Bluetongue - Analysis of Submissions

Consultation paper reviewing CFIA's import policy for bluetongue for ruminant animals imported from the United States

• Consultation Paper: An overview of bluetongue and assessing the risks for Canada
• Reviewing the Canadian Food Inspection Agency's import policy for bluetongue [and anaplasmosis] for ruminant animals imported from the United States

June, 2006

Summary

In total, twenty-eight (28) written submissions were received consisting of twenty-one from various organisations or industries within Canada and four from the United States together with two private individuals and one company in Canada. The comments received reflected a spectrum of views ranging from fully supportive (18), supportive subject to addressing specific concerns (3), un-stated positions with some concerns (5) and opposed (2). It is worth noting that one of two submissions opposing the proposal was from the Province of Manitoba and that subsequent discussions with the CFIA have allayed their concerns.

The comments fall into several broad categories and include concerns about the potential loss of Canada's bluetongue free status and the impact on exports of breeding animals, semen and embryos (7); concerns about the size, scope and management of the indemnity fund proposed by the Canadian Cattlemen's Association to cover death losses in sheep (2); concerns that CFIA would no longer impose controls on any bluetongue incursions if and when they were to arise in the future (2); and, concerns that insufficient time was allowed to enable meaningful consultation to be undertaken by Provincial governments at a provincial level with industry and wildlife interests (2).

Submissions received

Table 1 categorizes the twenty-eight (28) submission received during the comment period according to their source, which can be divided into six broad groups: Canadian Federal Government (1); Canadian Provincial Government (6); Canadian organizations and industries (14); private individuals and companies in Canada (3); U.S. organizations and industries (3) and U.S. State government (1). Table 2 groups the submissions into four categories according to the level of support expressed. These categories are fully supportive (18), supportive subject to addressing specific concerns (3), un-stated positions with some concerns (5) and opposed (2).

Table 1: Source of submissions

Table 2: Written submissions on bluetongue grouped according to their level of support

* It is worth noting while the written submission from the Province of Manitoba indicated that they were opposed to the proposal, subsequent discussions with the CFIA have allayed their concerns.

1. Fully supportive

1.1 Alberta Agriculture, Food and Rural Development (AAFRD)

AAFRD "applaud CFIA's efforts in moving forward on this disease issue, as it has become a major irritant for the cattle industries in both Canada and the U.S." and "express support for the proposed changes". AAFRD "believe that the risk … is extremely small and the economic benefit … outweigh the cost associated with the potential introduction of BT to our sheep and deer populations". CCA's proposed indemnity fund "demonstrates that the industry that stands to gain … is not gaining at the expense of the industries that could suffer economic losses and would go a long way in gaining support from other stakeholders". AAFRD offer the resources of the Alberta Veterinary Surveillance Network and other staff to assist with bluetongue surveillance and research work.

1.2 Alberta Beef Producers (ABF)

ABF state that they are "the largest provincial cattle organization representing over 35,000 beef producers, from breeders to cow/calf operations, backgrounders, feedlots and beyond". They support the CFIA's proposed bluetongue revisions on the basis that the "risk of bluetongue is negligible", the CCA will indemnify death losses in sheep and possibly other ruminants, and that "the risk BT poses to Canada's livestock industry is insignificant compared to the damages due to the restriction of normalized trade with the U.S."

1.3 British Columbia Cattlemen's Association (BCCA)

BCCA state that they represent the interests of 1,400 cattle ranchers in B.C. They believe that the research and review undertaken by the Canadian Cattlemen's Association (CCA) supports the CFIA's proposal and indicate that the sooner the issue is resolved, the sooner trade between the U.S. and Canada will be normalized.

1.4 Canadian Bison Association (CBA)

CBA supports the CFIA's proposed bluetongue revisions based on their understanding of the issue and the scientific findings summarized in CFIA consultation paper. They also support enhanced surveillance and ongoing vector research and indicate that the proposed changes should move forward as quickly as possible.

1.5 Canadian Co-operative Wool Growers Limited (CCWG)

CCWG state that they are a "national sheep organization representing every province and region in Canada … responsible for marketing over 80% of the Canadian wool clip each year" and that "many of the directors of CCWG are also members of the Canadian Sheep Breeder's Association". They are "fully supportive" of CFIA's proposed bluetongue revisions indicating that the "scientific facts… justify the conclusions reached". CCWG take issue with the Canadian Sheep Breeder's Association's (CSBA) comments on the CFIA's proposal believing that those comments "are more the personal view of [the CSBA President] and not the collective conclusion reached by all members of CSBA". Based on the "many response received" by CCWG, it is believed that CSBA is "looking out more for a small group of purebred producers who desire to export genetics" and who are "less concerned with the larger part of the industry representing both purebred and commercial producers who want to maintain and expand our own national industry within Canada" and " need importation of both market and breeding stock".

1.6 Flater Veterinary Services, British Columbia

This submission was from a veterinarian practicing in the Okanagan Valley in B.C. who is involved in beef cattle exports. He believes that any negative effects associated with exporting live cattle, embryos and semen to bluetongue free countries would be outweighed by the advantages of normalizing trade with the U.S.

1.7 Health and Social Services, Government of Yukon

The Province of the Yukon "feel that the proposed changes will provide sufficient protection for Yukon livestock". No other comments were provided.

1.8 J.C. Matheson Livestock, Ontario

This Canadian company is apparently involved in the export of cattle to and the import of cattle from the U.S. and Mexico and is "in favour of lifting bluetongue restrictions". No other comments were provided.

