Optimus, Inc.

687 NE 79th Street * Miami, FL 33138 * Tel: (305) 758-9282 * Fax: (305) 758-0008


July 29, 2004


Division Of Scientific Authority
U.S. Fish and Wildlife Service
4401 N. Fairfax Drive, Room 750
Arlington, VA  22203


Dear Sir:

Optimus, Inc. submits this comment on the U.S. Fish and Wildlife Service (FWS) proposed rule under Section 4(d) of the Endangered Species Act relating to beluga sturgeon.  Optimus is one of the largest caviar and gourmet foods importers and distributors in the United States.  With nearly 20 years of experience in the field, it also enjoys a solid reputation on the international market of caviar and gourmet foods.  Optimus, Inc. is a member of the Sturgeon Stewardship Council and of the World Sturgeon Conservation Society, international organizations whose goals include sturgeon protection, research and sustainable use.  FWS has noted that while it is aware of range countries’ beluga hatchery operations, the agency is interested in learning more about the details of their commercial and restocking operations and how they relate to funding for recovery programs in the Caspian and Black Sea basins.  This comment responds to that request.

Optimus has a long history of extensive involvement with both the commercial and restocking aspects of beluga hatcheries in the range countries of Russia and Bulgaria.  For example, in March 2003, we signed an agreement with Raskat, a Russian caviar producer, to purchase beluga, osetra and sevruga caviar produced without killing adult female sturgeon. According to this agreement, in 2003 100% of beluga caviar would be produced without killing the fish; in 2004, this number would reach 90% for osetra caviar, and in 2005 -- for sevruga caviar.  The adult sturgeon that produced caviar would be tagged and released back into the wild, where their post- surgical adaptation and migration patterns would be studied. The agreement also ensured that there was a compensatory release of sturgeon fry into the Caspian Sea in order to replenish the declining stocks of sturgeon.

In February of 2004, Optimus signed an agreement with Lenriba JSC, another Russian caviar producer, to perform a compensatory release of sturgeon fry into the Caspian Sea for every kilogram of caviar that was purchased by the company for import into the U.S.  Every shipment had to be accompanied by an open DNA test of the product.

For many years, we have purchased caviar from a Bulgarian producer, Camarco Bros., which released 100 sturgeon fry for every kilogram of exported caviar.  The cost of this release was covered by Optimus.

In addition, Optimus was the first company to require DNA batch tests for each species of caviar, which would be verified by the CITES (Convention on International Trade in Endangered Species) Scientific Authority of the Russian Federation.  This DNA analysis of the roe of beluga, osetra and sevruga caviar has enabled us to ensure the quality of our product and that only legal sturgeon subject to the conservation measures implemented in Russia are placed into the commercial distribution chain.

We believe the above facts demonstrate that the beluga range countries have strong economic incentives in place to ensure a continued emphasis on conservation of the species.  Furthermore, we believe there is sufficient world demand for beluga products that these economic incentives would not be undermined by allowing U.S. aquaculture of the species.



Mark Zaslavsky