[APWG] Fwd: [Aliens-L] Comment Period on Nursery Stock Regulations

[Rachel Orwan]

Below is a message detailing how to submit commits to the USDA's Animal and 
Plant Health Inspection Service (APHIS) regarding  potential revisions to 
their policies on importing plants and seeds for the nursery industry.
Sorry for the rather long message, but many of us are probably interested 
in adding our two cents to the mix

Rachel



Rachel Orwan
Appalachian Forest Resource Center
Research Coordinator
P.O.Box 21, Glouster, OH 45732
740-767-2090
www.appalachianforest.org




>*************EXECUTIVE SUMMARY *************
>
>ISSUE:  The U.S. Department of Agriculture's Animal and
>Plant Health Inspection Service (USDA/APHIS) has asked for
>public comments on whether and how to revise its regulations
>for importing horticultural plants and seeds, or "plants for
>planting." At their strongest, such revisions would be
>revolutionary. They would help prevent the wholesale
>transformations of ecosystems by new pests and pathogens,
>take seriously the impacts of those horticultural plants
>that escape from gardens to invade natural areas and
>threaten biodiversity, and, generally, better mitigate the
>damages too-often associated with increasing global trade in
>plants and seeds.
>
>ACTION: Submit written comments.
>
>MAIN MESSAGE: USDA/APHIS should substantially revise its
>regulations to set a highly protective and measurable
>standard for the import of plants for planting. This new
>standard should provide two kinds of protection for native
>ecosystems and biodiversity: protection from pests and
>pathogens that such plants can convey and also protection
>from plants for planting that are themselves invasive or
>potentially so.
>
>DEADLINE:  The comment period closes April 11, 2005
>
>*************** THE ISSUE *********
>
>The U.S. Department of Agriculture's Animal and Plant Health
>Inspection Service is considering substantial revisions to
>the regulations known collectively as Quarantine 37. In the
>past, these were intended to exclude pests and pathogens
>inadvertently imported via nursery stock and seeds. Using
>somewhat cumbersome new terminology, APHIS is asking for
>broad input related to "plants for planting." For the first
>time, some of these revisions could address the known and
>potential invasiveness of imported plants and seeds, e.g.,
>by establishing a list of plant taxa that would be excluded
>from import pending risk evaluation and approval.
>
>Strong protections for native ecosystems and biodiversity
>are essential in any regulatory revision - something missing
>in the past. We want any new standards to provide high
>levels of protection from both the pests and pathogens that
>plants for planting can convey as well as from such plants
>that are themselves invasive or potentially so. Most of the
>public comments submitted so far oppose regulatory changes
>because of their possible impacts on gardening and small
>businesses, such as nurseries. To balance these, UCS is
>encouraging scientists to weigh in and support more
>stringent regulation.
>
>For more than 100 years, scientists have warned that imports
>of nursery stock are the most dangerous pathways for
>transporting pests. At least 14 of the most damaging non-
>native insects and pathogens now threatening North American
>forests and other ecosystems were likely introduced on
>imported plants. Some were imported early in the 20th
>Century, like chestnut blight. Several, though, have been
>imported since the late 1980's, breaching modern US border
>protections. This argues for much stronger measures to
>protect important US resources.
>
>In addition, hundreds of plant species imported for
>horticulture or other limited uses in the United States have
>become established and invasive in the wild. In Florida, for
>example, 90 percent of the species listed, in 1995, as most
>invasive by the state's Exotic Pest Plant Council were
>deliberately introduced. In California, 1,152 non-native
>plant species are established in the wild. Nearly 450 of
>them were introduced as ornamental or aquarium plants. By
