Comment from Jon Arost, SDL

Document ID: APHIS-2007-0022-0010
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: July 12 2007, at 12:13 PM Eastern Daylight Time
Date Posted: July 12 2007, at 12:00 AM Eastern Standard Time
Comment Start Date: June 21 2007, at 12:00 AM Eastern Standard Time
Comment Due Date: August 7 2007, at 11:59 PM Eastern Standard Time
Tracking Number: 80267725
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The new proposed ruling is very disappointing. The USDA has constantly stressed how science and not any outside force will dictate this ruling. After reading the science that went into the final rule being published, I can not comprehend how any sort of organization with the information at hand can honestly rationalize that they should continue to quarantine the movement of Florida citrus. Obviously there is a slight risk associated with Florida citrus; however, there is an extremely small risk associated with everything in all aspects of life. There are many different varieties of fruits, vegetables, trees, and many other species of agriculture that are under your jurisdiction. Many of these varieties have similar problems that could be considered harmful if movement goes unchecked and the problems are allowed to spread. However, your organization takes a drastically less severe approach in dealing with these varieties and their potential problems, rather than establishing state wide quarantines. When science is on the side of the Florida shipper - as canker has been scientifically proven, barring something just short of divine intervention, not to be able to spread from the packinghouse level once properly treated to other citrus producing states - it really makes an individual question the ruling. It becomes very easy to ponder whether this ruling has anything to do with science at all or whether political clout and money really do much more of the talking than science. Combining this with the fact that the state run organizations of Florida, ?Florida Citrus Mutual? and ?Florida Citrus Packers? are much more concerned about getting ?hand-me-downs? from your organization concerning anything to do with grapefruit, rather than what is really right concerning this issue makes one wonder if we will ever get this quarantine lifted. A rationale individual would just assume that the USDA much like most of our government is only concerned with what is important politically and monetarily instead of what is really right. If canker is such a serious threat why does the USDA allow Florida exports into the citrus producing areas of Europe? If canker is truly worth such restrictive interstate movement regulations, wouldn?t it be the USDA?s duty to disclose the serious threat of canker to the European countries and your organizations uncertainty about containing it and thus restrict Florida movement there as well in an effort to keep them from getting infected with this serious threat? Rather, it seems the USDA has once again taken the political approach by saying canker is only a serious threat to certain states within the United States and European citrus producing countries should not be worried about becoming infected by canker. Any rational individual must see the contradiction in the drastic difference between the two rulings; however once again your organization gives no scientific basis for this difference. The parties at stake must wonder if this difference is based on a combination between the selfish desires of other citrus producing states in order to easily promote their own products and a compromise struck between Florida?s governing bodies and your organization to gain grapefruit concessions and maintain European shipments instead of fighting the irrationality of your proposed ruling. Based on the present science and your organization?s position on diseases concerning so many other varieties under your govern; this ruling is not only incomprehensible but instead utterly appalling.

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