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NFC: Fw: Black Carp


(3 parts: Introduction, Federal Register Notice, Response Letter)

Introduction to the Problem

</fontfamily></bold><fontfamily><param>Geneva</param>This message is a
call for action to try and prevent the spread of the exotic black carp
throughout North America. The black carp is a large (up to a meter in
length) mollusc-eating fish that has been imported from Asia into North
America (Arkansas and other states) by the aquaculture industry.  Black
carp were first introduced into the U.S. in the early 1970s as a
"contaminant" in imported grass carp stocks.  The second introduction
came in the 1980s when the species was imported as a food fish, and as
a biological control agent to combat the spread of yellow grubs in
aquaculture ponds.  The Freshwater Mollusk Conservation Society,
American Fisheries Society, and other organizations have called for the
elimination of all black carp stocks in North America.  

Four other Asian carp species (common, grass, bighead, and silver
carps) have been introduced into U.S. waters, and all have been able to
establish themselves in the wild, producing large populations.  The
large numbers of Asian carp that presently occur in certain parts of
the Mississippi River Basin undoubtedly are producing significant
negative impacts on native fish species. However, the black carp poses
an even greater threat to native invertebrate populations because it
feeds almost exclusively on mollusks.  As most of you are aware, the
southeastern United States has the most diverse freshwater molluscan
fauna in the hemisphere and perhaps the world.  Freshwater mollusks are
the most endangered group of animals in North America, with over 70% of
our native mollusk species in need of conservation.

Last fall the Mississippi Interstate Cooperative Resource Association
(MICRA) learned that the state of Mississippi had decided to allow
catfish fish farmers to import reproductively viable (diploid) black
carp from Arkansas to control snail populations in their catfish ponds.
 This raised a significant "red flag" with other Mississippi River
Basin states.  First, because of the great potential of black carp to
proliferate in the wild and also because other methods of grub control
utilizing native fish species are available and have been used
successfully in other states.

The Freshwater Mollusk Conservation Society, MICRA, and others sent
letters to the governors of Mississippi and Arkansas asking that all
black carp presently stocked in Mississippi be recovered and destroyed,
or kept in closely controlled, laboratory-like environments which could
guarantee that escape to the wild would be prevented.  Copies of three
MICRA letters on this subject can be downloaded in .pdf format from
MICRA at http://wwwaux.cerc.cr.usgs.gov/MICRA (simply scroll down the
table of contents).  MICRA also expressed interest in assisting
Mississippi, or any other state or federal agency, by providing
resources and expertise, and experience using native species or other
measures as alternatives to black carp in treating the grub problem. 

On 24 February 2000 MICRA petitioned Jamie Rappaport Clark, Director of
the U.S. Fish & Wildlife Service (USFWS), to list the black carp
(<italic>Mylopharyngodon piceus</italic>) as an "injurious species of
wildlife" coming under jurisdiction of the Federal Lacey Act.  The
Lacey Act prohibits the import and/or possession of any species listed
as "injurious" without a Federal permit.  MICRA expressed concerns
that: (1) diploid (fertile) black carp are being used in the state of
Mississippi as a control agent for snail populations in fish culture
ponds, (2) the potential for the escape of these black carp to the wild
is high, and (3) the nation's mollusk populations (many of which are
threatened or endangered) could be devastated should the black carp
escape from captivity and establish wild populations.

Of even greater concern is the fact that 90% (191 species) of the
native mussel species designated as endangered, threatened, or of
special concern are found in the Southeastern states - not far from
where the black carp are being stocked.  Forty-eight percent or 102 of
these species are endemic to that region of the U.S., and the black
carp have the potential of driving some of these species to extinction.
 Black carp also could have a profound negative effect on native
fingernail clam populations which serve as a primary food source for
many migratory waterfowl species in the Mississippi flyway and

There is ample biological evidence to justify preventing black carp
from being used anywhere in the U.S. for any purpose.  However, the
final decision on this matter, and therefore on the ultimate fate of
our native mollusk fauna will be made by the USFWS.  Those who support
the use of black carp are busy lobbying their Congressmen and USFWS to
protect their perceived right to continue that use.  Those who oppose
the use of black carp will have to do the same.  I am urging you to
contact the individuals listed below the Fed Register Notice and ask
them to exercise their power to list the black carp as an "injurious
species of wildlife" under the jurisdiction of the Federal Lacey Act. 

For Additional information see: 


Below is a copy of the notice in the Federal Register and below that is
a letter that you can send (or draft your own) to voice your concern on
this issue. (<bold>SEE BELOW</bold>).  All comments must be received by
1 August 2000.


