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:

        [log in to unmask]

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 prevented 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