APHIS Public Comment

comment on aphis’ hpai control policy 1/30/2023

The Animal and Plant Health Inspection Service (APHIS), an agency of the United States Department of Agriculture (USDA), is seeking public comment on their HPAI strategy.

Please visit https://www.regulations.gov/document/APHIS-2022-0055-0001 to submit your thoughts!

Below is Hearth & Haven Farm’s comment:



I am writing to you today as a small farmer who has been directly impacted by the USDA HPAI response.

Case history

Prior to the USDA and WSDA-mandated cull of our flock at the end of 2022, I owned and operated Hearth & Haven Farm, a small duck egg operation located northeast of Seattle, WA.

On December 21st, 2022, we noticed four sick ducks in one of our flocks. We immediately reported these birds to the WSDA, who sent out a staff member that same day to obtain samples for testing.

Unfortunately, due to bad winter weather and the Christmas holiday, the delivery company was unable to get these samples to the state lab.

Our farm had been placed under a precautionary quarantine, so we did not know what disease we were facing and were unable to seek further testing or treatment from a veterinarian. As a result, we spent the Christmas holiday desperately nursing sick birds, culling those who appeared to be suffering, and burying the bodies.

While we suffered many devastating losses, 90% of our birds survived, and even birds who had showed symptoms began returning to health.  They were once again eating and behaving normally.

On December 28th, a WSDA employee was finally able to return to our farm to take new samples from our birds. State and federal employees heroically formed a relay to hand-deliver the samples to the distant state lab, and positive results were reported late that evening.

On December 29th, USDA and WSDA staff came to our farm and killed all of the surviving animals, regardless of their resistance or recovery status.

Business impact of the current USDA policy on our small farm

The current policy not only destroyed Hearth & Haven's flock, it has also destroyed our business.

Per USDA policy, we must wait for 120 days (four months) before we can even begin to incubate new ducks. Even if we began incubation the moment quarantine was lifted, it takes a month for eggs to hatch followed by an additional 4-6 months for a duck to reach laying age.

Given the timing of our case, that would mean our ducks wouldn’t reach laying age until November. Birds that mature in winter are unlikely to begin laying until the following spring…meaning that it would be more than a year before we could start producing eggs again.

Even if we did restart immediately, that still leaves us footing the bill for an entire year of expenses including feed, water, electricity, labor, and the purchase price of the replacement birds themselves, all while generating NO income.

No small business can afford to absorb these kinds of losses.

We had a quality product that was hard to find and that customers depended on. At the time of the cull, we supplied high-end Seattle restaurants, two grocery stores, a delivery service, and many local families – and we had a two-month-long waitlist for our duck eggs. The business was thriving and had a bright future ahead, with plans for expansion to meet the sky-high demand.

With few competitors in the marketplace for our niche product, there is nowhere for those customers to turn. Many local families who supported us relied on duck eggs because of a chicken egg allergy in the family. Their child could share Sunday brunch with the family or enjoy their own birthday cake thanks to our duck eggs. Now, sadly, there are very few options for them.

While the USDA does offer compensation for lost birds and eggs, it is only a tiny fraction of the farm's costs - for example, it would pay for only one third of a single delivery of feed. The program doesn't help with our ongoing operating costs, mortgage, bedding and supplies that will be collecting dust, empty barns and unused infrastructure that are slowly depreciating, or the five tons of leftover feed that will spoil before any new birds will be old enough to eat it.

We offered to not only quarantine, but to open up our farm as an experimental venue where officials could test and monitor the birds to better understand this horrible disease. Our offer was turned down for lack of funding, however, and the decision was taken to proceed with total elimination of our flock and our business.

The one-size-fits-all, elimination-only response the USDA has used until now is simply inappropriate in situations like ours. Applying one universal approach of killing every bird, every time is ineffective, unnecessary, and frankly needlessly expensive.

We need to change policies and consider farmers and hobbyists of all sizes, as well as the different species and even breeds involved. What's appropriate for a domestic million-chicken broiler operation may not be appropriate for a three million-bird turkey operation that sells meat overseas, a 6-chicken backyard flock, or my ~200-bird farm with ducks and geese. We need to adopt policies that allow for maximum flexibility in our HPAI response, since every farm and situation is different.

 Support for adaptive management

I would like to encourage adoption of the “adaptive management alternative.” As described in the EIS bulletin, this approach would allow for the adoption of new procedures and methods of responding to HPAI outbreaks. That flexibility is vitally important, especially as more and more research shows that there are promising alternatives to an elimination-only response.

Some small farms like ours could be managed under quarantine instead of culling. Especially in cases where the animals display a natural resistance to the disease, as ours did, it would not only be humane to allow the resistant birds to live, it would be a tremendous step forward in the development of natural resistance in our nation’s flocks.

