Comment from Lynn LeBeck

ANBP is the Association of Natural Biocontrol Producers (http://www.anbp.org), an organization with members from North America and world-wide who are involved in the production, trade and field implementation of beneficial organisms for the control of pests. As an association, ANBP has a great interest in the development of regulations regarding biological control (biocontrol) organisms that impact our members and the entire industry, as well as the current and future success of biocontrol organisms in our environment. ANBP favors an approach in the environmental impact statement (EIS) that makes a clear distinction between plant pests and biocontrol organisms. Biocontrol organisms have a long history of importation into the U.S. and biocontrol continues to contribute greatly to the control of highly damaging plant pests in important crops. ANBP understands the need for regulation of imported organisms; however, the risks of importing a biological control organism should be weighed against the potential benefits. ANBP favors an EIS in which equal effort is spent on analyzing the beneficial impacts of biocontrol organisms in controlling plant pests. See attached letter for more COMMENT