Thanks Peter for your comments and suggestions. I will try and 
clarify what I mean a little better. I was at the 1994 plants 
committee meeting is San Miguel de'Allende in Mexico when the whole 
nursery registration proposal came up. As the president of the 
Commercial Orchid Growers Guild at the time we were very much against 
nursery registration because CITES wanted to require nurseries to 
report annually on how many plants were sold, how many had died, how 
many were produced etc. We were very much against registration at the 
time because we simply don't have time to deal with the record 
keeping that was being proposed. The registration process is not 
quite like that now but does require a lot of work. In my case it 
took over 250 hours to complete my permit.

Nursery registration does not change the amount of paperwork required 
with each shipment nor does it prevent countries or trading states 
like the E.U. from requiring onerous import permits. What I am 
talking about really is once a nursery is certified let those truly 
art prop plants trade without a CITES permit altogether. All that 
would be needed is a CERTIFICATION stamp or number to travel with the 
plants. The permits themselves are a nightmare and require dozens of 
hours to prepare.

While I appreciate the concept behind the CITES nursery registration 
program it doesn't go far enough.

We in the U.S have a master permit requirement now which my own 
nursery Orchids Limited has complied with. This master permit is in 
fact a nursery registration. It precisely follows the guidelines of 
the registration requirements as explained in conf. 9.19 
http://www.cites.org/eng/res/all/09/E09-19R13.pdf . The point is that 
the process of exporting is worse not better because of this. We must 
for instance list species involved in each hybrid and if we are not 
already approved for exporting a particular hybrid on our master list 
then we must be approved for the species that go into making that 
hybrid. This takes lots of time as you can imagine! I have to chuckle 
when I am exporting a division of say a Paph. F.C. Puddle, a hybrid 
made near the beginning of the 20th century. Many orders may contain 
only one of each type of hybrid so this kind of reporting for each 
shipment really does not make it a viable business situation.

What I am asking for is that instead of leaving it up to the various 
countries to register their nurseries make it rather a certification 
process with CITES as the registrar. You can call it registration if 
you want to but require that all nurseries in any signatory country 
to be certified for art prop export. The various countries could in 
fact certify the nurseries under an overall umbrella or process 
overseen by CITES but CITES would be the registrar in the end. Once 
the nursery is certified let those truly art prop plants go into 
trade without further (complicated) permits.

What I am really saying is remove all art prop Orchids from the 
appendices and let them be traded. The treaty is designed to protect 
wild populations. Let's do so now.

Jerry Lee Fischer



Orchids Limited
4630 Fernbrook Lane N.
Plymouth, Minnesota 55446
USA
Toll-free: 1-800-669-6006
Local: 763-559-6425
Fax: 763-557-6956
Website: www.orchidweb.com
Email: [EMAIL PROTECTED]

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