacts would be short-term. CFT Legumine™ (5% liquid) is an EPA registered piscicide and is safe to use to eradicate invasive fish when applied according to label instructions. The proposed concentration of CFT Legumine™ is 1 ppm, but this may be adjusted within the label’s allowed limits based upon the results of on-site assays. 8 There are three ways in which rotenone can be detoxified once applied. The first detoxification method involves basic dilution by fresh water. This may be accomplished by fresh groundwater or surface water flowing into the lake. The second method of detoxification involves the application of an oxidizing agent such as potassium permanganate. This dry crystalline substance is mixed with lake water to produce a concentration of liquid sufficient to detoxify the concentration of rotenone applied. Detoxification is typically accomplished after about 15-30 minutes of mixing between the two compounds (CWE Properties Ltd, 2004). The third and most common method is to allow the rotenone to naturally breakdown. Rotenone is a compound that is susceptible to natural detoxification through a variety of mechanisms such as water chemistry, water temperature, organic load, and exposure to oxygen and sunlight (Ware 2002; ODFW 2008; Loeb and Engstrom-Heg 1971; Engstrom-Heg 1972; Gilderhus et a1. 1986). Rotenone persistence studies have found that in cold water (32°- 46° F), the half-life of rotenone ranges from 3.5 to 20 days (Gilderhus et al. 1986; Dawson et al. 1991, USEPA 2007). It has been demonstrated that in 46° F water decreases in mortality rate corresponded with degrading concentrations of rotenone such that rotenone concentrations are no longer lethal to test fish with 18 days of treatment (Gilderhus et al. 1986). However, an under-ice application of rotenone conducted in Minnesota showed that target levels of rotenone were sustained over a month until substantial snowmelt occurred that allowed sunlight to penetrate which resulted in a rapid breakdown of rotenone (Bandow 1989). It is conceivable under optimal conditions (low light, low temperature and low organic load) that rotenone could persist for months under the ice at concentrations lethal to fish, which would increase the likelihood that all northern pike in Arc Lake would be killed during this treatment. Because Arc Lake has no obvious surface water inlet to detoxify the lake water and groundwater recharge rates are unknown, the preferred detoxification method would be to allow the rotenone to degrade naturally over time. Even if the rotenone persists during winter beneath the ice, as the Minnesota treatment suggests it could, we anticipate that all rotenone in Arc Lake would detoxify by the time the lake ice melts in spring 2009. The degradation of rotenone results in at least 20 different degradation products, of which, only one is toxic (rotenolone) (Cheng, et al., 1972). Rotenolone is approximately one order of magnitude less toxic than rotenone (Finlayson 2000). The ultimate breakdown products of rotenone are carbon dioxide and water (for more information visit http://www.prentiss.com/Products/fishman.htm). There are several formulations of rotenone available as a piscicide, including liquid and powder formulations. CFT Legumine™ is a liquid mixture of rotenone and other organic compounds that facilitate the emulsification and dispersion of rotenone in water. CFT Legumine™ was analyzed by an independent contractor for the California Fish and Game Department in 2007 (Fisher 2007). This analysis showed that the primary ingredients are soluble organic compounds (SOCs) such as diethylene glycol ethyl ether (DGEE) (61.1%), Fennedefo 99™ (17.1%), N-methyl pyrrolidone (9.8%), rotenone (5.12%) and rotenolone (0.72%). Fennedefo 99™ is primarily a fatty acid ester mixture and polyethylene glycol (PEGs) and is used with rotenone as an emulsifying agent. The fatty acid ester mixture is likely derived from “tall oil”. Tall oil fatty acids are a byproduct of wood pulp (for more information visit http://www.harting.cl/talloil.html). PEGs are common ingredients in a variety of consumer products, including soft-drink syrups (as an antioxidant), lotions and antifreeze (Fisher 2007). PEGs are highly soluble, have low volatility and rapidly degrade within days. The fatty acids in the fatty acid ester mixture do not exhibit volatility, are virtually insoluble, and are readily biodegraded, although over a slightly longer period of time than the PEGs (Fisher 2007). Other compounds in Fennedefo 99™ include an array of volatile organic compounds (VOCs), but all in very low concentrations. All compounds, with the exception of polyethylene glycols (PEG), would be below the reporting limits of California. At the diluted concentration levels expected in Arc Lake, PEG levels would be 9 far below the California reporting limits. Regarding exposure to trace