# Importation of Hass
Avocados from Peru
into the Continental
United States

Environmental Assessment August 200 9 United States Department of Agriculture

Marke ting and Regulatory Programs

Animal and
Plant Health Inspection
Service

# Importation of Hass Avocados
from Peru into the Continental
United States

Environmental Assessment August 200 9

Agency Contact:

Ch arisse Cleare Regulatory Coordination and Compliance Plant Protection and Quarantine Animal and Plant Health Inspection Service U.S. Department of Agriculture
4700 River Road , Unit 133 Riverdale, MD 20737

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## Table of Contents

I. Purpose and Need

................................ ............................ 1

II. Alternatives

................................ ................................ ...... 2

A. No Action

................................ ................................ .... 2

B. Proposed Action

................................ ......................... 2

III. Environmental Impacts

................................ .................... 7

A. No Action

................................ ................................ .... 7

B. Pr oposed Action

................................ ......................... 7

C. C umulative Impacts

................................ .................. 11

IV. Other Environmental Considerations

........................... 12

A. Endangered Species Act

................................ ......... 13

B. Other Considerations

................................ ............... 13

V. Listing of Agencies and Persons Consulted

............... 14

VI. References

................................ ................................ ...... 151 

## I. Purpose and Need

International trade is impor tant to the United States. However, as trade with foreign markets increases, t he ability to introduce foreign plant pests into this country also increases . The United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (AP HIS)

, prohibits or restricts the importation of fruits and vegetables into the United States from certain parts of the world to prevent the introduction and dissemination of plant pests that are new to or not widely

distributed within the United States to protect American agriculture from foreign pests (7 Code of Federal Regulations (CFR) § 319.56).

The g overnment of Peru has requested that APHIS allow the importation

of Hass avoc ados ( Persea americana P. Mill.) into the continental

United States. Becau se Peru is in the Southern Hemisphere

, the harvest

and production season is different than that of the United States . There is a high demand within the United States for a steady supply of avocados

, thus making the avocados imported during the United Stat es ’ off

- season compl e ment ary to th os e grown and available during the United States’

avocado season

.

APHIS has prepared a qualitative, pathway

- initiated risk assessment ( USDA, APHIS, 200 9 a) and a risk management document ( USDA, APHIS, 200 9 b) to determine wh ich pests may pose a risk and wh ich mitigations will allow for the safe importation of avocados into the

continental United States from Peru ( USDA, APHIS, 200 9 a; USDA, APHIS, 200 9 b)

.

The plant pest risk assessment identified five potential pests of c oncern

— two fruit flies, one moth, one scale, and one mealy bug ( USDA, APHIS,

200 9 a). The risk management document identified a systems approach

that includ es establishment of low

- pest prevalence places of production or pest

- free areas

, or the use of quar antine treatment s (cold treatment and/or methyl bromide treatment)

, other requirements for production and harvest

, inspections, and certifications of compliance by the National Plant Protection Organization (NPP O ) of Peru to ensure that the pests of

con c er n are not introduced into the United States from the importation of Hass avocados from Peru (USDA, APHIS, 200 9 b).

This environmental assessment ( EA ) has been prepared consistent with APHIS’ National Environmental Policy Act of 1969 (NEPA) implementing pro cedures (7 CFR p art 372), for the purpose of evaluating

how the no action and proposed action alternatives may affect the qual ity

of the human environment.2 

## II. Alternatives

This EA analyzes potential environmental consequences of a proposal to

amend t he fruits and vegetables regulation s to authorize the importation of

Hass avocados from Peru into the continental United States. Two alternatives are being considered in this EA : (1) no change to the existing

regu lations (no action alternative), and (2) amend the regulations to allow for the importation of Hass avocados from Peru into the continental

United States under certain conditions (the proposed action).

