To: Biosecurity Australia,
G.P.O.Box 858,
Canberra. ACT. 2601.
From: Mr.Norm Halliwell,
Riverside Aquarium & Cichlid Centre,
16 Ninth Ave,
Campsie. NSW. 2194.
Date 1.4.09
Animal Biosecurity,
Biosecurity Australia,
G.P.O.Box 858.,
Canberra. ACT. 2601.
My comments with regards to the Draft Import Risk Analysis
Report for Ornamental Finfish with respect to Iridoviruses.
Dear Sir,
I would like to comment on the “Draft Import Risk Analysis Report for Ornamental finfish, with respect to iridoviruses” that I received the other day. First of all I wish to state that it is a very lengthy report of over 130 pages, and the time given for public consultation by 25.5.09 is rather short, as there would be very few people in the Australian Ornamental Fish Industry, that would be capable of condensing this report and then to make a comment on it. This report has probably been coming for over 2 – 3 years and you only allow 2 months to make comments on it. This is disgraceful! If anybody is late in commenting they should be allowed to do so, as long as it does not take too long.
Table of Contents
Introduction
Iridovirus of Mikrogeophagus ramerizi
Iridovirus of Angelfish species
Goldfish iridoviruses 1 and 2
Dwarf Gourami Iridovirus
Guppy Iridovirus –GV-6 (Species Santee-Cooper genus Ranovirus)
General Comments
Summary
Introduction
This draft import risk analysis report takes into consideration a tremendous amount of anecdotal evidence, assumptions, and misrepresented data, rather than to supply factual or scientific evidence, that it “flowers up this report” to be an enormously detrimental paper on the operations of the ornamental finfish Industry, when nothing is further from the truth, and I will explain this further as I go along.
To begin with, mentioning that Lymphocystis disease (LCDV) is an important iridovirus (which may be correct for the aquaculture industry), when we all know Australia has had an endemic strain of LCDV for decades, and everyone within our Industry knows that it is not fatal to ornamental finfish. This is what I would call “flowering up” the report, to make it sound as if it is a major discovery when LCDV has been endemic to Australia for over 60 years that I know of.
Iridovirus of Mikrogeophagus ramerizi
The iridovirus of Rams (M. ramerizi) SHOULD NOT BE TAKEN SERIOUSLY, as it will not affect any native endemic species as stated in your report, nor does it affect any other ornamental finfish in which it comes in contact with, because if a batch of imported stocks has it, they generally perish fairly quickly once released from post-quarantine facilities and sometimes whilst still in quarantine.
They are sold by retailers to in-house aquaria, and have never been introduced into natural waters, nor would they be as they are very sensitive to water quality as aquarists know, and our river systems would prevent any escapes surviving as indicated on page 65 of your report where the conclusion for Group 2 “exposure to farmed foodfish” is found to be very low and to Exposure Group 3- Fish in natural waters (page 68) it is also shown as very low, and the likelihood of rams surviving to form a self-maintaining population would depend on many factors, especially the “propagule pressure” measure of any release, and this simply will not occur.
I know of nobody in Australia that are farming or breeding this Ram species in any pond system outdoors that may escape into natural waterways, because they would have to compete with the relatively low import price, and nobody in Australia is going to outlay the time and effort to do so, for very little return on capital.
This report knows this very well, otherwise it would have been highlighted in your report, so your concerns on this species is totally unfounded and unwarranted. No other cichlid variety have any iridoviruses associated with Rams, especially ALL Rift-Lake varieties of which there are literally hundreds/thousands of species in Australia. Even other dwarf American cichlids that come into contact with M.ramerizi do not outbreak with the iridovirus, and nor do other tank occupants.
Conclusion
The exposure assessment (2.4.2) in your report expresses exposure pathways for ornamental finfish to be released, of which M.ramerizi is one. These potential pathways are TOTALLY FLAWED as follows:
1. M.ramerizi released from post-quarantine premises to wholesaler/retailer premises are then sold on to the general public for in-house aquaria, and nowhere else.
2. The Rams are NEVER SOLD on as live/dead fish for food for foodfish broodstock grow-out, as their costs would be too prohibitive, and the imported numbers are insufficient for foodfish producers to use, so this exposure does not occur.
3. The Rams are never released to other Groups to be released into natural waterways, as each State Government has laws on introducing fish into waterways, and besides the cost of the species would be too prohibitive for this to occur, so this exposure does not occur.
4. The solid/waste disposal from wholesaler/retailer premises is disposed to sewerage and in quarantine premises are treated before disposal, so this exposure does not occur.
5. This fish is never used as a recreational bait use, due to its high retail cost, when there are much cheaper species available for bait use, eg Gambusia spp, so this exposure does not occur.
