Today is your last chance to comment on new US plant import regulations

Michael Mace
Wed, 21 Oct 2009 12:03:26 PDT
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

--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

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


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



If you want to comment, use this web address:…


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.






San Jose, CA



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