Comment from Craig Cooper

Summary: Paramount Citrus Association (“Paramount Citrus”) is the largest integrated grower, shipper, and packer of fresh citrus in the United States. Paramount Citrus is dedicated to preserving our citrus crops through continuing scientific research to better understand how to reduce the effects of fruit and plant diseases. It is our understanding that USDA-APHIS intends to help stop the propagation of citrus greening (CG) and citrus variegated chlorosis (CVC) by implementing regulations such as those proposed in this Federal Register Notice. Paramount Citrus is fully aware of the devastating impact CG and CVC may have on the citrus industry, and we firmly support the actions of USDA-APHIS to serve the citrus industry via appropriate restrictions, provided that such restrictions are based upon sound scientific evidence and do not extend beyond the scope of propagation of these diseases. In particular, we are not opposed to addressing the potential propagation of CG and CVC diseases via seeds, but believe that the USDA must remain consistent in its practice of evidence-based regulatory enforcement rather than acting on premature findings. In this case, we do not believe that the scientific evidence relied upon in the Federal Register Notice is conclusive enough to warrant a change in regulation. Moreover, Paramount Citrus is firmly opposed to any regulation restricting importation and distribution of citrus fruit products with seeds. We would strongly oppose any USDA attempts to restrict importation and distribution of citrus fruits should they attempt to expand these regulations without sound, conclusive scientific evidence supporting such activities, which science currently does not exist. (For full comments, see attachment)