OFA Bulletin September/October 2012 : Page 3

September/October 2012 • Number 935 might pose to U.S. agriculture and the environment. Anyone can petition for such an analysis. Once the analysis is completed, APHIS will either remove the taxon from the NAPPRA list and allow its importation, allow import subject to certain requirements, or continue to prohibit it. The first proposed NAPPRA list was published for public comment late in 2011, and included 41 taxa of plants that may be quarantine pests themselves (invasive), and 107 taxa that could be hosts of 13 quarantine pests and are therefore suggested for addition to the list. Generally, plants were added to the list based in part on a low volume of trade history. For plants that might be hosts of quarantine pests, the first proposal generally addressed pests that are already restricted through federal orders (Citrus longhorned beetle, Asian longhorned beetle, Red palm weevil, Tomato severe leaf curl virus, and others). On the “invasive plants” side, the inclusion of an Alstromeria species was one which generated considerable adverse comment, but generally the invasives proposed were plants from parts of the world not historically trade partners of the United States. On November 25, SAF and ANLA provided joint formal comments on the NAPPRA list, pointing out several needed modifications. “It is essential that the proposed prohibitions not simply list ... cut flowers and greenery as potential hosts of pests unless there is reason to do so, and only after consideration of existing trade patterns,” the comments noted. Generally, species are to be added to the list based in part on a low volume of trade history. Another area of concern highlighted in the joint comments is the need to implement revisions to the current permit system allowing importation of plants in limited quantities for research, development, and new variety introduction. We also urged harmonization of the U.S.-Canadian NAPPRA lists, given the generally open, high volume of trade between the two countries. The ANLA/SAF comments also noted that “some interest groups may see the NAPPRA category as a way to ‘lock down’ large volumes of plant material and restrict entry just on the basis of a single pest” and urged that APHIS be prepared to act to remove a taxon from NAPPRA if presented with a mitigation proposal that addresses the quarantine pest for which the plant was listed in the first place, rather than requiring a full (and time-consuming) Pest Risk Analysis. The First NAPPRA List which usually identify critical control points within a production system are one important way of avoiding or controlling problems at the production point, and are likely to become more important as international trade continues to increase. “We believe that restriction of horticulturally significant plant taxa under NAPPRA without concurrent attention to the controlled import permit and integrated measures regulatory strategies will discourage compliant trade and encourage unauthorized importation. It may also subject APHIS to challenges under international trade agreements,” our comments noted. The Q-37 regulation-revision process is ongoing, and further revisions to the existing regulations are expected, although perhaps not in the very near future. After all, few regulations move forward during presidential election years. As of this writing, APHIS has not yet finished its review and modification of its first-proposed NAPPRA list. However, publication of a final list is expected shortly and likely with more additions. We will continue to publicize changes to the list as widely and early as we can, once they are made available. It will be very important for industry members to weigh in with comments on specific plant species – no one group, not APHIS, not ANLA, not SAF – can know which plants might be of current interest to our industry. Stay tuned and in-touch – the industry is important to U.S. agriculture and to our agricultural economy. We represent a vibrant and economically significant part of American agriculture, and our voice is a strong one. We have more than a century of history of working toward the goal of safeguarding the industry and America’s plant resources from the ravages of introduced pests, while at the same time enabling trade and access to new and useful plant varieties. Our voices – and your voices – must continue to be heard. Lin Schmale Senior Director – Government Relations Society of American Florists 1601 Duke Street Alexandria, VA 22314 (703) 838-5232 Lschmale@safnow.org Craig Regelbrugge Vice President – Government Relations American Nursery & Landscape Association 1200 G Street NW, Suite 800 Washington, DC 20005 (202) 434-8685 Cregelbrugge@anla.org What’s Next? Finally, we urged that APHIS move to establish a stronger regulatory framework for implementing the kinds of programs widely referred to as “systems approaches.” Those programs, “Systems Approach” Production as a New and Important Tool OF A Bulletin 3

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