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Argentine Lemon Imports - A letter to the USDA

Bruce Kelsey

Monday, August 08, 2016

Dear USDA:

  1. I am aware of the proposal to allow lemons in from Argentina.  I am spending $215.00 per acre for assessment and treatment costs associated with protecting our industry from Huanglongbing.  Why would USDA be suggesting that additional product from a pest and disease infested area is necessary?  While your proposal argues about mitigations steps, my reading is that it is based on dated information.  In 2007, which most of your information is based on, our treatments for ACP and scale, as an example, were nowhere near what they are today.
  2. Why does USDA make the argument that Argentine lemon imports would counter seasonal to California production?  That is blatantly not true which causes me to wonder how much of the "scientific basis" is flawed as well.  USDA is responsible for protecting the domestic food supply, not to advocate on behalf of others.  Our summer orange program no longer exists because other non-competitive product was allowed access to the United States.  Is it your goal to reduce the number of California lemon growers and volume produced?
  3. As a grower, I am extremely sensitive to pest and disease issues what with activists challenging our use of crop protection tools and my goal of providing a healthy, clean product in sufficient volume for customers across America.  Your document makes the argument that Argentine bugs or disease cannot impact my grove.  Well maybe not immediately but as I recall most introductions occur in urban settings first.  Why is that ignored?  Florida had HLB in Miami first.  We had medfly and mexfly in Los Angeles city/county first.  I remember the argument around LBAM.  That occurred in urban areas first.  Here in California ACP was found in San Diego, then Orange County and finally in LA County.  HLB is now found in Los Angeles city.  Why aren't all those discoveries taken into consideration?
  4. You seem to dismiss Citrus Black Spot (CBS) which I don't understand.  CBS was discovered in a Florida grove and nobody knows how and why.  I keep reading how the quarantine areas are expanding which means Florida growers cannot eradicate it.  If CBS comes into Southern California and infects a back yard tree what does this mean to me?  My production is totally fresh oriented meaning I can't have any surface issues and I really don't want to use any more copper of pesticides than I have to.
  5. I know that most of Argentine lemons go for processing but a significant amount of tonnage is exported fresh.  Farming practices for fresh market consumption versus processing are far more intensive.  But lemon acres in Argentina are intermixed, meaning one grower works harder at farming while a neighbor is less intensive thereby creating more problems for everybody regarding pest and disease.  How will you know if a grove or block of fruit is continually free of pests or diseases?  How can you be sure an area is pest or disease free?  That is not clear at all which places exported fresh fruit more susceptible as a carrier of a problem.  And since the Los Angeles/Long Beach ports would be a destination area and since there are so many back yard trees in Los Angeles, your rule carries significant risk for me.
  6. I am a citrus producer in California.  Right now I am assessed nine cents a carton for an ACP/HLB program.  For most growers, depending upon the variety of citrus, that equates to $63-$90 per acre.  To satisfy treatment regulations or requirements for ACP growers are spending $92-$200 per acre.  Your rule totally ignores the fact that invasive pests and disease normally start in the urban areas.  Your proposal, I believe is wrong regarding CBS.  It is risky regarding other pests and assumes farmers in Argentina all farm in the same intensive manner as we do when in fact most of that production goes to processing.  You cite old information and the combination of all this makes me believe we will get a pest or disease in Southern California and beyond.  It won't happen the first year band perhaps not the next, but eventually there will be a detection and guess who pays the price?  Citrus Growers1  I oppose your rule.


Bruce F. Kelsey

Family Citrus Grower