NAPPRA was primarily to be a tool to obtain pest risk from plants that have been imported in large numbers with a pest risk as a host to a plant pest or as a plant pest. Invasiveness is only one aspect of risk. The problem is that historically plants enter the us without any knowledge of what the risk is. Initially NAPPRA would look at a range of plants. Those with a risk associated with them and have low import records or high plant pest profiles. The weedy plants are the result of the promotion for 'Alien Invasive's' and the lack of funding to support domestic weed programs pit was lobbied that NAPPRA could be used to take care of weed plant imports. I always do long texts. Sorry about the read. William Aley Sent from my iPhone > On May 25, 2016, at 13:06, Michael Mace <michaelcmace@gmail.com> wrote: > > Hi, gang. > > We've gone over the US NAPPRA rules on this list a couple of times in the > last few years, but we keep adding new people to the list, so let me recap > how I think the system works. Bill and others, please jump in and correct me > if I get anything wrong. > > The way the NAPPRA process works is that APHIS occasionally proposes a list > of potentially invasive species that might be banned from importation unless > they pass a test of invasiveness. Those plants seem to have been nominated > by advocates or to have shown up on a weed list in Australia or something > like that. Reading between the lines from talking with some APHIS folks, I > don't think they necessarily love the NAPPRA approach, but they felt they > were required to implement it under the law. There is intense lobbying in > favor of even more radical action from a number of major conservation > organizations in the US, ranging from the Nature Conservancy to the > California Native Plant Society. They are very aggressive, they use > apocalyptic language about threats from non-native plants, and they know how > to lobby in Washington. > > Considering all the political pressures, APHIS has so far been surprisingly > open to feedback from normal folks like us. But you need to read their > requests for comment, and send information when they ask for it. Expressing > opinions is useful, but the most important thing to do is give them > evidence. Our experiences with non-native plants, and our knowledge of their > distribution in the US, are relevant information to them. > > There is a comment period in which we can respond to a proposed listing with > information, which can include things like: > > --That plant is already established in the US, so there's no point in > banning it. > --That plant has been imported for years and hasn't proven to be invasive. > --We grow that plant and it does not spread. > --There is no scientific basis for that weed list in Australia (you'd be > amazed at how haphazard some of the online lists are). > --And so on... > > In the first round of proposed NAPPRA list additions, several commonly grown > bulbs were tentatively listed, including Alstroemeria aurea and Gladiolus > undulatus. We documented that they had been imported to the US for many > years, and were even being sold by botanical gardens. We also gathered > comments on the plants' invasive potential. We were successful in getting > those species removed from the list. > > If the system continues to work they way it has in the past, we should be > able to prevent the listing of the sorts of plants we bulb-growers grow. The > things that are getting restricted now are generally aquatic plants or > obscure tropical plants that have caused problems in the Pacific. > > Also, I haven't seen a new proposal for listings in more than a year, so I > get the feeling that adding more species is not a super-high priority. > > Bill and others, did I get any of that wrong? > > I'd like to add one personal comment: yes some things like Kudzu have caused > big problems. But those problems were created when the plants were either > deliberately spread through government policy, or were brought in > commercially in large quantities. For example, the government deliberately > planted and promoted Kudzu. Star thistle supposedly came in with > contaminated feed from Europe. Other plants have escaped from the nursery > trade when heavily promoted. But I'm not aware of any documented cases in > which a plant escaped from private collectors to become a problem weed. > Zero. > > Think about it: We understand our plants pretty well, we know which ones > spread around, and we're careful with them. We warn each other about plants > that show aggressive tendencies. We're actually a pretty good source of info > on which species need to be watched. We're not a significant problem, and I > think we can be part of the solution. I think it makes sense for us to > partner with the regulators, and for them to listen to us. So far, I think > they are wiling to do so. > > It's too bad that places like Nature Conservancy and CNPS don't seem to have > the same reasonable attitude. > > Mike > San Jose, CA > > _______________________________________________ > pbs mailing list > pbs@lists.ibiblio.org > http://pacificbulbsociety.org/list.php > http://pacificbulbsociety.org/pbswiki/