Asian Carp Infestation into Non-Invaded Waters on The Tennessee River

TO: Emily Buck, Jason Maxedon, Mike Bell,  Frank Fiss, Cole Hardy, Mark Thurman, Bill Lee
 
CC: Martha Williams, Director USFWS, 126 Signers of Meigs County Resolution, Tim Joseph, Janice Moody, Pandora      Vreeland
 
I have read Ms. Bucks letter response to my letter and have shared it with many other people.  We stand in amazement about your  comments and your condescending attitude about people who are absolutely trying to make a difference in saving the only lakes on the whole of the Tennessee River that are not CURRENTLY infested with Asian carp. Your statement “We understand your desire to prioritize your local body of water, but our agency is mandated to prioritize for the entire state and cannot sacrifice other bodies of water to please one group of stakeholders”, sends a simple message that you are absolutely not following  the guidance in the document that you keep referring to as the basis for the current TWRA barrier placement plan,   US Fish and Wildlife 2007 Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Strategic Plan. It is also a real slap in the face to those of us wo truly care about the health of the whole Tennessee River. We are not asking you to “please one group of stockholders”. We are asking you to do your job as stated in the above document and save the ONLY non invaded lakes from Asian carp.  That should be your priority as stated numerous times in the US Fish and Wildlife 2007 Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Strategic Plan.”  I will unequivocally tell you and everyone else that from all the discussions I have had with stakeholders not one has made any suggestion that TWRA  should sacrifice the rest of the Tennessee River in favor of the uninvaded lakes. That is pure unadulterated BULL. It is  unfortunate that you consider the stakeholders as selfish people who only care about “our body of water.” It certainly is not the kind of response I would expect from a supposed professional agency of Tennessee 
 
 I stated in my letter, “ I think I can speak for all the other stakeholders that the control aspect including commercially harvesting Asian carp absolutely needs to continue along with any new ideas to get rid of these monster fish. But, as National Fish and Wildlife Service has stated many times in their Document, the one you refer to that you are confident you are following its guidance, the Asian carp MUST be stopped from going into uninvaded waters.” I would add that we believe that barriers should be placed at all strategic locations. Our issue is your priority of placement and in NO WAY suggest the rest of the river be sacrificed. In fact the current barrier placement plan will sacrifice the only lakes not currently invaded as well as Chickamauga which still has a chance for survival if appropriate barrier plans are put in place. You seem willing to sacrifice the non invaded lakes while spending time, tax payer money, and effort to fish out the carp in the invaded waters. This is a direct quote from that USFWS Plan, “Controlling a new introduction or range expansion is NOT an acceptable alternative to prevention and containment.
 
In your reply to me you stated, “You are asking us to follow USFWS guidance and we can confidently say that we are. Our current policies are informed by the US Fish and Wildlife 2007 Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Strategic Plan.” How can you say you are following it? I have researched that document. Have you even read it? It appears not. You are without question not following the guidance outlined in the USFWS document.   I will again quote directly from USFWS Plan that you say you are “confident” that you are following. Please read, or re read the following  direct quotes from that plan “1. Prevent accidental and deliberate introductions of silver carp in the United States: 2. Every effort should be put forth to prevent introduction and range expansions into new waters: 3. Preventing introductions into waters where these fishes do not already exist is of utmost importance: 4. Contain and control the expansion: 5.Take immediate actions to prevent interbasin transfers and limit intrabasin movement: 6. Watersheds currently uninhabited by each Asian carp species need to be identified so efforts to prevent expansions into these areas can be prioritized: and lastly, the one quoted above.  7. Controlling a new introduction or range expansion is NOT an acceptable alternative to prevention and containment.”  
 
