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LETTER TO MEMBERS OF U. S. CONGRESS AND GREAT LAKES SUPPORTERS
MUTUAL AID SOCIETY OF AMERICA, INC. 103 Methodist St., Cecilia, KY 42724 Ph: 270-307-4857; 270-307-4857 Fax: 270-862-4379 email: jimmiller5417@gmail.com
December 28, 2011
To Members of Congress and supporters of the Great Lakes Watershed and the Mississippi River Basin National Waters:
Re: Inaction and indifference by U.S. Federal Government to the Asian carp invasion
Greetings:
It grieves me to have to inform you that the U. S. Government intends to allow Asian Carp to invade the Great Lakes Watershed in order to devastate the existing native fish of that watershed and thus bring great injury to the fisheries and tourist industries of both the United States of America and Canada. J'accuse the Whitehouse and especially EPA of these charges, which are as yet not subject to the eye of the Mogul Media and very probably little understood by the supporters of the Great Lakes Ecosystems, especially the fisherfolk of native fisheries therein. As has been well documented over the past decade, the Asian carp species of Silver and Big Head have so overpopulated most of the Mississippi River Basin National Waters (MRBNW) that they have devastated the food chain upon which the native fish depend for their existence. The effect is the same as if these native fish have been “over-fished”. In the Illinois River, 95% of the fish biomass are these Asian carp. A couple of commercial fisheries, based in Illinois, are making a small dent in the population growth of the Asian carp, renamed “Silverfin” by chefs anxious to change the popular distaste for the name “carp” most generally associated with the bottom-feeding common carp. The bottom feeders have a musty taste and many small bones.
There are an estimated several million of Asian carp in the MRBNW. In the event of a major flood in the northern tributary waters, the carp will boil over into the tributaries of the Great Lakes Watershed. One study indicated some 28 pathways the carp could use to infest the Great Lakes Watershed. The electric barrier placed in the Chicago Ship canal, has proven to be only partially effective and ineffective as to the under five inch juvenile carp. Evidence of Asian carp DNA has been repeatedly found in Lake Michigan.
When one looks at the Silverfin population in the MRBNW as an entrepreneur, one does not see the devastation, but a huge economic opportunity now only partially being exercised. The Silverfin is a top feeder of microorganisms and can process 40% of its weight in daily feeding. The meat is firm, white and some say tastes like cod or Chinese Yellowfin Tuna because of the high oil content. It is a premium fish in high demand in Asia. To my charge of studied indifference and outright lies and mis-direction by EPA, I add the cover-up enforced by the EPA General Counsel and the EPA Inspector General. The applicant, Mutual Aid Society of America, Inc., a non-profit Kentucky corporation (MASA) formed as a worker cooperative made an application to EPA in response to its call for innovative proposals to mitigate the threat of invasion by Asian carp from MRBNW into the great lakes. [See: http://carpcatchersco-op.wetpaint.com/page/APPLICATION+FOR+DESIGN+GRANT+-+NARRATIVE+STATEMENT ] Of the 18 applications submitted pursuant to Category II.B.2, MASA's was rated lowest.
The low score attached by the Reviewers to the proposal by Mutual Aid Society of America, Inc. (MASA) put the application at the bottom of the list of 18 applications. The MASA application on behalf of Carp Catchers Cooperative [http://carpcatchersco-op.wetpaint.com ] was the only one which offered massive depopulation of Asian carp (10.8 millions pounds a year) as a method of mitigation of the threat of invasion. The application Narrative Statement could be no longer than 20 pages and the application web intake provision only allowed three attachments (we supplied three resume of the team members). As an attorney with 41 years of law practice and an author of successfully applications for grants, the form of the MASA application hit on all points required by the EPA request for proposals, within 20 page limit for the Narrative Statement. By reviewing the marks earned by the five successful applications, it appear that the “fix” was “in” because those applications were slack of the many requirements by the FOA which EPA admitted.
