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Hawaiian Dry Forests – Glimmer of Hope for one tree, Alarm for a shrub

wiliwili flower
photo by Forrest and Kim Starr, courtesy of creative commons

Hawaii’s dryland forest is a highly endangered ecosystem. More than 90% of dry forests are already lost due to habitat destruction and the spread of invasive plant and animal species. However, a new publication documents some recovery of wiliwili trees from one major pest. At the same time, a new pest is spreading and killing naio, a critical dryland shrub. Both pests originated in countries that have rarely if ever been a source of U.S. pests. This is worrying because phytosanitary agencies have their hands full with imports from the usual sources. The role of California as a source of invasive species in Hawai`i has long deserved federal attention – but as far as I know has not received it.

Hope for Wiliwili Trees

The Hawaiian endemic wiliwili tree, Erythrina sandwicensis, occurs in lowland dry forests on all the major islands from sea level to 600 m. Wililwili is a dominant overstory tree in these habitats. (Unless otherwise noted, the principal source is Kaufman et al. in press – full citation at end of blog.)

The tree has been severely affected by the introduced Erythrina gall wasp, Quadrastichus erythrinae (EGW). The gall wasp was detected on Oahu in 2005 and quickly spread to the other Hawaiian islands.

Arrival of the EGW on Oahu was part of the insect’s rapid global range expansion. Originally from East Africa, it was first detected in the Mascarene Islands and Singapore in 2003. At the time, it was unknown to science. Within a few years it had spread across Asia, many Pacific islands (including Hawai`i), and to the Americas, including Florida in 2006, Brazil in 2014 (Culik 2014), and Mexico in 2017 (Palacios-Torres 2017). Although apparently restricted to the Erythrina genus as host, it has lots of opportunities. This genus has 116 species distributed across tropical and subtropical regions: 72 species in the Americas, 31 in Africa, and 12 in Asia.

The severe damage to wiliwili (and to non-native Erythrina trees planted in urban areas and as windbreaks) prompted Hawaiian officials to immediately initiate efforts to find a classical biological control agent. The process moved rapidly. A candidate – a parasitic wasp species new to science, Eurytoma erythrinae – was found in East Africa in 2006. Host specificity testing was carried out. Scientists quickly learned to rear the parasitic wasp in laboratories. Release of the biocontrol agent was approved in November 2008 – only three and a half years after the EGW was detected on Oahu.

The biocontrol agent’s impact was quickly apparent. Establishment was confirmed within 1–4 months at all release locations throughout Hawai`i. Reduced pest impacts to trees were detected within two years. By 2018, only 33% of the foliage was damaged on the majority of wiliwili trees. Damage to non-native Erythrina had also declined.

Results of Biocontrol Agent’s Release

The biocontrol agent’s efficacy in reducing EGW’s impacts on trees has been evaluated for 10 years after the agent’s release. Monitoring was conducted at sites on four of the six main islands. (The monitoring program and its findings are described in Kaufman et al. in press).

I wonder how many other biocontrol agents have been monitored so closely for such a long time? Shouldn’t they all be?

Given the uniqueness and importance of such long-term assessment, it is worth looking at the data in detail.

1) Foliar Damage and Tree Health

In 2008, before release of the biocontrol agent, more than 70% of young shoots in wiliwili trees that were inspected were severely infested. The damage rating of “severe” fell from about 80% of trees in 2008 to about 40% in 2011. About 20% of trees surveyed – at sites on all islands – had no gall damage.

By three years after release of the biocontrol agent (2011), mortality rates attributed to stress from the EGW infestation for trees in natural areas fell to 21%. Mortality rates for trees in botanical gardens was somewhat higher – 34%. Kaufman et al. proposed several possible reasons: a) lingering presence of systemic insecticides that might have harmed the biocontrol agents early in the releases; b) year-round sustenance for the EGW as a result of the i) presence of alternative hosts and ii) supplemental irrigation which maintained fresh foliage on the trees.

Less intensive monitoring occurred during 2013 – 2018. It showed continuing substantial suppression of EGW damage on Erythrina foliage, although levels varied among locations. Sites with the lowest precipitation and higher temperatures throughout the year had the slowest recovery of wiliwili. Still, trees are now producing vegetative flushes and healthier canopies during non-dormant periods.

2) Flower and Seed Damage

Successful reduction of infestations in flowers and seedpods was less immediate. Still, by 2011, seed-set had increased from less than 3% of trees setting and maturing seed, to almost 30% with mature seed. The proportion of trees bearing inflorescences also increased, with more than 60% of trees blooming three years after introduction of the biocontrol agent. There was also a slow but steady increase in seed production.

However, in 2019, it remains unclear how infestation of seedpods will affect germination and therefore future plant recruitment.

More worrying, little recruitment was observed over the 10 years. Hawaiian authorities have completed tests on, and are preparing a petition for release of, a second biocontrol agent, Aprostocitus nites. It is hoped that it will further suppress EGW in flowers and seedpods.

Still, poor recruitment is likely due to the combined impacts of multiple invasive species in native environments. A significant factor is a second insect pest – a bruchid, Specularius impressithorax – which can cause loss of more than 75% of the seed crop. I hope authorities are seeking methods to reduce this insect’s impacts.

The Hawaiian species group of the IUCN has given the wiliwili tree the Reed Book designation of “vulnerable”.

Worries for Naio

naio in bloom
photo by Forrest and Kim Starr, courtesy of creative commons

Naio (Myoporum sandwicense)is an integral component of native Hawaiian ecosystems, especially in dry forests, lowlands, and upland shrublands. However, it is also found in mesic and wet forest habitats. Naio is found on all of the main Hawaiian Islands at elevations ranging from sea level to 3000 m. The loss of this species would be not only a significant loss of native biological diversity but also a structural loss to native forest habitats.

The invasive non-native Myoporum thrips, Klambothrips myopori, was detected on the Big Island (Hawai‘i Island) in 2009 – four years after it was first detected on ornamental Myoporum species in California. At the time of the California detection, the species was unknown to science. It is now known that this species is native to Tasmania.

The thrips feeds on and causes galls on plants’ terminal growth and can eventually lead to death of the plant.

For close to a decade, the Myoporum thrips was restricted to the Big Island. It has now been found on Oahu (Wright pers. comm.) Alarmed by the high mortality of plants in California, in September 2010, the Hawaii Department of Lands and Natural Resources Division of Forestry and Wildlife and the University of Hawai‘i initiated efforts to determine spatial distribution, infestation rates, and overall tree health of naio populations on the Big Island. Monitoring took place at nine protected natural habitats for four years. This monitoring program was supported by the USFS Forest Health Protection program. (See also the chapter on naio by Kaufman et al. 2019 in Potter et al. 2019 – full citation at the end of this blog.)

naio damaged by thrips
photo by Leyla Kaufman, University of Hawaii

The monitoring confirmed that the myoporum thrips has spread and colonized natural habitats on the leeward side of Hawai`i Island. Infestation rates increased considerably at all sites over the duration of the four-year sampling period. Trees experiencing high infestation levels also showed branch dieback.

Medium-elevation sites (between 500–999 m) had the highest infestations and dieback: over 70% of the shoots had the worst damage.. At two sites, over 70% of the monitored trees have died.

Even though flowers and fruits were still seen at all sites, little to no plant recruitment was observed at these sites. Thus another plant species important in this endangered plant community is in decline.

Few management strategies are available for this pest. They include preventing spread to other islands and early detection followed by rapid application of pesticides.

Implications and Conclusions

The Erythrina gall wasp and myoporum thrips are only two of the thousands of invasive species established in Hawai`i. Island ecosystems, especially Hawai`i, are well recognized as especially vulnerable to invasive species. It has been estimated that on average 20 new arthropod species become established in Hawai`i every year.

East Africa and Tasmania are new sources for invasive species. Phytosanitary agencies need to adjust their targetting of high-risk imports to recognize this reality. Regarding the Hawaiian introduction of the thrips, there was probably made an intermediary stop in California – which is not unusual. (See also ohia rust.)

I applaud Hawaiian officials’ quick action to counter these pests. I wish their counterparts in other states did the same.

There are multiple threats to Hawaii’s dry forests, including habitat modification and fragmentation; wild fires; seed predation by rodents; predation on seeds, seedling, and saplings by introduced ungulates (e.g. feral goats, pigs and deer); competition with invasive weeds; and damage by invasive insect pests and diseases.

With so much of Hawaii’s dry forests already lost, the release of biocontrol agents targetting specific pests is only one element of a much-needed effort. Long-term protection of wiliwili and naio depends on greater efforts to reduce all threats and to stimulate natural regeneration of this ecosystem. These programs could include predator-proof fencing to keep out ungulates; baiting rodents and snails; and active collection. Breeding, and planting of threatened plant species in an effort to protect both the individual species and the habitat.

SOURCES

Culik, M.P., D. dos Santos Martins, J. Aires Ventura & V. Antonio Costa. The invasive gall wasp Quadrastichus erythrinae (Hymenoptera: Eulophidae) in South America: is classical biological control needed?

Kaufman, L.V., J. Yalemar, M.G. Wright. In press. Classical biological control of the erythrina gall wasp, Quadrastichus erythrinae, in Hawaii.: Conserving an endangered habitat. Biological Control. Vol. 142, March 2020

Palacios-Torres, R.E., J. Malpica-Pita, A.G. Bustamante-Ortiz, J. Valdez-Carrasco, A. Santos-Chávez, R. Vega-Muñoz and H. Vibrans-Lindemann. 2017. The Invasive Gall Wasp Quadrastichus erythrinae Kim in Mexico. Southwestern Entomologist.

