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E-M:/ GLIN==> Encourage the Fish and Wildlife Service to List Asian Carp as Injurious

Subject: GLIN==> Encourage the Fish and Wildlife Service to List Asian Carp as Injurious

At its meeting in Duluth, MN earlier this month, the Great Lakes Commission adopted a resolution calling on the U.S. Fish and Wildlife Service to add Asian carp to the list of injurious species under the Lacey Act. As you may know, the U.S. Fish and Wildlife published a Federal Register notice inviting comments on a proposal to list the Asian silver and largescale silver carp as injurious species.

The Great Lakes Commission urges you to submit comments in support of the proposed listing. The deadline for submitting comments is November 6, 2006.

In its resolution, the Commission recognizes the severe environmental and economic threat Asian carp pose to the Great Lakes, if they are introduced in the region. The resolution supports the Fish and Wildlife Service proposal to list the carp as injurious because it will help prevent an accidental or intentional release of the carp in the Great Lakes by making it illegal to import the carp or transport them across states lines.

Attached is a copy of the resolution which contains information that may be helpful to you in preparing your comments. Also attached is a memo prepared by a Commission fellow (Erika Jensen) with useful background on the Lacey Act. Should you desire additional background information you may also visit the Fish and Wildlife Services web site, which includes the Federal Register notice. http://www.fws.gov/contaminants/Issues/InvasiveSpecies.cfm

The address for submitting comments is:
Chief, Branch of Invasive Species, U.S. Fish and Wildlife Service, 4401 North Fairfax Drive, Suite 322, Arlington, Virginia  22203 RE: RIN Number 1018-AT29

Comments may also be submitted by email to: silvercarp@fws.gov. Include "RIN Number 1018-AT29" in the subject line.

You might also note that the resolution calls on Congress to list the carp as injurious via legislation. Bills have been introduced in both chambers (HR. 3049 and S. 1402), which would accomplish this. We support this action as well, as it would be an alternative means of getting carp added to the list.

Thank you for your help presenting a compelling case to the US Fish and Wildlife Service that this dangerous species should be restricted. Should you desire additional information please do not hesitate to contact me or Kathe Glassner-Shwayder at 734-971-9135.

Tim Eder, Exec Director
Great Lakes Commission
2805 So Industrial Hwy, Suite 100
Ann Arbor, MI 48104
734-971-9135 ext 101

Great Lakes Commission Support for
Lacey Act Listing of the
Silver, Largescale Silver, Bighead and Black Carp As Injurious Species
species of Asian carp have been widely introduced from their native ranges of China and other Asian countries to the United States, for beneficial uses such as water quality improvement, removal of aquatic plants and animals or to improve fishery production; and
Whereas, species of priority concern including the silver, black and bighead carp, initially confined in the United States to aquaculture facilities in the lower Mississippi River, have escaped in the early 1990?s during periods of high precipitation and flooding; and
Whereas, the escape of these invasive fish species from confinement have allowed for self-sustaining reproducing populations to migrate through the Upper Mississippi and Illinois River systems with the potential to invade the Great Lakes given their close proximity to the Great Lakes with 22 rivers flowing into the lakes with suitable spawning habitat; and
Whereas, Asian carp threaten native fish and wildlife, including rare and endangered species, because of their rapid reproduction and growth patterns; opportunistic feeding habits in consuming primarily phytoplankton, as well as zooplankton, bacteria and detritus; and  ability to degrade habitat through increased sediment suspension; and
Whereas, silver carp inhabiting the Mississippi and Illinois River systems cause substantial impacts to the health and welfare of human beings using these infested waterways primarily by their jumping habits in the vicinity of moving watercraft, causing injuries that include cuts from fins, black eyes, broken bones, back injuries and concussions; and
Whereas, populations of the silver and largescale silver carp, if introduced, are nearly impossible to control and ultimately eradicate, both technically and financially; and
Whereas, the U.S. Fish & Wildlife Service proposed a rule in September 2006 to list all forms of live silver carp (Hypophthalmichthys molitrix) and all forms of live largescale silver carp (Hypophthalmichthys harmandi) as injurious wildlife species under the Lacey Act (18 U.S.C. 32); and
this proposed ruling is expected to have a minimal economic impact given the low commercial value of silver carp species which are not favored by commercial fishers due to their jumping behavior and are generally considered undesirable by consumers and sport fishers due to their unpalatibility; and
Whereas, the best available information indicates that this ruling is necessary to protect public health and safety, water quality, fish and wildlife and associated habitat from the purposeful or accidental introduction and subsequent establishment of silver carp and largescale silver carp populations in ecosystems of the United States; and
Whereas, listing the silver carp and largescale silver carp as injurious under the Lacey Act would prohibit their importation and interstate transport unless permitted in certain exceptions or if the species is not living; and
Whereas, no final action has been taken on a proposal by the Fish and Wildlife Service in 2002 to list the black, bighead and silver carp as injurious species under the Lacey Act;
Therefore, Be It Resolved, that the Great Lakes Commission supports the U.S. Fish and Wildlife Service proposal, or action by Congress, to list the silver carp and largescale silver carp as injurious species under the Lacey Act; and
Be It Further Resolved, that the Great Lakes Commission encourages its member states to support the proposed Lacey Act listing of the silver carp and largescale silver carp in addition to supporting regulation of these species on a state specific basis; and
Be It Finally Resolved
, that the Great Lakes Commission urges the U.S. Fish and Wildlife Service to finalize the 2002 proposal to add the bighead carp (Hypophthalmichthys nobilis)and black carp (Hypophthalmichthys piceus) to the list of injurious wildlife under the Lacey Act and advises its member states to also support the expanded listing.



Alex J. Sagady & Associates        http://www.sagady.com

Environmental Enforcement, Permit/Technical Review, Public Policy,
Expert Witness Review and Litigation Investigation on Air, Water and
Waste/Community Environmental and Resource Protection
Prospectus at:  http://www.sagady.com/sagady.pdf

657 Spartan Ave,  East Lansing, MI  48823 
(517) 332-6971; (517) 332-8987 (fax); ajs@sagady.com