A. No Action

The no action alternative would leave the fruits and vegetables regulations

unc han ged. Co mmercial shipments of avocados from Peru would continue to be prohibited from importation into the continental

United States. Although this would ensure that foreign pests would not enter the continental United States through the importation of avocados

from Peru , this alternative would unnecessarily hinder trade because the plant pest risk assessment and risk management document have outlined effective mitigation measure s for the safe importation of avocados from

Peru

.

B. Pr oposed Action

The proposed action would allow the importation of avocados from Peru into the continental United States under the following systems approach requirements that mitigate the risk of introduction of the five pests identified in the pest risk management document: Anastrepha fracterculus (South American fruit fly), C eratitis capitata (Med fly)

, Stenoma catenifer (avocado seed moth), Coccus viridis (green scale) and Ferrisia
malvastra (malvastrum mealybug). The requirements are as follows:

**•** The NPPO of Peru must p rovide a workplan to APHIS that details the

activities that the NPPO of Peru will, subject to APHIS’ approval of the workplan,

**•** The avocados must be grown at places of production that are registered with the NPPO of Peru and that meet the requirements for grove sanitation, pest

- free areas or trapping for A. fraterculus and Medfly, and surveys for the avocado seed moth that are described

below.

**•** The avocados must be packed for export to the United States in packinghouses that are registered with the NPPO of P eru and that meet the packinghouse requirements for fruit origin; safeguarding; culling; treatment; and washing, brushing, and waxing

.

**•** Avocados from Peru must be commercial consignments.

Monitoring and Oversight3 The systems approach includes monitori ng and oversight requirements to ensure that the required phytosanitary measures are properly implemented throughout the process of growing and packing of avocados for export to

the United States.

**•** T he NPPO of Peru must visit and inspect registered places of production monthly, starting at least 2 months before harvest and continuing until the end of the shipping season, to verify that the growers are complying with the requirements for grove sanitation and surveys for the avocado seed moth and follow pest control guidelines, when necessary, to reduce quarantine pest populations.

**•** I f trapping is conducted, the NPPO of Peru would also have to verify that the growers are complying with the trapping requirements and would have to certify that each place of pr oduction has effective fruit fly trapping programs.

**•** T he NPPO of Peru would be required to monitor packinghouse operations to verify that the packi nghouses are complying with the packinghouse requirements for fruit origin, pest exclusion, cleaning, safeguar ding, and identification that are described later in this

document.

**•** If the NPPO of Peru finds that a place of production or a packinghouse is not complying with the requirements of the regulations , no fruit from the place of production or packinghouse wo uld be eligible for export to the United States until APHIS and the NPPO of Peru conduct an investigation and appropriate remedial actions have been implemented.

**•** Avocado fruit that has fallen from the trees would have to be removed

from each place of production at least once every 7 days, starting

2 months before harvest and continuing to the end of harvest. Grove Sanitation

**•** F allen avocado fruit must not be included in field containers of fruit brought to the packinghouse to be packed for export

.

There are two options for mitigating the risk associated with A. fraterculus

in avocados from Peru: Establishment of an area free of A. fraterculus or trapping to demonstrate that places of production have a low prevalence of

A

. fraterculus

. Requ irements for A. fraterculus

**•** D eterminations of pest

- free areas must be made in accordance with International Standards for Phytosanitary Measures (ISPM) No. 4,

w hich sets out three main criteria for recognition of a pest

- f ree area: Establishment of Area s free of A. fraterculus

**•** Systems to establish freedom;

**•** Phytosanitary measures to maintain freedom; and

**•** Checks to verify freedom has been maintained.4 **•** APHIS must approve the survey protocol used to determine and maintain pest

- free status, as well as protocols for actions t o be taken upon detection of a pest. It also indicates that pest

- free areas are subject to audit by APHIS to verify their status.

**•** If avocados were produced in an area designated by APHIS as free of A. fraterculus , no further mitigations for those fruit fl ies would be necessary for fruit produced in that area. However, the avocados must follow the traceability, phytosanitary certificate and safeguarding requirements.

