Relict Dace Endangered Species Act Decision Expected by the End of September

A relict dace - photo: Nevada Department of Wildlife

Although it’s small in size, Nevada’s relict dace has become a big name in recent conservation efforts, as a petition and a lawsuit have been put forth to protect the fish under the Endangered Species Act (ESA). The process began in 2014 when Forest Service Employees for Environmental Ethics submitted a petition to the US Fish and Wildlife Service (FWS) to list the relict dace, found only in northeastern Nevada, under the ESA. 

“We received a petition back in June 2014 requesting that the relict dace population at the Johnson Springs Wetlands Complex in Goshute Valley be listed as endangered under the Endangered Species Act,” Laurie Averill-Murray, biologist at the US Fish and Wildlife Service, said. “So we’ve been evaluating the petition and we’re currently completing work on our 12-month finding in response to the petition.”

Under the ESA, a finding on a species petitioned to be listed as threatened or endangered is required within a 12-month period. The years-long delay in a finding prompted the Center for Biological Diversity (CBD) to file a Complaint for Declaratory and Injunctive Relief earlier this month in the US District Court for the District of Nevada.

According to the Complaint, the CBD is seeking declaratory relief that David Berhnhardt, Secretary of the US Department of the Interior, and Aurelia Skipworth, Director of the US FWS are in violation of the ESA by failing to make a decision on the relict dace’s status in the 12-month period.

The Complaint also seeks injunctive relief that would establish new dates by which a decision on the relict dace’s status will be made. According to the FWS, a decision is expected by the end of the federal fiscal year, September 30.

The Long Canyon Gold Mine

Construction on the Long Canyon Mine began in 2015 in the Pequop Mountains of northeastern Nevada. The mine was originally proposed to only have mining operations conducted above the water table.  

In 2018, Nevada Gold Mines, operator of the Long Canyon project, proposed an amended operations plan to include deep, large-scale dewatering at rates up to 43,000 gallons per minute. The dewatering plan triggered the Center for Biological Diversity Complaint.

Listing the relict dace on the ESA would present significant hurdles for the proposed gold mining project.

As you can see in the interactive map below, the Long Canyon Mine and Johnson Springs Wetland Complex exist side-by-side.

There is cause for concern that the mine’s proposed water-pumping plan would essentially wipe out the relict dace population located adjacent to the mine.

“It is the second phase of the 2018 amended plan of operation that is a particular concern,” Averill-Murray said. “[Underground water-pumping] is going to basically cause the spring in Johnson Springs Wetland Complex to dry up, and then the habitat for the fish to dry up with it. This is going to be a large-scale dewatering operation adjacent to the wetland and fish need water.”

For Patrick Donnelly, Nevada state director at the Center for Biological Diversity, the dewatering plan strikes at the heart of the ecosystem that supports the relict dace and other iconic megafauna, large and small.

“Nevada’s springs and wetlands are epicenters of the biodiversity that make Nevada so special, but gold mining companies are drying them up and killing off our native species,” Donnelly said. “Only the Endangered Species Act can save the relict dace.”

The petition for endangered status for the relict dace only pertains to the population found in the JSWC, located in the northern part of the Goshute Valley. The relict dace are also native to springs throughout Ruby Valley, Butte Valley and Steptoe Valley in northeastern Nevada. An additional relict dace population was later introduced to Spring Valley, but is not native to those springs. 

This relict dace is actually 8 centimetres long. A relict dace can live for more than 10 years – image: harvested from a Nevada Department of Wildlife photo

The relict dace was petitioned as a Distinct Population Segment (DPS), meaning that if a distinct population is unique in relation to the species found elsewhere, it can be just that distinct population that is listed as endangered. In this case, it’s the relict dace population at the JSWC that is being evaluated as a distinct population segment for endangered status. 

