# Peru's INRENA new rule



## SlipperFan (Oct 3, 2006)

Wasn't sure where to post this, but:
This rather long posting on the OGD this morning might stir up some dicsussion:

On a previous Orchid Guide, the following posting was made:

On July 13 2006, a Peruvian Government document referred to as Decreto 
Supremo No. 043-2006-AG announced that Peruvian Orchid Nurseries may no longer export collected orchids. From now on all orchids exported must have been propagated in-vitro. It has orchid nursery owners in an uproar, for most of them do not have any stock propagated in-vitro and many do not even have a laboratory. Some have operated this way for decades.. Nursery owners tell me that there is no lead in time given, which you and I know should be 7 years minimum, if your intend is not to destroy the orchid industry of your country. They all blame a given orchid nursery for suggesting the new laws to the government and conveniently forgetting to tell them to give a lead in time. That nursery started a lab a few years ago, is claiming to have propagated large quantities of flasks of different species, but the victims of this new law claim they purchased them from other orchid laboratories.

******************************************************
The following is a copy of the letter written to the Peruvian agency INRENA 
by the Moores of Miami and Peru: 

Ing. Alberto Morizaki INRENA 
Intendente Forestal y de Fauna Silvestre 
Autoridad Administrative CITES/PE 
LIMA 
Subject: Decreto Supremo No. 043-2006-AG 
Estimado Ing. Morizaki: 
I am Zadith Alegria de Moore, owner of the Vivero Nuevo Destino in Moyobamba. 
In reference to Decreto Supremo No. 043-2006-AG, we question the legality and constitutionality of this decree that has been imposed upon us at the last minute without having been previously notified of this impending decree to have the opportunity to discuss and oppose this drastic decision that affects all of the legal orchid exporters in Peru. From one day to the next, we are being expected to export only orchids reproduced in vitro that do not exist. Overnight, our nurseries have been forced to close exportations by this unreasonable decree violating our Constitutional rights to free enterprise. 
For many years we have been reproducing and propagating thousands of many species of orchids by vegetative means very successfully and we are now expected to make this transition to plants produced only in vitro overnight. This in not only unreasonable but an impossibility because most orchid plants from seed in vitro requires 5 or more years to produce small plants and then 2 more years to produce flowering plants of reasonable size for export. This means that we will have to close our nursery for 5-7 years until we can begin exporting again which is an absurd impossibility that is being imposed upon us. How are we expected to survive and make a living in the mean time. 
No country in the world has ever imposed or required such a drastic transition because they understand the reality of orchid production. Only INRENA/PERU. This reality can be confirmed by any qualified world class expert on the propagation of orchids which, apparently, are none in INRENA/PERU. It is also obvious that the person or persons that compiled this list of prohibited plants has no valid knowledge of orchids because there are many names of species on that list that do not even exist and others that do not exist in Peru but in other countries. Even Bromeliads are required to be reproduced in vitro for exportation. Everyone knows that Bromeliads are not and cannot be reproduced in vitro. This only displays the ignorance of the authors of this list. In other words, the authors of this Supreme Decree are not qualified to make such decisions that drastically affect the orchid exporters. 
What are the exporters now expected to do with the thousands of orchids that we have been reproducing and propagating over many years? These plants now have no value because they are prohibited for exportation. They will now have to be destroyed to make bench space for new plants produced only in vitro because bench space is very valuable in a nursery. In other words our nurseries will have to go bankrupt because we cannot wait 5 years for these new plants to make the first flowers and then 2 more years grow to a reasonable size for export. 
The Peruvian Government invites foreign capital to invest in Peruvian industry. Over the past 8 years we have invested over $300,000 U.S. from our business in Miami to develop Vivero Nuevo Destino in Moyobamba to reproduce and propagate orchid species for export and contribute to the economy of Peru and our employees. Now we are prohibited to export what we have reproduced. This is not a very good incentive for the Peruvian Government to invite foreign capital for investment. We will now have to declare bankruptcy and abandon our project in Moyobamba because it is impossible to continue this business with unreasonable and impossible restrictions. 
If INRENA would make a proper study with qualified experts on orchid reproduction, they would determine that this decree is not only unreasonable but also impossible and unrealistic to be accomplished. The only practical and reasonable way for INRENA to limit the exportation of orchid plants produced only in vitro, would be for INRENA to announce to the orchid exporters that INRENA will allow the exporters seven years from the date of this Supreme Decree, to prepare their nurseries for this transition. This would give the exporters a reasonable opportunity to make the transition from vegetative propagation to vitro. 
Perhaps INRENA is convinced that Peruflora can achieve this miraculous accomplishment in less than two years as they have claimed; but the rest of the exporters and expert orchid growers of the world do not possess the knowledge of how to achieve this miraculous accomplishment. We do not wish to attempt to deceive INRENA like Peruflora has done. 
It is obvious that this new decree was designed to benefit only one orchid exporter. Peruflora has successfully deceived and convinced INRENA that they have achieved this miraculous accomplishment in less than 2 years in order to obtain a monopoly of orchid exportation in Peru with the blessings of INRENA. The world and the rest of the exporters know that this is impossible. This is not a very complimentary image for INRENA. 
It has come to our attention that Peruflora continues to advertise and export their orchids that are on the prohibited list of D.S. 043-06AG that are claimed to be reproduced in vitro. This confirms that this D.S. is designed only to give Peruflora the sole monopoly for the exportation of Peruvian orchids and not for the protection of the orchids from being endangered. 
We, the orchid exporters, will be asking for a formal investigation into this irregular procedure to question the legality and constitutionality of this abuse that is being forced upon us with D.S. 043-06AG without the exporters prior knowledge. Further, we will formally be requesting that an independent, world class expert on the reproduction of orchids in vitro, to investigate the nurseries of Peruflora to determine the validity of their claims of having all of these species of available that INRENA is allowing for export. Also to investigate the validity of the published list of orchids in D.S 043-06AG, some of which do not exist and others that do not even occur in Peru, which will prove that the authors of this list were not capable or qualified for making such decisions that has drastically affected our financial investments in Peru. This will be executed at our expense and become available for Public Information to those that may be interested.


