Comment from Mike Lint, West Central Bait & Fisheries

When I look at the summarization of the new rule the following are a few of the initial questions of many that come to mind: What is a current Farm level inspection? What is the difference between protected waters and non-protected waters? If a grower has their water basin licensed through the State Competent Authority and the basin is fishless (rotenoned) and spring fed does this constitute protected waters? How can a fish farmer that is raising their fish in unprotected waters comply when it takes no less than 30 days to acquire a VHS test? How long can a veterinarian hold an inspection report? For example; for farmer’s that grow their fish in unprotected waters, could they have all of their fish tested on August 15th, September 15th, October 15th, November 15th, and December 15th. But then hold (not report) the August test until just prior of commencement of shipping say on September 20. Would the farmer be in compliance through January 15th providing the veterinarian sends the new health certificate from the prior month in as they receive them, and signs and completes the 72 hour inspection? Will there be any laws put into place that will provide insurance that the farmer will receive the health certification in a timely matter. And if there is no checks and balances for the health testing facilities will there be provisions in the rule to give the farmer some leniencies if the lab is not timely on the lab tests? Where must the shipment of fish be visually inspected? Example: at the farm in the tanks or can they be inspected at the water basin where the fish were grown? In many cases the fish are shipped the same day or within 12-24 hours of gathering, so for most farmers to comply with the 72 hour rule they will have to increase holding capacity as much as 3 times. Will there be any help available to farmers to provide for larger warehouses, greater water capacity, and water appropriation permits to increased water usage for the holding facility just to name a few of the problems and hurdles they will be faced with? Also in many cases the State Competent Authority may not be willing to appropriate more water for these farmers what should they do? Can APHIS help these farmers work with the Authority to help them achieve greater water appropriation? Are there enough veterinarians that will put their stamp of approval on a visual check of fish health, much less take a farmers word that he has properly disinfected his equipment. It seems as though there is some inherent risk to a veterinarian’s reputation, it concerns me that there will be enough of them to go around that will sign there name to the health of fish. Has APHIS taken this into consideration? What if the farmer can not find a vet that will come every day to their farm to inspect a load of fish, what is the farmer suppose to do then, this will mean certain death for fish already caught in traps that can't be emptied in a timely matter the day this happens.