Re: Proposed USDA rule on m

jhaskett@asrr.arsusda.gov
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