Interagency fish kill response guidance document and protocol

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Comment From: Minnesota Trout Unlimited (John Lenczewski)

5/10/24 @ 5:11 PM

Minnesota Trout Unlimited (MNTU) is submitting the following public comments to the draft interagency fish kill response guidance document and protocol required by Minn. Stat. § 103G.2165. MNTU and its several thousand members are concerned about pr...↓otecting, restoring, and sustaining coldwater fisheries and their watersheds across Minnesota. Given the exceptional coldwater fisheries in southeast Minnesota, our members are particularly concerned over the frequency of fish kills occurring there.
MNTU has identified several improvements that should be made in the final guidance document and protocol to ensure timely investigation and better public disclosure of lessons to be learned from fish kill. Although the draft Guidance & Protocol is a good effort overall, and one we support, we believe the priority focus of the agencies should be concrete actions to address the factors already known to contribute to the fish kills that have occurred in southeast Minnesota over the past decade.
The following additions and revisions should be made to the final guidance document and protocol to ensure that investigations occur without delay so that useable information is obtained that will prevent more fish kills:
1. Qualified contractors are needed "on call" for weeknights, weekends, and holidays. The draft on page 7 notes the agencies lack on-call staff during these times and that this will cause delays in response. It also notes contractors could be used yet does not call for this. These times represent 75% of the hours in a year! The draft must be revised to include the use of on-call emergency contractors trained and equipped for rapid response whenever agency staff are unavailable. A qualified contractor (or contractors) should be engaged and on a retainer so that it will respond at a moment's notice. This type of contracted service already exists for some toxic spills. It should be set up for toxic fish kills as well.
2. Stakeholders should be able to request an After Action Review. The draft on page 17 describes a process for the agencies to critique the response to a fish kill to identify and address future needs and modifications to improve the response plan. Only one of the agencies can request an AAR. Stakeholders should also be able to request this type of Review. And stakeholders should be able to easily obtain the results of these Reviews.
3. The DNR should be free to report its recommendations and prevention measures whether or not a unified interagency report is drafted. The draft on page 16 says individual agency reporting is typically sufficient but the interagency team may decide to prepare a unified report. Decision criteria are vague. Any agency should be able to request a unified report. The DNR should be free to report its recommendations and prevention measures even if its conclusions are not shared by the other agencies. Appendix C: Fish Kill communications guidance should be changed to specifically state that once the agencies complete their investigations the DNR is free to report its recommendations and prevention measures.
4. More detailed response procedures are needed for the karst region of Minnesota. The draft contains a one size fits all set of procedures for all areas of the state. Given the porous and fractured bedrock, the close connection between surface and groundwater, the steep terrain, and frequency of human caused fish kills here, the guidance should be further reviewed and revised with an eye to ensuring a more rapid and thorough response to southeast Minnesota fish kills.
5. MPCA should be the lead agency for fish kills in southeast MN, until investigation determines a cause warranting DNR be the lead. Time is of the essence in investigating fish kill. All the major fish kills did or would have fallen to MPCA to lead or co-lead. The guidance and protocol should designate the MPCA as the initial lead agency for investigations fish kills in southeast Minnesota, until such time as the investigation results indicate that a "natural" cause is involved.
6. Milestones needed. The current draft lacks timetables or milestones for all the various steps and procedures, including interagency coordination. We agree with the goal of "ascertaining the cause of the fish kill in 24-48 hours", but this is not attainable without clear timetables and milestones.
These are just the major areas for improvement of the draft from the standpoint of fisheries protection. There are also important points relating to the human health aspects of these fish kill events. Our comments on these aspects are included in joint comments with MCEA and other partners.
Thank you for your thoughtful consideration of our comments.
Sincerely,
/s/ John P. Lenczewski

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Comment From: Leech Lake Band of Ojibwe (Craig Tangren)

5/10/24 @ 4:01 PM

Please find attached the Leech Lake Band of Ojibwe's comments on the Draft Interagency Fish Kill Response Guidance Document.

