Comment from Caroline Gottesman

Re: Docket No. APHIS-2007-0152 “Importation of Grapes from Chile Under a Systems Approach” Dear Sir/Madam, My comment is directed at the amendment of fruits and vegetable regulations to allow fresh Chilean grapes into the U.S. using a systems approach. I believe that the proposed rule to reduce the amount of methyl bromine used in fruits entering the United States is valid, and a step toward fulfilling the obligations laid out in the Montreal Protocol and the Clean Air Act. This rule is valuable because it aims to both reduce emissions thereby protecting the Ozone layer and does not disrupt the market because growers are still allowed to use methyl bromide if they are unable to control Breviapalus cheilensis with a systems approach. I am curious as to whether or not these farms will be rewarded in some way if they abstain from using this chemical. I did not find an incentive for the extra cost and effort it would take for the farmers to implement and maintain a systems approach within this structure. If there is no incentive, and they are allowed to contain fumigating their fruit for export into the U.S., what would compel them to switch systems? Additionally, this rule does not state how customers would know which grapes were processed by a systems approach, and which by methyl bromide. Will the phytosantiary certificate follow the grapes into the U.S., or will it – like the phytosanitary inspection identification – only be maintained only until the fruit is released for entry into the U.S.? Customers may be interested in purchasing grapes that were not treated with methyl bromide, and they could pass this information along to consumers, who have shown great interest in reducing chemical contaminants in their food. The increased interest in non-treated grapes could serve as an incentive for Chilean farmers to switch to a systems approach. Best Regards, Caroline Gottesman