As President of the Nation’s Capitol Bass Federation (NCBF), I am responding to the Fish and Wildlife Service proposed rule to add all forms of live black carp to the list of injurious fish under the Lacey Act (Fed. Register/Vol. 70, No.207/Thursday, October 27, 2005).
The NCBF has reviewed the revised August 2005 “Draft Environmental Assessment for Listing Black Carp (Mylopharyngodon piceus) as Injurious under the Lacey Act”. Based upon this Assessment, and our broader concern about the adverse affects of invasive aquatic species, the NCBF goes on record in support of Alternative 2 of the Draft Environmental Assessment. The NCBF is of the opinion that prohibiting the import and interstate transportation of both diploid and triploid live black carp gametes and eggs is in the best economic and environmental interest of the Country.
The beneficial consequences of Alternative 2 are well documented in the Draft Environmental Assessment. Our support for Alternative 2 stems from the following concerns with the continued free use and transport of black carp.
1) Black carp exist over wide latitude in East Asia, indicating a clear potential for widespread adaptation across the conterminous U.S.
2) Black carp not only pose a direct threat to freshwater mussels and snails, many of which are listed as threatened or endangered, but a significant indirect threat to a variety of aquatic and terrestrial animals dependent on these mollusks.
3) The sterility of Triploid fish used for the control of snails in commercial catfish farms cannot be guaranteed as evidenced by existing research.
4) There is no guarantee that black carp used by fish farmers for snail control will not escape as a result of mechanical dam failure, flooding, theft or during transport. Black carp have escaped in Missouri and have been documented in Louisiana and Illinois public waters.
5) Chemical control of snail infestations in commercial catfish ponds is a viable option.
6) Adverse consequences from other invasive carp species are well documented. Escape and establishment of wild, free roaming black carp populations only fuels the flames of the invasive species wildfire for which the carp family is so well known.
7) Any potential economic hardship to a small segment of the commercial catfish farming industry will be far outweighed by the economic savings to a much larger segment of the public.
Impacts to sport fishing and associated recreation, economic losses and the environmental consequences from past invasions of carp and other non-native aquatic species should warn us of the need to stop black carp from adding insult to injury. We sincerely hope that the Fish and Wildlife Service takes appropriate action and adopt Alternative 2.
Thank you for the opportunity to comment and your consideration of our perspective.
Chuck Walker
President, Nation’s Capitol Bass Federation
Ncbfchuckwalker@earthlink.com