Comment from Richard Gaskalla

To Whom It May Concern: The Florida Department of Agriculture and Consumer Services’ Division of Plant Industry (FDACS’ DPI) has reviewed Federal Register Docket No. APHIS-2010-0127 regarding the movement of Hass avocados from areas where Mediterranean fruit fly or South American fruit fly exists. Hass avocados were demonstrated as being conditional non hosts for both Mediterranean fruit fly and South American fruit fly based on scientific research that was presented from Argentina, Peru and South Africa. Additional safeguards are recommended by APHIS and they include: 1) Hass avocados must be commercially produced; 2) fruit must be harvested from the tree and not picked up from the ground; and 3) the Hass avocados must be safeguarded after harvest, during packing and until export and arrival at the port of entry in the United States to prevent re-infestation by fruit flies. The FDACS’ DPI agrees there is good scientific justification that underpins this proposal; however, we remain concerned over the operational / regulatory oversight issues. What resources will be made available to assure that items 1, 2, and 3 above are properly carried out? Will there be any USDA oversight or audit reviews? Sincerely, Richard Gaskalla Division Director