Here is a recent comment submitted to www.regulations.gov from a California citrus leader about the proposed rule to allow movement of Florida citrus fruit from canker areas. Not everyone is ready to join hands and sing "kumbaya" yet, apparently...


Tim Peltzer
Peltzer Farm Management, Inc.
P O Box 10209
Terra Bella, CA 93270
559.789.9446


August 24, 2009


Regulatory Analysis and Development
PPD, APHIS, Station 3A-03.8
4700 River Road Unit 118
Riverdale, MD 20737-1238                RE:    Docket No. APHIS-2009-0023

I have just been made aware of the APHIS proposal to amend its rules regarding movement of fruit from citrus canker quarantined areas, to allow shipment to all U. S. states including California. As a member of the Board of Directors of the Southern Tulare County Citrus Pest Control District, and especially as a California citrus grower, this proposal causes me grave concern.

With an industry focused on fresh fruit, and a production value per ton far exceeding that in Florida, California stands to suffer disproportionately if citrus canker is introduced. The APHIS document Preliminary Regulatory Impact Analysis and Initial Regulatory Flexibility Analysis states “. . . a reduction in the packout rate for fresh market fruit in the other commercial citrus-producing States due to citrus canker infestation would likely have a larger economic impact than has been experienced by Florida, due to their greater reliance on fresh citrus sales, especially of oranges.” While the possibility of introduction via “commercially packed citrus from citrus canker quarantine areas” may be small, EVEN MINIMAL RISK IS UNACCEPTABLE.

The analytical document referenced above devotes almost 18 pages to the expected impacts of the proposed rule on the Florida industry. In the 2½ pages addressing the expected effects for the other commercial citrus producing states, it is noted that APHIS expects “the primary effect of the rule would be to preserve Florida’s fresh market in the long run,” and goes on to state “in the event that citrus canker were to spread to other commercial citrus-producing States, we do not anticipate that other commercial citrus-producing States would find profitable alternative markets for fruit that could not be sold on the fresh market.”

The impetus for this rule change is clearly for the benefit of the Florida industry. With due respect to the scientific researchers upon whose work the proposal rests, there are still a number of questions and uncertainties indicating that the proposed action is not appropriate at this time. The comments submitted by Dr. James Adaskaveg present an excellent reflection of the scientific concerns. In addition, because California’s growing situation is quite different than those in the research areas, there are serious issues about the extrapolation of data from study of only a few varieties. As well, the eliminating mandatory inspections raises questions about the assurance of adherence to compliance agreement requirements.

California is currently free of canker. We want to stay that way. APHIS presents its documentation including this statement: “Risk of introduction of citrus canker into other citrus producing states via the movement of commercially packed citrus from citrus canker quarantine areas is not assumed to be zero.” I urge the decision-makers at APHIS to give balanced consideration to the great potential harm to the industries of the other citrus producing states versus the anticipated economic benefit to the Florida industry, and NOT TO APPROVE THIS PROPOSED RULE CHANGE.


Tim Peltzer, Director
Southern Tulare County Citrus Pest Control District