San Miguel de Tucumán, December 10 th 2007.

Docket No. APHIS-2007-0112

Regulatory Analysis and Development

Policy Program and Development

Animal and Plant Health Inspection Service

Station 3A-03.8

4700 River Road, Unit 118

Riverdale, MD 20737-1238

Re: Docket No. APHIS-2007-0112

Availability of a Draft Pest Risk Assessment for Lemons From Argentina

72 Fed. Reg. 155 (August 13, 2007)

Dear Sirs,

S. A. San Miguel, located in the Province of Tucuman, in the North-West
of Argentina, is a company which produces lemons, devoting its
production to fresh fruit export as well as its industrial by-products,
mainly Essential Lemon Oil, Concentrated Juice, and Dehydrated Peel.

San Miguel produces 70% of the fruit needed and the remaining 30% is
provided by producer near to the company. Thus, the total yearly
production is about 400,000 metric tons (mt).

San Miguel has a production area of 6,500 hectares. The annual fresh
fruit export is around of 100,000 mt and the industrial production is
nearly 300,000 tons.

San Miguel has 6.400 employees, being the main employer in private
activities in the province of Tucuman.

From 1973, San Miguel has been continuously exporting citrus, with over
80,000,000 of cartons produced and shipped to more than 35 countries in
North America, Europe (EU and Non EU), Middle East, Asian, Africa and
those countries which are highly demanding in relation to quality,
quantities, as well as quarantine requirements and residues. Among these
countries, Spain, Germany, France, Italy, Canada, Japan, China
(regarding orange only), Canada, Holland, Belgium, U.K., Rassha, Turkey,
etc.

Identical importance is given to industrial products, whose production
started in 1960 and now, their by-products are exported to more than 20
countries, among them, U.S.A., Japan, Germany, France, Australia, Italy,
U.K, etc.

In order to satisfy its clients requirements, S.A. San Miguel has
certified its farms production of fresh fruit for export, under
international GLOBALGAP Protocol (Ex-EUREPGAP). The areas certified
includes 5,460ha, TESCO NATURES CHOICE- 440ha (its production goes to
U.K.). Packing House and Industrial Plant have been certified under
HACCP Norms by SGS Company.

In Argentina, its nurseries have been certified by INASE (National
Institute of Seeds: NIS). Moreover, the whole export process for Fresh
Fruit, from the field to the port of departure, has been certified by
SENASA (National Service of Sanitaty and Agro Alimentary Quality). It is
very important to mention, the fundamental role of SENASA supervising
the correct compliance of international rules regarding quarantine pests
and food quality.

It is also important to mention that during the period in which USA
market was open to Argentinian lemon export, S.A. San Miguel exported
fresh fruit to U.S.A., 6.000 mt in the year 2000 and 8.300 mt in 2001.
We had no claim regarding phytosanitary aspects or some others as agreed
quality, program compliance, pesticides, etc.

S.A. San Miguel, as an agro industrial company, has an important social
commitment, and it complies with every labour law and a precise program
in the area of Comporate Social Responsability.

Its environment commitement, from primary production to effluents
treatment, is widely developed. At the moment, we have been awarded a
loan by the IFC (International Finance Corporation), to complete works
liquid effluents.

It is necessary to remark that EEAOC (Estación Experimental Agro
Industrial Obispo Colombres- Agro Industrial Institution Obispo
Colombres-Obispo Colombres Agroindustrial Research and Extension
Estation) is an institution responsible for research, experimentation
and development of the citrus industry in the North-West region. It also
provides technical support in relation to every aspect associated with
this activity.

S. A. San Miguel, as a producer and exporter Company, strongly supports
the fruit international market and its by-products. It also supports
negotiations between Argentinean National Government and U.S.A. in
relation to the reopening of the exports lemons and other citrus to the
American market. The Company is aware that it produces, packages and
sells a quality product, which is innocuous regarding agro-chemical
residues and as vehicle to transmit quarantine diseases.

**Ernesto R. Saade**

**S.A. San Miguel**

**Institutional Affairs Manager**