Below is the briefing paper used by the MN DNR in the House hearing on HF 834.  My comments are in bold. 

 DNR Briefing Paper On Triploid Grass Carp / SF 718

  March 2001

   What are Grass Carp and Triploid Grass Carp?

1. Grass carp, or white Amur, are originally from Asia and a different species than the common carp.

 2.  Grass carp are one of the largest members of the minnow family and typically reach a size of 35 pounds; their life span is about 12 to 15 years.

 3. Fish less than six inches in size feed primarily on plankton and microscopic plants and algae.

 4.  Fish larger than six inches eat aquatic plants including pondweeds, elodea, coontail, naiads, duckweed, muskgrass, water milfoil, wild rice, and bladderwort.

 5. Grass carp less than 13 pounds can consume their weight in plants in one day.

 6. Triploid grass carp (three chromosomes) are produced from fertilized eggs of diploid or normal grass carp (two chromosomes).

 (Midwest) Fertilized eggs are pressurized to 8,000 psi shortly after fertilization.  This results in the retention of the second polar body (extra set of chromosomes).

7. Triploid fish are assumed to be sterile.

 (Midwest) Thirty-eight states consider triploid grass carp sterile.  There is no documentation of reproduction in watersheds that require triploids.  The state of Florida stocked 100,000 triploid grass carp in a single stocking and there is no evidence of reproduction.  Triploids of other fish species are also produced for situations where reproduction is unwanted.

 8. A blood test on each fish is required to test for triploidy.  Not 100% accurate.

 (Midwest) This is false.  The method is 100% accurate.  Flow cytometry is also 100% accurate.  Each fish is blood tested two times.  The blood is tested in a medical device known as a Coulter Counter.  Flow cytometry is also used to determine triploidy.

 

What are the Current Regulations?

 9. Grass carp (Ctenopharyngodon idella) were designated as prohibited in 1995 via the public rulemaking process (Minn. Rule 6216.0250). No opposing comments were received. 

 (Midwest) I did not comment on the rule because I believed that it was futile to comment.  See comments 11, 15, 20, 29.

 10. The prohibited exotic species category was established to keep known harmful species including their hybrids, cultivars, or varieties of the species from being imported, propagated, transported, or sold in the state except by permit for the purposes of disposal, control of the species, research, and education.

 

11. Commercial use of prohibited exotic species was intentionally not allowed in the statutes.

 

(Midwest) This shows the bias the MN DNR has against aquaculture.

 12. Experience in Minnesota and other states has shown that prevention is the best policy to address harmful exotic species such as Asian carp, Eurasian watermilfoil, and zebra mussels because there are no selective controls that can be used to eradicate these species once they are in public waters.

 (Midwest) Eurasian watermilfoil and zebra mussel populations in our state are the result of careless handling and have become problems because of the fact that they are capable of high rates of reproduction.  Triploid grass carp are sterile.  If triploid grass carp are not allowed, some ignorant people will buy diploids (illegally) and transport them into Minnesota. Which is better: a highly controlled, regulated approach or one that simply relies on peoples good will? There is a patented grass carp bait by Prentiss that only kills grass carp.

 

What are the risks and concerns?

12. Fish can and will escape from ponds.

 

(Midwest) Fish do escape ponds but the number of triploids likely to be contained in a pond is so low that the impact would be insignificant even if every one escaped.  My farm needs 30 fish.

 

13. Three species of Asian carp (grass, silver, and bighead) have repeatedly escaped from private aquaculture ponds in Arkansas and Missouri and entered public waters.

 (Midwest) It was from USFWS service ponds that the original grass carp escaped into public waters.  The southern states have regulations that are much more lax than the safeguards contained in this bill.  My ponds are located in a dry cornfield and are more than 1,000 feet from any public water.  They have no connection to public water.

 

14. Grass carp are in the state in two border waters as a result of escapees from other states:  Lake Okamanpeedan in Martin County and the Mississippi River near Winona.

 (Midwest) These fish are probably not just the result of escapees but also intentional stockings of diploids into public waters by other DNRs.  Grass carp have also been documented in the St. Croix and Snake River in Minnesota as far back as the early 1980’s.