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## gonewild (Oct 4, 2006)

A few years ago I read the INRENA law regarding nursery permits. The law was written somewhat vague and misleading. After reading it I was unclear as to whether orchids could be collected from the wild and reproduced by division in a nursery and then exported. I asked a number of INRENA officials about it and none had a good answer. (Except the normal blank stare and gapping open mouth when they are asked anything). 

As I recall the law said artificially reproduced orchids could be exported. However, "artificial" was not defined. Looking at it carefully it was clear to me the intent was that "artificial" meant invitro. Several INRENA Engineers told me reproducing an orchid by division was not artificial but in fact a natural way orchids reproduce. In reality the law in Peru most likely has always required invitro propagation for orchids for export.

The nurseries exporting orchids from Peru have simply worked a loophole that has now gone away. 

INRENA will not care about a few nurseries going bankrupt. The method (Peruflora?) used to gain a competitive edge is very common in Peru. Every Peruvian Industry has a leader that gets the gov. to place stupid requirements that wipe out the little guys. 

How about this... It is against Peruvian law to possess chlorox or any form of chlorine liquid in the Amazon regions of Peru. How are you ever going to do invitro work without some way to sterilize your lab?


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## NYEric (Oct 4, 2006)

More self serving beaurocratic manipulation. Disgusting.


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## Heather (Oct 4, 2006)

How is this (or is it not) going to affect Centro de Jardineria Manrique?


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## gonewild (Oct 4, 2006)

Heather said:


> How is this (or is it not) going to affect Centro de Jardineria Manrique?



It should not effect him as he has permits for invitro production and export.
Unless of course he makes money from export of conventionally grown plants. Which he would no longer be able to do.

You can read the Peruvian document *Aprueban Categorizacion de Especies Amenazadas de Flora Silvestre* if you want to see it for yourself. It is in Spanish of course.


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## SlipperFan (Oct 9, 2006)

I just received this letter from a friend who received it directly from Lee and Chady Moore:

From:Lee Moore
Sent: Monday, October 09, 2006 11:30 AM
Subject: Reply to Anders

We are Lee and Zadith (Chady) Moore, owners of Vivero Nuevo Destino in Moyobamba, Peru and authors of the letters to INRENA about this absurd Supreme Decree that has been imposed on us all of a sudden overnight without warning. 