Potter, K.M. B.L. Conkling. 2019. Forest Health Monitoring: National Status, Trends, and Analysis 2018. Forest Service Research & Development Southern Research Station General Technical Report SRS-239

Kaufman, L.V, E. Parsons, D. Zarders, C. King, and R. Hauff. 2019. CHAPTER 9. Monitoring Myoporum thrips, Klambothrips myopori (Thysanoptera: Phlaeothripidae), in Hawaii

Wright, Mark. 2005. Assistant Professor and Extension Specialist, University of Hawaii. Personal communication.

NPS Report Published in Journal – Has it Been Implemented? Can it Be?

invasive lake trout in Yellowstone National Park

The National Park Service has a legal mandate to manage lands and waters under its jurisdiction so as to “preserve unimpaired” their natural and cultural resources (NPS Organic Act 54 U.S.C. § 100101, et seq.) Invasive species undermine efforts to achieve that mission. In 2000, the NPS adopted a program to coordinate management of invasive plants. It’s not as effective as needed – see the strategic plan.

However, only recently has NPS begun trying to prioritize and coordinate programs targetting the many animals and animal diseases which threaten Park resources. These organisms range from emerald ash borer and quagga mussels; to pythons, goats, and pigs; to diseases such as white nose syndrome of bats and avian malaria in Hawai`i.

In 2017, NPS released an internal study of the pervasive threat to Park resources posed by invasive animals and discussed steps to overcome barriers to more effective responses (Redford et al., 2017; full citation at end of this blog). The Chief of the Biological Resources Division initiated this report by asking a Science Panel to evaluate the extent of the invasive animal problem, assess management needs, review best practices, and assess potential models that could serve as a service-wide organizational framework. The report was to pay particular attention to innovative and creative approaches including, but not limited to, new genomic tools. I summarized the Panel’s findings and conclusions in a blog when its report appeared in 2017.

Significantly, the Panel’s final report states that “a general record of failure to control invasive species across the system” was caused principally by a lack of support for invasive species programs from NPS leadership.

This report has now appeared in the form of a peer-reviewed article in the journal Biological Invasions by Dayer et al. 2019 (full citation at end of this blog). Although nine of the ten authors are the same on both reports there are substantive differences in content. For example, the journal article reiterates the principal findings and conclusions of the Panel’s final report, but in less blunt language.

What’s Been Watered Down

The toning down is seen clearly in the statements some of the panel’s six key findings.

Finding #1

The panel’s report says: invasive animals pose a significant threat to the cultural and natural values and the infrastructure of U.S. national parks. To date, the NPS has not effectively addressed the threat they pose.

Dayer et al. says: the ubiquitous presence of invasive animals in parks undermines the NPS mission.

Finding #2

The panel’s report says: managing invasive animals will require action starting at the highest levels, engaging all levels of NPS management, and will require changes in NPS culture and capacity.

Dayer et al. says: coordinated action is required to meet the challenge.

Finding #4

The panel’s report states: effective management of invasive animals will require stakeholder engagement, education, and behavior change.

Dayer et al. says: public engagement, cooperation and support is [sic] critical.

Wording of the other three “key findings” was also changed, but these changes are less substantive.

Drayer et al. also avoid the word “failure” in describing the current status of NPS” efforts to manage invasive animal species. Instead, these authors conclude that the invasive species threat “is of sufficient magnitude and urgency that it would be appropriate for the NPS to formally declare invasive animals as a service-wide priority.”

Where the Documents Agree – Sort of

Both the Panel’s report and Dayer et al. state that invasive animal threats are under-prioritized and under-funded. They say that addressing this challenge must begin at the highest levels within the NPS, engage all levels of management, and will require investments from the NPS leadership. Even within individual parks, they acknowledge that staffs struggle to communicate the importance of invasive animal control efforts to their park leadership, especially given competition with other concerns that appear to be more urgent. And they admit that parks also lack staff capacity in both numbers and expertise.

Also, both the Panel’s report and Dayer et al. urge the NPS to acknowledge formally that invasive animals represent a crisis on par with each of the three major crises that drove Service-wide change in the past: over-abundance of ungulates due to predator control; Yellowstone fire crisis (which led to new wildfire awareness in the country); and recognition of the importance of climate change.

The Panel suggested ways to update NPS’ culture and capacity: providing incentives for staff to (1) address long-term threats (not just “urgent” ones) and (2) put time and effort into coordinating with potential partners, including other park units, agencies at all levels of government, non-governmental organizations, private landowners, and economic entities. Dayer et al. mention these barriers but does not directly mention changing incentives as one way to overcome them.

Both the Panel’s report and Dayer et al. suggest integrating invasive animal threats and management into long-range planning goals for natural and cultural landscapes and day-to-day operations of parks and relevant technical programs (e.g., Biological Resources Division, Water Resources Division, and Inventory and Monitoring Division).

What is Missing from the Journal Publication

The Panel’s final report noted the need for increased funding. It said that such funding would need to be both consistent and sufficiently flexible to allow parks to respond to time-sensitive management issues. It proposes several approaches. These include incorporating some invasive species control programs (e.g., for weeds and wood borers) into infrastructure maintenance budgets; adopting invasive species as fundraising challenges for non-governmental partners (e.g., “Friends of Park” and the National Park Foundation); and adopting invasive species as a priority threat. Dayer et al. do not discuss funding issues.

The final internal report envisioned the NPS becoming a leader on the invasive species issue by 1) testing emerging best management practices, and 2) educating visitors on the serious threat that invasive species pose to parks’ biodiversity. As part of this process, the authors suggest that the NPS also take the lead in countering invasive species denialism. Dayer et al. do not mention the issue of invasive species deniers.

Common Ground: Status of Invasive Animals in the Parks

The Panel’s report and Dayer et al. describe the current situation similarly:

More than half of the National parks that responded to the internal survey (245 of the 326 parks) reported problems associated with one or more invasive animal species.
The total number of species recorded was 331. This is considered to be an underestimate since staffs often lack the ability to thoroughly survey their parks – especially for invertebrates.
Invasive species threats to Parks’ resources have been recognized for nearly 100 years. The original report notes that 155 parks reported the presence of one or more exotic vertebrate species in 1977. At that time, exotic animals were the fourth most commonly reported source of threats. In 1991, parks identified 200 unfunded projects to address exotic species, costing almost $30 million.
Only a small percentage of non-native animal invasions are under active management. Dayer et al. stated that 23% have management plans at the park unit level, and only 11% are reported as being ‘‘under control”.
Individual parks have effective programs targetting specific bioinvaders (examples are described in Redford et al; a brief summary of these efforts is provided in my previous blog.

Common Ground on Some Solutions

The report and Dayer et al. promote the same steps to improve invasive animal management across the Service. Both note that the NPS is adopting formal decision support tactics to update and strengthen natural resource management across the board. More specific steps include

establishing a coordination mechanism that enables ongoing and timely information sharing.
mainstreaming invasive species issue across the NPS branches or creating a cross-cutting IAS initiative among the Biological Resources Division, Water Resources Division, Inventory and Monitoring Division, Climate Change Response Program, and the regional offices.

While both documents call on the NPS to develop and test emerging technologies, the Panel’s final report is more detailed, providing, in Table 5, a list of several areas of special interest, including remotely triggered traps, species-specific toxicants, toxicant delivery systems, drones, environmental DNA, and sterile-male releases. Dayer et al. mention eDNA and metabarcoding for ED/RR, biocontrol, and gene drives to control invasive pathogens. (Neither document discusses possible concerns regarding use of CRISPR and other gene-altering technologies, other than to say there would be public concerns that would need to be addressed.)

Both documents note the necessity of working with resource managers beyond park boundaries to detect and manage species before they arrive in parks. They note that developing and operationalizing such partnerships requires time and resources. Furthermore, invasive species prevention, eradication, and containment programs can be effective only with public support. They suggest strengthening NPS’ highly regarded public outreach and interpretation program to build such support, including through the use of citizen scientists.

The Panel’s final report said that the NPS should recognize that the condition of the ecosystem is the objective of efforts. Its authors recognized that achieving this goal might require reconsidering how ecosystem management is organized within NPS so interacting stressors (e.g., fire) and management levers (e.g., pest eradication/suppression, prescribed fire) would be addressed. For this, the NPS would need to create a focused capacity to address the pressing issue of invasive animals in such a way that fosters integrated resource management within parks, focusing on fundamental values of ecosystem states, and not eradication targets. Dayer et al. called for the same changes without specifically labelling “condition of the ecosystem” as the goal.

Publication of Dayer et al. prompted me to find out what progress the NPS has made in responding to the “key findings” in the Panel’s final report (neither publication calls them “recommendations”).

The National Park Service has acted on the recommendation to appoint an “invasive animal coordinator” within the Biological Resources Division. That person is Jennifer Sieracki. However, I wonder whether a person located in BRD is of sufficient stature to influence agency policy across all divisions. It is not clear whether there is active coordination with the national-level invasive plant coordinator.

Dr. Sieriaki responded to my query by noting the following new efforts 1) to improve outreach to partners and the public, and 2) to expand formal and informal partnerships with local, state, federal and tribal entities and local communities near parks.

