Comment from Mark D. Dopp, American Meat Institute

September 26, 2006 Docket No. APHIS-2006-0096 Regulatory Analysis and Development, PPD APHIS Station 3A-03.8 4700 River Road Unit 118 Riverdale, MD 20737-1238 RE: Agricultural Inspection and AQI User Fees Along the U.S./Canada Border 7 CFR Parts 319 and 354, Docket No. APHIS 2006 ? 0096 To Whom It May Concern: AMI represents the interests of packers and processors of beef, pork, lamb, veal and turkey products and their suppliers throughout North America. Together, AMI's members produce 95 percent of the beef, pork, lamb, and veal products and 70 percent of the turkey products in the United States. The Institute provides legislative, regulatory, public relations, technical, scientific, and educational services to the meat and poultry packing and processing industry. We appreciate the opportunity to submit our comments on this issue. AMI opposes this rule removing the exemption from inspection for imported fruits and vegetables grown in Canada and the exemptions from user fees for commercial vehicles and air passengers entering the U.S. from Canada for the following reasons. ? Although our members do not export fruits and vegetables to the U.S., some AMI members have shipments of beef and pork crossing the US/Canada border on a daily basis. In 2005 these shipments totaled $2.4 billion - $401 million from the US into Canada and $2 billion from Canada into the U.S.. Delays caused by increased border inspection activity can create significant logistical and other problems, given the perishable nature of many food products and the strict inspection standards they are required to meet. Moreover, delays at the Canada-U.S. border also affect product being transported through the U.S. to Mexico. ? AMI members are responsible for ensuring that the shipments they receive from Canada are secure and that records are maintained and shipments into the U.S. are prior-notified. Given these measures, it is difficult to see how the additional inspection at the Canada-U.S. border at issue can be justified on the basis of alleged bioterrorism risks. ? Increased border inspection and user fees are contrary to many U.S.-Canada bilateral efforts and political commitments to enhance trade and security through better management of the border. Indeed, concerning the trade of food products, this type of unilateral ?emergency? action by the U.S. undermines the work of cooperative projects between the Canadian Food Inspection Agency and USDA?s Food Safety Inspection Service and the Animal and Plant Health Inspection Service. ? The American and Canadian governments should focus on enhancing cooperative efforts to ensure that North America as a whole is protected from more pressing food security issues, namely the elimination of animal and plant disease risks. AMI appreciates the opportunity to submit these comments. If you have any questions or would like to discuss our comments, please contact me. Mark D. Dopp Senior Vice President, Regulatory Affairs General Counsel American Meat Institute