Comment from Steven Hart, Indiana Soybean Alliance

A Federal policy governing the transportation of fish within the VHS-impacted states will allow for less confusion in the commercial industry; however, several changes need to be made in the interstate movement and import restrictions on certain live fish or this interim rule could prove to be devastating to the commercial aquaculture industry. Many of the rules outlined are currently not feasible. These are outlined below. • Accredited veterinarian – There are few accredited veterinarians and the proposed rules changes will not be feasible without increasing the number of accredited veterinarians to carry out all of these changes. Given the tightness of most state budgets, it is highly unlikely that more accredited veterinarians will be added. • Interstate Certificate of Inspection – Allowing an ICI to be valid for only 30 days will seriously increase the amount of paperwork for both the accredited veterinarian as well as fish producers. An ICI should be valid for at least 90 days, if not longer. The requirements of what is to be reported on the ICI also do not seem logical for the following reasons. - Requiring the accredited veterinarian to visually inspect fish to be transported 72 hours before they leave the facility will not be feasible as each state is already severely limited on the number of accredited veterinarians present. If a facility has a valid VHS test conducted and the results indicate the disease is not present, they should not be required to obtain visual inspection as well. Requiring this unnecessary inspection will just increase the financial obligations of the state as well as the fish producers and will prove to be economically hampering to the industry. If a producer makes 50 to 100 trips per year, how will the accredited veterinarian be able to visually inspect those fish every time they leave the facility? This is simply not feasible. - Requiring a fish producer to report names and addresses of all of their customers 30 days in advance is not feasible and will prove to be an economic hindrance to the industry. Fish producers will often not have this information available until immediately before a sale. Fish producers should be required to report the names and addresses of all of their customers after the transaction is completed. This should be simplified for both the producers and the accredited veterinarian by allowing the producer to submit the names and addresses once per year (at the conclusion of the year would be most logical). Requiring the list of customers in advance will reduce sales and cause a reduction in the industry. • Frequency of testing – Frequency of testing will be an economic stressor to the industry and the current number of required tests is unnecessary for the following reasons. - Secured facility – A facility operating under a secured water source should not be required to test every 6 months. This should be reduced to once per year. VHS testing is cost prohibitive for many producers operating under tight margins and requiring twice a year testing will cause unnecessary economic stress. As long as facilities test negative and bring only negative fish into their facility yearly testing would be adequate. - Unsecured facility – A facility operating under an unsecured water source should not be required to get monthly testing. There has been no evidence of VHS entering commercial aquaculture at this point. Requiring testing every 30 days will force any producer working in unsecured water sources to be under severe limitations. VHS testing takes about 30 days before results are even available, so producers will have to initiate tests before the results of the previous test are even available. This is not logical and will cause economic hardship for producers and likely cause a reduction in the industry. Facilities using unsecured water sources should be required to increase their frequency of VHS testing, but this increase should be limited to every 6 months. Anything more than that will not be economically feasible and cause a reduction in the industry. • Shipping containers – Requiring the cleaning and disinfection of shipping containers to be monitored by the accredited veterinarian is potentially unfeasible depending on the definition of monitoring. If the accredited veterinarian is required to be present and observe the cleaning, this rule would not be feasible. The accredited veterinarian does not have the available time to be present every time a fish producer cleans their shipping equipment. If the required monitoring is the submission of a form signed by the producer that they followed all of the required cleaning and sterilization regulations than that would be feasible. In fact, if the fish producer were to be required to submit the names and addresses of their customers once per year, it would be logical to also turn in their signed cleaning/disinfection forms for each of those shipments at the same time. • Requiring testing between 50 and 72 degrees Fahrenheit – While this testing requirement is scientifically logical, there are a few major hindrances to this requirement that may have been overlooked. - If testing in unsecured water sources is required every 30 days it is unreasonable to expect those facilities relying on ambient temperature conditions to have water temperature conditions that fall within that temperature range year round. Water temperatures will be much lower than that in the winter and much higher in the summer making a producer unable to comply with this regulation. That is why testing in these facilities should be limited to twice per year (spring and fall) when temperatures do fall within that 50 to 72 range. - Requiring indoor recirculating systems to be within the 50 to 72 range is unreasonable. These facilities are designed to provide year round ideal growth conditions for the fish they raise, so water temperature is typically above 72 depending on the species being raised. Requiring these facilities to lower their culture temperature to comply with this rule is unreasonable and will cause an economic hardship to be incurred by the producers using recirculating systems. The economic advantage of recirculating systems can only be achieved by providing year round optimum growing conditions. Because of this, these facilities should be exempt from the temperature testing requirements. If these changes are not made to the interim rule I believe the aquaculture industry in the impacted areas will be forced to endure undo economic hardships and the industry will suffer because of it. At a time when the country needs to be more concerned with the safety and quality of its food supply, seriously limiting the ability of our own farmers to compete in the market does not make logical sense.