Therefore, for all of the five avenues listed for exposure pathways for M.ramerizi, only one, “release of live fish to the ornamental Industry” applies to this species, and as stated before, when a batch is detected with this iridovirus, it only affects M.ramerizi, and no other tank occupants, and thus the batch invariably dies off rather quickly, so it cannot be released in any of the other pathways mentioned above, SO WHAT IS THE FUSS ALL ABOUT. This is tantamount to using a sledgehammer to crack a nut”.
There is no need for further draconian legislation measures to be applied to Rams when 4 of the 5 exposure pathways have all been eliminated, and the remaining one is negligible for the species concerned as mentioned above.
My recommendation to Biosecurity Australia would be that retailers/wholesalers and importers are the “soft targets” to satisfy a political whim or desire of some misguided individuals, with possibly heavily biased academic opinions which do not stand up to scrutiny, as in the case of this species and the next as this species as far as I, and the Industry are concerned is a non-event for an exotic disease outbreak in Australia, as this particular species iridovirus was described by Lewis and Leong in 2004, and we are now into 2009 and there have been literally thousands of this species imported since 2004 and no outbreaks have been shown.
The ornamental fish industry believe that all cichlid and gourami species should be in a 7 days quarantine system, just as in your report on page 95 under Conclusions and Recommendations you also believe that these groups should be placed into a 7 day quarantine period, rather than the 14 days that currently exists, and Industry would not at all be happy with further restrictions on M. ramerizi with all the added costs applied to this species with further testing procedures, sampling of import batches and the like, simply to satisfy the “whim of some bureaucrats” on matters that do not stand up to scrutiny or scientific rationale, as shown above in this report.
This risk of this iridovirus being released to native fish, broodstocks or river systems is therefore, “very low or negligible” and as such should be considered as acceptable to Australia’s appropriate level of protection (ALOP) in qualitative terms.
Iridovirus of Angelfish species
The exposure assessment (2.4.2) in your report expresses exposure pathways for ornamental finfish to be released into natural waterways, of which Angelfish are one. These potential pathways are again TOTALLY FLAWED, for this species as follows:
1. All Angelfish varieties released from post-quarantine and wholesaler/retailers premises are for on-sale to in-house aquaria and nowhere else.
2. This species is NEVER SOLD on as live/dead fish as food for foodfish broodstocks grow out, as their cost would be too exhorbitant to do so, and the numbers needed would not be there for foodfish producers to use, so this scenario does not occur.
3. This species is NEVER RELEASED directly or indirectly to groups for release into natural waterways, as their cost factor would be far too expensive to do so, and besides each State has its own regulations when it comes to releasing fish into natural waterways, so this scenario would never occur.
4. The solid/waste disposal from post-quarantine and quarantine rooms are regimentally treated before disposal and wholesaler/retailers are disposed to a recognized sewerage system, so this scenario does not occur.
5. Angelfish are NEVER USED as recreational baitfish, due to the heavy cost of specimens from retail establishments, as people can use other more cheaper varieties eg, Gambusia spp.
Therefore, of all the five avenues for exposure pathways, only the one, “release of live fish to the ornamental finfish Industry” applies for all varieties of Angelfish This again is using a “sledgehammer to crack a nut” to impose further restrictions and extra costs and burdens onto importers, which in turn increases the end-user costs for no valid scientific reason whatsoever, as no iridoviruses of angelfish is ever likely to get into native fish broodstocks, or natural waterways, similar in all respects to M. ramerizi.
So, there is no need for further draconian measures to be applied to Angelfish, when 4 of the 5 exposure pathways have been eliminated, as shown above, and the remaining one is negligible for the species concerned.
Conclusion
My recommendation to Biosecurity Australia would be to ignore any pressure being applied by the bureaucracy for this species for all the reasons highlighted above, as it is a non-event for any exotic disease outbreaks from Angelfish in Australia. The angelfish iridovirus has been on imported angels for quite a number of years now having been described by Lewis and Leong in 2004 and we are now into 2009 and millions of angelfish have been imported in that time without any signs of a disease outbreak.
Angelfish have not infected any other ornamental species in which they have come into contact with and this is literally hundreds of varieties and species, and the disease is not transferable to other ornamental finfish, so what is the problem here?
The risk of this iridovirus being released to native fish, broodstock grow out or to river systems is therefore “very low or negligible” and as such should be considered as acceptable to Australia’s ALOP in qualitative terms.
