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Sat Apr 20 05:33:26 CEST 2002

hardy Aroids)" <ARISAEMA-L at NIC.SURFNET.NL> Aroids)" <ARISAEMA-L at NIC.SURFNET.NL>
Sender: "Arisaema Enthusiast Group (AEG) Discussion List (and other=
From: "Carlo A. Balistrieri" <cabalist at GDINET.COM>
Subject: Re: About the proposal for Limitations on Seed distribution
In-Reply-To: <64.1dd24df9.29f2279e at aol.com>
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NOTE TO LIST MEMBERS: This is a longish response to Richard's recent mess=age
incorporating his paragraphs and Tasker's (the ones that start with
"Response". My comments are noted. This is an important issue being close=ly
watched by other plant groups as well. I hope you'll take the time to rea=d
it. Please do not take my comments as personal sniping at Richard. He's d=one
a service by raising the issue on this list. I'm just trying to make sure
the issue is clearly understood (and it is complicated--correct me if I n=eed
to be).

> Subject: About the proposal for Limitations on Seed distribution
> Please read the reply to my letter addressed to Alan Tasker at APHIS..
> I believe that this response puts the matter to bed.. Thank goodness..
> As I read this, there is problem with our seed exchange.  Richard Orr
Monroe, CT

[Carlo A. Balistrieri] Sorry Richard this is NOT the case. But let's be
clear about what we're talking about. The answers that Tasker gave you we=re
very carefully responsive to your exact queries--which confuse the issue =a
little bit.

>I am writing with respect to the proposal of the Invasive Species Counci=l
> to impose severe restrictions on seed and plant shipments within USA an=d
from
> other countries, including Canada.

Response:
The Invasive spp. council has no regulatory authority, they are a
coordination and advisory group, established by an Executive Order signed
by former President Clinton. Therefore they connot propose restrictions o=r
regulations on shipments either within or into the US.

[Carlo A. Balistrieri] Tasker is correct, and Richard's statement is not.
There is no new "severe restriction on seed and plant shipments." The iss=ue
we're talking about is the new APHIS policy to enforce existing regulatio=ns
regarding phytosanitary certificates for seed--which until January did no=t
require a phyto to be imported. This is a change in enforcement, not poli=cy.

>I now understand that this has been put on the backburner, but I wish to
express my concern that this ill-conceived proposal would severely restri=ct
my participation in the seed exchange within members of the Ariseama Seed
Exchange, which is operated by volunteers, and the major collection point=is
in Canada, with contributions coming from as far away as New Zealand, for

Response:
There is nothing to put on a back burner.  APHIS published for public
comment an Action plan regarding the Noxious weed regulatory program.
Unfortunately, much of the criticism of the Action Plan is based on what
appears to be someone's interpretation of the Action Plan, rather than th=e
Action Plan.  The plan is available on the APHIS Weed Program website
www.aphis.usda.gov/ppq/weeds .

[Carlo A. Balistrieri] Again Tasker is correct, Richard's statement is no=t.
Nothing is on the backburner. Seed now REQUIRES a phyto in order to be
legally imported into the United States. Tasker's statement is a bit
confusing. All the criticism I've heard is of the APHIS policy change to
require phytos for seed. (And the issue is broader than weeds. The change
was the result of concern over seed-borne pathogens/disease and noxious
weeds.

>Undoubtedly, this would also have a serious impact upon other seed
producers and nurseries, since they proposal required a Phytosanitary
inspection and report with each and every shipment.

Response:
Import or interstate movement of Federal noxious weeds (or other regulate=d
species) already requires a Federal permit. The recommended changes in th=e
Action Plan do not include any new permit requirements, nor restrict
movement of any plant or seed material not currently regulated.  The rule
changes and policy changes discussed in this plan involve mainly manageme=nt
of the current noxious weed list, not new phytosanitary rules.
Requirements for phytosanitary certificates and inspection for import hav=e
been in place for a long time, and are not changed in this proposal.  Thu=s,
any new enforcement activities regarding imports relate to other APHIS
policy changes, not to this Action Plan.  These changes relate to import,
but not interstate movement.

[Carlo A. Balistrieri] Here Tasker clearly does not understand where you'=re
headed. No one is talking about shipping noxious weeds (and only a rare f=ew
would argue FOR it). The rest is technically true but avoids dealing with
the fact that APHIS has changed the way it handles seed. Before: no phyto
required; NOW: PHYTO REQUIRED. End of story--unless our continued objecti=on
causes them to rethink their change in policy.

[Carlo A. Balistrieri] Please understand that this does not change
interSTATE shipment of seed, or your ability to send seed FROM the US to
another country. As it stands it is only seed coming into the US that nee=ds
the paperwork. The balance of Tasker's response is also confusing. It see=ms
to indicate that further change is anticipated but not finalized. I'm sur=e
that part of it is Tasker's position---he's with noxious weed management.
The change re the seed came out of the conclusions of the "Safeguarding
Report" (also on the web) and not from the Action Plan he keeps referring
to. At least to some extent, the activity will be related, but it's a
separate issue.

