Official Public Comment: Government Plan to Stop Asian Carp

Posted on September 20, 2017 by

On Monday, August 7, the U.S. Army Corps of Engineers released a draft plan for how to protect the Great Lakes from invasive Asian carp. It examined options for bolstering defenses at a lock and dam structure near Joliet, Ill.—officially called the Brandon Road Lock and Dam—which is a choke point between the current habitat of Asian carp and the Great Lakes.

The draft study was ready for release in February, but the Trump Administration delayed its release for five months. The live capture of a silver carp on the Lake Michigan side of the electric deterrents in June, combined with Bi-partisan Congressional pressure and public outcry, forced the Trump Administration to release the study.

Below is Freshwater Future’s official public comment, submitted to the Army Corps on September 20th, 2017. 

You can read more about the study and submit your own public comment here

The Stop Invasive Species Act of 2012—incorporated and approved as an amendment to the omnibus transportation bill passed that same year—directs the Secretary of the Army to “focus on…the prevention of the spread of aquatic nuisance species between the Great Lakes and Mississippi River Basins, such as through the permanent hydrological separation of the Great Lakes and Mississippi River Basins.” The Act was passed to clarify the timeline and purpose of the Great Lakes and Mississippi River Inter-basin Study (GLMRIS) first requested in the Water Resources Development Act of 2007. Neither Congressional directive instructs the Secretary to privilege, or even to focus on, the costs or impacts to navigation in the Great Lakes and Mississippi River Interbasin Study (GLMRIS).

Thus it is concerning that the Army Corps of Engineers declined to recommend lock closure, which was calculated to reduce the risk of establishment to just 2%. Rather, if fully implemented, the Corps’ recommendations will still carry an estimated 13% probability that the new barriers will fail and allow silver and bighead carp to establish breeding populations in Lake Michigan.

The language handed down by Congress makes clear that the top priority should be preventing the movement of invasive species between the basins, not reducing risk to a level deemed acceptable by the Army Corps for the shipping industry. The public and the Army Corps should not underestimate the industry’s ability to employ technology and efficiency measures to overcome any challenges posed by lock closure. Additionally, at the present, the potential for a $318 million burden on the shipping industry has been privileged over the potential for severe damage to other Great Lakes industries: a $7 billion fishing industry, a $16 billion recreational boating industry, and an $18 billion hunting and wildlife observation industry.

Restoring the natural division between the Mississippi River Basin and the Great Lakes is the necessary action required to prevent the spread of invasive species between the two. The severe economic and social disruption that will follow Asian Carp establishment in Lake Michigan is justification enough.


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Images courtesy of Steven Huyser-Honig,
West Grand Boulevard Collaborative, & Yellow Dog Watershed Preserve.