MASA applied for a “debriefing” which was granted only by telephone and not in writing. The debriefing was vague and never got at the reasoning of the Reviewers which reasoning was kept secret. Despite MASA's Freedom of Information requests for the reasoning, the request for the reasoning was denied by the Region 5 FOIA office, which denial was appealed to the EPA General Counsel, who dismissed the appeal. Bereft of the reasoning, thus not able to attack it head on, MASA filed a massive administrative appeal to the Regional Counsel, Region 5 (Great Lakes):
EPA's point man for the defense by EPA was Michael Russ, who replied in opposition and never set forth the actual reasoning advanced by the Reviewers, except for vague generalities.
MASA replied to Russ' brief; see: Reply by Mutual Aid Society of America, Inc., to EPA Responses to Appeal; http://carpcatchersco-op.wetpaint.com/page/REPLY+BY+MUTUAL+AID+SOCIETY+OF+AMERICA%2C+INC.++TO+EPA+RESPONSES+TO+APPEAL pointing out the inadequacy of Russ's brief.
Associate Regional Counsel Joseph Williams rendered his decision on December 14, 2011, dismissing the MASA appeal. http://carpcatchersco-op.wetpaint.com/page/DECISION+BY+REGIONAL+COUNSEL+DISMISSING+APPEAL Mr. Williams basically repeated Russ's brief. His basic point was that EPA had “procedurally” followed the steps and that he could not second guess the decision of the Reviewers. MASA is now awaiting a copy of the report Williams is required by law to make to the House and the Senate.
MASA tried to engage the EPA's Inspector General by filing a complaint and request for investigation. This attempt was stone-walled by the I.G. See: Nullification of EPA AIS Mission Re: Invasive Asian Carp; http://carpcatchersco-op.wetpaint.com/page/NULLIFICATION+OF+EPA%27s+AIS+MISSION+RE+INVASIVE+ASIAN+CARP . The irrelevant reply by the IG was rejected by MASA which filed this counter-response: Reply to Denial of Request for Investigation by EPA Inspector General: http://carpcatchersco-op.wetpaint.com/page/MASA%27S+REPLY+TO+DENIAL+OF+REQUEST+FOR+INVESTIGATION+BY+EPA+INSPECTOR+GENERAL It was, in retrospect, unlikely that EPA would fund the application for $300,000 to move the design criteria for the construction of three vessels into working drawings so the parts could be sourced and priced and the working drawings and specifications submitted to the U. S. Coast Guard. But we had to try. The three vessels are the Carp Avenger (fish harvester), the Carpe Carpae (the fish processor) and the Carp Ark (the flotel for the crew). These three vessels would be attached in railcar manner so they would all travel, linked together, thus allowing the workers to walk to and from work locations from the Carp Ark.
During the research and writing of the briefs, I discovered factoids which gave a glimmer of insight into the denial of the initial application. EPA had commissioned two major studies of Aquatic Invasive Species, referring to some 130 identified invasive species (AIS), but not mentioning “Asian” or “carp” in either study. I found that intentional omission very telling of the true intent of the EPA. However EPA joined with other Federal and State agencies in two later studies which focused on the Asian carp invasion of the MRBNW and the likelihood of the carp moving into the Great Lakes Watershed. EPA was also aware of a massive study by a TaskForce of multiple agencies and over 200 scientists, and of the positive recommendation that the best way to mitigate the threat of invasion of the Great Lakes was by depopulating the Asian carp by supporting commercial carp fisheries in the MRBNW. All of this information and more was furnished Mr. Williams who declined to examine the issue of the severity of the threat and its widespread potential for devastation of the Great Lakes fisheries and tourist industries. The conclusion I reached was that there was a cabal of high level policy makers in EPA probably reaching into the Whitehouse, which gave lip-service to the threat of the Asian carp invasion but steadfastly refused to fund the commercial depopulation of the Asian carp population in MRBNW.
The 1.5 million spent by EPA for Category II.B.2 (mitigation of invasive species) went for public relations work and some boat washing of boats already in the Great Lakes Watershed, but nothing to actually reduce the carp population in the MRBNW.
