Pugnose minnow plan: Line…

Numéro du REO

019-7741

Identifiant (ID) du commentaire

95455

Commentaire fait au nom

Individual

Statut du commentaire

Commentaire

Pugnose minnow plan:
Line 130 - you reference Black Redhorse instead of Pugnose minnow
Line 126 - you have an extra 'd' after e.g.
Line 79-81, 207 - incidental harvest - how is it not already known the incidental harvest of ALL non-target species by baitfish operators? This should be a basic concept already assessed as conditions of baitfish harvesters to perform their actions. Also, what is the response if you find that there is incidental harvest? Will you require harvesters to use different areas? If not, knowing about incidental harvest is pointless because you wouldn't be mitigating the threat (which again, how can you not know about this already? Why wait until a species is listed before trying to figure this out? It's way easier to prevent listing than to try to fix things when a species is critically low.)
Line 207-208: why include climate change and severe weather? You can't control either of these things, so in essence it's a waste of resources to model how they affect Pugnose minnow - they'll either happen or not, but there's nothing you can do specifically about either event.
Line 216 - isn't this a basic requirement of having a plan? If you can't mitigate the threats, they will continue at their low levels or continue to decrease.
Line 219 - 'captive rearing' is synonymous with hatcheries, and hatchery-raised fish almost always result in negative effects on the population they're released into. From artificial hatchery-induced selection, to epigenetic hatchery effects, to reduced genetic diversity, to removing mate choice - the negative effects of hatcheries are many fold.
Line 233 - you're essentially saying you're going to tell farmers about this fish and that will fix the problem. That's ridiculous. Education has been happening for multiple species for decades. It hasn't worked. You need regulations.
Line 171-173 - Again, how has this not happened already? There are multiple aquatic species already listed, most (if not all) have these items as threats. What will you do differently here? It sounds nice, but is a weak statement. How EXACTLY will you reduce say runoff of fields in a new way that will actually increase effectiveness, since the current rules are obviously not working?