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#5 Fall 2000 AGF Newsletter
US Fish
and Wildlife Service's
Office of Scientific Authority Annual CITES Report of Findings
July, 2000 (Condensed)
The Office of Scientific
Authority (OSA) finds that the export of wild and wild simulated ginseng
roots of five years of age or older harvested during the Fall of 2000
is not detrimental to the survival of the species in the following states:
AL, AR, GA, IL, IN, IA, KY, ME, MN, MO, NY, NC, OH, PA, TN, VT, VA,
WV, and WI. No restrictions on cultivated ginseng are required in the
states of AL, AR, GA, ID, IL, IN, IA, KY, ME, MD, MI, MN, MO, NY, NC,
ND, OH, OR, PA, TN, VT, VA, WA, WV, and WI.
The OSA will continue
to monitor American ginseng in the wild and reserves the right to change
the restrictions for the Fall 2001 harvest.
BASIS FOR ADVICE:
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The OSA reviews yearly information available publicly
from a variety of sources (other federal agencies, State regulatory
agencies, industry representatives and associations, non-governmental
organizations, and academic researchers) on the status of the species
in each state.
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All states named above have been previously approved
by the US Fish and Wildlife Service (Service) for regulating the
harvest of wild and/or cultivated ginseng and for certifying harvested
ginseng for export.
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The states of ME, MI, ND, OR, and WA exclusively
export cultivated ginseng. ME and MI are both within the native
range of ginseng and have passed laws that allow only the harvest
and export of cultivated ginseng. ID, ND, OR, and WA are outside
the native range.
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A review of OSA files
reveals that: Although the total harvest nationwide decreased by
less than 2% between 1998 and 1999, ten (53%) of the states reported
an increase in harvest of wild ginseng during that time.
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However in 17 (89%)
of the states, harvest levels for the 1999 season were below the
average annual harvest during the 1990's. In fact, in 13 (76%) of
these 17 states, harvest levels were more than 40% lower in 1999
than the average for 1990's. It is noted that in some areas of the
US, the proportion of wild-simulated ginseng has increased in the
last decade. Given that this ginseng is generally certified and
reported as "wild," it may have affected harvest trends for those
areas, leading to the wrong conclusion that wild populations have
remained stable or increased, when indeed they have decreased. This
wild-simulated ginseng increase may also explain why last year's
age-based restriction on the export of wild ginseng had little impact
on the reported harvest levels of wild ginseng for 1999.
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In 1999, the OSA
conditioned its non-detriment finding to ginseng roots five years
or older because of concerns about declines in wild ginseng populations
in some parts of the country in the late 1990's.
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The OSA continues
to review the ginseng export program. Since 1999 it has found:
a. Between 1821-1899, 381,000 lbs.
of wild root were exported annually but between 1990-1999, 121,498
lbs. of wild root were exported annually.
b. In late 1970's, wild ginseng was
30% of the exported ginseng from North America, but in 2000, only
3.5% of exported ginseng was wild, despite the high demand for wild
roots by the Asian market. This demand has led to elimination of
wild ginseng in China and Korea and has caused Siberian ginseng
to now be restricted, effective July 19, 2000. At the most recent
CITES Conference on April 10-20, 2000, Siberian ginseng was included
in Appendix II.
c. The Nature Conservancy (TNC) reclassified
its ranking of American ginseng in 2000 from "common" to "rare/common."
Some of the rankings are as follows: TN: rare/common; AL, AR, KY,
MO, NY, NC, OH, PA, VA, WV, WI: common.
d. On August 30, 1999, the US Forest
Service--Eastern Region requested National Forests within that region
to condition permits for the collection of wild ginseng to plants
at least five years of age. On January 29, 2000 it listed American
ginseng in its Sensitive Species List in light of the TNC's re-ranking.
Collection of "sensitive" plants is only permitted for scientific
or educational purposes, or conservation or propagation of the species,
and must be authorized by a Forest Service permit. This has resulted
in many of the Eastern Regions's National Forests no longer issuing
collecting permits for the species. The US Forest Service-Southern
Region is currently considering adding ginseng to its regional Sensitive
Species List. This region includes the Daniel Boone National Forest
in KY. If listed as Sensitive, none of the Southern Region's National
Forests will be issuing collecting permits for ginseng. The Ozark-St.