The development of HPAI-resistant breeds and strains of poultry can protect both farmers and wildlife. Studies have already shown that resistance is naturally present in some populations:

“Among these breeds, Chee, Dang, and LHK showed significantly longer survival times than White Leghorns. Virus shedding from dead Thai indigenous chickens was significantly lower than that from White Leghorns”
https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0153649

“Resistant Ri chickens showed higher antiviral activity compared to susceptible Ri chickens”
https://www.ncbi.nlm.nih.gov/pmc/articles/PMC9271386/

It is vital that part of the USDA-led response to HPAI includes consideration of resistant breeds. Especially since studies has found that not only do resistant birds fail to show as many symptoms, they shed the virus less and can therefore break the chain of infection:
https://www.thepoultrysite.com/news/2016/07/genetic-resistance-offers-potential-breeding-solution-to-bird-flu

Taking it further, several studies even offer a roadmap as to exactly how we can approach breeding birds for H5N1 resistance:
https://link.springer.com/article/10.1134/S0026893310010061
https://www.mdpi.com/1999-4915/4/11/3179

At the same time, flocks that are being managed under quarantine and observation could benefit from consultation with wildlife specialists. Farms with an outdoor component, like our pasture-based operation, may pose much less of a risk to wildlife if offered some assistance in simple ways to deter interaction with wild birds. Funding could be made available to help farmers purchase netting or even flash-bang devices that would scare wild waterfowl and predatory birds, protecting domestic and wild flocks alike. Wildlife officials may be able to suggest other low-cost options as well.

Testing of soil, water, and the domestic birds on affected farms under quarantine could also provide valuable insight into how long the virus survives in different real-life environments and thereby better inform future management strategies. According to the research we have found, ducks shed HPAI for 5 days (https://pubmed.ncbi.nlm.nih.gov/21719821/) and the virus can remain alive in the environment for a maximum of 8 weeks in ideal conditions (https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3784916/). So choosing to cull and not quarantine Hearth & Haven’s birds over a week after they showed symptoms, when they were already returning to health, seems totally unjustified.

Studying those farms held under quarantine will allow us to make better, more well-informed management decisions in the future. Better still, measures like these would protect small businesses and allow farmers to return to production immediately once their flock has returned to health. This could even save money, as there would be no indemnity payment nor expensive cull and disposal operations.  

Vaccines are another avenue that appear to hold tremendous promise for HPAI management. While single-dose vaccines may not offer complete protection in all cases, administering vaccines in combination may in fact offer excellent immunity: https://pubmed.ncbi.nlm.nih.gov/31251524/

No single vaccine is perfect, of course, as we all know through human flu and COVID vaccines. But they should absolutely be a key component of our approach to handling this disease. Thus far, the USDA approach appears to have dismissed vaccines entirely, which is short-sighted. A simple look at the number of reported cases and at the high egg prices and empty shelves in the grocery store shows clearly that an elimination-only approach simply isn't working.

As this paper argues, "Vaccination needs to be implemented as part of a comprehensive control strategy that also includes biosecurity, surveillance, education and elimination of infected poultry.": https://www.researchgate.net/publication/255690584_Vaccination_of_domestic_ducks_against_H5N1_HPAI_A_review

And this study from as far back as 2012 makes it quite clear that our current elimination-only approach has been failing for over a decade:
“Conventional control strategies in poultry based on surveillance, stamping out, movement restriction and enforcement of biosecurity measures did not prevent the virus spreading…The use of antiviral chemotherapy and natural compounds, avian-cytokines, RNA interference, genetic breeding and/or development of transgenic poultry warrant further evaluation as integrated intervention strategies for control of HPAIV H5N1 in poultry.”
https://www.mdpi.com/1999-4915/4/11/3179
 

Why adopting new management policies and remaining open to new approaches is necessary

On the ground, the current elimination-only policy is not only ineffective, it’s dangerous. It is breeding mistrust and is terrible for the USDA’s public relations. Dozens of farmers and smallholders across the nation have told me in confidence that, having seen the devastating personal and financial fallout from the USDA’s elimination-only policy, they would choose not to report sick birds if their flock was affected.

In fact, on the day these comments are being submitted, two more small farmers approached me to express the same sentiment – they would not report it if their flocks became infected with HPAI.

Indemnity and compensation is so inadequate and the response so heavy-handed, it’s simply not worth it for many farmers to report. This will inevitably make it increasingly difficult for the US to track and manage not only HPAI, but future outbreaks of disease, as farmers lose trust in the government’s response.

A new management strategy is urgently needed, before public mistrust grows any worse.

improved communication is also required

Updated policies must also be clearly communicated to concerned departments at every level of state government, as well as directly to as many farmers, backyard bird keepers, and farm organizations as possible.

Thus far, there has been a huge failure in communication between government departments. There is currently such a disconnect even between departments within our own state that we have found it a tremendous challenge to get a straight answer even to the single question of how to best sanitize our barns. The Washington State Department of Agriculture, the State Department of Health, and our own county’s Department of Health each gave us different timelines for the fallow period, different timelines on when it would be safe to enter the houses for cleanout, different ideas on how to dispose of soiled bedding, and different (and very vague) instructions on what the proper level of PPE would be.

As this illustrates, communication regarding HPAI policy has been wholly inadequate so far, and any new management strategies need to be clearly shared at every level of federal, state, and local government.

Conclusion

As our personal experience shows, the single solution of killing every bird every time is ineffective, unnecessary, and frankly needlessly expensive. We must change our strategy and consider the bigger picture - how does any given management strategy affect farmers and hobbyists of different sizes? Is this strategy appropriate for this farm’s mix of animals, infrastructure, exposure to wildlife, and financial situation? What preventative measures can be taken, such as breeding population resistance and vaccines, so we are not simply reacting to existing outbreaks but actually heading them off before a problem arises? 

A comprehensive and inclusive HPAI response that uses all tools available to us, from treatment and quarantine to prevention, is the best strategy to protect farms, farmers, and both domestic and wild animals. We must ensure that all options remain on the table, and that each affected property can be managed in the way most appropriate to the situation. For all of those reasons, I urge you to adopt the adaptive management alternative.

 
Thank you for your time,
Elaine Kellner
Hearth & Haven Farm