Goldfish iridoviruses 1 and 2
This genus is heavily bred in ponds around Australia with the two major ones being Bollara Fish Farms in Victoria and Pine Creek Fish Hatchery in northern New South Wales, which also breeds to a much lesser extent Guppies (Poeciliids) and to an even lesser extent Gourami species. Pine Creek is the only breeding premises from the mainland that are allowed to transport goldfish varieties to Tasmania, as Pine Creek stocks are considered diseased free of any communicable disease or any disease that may be classified as exotic to Australia, and that includes GFV-1 and GFV-2, otherwise Tasmanian Inland Fisheries in their very stringent import regimes, would soon prevent then from entering Tasmania if any problems did occur, and as of 1.4.09 imports to Tasmania are still permitted from Pine Creek.
All imported Goldfish varieties through recognized Quarantine facilities from the mainland of Australia, once they have passed through post-quarantine procedures are also permitted entry to Tasmania, so surely this is a “rubber stamp of approval” that all imported goldfish varieties are free of any “exotic” disease of Australia and that they pose no risks of outbreaks, if Tasmanian Inland Fisheries allows them in.
The GFV-1 isolated from healthy juvenile goldfish (Berry et al 1983) and GFV-2 isolated from a healthy “wild” adult goldfish (Berry et.al.1983) were both sampled from specimens collected in the United States of America, and were the only reported findings of GFV-1 and GFV-2 (Berry et.al.1983) as stated on page 39 of your report. For the record, Australian Importers do not import “wild “ goldfish varieties, EVER.
The more prevalent virus endemic to Australia is called Epizootic haematopoietic necrosus virus (EHNV) and it is carried everywhere Government Fisheries Departments
and stocking agencies introduce and translocate Red-fin Perch (Perca fluviatilis) into just about every waterway in Australia, all in the name of recreational fishing.
This species (redfin perch) does far more harm than any ornamental finfish species could ever do and THAT IS A FACT that must be realized here. It infected Trout species (an introduced exotic) below the Blowering Dam, when offal from minced up juvenile redfin perch filtered down into the river system below the dam wall where Trout were present. By the way, the Aquarium Industry was blamed for this outbreak until I investigated that matter and it was shown that redfin perch got minced up and was filtered into the river system below, but, did any retraction get made? NO ON YOUR NELLY!
The EHNV of redfin perch is also highly pathogenically fatal to natives species, in particular Murray Cod, Silver Perch, and Golden Perch and presumably to others eg, Bass, Macquarie Perch etc, as they have NEVER come into contact with this virus. However, Government Fisheries Departments and stocking agencies DON’T APPLY the “precautionary principle” as they continue to translocate redfin perch at their discretion, and all Departments continue to ridicule our ornamental finfish industry as being irresponsible when it is these organizations that are doing the majority of damage to Australia’s biodiversity.THIS IS HYPOCRITICAL TO SAY THE LEAST!
A paper by Damian Burrows called “Translocated Fishes in streams of the Wet Tropics region, North Queensland – Distribution and Potential Impacts in Rain-forrests areas in CRC Feb.2004, indicates quite clearly that the bulk of environmental introductions and degradation in warmer climate of Australia, have come about by numerous stocking agencies around Australia that continue to introduce and translocate native species into areas they are alien to, as well as graziers and landholders translocating aggressive native species into catchments and above waterfalls where they have NEVER EXISTED BEFORE, which in turn has obliterated hundreds of crustaceans, other native fish and frog species in the catchments in which they were liberated.
The species of major concerns in the tropics in this paper were Sleepy Cod (Oxeleotris lineolatus) that has all but made the spotted gudgeon (Mogurnda adspersa) EXTINCT in the Burdekin River system after it was deliberately introduced in 1980.
This was followed by Sooty Grunter (Hephaestus fuliginosus), into 23 separate sites in Queensland . Next was Barramundi (Lates calcarifer) being released everywhere. Sleepy Cod having been dumped into the Burdekin River in 1980, will soon dramatically impact on the living fossil Neoceratodus fosteri ; the Queensland Lungfish, because the cod breeds quicker than the lungfish, and the “DEATH NELL” has been sounded on this living fossil species. IT IS ONLY A MATTER OF TIME FOR IT TO BE MADE EXTINCT IN THE BURDEKIN RIVER, and this is a disgraceful set of circumstances!
The Striped Grunter (Amniataba percoides) was introduced to the Upper Clarence River in Northern NSW by a stocking agency as a contaminant with the Silver Perch fingerlings being introduced, when “blind freddy” could have spotted them in the consignment. Now, the striped grunter has formed a feral self-populating existence in the Upper Clarence and is causing problems to other species. By the way, our Ornamental finfish Industry was blamed for this introduction, but on further investigation it was shown to have been the stocking agency that caused the outbreak. Now, NSW is the only State of Australia that has a native species declared as NOXIOUS (the Striped Grunter). IS THIS NOT A LUDICROUS SITUATION?