It is clear the plan is telling you to prioritize lakes currently uninhabited and PREVENT the carp from entering. You are spending our tax money only on “inhabited” lakes. And  please look at #7. You are doing exactly what the plan states is not an acceptable alternative to prevention. PLEASE EXPLAIN how you are following those guidelines when your barrier placement priority plan has Watts Bar as the last barrier and Chickamauga as the next to last. Given the time and money to build these barriers, it does not take a “rocket scientist” to understand that the Asian carp will have invaded the non invaded lakes of Watts Bar, Tellico, Melton Hill, and Ft. Loudon well before a barrier is built. Again, THIS IS NOT IN COMPLIANCE WITH   the US Fish and Wildlife 2007 Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Strategic Plan that you say you are “confident ” you are following. I am not only confident you are not following that plan as proven by the seven statements above taken directly from that plan. but  I am absolutely certain you are not. I find it reprehensible that after many requests you will not respond and explain how you are following the plan when your plan of priority barrier placement will assure the infestation of the currently non infested lakes. That is without question, a contradiction to the USFWS Plan that , as sated above, prioritizes prevention of Asian carp into non invaded waters.  Your organization has had many request to supply your information about how putting barriers behind the Asian carp, as  is your plan,  will prevent them from going further upstream. It is simply not logical that can happen. It is also simply inconceivable that you will not admit to that fact and correct your plan to become compliant with  US Fish and Wildlife 2007 Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Strategic Plan which Ms. Box has stated is the basis for the TWRA Asian carp plan and you state you are confident you are following.   You refuse to answer. And  I am sure I know why you will not answer…….There is no answer. 
 
Also, I have read all TWRA and TFWC’s replies to Dr. Joseph. You stated “TWRA will not be re-answering these questions.” I have also read your responses which, as is the case with your response to me, a lot of words with multiple erroneous statements and NO ANSWER TO MY QUESTION. All your responses just said what you are doing and you have not answered his direct questions. o9r my very simple question. He has labeled specific questions and you beat around the bush skirting the questions and you use that to say you have answered them. This is highly unprofessional and unacceptable. His questions were straight forward were easy to answer. 
 
It is truly unfortunate that for an organization whose Mission Statement is. “to preserve , conserve, manage, protect, and enhance the fish and wildlife of the state and their habitats for the use, benefit, and enjoyment of the citizens of Tennessee and its visitors”  that I  have to continue over and over to  repeat my request  that you absolutely refuse to answer which is the same request that Dr. Joseph has asked many times. How will putting a barrier at Wilson Dam, which is behind the invading Asian carp,  stop the invasion of Asian carp into non invaded waters. What is to stop the carp that have  invaded Wilson Lake and all the lakes upstream from Wilson Dam except for Watts Bar, Tellico, Melton Hill and Ft. Loudon Lakes. The very simple question that after many attempts from Dr. Joseph, myself and many others is how  can that happen.  Your letter  erroneously  states you are following the plan stated in “ US Fish and Wildlife 2007 Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Strategic Plan”. You are absolutely NOT following that plan as shown from the quotes above. You refuse to answer the simple question of how your barrier plan BEHIND the migrating fish  will prevent fish from continuing their journey upstream. It is simply not logical that your plan will prevent Asian carp from continuing their migration upstream to non invaded waters. Its like shutting the door after the dog is out will prevent him from going across the street. It CANNOT happen. Please answer the question and quit trying to convince everyone that your plan follows USFWS plan and that the carp will just stop swimming unimpeded upstream. It is beyond logic that you can state that you are following the “US Fish and Wildlife 2007 Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Strategic Plan ” which is stated in the seven quotes above that stress prevention of uninvaded waters as the priority.  In fact your plan will  certainly allow the continued migration upstream from Wilson Lake into the non invaded waters. Please respond to the question. If you have no answer to my question, please at least be honest enough to admit it and put a legitimate plan in place to stop the migration of Asian carp into the non invaded waters as is without question is the guidance of the U.S Fish and Wildlife Services, Your current response in NO WAY answers the question that the people you supposedly represent as TWRA, TFWC, TVA , USACE, and the Governors Asian Carp Council continue to ask. It is sad that I have to be so repetitive in this letter but I don’t know how else to get someone to listen and directly answer the simple question. It is totally irresponsible that thus far, as the Asian carp are swimming towards the non invaded lakes, TWRA and all other agencies are doing nothing to stop the devastation that they will bring when that can be prevented. Again, as dictated by the USFWS.
 
As an aside I thought it interesting that my sister and brother in law  received a response to her letter signed by Mike Bell. It was identical to the one I received signed by you Ms. Buck.
 
