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FIFTH SUPPLEMENTAL BRIEF
MUTUAL AID SOCIETY OF AMERICA, INC. 103 Methodist St., Cecilia, KY 42724 Cell) 270-307-4857; Office) 270-862-4537 Skype) 270-872-4493; Fax. 270-862-4379 email) jimmiller5417@gmail.com
August 23, 2011
Mr. Joseph Williams
Associate Regional Counsel
Office of Regional Counsel
USEPA Region 5 (C-14J)
77 West Jackson Blvd.
Chicago, IL 60604-3590
(312) 886-6631(phone)
(312) 692-2965(fax) Email: Williams.Joseph@epamail.epa.gov
Re: Notice of Dispute on behalf of Mutual Aid Society of America, Inc.; Fifth Supplemental Brief, EPA GLNPO-2011-is-2-1356
Dear Mr. Williams: This Fifth Supplemental Brief discusses the location and construction of the Silverfin low-cost, quick-start shipyard which is in lieu of the earlier description of a shipyard. It also gives better insight into the costs of current efforts to eradicate the Asian carp threat to the Great Lakes.
1. SILVERFIN LOW-COST, QUICK-START SHIPYARD LAND SITE (North Shipyard) The proposed site is the 10 acres of “Hugs Landing” in Crystal City, MO, which is zoned M2. We would lease the property including the office and warehouse from Hugs Farm Partnership, owned by Bill Bradley (former Senator and NBA superstar).i We will also attempt to raise funds with which to purchase the site. The site is at the easterly end Hugs Landing Road. There is a very low cost solution to the lack of capital for the traditional shipyard, namely the Silverfin low cost, quick-start shipyard. We would install a crushed gravel “pad” about 224' wide by 560' long plus a ramp into about four feet of river water (at low water level). The westerly portion of this pad would be for the “Assembly Tent” and the easterly foreground would be for the “Assembly Pad” which would front the river and lead to the ramp. The gravel bed for each of these two pads would be about two feet deep and for the ramp about six inches deep. As each ship is completed and launched, it would be moored to pilings in the river. There are some existing pilings in the water about which the depth is probably four to six feet to which the ship could be moored or we could use the anchors. This approach will be seen as one of the “solutions” to the need for a quick start and a low cost, thus attracting grants, guaranteed loans and private investment. The deployment of funds in support of this new approach will cut nearly a year off the time to begin harvesting Asian carp. INITIAL FLEET The initial fleet will need to include:
The 200 scientists who participated in the Task Force report, recommended that the Asian carp threat to the Great Lakes could best be dealt with by depopulation of the fish by use of commercial carp fisheries. To the credit of the State of Illinois, it mustered $2,000,000 in aid of commercial carp fisheries which, one report indicated, resulted in the depopulation of an additional 150 tons of carp. Presumably, the highly eatable fish meat was processed for human food and fish meal for animal feed.
The $2,000,000 produced 300,000 pounds of fish meat and fish meal at a cost of $6.67 per pound (2,000,000/300,000 = 6.6667). This “gift” to the Illinois commercial carp fishing industry and to the few favored sons of Illinois who actually got the grants, gives us a glimpse of the total cost of serious Asian carp depopulation costs, if the Illinois effort is the “model”.
The Carp Catcher's annual harvest of 12,000,000 pounds of fish which would yield about 10,800,000 pounds of carp (12,000,000 x 90%), and would, under the Illinois model, cost the governments supporting such harvest, 10,800,000 x $6.67 = $72,036,000 per year, if the Illinois model were applied to just the Carp Catchers' operation. Even this significant catch hardly addresses the entire Asian carp ecological disaster. We have already seen this disaster visited upon the native fish population of the Mississippi River Basin National Waters. Why wait until it moves north into the Great Lakes and creates havoc in the international waters of two countries?
The Carp Catcher's solution is to build a fleet of three ships, costing, in capital expense $21,500,000 plus the shipyard costs – a one-time cost- which fleet would be harvesting Asian carp over the 50 year life-span of the fleet. Thus, one fleet could in 20 years, harvest 20 x 10,800,000 = 216,000,000 pounds of carp at no cost to any government, but at the cost to the consumer of Silverfin meat and the livestock industry of highly nutritious fish meal. All that is needed at this stage is a “jump-start” for the working drawings so they can be submitted for review and approval by the regulatory authorities – mostly the U. S. Coast Guard.
