I'm forwarding this on Carson's behalf, seems his mail did not make it onto the list...
"Subj: OD V 9, Issue 211, Item 10, Fischer's proposal Date: 7/1/2007 To: orchids@orchidguide.com To Jerry Fischer's suggestions on approaches for CITES, there is a lot that needs to be done, but not in the way he sees it, as far as I am concerned. Placing all orchids on Appendix 1 does nothing but make it even more of a mess than it is already - since the CITES officials have applied everything to both wild AND artificial propagated, species and hybrid material already. As noted, "The entire reason CITES was created in the first place was to protect wild populations of living organisms that were threatened by trade." It is time we held the CITES officials to that purpose. There is no justification for even identifying nor keeping track of the number of hybrid plants, except at most as a total quantity. CITES officials have been concerned with primary hybrids and the species involved but they are never going to reintroduce plants arising from hybrid stock even when if they are from primary hybrids. And with the exception of a few species, nearly everything in commerce in the US is either artificially propagated or imported legally with documentation, now. (It was not until the last few years that the CITES officials saw it necessary to provide the importer with copies of the import documents, which meant that the importer could be receiving plants without documentation and never know they were brought in illegally. Likewise, an exporter can have an agent which receives a large quantity of plants with proper documentation, then reships within the country and does not need to document them.) There is absolutely no justification for 95% of the species even being included under Appendix 2, let alone have everything as Appendix 1. CITES needs to first declassify all those where there is no trade going on or where there is no scientifically defined need to protect them in the wild. They have continued to refuse to do this with excuses which are nonsensical. Here in the US few of the orchids in international trade are endemic to this country so what is the justification for having to document them to the degree that Jerry notes is required? It is nothing more than paperwork which is used for nothing other than to fill the bureaucrats files. We have enough problems with salvaging plants now, and why should they be required to be grown on for 2 - 3 years? This could easily limit the number salvaged because of space considerations especially over the period required. And documenting the numbers would be difficult as well, since some will die. It is more important to get them rescued than provide a nursery quality product. When I held my permit for artificially propagated plants, I had to tell the CITES people annually the number of each species I had, how many were added yearly, how many died, how many were sold, etc., for each species AND hybrid. When it appeared that I had more the next year than I should have had by division, they challenged it and literally told me it wasn't possible. These are people that had no real idea about propagation. But most embarrassing for them is that they could not even tell me what a "plant" consisted of. Cypripediums produce stems, then growths for the next year. If I reported the number of plants, one may have one stem, another two, another twenty. If I divided them, instead of 3 "plants" I might have 10. On the other hand, if I used a stem count for the number of "plants" when they went dormant, and I sent or sold plants, the plant may have one, two or more new growths which would count as one "plant" being exported. I asked them to define just what they wanted counted and TO THIS DAY they have never responded with an answer. But what do they do with this data? Absolutely nothing. Now lets get to the actual exporting of the plants. I talked to the head USDA inspector some time ago about this. Why is it that I get my plants inspected for a phytosanitary certificate here in Iowa, naming the plants, numbers, etc. This phyto then goes to the USDA with the CITES permit for signatures, and issue of the Federal phyto. These are returned to me and then the plants are shipped. Now the state official don't know what the plants are, they are only interested in the disease considerations. The feds never see the plants. The head inspector say that the State official are responsible for knowing what the plants are and that they are properly labeled. The state officials say, no are not. The absurdity is that I could have sent out anything - wild collected, artificially propagated, mislabeled, since no one really knew what these plants were, only the locals saw them, and they would not know even IF THEY SAW THEM! My permit was based entirely on documentation that could easily been fraudulent. No one was going to come to my place and double check my figures and any shortages or overages could be readily "explained." CITES in this country is a farce, it no longer has anything to do with its mission. It provides a government agency with work and the more work they can make us do, that they have to review, justifies the time and effort and size of the agency to do it. I only wish that Congress would recognize that this is not the International Treaty but applications to justify there very being. 90% of the "work" done by C&WS, CITES, is wasted on such things as Jerry indicated - thinking of ways to make work for themselves. What would they do with all this information that take hours to compile? Why isn't OMB asking why this amount of paperwork is required, how is it used and does it justify the time required of those requesting the permit? I am surprised that the President hasn't done more in this area, since he has been labeled as one undermining our conservation efforts. I do not agree with Jerry's comments that if we were not allowed to import plants that business and the hobby and industry would dry up. Seed is still available and is not regulated. Hybrid seed form foreign countries would possibly be available, if needed. But we have so much hybridizing and production of quality and variety that business, societies and the hobby would continue. It might even lead to creative hybridizing and even more exciting things coming about, something many of the businesses cannot do now because of financial concerns. We might not get the next "Phragmipedium kovachii" as soon as we would like, but it would get here eventually. I have other comments but they will have to wait. I am sorry that I cannot continue this discussion for a few weeks as I am about to leave on a family vacation and do not now when or if I will have time to dedicate to this. But I can assure you that what is being offered will end up as more bureaucracy and control which will force all but a few out of business. Of course this was the basis for CITES in the first place. Carson E. Whitlow Adel, Iowa" <BR><BR><BR>**************************************<BR> See what's free at http://www.aol.com.</HTML> _______________________________________________ the OrchidGuide Digest (OGD) orchids@orchidguide.com http://orchidguide.com/mailman/listinfo/orchids_orchidguide.com
