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October 27, 2006

IDNR asks U.S. Department of Agriculture to reconsider Emergency Order prohibiting importation of certain species of live fish
Order will place undue hardships on Illinois’ aquaculture industry

SPRINGFIELD- Illinois Department of Natural Resources (IDNR) Acting Director Sam Flood, today sent a letter to the U. S. Department of Agriculture Animal, Plant and Health Inspection Service (USDA-APHIS) asking that an Emergency Order put in place Wednesday be reconsidered.   Though there is no evidence that viral hemorrhagic septicemia (VHS) exists in Illinois, the Order prohibits the interstate movement of 37 species of fish from the eight states bordering the Great Lakes due to outbreaks of this virus elsewhere.  The text of the letter follows:

October 27, 2006
Dr. Paul Egrie
U.S. Department of Agriculture
Animal and Plant Health Inspection Service
4700 River Road
Riverdale, MD 20737

Dear Dr. Egrie,

This letter is in response to the Federal Order published on October 24, 2006 by USDA - APHIS regarding quarantine of Viral Hemorrhagic Septicemia (VHS) in the states bordering the Great Lakes.  This Order will place an undue hardship on the aquaculture industry in Illinois.  Estimated direct impacts of the 37 restricted species alone are $2.28 million per year in lost sales revenue for the State.  VHS poses no threat to humans, and even if the virus were located at an Illinois aquaculture facility, it poses little danger for spread to other aquaculture operations. 

If the concern is for transportation of VHS into an aquaculture facility, and it is only located within a known geographic range, then certainly fish being transported out of endemic areas should be suspect.  In fact, Illinois Department of Natural Resources (IDNR) biologists have refused shipments of susceptible fish species from infected areas.

However, quarantine on all shipments from an entire state which has very little area within the Great Lakes basin, and only that in Lake Michigan where VHS has never been detected, is far too restrictive.  This Order will completely eliminate long-established trades of sport fish between state agencies that are crucial to the maintenance, restoration, and enhancement of sport fish programs within and among the identified states.  The task to slow the inevitable spread of the disease is difficult; however, the wide boundaries used in the Emergency Order causes undo hardship to state-owned hatcheries and private aquaculture facilities that in no way further the spread of VHS in their normal operations. 

In approximately six weeks to two months, there will be accepted, standardized protocols for testing and certification that will facilitate shipment of fish from these areas.  If these certifying tests are established and still no VHS-positive fish have been found in the western Great Lakes or elsewhere in Illinois, then the economic impact felt by the Illinois aquaculture industry and Illinois sport fishermen will have been for nothing.  At best, this Order is premature.

There is no indication that Illinois is currently infected with VHS, so there is no reason to list Illinois as an area prohibited from shipping.  Without a “pest or disease of livestock” found in the area, there is no justification for quarantine.  Even if Illinois did have detections of VHS in Lake Michigan, then only the Lake Michigan basin should be affected by any prohibition on export. 

There is no justification for placing a restriction on fish raised in hatcheries or pond systems outside of the Great Lakes basin which have no connection to waters where VHS has been found.

The purpose of the APHIS authority is to prevent economic damage to the livestock industry.  Including the State of Illinois in the Order as a Prohibited Domestic Area does nothing to protect the livestock industry, and instead does irreparable economic harm to the Illinois aquaculture industry.  Further, we feel APHIS made its ruling with little input from the regulated states which shows a disregard for damages caused by the Order.  APHIS has been withdrawn in this decision-making process, and was not forthcoming with their intention to proceed with this Order against the recommendation of many states and the Great Lakes Fish Health Committee. 

Our hope is that these issues can be resolved to provide adequate protection to facilities potentially affected by VHS, and yet not place additional undue burden upon the state hatcheries, the baitfish industry, sport fishermen, and the Illinois aquaculture industry.


Sam Flood,
Acting Director
Illinois Department of Natural Resources


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