Comment from Thomas Culliney

Based on the recommendation in the Peruvian citrus PRA, the new rule proposes to mitigate risk associated with the introduction of the citrus fruit borer, Ecdytolopha aurantiana (currently accepted name: Gymnandrosoma aurantianum) (Lepidoptera: Tortricidae) merely with post-harvest inspection in Peru and fruit cutting at the U.S. port-of-entry. (Curiously, the Federal Register notice cites the effectiveness of port-of-entry fruit cutting in detecting fruit fly infestations in clementines from Spain, two years or so after these very fruits were discovered in American grocery stores, infested with Mediterranean fruit fly.) The notice suggests that G. aurantianum is not likely to find suitable hosts in the United States because of its limited powers of flight, and makes the bold assertion that the pest "is easy to detect in visual inspections" (p. 57209; italics added for emphasis). I certainly would not make such a facile statement, and do not believe that the confidence in inspection as a sole mitigative measure is warranted, particularly given the tiny proportion of consignments typically inspected and the rumored unreliability of inspections now that AQI is largely the responsibility of Department of Homeland Security personnel. Gymnandrosoma aurantianum is dangerous, and the proposed rule change for Peruvian citrus seems to gloss over the danger. The moth is considered a key pest of citrus in Brazil and is difficult to control; as such, it represents a significant threat to the U.S. citrus industry. It also is found in Mexico, and has been recorded on guava. It was analyzed and given an overall risk rating of high in the Mexican guava PRA. As discussed in that PRA, a parapheromone has been synthesized, is available commercially, and can be used in a trapping program to certify area freedom from the pest. Gamma irradiation at a dose of 400 Gy has been shown to provide effective control of G. aurantianum in citrus. Mere inspection for G. aurantianum in fruit is inadequate to ensure phytosanitary security. I suggest that any rule change to establish conditions for Peruvian citrus imports consider potentially effective mitigations, such as certification of area freedom from the pest or pest-free places of citrus production, or a combination of treatments, such as irradiation, cold, or heat (the latter two requiring research to determine efficacy) plus other measures to provide the appropriate level of protection.