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Comment From: Minnesota Well Owners Organiza... (Jeffrey Broberg)

5/10/24 @ 2:54 PM

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Comment From: Jeffrey Broberg

5/10/24 @ 2:34 PM

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Comment From: Minnesota Center for Environme... (Akilah Sanders-Reed)

5/10/24 @ 12:09 PM

The Minnesota Center for Environmental Advocacy ("MCEA") and other organizations listed as signatories submit the attached comment in response to the draft interagency fish kill response guidance document and protocol required by Minn. Stat. § 103G....↓

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Comment From: Kenneth Fetterly

5/07/24 @ 10:42 AM

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Comment From: Murray County Emergency Manage... (Carl Nyquist)

4/24/24 @ 8:40 AM

I will start with the backstory.

We understand that fish kills happen.

Our concerns are with the response and cleanup efforts.

In 2022 Murray County lakes were impacted with a significant winter kill. To get ahead of the response, I ...↓

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Comment From: Nick Phelps

4/16/24 @ 12:21 PM

Great report - it is a big step in the right direction. Thank you for your effort on this!

It would be helpful to provide a stronger definition/disclaimer/context for two words commonly used in the report: non-urgent and natural. While the nuance is...↓ mentioned in a few spots in the report, it could be strengthened by being more explicit. I have repeatedly seen agency folks (state and local) and the public use words like non-urgent and natural to describe fish kills, often in the context of justifying reasons not to report and/or respond. Continued use of these words may unintentionally counteract the legislative mandate to increase reporting of fish kills.

1. Urgent/Non-urgent -- I understand the value of triaging fish kill response, but am concerned the classification as urgent vs non-urgent does not accurately describe what you are trying to achieve. It really isn't about urgency of response, as fish die offs due to pathogens also require urgency if an accurate diagnosis is to be ruled out/in. Instead, perhaps there are tiered response categories... For example: Tier 1-acute toxic events, high importance areas, etc (current 'urgent' category led by MPCA/MDA); Tier 2-significant fish kill/die off not associated with acute event, chemical permitted by DNR (current 'non-urgent' category, but warrant rapid response, led by DNR); and Tier 3-summer/winter kill and/or small fish kills of low-priority species (current 'non-urgent' category, led by DNR). Furthermore, I am concerned that the use of 'non-urgent' may unintentionally leave agency staff and/or the public to misunderstand this categorization as 'non-important', which would be problematic for increasing the goal of reporting and the DNR's ability to effectively and rapidly respond if their responsibility is most often 'non-urgent'.

2. Natural -- While fish (and other aquatic life) will naturally die, the suggestion that mortality events caused by low-DO, warm temp, etc are 'natural' disregard the human-induced impacts to our lakes. I assume the interagency team understands this nuance, but this is a term that will be picked up from this report and used for public communication (it already happens, including in the public presentation). The consequence of this misunderstanding may lead folks to under-report what they may consider a 'natural' event. If you want to continue to use the word 'natural', I suggest including a statement that more directly says something like: "Fish die offs are often associated with low DO, warm temp, and opportunistic fish-specific pathogens. While this report refers to these types of events as 'natural', we recognize that these conditions can be exasperated by human-induced impacts to our water and climate. Reporting fish die offs helps to inform long-term trends and mitigation strategies, both areas of ongoing research and management."

If you have any questions, don't hesitate to reach out.
Nick Phelps, [email protected]

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Comment From: Marv Nysetvold

3/15/24 @ 11:53 AM

It appears the document seeks to clarify the roles of the different agencies, which is commendable. However, when we experienced a large fish kill on Lake Shetek last spring (2023), no agencies had a plan to assist with any of the clean up and indiv...↓

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Comment From: Trevor Humphrey

3/13/24 @ 12:32 PM

As someone who has gone through two 75% winter die-offs in a 15 years timespan. This guidance response gives to much discretions to an already understaff DNR. If a winter die-off is deemed non-urgent then the DNR has indefinite time to come up with...↓

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Comment From: Virgil Luehrs

3/12/24 @ 12:59 PM

Just wondering if SWCD are included in governing bodies to be consulted?

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Comment From: Murray County Sheriff's Office (Heath Landsman)

3/11/24 @ 3:24 PM

2 years ago Murray County experienced a very large winter fish kill due to prolonged low oxygen levels from an extremely cold winter. Murray County residents were left to deal with the fish clean-up on their own. The state agencies involved chose t...↓

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