But in general we need some kind of regulation.
The Import of Live Fish (England and Wales) Act 1980 does make it a statutory offence to release Oryzias species in the UK. It doesn't matter whether you are a license holder or whether you did it accidentally, the law is already quite strict, even excluding
mens rea as a defence when committing environmental damage. Although, if you can find the specific statutory order that mentions this species and informs this act, then you have done better than me.
Everyone:
The problem that <
I often suffer from> is that this is not very clear.
Oryzias latipes is at least on the DEFRA website as a "pest" - this time around. But lets be clear, I can find no guidance, no searchable website results nor scientific literature, and nothing on the GB Non-native Species Secretariat (NNSS) website about this species. How well the government, NNSS, CEFAS, and the Fish Health Inspectorate have actually communicated on these risks is summarised as one re-tweet on Twitter, and a re-post on Facebook. I simply think that Ornamental Aquatic Trade Association Limited drummed-up the press. Where is the risk assessment, where are the facts??
This is precisely hysterical, because it's all either very poorly thought-out or simply badly communicated. They may still have a severe magnitude of impact on UK ecosystems/biodiversity, but at the moment decisions are centred upon the "
precautionary principle". The implied risk being, that a tub or pond in somebody's back garden could get flooded and wash into a nearby watercourse, or that eggs transmit via birds feet etc. The implied consequence - that they are an "invasive" species. Well I do not see them included in schedule 9 of the Wildlife and Countryside Act 1981. I'm especially baffled by this interpretation. Outside of Dominic Whitmee from Ornamental Aquatic Trade Association Limited - who else has indicated that this species could even become invasive? Statements need to have some veracity, and if not, a level of authority. Where is the work on Oryzias? I would hope that some degree of risk assessment would have been publicised by now - or perhaps I missed that memo. Perhaps I am a buffoon, but it would be nice to know what the hoo-ha is all about. If it is "invasive", then it would need to be capable of spreading, presumably at a momentum faster than slow treacle. This is the part I never got about The Day of the Triffids.
It's not that necessary that UKAPS (or Tim for that matter) needs to be dragged into this debate. If members want to contact one of the relevant parties and let us know why a position needs to be established, then be my guest. I don't mind supporting a poll that expresses some sort of communal viewpoint if somebody wants to do this on another thread. It would be great if somebody could author an article explaining these issues first, with a risk assessment, if it is plausible and well-evidenced. Terms of reference could include whether the species predates on fish eggs and fry, what could predate upon it, survivability, reproductive potential, pathways for spread, mechanisms for control etc. Not easy work, and again, if serious conservation ecologists had looked at this species then there would be at least some evidence coming to light by now. Yes it is potentially illegal to allow them to be released, but the
UKAPS rules and guidelines do not need to be revised just to tell us to follow every law that exists. This is not my website. It is offered free and maintained by the hard work of people like Tim. I don't think it is necessary to generate debate when it is suppositional, adversarial, and has no intended outcome. Please believe me, from the bottom of my heart, I would love to see more work on this topic and on conservation or biosecurity as a whole. It is something I am already studying in my own time and would be worth the merit of investigating, because as has been pointed out, we cannot rely upon the government to resolve environmental issues on their own.