Support for Chilean orange and grapefruit imports

The USDA's proposed rule that would allow imports of Chilean oranges and grapefruit under a "systems" approach brought support in this letter published recently on the federal docket. Comments for the proposed rule, published Aug. 28, are due Oct. 27.

September 22, 2008

Regulatory Analysis and Development

PPD, APHIS, Station 3A-03.8, 4700

River Road Unit 118, Riverdale, MD

20737-1238

RE: Docket No APHIS-2007-0115

We are writing to express our strong support for the Animal and Plant Health Inspection Service (APHIS) proposed rule Docket No. APHIS-2007-0115 to allow for the importation of oranges and grapefruits from Chile into the United States under certain conditions as outlined in the docket.

Safco of America LLC is an importer of Chilean products, to include lemons and Clementines. These products have been favorably ordered and accepted by our retail customers, some of the top supermarket chains in the country. The imports of Chilean oranges and grapefruits would further enhance our business with our current customer base. Additionally this would provide our employees more activity during the offseason months and provide Safco the basis to consider expanding our staffing, a result we imagine would permeate through the entire industry from port operations, to storages, to trucking.

Chile has one of the strictest Phytosanitary conditions in the world for their fruits and this proposed rule is based on sound science. The proposed rule is also complementary in nature since it will allow Chile to export oranges and grapefruits during the summer months – a period when U.S. production is at its lowest.

The rule is based on a “systems approach” which APHIS already uses successfully with imports of Clementines from Chile and other fruits from around the world. APHIS also uses similar “systems approaches” to ensure that Florida and California citrus products meet the requirements of our trading partners from around the globe.

Consumers, grocery stores and restaurants will benefit from this proposed rule since they will have another source for quality oranges and grapefruits during the summer months.

Thanks to the Chile-U.S. Free Trade Agreement, Chile is now one of our largest trading partners in South America and this proposed rule is a good example of our bilateral trade relationship.

We petition APHIS to adopt this proposed rule as soon as possible.

Thank you and best regards.

Dirk Winkelmann

General Manager

Safco of America LLC

1150 Chinowth Street, Suite A

Visalia, CA 93291