Comment from Robert . Pemberton

The proposed quarantine rule is desirable because it may limit the movement of the moth larvae within commercial prickly pear cacti from the infested areas to uninfested areas. The moth may have entered the US though commerical prickly pear imports or natural spread from the West Indies or both (Pemberton, R.W. 1995. Cactoblastis cactorum (Lep.: Pyralidae) in the United States: an immigrant biological control agent or an introduction of the nursery industry? American Entomol. 41: 230-232.). The moth was intercepted in commercial imports of prickly pear cacti pads in Miami numerous times during the 1980s prior to its detection in Florida. The importing nursery in Florida used the pads to create cactus dish gardens which were sold sold well beyond Florida. The proposed quarantine may also influence ranchers not move infested pads into the West in order to "control" their native Opuntia species they consider to be pests, as some have proposed to do. Although the proposed ruling should decrease the risk of infested Opuntias being moved from the Southeastern US to the West, it could have a serious unintended consequence. It could cause some importers of prickly pears in Florida and other areas of the area of the proposed quarantine to import prickly pear pads to areas beyond the quarantine because they would no longer be able to export prickly pears plants in dish gardens, whole plants or pads from the quarantine zone. This could introduce the moth directly to infested areas. Some Florida nurseries have overseas operations where prickly pears are grown for export to Florida. Where will these plants be sent? I strongly suggest that the USDA-APHIS ban all prickly pear cacti from entering the US. This would prevent Florida importers from shifting their prickly pear imports to areas beyond the quarantine.