MASA did submit an application for assistance to the U. S. Maritime Administration for small shipyard assistance. The files for this application have previously been submitted in support of this application for dispute resolution. No response to such application has been received. The gist of the USMA FOA seems to be directed toward purchase new, more efficient steel fabricating equipment for construction of steel ships and worker training on the use thereof.
Once the first fleet is built, then additional replications could be built to accelerate the depopulation of Asian carp in the many rivers and streams of the Mississippi River Basin National Waters. MASA's working drawings and specifications, sources and prices, will be made available at low/no cost to reputable wooden shipbuilders.
Throwing money at a continued stream of studies and miniscule abatement of Asian carp using the Illinois model, is not doing much to address the major issue, that of massive depopulation of Asian carp using a system which preserves the native fish gene pool while harvesting the carp for beneficial use. MASA's application is detailed enough to provide a sufficient basis for a careful, “stages and gates” approach to creating the working drawings and specifications which will be adequate for regulatory review.
The MASA - Carp Catcher's proposed solution has, admittedly, not been studied to death by highly credentialed academicians. The “solution” to this situation is for any of such highly credentialed folks who wish to study the proposal, do so, with our gratuitous assistance, while we are building the ships and getting them into operation as fast as we can. By the time such highly credentialed folks finish their studies, we will have made our first year's catch, sold the fish products and began paying back the recoverable grant made by EPA.
Respectfully submitted, James E. Miller, BA, BS, JD President, Mutual Aid Society of America, Inc. Cc: Michael Russ: russ.michael@epa.gov; Dave Cowgill, Phone: 312-353-3576; Email: cowgill.david@epa.gov' Attachments: CRYSTAL CITY ENVIRONMENTAL – PLATTIN BOAT CLUB pdf KENTUCKY RIVERPORT IMPROVEMENT PROJECT, pdf Sky High: Solar Power [kyosemi sheplar Soar_power_eng.pdf] Wickliffe Port Authority Request for Funding, pdf Letter to Vicki Viniard, Judge Executive, Ballard County, KY, pdf
August 23, 2011
Mr. Joseph Williams
Associate Regional Counsel
Office of Regional Counsel
USEPA Region 5 (C-14J)
77 West Jackson Blvd.
Chicago, IL 60604-3590
(312) 886-6631(phone)
(312) 692-2965(fax) Email: Williams.Joseph@epamail.epa.gov
Re: Notice of Dispute on behalf of Mutual Aid Society of America, Inc.; Fifth Supplemental Brief, EPA GLNPO-2011-is-2-1356
Dear Mr. Williams: This Fifth Supplemental Brief discusses the location and construction of the Silverfin low-cost, quick-start shipyard which is in lieu of the earlier description of a shipyard. It also gives better insight into the costs of current efforts to eradicate the Asian carp threat to the Great Lakes.
1. SILVERFIN LOW-COST, QUICK-START SHIPYARD LAND SITE (North Shipyard) The proposed site is the 10 acres of “Hugs Landing” in Crystal City, MO, which is zoned M2. We would lease the property including the office and warehouse from Hugs Farm Partnership, owned by Bill Bradley (former Senator and NBA superstar).i We will also attempt to raise funds with which to purchase the site. The site is at the easterly end Hugs Landing Road. There is a very low cost solution to the lack of capital for the traditional shipyard, namely the Silverfin low cost, quick-start shipyard. We would install a crushed gravel “pad” about 224' wide by 560' long plus a ramp into about four feet of river water (at low water level). The westerly portion of this pad would be for the “Assembly Tent” and the easterly foreground would be for the “Assembly Pad” which would front the river and lead to the ramp. The gravel bed for each of these two pads would be about two feet deep and for the ramp about six inches deep. As each ship is completed and launched, it would be moored to pilings in the river. There are some existing pilings in the water about which the depth is probably four to six feet to which the ship could be moored or we could use the anchors. This approach will be seen as one of the “solutions” to the need for a quick start and a low cost, thus attracting grants, guaranteed loans and private investment. The deployment of funds in support of this new approach will cut nearly a year off the time to begin harvesting Asian carp. INITIAL FLEET The initial fleet will need to include:
- The Silverfin Fisher (aka Carp Avenger)
- The Silverfin Flayer (aka Carpe Carpae)
- The Silverfin Flotel (aka Carp Ark)
- The USES Silverfin (the U. S. Electric Ship – auto-ferry-cruise-cargo ship)
- The Silverfin Builder (floating work platform/drydock)
The 200 scientists who participated in the Task Force report, recommended that the Asian carp threat to the Great Lakes could best be dealt with by depopulation of the fish by use of commercial carp fisheries. To the credit of the State of Illinois, it mustered $2,000,000 in aid of commercial carp fisheries which, one report indicated, resulted in the depopulation of an additional 150 tons of carp. Presumably, the highly eatable fish meat was processed for human food and fish meal for animal feed.
