Comment from Bill Manci, Fisheries Technology Associates, Inc.

Rules requiring inspection twice per year or within 72 hours of shipment simply are not logistically or economically feasible. As currently structured, most states do not have the public or private fish-health personnel to effectively implement these rules, the benefits of the approach proposed in these rules are not clear or proven, and the financial impact on the industry would be devastating. This is not a reasonable way to protect the common good, and certainly is counterproductive relative to development of aquaculture in the United States--an industry we desperately need in the face of a massive imbalance in trade of fisheries products.