U.S.D.A. Proposes User's Fee for Quarantine Stations

Clifton R. Witt

Abstract


On August 9 and 11, 1978, the U.S.D.A. proposed interim rules for the implementation of a quarantine station user's fee destined to recover government costs incurred as a result of U.S.D.A. verterinary services provided. These services were previously provided at government expense.

On August 29, 1978, the U.S.D.A. published a proposal in the Federal Register to establish procedures for the collection of costs. The final rule making appeared in the Federal Register September 29, 1978. Of the sixteen comments received the A.F.A. was the only organization mentioned by name.

The new rule requires each quarantine operation to place $10,000.00 on deposit from which the U.S.D.A. may withdraw funds as expenses are incurred. A schedule of fees has been established for the various aspects of veterinary services. Charges of an approximate average of $1 ,850.00 monthly for the attending veterinarian, $11. 76 per laboratory submission, and $5 .50 per hour for guard service will be required. Further, a station owner must sign a written agreement that he will abide by the ruling for each station he operates.

The fee system is expected to replace the 2 .9 million dollars proviously allocated to the importation program and recently cut by the Government Accounting Office. Naturally, consumers, i.e. aviculturists, can expect significant increases in the price of imported birds, particularly finches, less expensive parrots and softbills. Moreover, it is expected that the supply of imported finches will drastically decline since they generally spend extended periods in quarantine compared with psittacine birds.

American Federation of Aviculture has submitted the following comments on the Proposed Rule on Procedures for the Recovery of Costs of Services of Importation of Birds.

This Proposed Rule Making appeared in the Federal Register of Tuesday, August 29, 1978,pg. 38585-87.

A .F .A.' s official comments on this new ruling follow:

The American Federation of Aviculture is dedicated to the conservation of Bird wildlife through captive breeding programs. The impact of this proposed rule will have a significant effect on all aviculture in the United States and it is therefore proper that our comments be heard.

Our first observation is that the structure of the contract and the fee schedule works in opposition to the USDA mission to protect the poultry industry from diseases, primarily WND. It does so by encouraging smuggling by increasing bird prices. It does so by making birds that once were not profitable to the smuggler, now worthy of ms consideration. It makes buying from the smuggler more attractive both in terms of price and availablility. The smaller, inexpensive, birds could easily dissappear from the legal import price lists. Aviculturists interested in breeding populations of these birds will be faced with only one source from which they can acquire new stock - the smuggler. The battle against smuggling is already difficult as it is. To eliminate or certainly reduce the number of sources for certain species will make it that much more aggravating and dangerous.

Our second observation is that the requirement of a deposit equal to the expected fees for two lots of birds will force out the smaller quarrantine stations leaving the bird import business to a relatively few people who can maintain that amount of money on deposit with the Deputy Administrator at all times (if there is to be the normal turnover of lots of birds that they have come to expect without long periods of empty stations while the deposit is replenished.) In this manner the proposed rule is discriminatory agains the small businessman. It creates a block to free enterprise and leaves a multi-million dollar industry in the hands of just a few people. This would return us to the situation of three and a half years ago when bird prices were very high and very attractive to the smuggler. While the proliferation of quarrantine stations presented some problems for APHIS in terms of personnel and management, it had the very positive effect of creating competition and depressing bird prices. It also had the positive effect of making every bird lost more significant financially and every bird in poor condition harder to sell, thereby bringing about better conditions and treatment for the birds in the station. Without competition we can possibly expect to see inferior birds at higher prices.

Our third observation is that a major effect of this users fee system will be to reduce or even eliminate certain avian species from the North American market. The inexpensive birds we refer to as "finches" will suddenly become too expensive for the average aviculturist and consequently will be avoided by the importers. This we see as tragic since we are on the verge of an era when these birds will become established in captive breeding programs. The last few years have seen many more people working hard to learn the requirements of these birds for propagation. We realized some time ago that the days of the cheap source for large members of the finches were coming to a close as their native habitats are systematically destroyed and we realized that we must establish domestic captive populations. Much progress has been made toward that end, but the captive population is still too small for many species. This proposed rule could mean an end to their imports.

These small, inexpensive, birds also are largely responsible for the initial interest a person takes in bird breeding. New people coming into aviculture are logically attracted to these less expensive birds as a first step and from there, their interest grows and many enter into aviculture. This proposed rule likely will close the door to most new comers to aviculture - an intolerable situation with its own set of obvious negative effects.

A fourth observation concerns the manner in which USDA went about bringing this users fee system into being. At this point, AFA fully realizes how difficult it will be to regain funding for the bird quarantine program. True, it has been presented as a Proposed Rule with the appropriate comment period. The comment period in this case, however, is a farce, of sorts, since the changes that can be brought about are minimal and the comments in no way can effect a cancellation of the fees to be charged. We feel that APHIS officials failed to present a strong case for continuation of funding of the quarrantine program to the Office of Management and Budget to prevent OMB from stripping out the money to run this program (a sum so small, in the larger picture, that it could easily have been retained). If APHIS was unwilling to present the case, A vicultural interests should have been notified immediatly so that we could have worked through our Congressional...


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