Bulb import permits

Lee Poulsen wpoulsen@pacbell.net
Tue, 08 Mar 2016 17:19:28 PST
On Mar 8, 2016, at 11:06 AM, William Aley <aley_wd@icloud.com> wrote:

> By the way if you don't know about the controlled Import Permit you are missing out on opportunities. 
> Feel free to hit me up to discuss how to import plants into the USA. 
> Get the facts directly from the source. 
> http://ecfr.gov/cgi-bin/text-idx/…

> On Mar 8, 2016, at 1:06 PM, penstemon <penstemon@Q.com> wrote:
> I read that entire document twice. I see nothing in it which contradicts the information I have been providing, namely, that importation of flower bulbs free from soil require only a phytosanitary certificate. 
> Agreed?
> I think that the confusion here results from considering seeds, bulbs, and plants (ie herbaceous plants or something other than dormant bulbs) as requiring the same permits.

Bob, I think Mr. Aley is hinting that there is a third method of importing plant material that some of us might want to use to bring in something really desirable that can’t be imported using the two other methods. (By two other methods, I’m referring to (1) the standard plant import permit which allows you to import any non-banned plant material, be it plants, bulbs, seeds, scions, etc., as long as you can obtain a phytosanitary certificate to accompany the material. And (2) the small lots of seeds permit which allows you to import only seeds *without* having to obtain a phyto certificate.)

My reading of Mr. Aley’s link seems to talk about a third way to import plant material "for experimental, therapeutic, or developmental purposes”. This third method is called a “Controlled Import Permit”  (“CIP”). And I think it's saying that a CIP can be used to possibly import (1) plant material that is otherwise banned or prohibited, or also (2) non-banned plant material, but in a manner different than the two normal methods, i.e., using a plant import permit with an accompanying phyto certificate or using a small lots of seeds permit for seeds only without a phyto. (See the second half of paragraph (b).) In addition, the CIP is also free.

I think the key purpose Mr. Aley might be hinting at is the “developmental purpose” which according to paragraph (a) includes the definition: "The evaluation, monitoring, or verification of plant material for ... the adaptability of the material for certain uses or environments.” For example, verifying that a particular bulb species from the Andes Mountains can be grown outdoors in Southern California?   ;-)   And I don’t see that a phyto certificate is required using this type of permit.

The catch seems to be paragraph (e) “Post-importation conditions” where the plant must be grown under quarantine—but monitored and grown by the CIP permit holder, i.e., ourselves!—in an approved facility. But I can’t tell what an “approved facility” consists of. Maybe it’s something we can build ourselves, such as a netted enclosed covering that prevents pests from entering or leaving the plant?

I also couldn’t find out what you have to do with the plant after you’ve successfully evaluated, monitored, and/or verified its "developmental purposes”. I see that if anything changes before the permit expires, you either have to destroy it or properly transfer it to another person. It also appears that if you get permission from the USDA PPQ Permit Unit it may be possible for you to distribute some of the plant material to other people.

Maybe this is a way to import bulbs in those all-too-frequent cases when a phyto is very difficult to impossible to acquire? Anyway, maybe Mr. Aley can enlighten us further about this particular type of permit and what it can be used to do by ordinary hobbyists?

--Lee Poulsen
Pasadena, California, USA - USDA Zone 10a
Latitude 34°N, Altitude 1150 ft/350 m

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