Re: APHIS proposed changes to nursery stock regulations

I am sorry that this is not well organized, due to time constraints and my 
poor writing organization this will have to do.  It would not hurt to extend the 
deadline for input for another 6 months to a year as this issue is just 
starting be noticed by those that potentially will be effected.

To be up front,  I am biased, being in the horticulture field.

I realize that there is strong pressure from different interest groups to 
develop some type of exclusionary protocol in regards to exotic pest species, but 
feel that what is under consideration would not have any positive effect in 
regards to the issues raised by those promoting such legislation.
  
The purpose is to exclude problem animals and plants, but its real effect is 
the crippling of the Horticultural industries development of new ornamentals 
and research both by privet and public institutions on plants, effecting both 
relationship and taxonomy studies and the exploration of beneficial chemical 
agents from plants.  The drastic solution of exclusion is a greater economic 
concern than the importation of any new pest plant that might at this time be 
introduced.

If one looks at the current lists of plants that are considered noxious 
pests,  both federally and from each state, one sees that very few of those plants 
have come from plants that have their origins from the ormentlal plant 
industries (and the ones that have were introduced well over 150 years ago and were 
know to be pests early one, one just has to read any old flora studies to see 
the notes about each of those. Example "Illustrated Flora of the Northern 
United States and Canada"by Britton and Brown 1897. Those plants listed now as 
pests or potential pests are already listed as introduced into our flora - if we 
have such a crises of invasive plant  species then why is there so few new 
species listed). - Any blanket exclusionary protocol would have the greatest 
effect on the Horticulture and research sectors.  Those plants that  have found 
there way to the USA and are truly pest species are mostly here do to agriculture 
and as incidental waifs in the transportation industry(ships for the most 
part). 

The problem that I see, is that we are closing the door after the fact and no 
positive effect will be realized at this time.  Those species or plants that 
are weedy have already made there presence know on our soils, and any new 
plant imported because of its ornamental appeal would not likely become a pest. 

 Its not hard to identify which species are likely to become pests, those 
that are dominate in there native habitats are the best canadates for spreading 
when introduced into new locations.  They have become dominate because they are 
able to spread by way of prolific production of seeds or vegativly, and are 
opportunistic growers. For the most part any of these species that have any 
ornamental value have already been introduced into the USA or Europe already.  
There are many countries that have developed lists of pest plants, and we would 
be better off learning from those countries what is a problem than spending 
lots of money to intercept 99.90 percent of the plant species that are benign in 
regards to the invasive issue. The current laws are sufficient if  enforced.
  

The use of a blanket exclusionary protocol or a"white list" serves no real 
purpose, it can not change what has already happened and will not in any  real 
way exclude problem plants. Because the only effect it will have is the 
exclusion of rare horticulture varieties not already in this country and  those  
species that have a limited geographical area because they  grow in specialized 
habits and are not abundant or aggressive. and have not yet been introduced.

The implementation of such a law would be costly both in human resources and 
adversely effect the movement of both people and goods from and to the USA 
from other countries.

Currently those wishing to ship seeds and plants to the US know already what 
they can not ship, and those shipments are easily checked for compliance, but 
the use of a clean list would involve the listing of thousands of species that 
would need to be checked against any plant material shipped, what now takes 
only a few minutes to inspect would then take much more time and resources to 
accomplish and be hardship on those wishing to export to the US because they 
would have to go threw long lists of plants that are acceptable and changing as 
new additions are made.

What should occur to address this issue is the development of better lists of 
pest species or potential pests species.  This can be accomplished in a 
number of ways: the integration of lists from other countries as to what is 
invasive. The study and listing of those plants that are native to other parts of the 
world that are aggressive spreaders in there native environments and as such 
are more likely to be problems in similar parts of the USA.. Funding research 
could be accomplished by an import tax on Horticulture products from other 
countries into this one.  

The cost would be much less than any long term enforcement of a "White List" 
and I belive much more effective too.


Paul Henjum
Specialty Perennials
481 Reflection Road
Apple Valley, MN 55124
Hardyplants.com

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