**•** Be ginning at least 1 year be fore harvest begins and continuing through the end of the harvest, trapping would have to be conducted in registered places of production with at least 1 trap per 0.2 square kilometers (km 2 ) to monitor A. fraterculus populations. APHIS

approved traps bait ed with APHIS

- approved plugs would have to be used and serviced at least once every 2 weeks. Establish ment of area s of low prevalence of A. fraterculus

**•** During the trapping, when traps are serviced, if A . fraterculus and are trapped at a particular place of production at cumulative levels above 0.1 flies per trap per day, pesticide bait treatments would have to be applied in the affected place of production in order for the place of production to remain eligible to export avocados to the United States.

There are two options for mitigatin g the risk associated with Medfly in avocados from Peru: Establishment of an area free of Medfly or treatment with methyl bromide and/or cold treatment

. Requirements for Medfly

**•** D eterminations of pest

- free areas must be made in accordance with International Standards for Phytosanitary Measures (ISPM) No. 4,

w hich sets out three main criteria for recognition of a pest

- free area: Establishment of area s free of Medfly

**•** Systems to establish freedom;

**•** Phytosanitary measures to maintain freedom; and

**•** Checks to verify freedom has been main tained.

**•** APHIS must approve the survey protocol used to determine and maintain pest

- free status, as well as protocols for actions to be taken upon detection of a pest. It also indicates that pest

- free areas are subject to audit by APHIS to verify their sta tus.

**•** If avocados were produced in an area designated by APHIS as free of Medfly in accordance with § 319.56

- 5, no further mitigations for those fruit flies would be necessary for fruit produced in that area. However, the avocados must also follow the tra ceability, phytosanitary certificate and safeguarding requirements.5 **•** If the avocados were not produced in an area free of Medfly, avocados from that place of production would only be allowed to be exported to the United States if they are treated with either cold treatment in

accordance with T

- 10 7

- a , methyl bromide treatment in accordance

with T

- 101

- c

- 1 , or a combination treatment of cold treatment and methyl bromide in accordance with T

- 108

- a

- 1, T

- 108

- a

- 2, or T

- 108

- a

3

. Treatment for Medfly

**•** Surveys by the NPPO must demonstrate that registered places of production are free of the avocado seed moth at least once annually, no more than 2 months before harvest begins, and found to be free from infestation by the avocado seed moth. APHIS would have to approve the survey protocol used to determine and maintain pest

- free status and the actions to be performed if the avocado seed moth is detected. Surveys would have to include representative areas from all parts of each register ed place of production. The NPPO of Peru would have to cut and inspect a biometric sample of fruit at a rate determined by APHIS. Fruit sampled would have to be either from the upper half of the tree or from the ground. Sampled fruit would have to be cu t and examined for the presence of eggs and larvae of the avocado seed moth in the pulp or seed and for the presence of eggs in the pedicel. Surveys for t he Avocado Seed Moth

**•** If one or more avocado seed moths is detected in the annual survey or during any other monitoring or inspection a ctivity

, the affected place of production would be immediately suspended from the export

program until appropriate measures to reestablish pest freedom , agreed upon by the NPPO of Peru and APHIS, have been taken. These

measures could include further delim iting surveys, appropriate pesticide treatments, or removal of infested host material.

**•** Harvested avocados would have to be placed in field cartons or containers that are marked with the official registration number of the place of production. The place of production where the avocados were

grown would have to remain identifiable when the fruit leaves the grove, at the packinghouse, and throughout the export process. Harvesting Requirements

**•** The fruit must be moved to a registered packinghouse within 3 hours of harvest or to be protected from fruit fly infestation until moved. The

fruit would have to be safeguarded by a n insect

- proof screen or plastic tarpaulin while in transit to the packinghouse and while awaiting packing.6 **•** Registered packinghouses can accept only avocados that are from registered places of production and that are produced in accordance with the requirements of the systems approach during the time they are in use for exporting avocados to the United States. Packinghouse Requirements

**•** A vocados must be packed within 24 hours of harvest in an insect

exclusionary packinghouse. All openings to the outside of the packinghouse would have to be covered by screening with openings of not more than 1.6 mm or by some other barrier that prevents pests from entering. Screening with openings of not more than 1.6 mm

excludes fruit flies.