[<bold>Federal Register</bold>: June 2, 2000 (Volume 65, Number 107)]

[Proposed Rules] [Page 35314-35315]

>From the Federal Register Online via GPO Access [wais.access.gpo.gov]




Fish and Wildlife Service

50 CFR Part 16

Injurious Wildlife; Review of Information Concerning Black Carp
(Mylopharyngodon piceus)

AGENCY: Fish and Wildlife Service, Interior.

ACTION: Advance notice of proposed rulemaking.


SUMMARY: The U.S. Fish and Wildlife Service is reviewing available
economic and biological information on the black carp (Mylopharyngodon
piceus) for possible addition to the list of injurious wildlife under
the Lacey Act. The importation and introduction of M. piceus into the
natural ecosystem of the United States may pose a threat to native
mollusk and fish populations. Listing M. piceus as injurious would
prohibit its importation into, or transportation between, the
continental United States, the District of Columbia, Hawaii, the
Commonwealth of Puerto Rico, or any territory or possession of the
United States, with limited exceptions. This notice seeks comments from
the public to aid in determining if a proposed rule is warranted.

DATES: Comments must be submitted on or before August 1, 2000.

ADDRESSES: Comments may be mailed or sent by fax to the Chief, Division
of Fish and Wildlife Management Assistance, U.S. Fish and Wildlife
Service, 1849 C Street, NW, Mail Stop 840 ARLSQ, Washington, DC 20240,
of FAX (703) 358-2044.  e-mail susan_mangin at fws_gov

FOR FURTHER INFORMATION CONTACT: Susan Mangin, Division of Fish and
Wildlife Management Assistance at (703) 358-1718.

SUPPLEMENTARY INFORMATION: In a February 24, 2000, letter to the
Director of the U.S. Fish and Wildlife Service, the Mississippi
Interstate Cooperative Resource Association (MICRA) expressed concern
that Mylopharyngodon piceus posed a threat to native fish and mollusk
populations. MICRA requested that the Director take the necessary steps
to list M. piceus as an injurious species of wildlife.

M. piceus is a freshwater fish that inhabits lakes and lower reaches of
rivers. It is native to most major Pacific drainages of eastern Asia
and highly esteemed as a food fish in China. M. piceus was introduced
into the United States in the early 1970s as a ``contaminant'' in
imported grass carp stocks. A second introduction occurred in the 1980s
for yellow grub control and as a food fish. M. piceus larvae and
fingerlings feed on zooplankton, while larger M. piceus feed on benthic
organisms with shells. Because the species commonly feeds on mollusks,
M. piceus is considered an effective method of biological control of
snails. M. piceus spawn in rivers, and their eggs are pelagic or
semipelagic and drift downstream. They are annual spawners, with
spawning triggered by water temperature, rising water levels, and
availability of food. Research has indicated that pond-cultured females
can produce an average of 65,000 eggs per kg (29,000 per lb.) of body

The Lacey Act (18 U.S.C. 42) and implementing regulation in 50 CFR part
16 restrict the importation into or the transportation of live wildlife
or eggs thereof between the continental United States, the District of
Columbia, Hawaii, the Commonwealth of Puerto Rico, or any territory or
possession of the United States of any nonindigenous 

species of wildlife determined to be injurious or potentially injurious
to certain interests, including those of agriculture, horticulture,
forestry, the health and welfare of human beings, and the welfare and
survival of wildlife and wildlife resources in the United States.
However, injurious wildlife may be imported by permit for zoological,
educational, medical, or scientific purposes in accordance with permit
regulations at 50 CFR 16.22, or by Federal agencies without a permit
solely for their own use. If the process initiated by this notice
results in the addition of M. piceus to the list of injurious wildlife
contained in 50 CFR part 16, their importation into the United States
would be prohibited except under the conditions, and for the purposes,
described above.

This notice solicits economic, biologic, or other information
concerning M. piceus. The information will be used to determine if the
species is a threat, or potential threat, to those interests of the
United States delineated above, and thus warrants addition to the list
of injurious wildlife in 50 CFR 16.13. The information will also assist
us in preparing impact analyses and examining alternative protective
measures under the Regulatory Flexibility Act (5 U.S.C. 601).

Authority: This notice is issued under the authority of the 

Lacey Act (18 U.S.C. 42).

Dated: May 16, 2000.

Jamie Rappaport-Clark,

Director, U.S. Fish and Wildlife Service.

