Comment from Bob Zuckerman

I do not advocate importation of harmful plant materials, including citrus seed, into the United States. Also my comments are restricted to HLB (Citrus Greening) However, I have several serious concerns with: 7 CFR Part 319 [Docket No. APHIS-2008-0052] RIN 0579-AD07 Citrus Seed Imports; Citrus Greening and Citrus Variegated Chlorosis First, I understand that the same rules USDA adopts will be met with equivalency from other countries. Because the proposed regulation refer wholly to countries, California would be included within any restrictions even though no evidence of HLB has been discovered here and the closest incidences of HLB within the US are over 1500 miles away. If other countries would adopt these same restrictions, California citrus seed producers would lose significant market for their products. Under this scenario, it would also severely limit countries that need sources of clean rootstock seed from being able to obtain them from California producers. More importantly, your criteria is based on a 2004 publication that references a 1981 observation only, hardly emerging evidence and with no actual data to back it up: From the proposed regulations: "Emerging evidence suggests that propagative seed of genera that are hosts of citrus greening or CVC can transmit these diseases. First, when seedlings are generated from seed that is taken from plants infected with citrus greening, a small percentage of those seedlings have been found to be infected with citrus greening.3" From source reference (3) in the Federal register: "Seed Transmission There is little information on seed transmission. Most fruit is lost, and that which remains has a high proportion of aborted seed; however, Tirtawidjaja (1981) collected normal and greening-affected (very small) fruit and harvested normal-looking seeds from each. No symptoms were observed on seedlings from seed taken from normal fruit, even when they were collected from infected plants; however, seeds derived from smaller, greening-affected fruit produced some stunted chlorotic seedlings. Three of the seedlings had the same appearance as insect-inoculated seedlings. This experiment bears repeating." Basing drastic changes in regulations on observations and not actual verified results, is problematic. Additionally, more recent research has shown that HLB can not be recovered through seed transmission in citrus. Indications are that normal hot water seed treatments of harvested citrus seed may assure that no HLB could survive, in any case. Please note that even your reference indicates that any seedlings, even from HLB infected trees, except those from obviously infected fruit, were symptomless. What we need are standards for regulations that can help assure clean source materials such as testing seed trees for HLB, prohibiting use of infected seed fruit and requiring heat treatment standards for citrus seed. We also need to have scientifically validated studies which can determine if there is an existing threat from HLB citrus seed transmission. This must be done before we propose new Federal regulatory actions which can adversely affect the export of California citrus seed and initiate crippling regulatory actions on California citrus nurseries, as proposed by the California Department of Food and Agriculture.