1.9 Manitoba Cattle Producers Association (MCPA)

MCPA state that they represent "12,000-plus producers involved in various aspects of the beef cattle industry, including the cow/calf, backgrounding and finishing sectors". They support CFIA's proposed bluetongue revisions and "believe that the CFIA's research related to bluetongue - in addition to protecting the health of livestock - will also help to resolve some of the long-standing trade issues between Canada and the U.S."

1.10 Nova Scotia Agriculture (NSA)

NSA is "supportive of the CFIA's position to make bluetongue an immediately notifiable disease rather than a reportable disease". NSA forwarded the consultation paper to several provincial industry organizations: the Nova Scotia Cattlemen's Association, the Dairy Farmers of Nova Scotia and the Sheep Producer's Association. Responses were received from both cattle organizations who indicated that their respective national organizations would be responding to the CFIA.

1.11 Ontario Association of Bovine Practitioners (OABP)

OABP is in "complete agreement" and state that "annual sentinel studies, the very low likelihood of spread and the chance of improving the USDA's decision to once again open their borders to the movement of cattle over thirty months of age are all good reasons". They provided one specific comment in relation to the proposal:

• OABP "strongly encourage" the CFIA to carry out annual sentinel studies, which they hope "will ensure our excellent health status in the face of relaxed BT restrictions".
  • CFIA response: As discussed in the consultation paper, the CFIA proposes to enhance its surveillance activities for bluetongue, which are currently undertaken every three to four years, by moving to an annual surveillance program that will incorporate sentinel animal monitoring at strategic locations across Canada as well as testing of animals in the fall, at the end of the vector season. The CFIA will also continue to support ongoing vector research and risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or to identify changes in risks at an early stage.

1.12 Saskatchewan Stockgrowers Association (SSGA)

SSGA stated that although CCA speaks as one voice for the beef industry, in a policy as important as this they felt it was important to submit a letter of support "in addition to CCA's letter". They are "confident that the risk for Bluetongue is negligible for all species in all regions of Canada" and that "the risk is much larger" for delays in resuming "normal trade relations for all classes of livestock" with the U.S.

1.13 Western Canadian Association of Bovine Practitioners (WCABP)

WCABP state that they represent "approximately 300 veterinarians in Western Canada who are dedicated to, or have a special interest in, beef cattle production". They indicated that the scientific rationale outlined in the consultation paper for supporting change is "very compelling"; that they are satisfied that CFIA "has done its due diligence on this issue"; and that they "support, without reservation, the changes being proposed". WCABP believe that the proposal is "extremely timely because it coincides with the rule making process and hopefully the adoption of Rule 2" and that it demonstrates to "the U.S. and our other trading partners that Canada is committed to revising policies if and when new scientific data supports the need for a change".

1.14 Wildlife and Landscape Science Directorate, Environment Canada (EC)

EC states that "based on the clear and complete information provided on the ecology of bluetongue virus … the proposal … is scientifically sound". EC adds that "the risk of spillover (from infected cattle to midge to wild ruminant) … and the risk of persistence in wild populations even if spillover occurred appears to be low".

Submissions from the United States

1.15 Department of Agriculture, State of Washington (WSDA)

WSDA "compliments the Canadian Food Inspection Agency on their decision to review the anaplasmosis and bluetongue import requirements based on science" and adds that "this is in the spirit of cross border cooperation".

1.16 Montana Wool Growers Association (MWGA)

MWGA "receive this news with high regard" and "do not feel" that quarantining and testing for bluetongue "is necessary". They expressed concern about "unwarranted effects restrictions may have on trade".

1.17 National Cattlemen's Beef Association (NCBA)

NCBA state that they are "the largest organization representing America's cattle industry" and "fully support" the CFIA's proposed bluetongue revisions and indicate that they are "a real breakthrough". They claim that "Canada's bluetongue related import restrictions have been a real obstacle for U.S. cattlemen for many years" and state that "NCBA has made it a top priority to ensure that our cattlemen have fair access to the Canadian market, for both feeder and breeder cattle".

1.18 Washington Cattlemen's Association (WCA)

WCA "strongly supports the recommendation of the CFIA regarding bluetongue". They state that "non-tariff barriers pertaining to bluetongue have caused substantial economic loss because of their adverse impact on animal movement and trade, particularly that of cattle and germplasm" and that when finalized the policy "will facilitate better relations between Canada and the U.S.".

2. Supportive subject to addressing specific concerns

2.1 Canadian Beef Breeds Council (CBBC)

CBBC "continues to be supportive of the proposal" and "believe the available science indicates that the risk of Bluetongue incursion and establishment is low and acceptable". They "commend the CFIA for the initiative in presenting a discussion that has historical context, is comprehensive, balanced, scientifically justifiable, and refreshing". They "hope" the indemnity fund proposed by CCA "will be favourably received by that [sheep] industry". Several questions and comments concerning the proposal were provided:

• Will the surveillance program include susceptible wildlife species as well?
  • CFIA response: Since cattle are more frequently infected than other species, as the midge prefers to feed on them and they are the natural reservoirs and main amplifying host for the bluetongue virus, the focus of the CFIA's surveillance program will be on cattle. This is consistent with surveillance programs in other countries.
• CBBC want to ensure that animals imported from the U.S. are individually and uniquely identified.
  • CFIA response: Under the Health of Animals Regulations all cattle imported into Canada, other than those destined for immediate slaughter, must have a Canadian Cattle Identification Agency (CCIA) approved and registered tag applied. Information including the tag number and the origin of the imported animal are recorded in CCIA's database.
• CBBC are concerned about possible disruptions to exports of breeding livestock and germplasm, particularly from the Prairie provinces and B.C. as export certificates have been negotiated on the basis of Canada being bluetongue free. They would like to be consulted on this issue and suggest that the Beef Cattle Producers Advisory Committee (BCPAC) would be an appropriate forum.
  • CFIA's response: As part of the implementation phase of the proposed policy, the CFIA will liaise with CBBC and other industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Eastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.

