Comment from Dirk T Winkelmann

July 19, 2006: We view the import of Namibian grapes to the US as a benefit to both our organization and to US consumers. Benefit to our organization: We are a California producer of table grapes and market our grapes in the June through November time frame. Our commercial association with Namibian growers for imports to the US would allow for a continuing service to our US customers during the off season months and help to maintain an active workforce. We fully expect that the protocol (Cold Treatment, fumigation and NPPO inspections) to address the phyto risks associated with the import of the product into the US. Benefit to US Consumers: It is well known that fruits and vegetables are part of a healthy diet. The continuous offering of fresh, good quality produce is essential to creating demand and enticing consumers to buy fruits and vegetables. Namibian product arrivals to the States, taking into account transit times and treatment protocols, would fill a window when US production is on the wane and/or over in seedless production. Namibian "commercial" producers can be generally classified as highly professsional growers with extensive experience in meeting rigorous export and import requirements in different markets around the world. Namibian growers have weel established programs to British retailers who are extremely stringent in their food safety requirements, and while this is not a phtosanitary related aspect, it does speak to the general discipline exhibited by the commercial Namibian growers. Nambian exports to the US will be minimal compared to their exports to other markets, speciffically the UK and the European continent. The reality is that the UK and the European continent are closer markets requiring much less transit time which allows a large percentage of the product to arrive prior to the Christmas holidays when a higher average price is received in the market. Shipping to the US requires an additional two weeks transit time which will for the most part always place the US as a smaller market target for Namibian growers. Despite this, the growers will most likely send some minimal volume to the States to diversify their market risk. Given this they will be all the more disciplined in assuring a top quality is presented to the US consumer and a quality image is created for their product. Namibia will be competitng against Chilean product in the same time frame of late November and December arrivals to the States. The infrastructure surrounding imports is well established, to inlcude inspections, surveys, shipping, port facilities, expediting, trucking and cold storage. The Namibian product would be arriving at a generally slower time for some of these operations and undoubtedly will be viewed favorably by these service providers in terms of additional business and employment. In summary, we support the proposal to allow Namibian table grape imports to the US and the myriad of benefits that would accrue to multiple types of companies and to the US consumer. Sincerely, Dirk Winkelmann Sr. VP Global Business Development Sun World International LLC