NPS should soon finalize two formal partnerships with other agencies and organizations for outreach and management of invasive animal species.
NPS is working with researchers at the US Geological Survey to expand an existing modeling tool for identifying potential suitable habitat for invasive plant species to include invasive insects. This will help staff focus on the most likely locations for introductions and thus assist with early detection and control.
NPS has created a Community of Practice so NPS employees can seek each other’s advice on addressing invasive animal issues. A workshop of regional invasive species coordinators is planned for the coming months to guide direction of the service-wide program and identify other top priorities. (Seriacki pers. comm.)

I also wonder whether the NPS can achieve the top-level coordination and outreach to the public called for by both reports while complying with the terms of Public Law 116-9 – the John N. Dingle Jr. Conservation, Management, and Recreation Act, which was enacted a year ago. Title VII, Section 10(i) of this law limits spending to carry out invasive species program management and oversight to 10% of appropriated funds. Less than 15% may be spent on investigations (research), development activities, and outreach and public awareness efforts (Section 10(h)). The law does allow spending for investigations regarding methods for early detection and rapid response, prevention, control, or management; as well as inspections and interception or confiscation of invasive species to prevent in-park introductions.

For more information, see my previous criticism of NPS failure to address invasive species issues here.

Posted by Faith Campbell

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

See also my earlier discussion of the new legislation here.

SOURCES

Dayer, A.A., K.H. Redford, K.J. Campbell, C.R. Dickman, R.S. Epanchin-Niell, E.D. Grosholz, D.E. Hallac, E.F. Leslie, L.A. Richardson, M.W. Schwartz. 2019. The unaddressed threat of invasive animals in U.S. National Parks. Biol Invasions

https://doi.org/10.1007/s10530-019-02128-0

Redford, K.H., K. Campbell, A. Dayer, C. Dickman, R. Epanchin-Niell, T. Grosholz, D. Hallac, L. Richardson, M. Schwartz. 2017. Invasive animals in U. S. National Parks: By a science panel. Natural Resource Report NPS/NRSS/BRD/NRR—2017/1564. NPS, Fort Collins, Colorado. Commissioned by the NPS Chief of Biological Resources Division. https://irma.nps.gov/DataStore/DownloadFile/594922

Jennifer Sieracki, Invasive Animal Coordinator, Biological Resources Division, National Park Service

New USFS Report on Forest Health – Confusing Differences from Other Studies

ash killed by emerald ash borer
photo by Nate Siegert

USDA Forest Service has issued its annual summary of the nation’s forest health, based on various data sources.

The report seeks to provide status and trends at the national and regional levels as of 2017. It analyzes drivers of tree mortality including insects and pathogens, fire, and weather (especially drought). The report also discusses plant invasions in forests in the East. There is considerable discussion of emerging methods to improve data collection and analysis. Finally, it includes three case studies to illustrate the power of these approaches for analyzing forest health issues at specific sites:

• Decline of bishop pine (Pinus muricata) stands in California’s northern coastal areas;

• Impacts on naio (Myoporum sandwicense) on Hawaii’s Big Island of the myoporum thrips; and

• Impacts of increasing temperatures on Great Basin bristlecone pine (Pinus longaeva) communities.

Tree-Killing Insects and Pathogens

In 2017, the USFS Forest Health Protection (FHP’s) national Insect and Disease Survey (IDS) covered 55.1% of the total forested area of the lower 48 states. In Alaska, surveys covered about 7.3% of the total forested area. In Hawai`i, the surveys covered about 80.1 %.

The FHP program and partners in State agencies identified 63 mortality-causing agents and complexes that cumulatively affect 3.27 million hectares in the lower 48 states – 1.3% of the total 252 million hectares of forested land in these states. They also identified 50 defoliating agents and complexes affecting approximately 2.34 million hectares.

Most of the analyses focus on ecoregions developed by USFS scientists based on concepts put forward by Bailey (1995). Ecoregions are made up of regions with similar geology, climate, soils, potential natural vegetation, and natural communities. The area of the lower 48 states is divided into 190 ecoregions (see Chapter 1, esp. page 7).

Their damage, by type and level, was not evenly spread. Geographic hot spots of forest mortality were associated with bark beetle infestations in the West, and with emerald ash borer and southern pine beetle in the East. Hot spots of defoliation were associated with European gypsy moth and several native insects. Several native insects were the principal agents of defoliation in Alaska. In Hawai`i, about 37,000 hectares of mortality were listed officially as caused by an unknown agent, but the report attributes this mortality to rapid ‘ōhi‘a death.

The emerald ash borer was the most widespread single mortality agent in 2017, causing measurable tree mortality on 1.42 million hectares. In the program’s North Central region, 91% of the area suffering tree mortality was associated with the EAB. In one ecoregion – the Lake Whittlesey Glaciolacustrine Plain ecoregion (on the Ohio-Michigan border), about 73% of the mortality was caused by insects, especially the EAB. In a second, the Southwestern Great Lakes Morainal ecoregion (along the western shore of Lake Michigan in Wisconsin and Illinois), a quarter of the surveyed forest was experiencing exacerbated mortality due to EAB. The EAB also is causing mortality across 10,346 ha in the Northeast and more than 5,000 ha in the South.

However, heightened mortality (rates above 1%) in several Great Plains ecoregions were attributed largely to drought – even in the elm-ash-cottonwood forest type. However, such biological factors as oak decline, bur oak blight (Tubakia iowensis), Dutch elm disease, and native pests of ash were also significant. Emerald ash borer is mentioned rarely. I am confused by this finding – perhaps it reflects the fact that EAB has not yet been detected in North Dakota?

Other non-native pests that affect more than 5,000 ha in the lower 48 states were the Balsam woolly adelgid (20,758 hectares, primarily in the Northeast), beech bark disease (12,222 ha, primarily in the North Central region), oak wilt (9,573 ha, primarily in the North Central region), and sudden oak death (6,335 ha, in California). (All are described here.)

Still, despite the numerous and widespread presence of EAB and other non-native tree-killing insects and pathogens in the Central and Eastern States, in most areas, tree mortality is low relative to tree growth. Indeed, in nearly all the other North Central ecoregions, as well as those in the Northeast and South, 1% or less of the forested area was exposed to mortality agents. Hot spots associated with EAB were detected in Connecticut and eastern Kentucky.

Oak wilt was reported as a mortality agent in Michigan and Texas.

I am confused by the discrepancy between the findings of the Forest Health Protection (FHP’s) national Insect and Disease Survey and studies by other USFS scientists – as reported in earlier blogs. Thus, Randall Morin, speaking at the 81^st Northeastern Forest Pest Council in March 2019, reported detecting an approximate 5% increase in mortality – measured by tree volume – nation-wide. The greatest increases in mortality above the background rate was the four-fold increase for redbay and the three-fold increase for ash trees (from 0.8% to 2.7%), beech (from 0.7% to 2.1%), and hemlock (from 0.5% to 1.7%). (The increase for ash was incorrectly stated in my earlier blog).

Other studies by, among others, Guo et al. 2019 and the Potter studies discussed the threat – present and future – rather than current changes in mortality levels. See my blog here.

All note that their estimates are probably underestimates.

All the studies agree that EAB, European gypsy moth, and oak wilt threaten the greatest number of species (Potter et al. 2091b).

However, these reports also note the widespread presence of other damaging invaders – several of which don’t appear in the FHP survey. These include white pine blister rust (present in 94% of the potential hosts’ ranges; 955 counties); and dogwood anthracnose (in 609 counties in the East; plus uncalculated number of counties in the West) (Morin and the western counties were not calculated) (FIA “dashboards”).

whitebark pine in Crater Lake National Park killed by white pine blister rust
photo by F.T. Campbell

Data available from the West are less suited to the kind of analysis the FHP report used (for an explanation, see chapter 5). In the FHP West Coast and Interior West regions, principal mortality agents were bark beetles, drought, and fire. Some ecoregions suffered up to 5% mortality. Using a different measurement tool — annual mortality volume to gross annual volume growth (MRATIO) – the Southern California Mountain and Valley Ecoregion had the highest damage – at 2.50. This was attributed to a combination of prolonged drought, bark beetles, and fire.

Of 50 defoliation agents and complexes across the lower 48, the most widespread was the European gypsy moth. Across the continent, its impacts were detected on 39% of the total forested area of the lower 48 states (913,000 ha). Defoliation was particularly severe in the Northeast Region — again primarily by the European gypsy moth (869,000 ha). Other non-native defoliation agents affecting more than 5,000 ha in the lower 48 were the larch casebearer (25,891 ha in the North Central region, another 7,400 ha in the West Coast region) and winter moth (12,760 ha in the Northeast region). (The last is described here.)

The report concedes that death of tree species that are scattered in multi-species forests, such as most of the victims of non-native forest pests in the East, are not easily detected by the methodology the USFS uses. Examples cited by the report include emerald ash borer, hemlock woolly adelgid, laurel wilt, Dutch elm disease, white pine blister rust, and thousand cankers disease. (All are described here.)

Hence the authors advise decision-makers to use other forest health indicators in addition to this report.

I have already reported on studies by Morin, Liebhold, and colleagues and Kevin Potter and colleagues. Each finds ways to analyze Forest Inventory and Analysis (FIA) data to provide more detail on mortality caused by non-native insects and pathogens.

Invasive Plants

Invasive plants have already invaded a large proportion of rural forest in the East. Christopher Oswalt and colleagues used FIA data to assess the plant invasion status in 13 bioregions covering most of the temperate and boreal forests in the Eastern U.S. I blogged about Oswalt’s studies previously. Their findings are also reported here, in chapter 6:

Data were analyzed on 71 invasive plant species;
Half of the total area of 74 forest types was found to be invaded;

Plant invasions are almost twice as likely on privately than publicly owned land. Ownership alone was the deciding factor for the most-invaded forest types.)

