Comment from RICHARD GASKALLA, Florida Department of Agriculture and Consumer Services

June 12, 2008 Federal Docket No. APHIS-2007-0144 Regulatory Analysis and Development Plant Protection Development Animal & Plant Health Inspection Services Station 3A-03.8 4700 River Road Unit 118 Riverdale, Maryland 20737-1238 To Whom It May Concern: The Florida Department of Agriculture and Consumer Services’ Division of Plant Industry (FDACS’ DPI) has reviewed Docket No. APHIS-2007- 0144, “Importation of Baby Squash and Baby Courgettes from Zambia” and offers the following comments. Florida is unique in climate, geography, and crop diversity in the United States and is justifiably one of the highest risk areas for exotic agricultural pest and disease introductions and establishment. Therefore, we are concerned about the proposal to import squash and courgettes from Zambia and the risk of exotic pest introductions. All the pests found in Zambia associated with the proposed product could become established in Florida. With the Dacus, Spodoptera, and Diaphania species all being internal feeders, inspection and detection at origin and destination are problematic and place Florida at high risk of introduction of these unwanted biological invaders. The use of systems approaches to achieve phytosanitary security must be carefully developed and applied. Oversight of the program is arguably the most critical component. It is very troubling to read in the proposal that oversight of the program will be carried out by the Zambia National Plant Protection Organization or its approved designee? What does this mean? Who is the designee and who approves them? Docket No. APHIS-2007-0144 June 12, 2008 Page Two Further, the proposal indicates APHIS can monitor the production sites before and during harvest. The word “can” is meaningless and, therefore, should read APHIS will monitor the production sites. The use of McPhail traps as a detection tool is also problematic as they have very limited sensitivity in detecting low-level fruit fly populations. The two pests that have the highest unmitigated risk, Helicoverpa and Spodoptera, are of great concern to us in Florida. Yet, there are no real mitigative measures to exclude these pests other than insect exclusionary greenhouses. There is no trapping requirement or specific inspection regime to assure there have been no breaches of greenhouses. In reviewing this proposal, the cumulative pest introduction risk is too high and the mitigative measures too low; therefore, we do not support the request and respectfully ask the USDA-APHIS to withdraw it to provide reasonable and well-justified safeguards to U.S. agricultural interests. As Florida is a particularly high-risk sentinel area and has a very large stake in pest exclusion programs, it would be wise and prudent to include FDACS’ expertise in the development and review of phytosanitary protocols much earlier in the development process. Sincerely, CHARLES H. BRONSON COMMISSIONER OF AGRICULTURE Richard D. Gaskalla Division Director RDG/dh