The logical conclusion is that the EPA and others in the Federal Government who ballyhoo the “problem” and recommend more “studies”, only have one true intent: Do nothing with the intent of the Asian carp breaching the USACE barrier and populating the Great Lakes Watershed with fast growing, prolific, Asian carp. EPA has the funding and has had the critical information, but refuses to act rationally. Why? Why the “cover-up” of the reasoning of the Reviewers? Why has EPA not issued a request for proposals for the development of commercial Asian carp fisheries? The answer is that such fisheries are the best method of depopulating the Asian carp in the MRBNW and thereby reduce the threat of migration into the Great Lakes Watershed and for that reason, no funding is made available by EPA for a massive commercial carp fishery.
The mind-set of the EPA cabal most likely extends to the Whitehouse and to other agencies of the Federal Government, so further applications by MASA for funding of the working drawings and for construction of the vessels are unlikely to succeed. States are strapped for funding. The private equity market in nearly dead, especially for “innovative” ideas such as the Carp Catcher Cooperative's designs for the commercial fishery. Banks are not in the lending business except to other banks and insiders who use the available funds to buy foreclosed real estate, bankes bused by FDIC, and to invest of off-shore commercial and industrial firms.
Friends and supporters of the Great Lakes Watershed should realize what is at stake here. It is not just the Great Lakes fishing industry and the tourists industry, it is much more. Fish have high protein content. The entire fish has use and value. Since most of our protein other than fish is from animal factories for beef, pigs and chickens, the mega-giant food producers simply do not want the competition in protein from the fishing industry (too labor intensive for them). The “K Street” lobbyists know how to arrange the campaign contributions so that the Asian carp fishery never amounts to any threat to the protein market held by the lobbyists' clients. Thus, the high policy cabal in the EPA/Whitehouse is backed by plenty resources in the form of campaign contributions and the “revolving door” of policy makers most likely making sure that the Asian carp does not become a dinner plate entreé.
We need to build a coordinated group of supporters of both the Great Lakes Watershed and the MRBNW Watersheds, and put pressure on Congress to over-ride the cabal and fund a Federal or group of State agencies which will support the creation of commercial carp fisheries in the MRBNW while there still may be time to take effective action.
Sincerely,
James E. Miller, BA, BS JD
Alternate Link to williams dismissal See: https://docs.google.com/open?id=1ejosOS33x8DbnGD0_Rgrcbh9XWtHi8qDzfA9Q61Yw-Anyj74FFAeFIB2-vrN
https://doc-04-0k-docsviewer.googleusercontent.com/viewer/securedownload/ei3b0kn1175g49dbienht1l232svq3jp/s8g43stonjv6mmjeu8m8u86tlbj5isar/1324928700000/Z21haWw=/AGZ5hq_qPla3qkz-UV0loDqCPRQ8/MTM0NmI5ODBjOWMyMjI2OHwwLjE=?docid=e5e087ed3532b6e4a638314834d7ef99%7Ce3b3fc193850207dcdd4da44664a8821&chan=EgAAACnyyjEreybWfpFLEfsDmUNo7OcgyVfyDNvkOJ0I92Px&sec=AHSqidanUumtvU74b7OGdgWt0ttgMXwx-F4GtYwZ3B5v0pVW-rvNf5xTQ4mVojBlZsq8QxO3RJy8H9D3YxdDrp0Y1WMgqkS70YjytxNJrL15Unq5yGpbAFJzT5xMzCFJ3MDO6Muf3xSyPARtgaKCyTzr1ISRhVZ-yVzqW8T1VF0UoOmeZ3onGtH5DmRGDeFsGQB_06StEfzUNiIRFCNU2BGSzG9KVThgo04YMF-4XXmXlDKWlThPZXr2vAkSL_nrF8WGFumXWmWK_9OJGSKlLZmax8Zr6OsUxqrw3KTTCdWnMHXzGU3JrZW8eVxqFZEXRAryS-YeZ9EVwATonF4Qv5vo4ioTy2SuyPOdnSFpIqLGMu4bm3FAdogzvgb3O8RfjcDhs3BDUQxD&a=gp&filename=20111222093923665.pdf&nonce=685niufv5clh4&user=AGZ5hq_qPla3qkz-UV0loDqCPRQ8&hash=c6ss1qcg1bga6oachmehki1osrj912uh
December 28, 2011
To Members of Congress and supporters of the Great Lakes Watershed and the Mississippi River Basin National Waters:
Re: Inaction and indifference by U.S. Federal Government to the Asian carp invasion
Greetings:
It grieves me to have to inform you that the U. S. Government intends to allow Asian Carp to invade the Great Lakes Watershed in order to devastate the existing native fish of that watershed and thus bring great injury to the fisheries and tourist industries of both the United States of America and Canada. J'accuse the Whitehouse and especially EPA of these charges, which are as yet not subject to the eye of the Mogul Media and very probably little understood by the supporters of the Great Lakes Ecosystems, especially the fisherfolk of native fisheries therein. As has been well documented over the past decade, the Asian carp species of Silver and Big Head have so overpopulated most of the Mississippi River Basin National Waters (MRBNW) that they have devastated the food chain upon which the native fish depend for their existence. The effect is the same as if these native fish have been “over-fished”. In the Illinois River, 95% of the fish biomass are these Asian carp. A couple of commercial fisheries, based in Illinois, are making a small dent in the population growth of the Asian carp, renamed “Silverfin” by chefs anxious to change the popular distaste for the name “carp” most generally associated with the bottom-feeding common carp. The bottom feeders have a musty taste and many small bones.
