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> From: Joyce Fingerut
> I have promised to offer an outline of points that can be raised
> petitioning the USDA-APHIS-PPQ for a change in the regulation that
> requires a point-of-origin phyto for seeds entering the US.
> I have had help in this from Tom Stuart and Carlo Balistieri.
> Here is what I propose:
> To begin with, the alphabet soup stands for:
> United States Department of Agriculture - Animal and Plant Health
> Inspection SERVICE- Plant
> Protection and Quarantine. This arm of the government is charged
> with the protection of the nation?s agricultural and environmental
> health and welfare. They are a line of defense against imported
> diseases that could potentially infest our crops and our
> and decimate industries, a worthy purpose by anyone's standards.
> There are problems, however, with how they propose to accomplish
> We need to bring to their attention the fact that enforcement of
> regulations contained in 7CFR PART 319, specifically sections
> THROUGH 319.37-14,
> requiring a point-of-origin phytosanitary certificate for for seed
> entering the United States
> from other countries has unforeseen consequences. We have been
> that we cannot ask
> for an exemption from this regulation to allow small packets of
> enter the US without a phytosanitary certificate and, consequently,
> petition for a change in the regulation itself.
> One petition with several names will not be anywhere near as
> effective as several separate letters. In this case, mass is
> We need to demonstrate that these regulations do, indeed,
> have a much broader impact than they imagined. It will take a
> many letters to persuade them of this. Contact your local garden
> favorite mail order nurseries and regional botanic gardens and
> encourage them to write as well.
> Email is not considered to be correspondence, nor are form letters
> taken seriously. A simple, direct, one-page letter stating a few
> points, clearly and forcefully, will demonstrate your interest in
> matter. Those of you who are heads of organizations or businesses
> and wish to write a longer petition may contact me privately.
> All letters should be addressed to:
> Michael Lidsky, APHIS-PPQ
> 4700 River Road, Unit 141
> Riverdale, MD 20737
> In our letter to the USDA-APHIS-PPQ, we (NARGS) are stating that:
> Enforcement of this regulation will have unintended and negative
> effects to many sectors of the horticultural community:
> -Seed houses will be severely damaged or forced out of business;
> -This is an unreasonable restriction on international trade,
counter to the
> WTO (World Trade Organization) Agreement on Sanitary and
> Certificates that ?Sanitary and phytosanitary measures shall not be
> in a manner which would constitute a disguised restriction on
> -International plant societies and botanic gardens will be
> from sharing seed through their seed exchanges.
> -Private trades between gardening friends will be in violation of
> unless accompanied by a phyto-sanitary certificate.
> -The resulting loss of seed diversity will lead to financial losses
> in the plant industry and a concomitant weakening of plant stocks,
> through inbreeding and perpetual vegetative propagation.
> -The recommendation to consistently enforce the requirement for
> certificates was formulated without a risk assessment; that is, it
> was assumed, without a scientific basis, that even small packets of
> seeds, from ornamental horticultural origins, would pose a risk to
> agriculture and the environment; nowhere has this been proved or
> Above all, treat the recipient of your letter with respect. Assume
> that he has at least as much knowledge and intelligence as you do;
> you are introducing him to your perspective on this question, not
> assailing his credentials. State your case clearly, logically and
> impersonally. Don?t whine. Your personal losses will not make a
> compelling argument; broader losses to sectors of the gardening
> industry and science might.
> I welcome your contributions of further ideas and points that
> might be raised with USDA-APHIS-PPQ either by specific sectors
> of our community (commercial vs amateur societies, for example)
> or by other Alpine-L gardeners.
> The future of the seed exchanges and the diversity in our gardens
> garden centers depends upon the removal of these restrictions.
> Actually, all the future fun of gardening depends on winning!
> Joyce Fingerut
> Stonington, Connecticut
> Zone 6