Idaho Tribal Fish Consumption Survey July 2016

Idaho Tribal Fish Consumption Survey
July 2016

&EPA

U.S. EPA Region 10

At-A-Glance

• The Nez PerceTribe, Shoshone-BannockTribe, and EPA completed surveys of currentTribal fish consumption
during 2014-2015.

• The data collected indicate that Idaho Tribes currently consume more fish than the general population
(see Figure 3, page 2).

• This survey indicates increased Tribal fish consumption from a 1994 Columbia River Inter-Tribal Fish Commission
(CRITFC) survey which included the Nez PerceTribe. Increased consumption may be associated with fish
restoration work, but also may be due to differences in survey design.

• A 2016 review of heritage (i.e., historic) fish consumption for the Kootenai, Coeur D'Alene, Nez Perce, and
Shoshone-BannockTribes compiled past harvest and consumption rates1.

• The heritage fish consumption information assists in quantifying suppression of currentTribal fish consumption
relative to historic levels.

Background-Tribal Fish Consumption and Ambient Water Quality Criteria

The Clean Water Act establishes the national goal that water
quality should provide for the protection and propagation offish,
shellfish, and wildlife, and recreation in and on the water. It also
requires states to develop water quality criteria for all priority
toxic pollutants to protect the health of high fish consumers.

EPA's national ambient water quality criteria are currently being
developed using a fish consumption rate of 22 grams per day
(based on the 90th percentile of a national, general population
data set). EPA recognizes the importance of drafting water quality
criteria that protect Tribal fish consumers. With EPA and tribal
involvement that included review and discussion of tribal fish
consumption rates, Oregon and Washington now have water
quality criteria using a fish consumption rate of 175 grams per day.

Since December 2012, EPA has been collaborating with Idaho
Tribal Governments (Kootenai, Coeur D'Alene, Nez Perce,

Shoshone-BannockTribes and Shoshone-PaiuteTribes) on a Id®(1

Tribal fish consumption survey. The purpose of the survey was to:

• Build Tribal environmental capacity; ^UK 1 mbalgovernments in Idaho.

• Determine current and heritage fish consumption rates;

• Understand the causes of and reasons for suppression offish consumption and Tribal hopes for the future; and

• Collect data to support:

o Development of Tribal water quality standards;
o Use by Idaho Department of Environmental Quality (DEQ); and
o EPA's actions in Idaho.

To ensure unbiased and defensible results, EPA built a team of subcontractors with recognized expertise in facilitation,
survey design, survey implementation, statistics, and working with Tribes. EPA shared updates on the survey at all
Idaho DEQ negotiated rulemaking meetings and coordinated with DEQ staff on the State's own survey efforts. The
survey could not have happened without support of Tribal leadership. Tribal governments provided tremendous
leadership and resources to complete the surveys.

1 Heritage fish consumption rates are those Native American fish consumption rates that existed prior to changes in fish consumption associated with the
impacts of non-tribal settlement on tribal fisheries resources as well as changes in tribal culture and lifeways.

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Methodologies Used

The survey used two methodologies to
derive fish consumption rates:

1, State of the art nutritional survey
methodology developed by the
National Cancer Institute (NCI)2.

a. Employed a face-to-face and a 2nd
phone interview to collect fish
consumption information for the
previous 24 hours.

b. Used statistical modeling to develop usual fish consumption rates.

2. The Food Frequency Questionnaire (FFQ) methodology required individuals to estimate their fish consumption
over a calendar year in a single face -to-face interview, usually lasting about an hour.

Tribal consumption data were used to develop fish consumption rate statistics for two different groups:

Group 1: All fish and shellfish.

Group 2: Fish and shellfish species that may acquire contaminants from habitat waters that are of concern
under the Clean Water Act (CWA) (i.e. near coastal, estuarine, and freshwater).

Note that salmon were included in Group 2.

Interviews ranged over an entire calendar year to assess seasonal changes in fish consumption. The survey
methodology was reviewed by two institutional review boards, including one familiar with Tribal traditional lifeways.

Implementation of the Idaho Tribal Fish Consumption Survey

The Shoshone-Bannock
and Nez Perce Tribes
participated in the
quantitative survey.

EPA's market research
subcontractor hired,
trained, and managed
Tribal interviewers from
each Tribe to improve
response rates and
protect culturally-sensitive
information.

Tribal enrollment
records were used to
randomly select survey
respondents and to
insure that results from
the individuals surveyed
accurately reflected the
fish consumption behavior

of the tribal populations. Interviewers utilized computer assisted personal interview technology with error checking
to ensure accurate administration of survey and recording of data. Interviewers also used 3-D portion size models and
supplemental photos to characterize portion sizes. EPA pilot tested the survey in spring of 2014, interviews started in May
2014 and ended in April 2015. The Tribes, EPA, and the subcontractor team conducted quality control throughout the
survey to ensure the survey stayed on track.

Figure 2 Interviewers used salmon fillet replicas to help estimate portions.

