HomeMy WebLinkAboutCOM 1145.129 2012-2014CC i 51r
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November 17, 2014
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TO: Honorable Chair and Members of the Hawaii County Council
"Section 1. Findings" of Hawaii Bill number 318, has NO basis in fact, in actual
practice, scientific data or research, to support these proposed requirements for
the transport and handling of tropical fish, and is highly discriminatory. I strongly
oppose it for these reasons.
IATA, the International Air Transport Association, requires shippers to
"responsibly pack specimens to survive 48 hours in transit". Feeding fish prior to
shipment causes shipping water to become fouled. Ammonia, a product of fish
waste, is toxic to fish and would insure high mortality rates during transit. So, in
order to meet the IATA 48 hour rule, withholding food is "essential to clear the
gut of food to minimize the fouling of transport containers".
The IATA live animal regulations, known as LARS, contains detailed criteria and
recommendations and guidelines which has been developed over decades of
experience involving the transport of hundreds of millions of live animal
shipments. The IATA LARS are the GLOBAL adopted standard and incorporated in
national laws, and prescribed by one or more United Nation's Treaties. Bill 318
would require shippers to violate these regulations, which have long been the
practiced standard in the pet industry.
The Convention on International Trade in Endangered Species of Wild Flora and
Fauna, referred to as CITES, has now adopted the IATA LARS as a substitute for its
own guidelines.
Fish are cold blooded and do NOT require daily feeding. They do, however,
require clean water and oxygen.
It is important to keep metabolic rates of fish at a low level prior to shipping so
that less oxygen will be consumed. This is accomplished by reducing
temperature, combined with cessation of feeding for several days prior to
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shipping. These are guidelines from the APEC Fisheries Working Group, January
1999.
Water requirements for shipping is not a "one size fits all" situation, but varies by
species, pre -shipment conditioning, age, size, and length of transit.
The passage of this legislation will not only limit a fully sustainable trade, but
would prevent the normal and ethical transport between facilities under the best
standards of practical care.
I encourage you to carefully review the written submission of the Pet Advisory
Council.
This bill does NOT support the ethical treatment of aquatic life. In fact, it actually
will have the impact of insuring high mortality rates, and therefore must not
seriously be considered for passage.
Respectfully submitted,
JudM Perino
Small_�usiness owner and Kailua Kona resident for 37 years.