Comment from Lawrence Cleveland

Document ID: APHIS-2006-0107-0011
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: September 24 2006, at 07:36 AM Eastern Daylight Time
Date Posted: September 25 2006, at 12:00 AM Eastern Standard Time
Comment Start Date: August 30 2006, at 07:23 AM Eastern Standard Time
Comment Due Date: October 30 2006, at 11:59 PM Eastern Standard Time
Tracking Number: 801cdf18
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We are a producer of goldfish and koi with two fish farms, one in Missouri and a second in Indiana. Our business has existed for over 80 years and employees over 65 people. 1. We must have protection from SVC as it would devastate our business and that of the industry here in the United States. It also represents a huge potential liability to our government if it is to indemnify all farmers for losses that may occur due to the presence of SVC on their farms. 2. We do not import fish as a normal practice in order to operate our breeding operation. However we do occasionally import new blood lines to cross with our existing lines to improve the quality of our fish. We only do this once every 5 years or so. On those occasions we do not directly pass on the cost of that shipment to our customers. 3. We agree that this rule will encourage goldfish and koi wholesalers who currently do import a certain amount of their stock to purchase more fish domestically. This will encourage the sale of more domestic goldfish and koi which will benefit domestic producers; however the real benefit to these domestic growers will come in reduced risk of SVC infection, not in added sales. 4. I believe strongly that there will be considerable abuse of the methods used to obtain the health papers necessary for the importation of all of the SVC susceptible fish from the government officials in the exporting countries. Many of the exporters will obtain these papers and perform these SVC bi-annual tests in a way that will be of little value and offer us very little real protection. 5. Nevertheless, I do support the interim rule as written.

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