USDA / USFW Insect Permits

[Wayne F Wehling]

The thread on insect trading both deadstock (papered and pinned) and livestock has appeared in a timely manor.  As a result of new legislation, many changes are in the wings with respect to insect permits in the United States.  I am a scientific advisor at the USDA for butterfly and other exotic insect permits (mostly butterfly houses, butterfly releases, insect zoos).  Basically, if you want to transport live insects across state lines or import into the United States, you need a permit from Plant Protection and Quarantine (USDA APHIS PPQ).  This includes: research (both amateur and academic), hobby interests, commercial butterfly release, biocontrol, exhibitry, etc.   I do not deal with dead stock.  Dead stock importation requires a 3-177 form from Fish and Wildlife.   For dead stock see:     http://permits.fws.gov/

I am planning a discussion group/meeting for the Lep. Soc. Meeting at Wake Forest in July.  I hope to talk about what the new changes will mean but more importantly what can be done to help lepidopterist's comply with these regulations.  I have been a lepidopterist for 35 years and have reared most of the available exotic saturniids when I was a kid.   I am a professional lepidopterist because I had these opportunities as a child.  Currently, these kinds of activities are illegal and when the new legislation goes into effect such activities could carry a $50,000.00 fine.   I would like to discuss the possibility of pulling together a list of Lepidoptera that could be exempted from these regulations (yes, with proper documentation this can be done).  I am considering Saturniids at the moment.  And my (off-the-cuff) list would consider cercropia, luna, promethea, polyphemus, A. peryni, A. mylitta (sp?), A. atlas, A. mettrei, and some others.  To do this would require a risk assessment for each of these species.  The risk assessment would detail the biology of each species including an exhaustive host list and would go on to address the likelihood of establishing and becoming a pest if the critter escaped.  If the results of these investigations indicate little or no likelihood of an impact then I would consider the necessary steps to exempt these species from the permit requirements or make it easy to get permits for these specific species.   Currently, there are no charges for permits.  I hope I can turn to other lepidopterist's to do the leg work on pulling this literature together.  I am too strapped for time to do it all myself.

 I would like to hear from folks with possible agenda items for the meeting or with species to include for consideration.  Obviously, this could be a very heated topic and it will require careful planning to make it useful.  To that end, I would like to cover some territory here on Leps-l so that when we convene in North Carolina we can make good use of our time.  I would also add that I may not reply to all of the email this generates.  I will not respond to email that slams the government or discusses why the USDA regulates these insects.  I don't have the time.

I am also considering approaching USFW to see if they would consider a memorandum of understanding (MOU) giving regulatory authority for T&E and CITES to USDA for imports of insects.  Currently, all live material is inspected by both departments and consequently importation is slowed by a day or two.  Any USFW regulators out there??

Here is what's up with the new legislation.  Congress has passed the "Federal Plant Protection Act" and President Clinton is expected to sign it shortly.  It repeals 11 laws, including the Plant Quarantine Act, the Federal Plant Pest Act and the Federal Noxious Weed Act.  This new act has been 17 years in the making.  In essence, it increases my ability to regulate insect movements by expanding the definition of "plant pest" to include insects causing secondary effects.  It also substantially increases the fines for non compliance (up to $500,000.00 for commercial violations).

http://www.access.gpo.gov/nara/cfr/cfr-table-search.html#page1

For more information on permits see our web site.
www.aphis.usda.gov/ppq/ss/permits/pests/ 

Cheers,

Wayne Wehling, Ph.D.
Entomologist
USDA APHIS PPQ