2.2 Canadian Livestock Genetics Association (CLGA)

CLGA state that they "accept the scientific rationale that is presented" and indicate that while "the comments in this letter are primarily from the bovine genetics sector … they do overlap with the small ruminant sector" as they "cooperated with [the Canadian Sheep Federation] in the development of their comments". Several "technical" questions and comments were provided:

• CLGA would like clarification as to whether the risks of bluetongue transmission in Canada under the proposed policy would be higher, lower or the same as the existing policy and whether restricting imports to "the 39 states included in the current policy would reduce the risk".
  • CFIA's response: The 39 states are those that are recognized by the CFIA as having low or medium bluetongue incidence. When determining the level of risk associated with importing ruminants from the U.S., the likelihood that an imported animal is viraemic is taken into account. This is influenced by its state of origin, the time of the year, the duration of viraemia, its history of past exposure and its level of immunity. In addition, there are a number of other factors to consider before determining the likelihood of transmission within Canada. For example, its destination in Canada, the time of year the animal is imported, the short duration of viraemia in infected animals, the narrow window in late summer and early fall in which transmission could potentially occur, and the capacity of local vector populations to transmit bluetongue virus which is influenced by both genetic and environmental effects such as the temperature and rainfall that have a profound effect on vector activity and the ability of the virus to multiply in the vector. As discussed in the consultation paper, it can be reasonably concluded that there may be very limited opportunities for bluetongue transmission over several weeks in mid to late summer and into the fall in some years in the southern most fringes of the Prairie Provinces and B.C. The likelihood of bluetongue becoming established beyond a single vector season is considered to be negligible. Taking all these factors into account and considering the natural history of bluetongue in the northern tier States, the risk posed by the proposed policy is likely to be no greater than previous estimates and in all likelihood less than those estimates.
• CLGA "fundamentally object to changes to our Bluetongue import policy being linked to the USDA's BSE rule 2". While they appreciate that the two issues are not linked by the CFIA or the USDA, they are concerned that "support for the rule depends on Canadian action on Bluetongue".
• A request that CFIA immediately amend all export certificates that state that Canada is free of bluetongue. These amendments should be in accordance with OIE standards. At the same time CLGA indicate that "Canada must be seen as BT negative until a Canadian case is found."
  • CFIA's response: As part of the implementation phase of the proposed policy, the CFIA will liaise with CLGA and other industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Eastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.

• CFIA must ensure that bluetongue surveillance is consistent with OIE standards.
  • CFIA's response: CFIA will ensure that bluetongue surveillance meets appropriate international standards.
• CLGA raised several questions concerning the competence of C. sonorensis in the southern Prairies and the existence of vectors in other parts of the world and whether or not they should be considered.
  • CFIA's response: As discussed in the consultation paper, although there are over 1,250 Culicoides species that have been described throughout the world only a few have been shown to be involved in spreading bluetongue virus. In addition, different bluetongue serotypes have co-evolved in different regions of the world with different midges and exist in distinct, stable ecosystems. While the spread of certain serotypes has been associated with a particular species of midge, some populations may not have the ability to spread the bluetongue virus as they have not had the opportunity to co-evolve with the virus. This may be seen, for example, in those areas at the limits of the natural distribution of the vector where environmental and climatic conditions for both the vector and the virus are marginal, which is likely to be the case in the southern Prairies.
• CLGA want CFIA to determine whether or not the EU will apply the recommendations in the OIE Code for bluetongue when dealing with Canadian imports.
  • CFIA's response: As is the case with many trading partners, the measures applied by the EU are not entirely consistent with OIE recommendations.

2.3 Dairy Farmers of Canada (DFC)

DFC "is prepared to agree with the proposition made by CFIA". They endorse the CFIA's proposal to enhance bluetongue surveillance as proposed in the consultation paper. DFC raised two concerns, one related to retaining bluetongue as a reportable disease and the other about the potential loss of Western Canada's bluetongue free status:

• DFC "request the CFIA retain bluetongue as a reportable disease".
  • CFIA's response: As discussed in the consultation policy it is the CFIA's intention, that in removing bluetongue from the reportable disease list, it would no longer respond to incursions. This means that movement controls would no longer apply and would include animals from the Okanagan Valley even if bluetongue activity is detected. While the CFIA would not intervene beyond an investigation into death losses in domestic ruminants in the event of an incursion, by making bluetongue immediately notifiable, the CFIA retains the option of responding should the need arise, for example if changes in risks were identified. In addition the CFIA would still be able to fulfill its international reporting obligations to trading partners and the OIE. Under OIE guidelines, a country is required to immediately report the first detection of bluetongue and/or the introduction of new serotypes. It is important to note that with the easing of bluetongue restrictions the CFIA proposes to enhance its current surveillance activities by moving from a triennial to an annual surveillance program that will incorporate sentinel animal monitoring at strategic locations across Canada as well as testing animals in the fall at the end of the vector season. The CFIA will also continue to support ongoing vector research and risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or to identify changes in risks at an early stage.
• DFC "requests that, before implementing the decision" to remove import restrictions that CFIA "officially recognizes its responsibilities for any income losses to dairy producers if the consequence of the policy change means the loss of the bluetongue free status for [western] Canada". They want to initiate discussions on financial compensation for any losses that might be incurred before the proposal is finalized.
  • CFIA's response: As discussed in the consultation paper, while cattle are susceptible to infection with bluetongue virus, they are only affected by a very mild self-limiting infection, not overt clinical disease. As a result, the only potential impact that bluetongue would have would be associated with the export of live animals and their germplasm due to measures that some countries may apply. While a complete ban on these commodities would be highly unlikely, there may be some restrictions applied. For example, the export of live animals or the collection of semen could be restricted to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen collected during the vector season tests may be required. It is important to note that under OIE guidelines, cattle embryos collected in-vivo according to the method prescribed by the International Embryo Transfer Society (IETS), are accepted as posing a negligible risk of transmitting bluetongue virus. The methodology prescribed by the IETS is an international practice applicable to all countries regardless of their bluetongue status.
    
