June 18, 2009
Ms. Lynn Evans-Goldner
Karnal Bunt Program Manager
Animal and Plant Health Inspection Service
U.S. Department of Agriculture
Attn: Docket Number APHIS-2009-0036
Dear Madam/Sir:
The North American Millers’ Association is submitting these comments in response
to the Agency’s June 4, 2009 interim rule and request for comments relative to the
Karnal bunt regulations.
The North American Millers' Association (NAMA) is the trade association
representing the wheat, corn, oat and rye milling industry. NAMA’s 48 member
companies operate 170 mills in 38 states and Canada. Their aggregate production of
more than 160 million pounds per day is approximately 95 percent of the total
industry capacity.
NAMA supports amending the Karnal bunt regulations to remove certain areas or
fields in Riverside County, CA from the list of regulated areas. However, we think the
rule does not go far enough. Karnal bunt is a wheat disease of only minor agronomic
importance, and in most circumstances is of little or no consequence from a food
quality standpoint.
The U.S. is the world leader in the elimination of unnecessary and unscientific
sanitary and phytosanitary regulations that only serve to restrict trade. Therefore, the
U.S. must work with export customers to educate them about the insignificance of
Karnal bunt with the goal of eliminating all Karnal bunt-based regulations as soon as
possible.
Durum wheat grown in Arizona and California is of exceptionally high quality.
Further, with its spring harvest, it fills a critical hole in the supply chain when the U.S.
northern plains durum crop, always insufficient to supply total usage, has been nearly
exhausted.
Reducing or, ideally, eliminating the planting restrictions in the desert southwest
would:
- Ease the shortage of high quality durum perennially faced by U.S. users and
exporters; - Reduce tension between millers forced to import durum from Canada and U.S.
growers who oppose such trade; - Make the U.S. less reliant on imports for a basic, wholesome staple food;
- Make the U.S. more competitive and help stave off imports of subsidized, and
frequently lower quality, finished pasta; and
- Give growers another crop option.
The U.S. must recognize its Karnal bunt regulations are damaging a vital industry of
strategic national importance, and work toward eliminating them. We thank you for
any consideration you can offer these comments.
Sincerely,
James A. Bair
Vice President
jbair@namamillers.org