There are an estimated several million of Asian carp in the MRBNW. In the event of a major flood in the northern tributary waters, the carp will boil over into the tributaries of the Great Lakes Watershed. One study indicated some 28 pathways the carp could use to infest the Great Lakes Watershed. The electric barrier placed in the Chicago Ship canal, has proven to be only partially effective and ineffective as to the under five inch juvenile carp. Evidence of Asian carp DNA has been repeatedly found in Lake Michigan.
When one looks at the Silverfin population in the MRBNW as an entrepreneur, one does not see the devastation, but a huge economic opportunity now only partially being exercised. The Silverfin is a top feeder of microorganisms and can process 40% of its weight in daily feeding. The meat is firm, white and some say tastes like cod or Chinese Yellowfin Tuna because of the high oil content. It is a premium fish in high demand in Asia. To my charge of studied indifference and outright lies and mis-direction by EPA, I add the cover-up enforced by the EPA General Counsel and the EPA Inspector General. The applicant, Mutual Aid Society of America, Inc., a non-profit Kentucky corporation (MASA) formed as a worker cooperative made an application to EPA in response to its call for innovative proposals to mitigate the threat of invasion by Asian carp from MRBNW into the great lakes. [See: http://carpcatchersco-op.wetpaint.com/page/APPLICATION+FOR+DESIGN+GRANT+-+NARRATIVE+STATEMENT ] Of the 18 applications submitted pursuant to Category II.B.2, MASA's was rated lowest.
The low score attached by the Reviewers to the proposal by Mutual Aid Society of America, Inc. (MASA) put the application at the bottom of the list of 18 applications. The MASA application on behalf of Carp Catchers Cooperative [http://carpcatchersco-op.wetpaint.com ] was the only one which offered massive depopulation of Asian carp (10.8 millions pounds a year) as a method of mitigation of the threat of invasion. The application Narrative Statement could be no longer than 20 pages and the application web intake provision only allowed three attachments (we supplied three resume of the team members). As an attorney with 41 years of law practice and an author of successfully applications for grants, the form of the MASA application hit on all points required by the EPA request for proposals, within 20 page limit for the Narrative Statement. By reviewing the marks earned by the five successful applications, it appear that the “fix” was “in” because those applications were slack of the many requirements by the FOA which EPA admitted.
MASA applied for a “debriefing” which was granted only by telephone and not in writing. The debriefing was vague and never got at the reasoning of the Reviewers which reasoning was kept secret. Despite MASA's Freedom of Information requests for the reasoning, the request for the reasoning was denied by the Region 5 FOIA office, which denial was appealed to the EPA General Counsel, who dismissed the appeal. Bereft of the reasoning, thus not able to attack it head on, MASA filed a massive administrative appeal to the Regional Counsel, Region 5 (Great Lakes):
- Notice of Appeal - MASA APPEAL-DISPUTE OF EPA FAILURE TO SELECT MASA APPLICATION FOR AIS
- Protest of award of grants for Category 1.B.2 under EPA GLNPO-2011-IS
- Opening Brief
- First Supplemental Brief
- Second Supplemental Brief
- Third Supplemental Brief
- Fourth Supplemental Brief
- Fifth Supplemental Brief
- Sixth Supplemental Brief
- Seventh Supplemental Brief
- Eighth Supplemental Brief
- Ninth Supplemental Brief
- Tenth Supplemental Brief
- Eleventh Supplemental Brief
EPA's point man for the defense by EPA was Michael Russ, who replied in opposition and never set forth the actual reasoning advanced by the Reviewers, except for vague generalities.