 
February 28, 2023
                                                     
 
From:       Chip and Bev Whitaker
                 206 Mallard Lane
                 Ten Mile, TN 37880
       
 To:           Angie Box, Chairman, Tennessee Fish and Wildlife Commission      
                Mike Bell, Chairman, Governors Asian Carp Advisory Council         
                Governor Bill Lee 
                Jason Maxedon, Executive Director, TWRA 
                Bob Deacy, Senior Vice President, TVA
                Craig Carrington, USACE
 
   CC:       Michael Butler, David Salyers, Monte Belew, Travis Wiley, Stuart McWhorter, Denis Tumlin,Cole R. Harty, Ed Carter, Emily A. Buck, ClintJones,                  Frank Fiss, Jim Ripley, Jeremy Crossland,    Gary Fleeman, Kathleen McConnel, State Senator Ken Yager, Lt. Governor Randy McNally,
State Representative Monty Fritts, State Representative Lowell Russell, State Representative Jason Zachary, U.S. Senator Bill Haggerty, U.S. Congressman Tim Burchett, U.S. Congressman Chuck Fleischmann, Meigs County Mayor Eddie Jewell, Meigs Count Clerk Janie Meyers, Meigs County Commissioner Zach England, Tim Joseph, Janice Moody, Pandora Vreeland, 126 Respondents Agreeing with Meigs County Resolution
          
     
Subject: Asian Carp Infestation into Non-Invaded Waters on The Tennessee River
 
 
INTRODUCTION
 
We are permanent lakefront residents on Watts Bar Lake in Ten Mile Tennessee. I have been enjoying this incredible lake since the mid 1950’s and hope to help save it from total destruction by the infestation of Asian carp.
 
I am writing this letter to express my concern that the TWRA plans for Asian carp to build the first Asian carp barriers at Kentucky Lake and Wilson Lake and the last at Watts Bar and Chickamauga will in fact allow the carp to continue to swim upstream and move into non-invaded lakes of Watts Bar, Tellico, Melton Hill and Ft Loudon. A first barrier at Watts Bar would prevent that from happening. A second barrier at Chickamauga would save that lake from total devastation since few of the Asian carp have been seen in that lake. The U.S. Fish and Wildlife Services Management Plan and Control Plan for Bighead, Black, Grass, and Silver Carps in The United States (attached) recommends many times that the prevention of these carp into waters where they do not exist is a priority. I will list some of those direct comments from this document below. Ms. Angie Box, CEO of Tennessee Wildlife Federation, stated in her recent article in the Knoxville News Sentinel that this document is the basis for TWRA plan for Asian carp. I do not understand how that can be the case when the current TWRA plan will allow that migration of Asian carp into waters where they do not exist today. That is contrary to the U.S. Fish and Wildlife Services plan recommendations.
 
 
Excerpts from :
 
 “The U.S.Fish and Wildlife Service’s Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States Submitted to the Aquatic Nuisance Species Task Force”. (note: This is the document Ms. Angie Box, CEO Tennessee Fish and Wildlife Commission, states is the document that is the basis for TWRA Asian carp plan)
 
CHAPTER 3. MANAGEMENT AND CONTROL OF ASIAN CARPS
 
Strategies and recommendations developed by the Working Group to accomplish each of the seven goals presented in Section 1.2 are discussed in detail within this chapter. A summary table listing each of the recommendations is presented in Chapter 4 (Table 4.1, page 120).
 
                                              
                                                Goal 3.1.  (First Goal) 
 
Prevent accidental and deliberate unauthorized introductions of bighead, black, grass, and silver carps in the United States.……..Preventing introductions into waters where these fishes do not already exist is of utmost importance throughout the remainder of the United States (e.g., Great Lakes and Columbia River basins)…….
 
 
                                                Goal 3.2. (Second  Goal)
 
Contain and control the expansion of feral populations of bighead, black, grass, and silver carps in the United States
 
To prevent their expansion into waters where they do not exist, a long term, dedicated, and cooperative effort by federal, state, tribal and private partners is required to create or maintain dispersal barriers….
 
 
Strategy 3.2.1. 
 
Develop a national strategy and guidelines for science-based decision making concerning the need for continued and additional containment measures. The rapidly growing and expanding populations of bighead and silver carps are forcing federal and state agencies to develop both immediate and long-term strategies for containing these fishes and for limiting their distribution. Decisions to undertake specific containment actions should be science-based. In addition, a long-term strategic, rather than an opportunistic, approach should be used to contain feral Asian carps. Due consideration should be given to the effects of containment actions on the long-term ecological sustainability of native aquatic resources.
 