“The basis of the petition was that there was an imminent threat of extinction of this population in Goshute Valley because of the ongoing development of the Long Canyon Mine,” Averill-Murray said. “The habitat modification and degradation that would occur from groundwater development associated with the mine would put an imminent threat on the fish. They also pointed to the rather restricted distribution of the species, its unique genetics, its small population size and the inadequacy of existing federal regulatory protections for the species.”

The relict dace population has persevered since the Pleistocene era, when ancient Lake Lahontan covered most of Northern Nevada over 10,000 years ago. At the same time, ancient Lake Bonneville also existed in what is now northern Utah. Now, various species of dace live in spring systems in locations across the Great Basin.

“In northeastern Nevada, there are four lakes in which we have evidence that the only species that occurred in these lakes was the relict dace,” Chris Crookshanks, a staff biologist at the Nevada Department of Wildlife (NDOW), said. “Over the course of thousands of years as these lakes desiccated, relict dace were isolated to a number of spring systems that occur generally on the valley floor where these lakes once existed.”

Due to the isolated nature of their desert-spring habitats, the relict dace has no natural predators. 

“[The relict dace are] unique in that in its natural state it has no predators because it’s the only known species to evolve in these systems,” Crookshanks said. “Once these giant lakes became spring systems, [relict dace became] the sole inhabitant. But if you introduce non-native species, they become very susceptible to predation.”

Over the past 20 years, NDOW has taken a series of range-wide field surveys to assess the status of the relict dace population.

“We go to known locations where the species exists and do trapping surveys to see the extent of abundance and distribution to see if they’re still there,” Crookshanks said. “We also look for new locations that possibly haven’t been surveyed and see where relict dace are existing now.”

The relict dace lives in shallow, spring-fed wetlands on the Goshute Valley floor adjacent to the Long Canyon gold mine – photo: Nevada Department of Wildlife

Despite their limited habitat locations, it’s still difficult to assign a number or estimate to their total population size. This is due to the relict dace being a spring-dependent desert species, whose population size naturally fluctuates dramatically over time.

“[We don’t have an exact population number] because a lot of these populations increase and decrease naturally over time based on weather, climatic patterns and changes in their habitat,” Crookshanks said. “So you can go to one location and get a relative number of the species in this habitat and come back the next year to do the same type of survey and it would appear that the species has plummeted. That would typically raise a bunch of red flags, but we see these natural fluctuations all the time in these spring-dependent desert species.”

Consequently, the field surveys are conducted to discover the relative abundance of the population, which is evident by the number of age classes existent in a single habitat.

“The number of age classes is a huge indicator of not only continued reproduction, but recruitment into that population,” Crookshanks said. “We have a number of age classes: young of the year, juvenile fish and adult fish that shows you that the population is persisting over time and we’re getting continued reproduction and recruitment into that population. We’re also looking at the distribution of fish in one particular habitat over time.”

Yet the surveys can oftentimes be restricted by private landowners of the springs in which relict dace are found. In 2006, Crookshanks and NDOW received permission by private landowners to conduct surveys at a number of spring locations in northeastern Nevada, but were denied access to those same locations ten years later due to a change in land ownership.

“[The relict dace population] has stayed relatively static in that they are still occupying most locations where they have historically been,” Crookshanks said. “But it gets a little bit tricky because a lot of these ranches in northeast Nevada change hands relatively frequently. So we can’t say definitively if they’re still there or if they were extirpated. It remains a question mark because we didn’t get access to survey.”

The surveys still play a vital role in assessing the relict dace population, a population that has endured through centuries of changes in Nevada’s desert springs as settlers and ranchers began developing the land. 

“A lot of these spring systems have been used for irrigation purposes for ranching,” Crookshanks said. “Most [relict dace] habitats associated with agricultural property have been extremely modified and manipulated. With that being said, the species is extremely resilient and has persisted despite these constant manipulations, dams, diversions and whatnot over the course of the past 100-plus years.”

Downstream flow from the Johnson Springs Wetlands Complex in the Goshute Valley, Nevada – photo: Nevada Department of Wildlife

Although the relict dace has persevered through these changes to its habitat, there is concern that the Long Canyon Mine’s expansion of operations below-ground will affect the population at the JSWC drastically.

