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
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
Full text of the proposed regs are available from:
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.