Recommendation 3.2.1.1. 
 
Develop a Decision Support System to assist natural resources managers in prioritizing specific locations for the construction, maintenance, monitoring, or removal of barriers to carp dispersal….. 
 
 Recommendation 3.2.1.3. 
 
……. Effective containment is an immediate need that will require a long term commitment of personnel, equipment and funding………
 
Strategy 3.2.2. T
 
Take immediate actions to prevent interbasin transfers and limit intrabasin movements of feral Asian carp populations. Once an aquatic nuisance species becomes established it can be very difficult and costly to manage and potentially impossible to eliminate (Kolar et al. 2007; USEPA 2005). The best protection for native aquatic ecosystems is to minimize the distribution of feral Asian carp populations and prevent their access to additional waters. Because existing feral Asian carps populations are dispersing and will not wait to be contained, implementation of this strategy is urgent and immediate actions are warranted to prevent the expansion of feral Asian carp populations throughout the Mississippi River Basin and into new watersheds………
 
 
 
                                                                Goal 3.3 (Third Goal)
                                                                                . 
Extirpate, or reduce to levels of insignificant effect, feral populations of bighead, black, grass, and silver carps in the United States.
 
Every effort should be put forth to prevent introductions and range expansions into new waters. Experiences controlling populations of other aquatic nuisance species introduced into the United States have proven difficult (e.g., sea lamprey, zebra mussels, and common carp) and indicate that extirpating or reducing feral populations of Asian carps to levels of insignificant effect will at best be challenging, expensive, and will require a long-term, dedicated effortControlling a new introduction or range expansion is not an acceptable alternative to prevention (Goal 3.1) and containment (Goal 3.2), however once a population is established, control measures should be done in concert with aggressive prevention and containment actions………
 
…..Depending upon the funding and staffing committed to the completion of the project, a fully functional Decision Support System could take from one to several years to develop. However, containment measures are needed now to be most effective……. 
 
 
Goal 3.4. (4th Goal)
 
Minimize potential adverse effects of feral bighead, black, grass, and silver carps in the United States.
 
 
Recommendation 3.6.2.1. 
 
….. Watersheds currently uninhabited by each Asian carp species need to be identified so efforts to prevent expansions into these areas can be prioritized….….
 
Strategy 3.6.3.
 
…. The need for effective barriers to prevent the continued spread of Asian carps into uninhabited waters is a high priority …….
 
Summary of the USFWS Document
 
The guidance from US Fish and Wildlife Asian carp planning document states numerous times that prevention from invasion into non invaded waters should be the priority. That is certainly not the current plan for TWRA by putting barriers behind the invasion to allow the carp to continue their migration into uninvaded waters of Watts Bar, Melton Hill, Tellico, and Ft. Loudon.  I hope that TWRA will take this to task and begin to re-prioritize the TWRA plans and make Watts Bar the first dam to have an Asian carp barrier rather than the last. In doing so, the TWRA would be using the US FWS Plan as the basis for the TWRA plan.  The current TWRA barrier placement plan goes against all guidance from the document which states many times that prevention into new waters is what needs to be a priority.
  
 
 
 
ILLINOIS PLAN TO SAVE THE GREAT LAKES FROM ASIAN CARP DEVATATIONS COMPARED TO TWRA PLAN
 
The Illinois River is, like part of the Tennessee River, overwhelmed with Asian carp.  The plan is to construct barriers at the Bradford Road Dam AHEAD of the Asian carp some 20 miles downstream from non invaded lake Michigan in the Illinois River just as the USFWS recommends in the above document excerpts. Their goal is to prevent the invasion of Lake Michigan and subsequently all the Great Lakes and save the 7-billion-dollar-a-year economy of commercial fishing and the 11-billion-dollar tourism economy.  It is hard to understand why the people in the Great Lakes area understand the priority of preventing the invasion, as does the U.S Fish and Wildlife Service, and the TWRA does not. They are doing exactly what needs to be done on the Tennessee River by preventing introduction of Asian carp into waters that are currently not infested by putting the barrier ahead of the Asian carp.
 
The forecast from a comprehensive study conducted by TVA and University of Tennessee says that the lakes in the East Tennessee Upper Basin generate an economy of one billion dollars a year. Those are the current non-invaded lakes mentioned previously.  The Asian carp invasion will decimate that economy. That will be a devastating loss to the region’s economy as would be the loss in the Great Lakes area. And the economy is only a portion of the loss that this region bordering or close to these lakes will see.  
 