    As part of the implementation phase of the proposed policy, the CFIA will liaise with DFC and other industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Eastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.

3. Un-stated position with some concerns

3.1 Canadian Sheep Breeder's Association (CSBA)

CSBA "believes there is substantial risk to the Canadian sheep industry … from the proposed changes" and that "these changes should not be implemented until a plan for compensation … has been fully developed". They raised the following concerns:

• CSBA is very concerned that the details of the indemnity fund proposed by the Canadian Cattlemen's Association (CCA) were not included in the CFIA's consultation paper. They are concerned that in addition to the monetary value of animals that die, the loss of genetic potential can never be properly compensated. CSBA are of the opinion that the fund should be indefinite and reviewed every 3-5 years by all parties involved including the CFIA.
  • CFIA's response: The CFIA has been assured by the CCA that they will implement a credible program. Furthermore, CFIA understands that the CCA are currently undertaking negotiations on the details, scope and management of the fund with the sheep industry.
    
• CSBA are also very concerned about the risk of losing international markets currently being developed if Canada is no longer considered to be bluetongue free. "With the loss of our major export market in the U.S., a significant effort has been initiated … to network with sheep breeders in Central and South America and elsewhere, to enhance sales of Canadian genetics". Prior to the closure of the U.S. border in 2003 "exports of Canadian sheep genetics grew 36% from 2001 to 2002, and a further increase of 71% was projected for 2003 had the border not been closed".
  • CFIA's response: The CFIA acknowledges the profound effect that the closure of the U.S. border following the detection of BSE in 2003 has had on the sheep industry in Canada. As shown in Table 3 in Appendix 1, export revenue for live sheep and goats plummeted from nearly $20 million in 2002 to just $0.09 million in 2005. Export revenue for countries other than the U.S. as shown in Table 4 in Appendix 1 has also declined markedly from $0.28 million in 2002 to $0.07 million in 2005. The CFIA also acknowledges that seeking markets outside the U.S. is important for the recovery of the export sector.
    
    As part of the implementation phase of the proposed policy, the CFIA will liaise with CSBA and other industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Eastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.
• CSBA want to know if there are any implications for the movement of breeding stock, feeder and market animals within Canada, if Canada were divided into a bluetongue free zone in the East and a seasonally free zone in the West. Purebred breeders, especially those with smaller flocks "rely on frequent purchases of unrelated animals from fellow breeders across the country." In addition "the movement of feeder and market animals within the country … is so critical to ensuring the best price for lamb producers."
  • CFIA's response: The movement of animals between a free zone and a seasonally free zone and vice versa is not restricted under OIE guidelines and has no implications for the status of the respective zones. Furthermore, even if a viraemic animal were imported into a free zone the status of the zone would not change under OIE guidelines as one of the criteria for being a free zone is that competent vectors do not exist. This is the situation in Eastern Canada.

3.2 Canadian Sheep Federation (CSF)

CSF "represents over 13,000 sheep producers" and "has suffered tremendously since the closure of the [U.S.] border in May 2003" as a result of BSE. While lambs under 12 months of age can be exported to the U.S. the border remains closed to breeding stock. Prior to the closure of the U.S. border there had been significant growth of the export of breeding stock. CSF states that it "understands the need to resume normal trade relations with the United States for both the sheep industry and cattle industry" and that "while we don't want to stand in the way of normalisation of trade with the United States, we do have some concerns about the proposed changes":

• CSF is concerned that sheep may not be included in the USDA's BSE rule no. 2. If this is the case and Canada is no longer considered to be bluetongue free, "the industry then is facing the possibility of still not being able to export to the U.S. while simultaneously losing our ability to export to other countries". CSF is currently fostering international markets and claims that "over 30 countries have approached Canada indicating that they are interested in our breeding stock".
  • CFIA's response: The CFIA acknowledges the profound effect that the closure of the U.S. border following the detection of BSE in 2003 has had on the sheep industry in Canada. As shown in Table 3 in Appendix 1 export revenue for live sheep and goats plummeted from nearly $20 million in 2002 to just $0.09 million in 2005. Export revenue for countries other than the U.S. as shown in Table 4 in Appendix 1 has also declined markedly from $0.28 million in 2002 to $0.07 million in 2005. The CFIA also acknowledges that seeking markets outside the U.S. is important for the recovery of the export sector. The CFIA will assist in opening up new markets by negotiating export certification with the relevant authorities and re-negotiate existing protocols where appropriate.
• To minimize the potential impact on trade CSF requests that the CFIA re-negotiate export health certificates with trading partners.
  • CFIA's response: As part of the implementation phase of the proposed policy, the CFIA will liaise with CSF and other industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Eastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.
• The indemnity fund proposed by CCA is limited in scope to death losses in sheep. It does not cover losses associated with trade restrictions such as border closures, testing and quarantine in the event that trading partners may no longer recognize Canada as bluetongue free. Other concerns are that CCA has not indicated how much money would be set aside for the fund; that a time frame of 5 years is not long enough; that the fund should be held by a third party; and that it should be reviewed every 3 to 5 years by all of the involved parties.
  • CFIA's response: The CFIA has been assured by the CCA that they will implement a credible program. Furthermore, the CFIA understands that the CCA are currently undertaking negotiations on the details, scope and management of the fund with the sheep industry.
    