MASA replied to Russ' brief; see: Reply by Mutual Aid Society of America, Inc., to EPA Responses to Appeal; http://carpcatchersco-op.wetpaint.com/page/REPLY+BY+MUTUAL+AID+SOCIETY+OF+AMERICA%2C+INC.++TO+EPA+RESPONSES+TO+APPEAL pointing out the inadequacy of Russ's brief.
Associate Regional Counsel Joseph Williams rendered his decision on December 14, 2011, dismissing the MASA appeal. http://carpcatchersco-op.wetpaint.com/page/DECISION+BY+REGIONAL+COUNSEL+DISMISSING+APPEAL Mr. Williams basically repeated Russ's brief. His basic point was that EPA had “procedurally” followed the steps and that he could not second guess the decision of the Reviewers. MASA is now awaiting a copy of the report Williams is required by law to make to the House and the Senate.
MASA tried to engage the EPA's Inspector General by filing a complaint and request for investigation. This attempt was stone-walled by the I.G. See: Nullification of EPA AIS Mission Re: Invasive Asian Carp; http://carpcatchersco-op.wetpaint.com/page/NULLIFICATION+OF+EPA%27s+AIS+MISSION+RE+INVASIVE+ASIAN+CARP . The irrelevant reply by the IG was rejected by MASA which filed this counter-response: Reply to Denial of Request for Investigation by EPA Inspector General: http://carpcatchersco-op.wetpaint.com/page/MASA%27S+REPLY+TO+DENIAL+OF+REQUEST+FOR+INVESTIGATION+BY+EPA+INSPECTOR+GENERAL It was, in retrospect, unlikely that EPA would fund the application for $300,000 to move the design criteria for the construction of three vessels into working drawings so the parts could be sourced and priced and the working drawings and specifications submitted to the U. S. Coast Guard. But we had to try. The three vessels are the Carp Avenger (fish harvester), the Carpe Carpae (the fish processor) and the Carp Ark (the flotel for the crew). These three vessels would be attached in railcar manner so they would all travel, linked together, thus allowing the workers to walk to and from work locations from the Carp Ark.
During the research and writing of the briefs, I discovered factoids which gave a glimmer of insight into the denial of the initial application. EPA had commissioned two major studies of Aquatic Invasive Species, referring to some 130 identified invasive species (AIS), but not mentioning “Asian” or “carp” in either study. I found that intentional omission very telling of the true intent of the EPA. However EPA joined with other Federal and State agencies in two later studies which focused on the Asian carp invasion of the MRBNW and the likelihood of the carp moving into the Great Lakes Watershed. EPA was also aware of a massive study by a TaskForce of multiple agencies and over 200 scientists, and of the positive recommendation that the best way to mitigate the threat of invasion of the Great Lakes was by depopulating the Asian carp by supporting commercial carp fisheries in the MRBNW. All of this information and more was furnished Mr. Williams who declined to examine the issue of the severity of the threat and its widespread potential for devastation of the Great Lakes fisheries and tourist industries. The conclusion I reached was that there was a cabal of high level policy makers in EPA probably reaching into the Whitehouse, which gave lip-service to the threat of the Asian carp invasion but steadfastly refused to fund the commercial depopulation of the Asian carp population in MRBNW.
The 1.5 million spent by EPA for Category II.B.2 (mitigation of invasive species) went for public relations work and some boat washing of boats already in the Great Lakes Watershed, but nothing to actually reduce the carp population in the MRBNW.