The types of forest most heavily invaded were loblolly-shortleaf pine (61%), elm-ash-cottonwood (59%) oak-pine and oak-hickory (each 58%). The forest types least invaded were northern types: spruce-fir (20%), aspen-birch (32%), and maple-beech-birch (34%).

However, several forest type groups were excluded from the study; these included other eastern softwoods; pinyon-juniper; exotic softwoods; other hardwoods; woodland hardwoods; tropical hardwoods; and exotic hardwoods, and Fraser fir.

One-third of publicly owned (federal, state, and local) forest land was invaded, compared to 46% of private corporate forest and 59% of private non-corporate forest.

SOURCES

Bailey, R.G.. 1995. Descriptions of the ecoregions of the United States. 2d ed. Miscellaneous Publication No. 1391. Washington, D.C.: U.S. Department of Agriculture Forest Service. 108 p.

Fei, S., R.S. Morin, C.M. Oswalt, and A.M. 2019. Biomass losses resulting from insect and disease invasions in United States forests

Guo, Q., S. Feib, K.M. Potter, A.M. Liebhold, and J. Wenf. 2019. Tree diversity regulates forest pest invasion. PNAS. www.pnas.org/cgi/doi/10.1073/pnas.1821039116

Morin, R.S., K.W. Gottschalk, M.E. Ostry, A.M. Liebhold. 2018. Regional patterns of declining butternut (Juglans cinerea L.) suggest site characteristics for restoration. Ecology and Evolution.2018;8:546-559

Morin, R. A. Liebhold, S. Pugh, and S. Fie. 2019. Current Status of Hosts and Future Risk of EAB Across the Range of Ash: Online Tools for Broad-Scale Impact Assessment. Presentation at the 81^st Northeastern Forest Pest Council, West Chester, PA, March 14, 2019

Potter, K.M., B.S. Crane, W.W. Hargrove. 2017. A US national prioritization framework for tree species vulnerability to climate change. New Forests (2017) 48:275–300 DOI 10.1007/s11056-017-9569-5

Potter, K.M., M.E. Escanferla, R.M. Jetton, and G. Man. 2019a. Important Insect and Disease Threats to United States Tree Species and Geographic Patterns of Their Potential Impacts. Forests. 2019 10 304.

Potter, K.M., M.E. Escanferla, R.M. Jetton, G. Man, and B.S. Crane. 2019b. Prioritizing the conservation needs of United States tree species: Evaluating vulnerability to forest insect and disease threats. Global Ecology and Conservation. (2019)

USDA Forest Service. Forest Health Monitoring: National Status, Trends, and Analysis 2018. General Technical Report SRS-239. June 2019. Editors Kevin M. Potter Barbara L. Conkling

Will Chaos Replace International Trade Rules?

The United Nations has designated 2020 as the International Year of Plant Health. I welcome the possibility of heightened awareness – although it could result in promises that are more optimistic than facts warrant.

APHIS and probably other national and international phytosanitary bodies have planned events to draw attention to the importance protecting of plant health. For example, the APHIS website lists numerous meetings, some of which are special events, e.g., Safeguarding 2020: North American Safeguarding and Safe Trade Conference in Washington, DC, in August. Another event is a continuation of the Entomological Society of America’s Grand Challenges event, “Pre-border Prevention: A New Conversation on Invasive Pest Pathways Through Trade” – which will take place in Orlando in November.

I repeat that we should support the international phytosanitary community’s efforts to raise political leaders’ awareness of the importance of preventing phytosanitary disasters.

However, at the same time, the international system that, for more than two decades, has governed trade, with all its associated phytosanitary risks and regulations, is falling apart.

The World Trade Organization – which is the basis for international trade rules – is under unprecedented threat. United States has blocked nomination of individuals to the World Trade Organization’s Dispute Panel. As of December 10, 2019 the Panel no longer has a quorum. As a result, experts expect countries to revert to the pre-WTO practice of bullying trade “partners” with whom they have a quarrel. They will probably erect tariffs and other barriers in order to force other parties to concede. Phytosanitary requirements might again be governed by individual countries’ bilateral agreements, leading to confusion and perhaps a “race to the bottom” in the name of facilitating trade.

Collapse of the WTO rules alarms me – despite my having criticized WTO restrictions on strong national phytosanitary measures over the past 25 years. (The restrictions were imposed by the WTO’s Agreement on the Application of Sanitary and Phytosanitary Measures – the SPS Agreement). For more details, see Fading Forests II. All-out country vs. country trade battles seldom put a priority on preventing the movement of pests. At least under WTO SPS, there has been a process for addressing pest problems.

Most phytosanitary issues – including development of international standards – are addressed under the International Plant Protection Convention. The IPPC is a separate organization from the WTO, so it might continue to function with fewer disruptions. Still, much of its clout comes from its recognition by the WTO SPS as the standard-setting body for plant health matters.

Of course, there are benefits associated with individual countries’ acting independently. Might the current collapse of trade rules allow the U.S. to adopt more stringent regulations governing introduction pathways of concern to us — for example, wood packaging? Can we hope that an administration focused on “America First” take aggressive phytosanitary actions to protect our agriculture and environment?

Unfortunately, I see no indications that the U.S. Department of Agriculture – much less other agencies – might seize this opportunity.

The United Kingdom has an even greater opportunity to act independently, since it is “Brexiting” the European Union in January 2020. In theory, the UK is now free to adopt its own phytosanitary measures. A House of Lords committee held extensive hearings to explore options in 2018.

While eminent plant pathologist Clive Brasier and others urged the UK to adopt more stringent rules based on a precautionary approach – for example, by banning imports of semi-mature trees with large root balls – the committee noted that the British government has often said that it wants to maintain “seamless” trade with the EU. It therefore seems unlikely that the UK will seize this opportunity to erect more effective phytosanitary barriers to prevent pest introductions to the islands.

Meantime, the European Union is making some mildly encouraging changes. Europe (including the UK) has the highest number of introduced tree-killing non-native pathogens of any continent – five times more than North America (Ghelardini 2017). Europe has a much more leaky phytosanitary system for plant imports than does the United States. See also Jung et al. (2015), Roy et al. (2014), the Montesclaros Declaration.

participants at the Montesclaros negotiation

In response to growing awareness of the plant pest threat, EU officials have gone through a multi-year process to strengthen phytosanitary rules governing movement of plants for planting (living plants, such as nursery stock). The process was described in Klapwijk et al. (2016) and discussed in my blog in October 2016. The new rules took effect in December 2019. The new European Commission regulation simplifies and harmonizes the “plant passport” system, under which plants are moved among EU member states. Plant imports that pose the greatest risk – called “priority pests” – are subject to enhanced measures concerning surveys, action plans for their eradication, contingency plans and simulation exercises. Plants for planting and plant products being imported into the EU will be subject to varying levels of restrictions, including prohibition of importation of those posing the highest risk. Less risky plants must be accompanied by a phytosanitary certificate issued by the phytosanitary agency of the exporting country (House of Lords report). The new system no longer depends on a list of harmful plant pests, but instead “sets out the conceptual nature of quarantine pests” and empowers the Commission to adopt measures to control certain pests (Klapwijk et al. (2016)).

Three years ago, Klapwijk et al. (2016) praised the new approach as a significant step forward. However, they note that the new rules still don’t provide for precautionary assessments of high-risk commodities. Nor do they actually restrict import of the highest-risk commodities, such as imports of large plants or plants in soil (my emphasis). Such restrictions still must be enacted separately. Organisms whose pest status is unknown will continue to be allowed into the EU. (See discussions of the impact of failing to curtail imports of “unknown unknowns” by Brasier (2008) and in Fading Forests II.

(While the U.S. also does not address organisms with unknown pest potential, it is much more stringent regarding sizes of plants, presence of soil or other growing media, and other issues. Furthermore, it has the NAPPRA process, which facilitates a more rapid response to emerging pest threats.)

Posted by Faith Campbell

SOURCES

Brasier CM. 2008. The biosecurity threat to the UK and global environment from international trade in plants. Plant Pathology 57: 792–808.

Ghelardini, L., Luchi, N., Pecori, F., Pepori, A.L., Danti, R., Della Rocca, G., Capretti, P., Tsopelas, P. , Santini, A. 2017. Ecology of invasive forest pathogens. Biological Invasions. June 2017

Jung, T. et al. 2015 “Widespread Phytophthora infestations in European nurseries put forest, semi-natural and horticultural ecosystems at high risk of Phytophthora disease” Forest Pathology. November 2015;

Klapwijk, M., Hopkins, A.J.M., Eriksson, L. Pettersson, M., Schroeder, M., Lindelo¨w, A., Ro¨nnberg, J. Keskitalo, E.C.H., Kenis, M. 2016. Reducing the risk of invasive forest pests and pathogens: Combining legislation, targeted management and public awareness. Ambio 2016, 45(Suppl. 2):S223–S234 DOI 10.1007/s13280-015-0748-3

Roy, B.A., Alexander, H.M., Davidson, J., Campbell, F.T., Burdon, J.J., Sniezko, R., and Brasier, C. 2014. Increasing forest loss worldwide from invasive pests requires new trade regulations. Frontiers in Ecology https://cpb-us-e1.wpmucdn.com/blogs.uoregon.edu/dist/1/11561/files/2018/07/Roy-et-al-2014-Frontiers-12p4898.pdf

APHIS seeks comments on NAPPRA proposals

APHIS proposes to place numerous plant taxa on its list of plants for planting whose importation is “not authorized pending pest risk analysis” (NAPPRA). Unfortunately, the proposal comes too late for some pests; doesn’t apply to at least one significant pathway of entry; excludes some highly damaging newly detected pathogens; and too often applies only to agricultural pests. Nevertheless, the proposal is worth supporting – while mentioning those caveats.

