Hi Sam,
I always thought this was available only to persons who
suffer significant economic loss, like fish farmers.

That said, I went and read the permit and it does say you
have to really have tried nonlethal means and you have to
continue nonlethal means.

So then I called the number and left a message (past working
hours in Denver) and asked specifically about backyard ponds
and koi keeping.
Also wondering what kind of lethal means would be available to
your average suburban pond owner?

Should be interesting what I hear back!

kathy :-)