Crayfish Regulations

There's already enough stressor on the environment without purposefully importating a well documented problematic species. The consequences off establishment are too great. Look at the science.

I, for one, would eat any and all crawfish I imported. Why does it make sense to have rules that punish the majority for the presumed sins (intentional release) of the few? And does that even really solve the problem? Or just punish rule followers? What’s next - oysters?

Absolutely no importation of these. We really need to understand the harm importing, non-native species does. No

This is a complex issue. I appreciate that the food industry intends to be responsible with their importation and use of RSC. I imagine from the perspective of those importing and consuming the concern over introduction in Colorado waters seems like worrying about something they wouldn't allow to happen. However, the history of unintentional species introductions includes many examples of well intended utilization resulting in uncontrollable infestations. In my mind continued importation almost assures an eventual introduction. The fact that CPW has no tools to reverse the results of an introduction of RSC suggests to me that the costs of allowing importation is significant. Are the benefits of this one niche food item important enough to the people of Colorado to warrant the risk? I don't think so.

Unenforceable regulations do nothing to alleviate problems. If you can figure out how to prevent suppliers from shipping live crayfish to CO, stick to your existing regulations and go after the suppliers. I love a boil as much as the next person, but I can catch them locally or live with frozen, boiled crayfish from a Colorado store or shipped from Louisiana. At some point, the gulf states need to figure out how to sterilize crayfish prior to shipping them out of state - that won't happen without economic pressure.
It's already also illegal to release crayfish and other aquatic wildlife in the state. If you can't figure out how to prevent suppliers from shipping to CO, I'd change your unenforceable regulations to allow them into the state and invest your time in public outreach (Don't Let it Loose), make penalties for releasing crayfish very steep, encourage people to turn someone in if they hear of a live release - and let people get their crayfish shipped live to their door and have their crayfish boils. "When there was no meat, we ate fowl and when there was no fowl, we ate crawdad and when there was no crawdad to be found, we ate sand."

Comments regarding Colorado not being suitable for red swamp crayfish are incorrect. The science shows that climate suitable for red swamp crayfish is high for every state in the contiguous US.

https://www.fws.gov/sites/default/files/documents/Ecological-Risk-Screening-Summary-Red-Swamp-Crayfish.pdf

Don't ignore the science.

The red swamp crayfish is currently the most widely distributed crayfish globally as well as one of the invasive in terms of it's ecological impacts.

The science on this matter is clear.
1. People intentionally release live crayfish into rivers and lakes with the hopes that they establish populations. Other comments that crawfish are expensive and thus would never be released are completely false. The fact that RSC is expensive is the exact reason why people release them with the hopes they can harvest them for free in the future!
2. Once established, RSC has devastating impacts on freshwater ecosystems. This is evident from over 30 years of peer-reviewed studies (reviewed in Twardochleb et al. 2013).
- Crayfish are generalist omnivores, and thus, have large effects on both primary and secondary producers (Lodge et al. 1994, Perry et al.
2000).
- Crayfish are ecosystem engineers that increase rates of leaf-litter breakdown and nutrient cycling in streams (Charlebois and Lamberti 1996, Bobeldyk and Lamberti 2008), and their grazing and burrowing can reduce benthic algae and macrophyte cover, producing a state change in lakes and wetlands from clear- to phytoplankton-dominated turbid-water systems (Feminella and Resh 1989, Matsuzaki et al. 2009).
- Coupled with habitat modification, crayfish predation drives declines in diversity and abundances of native invertebrates (McCarthy et al. 2006, Correia and Anastacio 2008), and reduces amphibian populations through predation on eggs and larvae (Gamradt and Kats 1996,
Gamradt et al. 1997).
- Crayfish invasions have resulted in fish declines through predation, shelter competition, and indirect competition for prey (reviewed
in Reynolds 2011).
- Population declines, extirpations, and extinctions of native crayfishes are among the most alarming effects of widespread crayfish introductions (Lodge et al. 2000, Perry et al. 2001).
3. Invasive crayfish such as red swamp crayfish are impossible to control once they are established. In other words, there is no going back.

