ACTION NEEDED IMMEDIATELY
(Part 3: Draft Letter)
WHAT CAN YOU DO?
1. COPY THE FOLLOWING LETTER OR DRAFT YOUR OWN AND SEND IT TO THE
FOLLOWING USFWS STAFF AND MEMBERS OF THE AQUATIC NUSCIENCE SPECIES TASK
FORCE:
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Dear Director Clark, USFWS Staff, and members of the ANS Task Force:
I am writing this letter in response to comment on the Injurious Wildlife;
Review of Information Concerning Black Carp (Mylopharyngodon piceus)
published in the Federal Register 2 June 2000. I urge you to use your
authority to list the exotic black carp as an injurious species under the
Lacey Act. As you have stated on your web page, the control and spread of
exotic species is one of the top priorities of the U.S. Fish & Wildlife
Service (http://www.fws.gov/prioinv.html). Exotic species introductions
are one of the most serious natural resource issues faced by the United
States today. The introduction of exotic species is costing the U.S.
taxpayer 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 damage annually. Freshwater
mollusks are the most endangered group of animals in North America.
Because black carp can grow quickly to a large size (3-4 feet in length)
and feed almost exclusively on mollusks, this exotic species has the
potential to adversely impact endangered mollusk populations and perhaps
drive some to extinction. In order to protect our nations endangered
molluscan fauna it is imperative that this species 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. The vast majority
of fisheries biologists in the states within the Mississippi River drainage
and throughout North America also want this species abolished. 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. In their report they concluded that
there was a high risk to aquatic resources if this species were to escape
and proliferate. I urge you to contact USFWS field staff, state fisheries
biologists, and others and solicit their opinions on this issue. By
working together we can help solve the problem faced by the catfish farmers
without using the black carp.
Another issue needs to be raised here. The use of genetically sterile or
triploid fish as a management tool or policy to prevent the spread of
exotic fish species has failed miserably. There are no demonstrated cases
where the use of triploids has prevented the eventual escape and
proliferation of exotic fishes. In fact, all of the other species of Asian
carp (silver, bighead, grass) 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 have documented up to 97% of
the fish collected were Asian Carp. These large numbers of exotic species
are undoubtedly producing significant negative impacts on the River's
native fish species. The use of triploid black carp is NOT a viable option
here. Genetically sterile fish can still consume large numbers of mollusks
throughout their lives.
The USFWS needs to do all that it can within its power to see that the
black carp does not proliferate as all of the other carp species have done.
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 help rid North America
of this exotic while there is still time.
Sincerely,
Kevin S. Cummings
Research Scientist
Illinois Natural History Survey
607 E. Peabody Drive
Champaign, IL 61820
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http://www.inhs.uiuc.edu/cbd/collections/mollusk.html
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