Updates from the National Aquaculture Association

Here is an update about the active petition to put Koi on the Injurious Wildlife list.

You can read more about how this ongoing battle has progressed in these two Next Day Koi articles:

• Someone Is Trying To Kill The US Koi Industry
• Take Action Now To Help Save The Koi Industry

On September 23, 2016, the Fish and Wildlife Service (FWS) received a petition that seeks to add 43 species of fish to the Injurious Wildlife list under the authority of the Lacey Act, based on a risk screen (Ecological Risk Screening Summaries or ERSS), that the National Aquaculture Association (NAA) deemed “rapidly performed.”

Common Carp (and so, Koi) have been named on that list. As you know we at Next Day koi have been active in combatting this hasty and poorly thought out petition at the highest level and continue to raise awareness of its potentially devastating consequences for both dealers and enthusiasts.

These are the updates regarding the proposed legislation that would declare Koi an Injurious Species.

• The NAA distributed a comment letter submitted to the FWS by the American Fisheries Society that included comments by Dr. Jeff Hill, UF Tropical Aquaculture Lab, which take aim at the climate match used in the Ecological Risk Screening Summary method as well as errors within specific reports. It also contained NAA comments that identify errors in the process, reports and implementation.

• The NAA presented the issue of the 43 species Injurious Wildlife petition via conference call to the California Aquaculture Association The NAA participated in the California Aquaculture Association Board of Directors meeting. The CAA posted NAA’s four-page summary to their website and wrote a comment letter to the FWS, encouraging their members to comment.

• The NAA attended the Aquatic Nuisance Species Task Force meeting in DC where they spoke at length with FWS representatives “concerning the 43 species Injurious Wildlife petition, the errors inherent to the quick screen methodology that they are using and the information quality of the quick screen reports.” 

  The FWS’s response “while noncommittal, they did acknowledge receiving public comments on the petition and appear to be beginning to grasp the size and scope of the farms and businesses that produce the farm-raised species in the petition, state regulatory requirements, and that these species do not pose a high risk to the United States.”

• At that same meeting, the NAA also spoke before the ANSTF regarding the effort, cost and difficulties for aquaculturists and distributors to remain current with state regulations when transporting live species across state lines. 

  The presentation also “provided in-depth information to the ANSTF, driving home the point that states have regulations to prevent the introduction of non-native species appropriate to their environments and that the federal agencies should defer to the states rather that adopting nationwide prohibitions under the Lacey Act.”

• By invitation, the NAA submitted an issue that describes the US Fish and Wildlife Service (FWS) regulatory overreach relative to the Lacey Act and animal disease to the American Farm Bureau Federation white paper entitled, Regulatory Improvement and Reform: A Priority for American Agriculture (which 53 agricultural organizations have signed on to).
• The FWS has accepted the NAA’s invitation to present at a special session in the upcoming Aquaculture America 2017 conference in San Antonio, TX on February 19-22, 2017. 

  Agency speakers will present an overview of the Lacey Act and in-depth information on the Injurious Wildlife list, Injurious Wildlife listing process and decision making, Lacey Act law enforcement, the Ecological Risk Screen Summary methodology and reports, and any other aspects of the Lacey Act that the FWS thinks is pertinent to communicate.

• The NAA has met with the Pet Industry Joint Advisory Council (PIJAC) in Washington to discuss collaborative efforts to defeat the petition, stop or amend the use of quick screens, and amend or withdraw factually inaccurate quick screen reports.
• The NAA has reached out to the National Aquaponics Association and the US Aquaculture Society and is working with them to submit comments on the petition.

• The NAA also submitted a Freedom of Information (FOIA) request to the US Fish and Wildlife Service (FWS) for the 2,000 Ecological Risk Screening Summaries that have not been publicly posted and are meeting with the University of Florida’s Tropical Aquaculture Lab to discuss an analysis of the reports.

We at Next Day Koi remain committed to fighting this harmful action toward the industry, and will keep you updated of any new developments as they become known.