Hon Anthony Abbott

Member for Warringah

Level 2, 17 Sydney Road, Manly

NSW 2095

Please be aware that the following information is NOT an April Fool’s Joke.
Australia’s environment is in danger of being severely damaged by plans to release a Herpes Virus (CyHV-3) into rivers, lakes and dams in 2018 to control Feral Carp populations.

Image of volunteers struggling to clean up thousands of dead Carp carcasses

Summary:

  • Millions of dead Carp in Rivers within days of virus release
  • Clean-up campaign costing $ Millions, and beyond scope of local Councils, Water Authorities or Volunteers
  • Overseas experts in Biocontrol published warnings to Australia (Nature -Feb 2017)
  • Virus is irreversible and high-risk
  • Unprecedented number of viral particles in the environment
  • Serious risk to global food security
  • Catastrophic ecosystem crashes (Murray–Darling Basin)
  • Risk to human health
  • Success of programme unlikely
  • The Herpes Virus (CyHV-3) is a notifiable disease in Europe, Japan & USA
  • CSIRO, NCCP, NSW DPI and Invasive Animal CRC are not considering options that have less environmental impact (e.g. Daughterless Carp technology, Commercial Fishing, Traps, Exporting Carp as a Food source)

Action Requested:

  • Please do not allow NCCP, CSIRO, NSW DPI and Invasive CRC to progress ‘un-checked’ with this project. Tasmania has controlled their carp population without CyHV-3, using environmentally sustainable methods. We should too!
  • CyHV-3 is not the ‘Magic Bullet’ to solve the Carp problem.

More information available from the following individuals:

  • Gerard McDonaldmobile: 0420 988051email:
  • Martin Rocliffemobile: 0407 475757 email:
  • Bradley Bradleymobile: 0439 839 868 email:

Mr Gerard McDonald
President – Koi Society of Australia
87 Boundary Street, Roseville, NSW 2069

Hon Anthony Abbott

Member for Warringah

Level 2, 17 Sydney Road Manly

NSW 2095

28thMarch 2017

Ref:Intended release of Herpes Virus into waterways by CSIRO, NCCP, NSW DPI & Invasive Animals CRC and the irreversible damage to the Australian Environment

I am writing to you regarding potential wide scale damage to Australia’s aquatic environment. Namely, the intended 2018 release of a Herpes Virus (CyHV-3) into our waterways. This virus (sometimes called Koi Herpes Virus or KHV) has been extensively researched by CSIRO for more than eight years. Whilst tests have proven that CyHV-3 is a potent killer of the Carp in our rivers, lakes and dams, there are still many unanswered questions relating to its safety and the potential environmental damage caused by using this biocontrol agent.

Let me state from the outset that the concerns of the Koi Society of Australia (KSA) stem principally from the environmental impact of CyHV-3 release and not the impact on our own pet Koi. Whilst KSA members are justifiably proud of our pet Koi, we appreciate that our hobby (and Industry) is small and perhaps not overly significant compared to the problem of feral carp in our waterways. There is evidence to show low numbers of Koi are in some waterways and the KSA is strongly opposed to inappropriately released Koi. But more importantly we support eradicating the far more significant numbers of feral Carp that plague our rivers, lakes and dams.

Our research has shown that in Australia and overseas in the USA, Asia and Europe that wild carp populations can be controlled and the carp themselves turned into a resource, rather than a problem. A company in Illinois (Big River Fish Corp.) has secured a $2m US Federal grant and is now catching Carp and selling them to China where the current market for Carp as a food source is 1.2 Million Tonnes per year. Big River Fish Corp. employs 61 staff but more importantly has almost zero environmental impact compared to CyHV-3 release. In Australia, the employment potential from a similar Carp fishing scheme, especially to some of the Aboriginal communities around the Murray Darling Basin would be tremendous. Companies like “Charlie Carp” have already successfully used carp to produce Agricultural Fertilizers, and this type of operation could easily be up scaled.

Australia already has a model for successfully controlling Carp populations using progressive, integrated, environmentally sustainable methods. In Tasmania the Carp Management Program (CMP) was established within the Inland Fisheries Service (IFS) in 1995 and has proven to be phenomenally successful.

The evidence supporting the release CyHV-3 as a biocontrol agent and solution to this problem is far from convincing. The sheer size of the clean-up campaign required is almost beyond comprehension.


