California opposes Florida rule

Brother against brother? Well, Richard Kinney and Joel Nelsen are on opposite sides of this issue, as are citrus interests in Florida and California. This just slid across the inbox this afternoon:

CALIFORNIA CITRUS INDUSTRY OPPOSES FLORIDA
RULE RELAXATION

In comments filed today, August 7, 2007 the California Citrus industry filed comments opposing the U.S. Department of Agriculture’s proposed rule that would allow greater flexibility to the Florida industry and therefore ship greater volumes of fresh fruit from diseased areas.

“…it is not possible to design an operationally feasible system that ensures only uninfected fruit moves from quarantined areas. Resource constraints and other practically consideration make it difficult to implement a grove center regulatory systems approach....” (USDA 7 CFR Part 301, Docket No. APHIS-2007-0022, pg 34182; published June 21, 2007, Federal Register/Vol. 72. No. 11999

“In effect what USDA proposes is since Florida can’t do what’s necessary and what historically has been mandated on other commodities within the United States and around the world then we should accept what they can do;” states Joel Nelsen President of California Citrus Mutual, as he cites language from the proposed rule.

“We have to object to this proposal inasmuch the Department has written a rule that gives greater flexibility to 10% of the Florida industry while jeopardizing 100% of the fresh citrus industries in California and Arizona;” continues Mike Wootton, Senior Vice President, Sunkist Growers.

The California citrus industry has united behind a series of comments submitted by California Citrus Mutual, Sunkist Growers, the U.S. Citrus Science Council, The California Citrus Quality Council and Dr. Edmund Crouch, Cambridge Environmental Inc.

The combined comments focus on a series of mathematical flaws in the USDA proposal; the use of ambiguous statements that create uncertainty which ultimately led to a proposal that has been conducted under specific operational constraints without real world replication. “We believe more protective measures must be taken based on the current state of science of citrus canker transmission,” comments Dr. Hugh Ewart, President of the California Citrus Quality Council. He further noted that “increasing risk of canker infestation of California is not acceptable to the California citrus industry.”

“USDA and Florida will argue that there is a greater degree of protection for citrus producing areas inasmuch fresh shipments are prohibited into states such as California and Arizona;” Nelsen acknowledges; “but in the opinion of industry leadership that too is a flawed assumption.” The combined comments argue that there is no determination of risk pressure at Florida packing houses, the on site inspection program which assumes a specific level of interception does not take into consideration the amount of volume being packed or inspected and there is an underlying assumption that only citrus producing states are at risk of infection or introduction.

The industry submits that this proposal will lead to increased pressures from off shore producers who will seek the same relaxed standards thereby adding to admitted uncertainties by the Department. “This was not discussed;” Nelsen noted. The end result will be more risk originating from Florida and from off shore locations. Thus states with clean production areas are at greater risk of being infected thereby jeopardizing their ability to ship fresh fruit. Canker infestation does not necessarily impede processing production.

“We all sympathize with the plight our cousins in Florida are facing;” Richard Pidduck of the U.S. Citrus Science Council adds; “but to that end let’s determine whether this untested effort can work by conducting a pilot program. We don’t believe a program in 48 states that is not monitored and ultimately will be expanded because of other requests is a sound proposal.”

The industry is suggesting that a more solid scientific foundation is necessary for the proposal. It is also questioning why the Department is abandoning the systems approach it implemented over a decade ago. “We believe the proposal is designed to facilitate the movement of fresh fruit from a diseased area rather than protecting existing fresh fruit production areas;” Pidduck concludes.

Mike Wootton agrees; “if the Department fees compelled to allow fresh fruit shipments from Florida under these tenuous circumstances then it should be done as a test program for two years and to a limited geographical of the United States.”

We’re establishing a template for the future;” Nelsen states, “let’s be sure it is an accurate one.”