Comment from Richard Gaskalla

To Whom It May Concern: The Florida Department of Agriculture and Consumer Services, Division of Plant Industry has concerns with portions of the proposed systems approach in relation to the allowance of imported peppers without treatments from Panama. Florida is an extremely high risk area of the US for agricultural pest incursions, especially from tropical / sub-tropical areas of the world. Peppers are an excellent host of Medfly and Mexfly; both of which, if introduced, would result in multi-million dollar eradication programs as well as significant economic impact to Florida agriculture. Systems approaches are only as good as the creditability of the regulatory agency providing oversight of the program. What measures will be in place to help assure the phytosanitary measures are being appropriately monitored and conditions complied with? It would be very helpful to invite stakeholders from the areas of the US that are at highest risk to participate in site visits when proposals of this nature are being considered to help address concerns over the monitoring and sophistication of the systems approach infrastructure, etcetera. Further, we have concerns over the evaluations of the pea leaf miner, Liriomyza huidobrensis. Agromyzid larvae are typically not identified beyond the family level, and 1.6 mm screening around production areas may not be sufficient in excluding this small fly. Additionally, early instar larvae of L. huidobrensis and associated mines are relatively small and could easily be missed during visual inspections. The FDACS’ DPI does not support this proposal based on the above comments. Regards, CHARLES H. BRONSON COMMISSIONER OF AGRICULTURE Richard Gaskalla, Division Director Division of Plant Industry Florida Department of Agriculture and Consumer Services PO Box 147100 Gainesville, FL 32614-7100