**•** The packinghouse must have double doors at the entrance to the facility and at the interior entrance to the area where the avocados are packed.

**•** All avocados must be cleaned of plant debris before packing.

**•** F ruit must be packed in insect

- proof packaging , or covered with

insect

- proof mesh or a plastic tarpaulin, for transport to the United States, to prevent fruit fly infestation after the fruit is packed.

**•** Shipp ing documents must accompanying consignments of avocados from Peru that are exported to the United States to include the official registration number of the place of production at which the avocados were grown and must identify the packing shed or sheds in which the fruit was processed and packed. This identification would have to be maintained until the fruit is released for entry into the United States.

**•** Inspectors from the NPPO of Peru must inspect a biometric sample

fro m each place of production at a rate to be determined by APHIS. The inspectors would have to visually inspect fruit from each place of production for all the quarantine pests. The inspectors would also have to cut fruit to inspect for the avocado seed mo th and to inspect for A. fraterculus, and Medfly if the avocados did not originate from an

area free of those fruit flies. Inspection by the NPPO of Peru

**•** If any quarantine pests are detected in this inspection, the place of production where the infested avocados were grown would

immedia tely be suspended from the export program until an investigation has been conducted by APHIS and the Argentine NPPO and appropriate mitigations have been implemented

.

**•** If Medfly is detected, avocados from the place of production where the

infested avocado s were produced would be allowed to be imported into the United States only if treated with an approved treatment for Medfly in accordance with 7 CFR part 305

.

Each consignment of Hass avocados imported from Peru into the United

States to be accompanied by a phytosanitary certificate issued by the Phytosanitary Certificate7 NPPO of Peru with an additional declaration stating that that the avocados in the consignment were grown, packed, and inspected and found to be free of pests in accordance with the requi rements of proposed § 319.56

- 48.

In addition:

**•** If the avocados were produced in an area free of A. fraterculus, the phytosanitary certificate would have to state that the avocados in the consignment were produced an area designated as free of

A. fraterculu s in accordance with 7 CFR 319.56

- 5.

**•** If the avocados were produced in an area free of Medfly, the phytosanitary certificate would have to state that the avocados in the consignment were produced an area designated as free of Medfly in accordance with 7 C FR 319.56

- 5.

**•** If the avocados were treated for Medfly, the phytosanitary

certificate would have to state that the avocados in the consignment were treated for Medfly in accordance with

7 CFR part 305.



## III. Environmental Impacts

A. No Action

Current reg ulations do not allow the importation of avocados from Peru

into the continental United States . Under the no action alternative,

avocados from Peru would continue to be prohibited . Although there would be no potential environmental consequences from proh ibiting the importation of avocados from Peru , this alternative would unnecessarily

hinder trade because mitigations can be implemented that will allow for the safe importation of avocados from Peru ( USDA, APHIS, 200 9 b)

.

B. Pr oposed Action

Under the p r oposed action alternative, APHIS would allow the importation of avocados from Peru into the continental United States following certain conditions.

The pest risk assessment identified five quarantine pests Anastr e

pha fraterculus (South American fruit fly ), Ceratitis capitata (Mediterranean fruit fly), Stenoma catenifer (avocado seed moth), Coccus viridis (green scale), and Ferrisia malvastra (malvastrum mealybug). The pest management document outlined a systems approach method which

include s monitoring and oversight, production site requirements, harvest requirements, surveys, packinghouse requirements, traceability, and phytosanitary inspection and certification to ensure that the five pests are
not introduced into the continental United States through the importation

of avocados from Peru (USDA, APHIS, 200 9 b)

.8 Areas that are not established as pest free areas for Anastrepha fraterculus will require s urveys to ensure that the area has a low prevalence for Anastrepha fraterculus

. If any of these pests are detected at more than the

level indicated in the requirements

, the place of pr oduction will no longer be eligible to ship avocados to the continental United States until appropriate mitigations have been implemented.

