Hi Jerry.

Regarding your two "Revolutionary CITES proposals for nursery certification":

Your Proposal #1. I'm not going to comment, not because I have no
opinions, but because I'd rather focus on your

Your Proposal #2. "Certify nurseries that are truly growing, or buying
for resale orchids that are artificially propagated."

This provision already exists under CITES. Go to the CITES homepage at:

http://www.cites.org/

and type "Registered nurseries" into their search engine. I got 107 hits.

The key document is "Conf. 9.19 (Rev. CoP13) Guidelines for the registration
of nurseries exporting artificially propagated specimens of Appendix-I
species", which is at:

http://www.cites.org/eng/res/all/09/E09-19R13.pdf

This document says you can already do exactly what your Proposal 2
suggests, at least for Appendix 1 plants.

A list of registered nurseries is provided at:

http://www.cites.org/common/reg/nu/e-nu-beg.shtml

When last updated, there were 101 CITES-registered nurseries, the
majority being in India. I see that the Moreno's Colomborquideas
nursery in Colombia is CITES registered (Number P-CO-1001). The number
of registered nurseries in the USA is zero. I strongly suspect the
reason for this astonishing low number can be found in the 3rd
paragraph on the right-side column of the 1st page of the summary
document on:

http://www.cites.org/eng/cop/09/doc/E9-Doc-30-32.pdf

which says "It may therefore very well be that the Management
Authority of a country of origin does not wish to introduce such a
facilitation."

Yes, CITES gave the US Management Authority the right to refuse
registration of US nurseries. Jerry, I think you are proposing to
address the wrong people. Instead of petitioning CITES in Geneva, you
should talk to your local representatives (ie, in the USA) about
registering your nursery under the existing CITES provisions.

Good luck.

Peter O'Byrne
Still under a rock in Singapore

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