HomeMy WebLinkAboutCOM 1145.027 2012-2014Bill 318 Testimony
Bill 318 Testimony
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Mon 11/17J2014 11:44 AM
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Dear Honorable Members of the Hawai'i County Council, NJ
Please find enclosed herewith our testimony opposing the proposed ordinance amending Chapter 4.
Respectfully,
Chris Buerner,
Quality Marine
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November 17, 2014
Testimony of Quality Marine On County of Hawai'i Bill No. 318 An Ordinance Amending Chapter 4
Dear Honorable Members of the Hawai'i County Council:
While at face value it may appear that the proposed ordinance amending Chapter 4, Article 1,
Section 4 -1 and adding a new Section to Article 41 relating to Aquarium Life, is well intentioned and
beneficial for the survivability of "aquarium life" species during and post transport, there is little to no
data illuminating any validity to the suggestion that current shipping practices of Hawaiian species
specifically lead to injury or death.
Current practices afford species of varying nature and size, appropriately sized transport
containers and water volumes. As importers of Hawaiian sea -life to the mainland, we experience
virtually no mortality on arrival and no appreciable mortality post arrival that would indicate stress -
induced shipping procedures or prolonged fasting of a species prior to shipment. In fact, aquarium
species from Hawaii are noted for their robustness in part due the short supply chain of fisher bringing
catch to an exporter the day of harvest, and exporter shipping within days of receiving the catch. The
short supply chain, coupled with efficient short trans - pacific air transport times does not subject the
shipped organisms to stressors that would result in elevated mortality rates. Suggestions and
indications to the contrary are simply mythical.
If this ordinance hopes to provide improved welfare with the goal to "prevent cutting short the
normal lifespan of aquatic life ", it is clearly limiting in its scope to only afford protections to "aquarium
life ", and specifically, only marine aquarium life. The Section 4 addition while providing guidelines and
theoretical benefits for the treatment of "aquarium life ", also conspicuously discriminates against all
other types of aquatic life, including species harvested from Hawaii's marine environment for any other
use, including for use as bait or human consumption, any and all species of aqua - cultured origins
whether destined for a dinner plate or an aquarium, and all freshwater species, seemingly whether
intended as aquarium life or not. If this ordinance is designed to prevent cutting short the lifespan of
aquatic life, then there are numerous examples of aquatic life not afforded these theoretical life -span
enhancing benefits.
Furthermore, to the specific prescribed prohibitions in the ordinance, a "one -size fits all"
standard is careless and inappropriate. To suggest that a one - gallon minimum requirement for
transport of aquarium life "Saltwater fish, mollusk, crustacean, arthropod, invertebrate..." be
implemented without consideration of an organism's size or biology is a further indication that this
ordinance is a poorly- crafted attempt to harass the marine aquarium trade.
There are numerous published live -fish shipping standards and references that are in direct
contradiction with the benefits this ordinance proposes. These various internationally accepted,
endorsed and even prescribed standards, call for species- specific fasting times of 24 hours or longer,
rather than the requirement to feed all "aquarium life" within 24 hours of transport. Additionally,
packaging requirements are species- specific and meant to ensure that all organisms are packed
accordingly to withstand a 48 hour transport duration in good health. The majority of aquarium species
packaged in Hawaii face either a very short transit to Honolulu, or an average of 10 hour time in transit
to the mainland. We feel strongly that the requirement to feed, although it is not clear how much, nor
how heavily, within 24 hours of transport would very likely adversely affect the health of the organisms,
rather than reduce shipping induced stress and elevated mortality.
The only aspect of this ordinance that we would support would be the provision "intentionally,
knowingly, recklessly, or negligently carrying or causing to be carried in or upon a vehicle or other
conveyance aquarium life within the County in a manner that is likely to result in the injury or death of
the aquarium life." However, the words "likely" and "injury" are tremendously vague and subjective.
We would suggest that in no instance is any fisher or exporter intentionally, knowingly, recklessly, or
negligently transporting aquarium life in a manner likely to result in death, as the purpose and intent of
harvesting and transporting aquarium life is to ensure that it is ultimately alive, resalable, and healthy.
Again, the transportation of any other aquatic life, by any other individual not participating in the
marine aquarium trade in wild- harvested marine aquarium species, for private use outside of the county
is seemingly exempted from demonstrating a similar level of care or humane treatment.
It would appear to the casual observer that this proposed ordinance is a well- intentioned animal
welfare benefit. We believe, however, that it is a discriminatory set of rules with the goal of causing
unnecessary burden, complexity, and financial harm to the wild- harvested marine aquarium life trade.
In fact section 4(C) states specifically that "any government or non - profit agency that specializes in the
state of captivity within the County for education or scientific study" is exempted from affording these
welfare enhancing benefits to the aquatic life in their care. Additionally, aquarium life transiting in the
county, within the airport boundaries are exempted from these welfare benefits. Essentially, only
marine aquarium species, harvested from local waters, destined for private aquariums outside of the
county are afforded the proposed welfare benefits.
A clearer case of discriminatory treatment of both the aquatic life and a specific industry
associated with it could hardly be imagined.
Respectfuly,
G. Christopher Buerner
President, Quality Marine