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Thread: Ban On Koi Imports...Again

  1. #1
    Daihonmei MikeM's Avatar
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    Ban On Koi Imports...Again

    I was recently provided the following from the National Aquaculture Association. A new petition to ban all carp imports (which would include koi), as well as numerous other species was filed in September with the U.S. Fish & Wildlife Service. The NAA is encouraging its members to urge public opposition. Their cry is: "Don’t let this hobby slip away from you!! Stand up and be heard!!" I am not sure of the status currently, but this is an issue that does not go away.


    Nationally Important Aquatic Species Petitioned for Federal Regulation
    Issue

    The U.S. Fish and Wildlife Service (FWS) received a petition on September 23, 2016 to list 43 native and nonnative aquatic species as Injurious Wildlife under the authority granted by the Lacey Act. The petition includes the black acara, blue catfish, common carp (i.e., koi), grass carp, guppies, Jaguar guapote, three plecos (Amazon, Orinoco and vermiculated sailfin catfish), red swamp crawfish, and three tilapias (i.e., blue, Mozambique and Nile). Upon listing, these live animals and their gametes, viable eggs or hybrids may not be imported into the United States or transported interstate. The petition is predicated upon rapidly performed ecological risk screens, termed Ecological Risk Screening Summaries (ERSS), completed by the FWS and posted to a public website. Each species has been identified as “high risk” by the FWS.
    Action

    Growers, distributors, sellers, users, consumers or hobbyists that may oppose this petition should distribute this publication and become familiar with the ERSS reports and the Injurious Wildlife petitioning process. The FWS’s Injurious Wildlife listing process may take months to complete which will allow time to share information and prepare written comments. Information that will inform the FWS about these species includes:
    • The value, economic, ecological or aesthetic, of these species to your farm, business, hobby or the environment.
    • State or local regulations that govern culture, possession or sale and estimated regulatory costs.
    • The physical and practical methods that are implemented to prevent escape.
    • Observations or published papers that describe or assess whether the species and species hybrids pose a risk to the environment, humans or the economic interests of the United States.
    The FWS welcomes the public to provide informal input at this stage in the petition process; although, information provided at this time will not be part of a formal public review process or comment period. The FWS is processing the petition consistent with the agency's regulations found at 43 CFR part 14. When the FWS receives a petition from the public for Injurious Wildlife, they assess the petition and may find that no action is warranted, formally go out to the public with a Notice of Inquiry, or proceed with rulemaking for all or a portion of the petitioned species.

    Send comments to: [??Nothing listed.... perhaps FWS has not noticed for comment yet???}

    Send a copy of your comments to:

    Mr. Craig Martin, Chief National Aquaculture Association
    Branch of Aquatic Invasive Species PO Box 12759
    U.S. Fish and Wildlife Service Tallahassee, FL 32317-2759
    5275 Leesburg Pike Telephone: 850-216-2400
    Falls Church, VA 22041 Email: [email protected]
    Telephone: 703-358-1932
    Email: [email protected]

    Background
    The U.S. Fish and Wildlife Service and the Lacey Act
    The FWS is the primary federal agency for enforcement of the Lacey Act, a law designed to protect our nation’s wildlife resources. Within the Lacey Act is a provision for listing wildlife as injurious when they have been proven to be "injurious to human beings, to the interests of agriculture, horticulture, forestry, or to wildlife or wildlife resources of the United States." When first written in 1900 the list included 81 species – English sparrow, starling, mongoose or merkat (60 species), and fruit bat (19 species). Today the list includes 92 mammals, 6+ birds, 142 fish, 201 amphibians, 2 crustaceans, 1 mollusc, and 5 snakes. The recent addition of the 201 native and nonnative salamanders is the first instance where native species have been listed. For more information please visit: https://www.fws.gov/injuriouswildlife/index.html.

    Once a species is listed by the FWS as Injurious Wildlife, importation is forbidden into the United States and its territories except under strict permitting for scientific research or institutional exhibits. While currently under judicial scrutiny due to a legal challenge, Injurious Wildlife are also prohibited for interstate movement or trade. Therefore, once listed, there is essentially no commercial value of an Injurious Wildlife species and commercial or personal transport of Injurious Wildlife across state lines and importation is a federal crime. Due to this very serious impact, the process for listing species has been deliberate, based on science and a full assessment of the pros and cons of listing or not, especially when there was an impact to businesses in the United States. For more information, please visit: https://www.fws.gov/injuriouswildlif...tSheet2013.pdf.