The $2,000,000 produced 300,000 pounds of fish meat and fish meal at a cost of $6.67 per pound (2,000,000/300,000 = 6.6667). This “gift” to the Illinois commercial carp fishing industry and to the few favored sons of Illinois who actually got the grants, gives us a glimpse of the total cost of serious Asian carp depopulation costs, if the Illinois effort is the “model”.
The Carp Catcher's annual harvest of 12,000,000 pounds of fish which would yield about 10,800,000 pounds of carp (12,000,000 x 90%), and would, under the Illinois model, cost the governments supporting such harvest, 10,800,000 x $6.67 = $72,036,000 per year, if the Illinois model were applied to just the Carp Catchers' operation. Even this significant catch hardly addresses the entire Asian carp ecological disaster. We have already seen this disaster visited upon the native fish population of the Mississippi River Basin National Waters. Why wait until it moves north into the Great Lakes and creates havoc in the international waters of two countries?
The Carp Catcher's solution is to build a fleet of three ships, costing, in capital expense $21,500,000 plus the shipyard costs – a one-time cost- which fleet would be harvesting Asian carp over the 50 year life-span of the fleet. Thus, one fleet could in 20 years, harvest 20 x 10,800,000 = 216,000,000 pounds of carp at no cost to any government, but at the cost to the consumer of Silverfin meat and the livestock industry of highly nutritious fish meal. All that is needed at this stage is a “jump-start” for the working drawings so they can be submitted for review and approval by the regulatory authorities – mostly the U. S. Coast Guard.
MASA did submit an application for assistance to the U. S. Maritime Administration for small shipyard assistance. The files for this application have previously been submitted in support of this application for dispute resolution. No response to such application has been received. The gist of the USMA FOA seems to be directed toward purchase new, more efficient steel fabricating equipment for construction of steel ships and worker training on the use thereof.
Once the first fleet is built, then additional replications could be built to accelerate the depopulation of Asian carp in the many rivers and streams of the Mississippi River Basin National Waters. MASA's working drawings and specifications, sources and prices, will be made available at low/no cost to reputable wooden shipbuilders.
Throwing money at a continued stream of studies and miniscule abatement of Asian carp using the Illinois model, is not doing much to address the major issue, that of massive depopulation of Asian carp using a system which preserves the native fish gene pool while harvesting the carp for beneficial use. MASA's application is detailed enough to provide a sufficient basis for a careful, “stages and gates” approach to creating the working drawings and specifications which will be adequate for regulatory review.
The MASA - Carp Catcher's proposed solution has, admittedly, not been studied to death by highly credentialed academicians. The “solution” to this situation is for any of such highly credentialed folks who wish to study the proposal, do so, with our gratuitous assistance, while we are building the ships and getting them into operation as fast as we can. By the time such highly credentialed folks finish their studies, we will have made our first year's catch, sold the fish products and began paying back the recoverable grant made by EPA.
Respectfully submitted, James E. Miller, BA, BS, JD President, Mutual Aid Society of America, Inc. Cc: Michael Russ: russ.michael@epa.gov; Dave Cowgill, Phone: 312-353-3576; Email: cowgill.david@epa.gov' Attachments: CRYSTAL CITY ENVIRONMENTAL – PLATTIN BOAT CLUB pdf KENTUCKY RIVERPORT IMPROVEMENT PROJECT, pdf Sky High: Solar Power [kyosemi sheplar Soar_power_eng.pdf] Wickliffe Port Authority Request for Funding, pdf Letter to Vicki Viniard, Judge Executive, Ballard County, KY, pdf
i
CARP CATCHERS COOPERATIVE SHIPYARD SITE
small wooden boat yard
Parcels 19-3.0-05.0-1-001-001 19-3.0-05.0-4-001-001 19-2.0-04.0- - -001 Owner Hug Farm Partnership %Hicks 211 N Broadway St Louis, MO 63102
CARP CATCHERS COOPERATIVE SHIPYARD SITE
small wooden boat yard
Parcels 19-3.0-05.0-1-001-001 19-3.0-05.0-4-001-001 19-2.0-04.0- - -001 Owner Hug Farm Partnership %Hicks 211 N Broadway St Louis, MO 63102
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