Image of thousands of dead Carp carcasses polluting a lake

Estimates put feral Carp as being 80% of the Biomass in some waterways. That means that 80 tonnes out of every 100 tonnes of a River or Lake's biological material could be rapidly turning into putrid dead waste as Carp die off over several days/weeks. Respected WA Aquatic Veterinarian Dr. Richmond Loh stated recently that a single drop of viral water in Lake Burley Griffin, right next to Parliament House, could send belly-up an estimated 10,000 tonnes of carp in a single week. That would be equivalent to a Semi-trailer of dead fish being dumped outside Parliament. Dr.Loh went on to say that "Once the virus is out there there's no going back".

CSIRO, NCCP, NSW DPI and Invasive Animal CRC have repeatedly stated that the clean-up campaign to deal with large numbers of dead fish is a major consideration to the success of the overall project. It seems incredulous that with a potential release date of CyHV-3 in 2018 that the exact costings and methodology for the clean-up are not finalised. The campaign would also need to be ongoing as CyHV-3 will be around for a very long time once released, and one estimate puts the cost in excess of $175million annually. CSIRO, NCCP and NSW DPI originally stated likely costs of $15-30million (in addition to the $15million allocated so far) and also suggested the use of "Volunteers" or even allowing Birds and small mammals to consume the dead fish carcasses. Can you imagine teams of volunteers trying to remove tonnes of dead carp from the most inaccessible areas of the Murray Darling Basin, or the stench of rotting fish carcasses before the local wildlife is able to consume them?

Overseas, experts are also concerned about the planned release of CyHV-3 by the Australian authorities. An article (copy attached) publish in Nature February 2017 titled “Biocontrol of common carp in Australia poses risks to biosecurity” stated the following:

  • KHV is an irreversible, high-risk proposal
  • The planned release will result in the propagation of an unprecedented number of viral particles in the environment
  • The large-scale release of a notifiable disease for biocontrol constitutes a serious risk to global food security
  • In the aftermath of KHV release, millions of tonnes of fish will be decomposing in the Australian rivers, resulting in significant declines in dissolved oxygen, eutrophication, algae blooms, as well as spikes in ammonia and bacteria. We fear this could lead to catastrophic ecosystem crashes, which, given the importance of the Murray–Darling Basin for the country’s water supply, may also pose a risk to human health.
  • Carp Populations can rapidly recover after a population crash, rendering the long-term success of a carp biocontrol programme unlikely.

Representatives from NCCP, CSIRO, Invasive Animal CRC and NSW DPI have stated in public presentations and webinars that the release of CyHV-3 on its own will not reduce Carp populations in the long term. CSIRO state that due to carp fecundity and a significant level of immunity to CyHV-3, carp populations will bounce back and other technologies such as ‘Daughterless Carp’ should be employed. ‘Daughterless Carp’ technology shows some real promise and would have far less environmental impact than CyHV-3 as it reduces numbers over period of time/generations. However, there has been absolutely no research in Australia into ‘Daughterless Carp’ for many years, and the American research has only looked at non-Carp species, so this is a false hope at this stage.

Today date, communication from Matt Barwick of the NSW DPI, the National Carp Control Plan (NCCP) and the Invasive Animals CRC has been delivered as a Marketing and Promotional Campaign, aimed at gathering support for the release, rather than as a Stakeholder Consultation. Therefore, the KSA requests that the proposed release be postponed until there is a thorough of the review of the science and the consultation process.

CyHV-3 (KHV) has created major problems overseas. In South Africa, regular outbreaks are witnessed in rivers resulting in wide scale fish kills and pollution. Locals are warned not to consume the dead carp or the water itself. In Europe, KHV has rendered many lakes unusable for recreational fishing as the virus can be spread by birds, animals or even a Fisherman’s Keep nets etc. In Japan, some commercial Koi breeders and dealers have gone out of business following KHV outbreaks. One owner even committed suicide. Authorities in the USA (which is equally plagued by wild carp) would never consider the use of CyHV-3/KVH due to the environmental impact.

I urge you to please consider the damaging and irreversible impact that CyHV-3 will have on Australia’s aquatic environment. The problem of rising feral carp populations and their impact on native fish species is a massive problem. But CyHV-3 is not the ‘Magic Bullet’ to solve the problem. It is going to take time and hard work to get things under control using traps, commercial fishing, research into 'daughterless carp' technology and development of export partnerships.

Please do not allow NCCP, CSIRO, Invasive Animal CRC and NSW DPI to progress ‘un-checked’ with this project.

Yours Sincerely,

Gerard McDonald
President – Koi Society of Australia

Gerard McDonaldmobile: 0420 988051email:
Martin Rocliffemobile: 0407 475757 email:
Bradley Bradleymobile: 0439 839 868 email:

Extract from Nature - February 20