APHIS is accepting comments on the data sheets justifying the proposed listings until 24 January. The Data sheets can be obtained here. We encourage you to comment.

APHIS’ Regulatory Framework

Under APHIS’ regulations in ‘‘Subpart— P4P’’ (7 CFR 319.37 through 319.37–14 …), APHIS prohibits or restricts the importation of “plants for planting” – living plants, plant parts, seeds, and plant cuttings – to prevent the introduction of “quarantine pests” into the US. A “quarantine pest” is defined in § 319.37–1 as a plant pest or noxious weed that is of potential economic importance to the United States and not yet present in the country, or is present but not widely distributed and is being officially controlled.

§ 319.37–2a authorizes APHIS to identify those plant taxa whose importation is not authorized pending pest risk analysis (NAPPRA) in order to prevent their introduction into the United States. If the plant taxon has been determined to be a probable invasive species, its importation is restricted from all countries and regions. If the taxon has been determined to be a host of a plant pest, the list includes (1) names of affected taxa, (2) the foreign places from which these taxa’s importation is not authorized, and (3) the quarantine pests of concern.

APHIS finalized a rule giving itself the authority to place plant taxa in the NAPPRA program in 2011; it has previously used this process twice to restrict imports of plant taxa – most recently in 2017.

Plant Taxa that Host a Damaging Pest or Pathogen

The proposed restrictions would apply to two plant families — Myrtaceae taxa (when destined to Hawai`i), and the subfamily Bambusoideae (bamboo); plus 43 other taxa that are likely to transport damaging insects, pathogens, or viruses.

`ohi`a in bloom; National Park Service photo

1) All plants in the family Myrtaceae that are destined for Hawai`i.

The proposed restriction is intended to counter the risk that additional strains of the `ohi`a rust pathogen Austropuccinia psidii might be introduced and prove more damaging to native Hawaiian vegetation than the strain already present on the islands. (See description of `ohi`a rust here.

`Ohi`a rust was detected in Hawai`i in 2005. Detection was followed by scientific studies to determine whether different strains exist and, if so, whether they posed a threat to Hawaiian vegetation. Under the circumstances, the proposed action is disturbingly tardy.

Worse, the pathogen was probably introduced to Hawai`i on imports of flower and foliage cuttings, rather than entire plants or propagules. Unfortunately, the section of APHIS’ regulations that governs imports of plants that can be grown (“plants for planting”) does not apply to imports of cuttings (including flowers). In the Federal Register notice, APHIS says it will issue a separate proposal to tighten regulations on imports of cuttings and flowers. I hope they move expeditiously on this rulemaking – which will be more cumbersome in even the best case because it requires a full rulemaking, not the expedited notice and comment process allowed under the NAPPRA program.

It is disturbing that the proposal does not include the two Ceratocystis species that are killing millions of `ohi`a trees in Hawai`i link to DMF writeup. It is true that these were identified relatively recently – in 2017. However, other plant taxa proposed for inclusion in the NAPPRA category were also detected or determined to be the cause of a disease as recently as 2017.

`ohi`a trees killed by Ceratocystis; Island of Hawai`i; photo by J.B. Friday, University of Hawai`i

2) APHIS proposes to include another pest that might attack a native Hawaiian plant, Phyllanthus distichus. Another species in the genus, P. saffordii is endemic to Guam; it is listed as endangered under the federal Endangered Species Act. Other Asian gooseberries in the Phyllanthus genus are grown in backyards in Hawai`i and other semitropical areas and there is some interest in expanding commercial uses.

3) APHIS proposes to include several plant taxa important in tropical agriculture because of the threat that imports of those plants will transport diseases or pests. These include two pathogens that threaten production of macadamia nuts (Neopestalotiopsis macadamiae and Pestalotiopsis macadamiae); and pests of breadfruit, lychee, and durian.

4) Some of the plant taxa that APHIS hopes to protect from new pests or pathogens by placing hosts in the NAPPRA category are invasive. These include – in Hawai`i – Syzygium jambos (rose apple). It is named as a host of two pests targetted by the proposed action – the `ohi`a rust pathogen Austropuccinia psidii and armored scale insect Myrtaspis syzygii.

Euonymus bungeanus (winterberry euonymus) is in the same genus as several plant species invasive across the continent. APHIS proposes to restrict its importation in order to prevent introduction of the Euonymus yellow mottle associated virus (EuYMaV), which has only that plant species as a known host.

5) APHIS also proposes to add to the NAPPRA category several plant taxa that could transport the Elm mottle virus (EMoV) because of the threat the virus poses to several European elm species – and presumably also to North American elms. The virus also attacks hydrangea and lilac.

In several cases, some of the primary hosts of the target pest or pathogen are already in NAPPRA for other reasons from some origins. Nearly all the woody hosts are already required to undergo post-entry quarantine – which presumably APHIS now considers to provide inadequate protection.

6) Also proposed are diseases or pests that threaten grapevines and tomatoes.

Several of the proposed taxa are already present in the US (including `ohi`a rust). Other proposed listings appear to be precautionary actions to protect plant taxa that USDA expects to be increasingly important economically in the future.

Plant Taxa Proposed Because They Appear Likely to be Invasive

APHIS has proposed 26 plant taxa for inclusion in the NAPPRA category because they might themselves be invasive. Of greatest ecological concern are two taxa of mangroves which had been introduced by early 20^th century plant explorer David Fairchild and have since been detected to be spreading in South Florida. These are Bruguiera gymnorhiza and Lumnitzera racemose. Also of concern is a vine that grows in Asian and Indian Ocean mangrove forests, Derris trifoliate.

Several proposed species are aquatic plants that can form dense mats.

Other taxa proposed appear to possibly threaten pastures or other agricultural uses.

Posted by Faith Campbell

Sudden Oak Death update

*P. ramorum*-infected rhododendron plants
Indiana Department of Natural Resources

As you may remember, in June and July I blogged about a troubling outbreak of sudden oak death pathogen Phytophtora ramorum in the nursery trade. The discovery was made by Indiana authorities, who carefully inspected plants being sold in the state. They discovered that rhododendron plants imported from an Oklahoma wholesaler included infected plants.

By the end of May, Indiana state inspectors had destroyed more than 1,500 rhododendrons and prohibited sale of another 1,500 plants pending determination of their health. [source: Indianapolis Star 29 May, 2019] Over the next months, APHIS determined that more than 50 rhododendron plants found in Indiana nurseries had been infected [California Oak Mortality Task Force Newsletter August 2019 ].

In the spring and summer, APHIS and state authorities alerted 28 states that they might have received plants from the suspect sources – the suppliers of the Oklahoma wholesaler — one nursery in Washington State and two nurseries from Canada. In the end, APHIS determined that plants exposed to the pathogen had been sent to 18 states – Alabama, Arkansas, Iowa, Illinois, Indiana, Kansas, Kentucky, Michigan, Missouri, Nebraska, North Carolina, Ohio, Oklahoma, Pennsylvania, Tennessee, Texas, Virginia, and West Virginia. As of late July, P. ramorum-positive nursery stock had been detected in nurseries in seven of these (Iowa, Illinois. Indiana, Kansas, Missouri, Nebraska, Oklahoma) plus Washington [California Oak Mortality Task Force Newsletter August 2019].

As I pointed out in the earlier blog, this is just the latest of several occasions since 2004 in which infected plants have been widely distributed by the nursery trade, despite federal and state regulations. Also, at the time of this outbreak, APHIS had just formalized several steps relaxing the regulations that had been implemented through Federal Orders adopted in recent years. (See the earlier blog for details.)

APHIS actions

I wonder at APHIS’ delay in explaining to stakeholders the situation– and what it is doing about it! APHIS provided minimal information to me – by email rather than a public announcement; this email came a month after Indiana announced detection of the pathogen to the public (as reported in my blog). APHIS issued an official notice even later, in mid-July [California Oak Mortality Task Force (COMTF) Newsletter August 2019]. Neither notice was timely, given the serious risks to both nursery and naturally growing plants from the pathogen.

It is now November and principal questions have not yet been answered. How did the inspection systems in Washington and British Columbia fail to detect the outbreaks before the plants were shipped? This lapse is especially worrisome because APHIS requires testing of soil and standing water, not just visual inspection of plants. Furthermore, rhododendrons are well known to be vulnerable to the pathogen and therefore are a specified focus of detection efforts!

The October COMTF newsletter includes a report by the Washington State Department of Agriculture that a nursery found positive in May will carry out a Critical Control Points (CCP) assessment. An “extensive fall certification survey” will also be conducted. Presumably, these efforts are aimed at determining how the outbreak occurred.

The Canadian Food Inspection Service (CFIA) described – briefly – its nationwide survey program. CFIA reported that one nursery was determined to be P. ramorum-positive in 2018, three in 2019. CFIA says that trace-forwards and trace-backs demonstrate that no Canadian nursery shipped infected plants to the U.S. in 2018 or 2019. So, apparently, none of the infected plants came from the Canadian nurseries.

I hope that Washington State and APHIS will soon determine the probable causes of the outbreak. APHIS should then promptly inform all stakeholders and engage them in developing improved programs and policies to minimize the likelihood that similar problems will occur again.

