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To: Asian Carp Commission, TWRA/TFWC
I find it necessary to respond to TWRA’s reply to Mike McCraken’s letter. PLEASE read carefully so you and TWRA/TWFC don’t once again ignore the facts and state categorical untruths. I have explained this to you and TWRA/TFWC at least six to eight times over the past years, yet TWRA/TFWC continues to twist facts and make false statements.
TWRA statements are in red.
Has the science from those sources been considered in the development of TWRA’s strategy? Absolutely. Both USFWS and MICRA helped develop the strategy in place. In fact, the plan does not belong to just TWRA but is the collective plan of the USFWS and MICRA, and our partner states. That is “true” however the “strategy” is a “PLAN” to reduce recruitment and remove fish, NOT to prevent them from accessing new lakes. It is NOT guidance, it is a “Plan” of action. I have pointed that out MANY times. I agree with the strategy. The GUIDANCE, however, states it is MORE important to prevent access into uninhabited lakes, which TWRA’s strategy/plan does not address. You continually state the USFWS/MICRA “PLAN” is your guidance, IT IS NOT. Stop using a plan to reduce recruitment to say you are following federal guidance. How can you not understand the difference between a PLAN and Federal Guidance?
The continued insistence that TWRA is not following the USFWS and MICRA Guidance as laid out in the “National Plan” is categorically false, and support for TWRA and partners has been clearly expressed by USFWS. You state you are following the USFWS/MICRA “National Plan” to reduce recruitment and then call it “GUIDANCE.” It is NOT guidance—as you say, it is a PLAN. TWRA is categorically NOT following USFWS and MICRA guidance. Please read this carefully. Here is the published guidance of the USFWS: “Goal 1: Prevent accidental and deliberate unauthorized introduction of silver carp in the U.S. Active control measures are needed to PREVENT introductions or range extensions.” Tell me please how TWRA is doing that? They are NOT. TWRA admits their plan will NOT prevent the silver carp from reaching the upper lakes. TWRA’s plan “deliberately” allows the ‘range extension’ of the silver carp, which will be an “unauthorized introduction” of silver carp into silver carp free lakes. This is 100% opposite of the USFWS guidance. I formally ask you to Explain why I am incorrect please.
Here is the published MICRA guidance, please read carefully: “Goal 1: Prevent the introduction and further spread of Asian carp.” TWRA is categorically NOT following this guidance. The guidance is clear— “PREVENT the introduction and further spread.” TWRA is doing the opposite. TWRA is ALLOWING the spread of silver carp into four lakes, and to say they are following the USFWS and MICRA guidance is “categorically FALSE.” Please explain to me how allowing the fish to reach four uninvaded lakes is following USFWS/MICRA guidance.
TWRA is actively working with partners to prioritize deterrent placement at the most effective locations in addition to implementing a removal program to fish carp populations down and monitoring carp populations to better understand them. Yes, they are, but to “reduce recruitment” and remove fish, but NOT to prevent their migration into new lakes. NONE of that will prevent the fish from migrating into our lakes and TWRA knows this as stated by Mr. Cole Harty. TWRA totally IGNORS all guidance which says “Prevent” the fish from reaching uninhabited lakes. Can you not understand simple facts?
The capability to absolutely stop carp is non-existent. Even closing a lock, which would be the most effective measure, would not prevent carp from being accidentally or intentionally introduced into a lake by fishermen. This statement shows TWRA’s lackadaisical attitude toward protecting our lakes and it is an embarrassment. AT least TWRA admits that “Closing the lock is the most effective measure.” To then say it doesn’t matter because just maybe a fisherman might release some silver carp into the lake is trivial and embarrassing. Even if that happened, they know full well the chance of successful reproduction is ZERO. This just shows how blatantly irresponsible TWRA is in their statements. So, closing Saint Anthony’s lock was a mistake? Tell that to Minnesota. Since TWRA admits closing the lock is the most effective measure, then WHY are they not doing everything to do so? Oh, because maybe a fisherman might just dump a carp in the lake? How ridiculous is that?
