Johannes ethics complaint MN DNR

 May 1, 2004

 Mr. John Guenther

Director of Fish and Wildlife

500 Lafayette Road

St. Paul MN 55155

  

Dear Mr. Guenther,

 I would like to file an ethics complaint against Mr. Roy Johannes for his unethical attempt to discourage me from adding turtles to my fish farm license. 

 In 2002 after hearing that turtle harvesting was under attack by the Fisheries division I requested that turtles be added to my fish farm license.

 When I received Mr. Johannes response I noticed that it contained the statement that the license would be conditional on complying with other state and federal agency requirements.  Mr. Johannes has no authority to require compliance with federal and non-DNR agencies.  My compliance with other state agencies is entirely between my farm and that agency.  The MN DNR has no business trying to encroach on their jurisdiction.

 Fisheries have never told me that my fish farm license was dependent on complying with another state or federal agency.  The agencies he listed are:

 1.         Food and Drug Administration (FDA).

2.         MN Pollution Control Agency (MPCA).

3.         MN Department of Health (MDH).

 Mr. Johannes continues to insist that I haven’t provided sufficient information and is using that as an excuse to avoid issuing the license.

 On April 22, 2002 Mr. Johannes requested the following information.

 “….we need you to send us more information about the waters you plan to use and what your commercial plans are for the turtles (i.e., farming, export, etc.).  Please include estimates of the expected size of your turtle farming activities, and the number and source of wild-caught individuals you expect to need per year to maintain your operation.  Please also include a site plan of your proposed facility, detailing measures for containing the turtles.”

 Here is the information I provided Mr. Johannes on June 3, 2002.

 “I will be raising turtles for food and export.  The turtles will be raised in man-made ponds surrounded by metal or fiberglass sheeting buried 12" and extending 16" above ground.  Turtle brood animals will be initially purchased from commercial turtle trappers.  The number of turtles raised will be 1 to 1,000,000.  The ponds will be those in Section 19 of Center township that are currently licensed and will also include future ponds at that site.”

 Mr. Johannes continues to claim in his 3-1-2004 email that information including a site map is missing.  A diagram (map) of my facility dated 12-31-2001 is in my file at the DNR office.  I believe that Mr. Tim Goeman is the person who drew the diagram.

 This is just one more example of how Mr. Johannes tries to use the “incomplete information provided” excuse to ignore M.S. 15.992.

 We are not required to report how many fish we intend on raising or the reason we are raising them.  Turtle farming should be no different.

 The bottom line is that this is nothing more than an attempt by Mr. Johannes to discourage me from raising turtles.  I have been told that I am not the only one to be subjected to his attempts to stop turtle farming.  I believe this type of behavior is unethical and unacceptable for a public employee.

 The deliberate attempt by the MN DNR Fisheries to discourage fish and turtle farming is the number one reason we do not have an aquaculture industry in Minnesota.  Too many people have been beaten down by the hostile anti-aquaculture attitude of the MN DNR Fisheries after risking enormous amounts of time and money.  It has to stop and the people responsible must be held accountable.

 Thank you for your time.

 Sincerely,

John Reynolds

Midwest Fish and Crayfish

26385 County Road 3

Merrifield MN 56465