This Decree was not made by INRENA (The CITES Authority in Peru) but a is Congressional Bill that was passed into law and signed by the President Toledo before he left office last July. INRENA only enforces and implements this Supreme Decree passed by Congress. This bill was sneaked through without the knowledge of any of the orchid exporters except Manuel Arias and Son, Manolo of Peruflora and his political friends who are the authors of this Decree in order to gain the monopoly on orchid exports from Peru because somehow, they have convinced INRENA that all of the 352 species being offered on their website are reproduced in vitro which is an absurd claim as anyone should know. 

All of the rest of us are expected to make this overnight transition of exporting mature plants that have only been reproduced in vitro. Peruflora has been able to accomplish this miraculous feat in less than a year like when Jesus fed the multitude with a basket of fish, a loaf of bread and a jug of water that he turned into wine. I am sure that professional orchid growers around the world would like to know his secret for this miraculous accomplishment.

This Decree includes such other things as Cacti, Bromeliads and even Mohogony trees etc. to be reproduced in vitro. Whoever heard of such thing? Also in the prohibited orchid list, we found species listed that do no even occur in Peru but from other parts of the world. This shows that the authors of this absurd Decree do not have any concept of what they are talking about. It is obvious that this Supreme Decree was designed only to benefit the Peruflora monopoly and not protect the orchids in the wild.

Everyone knows that the orchids Peruflora exports are 'wild collected' because we live there and we know all of the local collectors of wild orchids and they tell us about the plants that they ship to Peruflora. Besides, it is obvious that their plants have been blooming for over 5-6 years from first flowering indicated by the flowered out back bulbs. Peruflora has been operating a laboratory for only a few years which makes their claim of being reproduced in vitro an impossibility. Unfortunately, we cannot convince INRENA of this fact.

We are one of the legal registered growers of Phragmipedium kovachii authorized by INRENA. Each of the growers were allowed to possess 5 (five) collected plants to begin propagation and reproduction. In 2005 Peruflora published in their website a list of customers that have legally purchased and received their flasks of Pk and hybrids thereof. In less than a year and a half, They registered over 150 buyers of Pk flasks and numerous other hybrids of Pk. Many of the customers purchased up to 4 flasks of these. That is a lot of flasks to be produced from only 5 plants right out of the jungle not to mention the hybrids supposedly from a species that produces very little seed in each pod and a high percentage of these are not even viable. We would all like to know how this miraculous feat was accomplished. Not to mention a couple of hundred flasks that were offered for sale in the recent International Orchid Show in Australia. 

I have a feeling that a lot of people who bought these Pk flasks are going to be unpleasantly surprised when they start blooming and see what species or hybrid they really are.

I would like to see Peruflora try to explain this phenomena to a knowledgeable grower, not INRENA, who accepts their phenomenal claims. Unfortunately there are no knowledgeable orchid experts in INRENA that have any concept of this reality.

In 2002, we had purchased a number of these Pk that were being brought in from the wild and being offered to the nurseries. These plants were declared and registered with INRENA at the time. This was before all of the scandal started with this species. By 2005, we had reproduced over 220 seedlings of the Pk without the means of vitro. These grew naturally in our soil in our nursery before receiving authorization to possess the 5 legal plants to use in reproduction. Needless to say, since we had not received official authorization to grow this species, these 220 seedlings were confiscated by INRENA and sent to a university in Lima where they promptly died or disappeared. Now, we are starting over again and I can tell you that it is a very slow process with only 5 plants to work with.

This is the reality.

If anyone is interested in seeing a copy of this Supreme Decree
No 043-2006-AG It was published in El Peruano (Gov't newspaper that nobody reads-only lawyers) 13 July 2006 Look at www.inrena.gov.pe

Zadith Moore
Vivero Nuevo Destino
Moyobamba-Peru


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## kentuckiense (Oct 9, 2006)

I dislike that Arias crew more as each day passes. 

Edit: It seems like EVERYONE in this saga is shady to some extent.


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## SlipperFan (Oct 10, 2006)

kentuckiense said:


> I dislike that Arias crew more as each day passes.
> 
> Edit: It seems like EVERYONE in this saga is shady to some extent.


How can you say that? What evidence is there that the people who wrote this letter are shady? Or are you speaking of the way in which kovachii came to the US and now this? 

I think you have to be careful about painting with such a broad brush. How about the other Peru nurserymen involved in legal ownership of wild-collected plants? The Fischers, Glen Decker are to some degree in this saga. Are they shady also??? I don't think so!