There are heaps of these kinds of introductions and translocation that I could quote to you, but, it all seems to fall upon “deaf ears”, but when it comes to establishment or introduction of an ornamental finfish species, there is a huge reaction from Government Departments, and the Industry gets “beaten around their collective heads” because of it. This one sided reporting simply has to cease!
There are more introduction and translocations being done by Government Departments and stocking agencies than any from our Industry and that is a FACT not yet conceded by Government Departments. The two new species for translocation and introduction on the block are Jungle Perch and Mangrove Jacks, now they are being bred intensively in captivity. Only time will tell about the damage these species will do when introduced into alien areas.
What Bio-security Australia has to realize is that ornamental finfish species are not kept in captivity with aggressive native species in farming operations, or in retail establishments, as they would:
1. Not survive in colder conditions as that associated with Murray Cod, Silver and Golden Perch, Bass etc, as they would be eaten, and besides the bulk of ornamental finfish are tropical species.
2. They would not survive in warm water conditions associated with Sooty Grunters, Sleepy Cods, Spangled and Jungle Perch, Barramundi, Saratoga Mangrove Jacks and the like as they would again be eaten.
3. Finally, these aquaculture operations do not use ornamental finfish as food for their broodstocks, because the costs of same is too prohibitive to do so. Invariably they use farmed fish offal or juveniles of their own broodstocks that may be considered to be “runts” of a spawning, or they use the mosquitofish (Gambusia spp) which is an introduced exotic by Governments in 1925 to control mosquitoes, and which are plentiful everywhere in Australia, that can be harvested for next to nothing.
Retailers invariably sell uncoloured and sometime deformed goldfish as food fish to aquarists for feeding to fish eg, Oscars and other large cichlid varieties, as well as Saratoga, Barramundi and the like, and they also sell other feeders namely Firetail Gudgeons for feed to smaller species which are a bi-product of mariculture operators eg, Yabbies, Marron and Red-Claw crays.
Nobody that I am aware of has ever complained to Industry operators or anybody else for that matter, of any exotic disease outbreak associated with Goldfish or Firetail gudgeons or other native or ornamental finfish species. So, what is the big concern here?
The ornamental fish testing project (2006) as itemized on page 60 of your report for cichlids, goldfish, gouramis, and poeciliids, showed NO IRIDOVIRUS INFECTION for these four groups during the survey period.
This should be enough evidence based on all the facts mentioned above in this report for Bio-security Australia to reject any more stringent requirements to be placed upon all Goldfish varieties.
Conclusion
First of all, the ornamental finfish testing project (2006) does not highlight to Industry where the 100 cases were drawn from, nor does it allow Industry to scrutinize this project as it is not shown in the references of your report, so how can you list material of such importance to Industry, when we are unable to view it for accuracy. This is more “flowering” of your report mentioned at the beginning of this report.
It just so happens that the project reflects kindly on the ornamental finfish Industry, but, it could easily have been a detrimental report on the species sampled for all we knew. Matters of such importance should be given a reference source, so that Industry people may obtain a copy to review it.
Under 5.1 Release assessment of your report on page 60 it states in the conclusion that the likelihood of releases of iridoviruses associated with Goldfish varieties is estimated to be LOW and again under 5.2.2 Exposure Group 2- Farmed Foodfish on page 65 in the conclusion its states the likelihood of local farmed foodfish (exposure group 2) being exposed to an imported ornamental finfish infected with iridovirus is estimated to be VERY LOW. So, under Australia’s ALOP it means the measures or combination of measures currently employed for all Goldfish varieties is considered acceptable, and therefore no further actions need to be undertaken.
Given the fact there was only one report of an iridovirus of Goldfish detected from overseas, and as that Goldfish has been studied more than any other ornamental finfish in this report, and elsewhere, it would be very reasonable to consider that there is not enough evidence of concern that would make Bio-security Australia implement more stringent measures on Goldfish, therein increasing their collective costs further.
Some retailers have had Asian hobbyist ask for Goldfish that they can release culturally, often referred to in your report as the “Christmas syndrome” and this should not sway Bio-security Australia to place any further restrictions on the trade of Goldfish varieties
because the “propagule measure” should apply here. I personally have told these people in no uncertain terms that this should not happen and have explained the dangers of releasing fish into the environment, but that does not seem to dissuade them, so I will not sell ornamental fish under these circumstances.
Dwarf Gourami Iridovirus
The disease that affects Dwarf Gouramis has been around in Australia for a decade or more, and is not transmittable to other ornamental finfish species that they come into contact with and they are many and varied, nor is it an exotic disease as it is already here. This is a well known FACT!
