Today is your last chance to comment on new US plant importregulations
pelarg@aol.com (Wed, 21 Oct 2009 17:06:34 PDT)

I added my two cents in just now, took a while to figure out how to get to the place to add comments. Thanks all for the reminder!
Ernie DeMarie
Tuckahoe NY Z 7ish where we have had a rare nice weather day, lots of flowers still blooming in gardens very lighty touched by frost.

-----Original Message-----
From: Adam Fikso <adam14113@ameritech.net>
To: Pacific Bulb Society <pbs@lists.ibiblio.org>
Sent: Wed, Oct 21, 2009 3:58 pm
Subject: Re: [pbs] Today is your last chance to comment on new US plant importregulations

'm withTony Avent on this--for the most part-- most of his reasoning is
ound. Some consideration needs to be given to new species. There is
othing wrong with introductions even if they run wild. They only run wild
ecause they have been put in the wrong places. Kudzu still has good uses,
nd just because the USDA couldn't predict the future doesn't mean that we
hould put an embargo on all new species. We cannot predict the future
ither--so should not place a limit on our curiosity or on seeking new
nowledge. This is xenophobia and not sensible inquiry.n It might even be
nconstitutional. Much will depend on how the law is written and the
ubsections.
----- Original Message -----
rom: "Michael Mace" <mikemace@att.net>
o: <pbs@lists.ibiblio.org>
ent: Wednesday, October 21, 2009 2:03 PM
ubject: [pbs] Today is your last chance to comment on new US plant
mportregulations

Today (10/21) at midnight EST is the deadline to submit comments on the US
government's proposed plant import regulations, which would create a new
category of banned plants that have not yet been evaluated for potential
pest status (sometimes referred to as "NAPPRA"). Depending on how it is
implemented, it could ban a lot of the seed and bulb importing we do
today.

There are about 250 comments on the government's comment site now, almost
100% of them in favor of the regulations. In fact, the only dissenting
voice I could find was Tony Avent's. Many of the comments are from native
plant societies, and are advocating a very draconian version of the
regulations. For example, the Virginia Native Plant Society suggests a
blanket ban on any plant that does not have a 50-year documented record of
being grown outside its native habitat. That would ban many of the plants
in our collections today.

I won't bother to re-hash the things that I wrote about these regulations
before, but you can influence the rule-making process by submitting a
comment. In my experience, the government does listen to private
comments,
and they specifically asked for feedback from private plant groups like
PBS.
As a PBS member, you are qualified to respond.

I just posted a comment. So you know, what I suggested was that the
government:

--Create a definition for "in cultivation" that includes anything that is
currently in cultivation in the US, or has been in the past.

--Exempt the small lots of seed program from the regulations (because it
has
little risk of introducing pests, and the exemption would allow private
societies to continue their seed exchanges, which are important to them
financially).

--Collect information from plant collectors on the invasiveness of
imported
species.

Contact me privately if you want a copy of my comments.

If you want to comment, use this web address:

http://regulations.gov/search/Regs/…

Click on "submit a comment"

In "keyword" type: aphis-2006-0011

You will see a list of comments. Click on one of the small icons next to
them labeled "submit a comment"

This will open a window to submit a comment on that particular comment.
Don't do that. Instead, click on the box labeled "Comment directly on
proposed rules."

This will open a form that lets you comment on the rules themselves. If
you
want to write something long, you can submit a file. But short comments
can
be typed directly into the form.

Thanks,

Mike

San Jose, CA

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