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## NYEric (Oct 10, 2006)

*Legality and changing laws.*

Depending on your point of view anyone can be viewed as a little shady. The issue of when a plant is declared legal to ship will vary depending on whether the person is trying to control the distribution or rush the distribution, either of which is for profit. Either side will be obstructed by the actions of the other. I know some people who say the actions of those who are rushing kovachii and its'm hybrids into production is illegal and detrimental. I try not to take sides but I dont see how the distribution is bad. I hope breeding the plants allows them toj be returned to the wild.


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## kentuckiense (Oct 10, 2006)

SlipperFan said:


> Or are you speaking of the way in which kovachii came to the US and now this?


This one.


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## SlipperFan (Oct 17, 2006)

This was posted on the OGD yesterday:
From: "Anders Hjelmencrantz" Subject: [OGD] The INRENA Law.....again.

Question: OK as I understand it is still OK to export mature adult plants from Peru to another country as long as these plants have been propagated in vitro (right?). 
Reply:That is right but nobody has any!!!!!!!!! And they won't have for several years to come so, we are all out of business until then except for PeruFlora who has deceived and convinced INRENA that their plants are grown in vitro when they are all in fact wild collected.

Question: I also know there is a list issued by the Peruvian authorities stating which species that are controlled under this act. I have been trying to locate this list but have not been successful so far; does anyone have it? 
Reply: All of them! Go to _www.inrena.gob.pe_ (http://www.inrena.gob.pe/) / 
click link Forestal Y Fauana / Biodiversidad / Lista de Orquideas Amenazadas

Question: Furthermore, does anyone know what nurseries in Peru that have been authorized to sell mature plants (PeruFlora, Agroriente Viveros....? Any more???) 
Reply: Those two mentioned above plus our nursery of Vivero Nuevo Destino Moyobamba (_www.nuevodestino-us.com_ (http://www.nuevodestino-us.com/) ) are registered to export mature plants but PeruFlora is the only one claiming to have them from vitro which is a lie and being allowed only through the corruption that exists within the CITES organization to give him the momopoly. 
Best regards, Lee & Zadith Moore Vivero Nuevo Destino/Moyobamba, Peru


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## Heather (Oct 20, 2006)

Some more on Pk today from Peter Croezen.

part 1 of 2

Many books could be written, about all that has happened with and around Phragmipedium kovachii, since its discovery four years ago. 

In 1990, Manual Arias Silva had a flasking facility. In 1996 he stated in a lecture that he had stopped his in-vitro propagation of orchids, due to certain difficulties he faced running a laboratory. In 2000, when I and two Peruvian friends had a three hours tour of the Arias orchid growing facilities in Lima, guided by Manuel, he showed us a tiny room, possibly used for flasking a long time ago, but non-functional then. In December of 2004, Manuel Arias told one of my Peruvian friends that all the Phragmipediums he exported in 2004, with INRENA permits, were propagated by division from the large number of Mother plants he collected prior to the time CITES was enforced.

In May of 2003, when Manuel Arias obtained INRENA permit 002 to collect his five legal Pk plants from the habitat for the purpose of in-vitro propagation, he did not have a functioning laboratory. Though I informed INRENA of several orchid laboratories in Lima that were perfectly capable of starting Pk propagation in 2002, they were not issued a permit.. 

It was not until November 2003 that Manuel invested heavily in a new laboratory, by purchasing laminar flow hood units from Singapore. He then started a massive program of in-vitro culture, after some members of his family, or staff, were invited to learn in-vitro propagation techniques in England. Peruvian species orchids propagated from seeds in November of 2003, will not be full size plants today, October 2006.
Bill, it really does not matter today that Arias did some flasking in the 80's. The Moores are correct, it is impossible for the 352 full size orchid species, offered for sale by Arias today, to have been started from seeds in their laboratory that opened less than three years ago. 

part 2 of 2

Alfredo Manrique, the first Peruvian selected by INRENA to propagate Pk in-vitro from five legally collected Pk plants and now an expert Pk grower, fully agrees with the Moores that there simply is no way one can produce 800 flasks from five legal Pk plants in such a short time. What makes it even less likely is the fact that Manuel Arias divided his five legal plants into too many divisions; limiting flowering severely. The proof of this is in the pictures taken of his Pk plants in the last two years by INRENA. What many do not know is that INRENA, since 2004, kept a picture archive of all the Pk plants collected legally, taking pictures of the plants two or three times a year.

