easy pass for small quantities of dry bulbs

William Aley aley_wd@me.com
Mon, 24 Jan 2011 07:39:34 PST
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  

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

More information about the pbs mailing list