• How does the CFIA propose to deal with bluetongue should it become immediately notifiable?
  • CFIA's response: As discussed in the consultation policy it is the CFIA's intention, that in removing bluetongue from the reportable disease list, it would no longer respond to incursions. This means that movement controls would no longer apply. This would include animals from the Okanagan Valley even if bluetongue activity is detected. The CFIA would not intervene beyond an investigation into death losses in domestic ruminants such as deer and sheep in the event of a bluetongue incursion. By making bluetongue immediately notifiable the CFIA would retain the option of responding to an incursion should the need arise, for example if changes in risks were identified. In addition the CFIA would still be able to fulfill its international reporting obligations to trading partners and the OIE. Under OIE guidelines a country is required to immediately report the first detection of bluetongue and/or the introduction of new serotypes. It is important to note that with the easing of bluetongue restrictions the CFIA proposes to enhance its current surveillance activities by moving from a triennial to an annual surveillance program that will incorporate sentinel animal monitoring at strategic locations across Canada as well as testing animals in the fall at the end of the vector season. The CFIA will also continue to support ongoing vector research and risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or to identify changes in risks at an early stage.
• Would the movement of animals between Eastern and Western Canada be affected if Western Canada was classified as a seasonally free zone? In addition, would movement of animals from Western Canada affect Eastern Canada's bluetongue free status?
  • CFIA's response: The movement of animals between a free zone and a seasonally free zone and vice versa is not restricted under OIE guidelines and has no implications for the status of the respective zones. Furthermore, even if a viraemic animal were imported into a free zone the status of the zone would not change under OIE guidelines as one of the criteria for being a free zone is that competent vectors do not exist. This is the situation in Eastern Canada.

3.3 Fédération des producteurs de bovins du Québec (FPBQ)

FPBQ is in favour of the proposal. However, they indicated that the following concerns should be taken into account:

• If there is an outbreak of bluetongue, all losses will have to be indemnified by producers that are likely to benefit from this proposal.
  • CFIA's response: The CFIA has been assured by the CCA that they will implement a credible program. Furthermore, CFIA understands that the CCA are currently undertaking negotiations on the details, scope and management of the fund with the sheep industry.
    
• CFIA will need to ensure that it implements the proposed enhanced surveillance program.
  • CFIA response: As discussed in the consultation paper, the CFIA proposes to enhance its surveillance activities for bluetongue, which are currently undertaken every three to four years, by moving to an annual surveillance program that will incorporate sentinel animal monitoring at strategic locations across Canada as well as testing animals in the fall at the end of the vector season. The CFIA will also continue to support ongoing vector research and risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or to identify changes in risks at an early stage.
• CFIA will have to negotiate the classification of Eastern Canada as a free zone with the trading partners.
  • CFIA's response: As part of the implementation phase of the proposed policy, the CFIA will liaise with FPBQ and other industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Eastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.

3.4 Ministère de l'agriculture pêcheries et alimentation du Québec (MAPAQ)

MAPAQ raised a number of concerns:

• The consultation period was too short. As a result, meaningful consultation within the province was not possible.
  • CFIA's response: The CFIA granted additional time to provide comments.
• MAPAQ requested that the CFIA confirm with trading partners that the enhanced surveillance program, as proposed by the CFIA, would be sufficient to confirm the absence of bluetongue. In addition are trading partners likely to be satisfied with Canada's claims regarding the status of bluetongue vectors in eastern and western Canada?
  • CFIA's response: As part of the implementation phase of the proposed policy, the CFIA will liaise with MAPAQ and industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Eastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.
• Given that the response by trading partners is difficult to predict, MAPAQ considers that the CFIA should quarantine premises where a case of bluetongue occurs in order to control the movement of animals and their products. MAPAQ believes this will reassure trading partners about the safety of Canadian exports.
  • CFIA's response: As discussed in the consultation policy it is the CFIA's intention, that in removing bluetongue from the reportable disease list, it would no longer respond to incursions. This means that quarantine and movement controls would no longer apply. This would include animals from the Okanagan Valley even if bluetongue activity is detected. The CFIA would not intervene beyond an investigation into death losses in domestic ruminants such as deer and sheep in the event of a bluetongue incursion. By making bluetongue immediately notifiable the CFIA would still be able to fulfill its international reporting obligations to trading partners and the OIE. Under OIE guidelines a country is required to immediately report the first detection of bluetongue and/or the introduction of new serotypes. It is important to note that with the easing of bluetongue restrictions the CFIA proposes to enhance its current surveillance activities by moving from a triennial to an annual surveillance program that will incorporate sentinel animal monitoring at strategic locations across Canada as well as testing animals in the fall at the end of the vector season. The CFIA will also continue to support ongoing vector research and risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or to identify changes in risks at an early stage.
• MAPAQ indicated that they would provide additional comments.
  • CFIA's response: As of Friday, June 30, 2006, additional comments have not been forthcoming.