Avocados from areas that are no t established as pest

- free areas for Medfly may still be shipped if they undergo treatment for Medfly: C old treatment

under T107

– a, methyl bromide treatment according to T101

– c, or cold treatment combined with methyl bromide treatment under T108

– a

- 1,

T108

- a

- 2, or T108

- a

- 3

.

The systems approach ( which includes monitoring, grove requirements, surveys, harvest requirements, packinghouse requirements, inspection and

certification ) ensure s that the commodity has limited pest presence prior to harvest, the c ommodity undergoes harvest and production processes which will limit plant pest presence, and the commodity remains pest

- free during transport and throughout the packinghouse processes . The labeling requirement ensures that the place of production and pac kinghouse facility are tied to each shipment . This is in place so t hat APHIS and the NPPO of

Peru can identify the place of production and/or packinghouse at which the fruit was packed if inspectors find quarantine pests in the f r uit either before export or at the port of entry. These mitigations were fully examined in the risk management document and were determined to be

effective in providing protection against the introduction of quarantine
pests from the importation of avocados from Peru into the con tinental United States ( USDA, APHIS, 200 9 b)

. The concerns of the EA associated with these mitigations are discussed belo w

.

The Plant Protection Act of 2000 (SE C. 401.7 U.S.C. 7701) defines

“s yst ems a pproach” as “...a defined set of phytosanitary procedure s, at least two of which have an independent effect in mitigating pest risk associated with the movement of commodities.” Similarly, the Food and Agriculture Organization of the United Nations’ ( FAO ) Standard for Integrated Measures for Pest Risk Manageme nt proposes that a systems

a pproach be defined as, “The integration of different pest risk management measures, at least two of which act independently, and which cumulatively achieve the desired level of phytosanitary protection” (FAO, 2002). Pest risk m anagement is the decision making process of reducing the risk of introduction of a quarantine pest. Systems a pproaches are employed by an importing country as an alternative to the use of a single

measure that achieve s an appropriate level of phytosanitary protection when a single phytosanitary measure is nonexistent, infeasible

, or undesirable. 1. Systems Approach9 Combining specific mitigation measures in a way which provides overlapping or sequential safeguards is distinctly different from applying single mitigation method ologies

, such as fumigation or inspection. Specific measures may be selected from a range of preharvest and post

harvest measures (e.g., surveys, inspections, sanitation, chemical

treatments, etc

. )

, and include mitigation measures to compensate for

uncert ainty. APHIS, P lant P rotection and Q uarantine uses systems approaches for the importation of many commodities

, including Hass avocados from Mexico ( 7 CFR § 319. 56

– 30), Unshu o ranges f rom Japan ( 7 CFR § 319.28, 1997 ), t omatoes from Spain, France, Morocco, and Western Sahara ( 7 CFR § 319.56

– 28, 1997 ), and p eppers from Israel ( 7

CFR § 319.56

– 24, 1997 ). These programs have successfully prevented pests from reaching the continental United States for many years.

As described in the risk management document, t he effectiveness of the systems approach to eliminate live plant pests from avocados import ed

from Peru into the continental United States is adequate to prevent pest introduction ( USDA, APHIS, 200 9 b). As such

, the systems approach for the importation of Hass avocados from Peru into the continental United

States is not expected to have an effect on the human environment, including no ntarget animals and humans

.