 

15. Grass carp can harbor parasites and diseases such as Asian tapeworm that could threaten sport fish populations.

 (Midwest) All fish harbor parasites and it is currently legal to import other fish species from the same farms that culture grass carp thus it is likely that tapeworms or other parasites could be imported with other fish.  Many states that allow triploids require farms selling triploids to be certified tapeworm free.   Prazinquantel is 100% effective in eliminating Asian tapeworms and is required by some states allowing the use of triploid grass carp.  Minnesota has a history of illegal importation of golden shiners, which also carry Asian tapeworms.  Our state also allows the legal importation of fatheads minnows for forage.  Fatheads are a known carrier of Asian tapeworms.  I provided this information to the MN DNR in my letter to Mr. Ron Payer in September of 2000 but received no reply.

 

16. Grass carp can live 12 to 15 years so even if triploid, should they escape, could severely damage the aquatic vegetation, including wild rice, for many years in waters where they would exist.

 (Midwest) There is no evidence that triploid grass carp reproduce and all studies show how extremely unlikely reproduction is likely to occur even under ideal laboratory conditions.  Lack of reproduction will keep the number of fish escapees at numbers too small to be significant.

 

17. Waterfowl production could be curtailed and fish populations could be reduced because of reduced aquatic vegetation.

 (Midwest) Same as 16.  It takes large numbers of grass carp to severely reduce vegetation in large water bodies.  A 300-acre lake would require about 15,000 fish.  My farm would require 30. Arkansas is where almost all triploid grass carp are produced and it is the "Duck Capitol of the World"! Only two other states (Louisiana & California, which both allow triploid grass carp) sell more duck stamps than Arkansas. Arkansas also has numerous world record freshwater fish.

 

18. If permitted, it is only a matter of time until grass carp are reproducing in the state.

 (Midwest) This is false.  Sterile fish do not reproduce. 

Triploid grass carp are functionally sterile and do not reproduce.  Grass carp require highly specific environmental conditions to trigger spawning.  The water must be simultaneously rapidly flowing and rapidly rising.  The grass carp eggs are semipelagic and must remain suspended in water flowing at a minimum rate of 2.25 mph for a minimum of 16 hours.  This would require a minimum river distance of 36 miles under ideal temperature conditions.  These are ideal conditions required for successful hatching.  It is unlikely that these conditions exist in many places in Minnesota.

 

19. Identification of triploid fish is problematic.  No guarantee they will be triploid.

 (Midwest) Identification of triploids is not problematic; it is a science!

Same as 8.  Each fish is twice tested using an approved method.  Fish can also be tested using flow cytometry.  The probability that a diploid fish can make it through the testing not once but twice is almost too small to calculate.  The probability that a diploid male and a female will both make it through the testing is even smaller.

 20. Testing for triploid grass carp has a 2.5% error rate.

 (Midwest) This is false.  The testing procedure is 100% accurate. 

The bill requires that individual fish be certified by the United States Fish and Wildlife Service instead of the normal subsample.  The USFWS has a protocol that allows individual fish to be certified.  I offered to provide this information to the MN DNR but did not receive the courtesy of a reply.

 

Grass carp have a very limited potential beneficial use and are a risk to the state’s aquatic resources.  The DNR believes that the risk of harm is greater than the potential benefits from use of grass carp to control aquatic vegetation.

 

(Midwest) The main benefit of triploid grass carp is the reduction in the use of aquatic herbicide use in Minnesota.  The main users will be fish farmers and golf courses.  Municipal sewage treatment plants have also expressed interest in the substitution of triploid grass carp for herbicides.

 

Summary on Grass Carp Introductions

 

21.  High likelihood of escape into waters of the state if they are introduced many examples of this happening.

 

(Midwest) This bill contains adequate safeguards to ensure if escapes occur they will remain at an insignificant level.

 

22. High likelihood the species will naturalize in waters of the state currently found in Pool 4 of the Mississippi River.

 

(Midwest) This is false. Triploids are incapable of reproduction and cannot naturalize.

 

23. Will survive in waters of the state.

 

(Midwest) True but irrelevant because the numbers used in private waters are so small they insignificant.

