I'm withTony Avent on this--for the most part-- most of his reasoning is sound. Some consideration needs to be given to new species. There is nothing wrong with introductions even if they run wild. They only run wild because they have been put in the wrong places. Kudzu still has good uses, and just because the USDA couldn't predict the future doesn't mean that we should put an embargo on all new species. We cannot predict the future either--so should not place a limit on our curiosity or on seeking new knowledge. This is xenophobia and not sensible inquiry.n It might even be unconstitutional. Much will depend on how the law is written and the subsections. ----- Original Message ----- From: "Michael Mace" <mikemace@att.net> To: <pbs@lists.ibiblio.org> Sent: Wednesday, October 21, 2009 2:03 PM Subject: [pbs] Today is your last chance to comment on new US plant importregulations > 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 > > > > > > _______________________________________________ > pbs mailing list > pbs@lists.ibiblio.org > http://pacificbulbsociety.org/list.php > http://pacificbulbsociety.org/pbswiki/