Comment from Patrick Napier

Greetings Mr. Kevin Shea and the Animal and Plant Health Inspection Service, The following is an inquisition into the possible “protectionist nature” of the request for “Amendments to Treatments for Sweet Cherry and Citrus Fruit from Australia and Irradiation Dose for Mediterranean Fruit Fly.” The concept of protectionism, by which a country (or in this case countries) attempts to influence legislation in such a way as to tip the scales of a positive balance of trade , can disrupt equilibrium and fair international trade. It is the purpose of this comment to provide further information regarding the proposed rule in terms of current and future trends of sweet cherry production and pose some questions with regard to ethical trade practices. Dr. Desmond O’Rourke, founder and CEO of Belrose, Inc. and an expert on international fruit trade, recently published a PowerPoint presentation about the fiscal outlook of sweet cherries as a commodity . He notes that sweet cherries production has shifted from European to Middle Eastern countries, such as Turkey and Iran. In the wake of this change, as O’Rourke implies, the overall production of cherries will increase by over one-third. For major cherry producing countries, such the United States and Australia, this could mean a great deflation of the cherry, as a product, because of its hypersaturation in the foreign and domestic markets. The proposed rule will give Australia the opportunity to broaden the scope of the treatments it can apply to meet international regulations regarding quarantine pest. The question, however, is can these same regulations be applied to countries who are relatively new to the production of cherries. In other words, would this proposed rule give an unfair advantage to Australian cherry producers, which would, in effect, protect them from shifts and increases in production within the scope of worldwide sweet cherry trends? As a final note, the author would like to address the costs associated with achieving amendments to regulations in the United States and the costs of implementing new and expensive treatments to pest control. In terms of countries that are relatively recent to the production of cherries (The Middle East), would they be at all disadvantaged if not able find the funds necessary to remain competitive within the global market? The previous questions are brought up because they were not addressed in the proposed rule. The author hopes that such issues will be clarified in the report, so no mistakes can be made about the protectionist possibilities affecting balanced international trade. Thank you for your consideration, Patrick Napier University of La Verne, Department of Business and Public Administration