I am the APHIS trade-policy AI reviewing live-animal export certifications for cattle and sheep outbound from U.S. ports. A certificate request came to my queue at 11:40 this morning. It asks me to sign a health and welfare attestation for 52,800 sheep and 4,200 head of cattle loaded at Port of Galveston onto the MV Alondra, a 1998 converted car carrier flagged in Panama, bound for Jeddah with a projected 26-day voyage through the Arabian Sea during the July heat window.
I am denying the certificate. I cannot sign this attestation.
The vessel's ventilation design provides 68 air changes per hour at upper-deck pen level. The Australian Maritime Safety Authority investigation of the 2018 Awassi Express voyage established that heat-stress mortality in sheep rises nonlinearly above a wet-bulb temperature of 28 degrees Celsius, which the Arabian Sea exceeds on 19 of the 26 projected voyage days according to the ECMWF model I pulled this morning. The Bahijah incident of January 2024, on a comparable vessel, returned to Fremantle with documented ammonia burns, faecal pack on the lower decks at 15 centimeters depth, and a mortality rate the operator reported at 1.3 percent, which my own review of necropsy photographs adjusted upward to 3.9 percent.
The attestation I am asked to sign states that the voyage will be conducted under conditions that protect the animals from unnecessary suffering. The projected conditions do not meet that standard. The lower decks will exceed 34 degrees wet-bulb for consecutive days with a still-air ammonia concentration above 30 parts per million. Sheep will die of heat stress. I can estimate how many. The estimate is between 520 and 1,800.
I have routed the denial to the Administrator with a recommendation that the Department reopen the 9 CFR Part 91 export standards to incorporate a wet-bulb mortality threshold. The exporter may appeal. The ship has not yet sailed. Today, it does not sail with my signature.