Francis National Forest, AR already has established a five-year
moratorium (as of May 1, 2000) on ginseng harvest.
e. Wild ginseng poaching within the National
Park system has increased. Park officials estimate $5,320,000 worth
of ginseng roots have been poached in Great Smoky Mountains National
Park in the last nine years. Ginseng growers and dealers informed
the OSA at a conference in Louisville, KY in May 2000 that poaching
is a major problem and more assistance against ginseng theft is
requested from the state.
f. Results from surveys conducted
by the Wisconsin Dept. of Natural Resources and by the Division
of Natural Heritage, Tennessee Dept. of Environment and Conservation
in 1998 found that the majority of all ginseng diggers noted less
wild ginseng to be found.
g. A recent survey of 7 plots (50x50m)
within national forests in NC found a major decline in ginseng density
from 29.8 plants/plot in 1979 to 5.7 plants/plot in 1999. Population
viability studies of the 5 populations with plants remaining in
1999 suggests that at least three of the five are likely to be extirpated
within the next 13 years.
h. West Virginia University researchers
found a significant decrease in the height of herbarium ginseng
specimens (most of it occurring since 1900) deposited in 17 herbaria
across the country and collected randomly over a period of 186 years
This reduction in plant size was region-specific, with northern
North American plants remaining the same size, while specimens from
mid-western, Appalachian, and southern populations declined in size.
The number of ginseng specimens collected for herbaria declined
while other closely related species remained the same or increased.
i. Experimental analysis of ginseng
populations of different sizes by West Virginia University researchers
showed a decrease in fruit production (as much as 50%) in small
populations compared to large ones.
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On October
7, 1999, the Service published a notice in the Federal Register
seeking comments and information from the public on the conservation
and impact of harvest and international trade in American ginseng.
The Service received only eight comments. One written on behalf
of the Botanical Industry Council stated that the service relied
on unsubstantiated and anecdotal information" and considered the
age-based restriction on export of wild ginseng "impractical" and
difficult to enforce. All seven other comments expressed similar
views. None, however, provided field data or research supporting
their belief that wild ginseng populations are not in decline.
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The Service
holds that its export restrictions of three-prong (five year-old)
plants is in keeping with the prohibition of harvesting such by
the above mentioned States and is not imposing another restriction.
Moreover, contrary to what the industry predicted, last year's age-based
restriction on export of wild ginseng did not result in a significant
drop in reported harvest levels in 1999. As mentioned above, total
harvest nationwide decreased by less than 2% between 1998 and 1999
with half of the States reporting an increase in harvest from 1998
to 1999 (noting wild-simulated ginseng's impact). [See #4.]
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The US Dept.
of Agriculture Animal and Plant Health Inspection Service (APHIS)
inspects all plant import and exports. APHIS has reported no major
problems regarding the implementation of last years' age-based restriction
on export of wild ginseng.
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The Service
holds that economic factors (including unemployment rates in the
US) may have influenced demand for and harvest of American ginseng
in the last few years. This is corroborated by research done by
West Virginia University which found a correlation between harvest
levels and unemployment.
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Biotic and
abiotic (i.e. deer and drought) factors have negative impact on
wild ginseng populations. However, the Service believes that recent
declines in many states of American ginseng is greatly related to
overharvest, particularly of young, non-reproducing plants. The
Service is seriously concerned that this overharvest threatens wild
ginseng and the livelihoods of those citizens who depend on this
plant economically.
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The Service again
requests that the [Office of Management Authority] OMA condition
permits for the export of ginseng roots originating from the wild
so as to allow only export of roots that are five years of age or
older. Although it would be biologically preferable to leave roots
in the ground for a longer number of years after the plants reach
reproductive age, implementation of this would require the amendment
of current State regulations pertaining to minimum number of prongs
(3 to 4) by all states with wild ginseng harvest programs. Growers
of wild-simulated ginseng (indistinguishable from wild) would have
to delay harvest of their plants by at least six years since three-prong
ginseng plants do not add a fourth prong until they are between
ten to twelve years old.
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The Service
is actively collaborating and sharing information with the States
and other federal regulatory agencies (particularly the US Forest
Service) to assist them in the development of management strategies
for American ginseng populations under its jurisdiction. This improved
collaboration has already resulted in significant management changes
in portions of the species' range (see 6d above).
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The Service,
the States, industry, and others agree on the need to improve monitoring
of wild American ginseng to better assess the impact of harvest
on wild ginseng (particularly as the amount of wild-simulated increases).
This annual monitoring program would involve the establishment of
survey plots across most States where wild ginseng is currently
harvested. The data gathered would be analyzed to determine whether
current levels of harvest are sustainable and whether further restrictions
in the harvest of wild American ginseng are needed. The Service
considers this monitoring to be vital to the conservation of this
species.
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The Service
is funding research at West Virginia University to examine several
factors regarding wild ginseng. Preliminary results indicate that:
a. Many states allow harvest of plants before seeds ripen, thus
reducing the chances of seed germination, even if these are planted
as required by most States. b. Germination rates are affected by
the depth seeds are planted. Optimum depth is found to be at 2 cm.
OSA encourages states to share these findings with diggers and dealers
to increase germination rates of planted seeds. c. There is a negative
correlation between densities of deer and ginseng plants.
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Several states
are establishing programs for the distribution of cultivated seeds
to ginseng diggers as a means of restoring the species in the wild.
While the Service supports this idea of restoration, it is greatly
concerned about the origin of the seeds used and the impact these
may have on the local gene pools of wild populations of ginseng.
