Comment from John Snyder, Riverside County Agricultural Commissioner's Office

June 2, 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 it 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 different. 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 destined 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. Riverside County represents one of the major Hass avocado growing regions in the country, and is contiguous / adjacent to San Diego County’s intensive avocado growing area. While I appreciate the removal of the bait sprays and improved freedom of movement for our fruit, I also recognize the critical importance of insect trapping as the primary means for detecting and combating such infestations. In that regard, we don’t see a benefit from eliminating the trapping, only greater risks. I thank you for your consideration of our perspective. Sincerely, John Snyder Agricultural Commissioner/ Sealer of Weight & Measures Riverside County, California