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Proposed Injurious Wildlife Species Listing

Comment Period (June 2 - August 1, 2000)

On 2 June 2000 the U.S. Fish and Wildlife Service (USFWS) initiated a
60-day review and comment period to gather information and public input
on the status of and concerns related to use of the Asian black carp
(Mylopharyngodon piceus) for fish culture or any other purpose in the
U.S. The species is presently proposed for widespread use in fish farm
ponds for the control of snails, the intermediate host of a trematode
parasite effecting catfish. Since the black carp's primary food is
freshwater mollusks, it poses a major threat to the freshwater mussel and
snail resources of the U.S. if allowed to escape to the wild and
establish reproducing populations. Experience has shown that such escape
is inevitable if the species is used outside of closely controlled and
monitored hatchery facilities. Farm fish ponds are not closely controlled
and monitored and are often located in bottomlands that are subject to
flooding. Thus a single flood event could permit their escape, and this
could lead to the ultimate destruction of many our nation's freshwater
snails and mussels. If the black carp is declared an injurious species of
wildlife, it will come under jurisdiction of the federal Lacey Act. This
will allow federal agents to inspect fish culture and pond facilities,
and confiscate and destroy any illegally held black carp stocks.

I ask your support in providing comments to the USFWS on this important
issue by August 1,2000. I think if you review this situation carefully
you too will agree that the black carp should be controlled under federal
regulations, rather than under the numerous and separate regulations of
individual states. The UMRCC supports the Mississippi Interstate
Cooperative Resource Association (MICRA) proposal to list the black carp
as an injurious species under the Lacey Act. UMRCC expressed this concern
in an April 11, 2000 letter to USFWS Director Jamie Clark. On the
opposite side of this flier is a draft letter to use in crafting your own
letter to the USFWS. If you have any questions, please contact the MICRA
at (309) 793-5811.

Kevin Szcodronski, UMRCC Chairman

Ms. Jamie Rappaport Clark, Director
U.S. Fish & Wildlife Service
Department of the Interior
1849 C Street, Room 3012
Washington, D.C. 20240

Dear Director Clark:

I am writing in response to the "Injurious Wildlife: Review of
Information Concerning Black Carp", published in the Federal Register on
2 June 2000. I urge you to use your authority to list the exotic black
carp as an injurious species of wildlife under jurisdiction of the Lacey
Act. Exotic species introductions such as black carp are one of the most
serious natural resource issues in the U.S. today. The spread of such
exotic species are costing taxpayers 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 damages annually.

Introduction of the black carp poses a serious risk to the nation's
freshwater mollusks - the most endangered group of animals in North
America. Black carp can grow quickly to large sizes (3-4 feet in length),
and because they feed almost exclusively on mollusks, this exotic species
not only has the potential to adversely impact endangered mollusk
populations, but to drive some mollusk species to extinction. In order to
protect our nation's endangered molluscan fauna it is imperative that
black carp 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. Additionally,
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. They concluded that
there was a high risk to aquatic resources if this species were to escape
and proliferate. I urge you to contact U.S. Fish & Wildlife Service
(USFWS) field staff, state fisheries biologists, and others to solicit
their expertise and opinions on this issue. By working together we can
help solve the trematode problem faced by the catfish farmers without
allowing the use the of black carp as the method of choice for control of
the trematode's snail hosts.

The issue of using so-called triploid or genetically sterile fish as a
management tool or policy to prevent the spread of black carp also raises
significant concern. This technique has been tried for other species, and
while some success has been shown in slowing down the spread of the
target species; there are no demonstrated cases where such use has
totally prevented the eventual escape of fertile individuals. In fact,
the other Asian carp species (silver, bighead, and grass), supposedly
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, for example, have documented up to 97% of the fish
collected as Asian carp. These large numbers of exotic species are
undoubtedly producing significant negative impacts on the River's native
fish fauna. The use of triploid black carp is NOT a viable option. Even
if the technique did work, escaped genetically sterile fish can still
consume large numbers of mollusks throughout their lives.

As USFWS Director you need to do everything within your power to see that
the black carp does not escape to the wild and proliferate as all of the
other Asian carp species have. 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 rid North America of this exotic fish while there
is still time.