[MPWG] IFCAE response to US FWS Ginseng Decision

[etj-list at ifcae.org]

FYI - Copy of IFCAE response to recent FWS ginseng decision.

--------------------------------

August 10, 2005

Peter Thomas, Chief
Division of Management Authority
U.S. Fish & Wildlife Service
4401 N. Fairfax Drive, Room 700
Arlington, VA 22203

RE: Convention Permit Applications for Wild American Ginseng Harvested in 2005

Dear Dr. Thomas,

The Institute for Culture and Ecology has conducted basic and applied 
research on sustainable forest management, including nontimber forest 
products (NTFP), since the mid-1990s.  Scientists with the Institute have 
produced numerous general technical reports and peer review articles on the 
social and policy aspects of NTFPs.  We frequently conduct ethnographic 
research with commercial and noncommercial harvesters, buyers, and their 
communities, and work in close collaboration with Federal agency natural 
scientists and program managers.  Our work includes a national study of 
NTFP management and biodiversity conservation funded by the National 
Commission on Science for Sustainable Forestry.  That project examined NTFP 
management and biodiversity conservation issues throughout the United 
States, including areas in which ginseng is commonly harvested.  The goal 
of our research is to contribute toward a base of scientific knowledge for 
managing NTFPs on a sustainable basis.

We have just learned that the U.S. Fish and Wildlife Service has issued a 
decision to limit the export of ginseng roots to those obtained from 
"plants 10 years of age (4-leafed) or older (i.e., with 10 or more 
bud-scale scars on the rhizome" (decision issued August 3, 2005). We have 
several concerns about this decision:

1)  This decision is likely to have an adverse impact on minorities and 
economically disadvantaged populations and thus is subject to Executive 
Order 12898 on environmental justice.  Has an environmental justice 
analysis been conducted as part of the process leading to this 
decision?  If so, the results of that analysis need to be included in the 
text of the decision. If not, an environmental justice analysis needs to be 
conducted and mitigation measures need to be implemented to address any 
adverse impacts on minorities or economically disadvantaged populations.

2)  To what extent has the U.S. Fish and Wildlife Service met National 
Environmental Policy Act scoping requirements for soliciting input from a 
broad spectrum of stakeholders, including ginseng harvesters and buyers? 
Our research indicates that failure to include NTFP harvesters and buyers 
is likely to result in forest management decisions that are socially 
inequitable, difficult and costly to enforce, and undermine stewardship 
practices.

3)  Is the U.S. Fish and Wildlife and/or other federal agencies examining 
the impacts of other land use practices on ginseng populations (e.g., 
mining, herbicide spraying, logging, wildlife management, 
development)?  Has the agency identified management alternatives that could 
be taken to simultaneously achieve ginseng population conservation goals 
and the sustainability of harvesting cultures, traditions, and economies?

4)  To what extent is the decision in compliance with the Small Business 
Regulatory Fairness Act, including such provisions as informing the Chief 
Counsel for the Small Business Administration on the potential impacts of 
the decision on existing and future small businesses?

We urge that the U.S. Fish and Wildlife rescind the August 3, 2005 decision 
and take the steps to address these four areas of concern.  Please keep us 
informed of the steps that you take and any opportunities to participate in 
the process.


Sincerely,

Eric T. Jones, Ph.D.
Rebecca  J. McLain, Ph.D.
Kathryn A. Lynch, Ph.D.

Institute for Culture and Ecology
P.O Box 6688
Portland, OR 97228-6688
503-331-6681
ifcae at ifcae.org
www.ifcae.org

c.c.
Robert R. Gabel, Chief, Division of Scientific Authority
Kenneth Stansell, Chief of International Affairs
Matthew J. Hogan, Acting Director, U.S. Fish and Wildlife
Marshall P. Jones, Jr., Deputy Director, U.S. Fish and Wildlife
Gale Norton, Secretary of U.S. Department of Interior

Addresses:

Peter Thomas
Chief, Division of Management Authority
U.S. Fish and Wildlife Service, International Affairs
4401 N. Fairfax Drive, Room 700
Arlington, VA 22203

Robert R. Gabel
Chief, Division of Scientific Authority
U.S. Fish and Wildlife Service, International Affairs
4401 N. Fairfax Drive, Room 700
Arlington, VA 22203

Kenneth Stansell, Chief of International Affairs
U.S. Fish and Wildlife Service
1849 C Street, NW
Washington, DC 20242

Matthew J. Hogan, Acting Director, U.S. Fish and Wildlife
U.S. Fish and Wildlife Service
1849 C Street, NW
Washington, DC 20242

Gale Norton, Secretary of U.S. Department of Interior
Department of the Interior
1849 C Street, N.W.
Washington DC 20240
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