constituents in liquid rotenone including CFT Legumine™, trichloroethylene (TCE) is a known carcinogen. It is present in CFT Legumine™, but the concentration of this substance in water immediately following treatment (~0.0000073 mg/L) is far below the level permissible in drinking water (Fisher 2007). Diethylene glycol ethyl ether (DGEE) is the majority ingredient of CFT Legumine™. With respect to the environmental fate of this compound, volatilization, photolysis, and hydrolyses are all processes that will not be expected to occur to a significant degree in surface waters (SPECTRUM, Chemical Fact Sheet, 2006). Biodegradation is the most likely removal mechanism for the compound and 48-87% degradation would be expected in 20 days (for more information visit http://toxnet.nlm.nih.gov/). DGEE in water was observed to degrade greater than 90% after 28 days. Because DGEE is water soluble, it will not bind to sediments or bioconcentrate in fish. When tested on rats, the oral LD50 (oral dose that kills 50% of test animals) was 5.54g/kg (Bingham et al. 2001). In a lake treated with 1mg/L of CFT Legumine™, it would be expected that the concentration of DGEE would be at a concentration of 0.61 mg/L or 0.00061 ml/L. The estimated lethal dose (LD) of the chemical to humans is ~1mL/kg of body weight or about 70ml (or 70g) for a 70kg person. A 70 kg person drinking two liters of water from the lake (normal daily water intake) would only consume 0.00122mL/L of the compound, which is 1/57,000th of a fatal dose. The oral LD50 for dogs is around 3.0 g/kg, while for rats and mice the LD50 is 5.58.7 g/kg. A 10 kg (22 lb) dog drinking one liter of treated lake water would only ingest 1/49,000th of the LD50. To put this simply, unless humans or other mammals (represented here by dogs, rats and mice) drink about 195 gallons of treated water for every pound of their body weight, they will not be at risk. N-Methyl pyrrolidone. N-methyl pyrrolidone is increasing in use as a solvent because of its low toxicity. It is used as a solvent for pharmaceuticals for oral ingestion (Ott, 2008). This compound is expected to behave similarly to DGEE in an aquatic environment. Biodegradation is the pathway most likely to effect its removal from the environment, rather than volatilization, hydrolysis or photolysis (for more information visit http://toxnet.nlm.nih.gov/). The persistence of this compound in water has not been reported, but it has been found to have a half-life of 4.0, 8.7 and 11.5 days in clay, loam or sand. N-methyl pyrrolidone has been classified as readily biodegradable under aerobic conditions (Concise International Chemical Assessment Document available at http://www.inchem.org/). When rats and mice were tested, the oral LD50 reported values ranged from 3.9-7.7 g/kg. The LD50 of methyl pyrrolidone is similar to DGEE, but its concentration following lake treatment is expected to be only 1/6th that of DGEE, and acute toxic conditions should not arise for mammals drinking the water following treatment. In summary, CFT Legumine™ contains a mixture of rotenone, VOCs and SOCs and more water soluble chemicals, methyl pyrrolidone and DEGEE. The VOCs and SOCs in the formulation are expected to reach undetectable levels within a week to several weeks. However, N-methyl pyrrolidone and DEGEE would be expected to dissipate more slowly because they are water soluble and will not readily dissipate through volatilization, but both chemicals are biodegradable (for more information visit http://www.cdph.ca.gov/HealthInfo/environhealth/water/Pages/LakeDavis.aspx). Following rotenone treatment, there may be a substantial quantity of dead pike carcasses. Bradbury (1986) reported that approximately 70% of rotenone-killed fish in Washington lakes immediately sink. Parker (1970) reported that at water temperatures of 40° F and cooler, dead fish required 20-41 days to surface. The most important factors inhibiting fish from surfacing are cooler water ( 15 feet). Arc Lake has a maximum depth of 15 feet and the desired treatment period (Oct-April) would likely result in water that is 32-45 °F (Massengill In prep.) and would potentially result in few recoverable fish. Bradbury (1986) also reported that 9 of 11 water bodies in Washington treated with rotenone experienced an algae bloom 10 shortly after treatment. This occurred from the input of phosphorus to the water as fish decayed. Bradbury further noted that approximately 70% of the phosphorus content in the dead fish would be released into the lake through bacterial decay. This stimulates phytoplankton production which in turn increases zooplankton production, providing prey for macroinvertebrates and fish. This change in water chemistry is viewed as a benefit to stimulate plankton growth (UDWR 2007). Any changes or impacts to water quality resulting from decaying fish would be short-term and minor. Arc Lake