Phytosanitary officials from the states are apparently also seeking additional information from APHIS about what went wrong and how the agency plans to fix the problems. See the resolution adopted by the National Plant Board here

California Action

A much more positive development is that the California Department of Food and Agriculture (CDFA) has introduced a Voluntary P. ramorum Pre-Quarantine Program. This is a voluntary inspection program specifically for nurseries in California counties that are not currently regulated for the pathogen – but that might be put under regulation in the future. Inspections and sampling will be administered by county regulatory officials and samples will be processed by the CDFA Plant Pest Diagnostics Center. If P. ramorum is detected at a participating nursery, the PQP nursery may become a federally regulated establishment.

Broader Implications

As I pointed out in Fading Forests III, APHIS and the states have struggled to prevent spread of tree-killing pests once they have established in the country. Even regulated pests – such as Phytophthora ramorum and the emerald ash borer — have escaped the regulations. APHIS and/or the states have chosen not to engage on other pests, such as redbay ambrosia beetle and laurel wilt disease and the polyphagous and Kuroshio shot hole borers and associated Fusarium fungus. In other cases, some states have acted – and asked APHIS to not get involved – e.g., thousand cankers disease of walnut. This situation heightens the risk to our urban, rural, and wildland forests. Americans need a hard-nosed discussion of how we can improve coordinated efforts to prevent pests’ spread.

Posted by Faith Campbell

ISPM#15 – The Stamp is Not Effective as a Clue to Whether Wood Packaging is Pest-Free

For more than a decade, most countries in the world have required that crates, pallets, spools, and dunnage made from wood be treated in accordance with the requirements of the International Standard for Phytosanitary Protection (ISPM)#15 that this treatment be certified by applying an approved stamp to the wood. The goal of the program is to “reduce significantly the risk of introduction and spread of most quarantine pests that may be associated with that material.”

However, experience and studies in both the United States and Europe demonstrate that the ISPM#15 stamp is not a reliable indicator of whether the wood packaging is pest-free.

1) In the United States, over a period of nine years – Fiscal Years 2010 through 2018 – U.S. Customs and Border Protection (CBP) detected 9,500 consignments harboring a pest in a regulated taxonomic group. Of the shipments found with infested wood packaging, 97% bore the ISPM#15 mark (See Harriger reference at the end of the blog). The wood packaging was from nearly all trading countries. 2) In the past two years, CBP inspectors have repeatedly found pests in dunnage bearing the ISPM#15 mark – as reported by U.S. importers of “break bulk” cargo into Houston. While most of the criticism of non-compliant wood packaging refers to countries in Asia and the Americas, at least one of the Houston importers obtains its dunnage in Europe.

3) In Europe, a two-year intensive survey of wood packaging associated with shipments of stone from China to the 28 European Union countries over the period 2013-2016 again found that 97.5% of consignments found to harbor pests bore the ISPM#15 mark (Eyre et al. 2018). The scientists concluded that the ISPM-15 mark was of little value in predicting whether harmful organisms were present. (Eyre et al. 2018, p. 712)

As I have noted in previous blogs and policy briefs, the only in-depth study of the “approach rate” of pests in wood packaging, based on data which is now a decade old, found that 0.1% of incoming wood packaging transported a regulated pest (Haack et al. 2014). Given current trade volumes, as many as 17,650 containers per year (or 48 per day) transporting tree-killing insects might be entering the U.S. (My calculation of this estimate is explained in the blog on “risks of introduction” here.)

The Haack study excluded imports from Mexico, Canada, and China. The first and third countries have records of poor compliance with ISPM#15 requirements, so the “approach rate” for all incoming shipments might well have been higher.

The study of European imports focused on shipments of stone from China – which were deliberately chosen to represent types of imports presenting a high risk of transporting pests. Across Europe, over the four-year period, quarantine pests were detected in 0.9% of the consignments – somewhat higher than the U.S. number, as could be expected. However, there were large variations among participating countries’ findings. Austria and France found 6.95% of consignments inspected were infested, while half of European Union countries found none!

These differences demonstrate the importance of thorough inspections.

The data also indicate that the problem is not decreasing. Austria detected pests in nearly one-fifth (19.6%) of inspected shipments in 2016 – the final year of the study! However, during that same year, only 1.5% of wood packaging lacked the ISPM#15 mark.

So How Should the International Phytosanitary Community React to This Failure?

Data cited in numerous studies indicate that ISPM#15 has probably succeeded in reducing the presence of pests in wood packaging. This progress is good – but insufficient. Our forests need further reductions.

In the meantime, however, the international standard has demonstrably failed to provide a secure method to evaluate the pest risk associated with wood packaging accompanying any particular shipment. The presence of the stamp on pieces of wood packaging does not reliably show that the wood is pest-free. Officials need to determine why. Is it fraud? That would mean deliberately placing the stamp on wood that had not been treated, which U.S. CBP staffers think is occurring (Harriger). The European Union audit team that visited China also thought they detected instances of fraud. They concluded that “the current system of official controls in China does not adequately ensure that SWPM which forms part of consignments of goods exported to the EU is marked and treated according to ISPM No. 15” (Eyre et al. 2018, p. 713). On the other hand, the US importers in Houston say they are pressing their European suppliers to provide pest-free dunnage.

What more could we ask them to do to ensure that they are not receiving fraudulently marked materials?

Perhaps the problem has a different cause. Are the treatments themselves are less effective than expected? One APHIS study found that twice as many larvae reared from wood treated by methyl bromide fumigation survived to adulthood than larvae reared from heat-treated wood; the reason is unclear (Nadel et al. 2016). Unfortunately, it is apparently impractical to determine whether wood was heat treated by looking for changes in the chemical profile of the wood (Eyre et al. 2018).

Nor can we expect inspection of 100% of all risky consignments or detection of 100% of quarantine pests in those consignments that are inspected. Therefore, the European study authors concluded that inspection is best considered as a means of gathering evidence of risk and a deterrent rather than a means of completely preventing pest movement (Eyre et al. 2018).

The European study authors called for review of ISPM#15 as a control system and to investigate compliance at the source (Eyre et al. 2018 p. 714).

What is APHIS doing?

As I have noted previously – here and here – while U.S. CBP adopted a policy in 2017 under which it can penalize importers for each consignment not in compliance with ISPM#15, APHIS has not followed Custom’s lead on this. Instead, APHIS will apply a penalty only when an importer has accrued five violations over the period of a year. (The two agencies are acting under separate legal authorities.) This is yet another example of APHIS taking a less protective stance – as I described in earlier blogs.

Since Customs is now applying the letter of the law, the most useful step would probably be for APHIS (and the USDA Foreign Agriculture Service) to ramp up efforts to assist U.S. importers which are trying to comply. The importers are begging USDA to provide better information to them about foreign suppliers of wood packaging and dunnage. Which have good vs. poor records? USDA could also help importers trying to complain about specific shipments to the exporting countries’ National Plant Protection Organizations (NPPOs; departments of agriculture). In addition, APHIS could augment its pressure on foreign NPPOs and the International Plant Protection Convention more generally to ascertain the reasons ISPM#15 is failing and to fix the problems.

APHIS has not been idle. The North American Plant Protection Organization (including Canada and Mexico) has sponsored two workshops intended to educate NPPOs and exporters in Asia and the Americas about the standard’s requirements. APHIS is planning to address wood packaging in an international symposium organized under the auspices of the International Year of Plant Health in July 2020 – I will provide details when they become available.

APHIS is collaborating with the Entomological Society of America to host a workshop on wood packaging at the ESA annual meeting in November 2020 – I will provide details when they become available. The Continental Dialogue on Non-Native Forest Insects and Diseases plans to link its annual 2020 meeting to this workshop.

More immediately, the Continental Dialogue on Non-Native Forest Insects and Diseases will have presentations on the wood packaging issue at its annual meeting in just 11 days! in Cleveland

In preparation for the 2020 meetings, APHIS should fund more studies and audits of wood packaging to document the current efficacy of the standard (that is, the pest approach rate); remember, Haack’s study relied on data which are now a decade old. Not only has time passed … Both the standard and U.S. enforcement policies have changed since 2009.

Significance of the Wood Packaging Problems

The apparent failure of the ISPM#15 standard to provide a reliable means to certify treatment raises obvious issues regarding the risk of pest introductions. However, the implications are much broader.

The premise of the international phytosanitary system – the Agreement on the Application of Sanitary and Phytosanitary Standards (SPS Agreement) and International Plant Protection Convention (IPPC) – is that importing countries should rely on exporting countries to take the actions necessary to meet the importing countries’ plant health goals. The ISPM#15 experience casts doubt on this premise. The exporters are not reliably ensuring the cleanliness of their wood packaging. Worse, wood packaging is easier to treat than fruits, vegetables, and living plants (plants for planting). The latter commodities are much more easily damaged or killed by treatments than are boards or even logs – which are, after all, already dead! (A longer discussion of the SPS Agreement and IPPC is found in Chapter III of Fading Forests II, available here.

I hope that the international phytosanitary community will take advantage of the heightened attention and effort associated with the International Year of Plant Health in 2020 to re-examine all aspects of the current global phytosanitary system.

