NAPPRA and plant imports

William Aley aley_wd@icloud.com
Wed, 25 May 2016 14:44:55 PDT
Hi folks. It's interesting to see the evolution of the comments within this group. Even more Interesting is when someone actually reads the information. And to be honest I relate what goes on in these discussions back to the plants for planting group.  No one else in the import staff is relating your comments  back to the people who make decisions that will affect you. This group has influence government for over 10 years. 
Some points to ponder. 
We are not evil ( well mostly I cannot say I know everything about my coworkers.) just folks trying to get a job done mostly because of passion rather than making a fortune. 
The rules that we create are not done in a vacuum, in fact everything we do is vetted and reviewed. For instance we have to publish a draft PRA to see if the public agrees with the scientists ( I assume people with PhDs can be called scientist)   And what they wrote.  Although often the review of PRAs garners one or two comments. Somehow we are not reaching all stakeholders or people don't care to comment.  I'm working on a rule now and only two comments were received, one from the state of Florida that said no and another from Louisiana that said yes. Apparently no other state department of agriculture or Organization or individual thought it important enough to comment on. 
The rationale for making rules is often the result of pest interdiction or an import system needs a change.  Lately is allowing already enter able barefoot plants to be imported in growing media. Very controversial. Image having a foreign grown plant available directly to the retailer. It cuts out nurseries that buy plants. Pot them. Grown them and then sell them. It's not about pest risk that there is controversy. 
The Q37 quarantine group (P4P) is currently getting a make over to the system since the creation of this quarantine in the late 70's. 
Funding for my part of APHIS is primarily through user fees.  Of course every agency wants access to those fees. Remember Bush and the creation of Homeland Security. 75% of our uniformed officers were transferred to DHS. And we pay over 75% of our budget to DHS. They are constantly trying to get a larger slice to protect USA.  
The laws of USDA are very old- 'what was the commerce of trade for the 13 colonies?'. It certainly wasn't motorcycles and iPhones   Early trade was agriculture and the laws were put in place to protect the early states. Lincoln created USDA as the people's department. Because we deal with the stuff people use.   Customs is Revenue. Remember from prohibition the Gmen as revenuer's? 

I have said to this group many times. The power of one person is to influence those that agree. The power of many who use one spokesperson is huge.   Look at the landscape groups and the florists. They have paid advocates to discuss with us issues that their constituents are concerned for.  They can actually receive an audience from APHIS Administrator to the Secretary of Agriculture   (and both Osama and Tom are really nice folk). For the most part. The people I work with lack an agenda other than to do their job and protect American Agriculture and they try to do the best they can. 

I can only speak for my staff. We care about plants, we are a group of plant and plant pest geeks. We have pathologists, virologists, botanist and horticulturalist on out staff. Everyone has a minimum of a BS in science.  (that's me BS Env Hort CalPoly SLO'91). So yea I'm not as bright as most but somehow I get things done and take a lot of flack as the plant gestapo from people I'm willing to help.  
If you don't like the way things are currently we will listen. Sometimes individually we are just as powerless as you may feel. Many of these laws were written in the early  1900's  I wasn't born then.  
Here's an example. 
One of the documents in my cubicle. The director of plant quarantine requested the US inspectors to be lenient when inspecting Belgium boxed & field grown Azaleas (untreated raw wood containers with plants in native soil) entering the US due to the skirmish that was going on in Europe. It is dated 1915. 

So if you read into that import the way I do, you'd wonder why there are not more problems in the US. 
And our standard are far greater now than how last century started. 

Our job is to protect and serve. 

Thanks for your comments and commentaries. It provides me with information to educate our staff. 

William Aley. 
A very Google-able 
gov employee. 



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