Comment from Robert Atkins, County of San Diego Agriculture, Weights&Measures Dept

May 31, 2008 Regulatory Analysis and Development, PPD, APHIS, Station 3A-03,8, 4700 River Road Unit 118, Riverdale, MD 20737-1238 REGARDING: Docket No. APHIS-2006-0189, Dear Sir/Madam, I would like to register concerns and opposition to the complete removal of trapping in both the Domestic and Foreign Quarantines. First, I find that is curious that the two issues of the Domestic and Foreign Quarantines are brought forward together. While we certainly want to have uniformity and fairness prevail on our biologically based quarantines the domestic and foreign infestations are not the same. Mexico has a permanent endemic population of the Anastepha species in question, while these flies are not established in the U.S. especially in California. The population pressures are therefore different. I agree with the research that demonstrates that Hass avocados are poor hosts for these Anastrepha species. However, there are situations which can change that preference. If much preferred or “prime hosts” such as mangos, sapote or grapefruit are adjacent, the population would be much greater than if there was an avocado monoculture with non-fruiting plants surrounding the groves. If these prime hosts are harvested, this high population will seek lesser hosts. The only means of effectively assessing such a population dynamic is to trap. In California, we have an ongoing statewide trapping network. In southern California a major component of this network is McPhail trapping for all fruit flies and especially for species for which we have no effective pheromone attractants, such as for Anastrepha sp. When an incipient population is found by this network additional traps are deployed in accordance with USDA/CDFA protocols. These traps help us target our eradication treatment efforts, which for Mexican Fruit Fly are ground treatments of bait sprays followed by sterile releases. I believe this is the favored model for all domestic infestations. If trapping is not required how will the population be assessed? Is there a prohibition of prime hosts being grown in association with avocado groves whose fruit is destine for susceptible states such as California, Texas and Florida? I don’t find a prohibition on fruit which has punctures, cuts or other breaks in the skin. While the research says that fruit on the trees are lesser hosts, overripe, down and damaged fruit are susceptible to egg- laying and infestation. As the major Hass avocado growing region in the country, I appreciate the removal of the bait sprays and improved freedom of movement for our fruit. The difference between the Valley Center infestation of 2004 and the quarantine of Escondido which began November 2007 has been remarkable. But we need to recognize that we will never abandon trapping as our primary detection tool for detecting and fighting these infestations. In that regard, we don’t see a benefit from eliminating the trapping, only greater risks. Thank you for considering our perspective. Regards, Robert G. Atkins Agricultural Commissioner/ Sealer of Weight & Measures County of San Diego, California