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March 20, 2001 DNR Commissioner Allen Garber 500 Layfayette Road St. Paul MN 55155-4012 Dear Commissioner Garber, I believe you are a fair man and will be just as outraged as I am by the unethical behavior of the fisheries division and the way DNR staff is deliberately misleading the legislature about the dangers of allowing the regulated use of triploid grass carp. The fisheries division has been deliberately attempting to mislead the legislature in an attempt to kill bills HF 834/SF 718 introduced by my legislators, before the committee has a chance to make a decision based on the facts. I understand the accusation of deliberate misleading is serious but the DNR is or should be in possession of information that contradicts much of the DNR testimony given on March 15, 2001 to the committee and during further contacts made by the fisheries division with legislators. Below are the misrepresentations that I am aware of: 1. Testing for triploid grass carp has a 2.5% error rate. The method is 100% accurate. The USFWS will certify individual fish. I offered to supply the USFWS protocol that allows individual certification to the fisheries division last fall but did not receive the courtesy of a reply. I also offered to have the fish certified for a third time by flow cytometry, which is also an ironclad method of determining ploidy but did not receive the courtesy of a reply. 2. High likelihood that Asian tapeworm would be spread throughout the state. Prazinquantel is 100% effective at eliminating Asian tapeworm. Many states require a prophylactic treatment of grass carp before shipping. Farms are routinely certified to be tapeworm free. Many millions of golden shiners have been smuggled into the state and they are also carriers of Asian tapeworms. It is legal to import fish from farms that also raise grass carp so it is also possible that those fish can be carriers of Asian tapeworms. I supplied this information to the fisheries division in my letter last fall but did not receive the courtesy of a reply. 3. If permitted, it is only a matter of time until grass carp are reproducing in the state. Triploid (sterile) grass carp do not reproduce. After two years of reviewing the scientific literature and speaking to many of the authors of key papers I could not find any evidence that triploids were capable of reproducing with triploids. In order for reproduction to become established a male and female diploid must make it through two rounds of rigorous testing, escape the fairly rigorous security measures of a fish farm described in the bills, find each other, find the highly specific conditions suitable for triggering spawning behavior, spawn in a stretch of river at least 36 miles long that meets the highly specific conditions needed for hatching, the fry must then survive long enough to reproduce and find each other in order for a viable reproducing population to become established. The reproducing populations existing in other states are obviously the result of diploid stocking, some of which was done by state agencies. There is no evidence of reproduction in any watershed that requires grass carp to be triploid. The state of Florida stocked 100,000 triploid grass carp in a single project and there is no evidence of reproduction. If a spawning population were to become established in Minnesota and I sincerely hope not, it will likely come from diploid grass carp smuggled into the state since diploids do not require the strict documentation required of triploid grass carp. 4. A blood test on each fish is required to test for triploid. Not 100% accurate. The test is 100% accurate. Flow cytometry is also 100% accurate in determining ploidy (sterility). The only error comes in from human error and a non-sterile fish would have to accidentally make it through two rounds of testing. I offered to have each fish tested a third time using flow cytometry but did not receive the courtesy of a reply. 5. Grass carp (Ctenopharyngodon idella) were designated as prohibited in 1995 via the public rulemaking process (Minn. Rule 6216.0250). No opposing comments were received. The reason I did not submit a comment is because I believed then as I do now that it is futile to communicate with the fisheries division. Most of my sincere questions on this matter to the fisheries division have not received the courtesy of a reply. Waterfowl production could be curtailed and fish populations could be reduced because of reduced aquatic vegetation. This is an unfounded scare tactic. Arkansas is the leading producer of triploid grass carp and is known as the “Duck Capitol of the World”. Triploid grass carp cannot reproduce and are therefore unable to reach a number sufficient to impact aquatic vegetation. My farm needs 30 fish to stop using aquatic herbicides. A small Minnesota lake would take many thousands of fish to severely reduce the aquatic vegetation. Sincerely, John Reynolds Midwest Fish and Crayfish 26385 County Road 3 Merrifield MN 56465 (218) 765-3030 Cc: Assistant Commissioner Brad Moore Senator Don Samuelson Representative Dale Walz Representative Dennis Ozment Senator Jane Krentz Representative Kathy Tingelstad Senator David Tomassoni Representative Jean Wagenius Senator Pat Pariseau Representative George Cassell Senator Ellen Anderson Representative Tim Finseth Senator Charles Berg Representative Bill Haas Senator Steve Dille Representative Tom Hackbarth Senator Dennis Frederickson Representative Mark Holsten Senator Linda Higgins Representative Larry Howes Senator Tony Kinkel Representative Bud Nornes Senator David Knutson Representative Howard Swenson Senator Bob Lessard Representative Ray Vandeveer Senator Gen Olson Representative Tom Workman Senator Lawrence Pogemiller Representative Thomas Bakk Senator Leonard Price Representative Alice Hausman Senator Twyla Ring Representative Loren Jennings Senator Dan Stevens Representative Ruth Johnson Senator LeRoy Stumpf Representative Tom Osthoff Senator Jim Vickerman Representative Margaret Anderson Kelliher Representative Doug Peterson Representative Rod Skoe Representative Scott Wasiluk |