Re: NANFA-- Fwd: Snakehead Final Rule

Christopher Scharpf (
Fri, 04 Oct 2002 18:32:03 -0400

Issue 2: Twenty-one respondents requested that we not list the entire family
of snakehead fishes (Channidae) as injurious, but that we list those species
(up to five species) that are large and cold tolerant. The respondents
stated that the small, temperature-sensitive species used in the aquarium
hobby would not pose a threat in most of the United States because, if
released, they would not survive the cold climates.

Response: We acknowledge that five of the 28 species recognized in the
Channidae family at this time are considered large, approximately 6 are
considered dwarf species, and the remaining species are considered
medium-size snakehead fishes. As we presented in the proposed rule, the
family Channidae contains 9 species that are strictly tropical, 4 can be
considered tropical to subtropical, one is subtropical, 12 can tolerate
tropical or subtropical to warm temperate conditions, one is warm temperate,
and one is warm temperate to cold temperate.

The tropical species would survive in the warmest waters such as extreme
southern Florida, perhaps parts of southern California, Hawaii, and certain
thermal spring systems and their outflows in the American west. The tropical
to subtropical species would have a similar potential range of distribution
as for tropical species but with a greater likelihood of survival during
cold winters and more northward limits. The tropical or subtropical to warm
temperate species could survive in most southern States. The warm temperate,
and warm temperate to cold temperate, species could survive in most areas of
the United States.

Although the tropical to subtropical species of snakehead fishes are not
likely to become established in the northern waters of the United States,
all of the Channidae species, including the dwarf species, are aggressive
and highly predatory. Should a species of snakehead fishes be accidentally
or intentionally released into U.S. waters, the 131 taxa of threatened and
endangered amphibians, fishes, and crustaceans could face additional
threats. Additionally, because snakehead fishes are morphologically very
similar, it would be very difficult for biologists, wildlife inspectors at
entry ports, and law enforcement agents to differentiate among species of

Based upon the aggressive, predatory nature of all species of snakehead
fishes, the fact that one or more species could become established in most
waters of the United States, and the fact that it is very difficult to
differentiate among the species of snakeheads, the Fish and Wildlife Service
has determined that all 28 of the currently recognized species of snakehead
fishes in the Channidae family should be listed as injurious fishes under
the Lacey Act.

Issue 3: Six respondents indicated that most hobbyists and fish keepers are
responsible and know that releasing exotic species into the environment is
dangerous to the environment. The respondents indicated that the responsible
hobbyists should not be punished and all species of snakehead fishes should
not be listed as injurious. Additionally, most of these respondents stated
that an educational campaign should be initiated to explain the hazards of
releasing exotic species into the environment and encourage the proper
disposition of unwanted pets.

Response: The Service appreciates that most hobbyists and fish keepers are
responsible and properly dispose of unwanted pets. It is to the tremendous
credit of hobbyists that snakehead fishes have been imported into the United
States and only a small number have been found in the wild. This rule is not
intended to punish hobbyists; it is based upon the scientific evidence that
indicates that snakehead fishes are aggressive and highly predatory and
therefore threaten the wildlife and wildlife resources of the United States.

It is important to note that individuals or organizations who possessed
snakeheads prior to the injurious wildlife listing in States where
possession of snakeheads is legal will be able to continue to possess them;
however, they will be prohibited from transporting them across State lines.

The Fish and Wildlife Service has initiated a national public awareness
campaign known as Stop Aquatic Hitchhikers! This campaign targets aquatic
recreation users to raise their awareness about the growing aquatic invasive
species problem and to encourage them to become part of the solution in
preventing the spread of harmful, nonnative species. While aquatic
recreation users may not be responsible for bringing these species into the
country, they may inadvertently transport them overland. The Service is
working with State fish and wildlife agencies, conservation organizations,
and the fishing and boating industries to address this issue. The campaign
has a supporting web site with the address: http://

The Service is considering the development of a new campaign similar to Stop
Aquatic Hitchhikers! that would target aquarium hobbyists. This campaign
would be conducted in conjunction with the Pet Industry Joint Advisory
Council, the largest trade association in the United States representing the
pet industry in Washington, DC, and it would focus on raising awareness
about aquatic invasive species, and encouraging aquarium hobbyists to adopt
preventive actions to avoid having unwanted aquarium fish and plant species
become part of our environment. The campaign would be a multi-layered,
voluntary effort, and would encourage aquarium species importers,
wholesalers, retailers and consumers to focus on how the aquarium industry
is a responsible economic sector that collectively values the environment
and seeks to protect it while simultaneously enjoying the benefits of the
aquarium hobby.
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