Peruflora or Peruanino have no orchid nurseries, they are exporters of Manuel Arias' orchids and in charge of the in-vitro lab.

In 2002, as a non- Peruvian, I was concerned about the survival of the species and suggested to INRENA that they immediately start an in-vitro propagation program for Pk. I knew of several laboratories in Peru who actively propagated orchids in-vitro.
Government wheels of progress turn slowly, it took another full year, till 2003, before artificial propagation of Pk was started.
I know of one other non-Peruvian who also was concerned, Miss Angela Mirro, who generously donated the proceeds of her first painting of Pk to the Lima based Club Peruano de Orquideas, for the purpose of establishing a Pk conservation program.

Some failures of Peru in connection with Pk are that they did little to stop the total depletion of the big Pk habitats and they had no plans for marketing the Pk species in such a way that it would benefit the small vendors living in the Pk habitat area, who up to this day live on less than US$ 50.- per month and sell Pk plants illegally at US$ 7.- each.


Peter


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## Kyle (Oct 20, 2006)

Two comments to peters comments. Both I have said to him in the past. 

Prior to Laminar Flow Hoods, Peru flora used gloveboxes. Not the industry standard, but it is possible to (mass) produce orchids using a glove box. I use a glove box, so I know how much higer contamination rates can be. But its possilbe.

INRENA siezed a number of PK plants (around 50) sometime in 2005. Peruflora was aloud to harvest and sow seeds from those plants.

I don't agree with this new law, but I think that some of Peter C comments need to be mad a bit more clear.

Kyle


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## SlipperFan (Oct 20, 2006)

I thought Peter's comments were quite clear. Perhaps, Kyle, you should re-read them. What do you think is not clear?


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## Greenthings (Oct 25, 2006)

Kyle said:


> Two comments to peters comments. Both I have said to him in the past.
> 
> Prior to Laminar Flow Hoods, Peru flora used gloveboxes. Not the industry standard, but it is possible to (mass) produce orchids using a glove box. I use a glove box, so I know how much higer contamination rates can be. But its possilbe.
> 
> ...



Having extensive experience with both LFH and glove boxes, I can assure you that starting with a totally sterile environment in both, contamination
is easier accomplished in the LFH than in the glove box.

The history of this particular INRENA Pk seizure is well documented by my Peruvian orchid friends, one of whom even went to take time/date pictures of the seized plants in the nursery where most of them were detained.

There are many orchid collectors in Northern Peru; most of them have been operating all of their lives without a license from INRENA , for no one told them it was required. After the Pk scandals, collectors and nursery owners are now aware that it will be in their best interest to acquire an INRENA license for their orchid business.

Sr. Valle is an orchid collector who owns and operates an orchid nursery in Buenos Aires, a small town in Northern Peru, near lake Pomacocha in the department of Amazonas. The now depleted Phragmipedium kovachii habitats are nearby. Sr. Valle once shipped his collected orchids to Manuel Arias, who employed his son, Jhon Valle. When Sr. Valle stopped his orchid shipments to Manuel, John was fired. 

In 2005, Sr. Valle was about to apply for an INRENA license that would legalize his orchid nursery. It is said that Valle's son Jhon is an excellent orchid grower and flasker. In Peru, nothing remains a secret for very long, including Sr. Valle's intentions to register his nursery. It is believed this led to INRENA receiving a complaint about Sr. Valle's illegal Pk's, for it is a fact that illegal Pk’s can be found in nearly every collection in that part of Peru.
Sr. Valle then got a visit from INRENA officials, who happened to be on another mission, nearby, doing field studies in the Pk habitat. More than 70 Pk plants were seized from Sr. Valle. More than 60 of these were detained by INRENA to Sr. Valle's nursery, with the stipulation that these could not be sold and not be used. These 60 plus seized plants were not pollinated by Peruflora; as a matter of fact they were not pollinated by anyone, in compliance with INRENA orders.

12 of the seized plants were taken to an INRENA greenhouse in Lima. It is common knowledge among local orchid vendors that INRENA never gives seeds or plants to any nursery. My information is that no exception to this rule was made. 

