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

June 12, 2008 Federal Docket No. APHIS-2008-0017 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-2008- 0017, “Importation of Tomatoes from Souss-Massa, Morocco” and offers the following comments. Florida is a high-risk sentinel state for exotic agricultural pest introduction. Africa, with emphasis on equatorial Africa, is an area of the world that is considered to be high-risk for agricultural pests and diseases that could impact Florida agriculture. Florida is especially vulnerable to exotic fruit fly invasions including the Mediterranean fruit fly; therefore, we are wary of any phytosanitary program that involves fruit fly host imports from infested countries into Florida under a complex systems approach program. Specific questions regarding the systems approach phytosanitary program for tomato fruit from the Souss-Massa Region are: 1) What has the USDA-APHIS involvement and oversight been to make sure the provisions of the phytosanitary systems approach are in place? 2) Who makes the decision if the tomato fruit is at the correct stage of maturity (i.e., pink versus red) prior to harvest? Docket No. APHIS-2008-0017 June 12, 2008 Page Two 3) What safeguards are in place to mitigate high medfly population fluctuations that naturally occur and increase infestation risk? 4) How much fruit will be examined at U.S. ports of entry upon arrival? 5) What is the confidence level in the ability of Moroccan Ministry of Agriculture, Division of Plant Protection, Inspection, and Enforcement (DPVCTRF) to carry out this program? What checks and balances and quality control measures are in place to monitor compliance at origin? How many site visits have been made and how many are planned in the future? 6) What are the safeguards to assure the packing house is a fruit fly-free environment? Can there be fruit fly host plants in close proximity to the packing house? In closing, the FDACS’ DPI is opposed to the expansion of the Morocco and Western Sahara tomato export program into areas of Morocco with higher fruit fly prevalence without a probit 9 treatment. Sincerely, CHARLES H. BRONSON COMMISSIONER OF AGRICULTURE Richard D. Gaskalla Division Director RDG/dh