Over a few month period of time, I have been conversing with Roddy Gabel, Chief of the 
Division of Scientific Authority, of the USFWS, which governs CITES in the US. He has 
kindly agreed to help flesh out some of the ambiguous natures of CITES policy 
application in the US. A simplified transcript is can be found at:
http://www.nascentorchids.com/cites.html

Hope this clears some things up,
Steve Topletz  
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