>one estimate, more than 50 percent of the invasive plants in
>the co-terminus United States continue to be offered for
>sale. Yet weeds of natural areas have received almost no
>regulatory attention until a high-profile invader has caused
>serious damage. Given that imports of fewer than 100 weed
>varieties, species, or genera are limited as Federal Noxious
>Weeds, the arrival, establishment and spread of additional,
>seriously invasive plants is foreseeable and, without
>regulatory improvements, inevitable.
>
>**** THE ACTION *****
>
>Submit written comments on USDA's advance notice of proposed
>rulemaking.
>
>MAIN MESSAGE: USDA/APHIS should substantially revise its
>regulations to set a highly protective and measurable
>standard for the import of plants for planting. This new
>standard should provide two kinds of protection for native
>ecosystems and biodiversity: protection from pests and
>pathogens that such plants can convey and also protection
>from plants for planting that are themselves invasive or
>potentially so.
>
>TIMING: The comment period closes April 11, 2005
>
>DIRECTIONS:
>To submit comments
>Email: < regulations at aphis.usda.gov >
>Be sure to include your name and address in the text, and
>the docket id "03-069-2" in the subject line.
>
>Online:
>< 
>http://docket.epa.gov/edkfed/do/EDKStaffCollectionDetailView?objectId=0b0007d4806608c6  
> >
>
>If above link does not work,
>1. Go to < http://www.epa.gov/feddocket >
>2. Select " View Open APHIS Dockets"
>3. Under "Agency Docket Number" look for "03-069-2" and
>click on the icon under the "Submit Comment" column
>4. Read and accept the "EDOCKET User Agreement"
>5. Fill out form and click "Submit Comments" button
>6. Receive your confirmation and note the "Identifier
>Assigned"
>
>
>By mail (send four copies - an original and three copies)
>to:
>Docket No. 03-069-1
>Regulatory Analysis and Development, PPD,
>APHIS, Station 3C71
>4700 River Road
>Unit 118, Riverdale, MD 20737-1238.
>
>
>************ SUPPORTING MESSAGES ********:
>
>  -- There is ample evidence that APHIS's current regulatory
>system for plants for planting is outmoded, ineffective, and
>unable to keep pace with the annual import of hundreds of
>millions of plants for planting. Nor is it responsive to
>APHIS's explicit responsibility to protect the environment
>under the Plant Protection Act of 2000.
>
>  -- Effective regulation cannot exist without proper
>identification of biological material. APHIS should
>immediately require that shipments of plants for planting
>list their contents using accurate scientific names.
>Improperly labeled shipments should be excluded and those
>responsible should be fined enough to deter further
>violations.
>
>  -- Potentially devastating pests and pathogens have
>breached port-of-entry restriction many times, even in the
>past few years. Also, there is evidence that moving
>inspectors from USDA to the Department of Homeland Security
>has been detrimental. Therefore, the United States cannot
>count on border inspections to prevent harm. A truly high
>level of protection from unintentionally imported pests and
>pathogens could be reached by limiting imports of plants for
>planting to tissue cultured plantlets, certified seeds, or
>plants shipped to secure containment facilities employing
>stringent best management practices. USDA should take this
>approach.
>
>  -- So many imported plants for planting have themselves
>become costly weeds that the nation urgently needs a
>comprehensive system for evaluating their risks before
>import and for excluding those known or likely to harm
>native ecosystems and biodiversity. This will certainly
>require screening for invasiveness for all intentionally
>imported plant species. Species already shipped in
>significant amounts should not be presumed safe and excluded
>from this process. Standards for such a screening program
>should be:  highly protective and measurable; transparent
>and scientifically-based; and subject to frequent public
>review. In the short-term, the process by which plants are
>designated Federal Noxious Weeds should be examined and