3.5 Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA)

OMAFRA "commend the CFIA for the development of this further in-depth consultation paper" and "acknowledges the CFIA as the lead agency for national biosecurity". They raised the following concerns:

• OMAFRA would like assurance that zoos, wildlife and agricultural groups other then the beef cattle industry have been consulted.
  • CFIA's response: CFIA distributed copies of the consultation paper to members of the Canadian Animal Health Consultative Committee (CAHCC). This committee encompasses a broad and diverse range of stakeholders with an interest in issues pertaining to animal health. CAHCC members include provincial and national livestock industry associations, provincial veterinarians, veterinary college deans, wildlife interests, zoos, importers, exporters, meat councils, other government departments.
• OMAFRA are concerned that emerging hazards such as new strains of BVD, IBR, Mycoplasma spp. and multi-drug resistant Salmomella spp. should also be considered.
  • CFIA's response: These issues are not relevant to the issue under consideration.
• Moving bluetongue on to the immediately notifiable list would mean that diagnostic laboratories would be required to report.
  • CFIA's response: Laboratories are required to report both reportable and immediately notifiable diseases. For reportable diseases, animal owners, veterinarians and laboratories are required to immediately report the presence of an animal that is contaminated or suspected of being contaminated with one of these diseases to a CFIA district veterinarian. For immediately notifiable diseases, only laboratories are required to contact the CFIA regarding the suspicion or diagnosis of one of these diseases.
• OMAFRA are concerned about how trading partners may respond to a change in bluetongue import policy, particularly as "Ontario has a large and growing small ruminant industry."
  • CFIA's response: As part of the implementation phase of the proposed policy, the CFIA will liaise with OMAFRA and other industry groups to prioritize export opportunities and negotiate a strategy to engage trading partners. It is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
    
    The CFIA will present a case to trading partners arguing that all of Canada should still be considered to be free and that existing certification apply. This should be straightforward for Wastern Canada as there are no competent vectors but may be more challenging for Western Canada, at least in the short to medium term until sufficient surveillance information is gathered and the results of ongoing research are available. If it turns out that, despite lifting bluetongue restrictions, there has been no evidence of transmission, the CFIA could build a much stronger case that all of Canada be considered free. However, one possible scenario would be that the Okanagan Valley, in certain years, continues to experience sporadic incursions as a result of vectors being blown in on the wind from further down the valley in Washington State. Even if this was to occur and ongoing surveillance demonstrated that there was no evidence of bluetongue activity in areas outside the valley, there may be no implications for the rest of Canada. The Okanagan Valley is already recognized as a separate and distinct geographic zone from the rest of Canada by many trading partners. Until such time as sufficient evidence is accumulated, trading partners may consider Western Canada as a seasonally free zone. If that were to occur, they could legitimately impose certain measures, which under OIE guidelines could consist of restricting the export of live animals or the collection of semen or embryos to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen or embryos were collected during the vector season tests may be required. In such circumstances the CFIA would request that trading partners adopt the recommendations of the OIE Code for seasonally free zones and apply them to animals and germplasm exported from Western Canada.
• The indemnity fund proposed by CCA should broaden its scope to offset losses in wildlife, zoos and other sectors such as dairy cattle in the event of a bluetongue incursion.
  • CFIA's response: The CFIA has been assured by the CCA that they will implement a credible program. Furthermore, CFIA understands that the CCA are currently undertaking negotiations on the details, scope and management of the fund with the sheep industry.
    
• Will the CFIA or the CCA indemnity fund provide the resources required for surveillance to convince trading partners that Eastern Canada is a bluetongue free region in the event of a bluetongue incursion in Western Canada?
  • CFIA response: As discussed in the consultation paper the CFIA proposes to enhance its surveillance activities for bluetongue, which are currently undertaken every three to four years, by moving to an annual surveillance program that will incorporate sentinel animal monitoring at strategic locations across Canada as well as testing animals in the fall at the end of the vector season. The CFIA will also continue to support ongoing vector research and risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or to identify changes in risks at an early stage.

4. Opposed

4.1 Manitoba Agriculture, Food and Rural Initiatives (MAFRI)

SPECIAL NOTE: It is worth noting that while MAFRI's written submission raised the concerns discussed below and that MAFRI were initially opposed to the proposal, subsequent discussions with the CFIA have allayed their concerns. In the interests of transparency their original submission is presented below.

MAFRI "cannot support the CFIA's position … without serious consideration being given to the scientific concerns outlined." MAFRI provided the following comments:

• MAFRI stated that the "the request for response to this consultation paper was made with less than seven working days available. Meaningful consultation with provincial interest groups in industry and wildlife are not possible within this time frame. Additional time is required for MAFRI to gather additional information from these groups."
  • CFIA's response: The CFIA granted additional time to provide comments.
• MAFRI claim that the consultation paper and past risk assessments have not fully reviewed the risk of importing viraemic animals into breeding herds or flocks in Western Canada "where exposure to the insect vector is potentially greater, where vector control is far more difficult and costly to achieve and where surveillance and monitoring, especially if an outbreak were to occur, requires a great deal more resource and time".
  • CFIA's response: MAFRI was the only stakeholder to express concerns that the risks have not been adequately evaluated. The consultation paper provides a detailed assessment of the bluetongue risks for Canada by critically examining the epidemiology of bluetongue. As with any risk assessment it is very easy to claim that risks have not been adequately addressed, particularly if the criticism focuses on specific points and possibilities. Since uncertainties will always exit to greater or lesser degrees, the role of risk assessment is ultimately to provide a balanced perspective. To meet this goal, the CFIA's risk assessment draws on the many complex pieces of what essentially make up a large "jigsaw puzzle". It does so in a transparent, rational and logical manner.
• MAFRI are critical of the CFIA citing a vector competence study from southern Alberta that is "neither published or peer reviewed" and highlight that vector competence studies have not been undertaken in Manitoba and Saskatchewan. They would like to see a review of vector populations, vector competence and regional climatic conditions.
  • CFIA's response: The vector study in southern Alberta was undertaken as a collaborative project between researchers at the Agriculture and Agri-Food Canada Research Centre in Lethbridge, Alberta and the USDA-ARS Arthropod Borne Animal Diseases Laboratory in Laramie, Wyoming. While the study has not been peer reviewed or published to date, its findings are nevertheless valid. Although similar studies have not been undertaken in Saskatchewan or Manitoba to date, the CFIA is proposing to support ongoing vector research. In addition the CFIA is proposing to move from a triennial surveillance program to annual surveillance that will incorporate sentinel animal monitoring at strategic locations across Canada and as well as undertaking ongoing risk assessment work. These activities are needed to build confidence that opportunities for bluetongue transmission are either limited or negligible or will identify changes in risks at an early stage. Given that the likelihood of bluetongue becoming established beyond a single limited vector season is negligible, even in the unlikely event that significant bluetongue incursions were to occur in a particular year, CFIA would still be able to adjust its import policy prior to the beginning of the next vector season.
• MAFRI consider that "a significantly more detailed cost analysis … should be pursued" that addresses the following concerns:
  • MAFRI claims that the cost estimates associated with an outbreak of bluetongue (in reference to a CFIA risk assessment January 2006) are inadequate as it "specifically relates to Alberta and does not fully evaluate direct or indirect costs that could occur with other western provinces". Examples of these costs are provided and include reproduction losses, disposal, quarantine, vaccination, daily housing during risk times.
    • CFIA's response: MAFRI are referring to an earlier risk assessment undertaken by the CFIA that estimated the potential losses associated with an outbreak of bluetongue in southern Alberta. The scope of this risk assessment was focused on the consequences of introducing bluetongue into sheep and wildlife populations in southern Alberta as a result of importing feeder cattle from certain states in the U.S. The scope of the consultation paper, on the other hand, was much broader. It does not focus on outbreak scenarios, as the CFIA is proposing that it would no longer respond to incursions.
  • MAFRI are also concerned that the consultation paper does not "fully account for potential export losses and or additional laboratory costs associated with live cattle, bovine semen and bovine embryos" if trade restrictions were to apply.
    • CFIA's response: As discussed in the consultation paper, the CFIA acknowledged that it would be difficult to predict how individual countries would respond to Canada easing its bluetongue restrictions. While it is likely that some may no longer recognize Canada as bluetongue free, they would be requested to at least recognize Ontario, Quebec and the Atlantic Provinces as a free zone. Although there should be no bluetongue related restrictions for ruminant animals or their semen or embryos originating from Eastern Canada, it is important to note that the majority of Canada's trading partners already require that live animals and semen and embryo donors be tested for bluetongue even though certification is required that Canada is free from bluetongue (see Table 1 in Appendix 1). Although such certification is inconsistent with OIE recommendations, it is often the case that trading partners do not implement them.
      
      As also discussed in the consultation paper, the Prairie Provinces and British Columbia may be initially treated as a seasonally free zone with associated restrictions on live ruminants and their semen and embryos. From 1998 to 2002 the average export value of these commodities to countries other than the U.S. from these provinces was $5.1 million made up of: cattle $1.8 million; bovine semen $1.7 million; bovine embryos $1.4 million; sheep $0.1 million and goats $0.2 million. While a complete ban on these commodities would be highly unlikely, there may be some restrictions applied. For example, the export of live animals or the collection of semen could be restricted to the non-vector season without incurring any additional costs. Alternatively, if live animals were exported or semen collected during the vector season tests may be required.
• MAFRI are concerned that "the movement of bluetongue to an immediately notifiable disease would place greater demand on provincial and industry resources for prevention and control".
  • CFIA's response: While it is not the intention of the CFIA to respond to an incursion of bluetongue by imposing measures such as quarantine and movement controls, the CFIA will assist provinces to the extent of an investigation into death losses in domestic ruminants and ongoing surveillance activities.
• MAFRI are concerned that "the introduction of new viral strains of EHD or BTV via imported stock to the naïve populations of wild ungulates could have serious implications". They indicate that since "recent surveillance data on wildlife losses to EHD or BTV appears to be lacking … more surveillance data would further quantify the level of risk".
  • CFIA's response: The focus of the consultation paper and proposed policy is on bluetongue virus (BTV) not epizootic haemorrhagic disease virus (EHD). As discussed in the consultation paper, even in the Okanagan Valley, where conditions are likely to be the most favourable of any area in Canada and bluetongue transmission has been limited to mid summer to mid fall in some years, there have never been any reports of significant clinical disease or death losses attributable to bluetongue in either domestic or wildlife species. It is important to note that an extensive amount of surveillance data has been accumulated for the Okanagan Valley since annual surveillance first began there in the 1970s. Since cattle are more frequently infected than other species, such as wildlife, as the midge prefers to feed on them and they are the natural reservoirs and main amplifying host for bluetongue virus, the focus of the CFIA's surveillance program in the Okanagan valley has been be on cattle. This is consistent with surveillance programs in other countries.