It may affect native species eg, Murray Cod if housed together, but, we in our Industry would never house dwarf gouramis with Murray Cod for the obvious reason, they would be consumed. Industry stockists do not house such animals together for the same 3 reasons as that mentioned in the previous group of fish, NOR DO aquaculture operators purchase them as foodfish in their feeding regimes due to their high costs, and I know of NOBOBY who pond breeds these dwarf gouramis in Australia for sale to aquaculturalists as food for their broodstocks
Mr.Bruce Sambell may have supplied gouramis to aquaculture operators for feedlots, which to my way of thinking is irresponsible if it did occur, as they would have had to be at a very cheap price, because aquaculture operators would not be prepared to pay exorbitant prices for such animals, and Mr. Sambells price is not exactly cheap.
Your report (page 33) also agrees with me, that imported ornamental finfish purchased from wholesaler/retailers to farmed foodfish broodstock operators, is considered very rare, because of the high cost of imported ornamental finfish, as compared to the low cost of Goldfish and Poeciliids bred locally.
I have personally spoken to a number of pond breeders of Gouramis, who mainly breed 3 spot, opaline and golden varieties and not, I repeat not dwarf varieties, and they have advised me that they have not supplied gouramis to aquaculture operators, either now or in the past, as the cost to such operators was too high, so I can only presume that Mr. Sambell must have done this.
Irrespective of this, the activities at AQIS approved quarantine places present a negligible likelihood of disease “establishment” due to the required Biosecurity measures and procedures being employed there.
As AQIS currently puts it; 19 million ornamental fish are imported annually (2008), and based on data from one major wholesaler/importer who suggested that of an estimated 12.5 million tails imported in 2003-04 comprised in part that 8% were of Gouramis, so
that extrapolates to around 1.5 million tails of 2008”s 19 million imports for Gourami species.
There was no mention of how many dwarf gouramis made up the 8% total number imported in 2003-04, but I can certainly tell you here that the bulk of imports are from 3 spot, golden and opaline gouramis, followed by pearl and pink kissers, with dwarfs being next in line. Industry operators have known about the disease of dwarfs having symptoms of a swollen belly for years, without any concerns, as it has not affected other ornamental finfish that they have come in contact with, and as none are imported for the aquaculture industry, there should be no cause for concern by Biosecurity Australia, as again it is a non-event, similar in all respects to that of M.ramerizi.
Even in your conclusion for Exposure Group 2 – Farmed Foodfish, and Exposure Group 3 – Introduction to Natural Waters, Gouramis are shown as VERY LOW, so this would be considered to be sufficiently conservative to achieve Australia’s ALOP.
Your report page 34 under Berley and Bait surveys, it states there is NO indication that cichlids, goldfish or gouramis were used as recreational fishing bait, and that shows up as a very low likelihood of introductions of these species into natural waterways with an iridovirus of quarantine concern. You have only got to sample gouramis in the Ross River (considered not to exist R.McKay pers.comm.) or Sheepstation Creek in Queensland, to prove that this establishment does not have an iridovirus attached, (R.McKay pers.comm.), as it certainly would have been mentioned in your report.
Conclusion
Of the imported animals under consideration in this report, Gouramis must surely be one of the most studied species (apart from Goldfish varieties that is) and there is very little factual information in your report that should make Biosecurity Australia concerned about an iridovirus of an ornamental species like dwarf gouramis, when it only affects them.
Just because Murray Cod can be affected by GDIV this is not an indication that they will come into contact with the virus as they were only affected under experimental laboratory conditions. This is not a valid reason to place more stringent controls and costs onto our Industry for a hypothetical situation, when there should be heavy fines placed on aquaculture operators who break the law at their discretion by SUPPOSEDLY feeding broodstocks with “so-called” diseased ornamental finfish, when it is highly questionable, that this occurs anyway. Our Industry should not be used as a “scape-goat” for the “whims of some academic” who feels we should be singled out for more compliance measures to be implemented.
My recommendation to Biosecurity Australia is that Gouramis are again a non-event, as under your Group 2 Exposure – Farmed Foodfish and Group 3 Fish in Natural Waters,
they are shown as a VERY LOW risk and therefore would adequately satisfy Australia’s ALOP in qualitative terms.
Guppy Iridovirus –GV-6 (Species Santee-Cooper genus Ranovirus)
On page 17 of your report you state that PSM Group P/L (1999) estimated 95% of imported ornamental fish are directed towards the Ornamental Fish Industry and that Wholesalers import approximately 80% of the total volume of imports, with the other 20% being imported directly by Retailers, and that somewhere between 97.5% and 99% are sold to retailers, wholesalers and hobbyists directly, with the balance of which being sold to commercial breeders. These commercial breeders are ornamental finfish breeders, and not commercial aquaculture foodfish operators. Similar figures were obtained from a report by Dos O’Sullivan et. al. (2008) that was almost identical to that of PSM Group P/L (1999) some 9 years earlier, also shown on page 17 of your report.
