We are aware that longear sunfish are present in the Whitefish Chain.  However, their presence does not mean that this species is indigenous.  In fact, longear sunfish were not documented in the Whitefish Chain prior to 1990 (Northern Fishes, Eddy and Underhill 1974; Fishes of the Minnesota Region, Phillips, Schmid, and Underhill 1982; DNR lake surveys), and are not known to be naturally occurring in this part of the state.  In addition, their limited distribution pattern would indicate that they are present due to an unofficial introduction.  Our determination that longear sunfish are not indigenous to the watershed you are operating in is consistent with the statutory definition:

MS 17.4982 Subd. 18a.  "Nonindigenous species" means a species of fish or other aquatic life that is (1) not known to have been historically present in the state; (2) not known to be naturally occurring in a particular part of the state; *.

We conducted a survey of the Pine River in 2001 and did not collect longear sunfish.  As a result, we are unable to verify that they are present there and have access to the Mississippi River.

You are correct that we have approved importation of longear sunfish in the past, but that approval was intended to be only for ponds licensed for non-indigenous species.  We would not approve unrestricted importation and stocking of this species, given its limited distribution in the state and the strong likelihood that it was not native to Minnesota.

Based on the above information, our decision to limit your importation of longear sunfish to licensed waters approved for non-indigenous species stands.

The other points in your letter have been addressed in previous correspondence.  I would add that we support Mr. Goeman's decisions regarding licensing and permits related to your operation.  We continue to try to do the best we can to work with you and provide sound management of our resources.  It would seem that many of your concerns with regards to non-indigenous species would be addressed with the completion of the filter barrier you agreed to install at the December 2001 meeting.  Is there a particular impediment to the completion of the barrier that we could assist in overcoming?

Ronald D. Payer, Director

Division of Fisheries

MN DNR

500 Lafayette Road

St. Paul, MN  55155-4012

Phone:  (651) 297-4098

Fax:       (651) 297-4916

"John" <johnrey@uslink.net> 08/19/03 10:06AM >>>

August 19, 2003

Messrs.  Payer and Hirsch,

Recently I received a importation/stocking permit approved by Mr. Goeman for longear sunfish.  Notes made by Mr. Goeman highlighted another problem with my fish farm license.  He restricted the stocking to the only pond left with non-indigenous licensing.  It seems that Mr. Goeman has removed longear sunfish from the indigenous only licensed ponds.  That is incorrect.

Longear sunfish are found in my watershed and therefore indigenous.  In fact several years ago the MN DNR Fisheries sold me longear broodfish collected in my watershed.  He should know the facts before he makes a decision that impacts my farm.  I have personally seen YOY longears in the Pine River below the Crosslake dam.  This gives them access to the Mississippi River from the Grand Rapids dam to the Gulf of Mexico and all connecting lakes and streams.  Mr. Goeman personally approved the unrestricted importation and stocking of longear sunfish from the same source in 2001.

This is only one example of the continued erratic behavior of Mr. Goeman.   

One year he correctly approves all my ponds unconditionally according to Minnesota statute and then years later, a month after I filed the ethics complaint against the Fisheries Research Manager, reverses his decision.  

One year he unconditionally approves a permit to import fish and then two years later incorrectly restricts a permit from the same source.  

He rejects a permit in 2001 because he says the ponds are in the 25-year floodplain and yet 2 years later admits there is no documentation that the ponds are in the 25-year floodplain.  Then the reason for the rejection changes to the threat that heavy rainfall (18+") could overfill the levee type ponds.  

Then Mr. Goeman refuses to license a new pond designed to maintain a minimum 24" of freeboard for all Minnesota species because of the threat of 24+" rainfall overfilling the levee type pond.  

Mr. Goeman also incorrectly stated that I needed his permission to sell any of my fish in Minnesota.  

My questions to the two of you is why are you allowing him to behave like this and how much longer are the two of you going to allow this behavior?

Sincerely,

John Reynolds

Midwest Fish and Crayfish

26385 County Road 3

Merrifield MN 56465

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