Subject: Re: Proposed USDA rule on m

From: Patrick Madden <[email-masked]>
Date: Wed, 8 Mar 1995 16:17:43 -0800

I totally concur that exotic species imported for biological control must 
be quaranteened very carefully to prevent disastrous release of species 
that do unanticipated harm.  This is standard operational procedure for all
professionals working in this very important field of biological control, and
it should be required of all.  This is not an unreasonable restraint on 
non-chemical methods.  It is just good biology.  It also protects the 
biological control field from becoming a "loose cannon," doing more harm than
good and discrediting the superb work done in the past and (despite savagely
reduce budgets) is going forward in a few locations.  My only hope is that
a major increase in long-term funding be provided to support this kind of
work, including the taxonomy and systematics essential to proper identification
of both beneficial and pest species, as well as supporting explorations for
exotics and expediting responsible quaranteening.  Most of the funds in recent
years have gone for other approaches, and biological control has suffered.

Patrick Madden
World Sustainable Agriculture Association

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From: Kathy Brunetti <[email-masked]>
Date: Thu, 9 Mar 1995 08:40:28 -0800

>I have been a bit confused by this discussion.  Doesn't APHIS already
>regulate the movement of these organisms?  How exactly does this
>regulation differ from what is presently on the books.  I remember
>talking to someone at the Phillip Alampi Beneficial Insect Rearing Lab in
>New Jersey (which is either a State or Federal Lab, or both?) a couple
>years ago about all the quarantines, research and tight controls that they
>had to go through before they could import a foreign species such as a
>parasitic wasp for potential use as a biocontrol--to prevent (or at least
>make it less likely) that it
>would become another gypsy moth or chesnut blight, etc. problem.  I agree
>that we need to be cautious in this area, but it seems that USDA has
>already been addressing this with present regulations.  Maybe I missed a
>past posting (I admit that I don't ready everything that comes through),
>but has someone printed the text of the regulation and/or an explanation
>of why USDA finds it necessary, and how it differs from present regs.
>

According to the USDA Background statement: "The scope of the [existing]
plant pest regulations is limited to the movement of known plant pests; the
movement of nonindigenous organisms not known to present a plant pest risk,
as well as the release of such organisms into the environment are not
addressed...we believe that APHIS must supplement its current regulations
to prevent or minimize the potential problems presented by the introduciotn
of nonindiigenous organsm whose plant pest status is unknown."

At the March 7 hearng in Sacramento, several people testified that, since
these rules are to prevent problems with plant pests, it seems unclear why
the rule applies to the use of commercially available beneficial organisms,
commercially available compost and  USEPA-registered microbial pesticides.

Kathy Brunetti, Agriculture Program Supervisor
Department of Pesticide Regulation  1020 N Street Room 161  Sacramento CA 95814
voice (916) 324-4100  FAX (916) 324-4088  [email-masked]

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From: "Michael J. Ghia" <[email-masked]>
Date: Wed, 8 Mar 1995 20:33:06 -0500 (EST)

Mike UVM

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From: [email-masked]
Date: Thu, 9 Mar 1995 15:11:43 -0500 (EST)

On Wed, 8 Mar 1995, Sal Schettino wrote:

> On 8 Mar 1995, Mac Horton wrote:
> 
> >         Reply to:   RE>>Proposed USDA rule on movement of organisms.
> > 
> > alien organisms, such as chestnut blight, malaria, any myiasis, african bees,
> >  gypsy moths, imported fire ants, european starlings, english sparrows,
> > domestic pigeons, giant snails, tiger mosquitos, the mongoose into the
> > carribean islands, rabbits  or the cane toad into Australia, etc., etc., to
> > have an inkling why this kind of reg is  considered.  History is replete with
> > all sorts of horror tales about the consequences of the unthinking or poorly
> > researched movement of organisms around the globe.
> What instectory brings in fire ants for sale .  Who sells malaria.  Who 
> is ordering A. bees or giant snails.I think the movements of organisms in 
> the U.S. has been ok and imposeing a big tax on those that are doing it 
> is uncalled for.
> Did the people that raise benificials insects sell giant snails or tiger 
> mosquitos or any of the above to us organic farmers.  I don't think so.  
> I have not ordered any fire ants lately. > 
> I feel the people that are doing the releaseing seem to know what they 
> are selling.  the folks I buy my benificials from have years of 
> experience.  I am one of the ones that know the lest and worry the most.  
> I don't understand why the new rules are being made .  I feel the 
> insectaries 
> are run by responsable people.  They don't just send any old bug out for 
> sale . They 
> kind of know what they are doing.  I think this new law will let you send 
> fire ants and most the stuff you mention and not beneficials.It seems to we 
> from what I have read they are calling 
> benificial insects, pests where as you are calling pests pests.  no one is 
> selling pests that I know of.  Do you as a Profesor in the Entomology 
> Dept know of any benificial insect Sold in the U.S.A. to help us farmers  
> that has 
> turned harmful. So harmful that we have to 
> burden the people that are trying to help us with big permit fees.  .
> I talking about known helpful life .  Every time I order some living 
> helpful organizem I get a pice of paper with it telling me usually its 
> life cycle how it may help me and a little about the benificial.  You 
> can't blame these guys for all those bad things your talking about.They are 
> selling and 
> raising know benificials. Da not someting harmful but someting good. If 
> something is harmful yeah I say ok this is harmful 
> you cannot release or you have to get a permit    but I can't 
> understand if something is 
> helpful why people have to pay so much in permits for helpful things.  
> It will just make it very very hard to get something good and we will 
> have to use chemical poison instead.  A lot of us would like to get away 
> from  using pestisides. 
> 
I am strongly in favor of biological pest control, however, I have
to mention that some creatures that were introduced (i.e. carp, and
I think kudzu) were considered "beneficial" at the time. "Beneficial
is a relative not an absolute term, to whom, when, and in what context
need to be determined. Part of the problem is that we don't have
very good ways of determining *in advance* what the effect of an
introduction of a new species is going to be. We don't know what
combination of charactersitics in the environment and the introduced
species leads some species to "break out" and become problems while
most simply perish. This was the primary argument against the
release of genetically engineered organisms into the environment, i.e.
that we had no good way to predict what would happen. 

Now at the moment we have a body of evidence that suggests that
certain repeated introductions are not harmfull, i.e. in the 
sense of something getting out of control. This does not prove
that further introductions in the same areas will be harmless or
that the introduction of the same species in other locations
will be harmless either. So we are left with the problem that
actually trying to discriminate between safe and potentially
dangerous introductions before hand is so onoriously expensive
as to make the use of beneficial organisms impossible in many
instances, while not making such a determination includes the
risk of severe long-term damage. 

I tend to come down on the side of:

*Grandfathering in introductions that have happened before, i.e.
reintroducing species A at location B where a has been released 
before. 

*Setting some fairly lenient standards for introductions of 
organisms that have been safely introduced in many other areas
over long time periods (BT, Rhizobium, iquneumid(sp?) wasps). 

*Closely scrutinizing introductions of a new (previously 
untried) organism into a new environment.

*More research into the ecology of introductions to try to
develop a more sound predictive methodology to screen out
undesirable introductions.

Jonathan Haskett