With that in mind, and the FACT that NO information is available on the prevalence of iridoviruses in cichlids, goldfish or poeciliids, then WHAT IS THE MAJOR CONCERN HERE ? Just because Aplocheilichthys normani is reported as a carrier of an iridovirus of quarantine concern, and it is a member of the Poeciliid family, is a non-event, as this species is NOT a permitted import to Australia as mentioned in your report.
This is again another “flowering” of your report by mentioning a species not permitted entry to Australia.
The species of Poeciliids that are imported to Australia are not to my knowledge kept with A. normani, and even if they were, all exporters have to supply a health certification advising all exports are free of clinical signs of diseases of concern, and no signs have been indicated in your report that there have been imports of this iridovirus of Poeciliids, otherwise quarantine would have stepped in and stopped all Poeciliid imports if it was detected, and this, simply never eventuated.
I’m also well and truly aware that Singapore is an exporting Country now considered to be one of the cleanest Countries for exporting ornamental finfish in the World, and that Australia does not export from South America, the United States of America and United Kingdom thereby further limiting diseases of quarantine concern entering Australia directly, and this is FACT!
Under Exposure Group 2 Farmed Foodfish- Poeciliid species are shown in your conclusion as VERY LOW (page 65), and again under Exposure Group 3 – Fish in Natural Waters, all Poeciliids are shown in your conclusion as LOW. We all know that if it were not for a number of Poeciliids species, namely Guppies, Mollies, Platys and Swordtails etc being present in Australian environments, mainly in warm water zones, that your listing would have been VERY LOW as well. By the way a large number of these sites have been eliminated by predation and temperature fluctuation (R.McKay pers. comm.).
The sheer FACT that all Poeciliids are permitted entry to Tasmania, a State within Australia, is testament that ornamental Poeciliids are not causing Tasmanian Inland Fisheries any concerns, so it should not be a matter of concern for Biosecurity Australia, as Australia’s ALOP is well and truly covered here!
None of the Poeciliids in Australian waters have broken out with any iridovirus of quarantine concern, as it would have been mentioned somewhere in your report, and this simply was not done.
Guppies, Mollies, Platys, and Swordtails, in fact many Poeciliid species are bred by hobbyists in-house, and are then sold onto Wholesalers, Retailers and other hobbyists, but none are sold to any aquaculture operator for feedlots, as they simply would not be able to produce enough numbers and the prices obtained would be too steep for aquaculture operator purposes.
Pine Creek Hatchery in Northern NSW, used to produce huge numbers of Guppies, for sale to Wholesalers and Retailers, but, are now reducing their workload on these fish, as it has become increasingly un-profitable to the owners of this Hatchery over the past few years. They were producing more than they could sell, and aquaculture operators were not prepared to pay a much higher price for guppies when they could obtain cheaper alternatives, eg Goldfish, Gambusia spp.
Conclusion
My recommendation to Biosecurity Australia for all Poeciliids, is that Australia’s ALOP is adequately served qualitatively as under Exposure Group 2 – Farmed Foodfish that risk is shown as VERY LOW, and it would have been the same for Exposure Group 3 – Fish in Natural Waters if it were not for a number of Poeciliids that are in a number of places in Australia already, be they in tropical areas, and have been there for decades without any outbreaks of a quarantine disease of significance, ie an iridovirus as it would have been reported by now, and the FACT that it is listed in your conclusion as a LOW risk should be enough to allow Biosecurity Australia to do nothing.
The species of major concern here appear to be farmed foodfish eg, Murray Cod, Silver Perch and the like in the Southern half of Australia, where NO ornamental finfish Poeciliid varieties would exist due to the colder temperatures presiding in these places.
Also, the fact that there is NO information available on the prevalence of iridoviruses in cichlids, goldfish, or poeciliids: no exports from South America, USA, or United Kingdom, and the fact that Singapore is one of the cleanest exporters of ornamental finfish in the World; and the CLASSIC EXAMPLE of Tasmanian Inland Fisheries (a State within Australia) allowing all Poeciliids from mainland Australia is testament to these Poeciliids being a non-event as far as Biosecurity Australia should be concerned.
Tasmanian Inland Fisheries restrict a whole host of species of ornamental finfish into Tasmania for a number of reasons, but do not prevent Poeciliids, and this should be enough reason, together with Australia’s ALOP mentioned above to allow the continued import of all Poeciliids without any further restriction of impedence whatsoever, because there is NOTHING in your report that warrants it
General Comments
The misrepresented data mentioned in my introduction of this report comes about in Appendix 3 – Summary of the known locations of ornamental fish established in Australian waters in 2006 (Corfield et al. 2008).