CPW - please do the right thing. Don't ignore the science. Don't ignore the widespread invasion history of red swamp crayfish and thing that it would not have the same impacts in Colorado waters. Don't ignore the science!

It is ridiculous to prevent the importation of Louisiana crawfish into the state of Colorado. I have been importing La. bugs for years to boil, eat and enjoy not ever knowing there was some absurd regulation against doing do. These crawfish are expensive at over $5.00/ pound, and I would never think about using them for fish bait or releasing them into the wild as they are too expensive and too good to eat. I seriously doubt La. crawfish could survive the cold winters in Colorado anyways. My vote is to repeal this regulation so we can enjoy these delicious shell fish. There’s nothing like a good boil with family and friends.

I love crawfish, there's really nothing that compares to a good boil, however I've learned to never underestimate the depths of the potential human stupidity. No, 99% of people wouldn't dream of tossing expensive live crawdads into the creek, but all it takes is one bonehead to ruin things for the rest of us, just one of those types of people you see on the internet doing something they know they shouldn't because they think it's funny and harmless to break the rules. Coupled with our warming climate and our recent history of obscenely mild winters as compared to previous years, which leads to the potential for them to become invasive later on down the line, even if they couldn't today...
Sadly I can not support the importation of crawdads into our state, delicious as they may be.

I think that the red swamp crawfish should be allowed to be imported into the state live for human consumption. Strange that we have a rule on the books that isn't being enforced and yet hasn't led to the species becoming invasive, let's change the rule to meet the conditions.

Our annual crawfish boil was the highlight to kick off summer until this year and all of our crawfish saw a cooler, and the bottom of a boiling pot of water.

It is unclear as to what is being considered as "the Division’s review of current crayfish regulations" Are you considering a permit system, increasing enforcement, and new rules?

Before changes are made two issues should be addressed/reviewed. 1. CPW appears to "believe" that the red swamp crayfish is the major import - promulgating rule changes without data and understanding the fiscal impact. Clearly the enforcement of the rule is causing economic hardship to business, and it is unclear as to if and to what extent crawfish are invasive and the cost to mitigate. Both pieces should be considered as part of the rulemaking process and I believe are required by state law. 2. Per your spokesperson in the Denver Post article, "state biologists haven’t sampled for the species in more than a decade", so while I do not think CO should be reactive and have to address potentially invasive red swamp crawfish like we are trying to get a hold of the zebra mussel problem perhaps a permit and education campaign is an alternative. I would think if red swamp crawfish were appearing all over the state, wildlife aficionados would be raising concerns to CPW?

I believe that Red Swamp Crayfish should be legally allowed to be shipped to restaurants. Plus to organized licensed vendors

It’s ridiculous that this has been a law for decades & never enforced. Clearly people have been shipping crawfish into CO for years and we don’t have a problem with them invading our water streams. People have instead had fun and enjoyed eating them with friends and family. Focus on something more serious and modify or eliminate this silly law.

No one is going to pay top dollar for Louisiana crawfish and then release them. They are going to get eaten. Come on CPW, you've messed up enough good stuff in the past decade, don't add this to your list. There has to be a way to allow import for human consumption.

People are not buying these crawfish to release in the wild. They are meant to be consumed. I'm ok with registering in order to buy crawfish, but seems like another waste of taxpayer money. Just let us order dem mudbugs so we can eat!
laissez le bon temps rouler!

The crawfish in question are brought in for eating purposes only. The are so expensive to purchase no one is using them bait. They are not grown here, they cannot thrive here.

Please continue to keep crawfish out of our state waters. While I enjoy eating them, I got to the gulf coast and get them fresh. Last thing we need is another invasive species.

Of course these invasive species should not be let in the state. The CPW has opened the floodgates on so many non- native species I can’t believe you are actually asking this question. Will you ever learn?

Frozen crayfish only. We don't need another invasive species.

Please do no introduce an invasive species into our waters. There are always unintended consequences from the introduction of species of plants and animals that are not native to a given environment. The science does not always take into account these unintended impacts. The potential negative consequences to our fisheries is far greater than any economic impact for our state. Please, do not introduce the crawfish to our waters.