Comment from Walther Enkerlin

The North American Plant Protection Organization (NAPPO) considers the South American cactus moth (Cactoblastis cactorum) to be an invasive species which poses important economical and ecological threats to arid ecosystems throughout the Southwestern USA and to coastal ecosystems along the Gulf of Mexico. NAPPO is also concerned about the spread of Cactoblastis into Mexico where Opuntia cacti is also a vital resource as it is considered to be a staple food for the poorest people living in the rural areas of Mexico. In addition the Opuntia industry in Mexico, valued at US $150 million per year, is a major source of employment in the rural areas. If Cactoblastis was to spread into the Southwest USA, its spread to Mexico would be only a matter of time. In the USA the negative effects of Cactoblastis on the ecological balance would trigger other indirect effects. For example, the cattle industry would suffer as Opuntia are used by cattle as fodder during severe droughts. The highly lucrative hunting industry would also be affected as Opuntias sustain major wildlife such as white tail deer and javelina (pecari). In addition, the prominent cactus nursery industry along the Southwest USA would be severely affected as experience in the Caribbean has shown. If Cactoblastis were to establish and spread costly surveillance and control measures would have to be implemented, most likely including the use of synthetic insecticides. One key element in the integrated approach to control Cactoblastis is the enforcement of domestic quarantine regulations to prevent the movement of host material from the infested states in the Southeast part of the USA to non-infested areas in the Southwest and further along the Gulf of Mexico. The proposed APHIS rule addresses this phytosanitary measure and will be an important complement to current surveillance and suppression/eradication techniques being applied at the leading edge of the infestation. This program against a major invasive insect species has been successful so far and is considered to be a model of cooperation between the USA and Mexico.