Comment from Kerry Britton

General Comments: I am pleased to see APHIS publish another set of proposed NAPPRA genera. This new category is an important tool for the protection of America’s forest resources. Specific Comments on Proposed NAPPRA List Species: Re hosts of ALB: Why exclude Netherlands in the listing of Cercidiphyllum? ALB has been detected there more than once. Netherlands seems a high risk location given the EU policy of importing large plants in soil and the Netherlands well-known industry of plant consolidation. Re hosts of Dendroctonus micans: Why are Abies, Larix, Picea and Pinus not included? Current restrictions for these hosts under 7 CFR319.37 are mostly limited to Europe and Japan, which is not the limit of the current distribution of D. micans. Even using the broad geographical definition of “Europe” (ie 50 countries rather than the 27 EU member countries), this still leaves us importing these hosts from some countries that according to your datasheets currently have infestations (China, Mongolia, and Sakhalin). Re datasheet on Moniliophthora perniciosa On page 3 there is a confusing statement in paragraph 1. Possibly what is meant is that there are indications of geographical variation in the virulence of the pathogen? Re hosts of Monochamus alternatus This pest also occurs in Korea, Viet Nam, Laos, Taiwan and Hong Kong. Why are these sources not listed? Acer is only currently restricted from the EU and Japan. Cryptomeria is not currently regulated (per APHIS website http://www.aphis.usda.gov/plant_health/permits/downloads/ProhibitedPlants.pdf 10 May 2013 Thanks for the opportunity to comment. Again, NAPPRA is in important tool in protecting US natural resources.