Last week I attended the “Michigan Asian Carp Prevention Workshop” put on by the state’s Office of the Great Lakes. It was a really solid event with excellent presentations and new information.
The workshop highlighted the significant recent progress on Asian carp, including the:
- Hydrological separation feasibility study by the Great Lakes Commission/Great Lakes – St. Lawrence Cities initiative
- New Asian carp director, John Goss
- Upcoming Asian carp risk assessment facilitated by the Great Lakes Fishery Commission
- New structures to stop carp-carrying floods in the Chicago area and in Indiana.
Unfortunately, even as some progress is being made, the Army Corps of Engineers are opening the door for Asian carp.The Corps seems determined to resist serious consideration of hydrological separation in the Chicago waterway system.
The latest obstacle to shutting the door on Asian carp is the way the Corps is setting up its feasibility study for preventing the movement of Asian carp and other invasive species between the Mississippi River basin and the Great Lakes. Congress passed a law ordering the Corps to conduct that study (called GLMRIS – the Great Lakes Mississippi River – Study). The law (the Water Resources Development Act of 2007, Pub. L. 110-114, §3061(d)) says,
(d) FEASIBILITY STUDY.-The Secretary, in consultation with appropriate Federal, State, local, and nongovernmental entities, shall conduct, at Federal expense, a feasibility study of the range of options and technologies available to prevent the spread of aquatic nuisance species between the Great Lakes and Mississippi River Basins through the Chicago Sanitary and Ship Canal and other aquatic pathways.(emphasis added)
But the study that Congress ordered is not the study the Corps wants to conduct. In the Great Lakes Mississippi River study plan and in public presentations, the Corps says it will assess the feasibility of measures “that could be applied to prevent or reduce the risk of ANS transfer between Great Lakes and Mississippi River basins.” But “reducing the risk” can be pretty minimal – like doing more electrofishing. It certainly isn’t prevention, and it certainly isn’t what Congress ordered.
When I asked the Corps staff at the workshop why they were not following Congress’s explicit orders (and the law) on the study, the staff said that no mechanism can be 100 percent effective in preventing introductions, so they wanted to “lower expectations.” That’s why they added “or reduce the risk” to the purpose of the study.
That’s a pretty significant lowering of expectations – almost to zero. I asked why they didn’t at least say the study purpose was “prevent to the maximum extent possible.” The Corps said they hadn’t thought of that!
Here’s what’s at stake:
Congress has ordered the Corps to evaluate the feasibility of measures that will actually prevent the introduction of Asian carp into the Great Lakes. That assessment would include economic and social factors as well as ecological ones, and it could be that the Corps concludes that some prevention measures are not feasible, or that some measures are more feasible than others.
But the Corps isn’t even willing to live by those rules. Instead, the Corps wants to assess the feasibility of measures that do NOT prevent the introduction of Asian carp… but only reduce the risk of introduction. Virtually any measure can be said to reduce the risk in some way. So the Corps might be assessing the economic and social costs of doing more electrofishing, or more commercial fishing, or improving the operations of the electric fences – all well and good, but none designed to prevent the introduction of Asian carp into the lakes.
And the Corps plans to unfairly compare “risk reducing” measures and their costs to the costs of measures that really prevent the introduction of carp – like hydrological separation. Which ones do you think the Corps will conclude are more feasible? I can answer that question now; we don’t have to spend millions of dollars and wait 5 years for that bad news.
The Corps should obey the law. And we all should hold them to it. Let’s ask the new Asian carp director, John Goss to do just that. Email him at John_R_Goss@ceq.eop.gov.