A number of species mentioned therein are in isolated localities and can be eliminated very swiftly if Fisheries Departments wanted it so, BUT obviously this is not a priority of any Fisheries Department, because it would not suit their collective purposes, as they continually “beat the Industry” over their heads for these introductions.
The jewel cichlid (Hemichromis bimaculatus) are in the Botanical Gardens in Cairns, where they could easily be removed by electro-fishing, BUT, this does not happen.
Blue Tilapia (Oreochromis aureus) has no data shown. How can you list a species as this in Australian waters when you do not show a locality. This misrepresents the true story, and that is that the Blue Tilapia has not been in Australia, and listing it should never occur. I’m also told by R.McKay that they do not exist in Australia.
Oscars, (Astronotus ocellatus) are now believed to have died out in Cairns, as they are unable to be detected there (R.McKay pers.comm), and this should be removed as an establishment in this locality, due to fluctuating temperatures.
The three-spot cichlid (Cichlasoma trimaculatum) was caught from the Hinze Dam, but from all intents and purposes it has not established there, so this means it is an introduction not an establishment. So Corfield et al (2008) have not done their collective jobs properly by listed it as established as R.McKay pers.comm., has stated it has not established itself. This species should therefore be removed from your Appendix 3 listing.
Jack Dempsey (Cichlasoma octofasciatum) is shown in Angourie in northern NSW. This is a quarry, where it can easily be eliminated if need be, BUT, Fisheries do not feel it is a priority to do so. Therefore it should be removed from your Appendix 3 listing.
I’m reliably told by R.McKay in personnal conversation with him that the Firemouth cichlid (Thorichthys meeki) and the Banded cichlid (Heros severus) no longer exists in Ross River as they were an introduction that did not establish, so these two species should be removed from your Appendix 3 listing.
The redhead cichlid (Vieja synspilum) has no data shown for its establishment. How can this be shown, when no data is listed as to its existence. This will need to be removed from your Appendix 3 listing completely, and the authors of this list told to remove them, if no data is found on their existence. It would appear that these authors list species felt to be in existence when no work is done to prove it, which is tantamount to a LIE!
The convict cichlid (Archocentrus nigrofasciatus) is shown in Eel Hole Creek and LaTrobe River in Victoria, which is highly unlikely as the specimens in Hazelwood Power Station have tried to get into the lower reaches leading from the Power Station and have failed to survive, so there is no way the animals would have survived in Eel Hole Creek or LaTrobe river over any Winter season due to the very cold water conditions anticipated in those areas, so these should be removed from your Appendix 3 listing.
Blue Acara (Aequidens pulcher) are not present in Creeks in Brisbane and Leslie Dam as R.McKay in personnal communication with him states they are not present there. Again, this is another listing by these academics who have not researched their subject very well, or they have used other academic listings without first checking their existence, and they should be removed from your Appendix 3 listing.
Rosy Barbs (Puntius conchonius) is shown as established in Streams in and south of Brisbane where they are now EXTINCT from as R.McKay in personnal communication
has attested to this saying they died out when the water temperature reduced to lower than they would stand one Winter. Therefore this location should be removed from your Appendix 3 listing.
Whitecloud Minnows (Tanichthys albonubes) are in a quarry in Somersby NSW and can easily be removed by Fisheries if need be, BUT there is no priority to do so, and R.McKay in personnal communication states they are not in a creek in Brisbane, so these two locations should be removed from your Appendix 3 listing.
So, when you remove all these comments of mine above the Appendix 3 listing will probably be only one page and not two as shown by the authors Corfield et al 2008.
I don’t know how many times I have pulled such lists apart, and advised of errors in them, BUT they never get amended by anybody in Government circles and THEY SHOULD be amended to show the TRUE picture of establishments.
Summary
I commend Biosecurity Australia to look into matters of significance to Australia’s biodiversity when it comes to disease outbreaks and the like. However, I have not been able to find any evidence in your report or elsewhere that would give Biosecurity Australia any cause for concern, as Australia’s ALOP is well and truly covered by all the particular risk management measures or combination of measures for the following reasons;
1. Microgeophagus ramerizi: The virus associated with this species only affects it and no other ornamental finfish or other native species in which it comes into contact with and 4 of the 5 Exposure Groups of concern are eliminated in this report as shown above, therein satisfying Australia’s ALOP in qualitative terms, as it is shown to be a VERY LOW or NEGLIGIBLE risk.
