possible change in importation rules (NAPPRA)

Michael Mace michaelcmace@gmail.com
Wed, 25 May 2016 10:06:48 PDT
Hi, gang.

We've gone over the US NAPPRA rules on this list a couple of times in the
last few years, but we keep adding new people to the list, so let me recap
how I think the system works. Bill and others, please jump in and correct me
if I get anything wrong.

The way the NAPPRA process works is that APHIS occasionally proposes a list
of potentially invasive species that might be banned from importation unless
they pass a test of invasiveness. Those plants seem to have been nominated
by advocates or to have shown up on a weed list in Australia or something
like that. Reading between the lines from talking with some APHIS folks, I
don't think they necessarily love the NAPPRA approach, but they felt they
were required to implement it under the law. There is intense lobbying in
favor of even more radical action from a number of major conservation
organizations in the US, ranging from the Nature Conservancy to the
California Native Plant Society. They are very aggressive, they use
apocalyptic language about threats from non-native plants, and they know how
to lobby in Washington.

Considering all the political pressures, APHIS has so far been surprisingly
open to feedback from normal folks like us. But you need to read their
requests for comment, and send information when they ask for it. Expressing
opinions is useful, but the most important thing to do is give them
evidence. Our experiences with non-native plants, and our knowledge of their
distribution in the US, are relevant information to them.

There is a comment period in which we can respond to a proposed listing with
information, which can include things like:

--That plant is already established in the US, so there's no point in
banning it.
--That plant has been imported for years and hasn't proven to be invasive.
--We grow that plant and it does not spread.
--There is no scientific basis for that weed list in Australia (you'd be
amazed at how haphazard some of the online lists are).
--And so on...

In the first round of proposed NAPPRA list additions, several commonly grown
bulbs were tentatively listed, including Alstroemeria aurea and Gladiolus
undulatus. We documented that they had been imported to the US for many
years, and were even being sold by botanical gardens. We also gathered
comments on the plants' invasive potential. We were successful in getting
those species removed from the list.

If the system continues to work they way it has in the past, we should be
able to prevent the listing of the sorts of plants we bulb-growers grow. The
things that are getting restricted now are generally aquatic plants or
obscure tropical plants that have caused problems in the Pacific.

Also, I haven't seen a new proposal for listings in more than a year, so I
get the feeling that adding more species is not a super-high priority.

Bill and others, did I get any of that wrong?

I'd like to add one personal comment: yes some things like Kudzu have caused
big problems. But those problems were created when the plants were either
deliberately spread through government policy, or were brought in
commercially in large quantities. For example, the government deliberately
planted and promoted Kudzu. Star thistle supposedly came in with
contaminated feed from Europe. Other plants have escaped from the nursery
trade when heavily promoted. But I'm not aware of any documented cases in
which a plant escaped from private collectors to become a problem weed.

Think about it: We understand our plants pretty well, we know which ones
spread around, and we're careful with them. We warn each other about plants
that show aggressive tendencies. We're actually a pretty good source of info
on which species need to be watched. We're not a significant problem, and I
think we can be part of the solution. I think it makes sense for us to
partner with the regulators, and for them to listen to us. So far, I think
they are wiling to do so.

It's too bad that places like Nature Conservancy and CNPS don't seem to have
the same reasonable attitude.

San Jose, CA

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