is already exposed to abnormal concentrations of bird waste because gulls feeding at the nearby landfill often utilize the lake to rest and stage. High levels of preexisting fecal coli-form bacteria may be present and will be tested for before treating Arc Lake with a piscicide. Nonetheless, ADF&G personnel will recover and dispose of all surfacing dead fish at regular intervals until ice-up, an then again after ice-out until no dead fish are observed. Comment 2f: No contamination of groundwater is anticipated to result from this rotenone treatment. Because Arc Lake has no surface flow outlet, water must leach out of the lake through its bed or via evaporation. Rotenone binds readily to sediments and is broken down in soil and water (Skaar 2001; Engstrom-Heg 1971, 1976; Ware 2002). Rotenone penetrates approximately 1 inch in most soil types; the only exception is sandy soil where movement is about 3 inches (Hisata 2002). The primary soil type in the Arc Lake area consists of silty loam which is a clay and sand mixture (Van Patten 2005). Other studies indicate that the other compounds in liquid rotenone formulations have not been detected at harmful levels in groundwater associated with rotenone application (Finlayson et al. 2000, Ridley et al. 2006, Fisher 2007) and case studies in Montana have concluded that rotenone movement through groundwater does not occur (MFWP 2008). Regardless, there are no known groundwater wells in close proximity to Arc Lake. The nearest groundwater well to the project site is located approximately 100 yards to the north (Alaska Department of Transportation maintenance station). Because water leaving Arc Lake must travel through lake sediments, soil, and gravel, and rotenone is known to bind readily with these substances, no contamination of ground water is anticipated. Comment 2j: The existing sport fishery in Arc Lake is for northern pike. Anecdotal evidence suggest fishing effort for northern pike is light, yet there may be sport fishers who prefer northern pike that will experience lost opportunity. The loss of northern pike fishing opportunity would be minimal because there are six lakes within 3 miles of Arc Lake that provide northern pike fishing, some of which provide a high quality fishing experience in terms of fishing success. Comment 2m: The treatment will be confined to Arc Lake and no discharge is expected to occur outside of the lake. As required by state regulation, ADF&G will submit a pesticide permit application to the Alaska Department of Environmental Conservation (ADEC) which must be approved prior to treating Arc Lake with rotenone. 11 3. Air Will the proposed action result in: Impact Unknown None Minor Potentially significant Can impact be mitigated a. Emission of air pollutants or deterioration of ambient air quality? (Also see 13 c) X 3a b. Creation of objectionable odors? X 3b c. Alteration of air movement, moisture, or temperature patterns or any change in climate, either locally or regionally? X d. Adverse effects on vegetation, including crops, due to increase emissions of pollutants? X e. Will the project result in any discharge which will conflict with federal or state air quality regs. X Comment 3a: Emissions from four-stroke outboard motors would be produced,but are expected to dissipate rapidly. Comment 3b: CFT Legumine™ contains some solvents that make it soluble in water. The odor from these solvents can last from several hours to several days, depending on air conditions. The product manufacturer now advertises that the new CFT Legumine™ formulation is virtually odor free since reducing or eliminating a number of solvents. Nonetheless, relatively "heavy" organic solvent compounds tend to sink or remain close to the ground and move downwind. The California Department of Pesticide Regulation (CDPR 1998, cited in Finlayson et al. 2000) found no health effects from odors from rotenone formulations that consisted of greater solvent concentrations than that found in CFT Legumine™. Applicators will have the greatest potential contact with odors. However, as the product label recommends, they will wear respirators for protection. Any impacts caused by objectionable odors would be short-term and minor. The northern pike carcasses from this project may cause objectionable odors. Collecting and/or sinking dead fish in the lake will help mitigate this, making the effects from these odors short-term and minor. 