Comment from Elizabeth Nagano

February 8, 2009 We strongly oppose the Animal and Plant Health Inspection Service (APHIS) proposed rule Docket No. APHIS-2008-0126 which would allow the importation of Hass avocados from Peru. California avocado growers have suffered severe economic hardships for the past several years. Along with crop loss attributable to weather problems, we have seen our market price diminish while American packing houses import produce from Chile and Mexico. As a result of the Mexican importation, we have experienced crop damage from insects which piggybacked in on poorly inspected fruit. We have no reason to expect that the inspection of Hass avocados from Peru will be provide any better protection for American growers. The vast majority of California avocado growers operate small family farms, with 5 to 20 acre groves. In the best times, their profit margins are extremely narrow. At this difficult economic time, adding a projected 41,900,000 pounds (19,000 metric tons) at .064/pound of Hass avocados (as shown in Table 1 of the Proposed Rule) to the American market can only adversely affect producer prices while having a negligible effect on the consumer price. We would beg to differ with the determination that this proposal is insignificant for the purposes of Executive Order #12866. The introductory sentence of the order states “The American people deserve a regulatory system that works for them, not against them...that protects and improves their health, safety, enviroment...without imposing unacceptable or unreasonable costs on society”. This proposed rule runs counter to the interests of American avocado growers and does little to assure the health and safety of the American consumer.