>streamlined. Many more species should be added promptly to
>that list -- something APHIS has been contemplating and
>experts have been urging since before the original weed
>legislation was passed in 1974.  For a long-term solution,
>APHIS should immediately begin developing the means to
>exclude from import certain taxa of plants for planting
>until their risks are assessed and approved.
>
>  -- Emergency eradication campaigns typically cost more than
>a million dollars, with Federal, state, and local agencies
>bearing the burden. For example, the campaign to eradicate
>Caulerpa taxifolia in California has cost more than $3.5
>million so far. Stronger emphasis on prevention will save
>taxpayers' money. Steps should also be taken to ensure that
>those who benefit from imports bear the costs when things go
>wrong.
>
>  -- APHIS deserves credit for considering major revisions to
>its general approach and specific regulations on plants for
>planting. We support truly significant changes in both.
>However, we do not want to restrict imports of non-native
>plants unnecessarily nor limit plant use in the United
>States to only native species. Harm to nurseries and other
>businesses should be avoided when possible. However, the
>risks to native species and ecosystems from the current
>regulatory system are unacceptably high.
>
>***** SUPPLEMENTAL INFORMATION ************
>
>Examples of pests and pathogens probably introduced on
>imported horticultural stock: balsam woolly adelgid (Adelges
>piceae), butternut canker (Sirococcus clavigignenti-
>juglandacearum), chestnut blight (Cryphonectria parasitica),
>citrus longhorned beetle (Anoplophora chinensis), dogwood
>anthracnose (Discula destructiva), European viburnum leaf
>beetle (Pyrrhalta viburni), larch casebearer (Coleophora
>laricella), lobate lac scale (Paratachardina lobata lobata),
>sudden oak death (Phytophthora ramorum), white pine blister
>rust (Cronartium ribicola).
>
>Examples of introduced plants that invade and damage natural
>areas: arundo (Arundo donax); Asiatic bittersweet (Celastrus
>orbiculatus); Chinese tallow (Sapium sebiferum); fountain
>grass (Pennisetum sp.); gorse (Ulex europaea); Japanese
>honeysuckle (Lonicera japonica); Japanese and Eurasian
>climbing ferns (Lygodium sp.), multiflora rose (Rosa
>multiflora); purple loosestrife (Lythrum salicaria), Russian
>olive (Elaeagnus angustifolia), tamarisk (4 species of
>Tamarix).
>
>--- Proposed rules are at: Federal Register vol. 69, No.
>237, Friday, 12/10/04,
>< 
>http://docket.epa.gov/edkfed/do/EDKStaffAttachDownloadPDF?objectId=090007d4806807f1  
> >
>
>  -- The notice of the extension of the comments period:
>Federal Register vol. 70, No. 46, Thursday 3/10/05,
>< 
>http://docket.epa.gov/edkfed/do/EDKStaffAttachDownloadPDF?objectId=090007d4806608c7  
> >
>
>--- Comments received already are at:
>< http://www.aphis.usda.gov/ppd/rad/LPOC/ >
>under Docket No. 03-069-1.
>
>--- Brasier, C. 2005. Commentary: preventing invasive
>pathogens: deficiencies in the system. The Plantsman. March,
>pp. 54-57.
>
>--- Doyle, M. 2005. Agriculture inspections fall off.
>Growers fear infestations after Homeland Security took
>USDA's border duty. "Sacramento Bee," March 14. p. D1. On
>the web at:
>< 
>http://www.sacbee.com/content/politics/nation/v-print/story/12561259p-13416312c.html  
> >
>
>--- Lambrecht, B. 2004. Focus on terror weakens fight
>against pests. "St. Louis Post-Dispatch," Sept. 9, p. A1.
>(Availalbe in the archive section:
>< http://www.stltoday.com/help/archives/simplesearch >
>or email Jason Mathers at ssi at ucsusa.org )
>
>--- National Plant Board. 1999, "Safeguarding American Plant Resources"
>(conducted at the request of USDA/APHIS/Plant Protection and
>Quarantine). On the web at:
>< http://www.aphis.usda.gov/ppq/safeguarding/ >
>
>--- Reichard, S.H. and P. White. 2001. Horticulture as a
>pathway of invasive plants introduction in the United
>States. "BioScience," Vol. 51, No. 2, pp. 103-113. Can be
>reached on the web from:
>< http://www.bio.unc.edu/faculty/white/references.htm >
>
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