Posted by Faith Campbell

SOURCES

Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)

Kevin Harriger, US CBP. Presentations to the annual meetings of the Continental Dialogue on Non-Native Forest Insects and Diseases over appropriate years. See, e.g., https://continentalforestdialogue.org/continental-dialogue-meeting-november-2018/

Nadel, N., S. Myers, J. Molongoski, Y. Wu, S. Linafelter, A. Ray S. Krishnankutty, and A. Taylor. 2016. Identificantion of Port Interceptions in Wood Packaging Material: Cumulative Progress Report, April 2012 – August 2016

https://www.joc.com/breakbulk/ispm-15-enforcement-leaves-shippers-no-good-nswers_20190717.htmlhttps://www.joc.com/breakbulk/enhanced-enforcement-ispm-15-costing-us-importers-millions_20190725.html

New Study: Non-Native Pests Threaten 2/5ths of 48 States’ Forest Biomass

redbay in Georgia killed by laurel wilt
photo by Scott Cameron

In August I posted a blog summarizing information on pest introductions and impacts gleaned over my nearly 30 years of engagement. Already, I need to post an update, with an alarming estimate of introduced pests’ impacts across the continent.

Fei et al. 2019 (see the full citation is at the end of this blog) estimate that the 15 most damaging introduced species threaten 41.1% of the total live forest biomass in the 48 conterminous states.

In fact, this might be an underestimate of the pests’ impacts on biomass loss. Fei et al. (2019) note several limitations in their data that might result in such an underestimate. These include:

1) Mortality rates – and impacts – may increase over several decades following the initial invasion.

2) For pests already established throughout nearly all their potential ranges, pest-induced biomass loss could be substantially underestimated because most of their hosts died long ago, before the FIA data began to be collected. Consequently, the actual loss of these tree species from the forest is much greater than has been measured by the study’s methods.

3) Mortality rates vary among species and regions, which might introduce errors. They cite European gypsy moth, in which relatively small areas of heightened mortality due to repeated defoliations are swamped by lower mortality rates across the chosen measurement area.

4) They considered only tree mortality, not crown or root dieback or reductions in tree growth.

5) They did not estimate carbon release to the forest floor as a result of defoliation.

6) Pest-related mortality rates may be underestimated due to salvage – although the authors did not observe evidence of substantial salvage efforts for most of these pests.

7) The data did not include losses from urban tree mortality.

Fei et al. estimate that more than 450 pests are established in the 48 conterminous states. This study excluded pests attacking palms; trees on U.S. Pacific and Caribbean islands; and pests native to portions of North America that are causing severe damage in naïve hosts – e.g., goldspotted oak borer. I did include the latter groups in my slightly larger estimate laid out in my August blog.

Fei et al. base their analysis on 83 of the introduced pest species considered to cause substantial effects on tree health and productivity and sometimes extensive tree mortality. (In my August blog, I described findings by another study by Guo et al (2019) that counted 91 species in that category.)

Fei et al. build on studies by a group of USDA Forest Service (USFS) scientists that I described in an earlier blog.

This team found that, nation-wide, non-native forest pests are causing an approximate 5% increase in total annual mortality by tree volume. They based their studies on analysis of 92,978 long-term plots maintained by the USDA Forest Inventory and Analysis program.

As noted above, the article cannot capture the full range of mortality in species affected by pests introduced decades ago. Chestnut blight, white pine blister rust, Port-Orford-Cedar root disease, beech bark disease, butternut canker, dogwood anthracnose, and European gypsy moths had all killed millions of trees before the USFS forest inventory plots were established. Fei et al. do form a solid basis for measuring some of the current impacts and projecting future ones.

The focus of the new article is on the amount of carbon being transferred from live biomass to dead organic matter as a result of the increased mortality caused by the 15 species with the highest impacts. This is arguably a more quantifiable measure of pests’ impacts than others’ approaches. Here, I focus more narrowly on the documentation of exacerbated mortality as measured by the loss of biomass. Added together, these 15 species have caused an additional (i.e., above background levels) tree mortality rate of 5.53 TgC per year [defined as terragrams of carbon]. This estimate of annual conversion of live biomass to dead wood is similar in magnitude to that attributed to fire (5.4 to 14.2 TgC per year) (Fei et al. 2019). Yet the fire threat gets much more attention – for both prevention and management.

It is important to remember that conversion of living biomass to dead wood does not result in an immediate release of carbon to the atmosphere. Atmospheric releases take place through decomposition which is both gradual and takes place at varying rates. Some of the carbon will remain in the soil. And, over time, some of the carbon storage capacity will be restored by compensatory growth in unaffected trees and the recruitment of new regeneration – although this faster growth is delayed by as much as two or more decades after pest invasions begin (Fei et al. 2019).

American elm being killed by “Dutch” elm disease
photo by Cheryl Kaiser, University of Kentucky; bugwood.org

The 15 species of introduced pests used in this analysis are laurel wilt disease, chestnut blight, butternut canker, dogwood anthracnose, emerald ash borer (EAB), Dutch elm disease, red pine scale, beech bark disease, hemlock woolly adelgid, balsam woolly adelgid, European gypsy moth, white pine blister rust, green spruce aphid, sudden oak death, and Port-Orford cedar root disease. Of these, the highest elevation in biomass loss – as measured by FIA plot data – was caused by EAB, Dutch elm disease, beech bark disease, and hemlock woolly adelgid. We know that elms and beech, at least, began dying decades before the FIA data began to be collected. So the reported mortality rates are an underestimate. This is especially true because beech mortality is highest in the first decade after invasion by beech bark disease.

Annual levels of biomass loss are virtually certain to increase. First, pests will spread to new host ranges and infestations in already-invaded ranges will intensify. As a result, substantial amounts of the hosts’ biomass are at risk of exacerbated mortality. As I noted at the top of the blog, the total amount of host biomass at risk from these 15 species is estimated to be 5,197 TgC – or 41.1% of the total live forest biomass in the 48 conterminous states. Further exacerbating future losses is the likelihood that additional pests will be introduced. I would add that pests not included in this analysis – e.g., polyphagous and Kuroshio shot hole borers and possibly the spotted lanternfly – are also likely to contribute to losses of live forest biomass.

Fei et al. (2019) did not attempt to determine the economic value of this biomass loss or to address other types of losses to ecosystem services.

Remember that a separate set of studies reported by Potter et al. (2019) (the CAPTURE project) also relied on data from the FIA plots to evaluate the impact of introduced pests. These studies focused on identifying the host species at greatest risk rather than highest-impact pests or biomass loss. I find it reassuring that the Fei and Potter studies – using different approaches – resulted in very similar species rankings. See my discussion of the Potter studies here.

Together, the teams led by Potter and Fei set clear priorities for addressing the threats from non-native pests. What we need now is action! See my recommendations in my recent “solutions” blog.

U.S. Capitol – inform your representatives that you want action to protect trees!

SOURCES

Fei, S., R.S. Morin, C.M. Oswalt, and A.M. 2019. Biomass losses resulting from insect and disease invasions in United States forests

Congressional Funding for Key USDA Programs (Assuming it Ever Passes)

Fiscal Year 2020 began on 1 October. Congress has not yet passed funding bills (appropriations) for the full year. Agencies are operating now on a short-term continuing resolution which expires on November 21^st. Meanwhile, representatives of the House and Senate will meet to reconcile the differences between the two bodies’ appropriations bills in hope that a year-long bill can be finalized by that time.

(Disagreement between President Trump and the Congress about funding for the border wall might prevent adoption of full-year appropriations bills and lead to another government shutdown.)

I report here the differences between House and Senate bills funding the USDA APHIS and Forest Service programs that are vital to addressing non-native forest pests.

APHIS

Over the years, I have complained that inadequate funding is a major cause of shortfalls in APHIS’ efforts to detect new invasions by tree-killing pests and to respond to those invasions in effective ways.

While funding levels are still too low, at least Congress is holding funding steady for APHIS for Fiscal Year 2020 (which began three weeks ago, on October 1^st). Both House and Senate bills maintain funding for two crucial programs at the FY19 levels:

“tree and wood pests” program – $60 million (this matches the FY19 level; it is $4 million above the funding provided in previous years); and
“Pest Detection” – $27.4 million.

The House provided slightly higher funding than the Senate for two other programs:

“specialty crops” (including sudden oak death) – $186.5 million in the House bill, $186 million in the Senate bill; and
“methods development” – $21.686 million in the House bill, $20.686 million in the Senate bill.

In the report accompanying its bill, the House called for two additional funding options to address emergencies. First, it set up a contingency fund of $470,000 to control outbreaks of insects, plant diseases, animal diseases and pest animals and birds to meet emergency conditions. Second, the report repeated language from past reports that authorizes the Secretary to take “such sums as may be deemed necessary” from other USDA programs in order to counter pest emergencies threatening any segment of U.S. agricultural production.

The Senate report addressed several high-profile tree pests. It called for complete eradication of the Asian longhorned beetle; mandated that APHIS report on its efforts to eradicate ALB and spotted lanternfly and to minimize spread of the polyphagous and Kuroshio shot hole borers; and to assist states that have recently detected the emerald ash borer. (This language is helpful, but it falls short of what I previously advocated – that APHIS continue efforts to prevent EAB spread, especially through movement of firewood.) The Senate report also urged APHIS to maintain FY19 level funding addressing the sudden oak death pathogen, in particular to improve understanding of the two strains of the pathogen present in Oregon’s forests link to blog to inform control and management techniques in wildlands. (Actually, management in wildlands falls largely to the Forest Service, with scientific input from both Agriculture Research Service and – to some extent – the NORS-DUC research nursery managed by APHIS.)