Just let's consider for one brief moment that Pk seeds had been obtained in 2005, legally or otherwise from whomever, these could not possibly have been the source of the one year old in-vitro Pk seedlings sold in 2005 and 2006. 

Finally, since the first day Peruflora started selling its legal Pk flask at the 18th WOC held in Dijon France, they published a List of Legal Pk Owners on their website, that list was periodically updated and grew to 138, the last time I checked it. That long list has been removed from the web site and replaced by a much shorter one of just 32 legal owners listed


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## SlipperFan (Nov 2, 2006)

Well, here's an interesting thing:
I happened upon this website: http://www.members.optusnet.com.au/~aoc2006/
Scroll down and, if you have MS Excel, download the NEW LIST of kovachii flasks from Peruflora.
Is it really possible to have that many flasks from 5 legal plants? Or....


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## Greenthings (Nov 3, 2006)

SlipperFan said:


> Well, here's an interesting thing:
> I happened upon this website: http://www.members.optusnet.com.au/~aoc2006/
> Scroll down and, if you have MS Excel, download the NEW LIST of kovachii flasks from Peruflora.
> Is it really possible to have that many flasks from 5 legal plants? Or....



No. It is impossible to have that many flasks from just 5 plants. 
I happen to know for a fact that the five Pk plants were divided into so many 
pieces that at least for one season already these did not produce any seeds.

Contrary to what some folks have said on another forum, these are not old Pk flask lists. Old crosses, yes, but new lists. I have been aware of the four lists from the day these were published on the Australian Orchid Council website.

The new lists have the date clealy marked on them as 2006. The Conference was real, the Pk vendor was in Australia and selling July 19-23, 2006


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## silence882 (Nov 3, 2006)

Quick questions about the Pk situation. How many nurseries / individuals were given permission to collect 5 plants? I know for sure that CJM and Peruflora were given permits, but I am unsure about the Moores [or anyone else?].

Also, does anyone know of a way to document when the permits were issued? The CJM permit was printed in the OD phrag issue, but I dunno about the other two (or one?).

--Stephen


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## Greenthings (Nov 3, 2006)

silence882 said:


> Quick questions about the Pk situation. How many nurseries / individuals were given permission to collect 5 plants? I know for sure that CJM and Peruflora were given permits, but I am unsure about the Moores [or anyone else?].
> 
> Also, does anyone know of a way to document when the permits were issued? The CJM permit was printed in the OD phrag issue, but I dunno about the other two (or one?).
> 
> --Stephen



CJM' permit 001 to collect 5 Pk from an assigned Pk habitat was issued in May 2003, it had a certain window in which to collect them. Alfredo Manrique collected his five plants on May 29, 2003, if my memory serves me correctly. 

Manuel Arias Silva got his permit 002 a few weeks later.

Lee Moore states in his letter that he has received a Pk permit, I believe this year, but he has not given us an exact date. 

The important thing to remember is that it took one whole year since the discovery of Pk, before INRENA did issue just two collectimg permits.

When Manolo started selling Manuel Arias' Pk flasks, nearly two years later, in March of 2005, there were still only two laboratories propagating Pk. Yet many laboratories, including two I set up in Lima, were capable of propagating Pk. I did communicate this to INRENA in June of 2002.You will have to ask them why these labs were not included in the Pk conservation/preservation program.


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## gonewild (Nov 4, 2006)

Greenthings said:


> When Manolo started selling Manuel Arias' Pk flasks, nearly two years later, in March of 2005, there were still only two laboratories propagating Pk. Yet many laboratories, including two I set up in Lima, were capable of propagating Pk. I did communicate this to INRENA in June of 2002.You will have to ask them why these labs were not included in the Pk conservation/preservation program.



Did the two labs you refer to as not being included actually file the parer work to request a permit? And then follow through with the long, completely ridiculous process INRENA has for granting any permit?


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## Greenthings (Nov 4, 2006)

gonewild said:


> Did the two labs you refer to as not being included actually file the parer work to request a permit? And then follow through with the long, completely ridiculous process INRENA has for granting any permit?



Not certain, but one of them may have. The point is that the initiative to use as many labs as are available should have come from the department charged with the conservation/preservation of endangered species, in this case INRENA. That did not happen; in fact they waited one full year(to May 2003)to do anything at all, even though they were reminded/urged in June 2002 to take action.


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