TWRA has not assumed or stated that invasive carp will not successfully spawn. Categorically FALSE. Cole Harty stated he assumes they won’t reproduce to me in my Nashville meeting, and at numerous public meetings, even at the TFWC meeting (please view the video), and at the Fishing Club meeting, and I have letters from TWRA saying it. Go look at the facts, they are recorded. Why do you not know this?
The current plan (i.e., fighting these fish on the invasion front) is the best approach. Unequivocally wrong. MICRA states: “The most cost-effective management approach is preventing the introduction and establishment of Asian carp into uninhabited waters. Prevention efforts are more viable than attempting to manage and control a species that has already been introduced.” Please tell me why TWRA is smarter than the USFWS and MICRA. There isn’t a biologist in the nation that would say it is better to attempt to control an invasive species in an ecosystem than it is to prevent them from entering it in the first place. For TWRA to state this shows their incompetence in dealing with an invasive species. Even a grade-school child knows that it is much better to stop a bad animal from entering their home than trying to deal with it inside.
The accusation that we and our partners are not using science is just wrong. The partnership is using the evolving body of knowledge – including existing peer-reviewed literature, scientific modeling, fisheries data, and structured decision-making processes – to manage and control carp. Once again, the guidance states that it is far better to “Prevent” access then try to “manage and control them in-place.” TWRA is using science only to reduce recruitment and remove fish. Why can’t you understand this. NOTHING they are doing or plan to do “Prevents” this invasive fish from reaching uninhabited lakes, which all the guidance states is Goal-1 in addressing this invasive species. Trying to manage them in place categorically cannot possibly prevent them from reaching our lakes and TWRA knows this and has stated such. They ignore the guidance, science, history, and the recommendations of the leading silver carp scientists in the nation and ignore simple ecology. Tell me how I am wrong please.
There are no alternative approaches currently available to completely stop carp. Even the closing of the locks at Watts Bar, which would take a literal (vote on legislation) act of Congress, would not be a 100% guarantee. SO WHAT? It is unequivocally the BEST way to save our lakes, period. TWRA admits closing the lock is the best choice yet doesn’t wish to pursue it while their plan is a 100% guarantee the silver carp will reach our lakes. Dr. Peter Sorensen, the leading silver carp expert told TWRA that a barrier at Watts Bar stands an “Excellent” chance of saving our lakes from the silver carp—so too did Jerry Rasmussen. Closing the lock until a barrier is operational is as close to 100% guaranteed as possible. But TWRA ignores all of this and continually states their plan is the best approach when they admit it will allow the silver carp to reach our lakes. How can that possibly be the best plan?
PLEASE explain this to me and the public how “fighting these fish on the invasion front is the best approach” when that approach allows the silver carp to reach our four silver carp free beautiful lakes. TWRA owes the public a response. TWRA/TFWC will be fully responsible for the devastation of the four Upper Tennessee River Lakes unless they do everything possible to PREVENT the silver carp from reaching the four lakes. As it stands, they continue to “Ignore” all the science, the guidance, the recommendations, silver carp history, and the simplest of ecological principles. Such ecological incompetence is unacceptable and the public needs to know.
TWRA/TFWC needs to work to get the Watts Bar Lock closed temporarily and work to get the most effective barrier in place so the lock can be reopened, and in the meantime work on their recruitment reduction. Why is it so difficult to understand that this is the best possible plan, and a plan that stands an “Excellent” change of saving four beautiful lakes? This is not rocket-science, it is simply ecology. Why do you not understand this? Please accept the facts and earn the legacy of saving the only four silver carp free lakes left on the Tennessee River, instead of earning the legacy of allowing their devastation.
I look forward to your detailed reply.
Dr. Timothy Joseph, Fisheries Biologist |
