USDA / USFW Insect Permits

[Bruce Walsh]

 Wayne & Leps-L folks:

I'd like to make a suggestion in terms of shipping live material. 
Interesting, thanks to Wayne's advice, I can send live material to Canada or
overseas without any problem, but its a no-no to send it (say) 150 miles west
into California.

My suggestion is that live material logically falls into two regulatory
categories:

(1)  Small numbers (typically much less than a dozen) of material that
will be killed immediately for a collection.  These DO NOT include protected
species or those known to be pests.

(2)  Larger number for the start of breeding colonies (often commercial).
 Releases would also fall into this category. Likewise, pest and
protected species.

For (2) it makes sense to require general permits and to have ones for
specific species (such as painted ladies).  For (1) the risk of release
seems far, far more trivial than that caused by the bugs simply hitchhiking in
cars or trucks.  Indeed, the collector has a VERY strong vested interest
NOT to let any material get away.   Perhaps there can be an expedited and
(somewhat) blanket permit to handle this latter case.   For example, 
suppose I come across some larvae of a common SE Arizona moth (say Manduca
muscosa).  If I want to send 5-6 to a collector in the east, it strikes me
that by the time the permit process is cleared, the material will have
already hatched!  Likewise, in such cases, it is very hard to predict just what
species one will come across.  Should I get a separate permit for all 200
butterflies and 300+ moths whose larvae I am likely to come across simply
to send one or two to someone outside of the state?

A further troubling issue is that all collectors I know when they find
larvae on a collecting trip are likely to take a few home.  If I find cool
stuff three feet across the bounder in New Mexico, do I need a permit to
cross the statelines to bring them back into AZ (in particular, I'm thinking
of nice collecting spots that crest right on the border of AZ and NM)? 
Perhaps if my feet are in AZ when I grab the larvae this is OK.  I'm trying
to be a little humorous, but the implications are much more far reaching
than most of us have likely thought.

As a group, we all agree with the notion of avoiding unintentional
releases of any sort (I'm ignoring the  commercial release debate here). 
However, if lepidopterists cannot bring back material for rearing, then most of
the unknown early stages of US lepidoptera are likely to remain unknown.

Perhaps Wayne can setup a general permit to handle the very small sorts
of transfers that lepidopterists have historically done.  If such is the
case, I'm sure that individuals will have no difficulty with this action,
esp. if the permits are easily to apply for the on web.  Indeed, given the
vast number of permits that come in, there should be a blanket-level
protocol for certain transactions that do not require detailed individual review
(provided the applicant agrees to specific procedures).  This frees up
the regulatory authorities to handle with the more difficult cases.  (Our
university biosatey committee, of which I've been a member for the past 8
years, does just this).  Otherwise, if we all have to submit 50-100 permit
applications each year for the species we MIGHT come across, poor folks
like Wayne will be swamped, effectively stopping legitimate research while
these are all sorted out. 

I welcome open debate on this issue (and, no I'm won't bring up GM
organisms).

Cheers

Bruce

Bruce Walsh
Associate Professor, Ecology and Evolutionary Biology
(Member, Center for Insect Science)
University of Arizona