    Listing Injurious Wildlife
    Concern has been repeatedly expressed by many involved in natural resource management that the amount of time it takes to list a species as Injurious Wildlife, often results in only listing species after they have become established as a population and caused environmental or economic damage. Notably, the Lacey Act does not establish a time frame for the FWS to reach a listing decision. As a result, some listings have occurred as a direct Congressional action, such as the 2012 listing of five large constrictor snakes, or through an interim rule proposed by FWS, such as the 2016 listing of 201 salamanders. A variety of interested and concerned scientists, regulatory agencies and the public have been advocating a focus on “pre-screening” species using less expensive and quicker screening processes. Others have sought an exemption from the need to assess the impact to private businesses that a listing may have.
    Ecological Risk Screening Summary
    For the past seven years, the FWS has been developing and utilizing a rapid screening tool, identified as an Ecological Risk Screening Summary (ERSS), to quickly evaluate a species potential for becoming invasive. In the ERSS reports for some 150 species, many of which are native species or commonly traded in the United States were posted on a federal webpage. Despite numerous comments and recommendations by the National Aquaculture Association to add a full disclaimer to the ERSS reports that says the findings are uncertain, may contain errors and should not serve as a basis for federal regulation, the webpage remains active and has gained significant attention.
    The FWS recently listed 11 nonnative aquatic species as Injurious Wildlife based primarily on these ERSS reports. These species are: crucian carp, Prussian carp, Eurasian minnow, roach, stone moroko, Nile perch, Amur sleeper, European perch, zander, wels catfish and the common yabby. The FWS has also
    stated that 2,000 ERSS reports have been drafted and that approximately 10% of the species analyzed have been identified as “high risk.” For more information, please visit: https://www.fws.gov/fisheries/ANS/species_erss.html.

    Center for Invasive Species Prevention (CISP)
    The Center for Invasive Species Prevention (CISP) publicly announced on September 30, 2016 that they had filed a petition with the FWS to declare 43 native and nonnative species as Injurious Wildlife. Their petition was based solely upon “high risk” ERSS reports produced and posted by the FWS. This petition includes native and nonnative species cultured, possessed or sold throughout the United States for food, water gardening, recreational fishing or biological control. These species, or their hybrids, are the black acara, blue catfish, common carp (i.e., koi), grass carp, guppies, Jaguar guapote, three plecos (Amazon, Orinoco and vermiculated sailfin catfish), red swamp crawfish, and three tilapias (i.e., blue, Mozambique and Nile). For more information, please visit: http://www.nivemnic.us/cisp-files-mu...per-lacey-act/.

    Injurious Wildlife Listing Process
    The FWS may begin an analysis to list a species, the public may petition for species to be listed as Injurious Wildlife or Congress may pass legislation to add a species to the Lacey Act. This process is illustrated in a diagram that can be accessed here: https://www.fws.gov/injuriouswildlif...sFlowChart.pdf.
    The FWS gathers information, or may request information from the public, via a Federal Register notice to evaluate these following factors that may contribute to a species being considered injurious, including:
    • Likelihood of release or escape.
    • Potential to survive, become established and spread.
    • Impacts on wildlife resources or ecosystems through hybridization and competition for food and habitats, habitat degradation and destruction, predation and pathogen transfer.
    • Impacts to threatened and endangered species and their habitats.
    • Impacts to human beings, forestry, horticulture and agriculture.
    • Wildlife or habitat damages that may occur from control measures.
    Second, the FWS evaluates factors that reduce the likelihood of the invasive species causing harm, including the:
    • Ability to prevent escape and establishment.
    • Potential to eradicate or manage established populations.
    • Ability to rehabilitate disturbed ecosystems.
    • Ability to prevent or control the spread of pathogens or parasites.
    • Any potential ecological benefits to introduction.

    Concerns with the Ecological Risk Screening Summary (ERSS)
    The National Aquaculture Association (NAA) and other groups have made repeated and concerted efforts to interact and communicate with the FWS on the implementation of the ERSS, biological and climate match errors and incomplete information within the reports. We have offered expert advice and a list of outside experts to review the reports, agreed to voluntarily cease trade in species that were determined a high risk and not in trade already, identified critical flaws in the ERSS rankings when discovered, and cautioned the FWS that posting the reports to a public webpage will trigger the public to, unquestioningly, accept the risk evaluations. Despite these efforts and comments, the FWS maintains the validity and value of the ERSS, declined stakeholder review, and refused to limit the publication of the results or to include a full disclaimer that they are based on a rapid screening tool and not an in-depth environmental risk analysis.