“The Johnson Springs Wetlands Complex, in relation to all other places where relict dace live across all four valleys, is a really special and an extremely unique place,” Crookshanks said. “It’s unique in that it’s made up of a number of different spring systems, something like 88 separate springs on the property itself.”

The vast and connective nature of the JSWC results in a relict dace population that is spread out across various different spring heads on the property, which further complicates the mine-expansion issue.

“We call [these relict dace] the Johnson Springs Wetlands Complex population, but it’s actually made up of a bunch of different populations,” Crookshanks said. “Some inhabit just a single spring source, while we’ve got populations that live in these channels and ditches on the property.

“So the Johnson Springs Wetland Complex is really unique and special in that it’s so big, so complex and it’s unlike anywhere else on the landscape of where relict dace live. [The Complex] is really pretty phenomenal in that it’s relatively intact as it’s been manipulated for ranching purposes over the years.”

But with the proposed expansion of the Long Canyon Mine to include underground mining, the large-scale water-pumping required for the active mining areas may result in the desiccation of spring sources that may further diminish the relict dace habitat and population.

Consequently, the relict dace population at JSWC is awaiting a decision for its potential listing under the Endangered Species Act. If the FWS decides to list the relict dace under the Endangered Species Act, the little fish would then receive federal protection that could thwart the proposed expansion operations of Long Canyon Mine. 

“[To be protected] would mean that if federal agencies are going to be approving a project, they would have to consult with the Fish and Wildlife Service about impacts to the dace,” Laurie Averill-Murray said. “Then we would conduct an analysis to determine whether the proposed action would jeopardize the continued existence of the relict dace at this location.”

The Nevada Department of Wildlife and the US FWS study relict dace populations in Nevada’s Goshute Valley – photo US FWS

If it is determined a proposed action would not significantly affect an endangered species, the proposal can move forward. But if it’s determined that the action would negatively affect the species, non-discretionary measures would have to be designed and implemented to minimize the effect on the endangered species population.

In the meantime, a long-term conservation plan is being designed to protect the relict dace species population at JSWC. The conservation plan is being put forth as a collaborative effort between the US Fish and Wildlife Service, Nevada Gold, BLM and NDOW. 

“This conservation plan is coming out of a letter of agreement that the US Fish and Wildlife Service signed with what was Newmont Corporation, but is now Nevada Gold Mines, back in August of 2015,” Averill-Murray said. “That letter of agreement called for establishment and operation of a technical working group for the conservation of the Johnson Springs Wetland Complex and to develop an ecological study plan that would provide appropriate management actions for the persistence of relict dace in the Wetland Complex.”

Since the amended plan of operation was proposed in 2018, the scope of the long-term conservation plan has had to change, however, a draft of the plan is expected to be released for peer-review in July.

After the peer-review process is completed, the plan will be attached as an appendix to the Long Canyon Mine’s Draft Environmental Impact Statement that will be released by BLM for public review by March of 2021, as required by the National Environmental Policy Act (NEPA).

The mine’s final Environmental Impact Statement is expected to be available for public review in August of 2021, with a Record of Decision made by September of the same year, according to BLM.

Patrick Donnelly said the conservation plan being put forward by the US Fish and Wildlife Service, Nevada Gold, BLM and NDOW is an act of greenwashing and in no way ensures the preservation of relict dace habitat. He said the rare fish is far more important to the planet than gold. 

“Nevada is the driest state in the union,” Donnelly said. “Our water resources are too precious to waste on mining so out-of-state shareholders can profit. This little fish has every right to continue living where it has for thousands of years. That’s what we’re fighting for.”


Scott King is a graduate student at the University of Nevada, Reno, pursuing his Master’s degree in Media Innovation. Originally from Cleveland, Ohio, Scott recently returned from Grenada, where he served for two years as a literacy teacher with the Peace Corps. Support his work in the Ally.