Those of you who subscribe any of the several mollusk list servers with interests in conservation will almost certainly have heard that Black Carp are back in the news.  Kevin Cummings offered a nice summary of the present situation at the recent AMS business meeting in Charleston.

Briefly, in response to 2.5 years of public outcry*, the US Fish & Wildlife has finally posted a proposed rule to list Black Carp as “injurious” under the Lacey Act.  A PDF file of the Federal Register article requesting comments can be found at the FMCS web site:
http://ellipse.inhs.uiuc.edu/fmcs/

It is expected that fish farmers will bring substantial political pressure to bear in an effort to defeat this measure.  So all of us with interests in freshwater mollusk conservation are encouraged to write messages of support.  Comments can be sent via e-mail (see the proposed rule for addresses, etc.) but genuine letters will certainly have greater impact.  Especially helpful will be comments with scientific and/or economic data.  The public comment period extends until September 30.

Appended to this message you will find the text of a letter I wrote to the FWS on the letterhead of the American Malacological Society.  By all means, feel free to contribute your own.

And keep in touch,
Rob
 

*See our previous posts for background:
11Jan00.htm
25Apr01.htm
 
 

—[begin Black Carp letter 8/19]--------

Chief, Division of Environmental Quality
U.S. Fish and Wildlife Service
4401 North Fairfax Drive, Suite 322
Arlington, VA 22203

Re: RIN 1018-AG70

Dear Sir:

The American Malacological Society is a nonprofit organization of approximately 300 scientists, students, and serious amateurs dedicated to the study of mollusks.  We strongly support the listing of Black Carp as injurious under the Lacey Act.  We wish to comment specifically upon the section of your July 30 notice subtitled, “Factors that contribute to Injuriousness.”

It is true that many freshwater fish may prey upon mollusks under some circumstances.  A number of fishes native to North America are specifically mentioned in your July 30 notice in this regard (FR 67:49282).  However, Black Carp possess special adaptations for molluscivory (powerful jaws and pharyngeal teeth) and attain a great size (3 feet in length), making these fish much more dangerous to our native freshwater mollusk fauna than any predator heretofore introduced.  Should Black Carp become established in North American waters, our native freshwater mussels and snails would have little defense.

We strongly endorse the brief statements on page 49282 regarding the endangered status of our native freshwater mollusk fauna.  Approximately 60% of our 600 species of freshwater gastropods are at currently at risk (Global heritage ranks GH, G1-G3), as well as 67% of our 300 mussel species.  The federal list of endangered species includes 71 species of freshwater mussels and 20 freshwater gastropods.

Given the great potential danger posed by Black Carp to our native freshwater mollusk fauna, and given the presently imperiled status of that fauna, the American Malacological Society strongly supports the proposed rule to list Black Carp as “injurious” under the Lacey Act.  Any further importation of this fish to the waters of the United States is a risk we do not think our country ought to take.

Sincerely,
Dr. Robert T. Dillon, Jr.
President

—[end Black Carp letter 8/19]--------