From prestons@ncatfyv.uark.eduThu Mar 16 22:44:55 1995 Date: Thu, 16 Mar 1995 15:26:21 -0600 (CST) From: Preston Sullivan To: "Sustainable Agric. Network" Subject: APHIS proposal I have read the 40+ pages of the proposed APHIS regs to regulate the interstate movement of nonindigenous organisms and am arlarmed in what I saw. I hope all who are reading this will get their own copy and take a look. Some highlights I saw include time requirements of 30 days lead time for the transport of a listed organism, 120 days lead time for the release of an organism and if our permit is denied, you must wait 12 months to reapply unless the permit is reinstated upon appeal. Duplication of effort: Most states already have quarantine regs in place banning the importation of pest species. Guilt by association: The rational for listing a species for regulation is that it falls in a taxonomic group which contains known pests. Included in the listed groups are: Rhizobium, Bradyrhizobium, and most of the families which contain bio-control insects. Costs: I cannot imagine what all this would cost to implement. Full text of the proposed regs are available from: gopher//hal.aphis.ag.gov.70/11/AI.d/PRNOFC.d The APHIS number to call for more information is: 301-734-8896. I have heard mention of an extension of the comment period but to my knowledge the comments must be in by March 27, 1995.