It's a difficult dilemma for bulbs, when there are plant pests that only manifest during the green stage. Even a phytosanitary certificate cannot verify that there are no hidden pests and the challenge will be convincing scientist- pathologists, nematologists and entomologists that any bulb is free of all plant pests without conducting destructive analysis to verify this. I am open to suggestions, ideas and solutions. Joyce has asked us in the past about what it would take to have a small lots of plants permit and we have the scientists reply with "how do you know the bulbs are free of plant pests?" That is the purpose of the NAPPRA, which will require a pest risk assessment before any Genera and or Species will be considered generally enterable. This is another LONG winded topic. As I mentioned earlier, seeds are for the most part free of many destructive plant pests. Other plant parts have pathways for plant pests: stem borers, leaf minors, egg layers, cankers, galls, cysts, spores and fungus each plant pest has a particular process to ensure survivability and in this modern era transportation to a new environment. I don't think anyone in this group wants to be known as the importer responsible for a blight, new rust or plant pest that uses the imported plant as primary or an alternative host which might attack other plants both commercial or for hobbyists. For regulators there is the balance between enough information to have a high level of confidence and pest freedom and not so restrictive to be a barrier for free trade. One new pest out break can cost thousands to millions of dollars to clean up. Take Hosta X virus, not even a quarantine pest but a quality plant pest that the Hosta Folks are very concerned about, each shipment imported into the USA must pass a screening to have only a total of plants below a 5% contamination per shipment, the individual test is not cheap and someone pays for the test, time and validation during the in inspection, you do as it's all funded by taxpayer and user fees. Would anyone-one be willing to pay $300 for an import permit to fund inspection and verification at the port of entry for any particular shipment? Usually there is a universal no to that question and then our managers must balance perception with the current trend to make government smaller. But we still have pests like emerald ash borer that will make American Ash tree go the way of the American Chestnut, Asian longhorn beetles that feed uncontrolled on hardwood trees. Barberry rusts that overwinter on barberries and kill certain annual grasses like wheat. Don't even get me started on Phytophthora. Our entire staff works to look for the balance and constructive suggestions are always welcomed, were just folk who have this as our job, just like many of you deliver or make or fix something for a living. Our staff has no problem giving credit where it is due when folks come up with great solutions to the existing dilemmas as the rules we have now are what have been in place at least from 1979 and often way before that. Any positive movement to that balance would be an improvement. But remember that many people view us as the plant nazis or mindless bureaucrats who live for the opportunity to screw over the population. There is a reason why many of my counterparts refuse to be in a public forum to discuss these issues and their absence is often a reflection of vitriolic comments from folks that think they know a lot but may be missing some of the information, understand the rules that restrict or control legal options or even the history of how we got to this place we are at today. To be honest, we in the regulatory side don't have all the answers, I don't think we claim to be the experts in everything. Often groups that have an affinity for a particular subject are far more equipped at being experts because they have a collective passion for the subject. I really believe that one of you may just come up with a suggestion that would work and make sense or galvanize a collective to accept a stance not previously thought of. Individually each of us have our passions and needs and wants, but collectively the resources and knowledge is far greater and that when harnessed can help make this little , tiny, slow moving and often insignificant part of government work just a little bit better so more people have a level of satisfaction rather than disappointment. Perhaps that's what's meant by saying, "We the people" Bill's soapbox about import options On Jan 24, 2011, at 8:24 AM, r de vries wrote: > Great idea! > > but they still have to be free of dirt and bugs and will likely > require someone to certify that.... > > Rimmer de Vries > > > Michael Mace wrote: > > And in the meantime, I think it would be *great* to see if we can > get something similar to the small lots of seed program applied to > small > quantities of dry bulbs. I'm interested in pursuing that. Is anyone > else > interested? > > Mike > > > > > _______________________________________________ > pbs mailing list > pbs@lists.ibiblio.org > http://pacificbulbsociety.org/list.php > http://pacificbulbsociety.org/pbswiki/ William Aley aley_wd@me.com http://www.aley.william.name/