 

24. Triploids can potentially cross with diploids.

 

(Midwest) This would require that diploids already be living in the river.

 

Triploids have been crossed with diploids in a laboratory setting using human hormone injections in three separate attempts.  Nearly all of the fertilized eggs failed to complete development and died before hatching.  Of those that survived incubation only .21% and .125% survived to five months.  Should a triploid male escape and mate with a free roaming diploid female the result will be that most of the eggs will not hatch.  Of those eggs that do hatch most or all offspring will die shortly after hatching if in fact any are produced.  The intentional release of sterile male insects like the Mediterranean Fruit Fly is a method of reducing the number of offspring produced by problematic exotic species.

 

25.     Triploids produce gametes and potentially may produce offspring

 

(Midwest) Triploids crossed with triploids would only produce more triploids.  It is nearly impossible produce triploid grass carp by this method.

 

26.  High likelihood that grass carp escapes could adversely impact native fish species, waterfowl production, outdoor recreation, and other uses of the natural resources destroy important fish and wildlife habitat by eliminating or reducing aquatic vegetation wild rice could be impacted by escapees

water quality could be changed by increased nutrient loading

 (Midwest) The number of triploid grass carp used for weed control is so small in culture ponds that even if every fish were intentionally released the impact would be insignificant in the natural system.  My farm requires 30 fish.  This is an insignificant number when you consider it takes thousands to control weeds in a small lake.

 

27. Low ability to eradicate or control the spread of exotics once they have escaped has been impossible to control/eradicate ruffe from the St. Louis River estuary

 (Midwest) Unlike the ruffe and other problematic exotic species triploids grass carp are self-limiting because they do not reproduce.  Ruffe became problem because of their high rate of reproduction.

 

28. Asian carp in other states   zebra mussel

 (Midwest) Nine states in the Mississippi River watershed have allowed the stocking of the diploid variety of some of these Asian carps (actual species allowed varies by state) for over 25 years into private ponds and public waters. Many DNRs actually stock diploid grass carp into their public waters and these same fish can swim up the Mississippi River into Minnesota.  Zebra mussels came in the ballast water of intercontinental ships and have a very high rate of reproduction.  This could have been prevented by simply requiring the tankers to exchange their ballast water at sea.

 

29. High likelihood that Asian tapeworm would be spread throughout the state

 (Midwest) Prazinquantel is 100% effective in eliminating Asian tapeworms.  It is also possible to buy triploid grass carp from farms certified to be free of this parasite.  I provided this information to the MN DNR in the September 2000 letter but did not receive the courtesy of a reply.  Same as 15.

 

30. Unknown likelihood about the spread of fish diseases

 (Midwest) Same as 15.

 

(Midwest) Additional comments

One concern of the MN DNR is that aquaculture may be adversely effecting waterfowl production in natural ponds by direct competition for invertebrates.  Since graduating with an aquaculture degree from Auburn University I have always advocated for moving Minnesota aquaculture production from natural ponds to man-made ponds.  One of my arguments has been that man-made ponds are many times more profitable to operate but unless we can control our weed problem there is little difference between a man-made pond and a natural pond.   This removes the financial incentive to build a pond for $3-5,000 per acre when the same acreage can be rented for as little as $5 per year.

 "The pressure technique varies from 98% to 99.9% triploid induction.

Typically when we are blood testing fish for triploid, we are only looking for 1 diploid per 100 fish to 1 diploid per 1,000 fish that must be removed by blood analysis."  Quote from major triploid grass carp producer.

 Grass carp have been smuggled into Minnesota and were most likely diploids because diploids do not require the strict documentation required of triploids.  If triploid grass carp are not allowed, some ignorant people will buy diploids (illegally) and transport them into Minnesota. Which is better: a highly controlled, regulated approach or one that simply relies on peoples good will? 

Triploid grass carp are "functionally sterile". The fact that a male triploid might produce one good sperm in 2 1/2 Billion does not indicate viable reproduction.

 After nearly two years of reviewing the literature, tracking down the authors and questioning them on their key studies I am confident that the use of certified triploid grass carp is safe for the environment and native fish populations.  If I didn't I would not ask for your support.

 

Sincerely,

John Reynolds

Midwest Fish and Crayfish