4.2 Robert Somerville (RS), Alberta

RS is a "cow calf producer and feedlot operator …in east central Alberta". He states that "the rationale for the change in the CFIA's import policy is based on political goals as the science does not support a change". He adds that "it is vital to Canada's interest that decisions involving trade are based on science and not a response to political pressure from trading partners" and believes that "if Canada changes its import policy … then the cow herd, especially … in the Prairie Provinces will become infected with these diseases [bluetongue and anaplasmosis]." RS provided the following comments:

• RS refers to the CFIA's consultation paper that cites industry figures "which suggest a cost of one million dollars per day if the proposed USDA rule is opposed". He states that "there is zero chance that the USDA rule will not be opposed by one or more U.S. lobby groups whether Canada changes its import policy or not. Therefore the rationale for the change … is baseless".
  • CFIA's response: CFIA's proposal to ease bluetongue restrictions for ruminants imported from the U.S. is not driven by the USDA's "BSE rule no. 2" which is expected to be released for comment in late summer. Nor is it influenced by the opinions of lobby groups in the U.S. Rather, the rationale for reviewing the bluetongue import policy is based on new scientific information that has enabled the risks to be re-evaluated and a consideration of ongoing concerns that the CFIA's measures may be having an unwarranted effect on trade.
• RS is concerned that if Canada removes import restrictions for bluetongue then "the incidence of bluetongue will, within relatively few years become equivalent in the southern regions of the Canadian Prairie Provinces to the northern tier states.
  • CFIA's response: Since the likelihood of bluetongue becoming established beyond a single vector season in Canada is negligible as a result of harsh climatic conditions during the winter months,any bluetongue, incursions, if they were to occur would be limited. It is important to note that the northern reaches of the border states are on the fringe of the northern most bluetongue boundary in North America. In fact, recent surveillance results from the U.S. suggest that the northern most extension of bluetongue in the U.S. may lie 100 to 200 kilometres south of the border.
• RS suggests that "a supply of feeder calves to meet the needs of Canadian feeders and packers can come from within Canada and does not have to be imported from the United States".
  • CFIA's response: Apart from not falling within CFIA's mandate, this issue is not relevant to the development of CFIA's import policy, which is concerned with mitigating disease risk not marketing conditions.
• RS suggests that "bluetongue and anaplasmosis are diseases of the cow herd and are not issues for the feeder sector". He is concerned that the cow calf sector will have further costs "thrust upon it" as a result of "abortions, death loss, loss of production, increased use of antibiotics for disease prevention, loss of export markets … once bluetongue and anaplasmosis become established". RS claims that "cow calf producers will bear the entire cost of the proposed policy change while other sectors of the beef value chain will reap any benefits". He advises the CFIA "to exercise caution when heeding the advice of the livestock industry that it is not just listening to the feeding sector which has its own vested interests it is putting forward".
  • CFIA's response: This consultation paper and proposed import policy cover bluetongue, not anaplasmosis. This disease will be considered separately in an further round of consultation in late summer.

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Appendix 1

Table 1: Commodity groups with export certificates containing bluetongue requirements for countries other than the U.S. classified according to the type of certification required.

Commodity	Export certificates	Country freedom	Farm/premises of origin or artificial insemination (AI) center freedom	Animal or donor tested
Animal products	9	5	5	4
Camelids	2	2	2	1
Cattle embryos	32	8	30	14
Cattle semen	70	17	54	64
Live cattle	5	4	4	5
Live sheep and goats	15	12	7	5
Sheep and goat embryos	5	3	2	3
Sheep and goat semen	8	4	5	5
TOTAL	146	55	109	101

Table 2: Commodity groups with export certificates containing bluetongue requirements classified according to whether exports occurred in 2005 to countries other than the U.S. in 2005.

Exports in 2005 to countries other than the U.S.

Commodity	Yes	No	Total
Cattle embryos	14	18	32
Cattle semen	48	21	69
Live cattle	-	5	5
Live sheep and goats	3	12	15
Sheep and goat embryos	-	5	5
Sheep and goat semen	1	7	8
TOTAL	66	68	134

Table 3: The value of live ruminants and their germplasm exported to the U.S. expressed in millions of dollars.

Exports to the U.S. ($million)
Source = World Trade Atlas (Statistics Canada)

Commodity	Western Canada		Eastern Canada
	2002	2005	2002	2005
Live cattle	1,411.97	569.66	412.32	57.47
Cattle semen	11.09	12.45	9.92	17.57
Cattle embryos	0.13	0.65	0.05	0.12
Live sheep and goats	15.50	0.01	4.23	0.08
Sheep and goat embryos*	n/a	n/a	n/a	n/a
TOTAL	1,438.69	582.77	426.52	75.25

*statistics not available

Table 4: The value of live ruminants and their germplasm exported to countries other than the U.S. expressed in millions of dollars.

Exports to countries other than the U.S. ($million)
Source = World Trade Atlas (Statistics Canada)

Commodity	Western Canada		Eastern Canada
	2002	2005	2002	2005
Live cattle	6.16	-	1.27	0.02
Cattle semen	3.64	4.91	21.18	33.16
Cattle embryos	2.39	2.50	0.91	4.15
Live sheep and goats	0.27	0.05	0.01	0.02
Sheep and goat embryos*	n/a	n/a	n/a	n/a
TOTAL	12.46	7.47	23.37	37.35

*statistics not available