12 4. Vegetation Will the proposed action result in: Impact Unknown None a. Changes in the diversity, productivity or abundance of plant species (including trees, shrubs, grass, crops and aquatic plants)? Minor X b. Alteration of a plant community? X c. Adverse effects on any unique, rare, threatened, or endangered species? X d. Reduction in acreage or productivity of any agricultural land? X e. Establishment of spread of noxious weeds? X f. Will the project affect wetlands, or prime and unique farmland? X Potentially significant Can impact be mitigated 4a Comment 4a: Arc Lake is located south of Soldotna and there is one unimproved boat launch/access that can be used for this project. There is also a small dirt parking area near the lake that will be used. Thus, there should be little trampling of vegetation around the lake. No direct, immediate, or long-term impacts to vegetation are anticipated from the treatment itself because rotenone does not negatively affect plants at concentrations necessary to kill fish. 13 5. Fish and Wildlife Minor Potentially significant Can impact be mitigated b. Changes in the diversity or abundance of game animals or bird species? X yes 5b c. Changes in diversity or abundance of nongame species? X yes 5c Will the proposed action result in: Impact Unknown a. Deterioration of critical fish or wildlife habitat? None X d. Introduction of new species into an area? X e. Creation of a barrier to the migration or movement of animals? X f. Adverse effects on any unique, rare, threatened, or endangered species? X g. Increase in conditions that stress wildlife populations or limit abundance (including harassment, legal or illegal harvest or other human activity)? X h. Will the project be performed in any area in which T & E species are present, and will the project affect any T & E species on their habitat? (Also 5f) X i. Will the project introduce or export any species not presently or historically occurring in the receiving location? (Also see 5d) X See 5b,c Comment 5b: Fish: This project is designed to kill non-indigenous invasive fish. It is not believed any fish species other than northern pike inhabit the lake based on ADF&G test netting results during the summer of 2007. Sticklebacks were native to Arc Lake prior to a rotenone application designed to remove them in the 1960’s. Minnow traps will be set in the summer of 2008 to determine if the stickleback population has survived although none have been observed by ADF&G staff that has recently worked at Arc Lake. All stocked coho salmon appear to have been eliminated by northern pike or naturally expired since stocking was discontinued. Game Mammals: Grizzly bears, black bears and wolves are found in the area but are not dependent on the lake or fish from the lake for food. The infrequent occurrence of bears in this area, human activity related to the project implementation, and the removal of dead fish resulting from this project would reduce the potential for these species to consume rotenone-killed fish. Even if rotenone-killed fish were consumed by bears, there would be no adverse effects because the rotenone would be degraded by enzymes in the animals’ digestive tracts (Finlayson et al. 2000, USEPA 2007). Because this project is planned for autumn, freeze-up conditions 14 would further limit bear scavenging behavior at the lake. Following rotenone treatment, daily monitoring of the lake to collect dead fish should limit fish carcasses from becoming an attractant to bears. The project itself would have no impact on bears. Ingestion of treated waters by terrestrial wildlife should also have no adverse effects because of the low rotenone concentrations and enzymatic action in the animal’s digestive tracts. Also, the gastrointestinal absorption of rotenone is inefficient (Finlayson et al. 2000). Rotenone has a low acute toxicity via the dermal route of exposure and receives a toxicity category IV rating; in rabbits, the LD50 is >5000mg/kg (USEPA 2007). Risk of inhalation exposure to rotenone from the liquid CFT Legumine™ to wildlife is almost nonexistent. Only individuals working with the concentrated product could be at risk and they would be protected with appropriate protective respirators suggested by the product manufacturer. There is a year-round distribution of moose and seasonal (spring-fall) presence of caribou in the area. It is possible these species may ingest water from the lake during the treatment period. EPA-approved bioassays indicate that, at the proposed concentrations, rotenone would have no effect on mammals that drink the treated water (Schnick 1974a, 1974b; Herr et al. 1967). Migratory waterfowl: During the proposed treatment period, most waterfowl will have already migrated from the area. The remaining waterfowl that could be present during the proposed treatment may be temporarily displaced from the Arc Lake area, but the availability of other waters in close proximity to the project area should minimize any impacts. It is possible that these birds may feed on rotenone-killed fish carcasses shortly after treatment. However, research has indicated it is not physiologically possible for birds to consume sufficient quantity of rotenone-killed fish to result in a lethal dose (Finlayson 2000 and USEPA 2007). Rotenone residues in dead fish are generally very low (