Comment from Peter Houle. Hawaiian Rainbow Produce

To: DEPARTMENT OF AGRICULTURE ANIMAL AND PLANT HEALTH INSPECTION SERVICE 7 CFR PART 319 DOCKET NO. APHIS -2008-0050 RIN 0579-AC95 Thank you for allowing my company Hawaiian Rainbow Produce and our 20 represented farmers the chance to speak regarding DOCKET NO. APHIS-2008- 0050. First of all Double Dipping of papaya was removed from the Federal Register almost 20 years ago in favor of Vapor Heat or Forced Hot Air treatments. It was also understood that PROBIT 9 conditions were MANDATORY by APHIS personnel. Therefore how does one now come to the conclusion that field sanitation and fruit fly trapping along with a single Hot Water Dip is now a PROBIT 9 method of treating papaya. Not only are our farmers against Colombia and Ecuador shipping papaya this way but we are also against Brazil and Mexico shipping to the United States of America. Over the last 15 years since the Federal Government has allowed Brazil and Mexico ship to the United States of America, Hawaiian market share has gone from 70 percent down to 7 percent and our price have been cut in half. We used to obtain $18.00 per 10 pound box, we now get $9.00 per 10 pound box and this is during the high price season which is four months each year and is our chance to make enough money to sustain us through the entire year.. The other eight months we lose money due to offshore competition mentioned above. The last few years we have been losing money for the entire fiscal year. Fifteen years ago the processors and farmers were making money and the industry was profitable. Today, farmers with the increase costs of inputs such as fertilizer, labor, land rent, fungicides, pesticides, and herbicides can no longer afford to feed their families. Processors such as myself have put our savings on the line in order to build facilities to Vapor Heat Treat papaya. Our costs have gone up as well such as labor, electricity, shipping, fuel, freight, box costs just to name the major costs. Yet we have seen our prices cut in half. Our margins are paper thin and in the last four years have been inverted much of the time. Red ink is common at some facilities causing many processors to go bankrupt. We work with our children just to keep costs low enough to survive. If we go bankrupt we lose everything we worked so hard for. And this is caused by our own GOVERNMENT allowing papaya to be imported into the UNITED STATES OF AMERICA WITHOUT USING THE PROPER TREATMENT PROTOCOL. THIS IS AN UNLEVEL PLAYING FIELD AND OUR OWN GOVERNMENT CREATED IT. WHY ARE YOU TRYING TO EXPORT JOBS TO OVERSEAS BUSINESSES WHEN THIS GOVERNMENT SAID IT WOULD PUNISH THOSE THAT DO THAT VERY THING. THIS WILL CREATE MORE SMALL BUSINESSES TO SHUT DOWN AND MORE LOSS OF JOBS IN THE UNITED STATES. THE UNITED STATES GOVERNMENT MUST NOT ALLOW ECUADOR OR COLUMBIA TO ENTER THE UNITED STATES PAPAYA MARKET AND MUST REMOVE BRAZIL AND MEXICO AND ANY OTHER COUNTRY NOT USING VAPOR HEAT TREATMENTS FOLLOWING A PROBIT 9 STRICT REGIMEN. OUR HAWAIIAN FARMERS AND HAWAIIAN PROCESSORS HAVE RIGHTS AS UNITED STATES CITIZENS TO BE PROTECTED FROM UNFAIR TRADE PRACTICES AND UNLEVEL PLAYING FIELD. AS A CHEMICAL ENGINEER I CAN NOT UNDERSTAND WHY FRUIT FLIES ARE ALLOWED TO ENTER INTO CALIFORNIA FROM THESE REGIONS. ON PAGE 18163 UP TO SEVEN FLIES PER TRAP IS AN OKAY NUMBER. HOW MANY FLIES PER FRUIT IS THAT? DOES CALIFORNIA NEED MORE FRUIT FLIES IN THERE FRUIT ORCHARDS? DID ANYONE ASK THEM? HAS ANYONE COME TO HAWAII AND ASKED US WHAT THE FINANCIAL IMPACT OF THE ACTION BY OUR UNITED STATES GOVERNMENT WOULD BE ON OUR FARMERS HERE IN HAWAII? IF NOT WHY NOT. I THOUGHT OUR GOVERNMENT CARED ABOUT ITS FARMERS AND WAS NOT TRYING TO PUT US OUT OF BUSINESS. MAY 27, 2009 HAWAIIAN RAINBOW PRODUCE PETER T. HOULE OWNER