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<font size=3>FYI - Copy of IFCAE response to recent FWS ginseng decision.
<br><br>
--------------------------------<br><br>
August 10, 2005<br>
<br>
Peter Thomas, Chief<br>
Division of Management Authority<br>
U.S. Fish & Wildlife Service<br>
4401 N. Fairfax Drive, Room 700<br>
Arlington, VA 22203<br>
<br>
<b>RE: Convention Permit Applications for Wild American Ginseng Harvested
in 2005<br>
</b> <br>
Dear Dr. Thomas,<br>
<br>
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.<br>
<br>
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: <br>
<br>
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.<br><br>
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.<br><br>
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?<br><br>
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?<br>
<br>
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.<br>
<br><br>
Sincerely,<br>
<br>
Eric T. Jones, Ph.D.<br>
Rebecca J. McLain, Ph.D.<br>
Kathryn A. Lynch, Ph.D.<br>
<br>
Institute for Culture and Ecology<br>
P.O Box 6688<br>
Portland, OR 97228-6688<br>
503-331-6681<br>
ifcae@ifcae.org<br>
<a href="http://www.ifcae.org/" eudora="autourl">www.ifcae.org<br>
</a> <br>
c.c.<br>
Robert R. Gabel, Chief, Division of Scientific Authority<br>
Kenneth Stansell, Chief of International Affairs<br>
Matthew J. Hogan, Acting Director, U.S. Fish and Wildlife<br>
Marshall P. Jones, Jr., Deputy Director, U.S. Fish and Wildlife<br>
Gale Norton, Secretary of U.S. Department of Interior<br><br>
<b>Addresses:<br>
</b> <br>
Peter Thomas<br>
Chief, Division of Management Authority<br>
U.S. Fish and Wildlife Service, International Affairs<br>
4401 N. Fairfax Drive, Room 700<br>
Arlington, VA 22203<br>
<br>
Robert R. Gabel<br>
Chief, Division of Scientific Authority<br>
U.S. Fish and Wildlife Service, International Affairs<br>
4401 N. Fairfax Drive, Room 700<br>
Arlington, VA 22203<br>
<br>
Kenneth Stansell, Chief of International Affairs<br>
U.S. Fish and Wildlife Service<br>
1849 C Street, NW<br>
Washington, DC 20242<br>
<br>
Matthew J. Hogan, Acting Director, U.S. Fish and Wildlife<br>
U.S. Fish and Wildlife Service<br>
1849 C Street, NW<br>
Washington, DC 20242<br>
<br>
Gale Norton, Secretary of U.S. Department of Interior<br>
Department of the Interior<br>
1849 C Street, N.W.<br>
Washington DC 20240<br>
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