Comment from RICHARD GASKALLA, FL DEPT OF AGRICULTURE AND CONSUMER SERVICES

April 14, 2008 Docket No. APHIS-2006-0189 Regulatory Analysis and Development PPD, APHIS Station 3A-03.8 4700 River Road Unit 118 Riverdale, MD 20737-1238 To Whom It May Concern: This is to provide comment on Docket No. APHIS-2006-0189, Movement of Hass Avocados From Areas Where Mexican Fruit Fly or Sapote Fruit Fly Exist. We understand that Hass avocado is resistant to infestation by the Mexican fruit fly while on the tree in early stages of maturation; however, it is subject to infestation after harvest or if fruit have been physically punctured by some means. Although the proposed rule seems to address these issues by requiring certification that fallen fruit are not harvested and that tree-harvested fruit not be exposed for excessive periods of time while in the field, we remain concerned that there is no adequate regulatory oversight of these programs to ensure that this does not take place. Workers hired to harvest these avocados are invariably paid based on the amount of fruit harvested each day. This means there is a large incentive to pick fruit up off the ground to increase one’s earnings. We continue to be very concerned about Mexican fruit fly becoming established in Florida since citrus is a preferred host and there is no adequate attractant for early detection purposes. For these reasons, we are opposed to this proposed rule. Sincerely, CHARLES H. BRONSON COMMISSIONER OF AGRICULTURE Richard D. Gaskalla Division Director RDG/cr