Statistic

Figure 3, Consumption ofnearcoastaiZestuarine/fresh water fish by the Nez Perce (NPT) and Shoshone Bannock
(SET) Tribes. (FFQ-food frequency questionnaire, NQ-National Cancer Institute Method)

2 https://epi.aiants.cancer.aov/diet/usualintakes/method.html

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Data Collection Challenges and Collaborative Solutions

Because enrollment records did not include necessary contact information, locating and contacting interview subjects
was difficult. In response, the interview staff arranged for, and conducted interviews at, central locations and at special
events. Further, EPA and CRITFC staff traveled to the Nez Perce Reservation to increase the number of completed
interviews. The Nez PerceTribe granted eligible Tribal employees administrative time to participate in interviews and
allowed non-Tribal interviewers from EPA and CRITFC to interview Tribal employees.

Working together, the interview teams conducted enough interviews to support both the FFQ and NCI methodologies.
The 717 FFQ interviews collected greatly exceeded the 385 interview project target.To have strong assurance for the NCI
methodology to work, there must be approximately 50 respondents who have recorded consumption of the fish species
of interest for both of their 24-hour recall interviews. 51 respondents reported consumption for both interviews. The
survey effort thus successfully collected the data needed to develop Tribal fish consumption rates.

Quality Assurance

Quality assurance was of major concern throughout the survey effort. The accuracy of interviewer data input was
verified. Re-interviews were conducted to assess the accuracy of results. The changes in interview protocol noted
in the previous section were evaluated and found not to have a significant effect. Almost all consumption rate
calculations per individual respondent were replicated independently by two project statisticians and all respondents'
rates used in consumption rate calculations were the same by the two independent calculations. Additionally, a
statistician with the NCI—one of the developers of the NCI method—was able to successfully replicate the distribution
of usual consumption (all species combined) obtained by project statisticians using the NCI method.

Peer Review and Preliminary Results

An independent peer review panel of experts reviewed the survey of current fish consumption and found the survey
was well done. Peer review comments were comprehensively addressed. Where necessary, modifications were
incorporated into the final survey report. Peer reviewers supported the methodology and analysis used to obtain FFQ
and NCI FCRs. Idaho DEQ found the Tribal survey to be of sufficient quality that it used survey data to calculate Idaho's
proposed fish consumption rate.

Tribal Heritage Fish Consumption Rates

EPA and contractors also
conducted a review of
heritage fish consumption
rates for the Kootenai,

Coeur D'Alene, Nez Perce,
and Shoshone-Bannock
Tribes and collaborated
with the Tribes and EPA
in drafting heritage fish
consumption reports
for each Tribe. Each
report summarized all
historical fish harvest
and consumption rates
by Idaho Tribes as well
as Columbia RiverTribes.

Heritage fish consumption
rates were based on direct
observation of past tribal
fishing activity as well
as daily caloric intake
requirements, the caloric

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Literature Citation

Figure 4. Heritage Fish Consumption Rates for Idaho Tribes and Columbia River Tribes.
(Note that full citations for specific heritage rates may be found in the references
section of the heritage fish consumption reports.)

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content offish, and the fraction of the diet that consisted offish. Reports discussed causes for fish population declines,
heritage fish consumption information and methods of rate derivation. Heritage fish consumption rates can be used
to develop Tribai water quality standards and heip inform the State standards. Idaho Tribal heritage fish consumption
rates are presented in Figures 4 and 5.

Key Outcomes and Findings

• Fish consumption rates for the
participating IdahoTribes indicate
that, in almost all cases, Idaho
Tribes currently consume more
fish than the general population.

• IdahoTribes generally consume
more fish than previously
documented 20 years ago in the
1994 Columbia River Intertribal
Fish Commission (CRITFC) survey.

• Tribal members attribute
increased fish consumption, in
part, due to habitat improvements
and an increased availability
offish in local rivers and lakes.

Differences in the design of EPA's
survey relative to the original
CRITFC survey may also contribute
to differences in derived fish
consumption rates. The current
survey comprehensively recorded

all fish consumption while the CRITFC survey focused on consumption of Columbia River Basin fish. The Idaho
Tribal surveys successfully collected data for and implemented the National Cancer Institute method, the state
of the art approach for conducting surveys of current fish consumption.

The Idaho Tribal surveys successfully collected data for and implemented the National Cancer Institute method,
the state of the art approach for conducting surveys of current fish consumption.

Independent peer review indicated that the Idaho Tribal fish consumption survey information was of high
quality and was properly analyzed.

Current and heritage fish consumption rate information was provided to Idaho DEQ in compliance with the
State's rule development schedule, informing the State's water quality criteria development process.

The heritage survey report documents and quantifies heritage fish consumption rates, providing support for use
of this information in developing Tribal water quality standards.

Comparison of current and heritage fish consumption rate information documents that current consumption is
suppressed relative to historic consumption.

All current and heritage tribal fish consumption reports are available at:

www.epa.aov/columbiariver/idaho-tribal-fish-consumption-survev

Literature Citation

Figure 5. heritage Ftsh Consumption Rates for IdahoTribes: and Columbia RiverTribes.
(Note that full citations for specific heritage sates may be found in therefetmces
section of the heritage fish consumption reports,)

For More Information

Please contact Mary Lou Soscia, at 503.326.5873 or Soscia.Marvloutaepa.aov

For technical information, please contact Lon Kissinger, at 206.553.2115 or Kissinaer.Lon@epa.gov

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