Comment from Michael Treiber

To whom it may concern, You have requested for stakeholder comments on the Advance Notice of Proposed Rulemaking for the treatment of Chrysanthemum White Rust (CWR). I am the Director of Purchasing with Color Spot Nurseries and we are producing approximately 5 million Garden Mums on a yearly basis, which makes us a member of the top 5 of mum producers in the country. As Color Spot Nurseries we have seen the industry professionalize tremendously over the past 25 years. Our operation and those of our competitors are operating in a highly competitive and professional market which quickly weeds out incompetent suppliers that fail to meet our professional requirements. We only buy from suppliers that supply quality and disease-free inputs at a competitive price. Incompetent suppliers are no longer in the business. The current CWR protocol represents a ‘death sentence’ for growers since it risks the loss of an entire crop in the main season should CWR be identified in our mum crop. For operations such as ours, that is an unnecessary and (in our eyes) unacceptable risk, especially since CWR has been found to overwinter in Pennsylvania (Plant Disease - 96(9)1381) and thus has the potential to infect crops from a domestic source. We believe our suppliers are more than capable of delivering non-infected material (delivery of infected material would be their ‘death sentence’ in terms of future business). What we call the ‘death sentence’ protocol for dealing with CWR could lead to bankruptcy of operations and unnecessary loss of valuable employment as well for a disease that does not spread readily and does not attack important agricultural-food crops. We believe firmly that the industry will be able to self regulate the threat of White Rust without the unnecessary use of government regulation and financing. The treatment and prevention of Chrysanthemum White Rust is our highest priority simply because of economic reasoning (waste is the most important cost