  
STAKEHOLDERS INVOLVEMENT
 
The USFWS Document states, ” Local community coordination and involvement is vital….
 
Timothy Joseph, PHD, fisheries biologist, Chairman of Watts Bar Ecology and Fisheries Council (WBEFC) which has over 700 stakeholders, is an expert in Asian carp, has spent years discussing and submitting science-based concerns with the current plan that TWRA has developed to combat the infestation of Asian carp, especially silver carp. His expertise in this field, his research, and his close professional relationships with the most experienced Asian carp experts in the United States should give him the absolute right to be heard by all who have any interest in saving our lakes from the destruction. He and all the Stakeholders of WBEC and all interested parties should have a legitimate response to his many requests to provide the science behind the TWRA plan that shows how building barriers behind the Asian cap can possibly prevent infestation of the non-infested lakes. The TWRA has failed to do so. In fact, recently Dr. Joseph was told that TWRA would no longer communicate with him. How insulting and how shameful.
 
I hope that everyone realizes that as chairman of WBEFC Dr. Joseph is the unifying voice for over 700 stakeholders of Watts Bar Ecology and Fisheries Council. We absolutely stand with him on his comments and his desire to just do what is right and what is recommended by USFWS and many other experts. The recommendations that Dr. Joseph has for barrier placement at locations to prevent Asian carp invasion of non-invaded lakes fits perfectly with the USFWS recommendations in the Document of “prevention of Asian carp into non invaded waters”. 
 
One of many examples of other local stakeholder involvement happened in my county, Meigs County. A Resolution was proposed for the Meigs County Commission to approve and forward to TWRA requesting that TWRA plan be changed to make Watts Bar Dam the first to receive an Asian carp barrier. A petition was circulated via available e mails as well as personal contacts, circular distribution, and social media to ask for support of this resolution. In a matter of days leading up to the commissioners monthly meeting we had 126 people agree with the resolution. I am certain had we had the ability to contact more people and time to do so we would have many more signatures. The resolution was passed unanimously and forwarded to TWRA.
 
On February 6 I met with our Meigs County Mayor, Eddie Jewell, as well as our County Clerk, Janie Meyers, to discuss the Asian carp issues. On February 9 I had a similar discussion with Zach England, Meigs County Commissioner who sponsored the Meigs County resolution discussed above. Mr. England is also Vice Chair of Meigs County Chamber of Commerce. I wanted to hear from them of any response from TWRA, TVA or any person or organization that received a copy of this resolution.  All were very concerned that there has been no response to the resolution they submitted to the TWRA.   Mayor Jewell specifically asked why the TWRA would put such a plan in place knowing that ultimately the non-invaded lakes will be overtaken. Both Ms. Meyers and Mr. England asked the same basic question.  Mayor Jewell has requested that Ms. Box send any technical data that supports TWRAs current plan of putting the first barriers behind the Asian carp at Kentucky Lake and Wilson Lake, and how that will prevent Asian carp from entering non invaded lakes. He needs to supply that information to his County Commissioners.  And, if there is no technical proof or data to support a plan that those fish above the barrier will not continue up the river  into the non-infested lakes, why is the TWRA not following USFWS, MICRA and the leading experts in the country to put a plan in place that will do so as recommended by USFWS  Management and Control Plan for Bighead, Black, Grass, and Silver Carps in the United States.  
 
Please consider all the above and revise the current plan of Asian carp barrier locations to make Watts Bar the first location and Chickamauga the second so we can save the currently uninvaded lakes and give Chickamauga a chance for survival.  I think I can speak for all the other stakeholders that the control aspect including commercially harvesting Asian carp absolutely needs to continue along with any new ideas to get rid of these monster fish. But, as National Fish and Wildlife Service has stated many times in their Document, the Asian carp MUST be stopped from going into uninvaded waters. That is the priority. Please help us save our lakes from devastation!   Prevention (Barriers) is much better than the cure (Harvesting the Fish). Ms. Box, will you please explain why you are not following all the CLEAR guidance that says stopping the Asian carp must come before trying to manage them in place. I ask that you explain this to me. I look forward to your reply. 
 
Thank you for taking the time to read this letter.