Cold t reatment s ensure that fruit is kept at a specific temperature for a

minimum amount of days to ensure that the pest of concern does not

survive. C old treatment is initiated once the fruit is packed for shipment

, and generally occurs as the fruit is being transported to the continental

United States. In this ca se, the treatment schedule i s T

– 107

– a as outline d

in 7 CFR part 305 w hich is as follows:

Temperature Exposure P eriod

34 °F or below 14 days

35 °F or below 16 days

36 °F or below 18 days

Cold treatments are conducted in contained facilities

, thus limiting the exposure of non targ et animals, including humans and the environment. Additionally, b ased on the effectiveness of cold treatment to eliminate the presence of live plant pests, the importation of avocados from Peru into

the continental U nited States is not expected to have an effect on nontarget

animals or the environment.

Methyl bromide fumigation would occur prior to exporting avocados from

Peru or w ould be done at a designated fumigation center at the point of
entry . The proposed rule requires that if the fruit must be fumigated it

must meet the following conditions as outlined in treatment schedule

T101

– c

– 1

. 3

. Methyl

Bromide 2

. Cold

Treatment10 Temperature Dosage R ate (lb/1000 cubic feet) Exposure
P eriod

7 0 or above ( °F) 2 4 hours

M ethyl bromide fumigation is conducted in contained facilities

, thus limiting the potential exposure of other nontarget animal s, including

humans

, and the environment . Occupational workers are most at risk of methyl bromide exposure ; however, a dherence to good practices and guidelines should ensure that there are no advers e effects on persons exposed occupationally. Additionally, based on the effectiveness of methyl bromide to eliminate the concern of live plant pests, the importation of avocados from Peru into the continental United States is not expected to have an effec t on nonta rget animals or the environment

.

The primary concern with the use of methyl bromide fumigation is ozone depletion. Methyl bromide has been classified by the Environmental Protection Agency under the Clean Air Act as a Class I ozone

- depleting

ch emical. The expected use of methyl bromide in fumigations of

avocados from Peru is well below any levels which w ould contribute substantially to ozone depletion

. The total number of avocados to be imported into the continental United States from Peru is approximately 19,000 metric tons

. Of the shipments that may require treatment, some will be treated with cold treatment or a combination of methyl bromide

and cold treatment. There is more environmental concern with the use of methyl bromide then with the use of cold treatment. However, e ven if all of the shipments were treated with methyl bromide the total amount of methyl bromide used would be roughly 1900 lbs. 1

A thorough review of the potential effects of methyl bromide uses in fumigations on ozone d epletion w as originally presented in the F inal Environmental Impact Statement (EIS) for Importation of Solid Wood Packing Material (August, 2003); this document has recently been updated and is titled Importation of Solid Wood Packing Material, Supplement to the Final Environmental Impact Statement ( USDA, APHIS,

2007 ). This supplemental EIS (SEIS) determined that the cumulative impact of methyl bromide from routine commodity treatments on ozone depletion is not expected to be consequential. The methyl bro mide

treatment for use on avocados from Peru is consistent with the commo dity

1 T he amount of containers for 19 ,0 00 metric tons is roughly 950 containers (20 metric tons per container) and each container is just under 1,000 cubic feet. The methyl bromide does rate is 2lbs of MB per 1,000 cubic feet.

950 (# of containers @ 1,000 cubic feet) x 2 = 1900 lbs of Methyl Bromide.11 treatments evaluated in the S EIS ( USDA, 200 8 c; pers. comm. with EPA

, 2008 )

.

The risk management document stated that treatment schedule T108

– a is effective against C. capitata. Under this treatment schedule, the commodity is exposed to methyl bromide followed by a cold treatment according to treatment schedule T

– 108

– a

– 1, T

– 108

– a

– 2, or T

– 108

– a

– 3

. The table below shows the recommended dose and exposure times for both methyl brom ide and cold treatment.

