Beginning sometime in November, 1995, APHIS implemented a subtle yet critically important change in they way certain permit requests are be handled. Specifically:

"APHIS is not asserting jurisdiction over first-time releases of nonindigenous species of non-plant pests (i.e. most entomophages) from quarantine."

In a nutshell, this means that if you have an entomophagous species in quarantine ("which does not attack (1) important naturally-occuring biological control agents, (2) introduced biological control agents, or (3) commercially important pollinators"), and apply for a _release_ permit from APHIS, APHIS will issue a letter saying they do not have jurisdiction over this action (they currently issue a "courtesy permit" which really means the same thing).

This means that THE APPLICANT is responsible for interpretation of, and compliance with, NEPA (ultimately requiring the development of an Environmental Assessment, or EA, and a Finding of No Significant Impact, or FONSI). A non-federal employee, then, would develop an EA, write a FONSI letter, and "place it in his(her) own file cabinet in case of future action". If the applicant: (1) is a Federal employee, (2) is using Federal funds for the action, or (3) is releasing on Federal land, then THAT Federal agency would be responsible for developing the EA and reaching a FONSI. Personally, I question ARS doing these....clearly this seems to be an APHIS role.

With this action, APHIS is really dropping out of the loop for releases of most non-plant-feeding arthropods. This change has been verified by many individuals, and it seems that official notice of this change by APHIS is awaiting action from the Science Advisor to the APHIS Administrator, Dr. Sally McCammon.

At what point, if any, was the scientific community to be made aware of this significant change? In spite of many public, private and political requests for APHIS to work _with_ the community, it seems that APHIS continues to work in a bubble.

This agency seems to have taken the official stance that, since "we" didn't like the proposed (Nonindigenous Organisms) rule, they will take their marbles and run. This change will ultimately leave states responsible for making all decisions on releases of most entomophagous species, and without Federal coordination, the chances for error, miscommunication, duplication of effort, etc. etc. increase dramatically.

Now what is the role of our Federal Government again?