“As an overarching comment, we are confused by the events that have taken place with respect to the request from China,” so states the opening paragraph of CCM comments submitted in response to Chinese petition to import citrus into the United States.

We question why pest-free areas of production were eliminated as a requirement and instead pest-free places of production became the standard. “Assuming a risk elimination protocol is put in place, this approach still creates vulnerability for the California citrus industry,” states CCM Strategic Advisor Joel Nelsen.

CCM noted that APHIS was neither advancing any oversight nor training on a proposed protocol that was complicated and sensitive, which increases the industry’s vulnerability.

CCM also submitted two lengthy scientific documents which seemingly counter APHIS’ justification for elements of the protocol. As an example, APHIS notes existing standards for Citrus Black Spot would provide the necessary protections, but we argue that the efficiency of existing protocols for the CBS pathogen have not been evaluated.

CCM believes there were too many assumptions and too few relevant scientific facts to justify actions in the proposed rule. An original proposal in 2014 placed strong barriers against Chinese citrus access to which the Chinese government protested. Now USDA is relaxing those requirements albeit pears and apples entering the United States are still required to satisfy the same stringent requirements.

This makes no sense and piles on the concern CCM articulated regarding increased vulnerability.