J. L. HUDSON, SEEDSMAN, BOX 337, LA HONDA, CALIFORNIA 94020-0337 USA

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HELP STOP THE 'WHITE LIST'

The government is proposing new, sweeping and highly restrictive policies regarding the importation, cultivation and movement of all living species, allegedly to prevent 'invasive species'. In 1999 the National Invasive Species Council (NISC) was formed. At the inaugural meeting of the NlSC, co-chair Bruce Babbitt called for use of a 'white list', where exotic species are presumed guilty until proven innocent. A list of approved, tested 'noninvasive' species would be established, and importation, cultivation and movement of all species not on the approved list would be prohibited.

This proposal will ban over 99% of the world's species of plants, animals and micro-organisms. Anything not approved will have to be exterminated, so major herbicide manufacturers are backing this proposal. Under this new system, expensive safety testing will be required for all new plants before they are approved for possession and propagation. Thus, only major corporations will be able to afford to introduce new plants into cultivation. We already have adequate weed prevention laws - it makes no sense to ban virtually the entire plant kingdom "just in case". This is equivalent to the government announcing that only 'pre-approved' books, magazine articles, etc. would be allowed, and all new writings would have to pass through government censors before publication. The world's biological diversity has been likened to a great library and now government book-burners will be in charge.

The bad news is that the NISC's Management Plan, published October 2000, is worse than we had imagined. It covers all species of life. Everything from butterflies to fish to flowers to trees. Even native species are called in invaders on government websites, and the NISC specifically states that they intend to "apply similar principles... to species currently in the trade." Clearly, not just new imports are at risk. Even botanic gardens aren't exempt.

The good news is that our anti-white-list campaign is having an effect. Word in Washington DC is that there is lots of dissatisfaction with the NISC and its Management Plan. Due to public outcry against the 'white list', the NISC has renamed the proposal 'comprehensive screening' or 'risk assessment', so 'that they can now claim that they have no plans to implement a 'white list'. The NISC has been spreading misinformation about their plans through a highly deceptive letter which obscures the facts of the issue, and last summer a rumor was spread claiming the white list was an 'internet hoax'. While the NISC claims they are only concerned with "invaders", their management plan clearly states that screening and management will apply to all species of living things.

Use the internet, post to garden groups, herbal groups. Don't let anyone tell you this is a hoax, or that there is no white list proposal. Tell them to read the government sites for themselves. Also write to local newspapers, and garden writers, and talk to local nurseries, pet stores, aquarium stores, butterfly groups, etc. Most importantly, write your congressman and send a copy to the NISC. Don't just write the NISC, as they will ignore your objections and send you a deceptive reply. Your representatives are the ones to write. Let's keep up the pressure!

National Invasive Species Council
U. S. Department of the Interior
Office of the Secretary (OS/SIO/NISC)
1849 Charter Street NW
Washington, DC 20240

invasivespecies@ios.doi.gov

Good points to make in letters are: we already have adequate weed laws; that 'invasiveness' is impossible to predict except for well-known agricultural weeds; that in the absence of proven risk-assessment procedures the implementation of any form of 'clean list' or 'comprehensive screening' is completely inappropriate; any pre-screening of imports will hamstring many areas of scientific research and place an expensive hurdle in front of biodiversity conservation efforts; that it will increase our dependence on foreign supplies of plant-based raw materials and decrease our competitiveness in world markets; that in a time of 're-inventing government' it is reckless and irresponsible to expand an antiquated, cumbersome and inefficient bureaucracy at a time when we should be moving forward to a streamlined and efficient future. More ideas for letters can be found at the website.

Be sure to state that you oppose any form of 'white list', 'clean list', 'gray list', 'pre-screening' or 'risk assessment' procedures.

Remember, a physical letter in an envelope carries as much weight as 100 phone calls or e-mails, so hit that print button and lick that stamp!

Check our links page to the No Whitelist website!

The White List is not a hoax.

Due to recent public outcry against the proposed new "white list" or "clean list" regulations which will require that all species of plants and animals will have to be tested for "invasiveness" and "safety" before they are allowed to be imported, possessed, sold or distributed, the government agencies involved have begun a deceptive campaign to deflect criticism and blunt objections. Form letters from the USDA and the National Invasive Species Council (NISC) claim that "there is no proposed legislation before congress based on a white-list." All this means is that the agencies involved have changed the name of the proposal—it is now being called "risk assessment" and "comprehensive screening," and that no legislation is currently before congress. Several of the agencies involved claim that no new legislation will be required to implement a clean list, that current regulatory powers already allow this. Anyone with any doubts about the white list should read the government publication "Harmful Non-Indigenous Species in the United States" by the U.S. Congress, Office of Technology Assessment, and check the entries under "clean" and "dirty" lists in the index. These detail the scope and intent of clean list regulations, and the history of past attempts to impose them on the American people.

Let the NISC and USDA speak for themselves:

"A key tool for prevention is risk analysis and screening system for evaluating first-time intentional introductions of non-native species before entry is allowed and for realistically applying similar principles, or other management options, to species currently in trade."—NISC (Note that this will necessitate a list of approved species—a "clean list", and that "species currently in trade" covers plants that are already here and being cultivated—they will be "tested" and either approved or rejected and prohibited.)

"The Council will undertake development of a comprehensive screening system for evaluating intentionally introduced non-native species. The purpose of the system will be to assure, upon full implementation, that non-native species which have not previously been imported will not be intentionally introduced in the United States unless the risk of establishment and harm has been evaluated and determined to be acceptable. The system should be fully implemented by January 1, 2007."—NISC

The comprehensive screening system will be applied to "Introduction of non-native propagative plants or seeds for any purpose (e.g. horticulture or botanical gardens) within the continental United States."—NISC (Note that even botanical gardens are not exempt.)

"These projects are intended... to promote acceptance by the private sector of future entry requirements."—NISC (note that pre-screening is just the beginning).

These quotes are directly from the NISC website, under the "National Management Plan":

www.invasivespecies.gov/council/nisc/actionb.html

Also note, from a letter from the Deputy Secretary of Agriculture: Invasive species which will be excluded are those which may cause "economic or environmental harm or harm to human health." It would appear that many medicinal plants used in indigenous herbalism could be excluded under the assumption that they might "harm human health". Some white list promoters have already proposed shutting down seed exchanges and banning medicinal plants that they deem are unsafe (see Mack, R. N., and W. M. Lonsdale. 2001. Humans as global plant dispersers: Getting more than we bargained for. BioScience 51:95-102).

Lest this all sound too far-fetched, note that clean list laws are already in place in South Africa, Australia and New Zealand. In South Africa, the list of "invader species" includes many native South African trees and shrubs, and laws are in place which may fine landowners for not destroying them, and which prevent the issuance of building permits or the sale of the land until the plants are destroyed. In Australia, it is called "plant profiling" (an interesting term), and the introduction of a single new species, a sterile cultivar of vetiver grass (used for erosion control and in perfumery, and which has been grown around the world for centuries, and in all this time has never been known to become weedy), required 7 years of testing and evaluation before release was approved. In New Zealand, imports have been almost completely shut down, as it costs NZ$30,000.00 to have a single importation approved.