A team of us in the USA need 30 seconds of your time to help protect
bees worldwide from the "next varroa", whatever that might turn out
to be.

Please send an e-mail before Nov 18, to:

regulations@...

with the subject:

Docket No. 98-109-1

Please ask them to:

Extend the comment period to Jan 31, 2003

Please include your name and snail-mail postal address (they require
it).

That's it.
You need do nothing more.

You need not even read further, unless you are either interested, or
not convinced that this is worth 30 seconds of your time.

If you were really nice, you could forward this to your local
beekeeper group's mailing list to insure that beekeepers are
alerted to a request for comments. We all know how much
beekeepers like to express their opinions, don't we? :)

Anyone can do this. One need NOT be a US citizen to express an
opinion on this issue to the US Government and be recognized as
a valid contributor to the process. (Of course, US citizens are
certainly encouraged to send a message to their own government.)

Why take 30 seconds of your day to do this? Because this may be
the first you have even heard of this, and you need to understand
this, and be able to express your opinion.

A very serious precedent is being set that "lowers the bar" on
pest and disease control in "World Trade", and thus will have
impact on other countries, not just the USA. (It also certainly
has impact on more than bees.)

Regardless of your view of "World Trade" as a "good" or "bad"
idea, you very likely will agree that no one needs more diseases
or pests killing their beehives.

What's happening? Bees from overseas are being considered
as "imports" by the USDA Animal and Plant Health Inspection
Service (APHIS), and they are being arm-twisted into agreeing
that not even random port-of-entry inspections, tests, and
record-keeping are required for such shipments.

But this is NOT about one country exporting bees to another!!!!
And this is NOT about "trade", "protectionism", or anything else.

This is ONLY about disease control.

This is about the right of a country to take reasonable steps to
verify that bees (and other live animals) are free of diseases
and pests before they get "into the ecosystem".

Precedents like this one could result in YOUR country being
forced into this approach as the "accepted norm", and being
revented from taking reasonable steps to protect the spread
of pests and diseases.

That's the way "World Trade" seems to work - the lowest standards
often become the worldwide standards.

You may not care about this issue at all, but we still need your
help so that SOMEONE has the time to slog through the pile of
paperwork and explain it to those who do care.

In August, the USDA Animal and Plant Health Inspection Service
(APHIS) announced a plan to allow imports of honey bees in the
form of queens and packages.

But there are NO inspections in the plan!
No testing or monitoring, either.
Not even "statistical samples" taken.
Nothing.

The deadline for "comments" is Nov 18th, 2002 unless extended by
public demand. An extension is needed because it became clear in a
public hearing that:

a) Only a handful of beekeepers are aware of this

b) Those that are aware of it do not yet understand it fully

c) Even APHIS clearly does not understand the implications

d) Some of the citations and references they offer as "science"
are not even published papers, and have not been reviewed by
anyone outside APHIS.

...and some time is needed to gather some facts, and educate
APHIS about just how many diseases and pests plague us now,
and how many more could come here unless inspections are
at least an optional part of the process.

This is a very strange proposal from an agency with "Inspection" in
its name.

Don't blame APHIS - they are clearly being pressured by the
current "administration".

The biggest problem is that the proposals are complex, and there
appear to be some assumptions made by APHIS that are incorrect,
and some conclusions not supported by the current consensus we
call "science".

The proposed "rule making" is here, in both plain text, and pdf.

(And no, you can't use google or altavista to translate it into
English, this IS what passes for English in US government documents.)

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?
dbname=2002_register&docid=02-20941-filed

http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?
dbname=2002_register&docid=02-20941-filed.pdf

The "pest risk assessment" documents in their current form
can be found here, if you like slogging through pages of gibberish.
(Warning - the server is very slow at times. It may take several
tries to get the documents.)

http://www.aphis.usda.gov/ppq/pra/honeybees/


Thanks!

jim