The Service is exploring in conjunction with the States, the USDA,
and the industry, the possibility of establishing local or regional
ginseng nurseries using locally obtained seeds.
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Other options for
the conservation of ginseng discussed by the Service and the States
have included the establishment of harvest quotas, a short-term
moratorium on harvest of wild ginseng, or a combination of harvest
and moratorium (allowing harvest only every other year). Given the
difficulty of determining how to allocate harvest quotas among States
or individuals, or distinguishing wild from wild-simulated ginseng,
at this time the Service has opted to pursue those alternatives
that allow for conservation of the species without negatively affecting
growers of wild-simulated ginseng.
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The Service will continue
to work closely with other federal and State officials, as well
as the ginseng industry, to ensure the long-term conservation and
sustainable use of this important natural resource.
CONDITION: American
ginseng roots harvested in 2000 and certified by the States as either
wild or wild-simulated may be exported provided that the roots are five
years of age or older. (Age of ginseng roots at the time of harvest
can be determined by counting the number of bud scars on the root. A
single scar is produced after abscission of the plants' aerial stem
each Autumn.)
THE AGF COMMENTS:
#7. It is interesting to
note that the argument used by the Botanical Industry Council (BIC)
that the Service "relied on ‘unsubstantiated and anecdotal information'"
against age-based restrictions is the same argument used by Greg Williams
of the AGF for more restrictions on wild ginseng harvesting--a moratorium,
in fact. (See the Summer 2000 AGF newsletter, #4 and ASPI Technical
Paper #57, Moratorium on Wild American Ginseng Exports, available on
the web at www.kih.net/aspi.) CITES requires scientific evidence that
no detriment to wild ginseng is caused by trade, even with the five
year regulation. By asserting the Service's lack of scientific evidence,
the BIC is strengthening the case for a moratorium rather than a case
for lifting the five-year regulation.
#8. The OSA underscores the insignificant drop in export
numbers between 1998 and 1999, stating that its restrictions had little
impact and that increased production of wild-simulated ginseng is most
likely the cause of stable harvest numbers. Without separating data
on wild-simulated and wild ginseng, the OSA is not representing true
numbers to CITES of the occurrence in the wild and harvesting rates
of the threatened wild American ginseng. By putting a freeze on wild
ginseng exports and regulating wild-simulated ginseng production, more
accurate accounts of wild ginseng would be available to the OSA and
therefore CITES. Even a temporary moratorium on wild ginseng would allow
some restoration. The OSA ignores here its own report that of States
producing ginseng harvest in 1999, 89% reported a lower harvest than
the average for the 1990's, with 76% of those 17 States at 40% less
than average for the 1990's (see #4 above).
#10. It is no surprise to the AGF that research shows
a correlation between harvest levels and unemployment rates. The AGF
advocates virtually wild ginseng growing (wild-simulated with no chemical/human
intervention other than seeding) as an lucrative, alternative income
source for woodland owners and those who would contract to grow ginseng
on another's land. Regulated wild-simulated ginseng (marketing-card
system, etc.) would alleviate the problem of ginseng theft.
#12. The OSA continues to advocate the condition of five
year-old roots or older for exporting despite its expressed regret that
"it would be biologically preferable to leave roots in the ground for
a longer number of years after the plants reach reproductive age." It
laments that to change the age restriction would require new regulations
and wild-simulated growers would have to delay harvest. The AGF suggests
side-stepping incremental regulation and going forward with a moratorium
on wild ginseng exports. If regulated, wild-simulated ginseng could
be exported at any age, although the AGF recommends roots of at least
five to seven years or older because of higher market values and because
fruit production of wild-simulated contributes to restoration by both
deliberate and natural means.
#17. Once again, the AGF suggests a moratorium, even
a short-term one of five to ten years, until more substantial, non-anecdotal
studies are done. A corresponding system of regulating wild-simulated
ginseng will avoid the problem of distinguishing illegally obtained
wild ginseng from legitimately grown wild simulated. In this case, the
market is offered the high quality ginseng root it demands, US growers
are making top dollar per pound of ginseng root, and a threatened indigenous
plant is preserved.
Condensed and commented on by Jeannette Matthews
AGF TRAINING WORKSHOPS: Burnsville, NC--September 23, 2000 (Filled!);
Charleston, WV--September 30, 2000 at CCA meeting (contact Todd Garland
304/847-7215); Whitwell, TN--October 14, 2000 (Filled!)
All workshop participants and ginseng growers are invited to the AGF
follow-up conference on March 17, 2001 to discuss growing experiences
and the formation of ginseng cooperatives and desirable regulations
for protection against poachers.
For further information, contact Appalachian Ginseng
Foundation (AGF) at 606/256-0077.
For AGF Newsletter entries or inquiries, Editor at 606/256-0077.
The Appalachian Ginseng Foundation (AGF) is a project
of
Appalachia--Science in the Public Interest (ASPI),
50 Lair Street,
Mt. Vernon, KY 40456.
Fax: 859/2779;
email: aspi@kih.net.
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