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April 6, 2003 Deputy Commissioner Mark Holsten 500 Lafayette Road St. Paul MN 55155 Deputy Commissioner Holsten, I spoke with the committee administrator of the House Agriculture Policy committee. She informed me that the Minnesota Aquaculture Association has taken the position that aquaculture regulation should remain under the MN DNR. I do not support that position for farms like my own where the ponds are manmade, have no connection to public water and are out of the 100-year flood plain. I believe that the Board of Animal Health should regulate operations that use manmade ponds without connection to public waters. I think that is covered under Chapter 17 statutes already. There are only a handful of operations like mine in the state at this time so the burden to the Board should be manageable. I have had repeated conflicts with the division of Fisheries over the operation of my farm. Those conflicts were completely unnecessary and would not have happened if the regulatory agency were the Board of Animal Health in my opinion. My farm produces fish for bait, stocking, aquarium and food. Many of my fish are never released into public water. It’s my opinion that until my fish leave my property for stocking or bait in Minnesota waters the regulatory authority should be with the Board of Animal Health. It’s understandable, at least partly, that Fisheries would issue rulings that disrupt farms. After all, their mission is to protect the states fish communities and how those rulings affect farms is not a consideration. Virtually every fish farmer I’ve spoken with has told me of rulings that disrupted their operations with NO benefit to the environment. Many times the rulings were not supported by Minnesota statute but the farmer was afraid to protest. I believe that the same objective of protecting our fish populations could be reached even while considering the effect of the rulings on fish farms. This will only happen under the Board of Animal Health. I have seen examples disruptive rulings and policy positions of Fisheries that run counter to the stated objective of Fisheries. For example; a stated position of Fisheries is to reduce the mixing of fish “strains” yet Fisheries has policies that encourages fish farmers to purchase breeder fish from other watersheds and in some cases other states. It took 10 years and a change of statute to allow farmers to obtain local breeding stock. Another example of how the Fisheries disrupts aquaculture is the redundant licensing system. A farmer gets specific ponds approved for specific species yet when it comes time to stock those same ponds the farmer has to get permission a second time to stock fish into those ponds. This “makes” work for someone in Fisheries. It also makes extra unnecessary unpaid work for the private farmer and exposes the farmer to arbitrary rulings. Requiring my farm to get permission a second time to stock an approved species is what has led to my $10,300 claim against Fisheries. The very same person who approved my ponds for all species is the one who denied stocking of a species he approved. He claimed to be confused by the word “all”. Why should a farmer have to get permission a second time? The Fisheries seems to treat this like some kind of game where the goal is to keep the farmer off balance. Minnesota aquaculture has a huge potential but in order to reach that potential, aquaculture will need to move out of natural ponds and into manmade ponds under the Board of Animal Health. The benefits of using manmade ponds are many. Compared to fish production in natural ponds fish production in intensively managed manmade ponds is much more reliable, more labor efficient, provides better predator control and is more profitable. The quality of farmed baitfish is better and there are no additional species moved. Disease control is also more effective. Moving aquaculture to manmade ponds will reduce the spread of exotic species and allow the natural ponds to return to their original fish-free state. It will also stop the smuggling of golden shiners from Arkansas. I do not believe this will happen as long as manmade ponds are regulated by an agency whose only goal is to protect wild fish populations and seems to view private farmers as competition. I graduated with honor from the top aquaculture program in the U.S. so I think I have a fair idea of the potential of sustainable aquaculture in this state. Short of allowing farms like mine to move to the Board of Animal Health I would suggest the removal of Mr. Ron Payer, Mr. Steve Hirsch and Mr. Jack Wingate. Those three staffers have consistently created unnecessary problems for fish farmers in this state for years and they need to go. I have a $10,300 claim against Fisheries and at least one other farm also has a claim. Without question my claim is the direct result of actions of the top Fisheries office. It was completely unnecessary for that conflict to spiral out-of-control like it did. In fact it never should have become an issue in the first place. I gave Mr. Payer several opportunities to get his staff to stop violating my license but he did not. This claim is likely to be followed by more claims in the future as long as Fisheries has a policy of defending bad decisions at any cost. Thank you for your time. Sincerely, John Reynolds Midwest Fish and Crayfish 26385 County Road 3 Merrifield MN 56465
cc. DNR Commissioner Gene Merriam Governor Tim Pawlenty Representative Dale Walz Senator Paul Koering
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