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• <br />• <br />• Implementation of all aspects of these procedures require assurances that certain criteria <br />are met. It is unclear when stocking fish under Table I criteria whose assurance will be <br />required or accepted,. how it will be obtained, and who will fund such a process. <br />• The procedures mandate identification of vertical location or elevation of a potential fish <br />planting site in the floodpIain of designated critical habitat without identifying a procedure <br />or process. <br />• Elimination of biological pest control agents such as tripioid grass carp and mosquitofish <br />will require greater application of pesticides to affect the same level of pest control. The <br />procedures encourage greater ecological risk of pesticide application, increased monetary <br />investment in pest control, and greater requirements for labor in pest control. <br />• The complexity of the procedures are generally beyond the expertise or interest of private <br />landowners. Additional services (at additional cost) will be required by landowners to <br />obtain understanding and compliance. <br />• Private landowner actions that trigger proposal review require an untenable time <br />constraint (I 20-210 days) and will serve to eliminate some fishery management <br />alternatives otherwise available to landowners. <br />• The procedures require landowners to determine whether their- proposed activities require <br />federal action and therefore require a section 7 consultation under the authority of the <br />Endangered Species Act. This will not occur given the level of understanding the public <br />has of the Endangered Species Act and its specific requirements and may cause a failure <br />to comply with the procedures.. <br />Policy mitigation recommendations for private landowners <br />u <br />• Develop a short, easily understood stocking policy explanation and implementation cazd <br />tazgeting private landowners and private five fish suppliers. Distribute this card to state <br />wildlife management agencies, aquaculture industry regulatory agencies, and private live <br />fish suppliers. These individuals could use the card to facilitate understanding and <br />compliance at points of sale and interested inquiries. <br />• Complete a structured, reasonable, and transparent risk assessment process for non-native <br />fish stocking in warm water habitats within and adjacent to designated critical habitat. <br />Example of risk assessment methodology: Aquatic Nuisance Species Task Force: RAM - <br />IntentionalIntroduction of Nonindigenous Fishes. <br />