September
24, 2002
Everett Wilson,
Chief
Division of Environmental
Quality
U.S. Fish and Wildlife Service
4401 North Fairfax Drive,
Suite 322
Arlington, VA 22203
Dear Mr. Wilson:
I am writing on behalf of
Great Lakes United regarding
the proposed rule to list
the black carp as an injurious
species of wildlife under
the federal Lacey Act, as
published in the Federal Register
(Vol. 67, No. 146, RIN 1018-AG70).
Great Lakes United is an international
coalition of over 150 environmental
and conservation organizations,
unions, academia and businesses
in the U.S., Canada, First
Nations and tribes dedicated
to the protection and restoration
of the Great Lakes-St. Lawrence
River basin. This comment
letter is being submitted
electronically and via mail.
Great Lakes United supports:
Listing of black carp as
an injurious species of wildlife
under the federal Lacey Act
Expansion of the Lacey Act
listing to include other Asian
carp species, including the
bighead, grass and silver
carp
Removal of species of carp
where currently stocked or
traded in the U.S.
Great Lakes United is extremely
concerned with the threat
of Asian carp invading the
Great Lakes basin and compromising
the already faltering biological
integrity of Great Lakes waters.
The threat of Asian carp invading
the Great Lakes is tremendous.
The black carp, for example,
prey heavily on native shellfish,
clams and mussels, which are
already under considerable
stress due to invasion by
the invasive zebra mussels.
The combination of competition
by the zebra mussels and the
predation by black carp may
drive native bivalve and univalve
species to extinction. Carp
also pose a significant risk
to native fish species, due
to the carp’s voracious
appetite, high fecundity,
and tendency to modify its
environment. These characteristics
could lead to disruptions
in native fish behavior, including
feeding and spawning, and
eventually fish population
extirpations.
Great Lakes United supports
the black carp listing to
be expanded to include the
bighead, grass and silver
carp species. This would eliminate
interstate shipment of live
Asian carp for trade. These
two bighead and silver carp
species have not yet invaded
the Great Lakes, and every
effort to prevent this species
from entering the Lakes should
be taken.
Due to the threat of living
carp stocks already in held
in the U.S., Great Lakes United
would support efforts to immediately
remove the black carp, or
other species listed as an
injurious under the federal
Lacey Act, from trade, markets,
fish ponds, or wherever they
may be found.
Further, to help get the
horse back in front of the
cart, Great Lakes United promotes
the creation of permitted
(white) lists, as well as
prohibited (black) lists.
Any species not listed as
permitted should be prohibited
from entering the United States
until reviewed and proven
safe by an independent scientific
panel, and also reviewed publicly
through the Federal Register.
Current regulations allow
importation of some species
that are later deemed injurious.
This is simply a backwards
approach and should be ameliorated.
This approach often lists
species as injurious after
extensive private investment,
after injurious species already
escaped into the wild, and
after prevention measures
are no longer available. This
approach would regularly require
extensive, expensive and questionably
effective and safe control
measures for species listed
as injurious. If U.S. businesses
are allowed to continue investing
money importing potentially
injurious species, any future
efforts to regulate these
species will be even more
contested than they are presently.
This is unnecessarily divisive
and should be avoided. To
protect the Great Lakes biological
integrity, fish communities,
fisheries and general public,
the burden of proof must be
satisfied before entry is
permitted. The U.S. Department
of Agriculture (through the
current permitting process)
single-handedly holds the
keys to the future of the
Nation’s aquatic resources.
That is wrong. Permitting
authority should therefore
be placed under control of
the U.S. Department of the
Interior.
We encourage federal agencies
to take immediate, aggressive
action with regard to limit
the spread of Asian carp and
other invasive species, issues
and make strong decisions
to protect the Great Lakes
biological integrity, fish
communities, fisheries and
the general public. Unfortunately,
the Great Lakes are in a position
where no compromise on this
issue is acceptable—the
basin integrity is “deteriorating
from an acceptable state”
(from the Environmental Protection
Agency and Environment Canada
report on the State of the
Lakes 2001), and invasive
species are the number one
cause of species change in
the Great Lakes (International
Joint Commission’s 11th
biennial report, page 29).
Invasion by Asian carp would
inflict significant modifications
to the ecosystem, and could
be catastrophic.
Great Lakes United will support
strong federal action taken
to control the introduction
and spread of invasive aquatic
species and exotics. The Fish
and Wildlife Service should
take immediate, aggressive
action to list and control
black carp under the federal
Lacey Act earlier than now..
Thank you for the opportunity
to comment on this critical
issue.
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