[FR Doc. <bold>00</bold>-<bold>13557 Filed</bold> 6-1-<bold>00</bold>;
8:45 am]




Susan_Mangin at fws_gov, Jamie_Clark at fws_gov, Nancy_Gloman at fws_gov,
a_gordon_brown at ios_doi.gov, Hannibal_Bolton at fws_gov,
Kari_Duncan at fws_gov, Sandra_Kepner at fws_gov, Denny_Lassuy at fws_gov,
Bob_Pitman at fws_gov, Linda_Drees at fws_gov, Pam_Thiel at fws_gov,
Gary_Sonnevil at fws_gov, Pat_Carter at fws_gov, cathleen_short at fws_gov,
Sally.J.Yozell at noaa_gov, snewsham at comdt_uscg.mil,
wes.smtp.therioe at ex1_wes.army.mil, redford.david at epa_gov,
Bill.S.Wallace at usda_gov, Sally.L.McCammon at usda_gov, blumberg at state_gov,
moserfc at state_gov, kahabka.j at nypa_gov, jdekam at concentric_net,
harding.russell at deq_state.or.us, mdonahue at glc_org,
gary.isbell at dnr_state.oh.us, ldunn at pda005_pda.state.pa.us,
cotfma at northernway_net, nkmiecik at win_bright.net,
mikeh at dec_anr.state.vt.us, judith.freeman at noaa_gov,
breeves at mail_state.tn.us, rlukens at gsmfc_org, sharon_gross at fws_gov

Dear Director Clark, USFWS Staff, and members of the ANS Task Force:

I am writing this letter in response to comment on the Injurious
Wildlife; Review of Information Concerning Black Carp
(<italic>Mylopharyngodon piceus</italic>) published in the Federal
Register 2 June 2000.  I urge you to use your authority to list the
exotic black carp as an injurious species under the Lacey Act.  As you
have stated on your web page, the control and spread of exotic species
is one of the top priorities of the U.S. Fish & Wildlife Service
(http://www.fws.gov/prioinv.html).  Exotic species introductions are
one of the most serious natural resource issues faced by the United
States today.  The introduction of exotic species is costing the U.S.
taxpayer billions of dollars each year.  The zebra mussel alone costs
U.S. industries approximately $3 billion a year and, a recent study
presented at the American Association for the Advancement of Science
estimated that non-native species cause $123 billion in damage
annually.  Freshwater mollusks are the most endangered group of animals
in North America.  Because black carp can grow quickly to a large size
(3-4 feet in length) and feed almost exclusively on mollusks, this
exotic species has the potential to adversely impact endangered mollusk
populations and perhaps drive some to extinction.  In order to protect
our nations endangered molluscan fauna it is imperative that this
species be listed as injurious and eliminated from North America.  

The Freshwater Mollusk Conservation Society, Mississippi Interstate
Cooperative Resource Association, American Fisheries Society (the
nations largest society of fisheries professionals) and others have
called for the elimination of all black carp stocks in North America. 
The vast majority of fisheries biologists in the states within the
Mississippi River drainage and throughout North America also want this
species abolished.  Scientists at the USGS/Biological Resources Science
Center in Gainesville Florida have developed and published a detailed
risk assessment on the black carp's potential for harm to the
environment.  In their report they concluded that there was a high risk
to aquatic resources if this species were to escape and proliferate.  I
urge you to contact USFWS field staff, state fisheries biologists, and
others and solicit their opinions on this issue.  By working together
we can help solve the problem faced by the catfish farmers without
using the black carp.

Another issue needs to be raised here.  The use of genetically sterile
or triploid fish as a management tool or policy to prevent the spread
of exotic fish species has failed miserably.  There are no demonstrated
cases where the use of triploids has prevented the eventual escape and
proliferation of exotic fishes.  In fact, all of the other species of
Asian carp (silver, bighead, grass) under theoretical control by using
triploids have escaped into U.S. waters, and all have been able to
establish themselves and reproduce in the wild.  Recent fish kill
investigations in backwater pools of the upper Mississippi River have
documented up to 97% of the fish collected were Asian Carp.  These
large numbers of exotic species are undoubtedly producing significant
negative impacts on the River's native fish species.  The use of
triploid black carp is NOT a viable option here.  Genetically sterile
fish can still consume large numbers of mollusks throughout their

The USFWS needs to do all that it can within its power to see that the
black carp does not proliferate as all of the other carp species have
done.  The choice on this issue is clear.  If protecting the nations
endangered aquatic resources and helping to control the spread of
exotic species is a priority of the USFWS, then I urge you to act now
to help rid North America of this exotic while there is still time.  

Sincerely, </fontfamily>

Kevin S. Cummings

Research Scientist

Illinois Natural History Survey

607 E. Peabody Drive

Champaign, IL 61820

ksc at inhs_uiuc.edu



Lawrence M. Page, INHS Principal Scientist  	

l-page1 at uiuc_edu

Illinois Natural History Survey

607 E. Peabody Drive

Champaign, IL  61820

Phone:  (217)-244-2104

FAX:  (217)-333-4949