For a lengthier justification of my funding requests, see my earlier blog on APHIS funding

Funding for Resistance Breeding through NIFA

As I pointed out in my blog in May, the 2018 Farm Bill included an amendment (Section 8708) that establishes a new priority for a grant program managed by the National Institute of Food and Agriculture. The amendment would support restoration to the forest of native tree species that have suffered severe levels of mortality caused by non-native insects, plant pathogens, or other pests. The amendment affects the Competitive Forestry, Natural Resources, and Environmental Grants Program under Section 1232(c)(2) of the Food, Agriculture, Conservation, and Trade Act of 1990 (16 U.S.C. 582A-8, as amended. However, this program has not been funded for more than a decade. In my blog, I asked you to support a $10 million appropriation to NIFA to fund a competitive grant program for such forests restoration.

Neither the House nor the Senate provided funding for this program.

USFS

The House bill provides $277,155,000 for USFS Research and Development – nearly $20 million more than the Senate bill ($257,640,000). The House report links this increase to the recognition of the increasing risk to urban, rural, and wildland forests from insect and disease outbreaks and invasive plant infestations. The report calls on the Forest Service to develop a research program that addresses several priorities critical to forest health, including preventing the spread of disease and invasive species.

USFS engagement on pest issues with other federal agencies and state, local government, and private land managers is carried out through the Forest Health Management program under the State and Private Forestry division. The Senate bill and report are confusing because they have separated out salaries and other expenses. As a result, I can’t compare its figures to those in previous years or to those from the House. Partly for this reason, I urge you to support the House bill, which is quite clear in appropriating $103,736,000 for Forest Health Management, which is a programmatic increase of $19 million above the FY19 level and $29,919,000 above the budget request. I am encouraged by the House’ report, which encourages the Forest Service to address high priority invasive species, pests, and diseases, including the emerald ash borer and bark beetle infestations.

For longer explanations, see my earlier blog on USFS funding.

These bills show an increasing awareness of forest pest issues in key funding committees in both the House and Senate. Let’s reinforce this message – and spread it to the rest of Congress. Please contact your senators and representative and ask them to support these funding levels.

Posted by Faith Campbell

APHIS’ EIS on Importing Plant Pests: What it reveals about APHIS

APHIS has published a final Environmental Impact Statement (FEIS) as one of the final steps in modifying its regulations governing conditions for issuing permits for importation, interstate movement, and intrastate movement of plant pests – including biocontrol agents. Access it here.

The original proposal to modify the regulatory system was published in March 2017.

I find the rationale for modifying the regulations to be compelling: the current regulations:

date from 2001;
do not adequately reflect changes in APHIS’ mandate enacted by the Plant Protection Act; and
do not focus agency efforts on the permit applications that pose the highest risk.

The FEIS presents two alteratives: the “preferred alternative” and the “comprehensive risk mitigation program.” APHIS settles for the less protective actions that expose natural resources, especially, to risk from non-indigenous species

1) The FEIS reiterates — without discussion or rationale — APHIS’ acceptance of the vague word “acceptable” to describe the level of protection the agency strives to achieve (see pp. 2, 22, 45, 106 of the FEIS). The FEIS does not attempt to quantify the differences in the levels of protection provided by the two alternatives.

2) APHIS advocates a policy alternative that does not require post-release monitoring of biocontrol agents. The FEIS justifies adoption of this alternative despite putting a welcome emphasis on the importance of just such efforts to determine the actual impacts of biocontrol organisms on both target and non-target species (p. 67). On page 70, the FEIS notes that the paucity of documented examples of adverse effects on non-target species “may be the result of insufficient monitoring after release …” It goes on to note that “very few introductions included a careful evaluation of nontarget impacts …” The FEIS notes the paucity of funding for this research and – sometimes – the lack of authority to require such monitoring.

In the case of APHIS, I see no legal impediment to the agency requiring biocontrol permit applicants to carry out post-release monitoring.

Indeed, if APHIS chose the “comprehensive risk mitigation program”, the agency would require enhanced post-release monitoring. The goal would be to document “the extent of establishment, spread, and limit to expected hosts” of the introduced biocontrol organism (p. 43). Nevertheless, the FEIS accepts the “preferred alternative”, which does not require such monitoring. The reason given for this choice is that the comprehensive program would require too many resources. I note below that we can overcome this barrier by lobbying for increased appropriations and higher staffing levels.

3) APHIS dismisses risks associated with high levels of uncertainty. In justifying the less rigorous “preferred alternative”, the FEIS refers 20 times to the persistence of uncertainties in analyses of the potential impact of importation, interstate transport, or release of non-indigenous organisms. FEIS also says that given these inevitable uncertainties, APHIS should regulate most organisms “conservatively” – defined in the FEIS as “based on what is known” ( p. 74). Of course, APHIS long ago rejected the precautionary approach – which is a truly conservative approach.

4) The FEIS accepts APHIS’ current practice of evaluating risks only in the geographic area of approved introduction – despite conceding repeatedly that introduced organisms often spread beyond the original introduction site. It is true that the geographic area evaluated includes all continental states (whether Alaska is included is unclear). However, there is no discussion of the likelihood that organisms introduced to the continental states will be transported to U.S. islands in the Caribbean or Pacific – through either authorized or unauthorized mechanisms.

The FEIS Asserts Principles that APHIS Sometimes Fails to Live Up To

As I note above, the FEIS makes numerous references to the reality that an organism released into the environment might establish and spread to its maximum geographic range based upon host distribution, climate and other range-limiting factors. According to the FEIS, APHIS’ decisions about issuing a permit allowing release of non-native organisms must reflect that likelihood. For example:

“In principle, therefore, release of the biological control organism, at even one site, should be considered equivalent to release over the entire area in which potential hosts occur, and in which the climate is suitable for reproduction and survival.” (P. 67)

However, APHIS’ recent decision to allow introduction of a thrips (Pseudophilothrips ichini) in Florida to control Brazilian pepper (Schinus terebinthifolius) does not reflect this principle.

The environmental assessment (EA) that analyzed this proposed release reported that the thrips would both encounter a suitable climate in Hawai`i (pp. 11 and 19) and feed on two native Hawaiian species – Rhus sandwicensis and Dodonaea viscosa. The EA described the feeding damage on these non-target species as negligible and noted that P. ichini sustained only one generation on these non-target species (p. 27). Furthermore, the EA noted (p. 29) that the action being reviewed did not include release of P. ichini in Hawai`i. However, the EA did not discuss the frequency with which insects established on the Continent are transported – without authorization – to the Islands. In my view, if introduced to Hawai`i – by authorized or non-authorized transport – the thrips is likely to thrive because several good hosts are widespread. By feeding on these good hosts, the thrips could enjoy a “food subsidy” that would allow it to put constant pressure on the vulnerable Hawaiian species. [You can obtain a copy of my comments on the draft EA by contacting me via the “contact us” button, or by visiting the Federal Register site at the link given above.]

*Rhus sandwichensis*; photo by Forest & Kim Starr

The FEIS fails to address an important risk

*Amynthes agrestis* one of the invasive earthworms established in the U.S.
photo by National Park Service

The FEIS doesn’t recognize – or even mention – the impact of non-native earthworms on native ecosystems and native plants! The only discussion of risks associated with earthworms is on p. 26, where the sole concern is the risk that soil-dwelling worms could vector crop and livestock diseases present in the soil in the country of origin.

Yet the FEIS notes that APHIS’ mandate – and the purpose of the permit system – is to protect not only American agriculture but also our natural resources. I have blogged about the severe impact earthworms have on native flora here. Why did the authors of the EIS ignore the large and growing scientific literature on this issue?

Good Points in the FEIS

1) The FEIS notes the concern that biocontrol agents will attack non-target species, with results that “may not be easily reversed.” (pp. 66, 74) The FEIS cites several examples, including Cactoblastis cactorum on North American prickly pear (Opuntia) cacti – see my blogs here and the potential impact of Rhinocyllus conicus on native thistles. The FEIS notes that these particular biocontrol agents would not be approved for release under current policies. However, the FEIS also reports that a biocontrol agent released on thistles in Virginia in 1997 – that is, under criteria currently in use – had spread across the continent to California and Nevada within two years! While the FEIS reports the spread as by natural means, I wonder if some enterprising farmers might have taken infected plants/inoculum without authority.

2) The FEIS notes several indirect concerns arising from the environmental release of biocontrol organisms, including contamination, adaptation, interference, competition, and hybridization. When biocontrol organisms establish but don’t reduce populations of the target weed, they can provide a “food subsidy” to some organisms, thus disrupting the ecological balance. The example given is two gall flies (Urophora affinis and U. quadrifasciata), which failed to control knapweed and led to population explosions of deer mice – with repercussions for competition among small mammals, possibly reduced recruitment of native plant populations, and increased incidence of a serious disease of humans, Sin Nombre hantavirus. (Recall my similar concern re: a thrips if it reaches Hawai`i, above.)

3) The FEIS cites scientific publications demonstrating the low rate of success of biological control in controlling invasive plants or arthropods. One such discussion – on p. 53 – notes that an estimated 65% of introduced arthropods successfully establish for the purposes of weed control, 25 – 34% of those introduced to control arthropods. These figures are repeated on p. 59. However, on pp. 67-68, even lower success rates are presented, based on worldwide estimates. This is not a good record, given the risks involved. Furthermore, given my focus on non-native insects, I am concerned by the statement in the FEIS that the scientific study of potential risks of biocontrol targetting arthropods control is not thorough. (pp. 68-69)

The Center for Invasive Species Prevention hopes that other stakeholders will work with us to persuade APHIS to work toward adoption of the more protective approach described in the “comprehensive risk mitigation program”. A key factor will be lobbying the Administration and Congress to increase appropriations and personnel ceilings so that APHIS has the resources necessary to carry out the more protective program.