The logical conclusion is that the EPA and others in the Federal Government who ballyhoo the “problem” and recommend more “studies”, only have one true intent: Do nothing with the intent of the Asian carp breaching the USACE barrier and populating the Great Lakes Watershed with fast growing, prolific, Asian carp. EPA has the funding and has had the critical information, but refuses to act rationally. Why? Why the “cover-up” of the reasoning of the Reviewers? Why has EPA not issued a request for proposals for the development of commercial Asian carp fisheries? The answer is that such fisheries are the best method of depopulating the Asian carp in the MRBNW and thereby reduce the threat of migration into the Great Lakes Watershed and for that reason, no funding is made available by EPA for a massive commercial carp fishery.
The mind-set of the EPA cabal most likely extends to the Whitehouse and to other agencies of the Federal Government, so further applications by MASA for funding of the working drawings and for construction of the vessels are unlikely to succeed. States are strapped for funding. The private equity market in nearly dead, especially for “innovative” ideas such as the Carp Catcher Cooperative's designs for the commercial fishery. Banks are not in the lending business except to other banks and insiders who use the available funds to buy foreclosed real estate, bankes bused by FDIC, and to invest of off-shore commercial and industrial firms.
Friends and supporters of the Great Lakes Watershed should realize what is at stake here. It is not just the Great Lakes fishing industry and the tourists industry, it is much more. Fish have high protein content. The entire fish has use and value. Since most of our protein other than fish is from animal factories for beef, pigs and chickens, the mega-giant food producers simply do not want the competition in protein from the fishing industry (too labor intensive for them). The “K Street” lobbyists know how to arrange the campaign contributions so that the Asian carp fishery never amounts to any threat to the protein market held by the lobbyists' clients. Thus, the high policy cabal in the EPA/Whitehouse is backed by plenty resources in the form of campaign contributions and the “revolving door” of policy makers most likely making sure that the Asian carp does not become a dinner plate entreé.
We need to build a coordinated group of supporters of both the Great Lakes Watershed and the MRBNW Watersheds, and put pressure on Congress to over-ride the cabal and fund a Federal or group of State agencies which will support the creation of commercial carp fisheries in the MRBNW while there still may be time to take effective action.
Sincerely,
James E. Miller, BA, BS JD
Alternate Link to williams dismissal See: https://docs.google.com/open?id=1ejosOS33x8DbnGD0_Rgrcbh9XWtHi8qDzfA9Q61Yw-Anyj74FFAeFIB2-vrN
https://doc-04-0k-docsviewer.googleusercontent.com/viewer/securedownload/ei3b0kn1175g49dbienht1l232svq3jp/s8g43stonjv6mmjeu8m8u86tlbj5isar/1324928700000/Z21haWw=/AGZ5hq_qPla3qkz-UV0loDqCPRQ8/MTM0NmI5ODBjOWMyMjI2OHwwLjE=?docid=e5e087ed3532b6e4a638314834d7ef99%7Ce3b3fc193850207dcdd4da44664a8821&chan=EgAAACnyyjEreybWfpFLEfsDmUNo7OcgyVfyDNvkOJ0I92Px&sec=AHSqidanUumtvU74b7OGdgWt0ttgMXwx-F4GtYwZ3B5v0pVW-rvNf5xTQ4mVojBlZsq8QxO3RJy8H9D3YxdDrp0Y1WMgqkS70YjytxNJrL15Unq5yGpbAFJzT5xMzCFJ3MDO6Muf3xSyPARtgaKCyTzr1ISRhVZ-yVzqW8T1VF0UoOmeZ3onGtH5DmRGDeFsGQB_06StEfzUNiIRFCNU2BGSzG9KVThgo04YMF-4XXmXlDKWlThPZXr2vAkSL_nrF8WGFumXWmWK_9OJGSKlLZmax8Zr6OsUxqrw3KTTCdWnMHXzGU3JrZW8eVxqFZEXRAryS-YeZ9EVwATonF4Qv5vo4ioTy2SuyPOdnSFpIqLGMu4bm3FAdogzvgb3O8RfjcDhs3BDUQxD&a=gp&filename=20111222093923665.pdf&nonce=685niufv5clh4&user=AGZ5hq_qPla3qkz-UV0loDqCPRQ8&hash=c6ss1qcg1bga6oachmehki1osrj912uh
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