2. Iridovirus of Angelfish varieties. The virus associated with this genus only affects them and no other ornamental or native finfish species that it comes into contact with, and again 4 of the 5 Exposure Groups of concern are eliminated in this report, as mentioned above, therein satisfying Australia’s ALOP in qualitative terms, as it is shown to be a VERY LOW or NEGLIGIBLE risk, particularly as there have been literally thousands of imported angelfish varieties to Australia since the virus was described by Lewis and Leong in 2004.
3. Goldfish Iridoviruses 1 and 2. Under 5.1 Release assessment in your report for Goldfish the risk (page 60) is shown as LOW and under 5.2.2 Exposure Group 2 (page 65) the risk is shown as VERY LOW, so under Australia’s ALOP it means the measures or combination of measures currently employed for all goldfish varieties is considered as acceptable, in qualitative terms.
Given the fact that there was only one report of an iridovirus of Goldfish being detected from the USA, and that goldfish has been studied more than any other species of ornamental finfish in your report and elsewhere, it is very reasonable to consider that there is not enough evidence of concern that would give Biosecurity Australia any cause for concern.
Your report simply does not show a need to place much more stringent measures on this genus as well as the previous two species or on exporting Countries whom are already unhappy about all the paperwork and certification that must accompany shipments of fish to Australia, as they consider Australia as only a very small percentage of their annual turnover, and if more and more measures and restrictions are placed upon them, without valid scientific grounds as in this genus, they will simply avoid Australia altogether and take their business elsewhere, therein an Industry worth in excess of $450 million P.A. will be at risk of surviving in financial terms.I’M SURE BIOSECURITY AUSTRALIA WOULD NOT WANT THIS TO OCCUR!
Particularly, in such volatile economic circumstances it would soon impact onto hundred and hundreds of more people being placed onto the unemployment line and business turnover being sizeably reduced, if we have more species eliminated from our retail trade for no concrete and valid scientific rationale whatsoever.
4. Dwarf Gourami iridovirus – DGIV. As stated in this report, the iridovirus associated with Dwarf Gouramis only affects them and no other ornamental finfish in which it
comes into contact with, and as they are NOT POND BRED in Australia, and have never been supplied to aquaculture operators as feedlots for foodfish broodstocks due to their collective costs, the risk is therefore a NON-EVENT. Especially as the 3 spot Gourami is reported to be in the Ross River in Queensland (although this introduction is not felt to exist. R.McKay pers.comm.) and in Sheepstation Creek in Queensland, and no specimens have been highlighted as having an iridovirus attached, as it would have been mentioned in your report.
Therefore, under your Group Exposures 2 and 3 the conclusion is that the risk
associated is VERY LOW and therefore, would adequately satisfy Australia’s ALOP
in qualitative terms.
5. Guppy iridovirus – GUV-6
From your report on page 17 it appears to me that 100% of all imported Poeciliids are directed to the ornamental finfish Industry, by one way or another, and this has been verified by two sources in your report that were 9 years apart, and none are imported for the aquaculture operated farms. It does appear again from your report that Farmed Foodfish operators use Gambusia spp., in their operations, which is a good thing, I would have thought as it helps to eliminate a pest species from the wild, which incidentally was put there by Governments in 1925.
In NSW the Fisheries Department allows all retailers to sell Gambusia spp, as a food fish for species like Oscars, Saratoga, Barramundi etc.
With all these facts in mind, and the sheer fact that there is NO information available on the prevalence of iridoviruses of cichlids, goldfish or poeciliids, then there is no cause for concern for Biosecurity Australia to do anything. The one example, be it a bad one, is that A.normani apparently carries this disease, but, it is not a permitted import to Australia, which is why it is a bad example – so it is a NON-EVENT.
Especially as shown under Exposure Group 2 – Farmed Foodfish the risk is shown as VERY LOW, and again under Exposure Group 3 it is shown as LOW, but we all know it would have been VERY LOW if not for the fact that there are a number of places in tropical Australia where they are existing, BUT not expanding their ranges, due in the main to predation.
The other CLASSIC EXAMPLE is that Tasmanian Inland Fisheries (a state within Australia) have not stopped the transportation of poeciliids to Tasmania from the mainland, is a clear case of a NON-EVENT when it comes to poeciliids.
Therefore, Australia’s ALOP in qualitative terms is well and truly covered, and Biosecurity Australia should not have any cause for concern
From all the information supplied above in this report, I cannot find any evidence of a cause for concern for Bioversity Australia to do anything with regards to M.ramerizi, Angelfish varieties, Goldfish varieties, Dwarf Gouramis and Guppies or other livebearers, as Australia’s ALOP is well and truly served in qualitative terms.
Yours Sincerely,
Norm Halliwell.