Comment from Javier Trujillo

Docket No. APHIS-2006-0189 RIN 0579-AC67 Movement of Hass Avocados From Areas where Mexican Fruit Fly or Sapote Fruit Fly Exist. To whom it may concern This is to provide Comments of the Secretaría de Agricultura, Ganadería, Desarrollo Rural, Pesca y Alimentación (SAGARPA) on the Proposed Rule Movement of Hass Avocado From Areas where Mexican Fruit Fly or Sapote Fruit Fly Exist ---Docket No. APHIS-2006-0189 SAGARPA has defended that avocados do not host Mexican fruit flies and Sapote Fruit fly. We believe that the scientific support contained in the article by Aluja et al. 2004 (Martín Aluja, Francisco Díaz Fleischer and José Arredondo, 2004, Non- host status of commercial Persea americana “Hass” to Anastrepha spp. fruit flies in México, Journal Of Economic Entomology 97 (2):293-309), which documents the scientific evidence showing that the Hass avocado is not a host for fruit flies, together with having been no detections of quarantine pests throughout 10 years of exporting, ensures an adequate level of plant health protection for the United States, including the avocados-producing areas, given that they would not be facing any plant health risk of any kind. In this regard, we strongly support APHIS proposal to formally recognize the scientific information available and to ensure consistency on what it is required to the domestic industry to those measures requested to foreign countries. When defining the definitive measures those domestic growers, packers and shippers will have to comply to eliminate the risk inherent with fruit flies, we encourage APHIS to ensure that those measures are identical to the ones requested to Michoacan growers (at the field level, packinghouses, packing material and transportation conditions). There should not be any evidence of discriminatory treatment against the Mexican growers when dealing with the same level of risk. We would have liked APHIS recognize the scientific evidence on avocados as a non host of fruit flies a long time ago. This would have send the right signal to trade partners that the US honors its trade obligations established under the WTO and NAFTA SPS Agreements. In this regard, the Government of Mexico encourages APHIS to proceed with others changes requested to the regulation that governs the exportation of Mexican avocados. It is highly important to adhere to existing scientific evidence and move to forward in a more expeditious manner to take care of third countries interests. Sincerely Javier Trujillo Arriga General Director