Methyl Bromide

Temperature Methyl Bromide Dosage Rate ( lb/1000 cubic feet ) Methyl
Bromide Exposure

Period Cold
Treatment Temperature Cold
Treatment Exposure

Period

70 °F or above 2 2 hours 33

– 37 °F 4 days

70 °F or above 2 2 h ours 38

– 47 °F 11 days

70 °F or above 2 2.5 hours 34

– 40 °F 4 days

70 °F or above 2 2.5 hours 41

– 47 °F 6 days

70 °F or above 2 2.5 hours 48

– 56 °F 10 days

70 °F or above 2 3 hours 43

– 47 °F 3 days

70 °F or above 2 3 hours 48

– 56 °F 6 days

Methyl bromide combin ed with cold treatment is expected to have the same environmental effects as discussed above in the separate treatment s of methyl bromide and cold treatment. Due to the nature of how these treatments are conducted, there is limited impact to nontarget spe cies and humans. As long as proper protocols are followed

, the treatment is effective against the pest of concern. In addition, following proper label requirements and safety protocols will ensure no adverse impacts to occupational workers, the group at most risk for exposure.



### C. C umulative Impacts

Cumulative impacts are impact s on the environment which result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions . The use of methyl bromi de can lead

to cumulative impacts when added to the uses of methyl bromide on other

commodit ies . However, the limited quantities of methyl bromide needed

to treat a vocados from Peru are not substantial and are within the negligi ble treatments anticipated from the previous cumula tive analysis ( USDA, APHIS, 2007 ). 4

. Methyl
Bromide
with Cold

Treatment12 

## IV. Other Environmental Considerations

The APHIS NEPA implementing procedures require, to the fullest extent possible, the integration of Federal environmental laws and executive orders with the analysis of environmental impacts (7 CFR § 372.7). Of the numerous environmental review laws and executive orders, this EA looks at the few that have any possible association to plant, animal, or human health impacts from the pr oposed action.13 

### A. Endangered Species Act

Section 7 of the Endangered Species Act and its implementing regulations require Federal agencies to consult with the U.S. Fish and Wildlife Service (FWS) and/or the National Marine Fisher ies Service to ensure the actions

taken are not likely to jeopardize the conti nued existence of threatened or endangered species or result in the destruction or adverse modification of critical habitat. APHIS has considered the potential effects of the ru le to allow importation of commercial shipments of Hass avocados from Peru

into the continental United States.

Cold treatments and methyl bromide fumigation s are c onducted in

contained facilities ; listed species and their habitats would not be exposed

t o these treatments. In addition, based on the ability of the requirements (methyl bromide fumigation, cold treatments, and a systems a pproach ) to eliminate the presence of live plant pests

, the program has determined that importation of avocados from Peru into the continental United States would have no effect on any threatened or endangered species or their

critical habitats.



### B. Other Considerations

Certain executive orders, such as Executive Order 13045 (Protection of

Children From Environmental Healt h Risks and Safety Risks) and Executive Order 12898 (Federal Actions to Address Environmental Justice in Minority Populations and Low

- income Populations)

, and departmental or agency directives call for special environmental reviews in certain

circumstances . No circumstance that would trigger the need for special environmental reviews is involved in implementing the proposed action considered in this document. No disproportionate adverse effects are anticipated to any minority or low

- income population

, or particular sub

group of the U.S. population.14 

## V. Listing of Agencies and Persons
Consulted

U.S. Department of Agriculture Animal and Plant Health Inspection Service Policy and Program Development

Environmental Services 4700 River Road, Unit 149

Riverdale , MD 20737

U.S. Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine Commodity Import s Analysis and Operation s 4700 River Road, Unit 133 Riverdale, MD 20737

U.S. Department of Agriculture

Animal and Plan t Health Inspection Service Plant Protection and Quarantine Phytosanitary Issues Management 4700 River Road, Unit 140 Riverdale, MD 20737

U.S. Department of Agriculture Animal and Plant Health Inspection Service Plant Protection and Quarantine Planning, Analysis, and Regulatory Coordination 4700 River Road, Unit 156 Riverdale, MD 2073715 

## V I

. References

APHIS

— See U.S. Department of Agriculture, Animal and Plant Health Inspection Service

EPA

— See U.S. Environmental Protection Agency.

FAO

— See Food and Agr icultural Organization

Food and Agricultur e Organization of the United Nations

, 2002.

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