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Re: Breeder's Club issues
Hi Dwight, all,
Thanks for the encouraging words, and I too am sorry for the confusion.
Just as you say, we have a lot of work ahead of us! I will email you
privately about some of the issues you listed later in the week.
Just to bring anyone interested up to speed on the status of shipping
shiners from Arkansas, I too found the section that you refer to in the
"Baitfish" part of the regs that prohibits the export of "minnows" taken
from "public waters". I have talked to the folks at AGFC, and sent in
another (more concise) cover letter explaining my goals to collect local
fish, raise them, and sell the offspring. I also sent my commercial
fishing license app, fish dealer app, and fish farmer app. Checks were
included, and I figured money involved might show my sincerity.
I heard last night from a Game Warden that called, saying he had to ok
the "pond" setup I would have for my "fish farm". I explained to him
that these fish would be raised in aquarium for the most part, and that
right now I have no pond established for them. After explaining the
situation that there is a growing demand for native fish for aquarist
nationwide, and internationally, and general issues concerning how to go
about selling or exporting fish from the state, we agreed that since
these are native fish they should be regulated by the code.
In the fish farmer regs, the aquarium use of fish is only covered under
a prohibition against non natives. Where non natives for "strictly
hobbyist aquarium trade" use are exempt from the prohibition, though may
not be raised to be used for any other purpose. He said the fish farm is
the way to go, much as game fish can only be sold from a fish farm here,
and none can be sold that are caught directly from the wild. Since these
fish are not game fish, and are not "commercial" fish that can be sold
directly from the wild, but fall into a gray area somewhere between, he
said he would ok the fish farm permit, and explain it to the other folks
involved. I assume the other folks are the fisheries people, who must
also ok the permit.
Although this may be the long way round, perhaps we can get there from
here. Just in case, as "plan B", please send what you have on Scientific
Collection Permits that you have been involved with. I'm quite sure my
personal experience will not be the only circuitous route a member has
to take to accomplish the desire to help the NFC and the fish.
Your help is greatly appreciated. I look forward to working with you.
Dwight Moody wrote:
> Had a chat with RR on Sunday evening about Breeder's Club issues. I
> didn't know that Robert had appointed you Breeder's Club Coordinator
> before I sent my posting, which was simply to get things started - I
> have a LOT to do in my other NFC capacities. Please accept my apologies
> for the confusion. I think you will make a great BPC and I am willing
> to help you in any way I can, especially on legal issues.
> I understand that you are aware that this job is going to involve a LOT
> of work. We have a whole bunch of state officials to convince that we
> are a legitimate organization and are doing things by the book. This
> requires research and discussions and developing a favorable track
> record. It might require that we get a whole stack of special permits.
> Lots of writing, record keeping and online meetings (along with helping
> the other breeders with their programs and keeping a running inventory
> of who has what available, who needs more equipment, cash flow,
> shipping, etc.).
> BTW, I called the Arkansas Game and Fish Commission and got a copy of
> their regulations. It seems that no baitfish, which includes minnows,
> shiners, etc., can be legally exported from the state of Arkansas. As I
> speak another language (state bureaucratese), this may mean a number of
> things implied by the language that is used in the regulation:
> 1. You CAN'T sell and/or export wild baitfish captured under a general
> fishing license; OR
> 2. You MAY be able to export wild baitfish if there is no money
> involved, just trading fish or donations; OR
> 3. You MAY be able to export wild baitfish if you obtain the necessary
> license(s) or permit(s); OR
> 4. You MAY be able to export domestically produced offspring of
> wild-caught baitfish but not their parents.
> Best idea I can offer is to write up a description of what it is you
> want to do, including alternatives (i.e., if I can't get a license to
> export wild caught shiners, can I breed them and legally export the
> offspring?) and ask for a ruling or determination on the issues
> involved. That way, you will get an official statement of what avenues
> may be available and what permits may be needed. Sure beats guessing,
> especially as there may be some provisions in Arkansas law that allow
> certain activities to be exempt from some or all of the regulations.
> Suggest that you might want to ask for a Scientific Collection Permit in
> your official capacity as NFC Breeder's Program Coordinator to attempt
> captive breeding of the bluenose shiner. You could state that you wish
> to evaluate methods of domestic propagation, which, if successful, will
> allow you to upgrade your project to a larger fish propagation facility.
> Part of the description would be the distribution of a portion of your
> captive breeding stock to other NFC breeders who would also attempt to
> breed these fish (like me, for instance). Distribution ensure that
> stock with the same genetics will continue to be available in the event
> of a catastrophe at your house, such as power failure, house fire, tank
> crash, etc. This is exactly what I did in the Scientific Collection
> permit application that I recently submitted to the Vermont officials (I
> expect approval for my proposed activities). Arkansas should have a
> similar program.
> I can send you a copy of what I put together for the VT officials if you
> want one to use for a working example. Just send me your snail mail