Carlo

Carlo A. Balistrieri
Nemorosa Horticulture
Oconomowoc, Wisconsin, USA
Zone 4a-5b
NARGS

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<DIV>NOTE TO LIST MEMBERS: This is a longish ==
response to 
Richard's recent message incorporating his paragraphs and Tasker's (the =
ones 
that start with "Response". My comments are noted. This is an important =
issue 
being closely watched by other plant groups as well. I hope you'll take =
the time 
to read it. Please do not take my comments as personal sniping at =
Richard. He's 
done a service by raising the issue on this list. I'm just trying to =
make sure 
the issue is clearly understood (and it is complicated--correct me if I =
need to 
be).</DIV>
<DIV>&nbsp;</DIV>
<DIV>&nbsp;</DIV>
<DIV>&nbsp;&gt;&nbsp;Subject:= 
About the proposal for Limitations on Seed =
distribution <FONT= 
color=#0000ff>&gt;&nbsp;Please read the reply to my =
letter 
addressed to Alan Tasker at APHIS.. &gt;&nbsp;I believe that this response =
puts the 
matter to bed.. Thank goodness.. &gt;&nbsp;As I read this, there is proble=m =
with our 
seed exchange.&nbsp; Richard Orr&nbsp; Monroe, CT [Carlo A. =
Balistrieri]&nbsp;Sorry 
Richard this is NOT the case. But let's be clear about what we're =
talking about. 
The answers that Tasker gave you were very carefully responsive to your =
exact 
queries--which confuse the issue a little =
bit.</DIV>
<DIV>&nbsp;</DIV>
<DIV>&gt;I am writing with==
respect to the 
proposal of the Invasive Species Council &gt;&nbsp;to impose severe =
restrictions on seed 
and plant shipments within USA and from &gt;&nbsp;other countries, including= 
Canada. Response: The Invasive spp. council has no regulatory= 
authority, they are a coordination and advisory group, established by ==
an 
Executive Order signed by former President Clinton. Therefore they =
connot 
propose restrictions or regulations on shipments either within or =
into the 
US. [Carlo A. =
Balistrieri]&nbsp;Tasker is 
correct,&nbsp;and&nbsp;Richard's statement is not. There is no new =
"severe 
restriction on seed and plant shipments." The issue we're talking about =
is the 
new APHIS policy to enforce existing regulations regarding phytosanitary ==

certificates for seed--which until January did not require a phyto to be ==

imported. This is a change in enforcement, not 
policy.</DIV>
<DIV>&nbsp;</DIV>
<DIV>&gt;I now understand =that =
this has been 
put on the backburner, but I wish to express my concern that this 
ill-conceived proposal would severely restrict my participation in =
the seed 
exchange within members of the Ariseama Seed Exchange, which is =
operated by 
volunteers, and the major collection point is in Canada, with =
contributions 
coming from as far away as New Zealand, for Response: There is ==
nothing 
to put on a back burner.&nbsp; APHIS published for public comment an =
Action 
plan regarding the Noxious weed regulatory program. Unfortunately, =
much of 
the criticism of the Action Plan is based on what appears to be =
someone's 
interpretation of the Action Plan, rather than the Action Plan.&nbsp; ==
The 
plan is available on the APHIS Weed Program 
website www.aphis.usda.gov/ppq/weeds . [Carlo A. Balistrieri]&nbsp;Again Tasker is ==
correct, 
Richard's statement is not. Nothing is on the backburner.&nbsp;Seed now =
REQUIRES 
a phyto in order to be legally imported into the United&nbsp;States. =
Tasker's 
statement is a bit confusing. All the criticism I've heard is of the =
APHIS 
policy change to require phytos for seed. (And the issue is broader than ==
weeds. 
The change was&nbsp;the result of concern&nbsp;over seed-borne =
pathogens/disease 
and noxious weeds.&nbsp;</DIV></FON=T>
<DIV> &gt;Undoubtedl=y, =
this would also 
have a serious impact upon other seed producers and nurseries, since =
they 
proposal required a Phytosanitary inspection and report with each and =
every 
shipment. Response: Import or interstate movement of Federal =
noxious 
weeds (or other regulated species) already requires a Federal permit. ==
The 
recommended changes in the Action Plan do not include any new permit= 
requirements, nor restrict movement of any plant or seed material not ==

currently regulated.&nbsp; The rule changes and policy changes =
discussed in 
this plan involve mainly management of the current noxious weed list, ==
not new 
phytosanitary rules. Requirements for phytosanitary certificates and= 
inspection for import have been in place for a long time, and are not ==
changed 
in this proposal.&nbsp; Thus, any new enforcement activities =
regarding 
imports relate to other APHIS policy changes, not to this Action =
Plan.&nbsp; 
These changes relate to import, but not interstate =
movement.&nbsp; </DIV>
<DIV>[Carlo 
A. Balistrieri]&nbsp;Here Tasker clearly does not understand where =
you're 
headed. No one is talking about shipping noxious weeds (and only a rare =
few 
would argue FOR it). The rest is technically true but avoids dealing =
with the 
fact that APHIS has changed the way it handles seed. Before: no phyto =
required; 
NOW: PHYTO REQUIRED. End of story--unless our continued objection causes ==
them to 
rethink their change in policy.</DIV>
<DIV>&nbsp;</DIV>
<DIV>=<SPAN =

class=499121203-20042002>[Carlo A. Balistrieri]&nbsp;Please understan=d =
that this 
does not change interSTATE shipment of seed, or your ability to send =
seed FROM 
the US to another country. As it stands it is only seed coming into the =
US that 
needs the paperwork. The balance of Tasker's response is also confusing. ==
It 
seems to indicate that further change is anticipated but not finalized. =
I'm sure 
that part of it is Tasker's position---he's with noxious weed =
management. The 
change re the seed came out of the conclusions of the "Safeguarding =
Report" 
(also on the web) and not from the Action Plan he keeps referring to. At ==
least 
to some extent, the activity will be related, but it's a separate 
issue.</DIV>
<DIV>&nbsp;</DIV>
<DIV>Carlo</DIV>
<DIV>&nbsp;</DIV>
<DIV>
Carlo A. Balistrieri Nemorosa =
Horticulture Oconomowoc, 
Wisconsin, USA Zone 4a-5b NARGS 
</DIV></BODY></HTML>

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