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Thank you Mr. Criswell At last some reasonable discourse on a topic that
is well overdue....I need a committe to help me develop this position
paper. A paper that would demonstrate reasonably and rationally why laws
should accomidate the collection of and aquarium rearing of native fish.I
would prefer an ecletic approach that includes Proffessionals, University
folks and lowley Amatures like myself. I will seek to get the support of
other associations(AFS, ASIH, ETC.) when I have a reasonable paper on
the table. SOOOOO any takers for a commitee approach?
--------- Begin forwarded message ----------
From: Robert Criswell <kcriswel at dns_tiu.k12.pa.us>
To: robertrice at juno_com
Subject: Position Paper
Date: Thu, 13 Mar 1997 23:08:00 -0500
Message-ID: <3328CF20.6CE7 at dns_tiu.k12.pa.us>
I was out of town for a few days and just returned, finding group email
correspondence concerning a NANFA position paper. I have a few
First, a brief introduction, since I have only been a member for several
years and not very active.
My regular position is as a Land Manager/Widlife Conservation Officer
with the Pa. Game Commission. In Pa. separate agencies are responsible
for what has been considered "wildlife", and fish (which is certainly
wildlife by almost any definition). I believe we're the only state left
in this position, and although its not a regular duty, I have authority
to enforce the laws of the Pa. Fish & Boat Comm., so I am fairly
familiar with them. I'm also a part-time outdoor writer, photographer,
and researcher. Although I conduct research on various groups of
animals and plants, primarily for the state's Natural Diversity
Inventory, I most enjoy the fish work I do for the conservancies and
projects for which I sometimes receive grants from our non-game tax &
license plate fund, called the Pa. Wild Resource Conservation Fund.
Most of my fish work is aimed at determining present status of T&E and
Special Concern species. I also enjoy keeping a few native tanks at
home. In addition, I was employed by the Pa. Fish Comm. (they recently
changed their name) in the late '70's & early 80's, so am quite familiar
with bureaucracy (not bragging here).
In regards to a position paper and the events and/or restrictions that
prompted its consideration, I think there are several issues that should
probably be addressed.
1) a position paper should be a generic statement of NANFA's goals,
intentions and desires at an international scale...this is where our
virtues should be sung and our general intentions (such as securing fair
regulation of non-game fish collecting & possession) stated, along with
our intentions to cooperate with government agencies toward positive
ends. This paper should be disseminated to the executive directors,
commissioners, and /or department chiefs, depending on the agencies'
type of organization. For example, the Pa. Fish & Boat Commission has
an executive director who oversees the operations of the agency, and a
board of citizen commissioners who oversee the agency, and must approve
by vote at regularly mandated meetings any changes in regulations or
policy. These people should receive the statement. I would not send
this paper to legislators at this juncture.
2) state-by-state evaluations should be conducted to determine if there
is a problem, its magnitude, and what course of action would be best for
its ultimate solution. As an example, Pa. isn't too bad. Minnows,
killifishes, madtoms, and darters, as well as suckers, chubs,fallfish,
lampreys, and eels under 8" are defined as "baitfish", and may be taken
with hook and line, minnow trap, or net no larger than 4'x4', with a
limit of 50 per day (combined species), with a general fishing license.
All others are considered "gamefish", with various restrictions such as
seasons, size, and gear limitations. Several species have slipped
through the cracks due to the default "gamefish" designation.
Noteworthy examples are sculpins, mudminnows, silversides, and
sticklebacks, for which there is no open season (probably not by
design), and bluespotted sunfish, which would have to be taken by hook &
line. There is certainly room for improvement.
3) where problems are identified that need a resolution, a member,
possibly as a liaison with that state, should determine a proper course
of action to affect a change, beginning with the agency, and make a
contact through phone call or letter, and escalate from that point if
and as necessary. It is not necessary to contact legislators first or
in all cases. In most states there are laws (promulgated by
legislators) and regulations (promulgated by agencies). It is
logistically much easier to change or add (or remove) a regulation than
a law. Where commissioners wield power, they are influential in the
rulemaking (regulations) arena and their support is essential. Using
politics (legislators) to get one's way and at the same time crying for
scientifically-based decisions and cooperative efforts often weakens
one's position or credibility, and if done successfully on a continual
basis, eventually dilutes the agency's ability to manage resources
objectively. Sometimes, of course, its the only option.
4) I would be reluctant to include a request for an aquarist/collector
permit in a blanket position statement. It will not be "simple" in many
states, and will probably carry tighter restrictions than the present
situation in many cases. This is certainly a viable option where it
becomes clear that relaxation of tight regulations is unlikely. I think
the organization needs to stress that these species are a renewable
resource that can be wisely utilized, just as gamefish are, and
emphasize our position on non-native introductions, bait bucket
releases, and interbasin transfers. I have a feeling that fears
concerning these events may be behind some of the seemingly unjustified
I do not have the time to develop a position statement, but I would
assist in reviews of and recommendations to a working draft. In
addition, if state-by-state reviews are in order, I would be willing to
begin some groundwork in Pa.
Thanks for your time & keep up the good work.
--------- End forwarded message ----------