Recommendations on Federal Regulations Governing Imports of Living Plants (Q-37)

To: Continental Dialogue on Non-native Forest Insects and Diseases

From: Workgroup #1 – Prevent Introduction of New Pests and Diseases

  • Faith Campbell, The Nature Conservancy (chair)
  • Jerry Carlson, NY Dept. of Environmental Conservation
  • Emily Davis, International Paper, Forest Resources
  • Bob Fledderman, MeadWestvaco
  • Deborah McCullough, Michigan State University
  • Anand Persad, Davey Tree Company
  • Gray Haun, TN Department of Agriculture (Resource)
  • Craig Regglebrugge, ANLA (ex-officio)
  • Marc Teffeau, ANLA (ex-officio)

Subject: Consensus Recommendations on Federal Regulations Governing Imports of Living Plants (Q-37)

In January 2007, the Continental Dialogue adopted a Vision which included the following goal:

  • Improve federal, state, and provincial programs so as to prevent new non-native forest insects and diseases from arriving on the continent by the year 2015.

The Problem

Importation of live plants is a major pathway by which forest pests are introduced. Examples of damaging forest pests introduced via this pathway include Chestnut blight, white pine blister rust, Port-Orford-cedar root disease, Phytophthora ramorum/Sudden Oak Death, and the wiliwili gall wasp. It is therefore important to curtail introductions via this pathway.

Why it is Important to Address the Problem

At its January 2007 meeting, the Dialogue specifically identified the live plant importation pathway as the highest priority because of its significance and the opportunity to engage in on-going governmental efforts to improve management of this pathway. Workgroup #1 was requested to develop a consensus position on the relevant rulemaking. The Workgroup members believed that Dialogue engagement will not only improve the quality of the final regulation; it will also enhance recognition of the Dialogue as an important stakeholder in pest prevention.

Outline of Potential Solutions and Strategies

The USDA Animal and Plant Health Inspection Service (APHIS) is responsible for preventing introductions of plant pests through various pathways. APHIS exercises its jurisdiction over one such pathway – plant imports – through a section of the agency’s regulations that governs the importation of nursery plants, roots, bulbs, and seeds. This section is called the “Q-37” regulations. APHIS has begun to revise the Q-37 regulations, thus providing opportunities for input by Dialogue participants.

Therefore, as requested by the Dialogue at its January 2007 meeting, Workgroup #1 developed a consensus set of recommendations on the Q-37 rulemaking (see below) which reflects the common goals of the Dialogue.

What You Can Do

Dialogue participants are encouraged to convey the consensus position to policymakers and other stakeholders, so as to advance discussion of the live plant pathway and ways to curtail introductions via that pathway. Efforts to propagate the consensus position are likely to have the greatest impact if they are carried out by ad hoc coalitions of stakeholder organizations. For example, six Dialogue participants representing conservation, nursery, and forest products entities met with USDA APHIS leadership in October 2007 to present the consensus position and discuss next steps. Other meetings with USDA officials are anticipated.

Other venues for disseminating the consensus document and discussion of the reasoning behind its recommendations include:

  • Meetings with key members of Congress, particularly those serving on the Agriculture or Agriculture Appropriations subcommittees
  • Meetings with stakeholders not already engaged in the Dialogue
  • Outreach tools targeting organizations’ own members, such as websites, newsletters, and presentations to regular meetings
  • Media outlets which cover conservation, forestry, or horticultural issues

The Dialogue’s Workgroup #1 welcomes your engagement in its efforts and help in implementing programs aimed at curtailing introductions of additional non-native forest pests.

Consensus Recommendations