Comment from Richard D Gaskalla, Florida Department of Agriculture and Consumer Services

April 23, 2007 Regulatory Analysis and Development USDA-APHIS-PPD Station 3C71 4700 River Road Unit 118 Riverdale, Maryland 20737 RE: Docket No. 01-054-3 To Whom It May Concern: This is to express the continued concern of the Florida Department of Agriculture and Consumer Services over the United States Department of Agriculture?s failure to implement adequate regulations to prevent the spread of Sudden Oak Death (SOD) on California nursery stock and to provide specific comments on Docket No. 01-054-3, Phytophthora Ramorum; Quarantine and Regulations. It is unconscionable to continue to permit the movement of hosts and associated hosts out of areas quarantined for SOD until such time as adequate techniques are developed to certify nurseries free of this disease. It was reported that no SOD infected plants were shipped out of California last season; however infected camellia plants continue to arrive in eastern nurseries. This is likely due to the overuse of fungicides that are masking disease symptoms at the California nursery of origin. The fact that SOD continues to spread by wind in coastal California, sporulation is occurring on asymptomatic leaves and the host and associated host lists continue to grow is justification for a very conservative approach. Nurseries within quarantine areas should be required to grow nursery stock within structures that are protected from windblown SOD spores and plants within the structure should have a negative SOD test prior to shipment. At a minimum, the high risk hosts: Pieris, Viburnum, Kalmia, Camellia and Rhododendron should be prohibited from moving out of quarantine areas. RE: Docket No. 01-054-3 April 23, 2007 Page Two Extensive SOD surveys in the eastern U. S. indicate that SOD has not yet become established in eastern forests or in any U.S. forest outside of western coastal states. This is unlikely to hold true for long if SOD infected stock continues to move out of quarantine areas. Sincerely, CHARLES H. BRONSON COMMISSIONER OF AGRICULTURE Richard D. Gaskalla Division Director RDG/cr