NECIS

Comments to the US Fish and Wildlife Service on Listing Black Carp under the Lacey Act

In response to a notice in the Federal Register, a few NECIS groups submitted comments on their own behalf regarding the listing of live black carp (Mylopharyngodon piceus) as an injurious species under the Lacey Act. It should be noted that this call for input is merely the latest round of a federal process that has kept the issue under consideration since the early 1990s. The following groups submitted letters:

Defenders of Wildlife <Download dowcarp_120506.pdf>

The Nature Conservancy <Download tnccarp_121605.pdf>

Union of Concerned Scientists <Download ucscarp_121605.pdf>

International Law Related to Precautionary Approaches to National Regulation of Plant Imports (2005) by Peter Jenkins, ICTA

This article by Peter Jenkins of the International Center for Technology Assessment discusses international law as it relates to attempts by countries to strengthen their national laws regulating the import of live plants from other countries. The paper specifically addresses whether and how countries can shift to regulating plant imports through a precautionary listing approach (clean, dirty and gray lists) while respecting their obligations under international law. Download jenkins_2005.pdf