Comment from Michael Sparks

United States Department of Agriculture – Animal Plant Health Inspection Service 1400 Independence Avenue, SW Room 1147 South Building Washington, DC 20250 RE: Federal Register APHIS 2011-0060 After reviewing Federal Register APHIS 2011-0060, Florida Citrus Mutual, the state’s largest citrus grower organization, does not support the proposed importation of fresh citrus fruit from Uruguay to the United States for several reasons outlined below: • The Pest Risk Analysis (PRA) referenced six significant pests that could be introduced through Uruguayan imports. Two of them pose a significant threat to Florida agriculture: the South American fruit fly and the Mediterranean fruit fly. • FCM does not agree with the methods proposed for fruit fly detection among Uruguayan producers. Using a minimum of two traps per square mile is not adequate and the potential for undetected fruit fly populations is high. • Another concern is the lack of a plan to address what resources the USDA will provide to monitor incoming shipments for protocol compliance and pests. The current levels of port inspection do not offer the necessary capabilities to detect fruit flies from countries that do not have adequate protocols in place. FCM maintains that Uruguay citrus should not be granted entry into the U.S. until the current systems approach removes any concern of accidental introduction of fruit flies. Thank for the opportunity to comment on this important issue. Please do not hesitate to contact me with any questions or concerns. Regards, Michael W. Sparks Executive Vice President/CEO (863) 682-1111 mikes@flcitrusmutual.com