Jim: Joyce Fingerut of the North American Rock Garden Society has been our point person for the hobbyist gardener, and the one responsible for getting the Small Seed Permit instituted. Her email is alpinegarden@COMCAST.NET There are a number of problem people in this debate...well meaning, but with a mystical idea that nature should always remain a Camelot...a pristine idealic static place that never really existed. We (all parties to the debate) originally all met back in 2001 for a meeting known as the St. Louis Summit, where we came up with a voluntary code of conduct. I tried to make the point that invasive species must be monitored on a local level. My proposal was to use trained master gardeners to monitor if a plant was becoming a problem in a region and subsequently use the media to let folks know that the plant was a problem in that region and should not be planted. Free market forces would then eliminate the demand in that area and the plant would subsequently disappear from production. There still may be an occasional case for government preemption, when good science deems it necessary (we currently have a Federal Noxious Weed Law which is more than adequate). About 10 years ago, I heard about a closed meeting in Chicago with the eco-nazis and USDA-Aphis. I showed up, uninvited just as a discussion was concluding to ban all plants that were invasive in any part of the US from the entire US. I asked Dr. Reichard if this indeed was her intent, to which she replied, yes. Can you imagine what would happen if this had occurred and every plant that invades in Florida, Hawaii, or California were banned from the entire country? Any new regulations must allow plants like water hyacinth, lantana, and impatiens to be grown and produced in areas where it is not winter hardy while not in areas where it can choke out waterways. As with everything, the devil is in the details and the current plants are to use a screening model such as devised by Dr. Sarah Reichard. Her model includes many factors including plant families that have weeds as members, the propensity to reseed in the wild, whether the seed coat is desirable to wildlife, etc. Such groups as the Nature Conservancy have conclucded that the only acceptable control of potential exotic weeds is exclusion....we must effectively shut the horticultural border under a guilty until proven innocent philosophy. The dollars that they cite spent on controlling /costs incurred by exotic pests is staggering (5% of the worlds GDP) until you realize that it includes everyone who uses a pesticide to kill cockroaches or crabgrass. I am including a link to the Nature Conservancy's Position paper on Invasive plants...pay particular attention to page 2...if this doesn't scare you to death, you're not a gardener. http://nature.org/initiatives/forests/… USDA Aphis is now accepting public comments, so please do so as well as call you Congressional representatives. Tony Avent Plant Delights Nursery @ Juniper Level Botanic Garden 9241 Sauls Road Raleigh, North Carolina 27603 USA Minimum Winter Temps 0-5 F Maximum Summer Temps 95-105F USDA Hardiness Zone 7b email tony@plantdelights.com website http://www.plantdelights.com/ phone 919 772-4794 fax 919 772-4752 "I consider every plant hardy until I have killed it myself...at least three times" - Avent James Waddick wrote: >> I hope you will read the Nature Conservancy's position paper posted all >> over the Internet...I have also been a member in the past. This is >> truly frightening. >> > > Dear Tony, > > I suspect you are the most knowledgeable member on this new > "Proposed Rule". > > Would you be willing to put down in a few simple words and > sentences what you think this Rule might result in and then > > Who exactly (name, title email or postal address) we could contact, > > What topics might be of greatest importance to bring up and, > > When the deadline is for contacting the responsible agency(-ies) ??? > > Has the agency proposing this already incorporated everything > in Hortus, specialty seed list, etc > > Will this list be by family, or genus, or species or down to cv? > > I'll certainly try to marshal some effort if I had a direct > contact to inform of my concerns. > > > Thanks Jim W. >