Comment from Richard Gaskalla

The Florida Department of Agriculture and Consumer Services’ Division of Plant Industry (FDACS’ DPI) appreciates the opportunity to comment on Docket No. APHIS 2008-0015, “Citrus Greening and Asian Citrus Psyllid Availability of an Environmental Assessment.” The Florida Citrus Industry has unfortunately been the first citrus production area of the United States to face the challenge of the Asian citrus psyllid (ACP) and Citrus Greening (HLB). It became very clear as Florida developed a recovery strategy for ACP and HLB that effective ACP control strategies was an essential element. Further, it was very evident that protection of foundation citrus budwood and citrus nursery stock was the first step in the Citrus Health Response Program. The citrus nursery stock protection program in Florida involves the use of approved insect-proof structures, frequent inspections, and the use of EPA-approved pesticides to maintain stock that is insect and pathogen-free. The FDACS’ DPI has reviewed the “Quarantine and Interstate Movement of Citrus Greening and Asian Citrus Psyllid – Environmental Assessment” July 2009 document and offers the following comments in the context that Florida has been and continues to be the area of the United States most impacted by this unwanted citrus pest and disease complex. The FDACS’ DPI fully supports the APHIS-approved treatments conclusion; however, due to the latency of HLB symptom expression, it would appear to be well justified to require citrus nursery stock moving in interstate commerce from quarantined areas to be produced from certified budwood and nursery stock produced in insect-resistant structures that are inspected on a frequent basis. As Florida is fully compliant with a certified clean citrus nursery stock program, we feel strongly that Florida citrus nursery stock should be eligible for interstate movement within the United States to non-citrus producing states.