    Further Action by the National Aquaculture Association (NAA)
    The concerns of the NAA that ERSS “high risk” evaluations will be inappropriately applied to the United States by concerned citizens have been realized. The ERSS tool and reports are now being interpreted as a basis for regulation and final determination of invasiveness and injury to our nation and its resources. Going forward the NAA will be working to:
    • To provide science, economic and state regulatory information to the FWS so that they may find there is no basis to accept the CISP petition and any others that may be submitted based primarily on the ERSS reports or any other rapid screening process.
    • Stop the public posting of the ERSS reports that do not include: a full disclaimer of the uncertainties associated with quick risk screens, state regulatory and economic benefit information, and recognition that certain species appear to pose limited risk to certain locations within the United States, they do not pose a risk to the entire country.
    • Achieve a full review of the process taken by the FWS staff in selection of the 11 species recently listed, including a thorough disclosure of how comments were received and evaluated, especially those that raised concerns over listing these species.
    • A formal and independent review by subject matter experts of the 2,000 ERSS reports that have not yet been posted.
    Additional Information
    For additional information or to keep track of the petition, please call, write or email the National Aquaculture Association:

    Injurious Wildlife Petition
    National Aquaculture Association
    PO Box 12759
    Tallahassee, FL 32317
    Telephone: 850-216-2400
    Email: [email protected]

  2. #2
    MCA
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    And the responses from AKCA, AKJA, IPPCA and other organizations are ?

  3. #3
    Honmei ricshaw's Avatar
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    Quote Originally Posted by MCA View Post
    And the responses from AKCA, AKJA, IPPCA and other organizations are ?
    A "no response" is a comment.

  4. #4
    MCA
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    Agreed. If Shinkokai, AKCA and others do not give this public attention........

  5. #5
    Jumbo Akai-San's Avatar
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    Species like these give carp a BAD name....

    Weird Jumping Alien Asian Carp Invade the Illinois River. In the 1970's silver carp were accidentally introduced into the Illinois River after escaping from a fish farm. The fish mistake pressure waves from the propellors of the boat's motors for the movements of predators and jump with fright.

    https://www.youtube.com/watch?v=tLmJjRqXDCo

  6. #6
    Jumbo Akai-San's Avatar
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    If the US really gets serious about banning the importing of koi, it would be great for the proven local US koi breeders to try and step it up to produce quality koi. There must be several koi breeders in the US worth mentioning?

  7. #7
    Tosai
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    KOI are already illegal in Maine. A Federal ban on imports, and transportation across state lines, will most likely result in more states completely forbidding KOI ownership altogether.

  8. #8
    Administrator Brian's Avatar
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    Quote Originally Posted by Akai-San View Post
    If the US really gets serious about banning the importing of koi, it would be great for the proven local US koi breeders to try and step it up to produce quality koi. There must be several koi breeders in the US worth mentioning?

    That would indeed be great and we do in fact have many quality breeders in the US. That being said, the numbers are few and we're not really "pioneers" leading the way, but following the example from Japan at the moment. If imports were to cease, the relatively low number of quality breeders and the cutoff from new genetics in parent stock would lead to issues such as inbreeding. Even the top-tier breeders in Japan will add new blood into their already winning lines once in a while to avoid this problem.

    I seriously hope that this ban is a flash in the pan and doesn't pick up any steam. It's already taking much longer than usual to get my import license renewed this year for some reason and I hope this isn't why.
    Brian Sousa
    Koi-Bito Forum

  9. #9
    Honmei ricshaw's Avatar
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    Quote Originally Posted by Akai-San View Post
    If the US really gets serious about banning the importing of koi, it would be great for the proven local US koi breeders to try and step it up to produce quality koi. There must be several koi breeders in the US worth mentioning?
    IMO if the US gets really serious about banning imported Koi from Japan, there will also be a ban on transporting Koi across state lines. This would hurt local US Koi breeders. The Koi hobby in the US would turn into an outlaw hobby with home breeders producing Koi. The end of Koi keeping for many hobbyist. I am betting it won't happen.

  10. #10
    Daihonmei MikeM's Avatar
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    As of now, I have only seen a couple of FB postings of the announcement first posted above. The posts were made by just a couple of domestic breeders. To be effective, the industry needs to do two things: (1) mobilize all involved in the U.S. koi industry... breeders, dealers, equipment suppliers and hobbyists. This is not done with FB posts. It requires someone to make personal contacts and provide quick and easy means for views to be made known to the proper decision makers. (2) A science-based case has to be prepared demonstrating that such a ban is not needed/effective, which may well be a matter of showing the horses are already out of the barn so it does no good to close the door. The few watersheds where carp are not already present are do not outweigh the adverse economic impacts, particularly given the likelihood of carp spreading without regard to an import ban on koi. Such an effort requires financial support and substantial time to be invested, which generally means a couple of paid staff devoted to the project. ...The koi industry in the U.S. is filled with individualists who have not shown much inclination toward cooperative group efforts. A ban could make their mutual interests clear and serve to energize a cooperative effort, but it would come too late if a ban occurs first. It is always easier to prevent government from acting than to get a change in position.

    Hobbyists can play a real role, but only if the numerous clubs and non-club hobbyists are organized. A hundred comments means little. Thousands of comments in opposition can carry weight, when combined with well articulated reasons that a ban is not the way to go.

    So, who in the industry will take the lead?

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