Ibex Ventures Inc.
The Old School House
Rural Route One, Swalwell, Alberta,
Canada T0M 1Y0
Telephone & Fax:


Dr. Samira Belaissaoui, Animal Health and Production Division,
Canadian Food Inspection Agency,
59 Camelot Drive, Ottawa,
Ontario K1A 0Y9

Dear Dr. Belaissaoui,

I am writing in support of the proposal to open the US border to importation of queen honey bees. Ref: Canada Gazette, Part I, Vol. 138, No. 15 April 10, 2004.

At this point the honey bee prohibition serves no useful purpose, but rather the ban impedes growth in our industry, and brings Canadian honesty into question in matters of trade with the USA at a time when we need to show that we mean what we say about open borders. We are not playing fair, and they know it. Please consider this public statement by Bill Wilson USDA (retired).

"The conclusions that are reached in the risk assessment communicate a message to knowledgeable beekeepers that the Canadian border closure is little more than a disguised trade barrier. Based on the evidence provided, there is no known reason for limiting any trade in queens, and very little information why packages should be restricted from trade. If America were to apply similar trade barriers to Canadian honey under equally obscure rationale, the Canadian industry would collapse."

As a cattle producer, as well as a beekeeper, I am particularly embarrassed by the slow progress being made in eliminating the outdated and indefensible exclusion of U.S. bees. As a former commercial beekeeper with over four thousand hives at one time, and student of the bee industry, and one who has worked with bees in both the USA and Canada in recent years, I can attest to the economic importance of restoring our supply of mainland U.S. queens and the urgency for an immediate repeal of the embargo.

As it appears at this moment -- even if the proposed changes go as proposed -- I estimate the industry will needlessly lose an additional $8,000,000 this season due to the late date at which this proposal was published, unless the approval process is accelerated and permits issued soon.

At present, it seems that the embargo cannot or will not be lifted in time for queens to be raised and shipped to Canada for the critical May market this Spring. This is not to say that there will not be huge benefits in the future, but the critical queen shortage occurs annually in mid-May, and -- especially since the closure of the U.S. border -- there have never been enough queens to meet demand.

Although the prohibition may have served a useful purpose at one time, and undoubtedly benefited a vocal segment of our industry, the total damage it has caused to the Canadian honey industry now appears to outweigh any good the ban has accomplished.

At this point, the prohibition serves no useful purpose, but rather the trade disruption greatly inconveniences those in the industry who would provide growth.

I urge you to treat the removal of this prohibition with the utmost urgency.



Allen Dick, president,
Ibex Ventures Inc.