Author: phytodoer@aol.com

Support Adequate Funding for Key USDA Programs

The people who work here work for us!!!

As I have written often, inadequate funding is a major cause of shortfalls in USDA APHIS’ efforts to detect new invasions by tree-killing pests and to respond to those invasions in effective ways. So, I ask you to contact your Representative and Senators in support of appropriations for APHIS and –National Institute for Food and Agriculture (NIFA) for the next fiscal year – (FY)2020.

APHIS’ efforts to detect and respond to non-native tree-killing pests were rudely interrupted by the five-week Government Shutdown from 22 December until late January. While inspection of incoming shipments continued, U.S.-based activities were halted. Chaos and confusion continued until 15 February, when the President signed legislation that funds APHIS (and other government agencies) until the end of September – the remainder of FY2919.

Surprise! The funding bill provides increased funds for two key APHIS programs:

  • $60 million for the “tree and wood pests” program — $4 million above the funding provided in recent years; and
  • $186 million for “specialty crop” pests (including sudden oak death) — $7.8 million above recent levels. 

I ask you to ask the Congress to maintain these funding levels for these budget “lines”.

I ask you also to support continuing the FY19 levels for two other programs:

  • Methods Development — $27.4 million; and
  • “Detection Funding” – $20. 7 million.

New this year, I hope you will support a $10 million appropriation to the National Institute of Food and Agriculture to fund a competitive grant program intended to restore to forests tree species significantly damaged by non-native insects and plant pathogens.

Justification for the Funding Requests

As we know, non-native insects and pathogens that threaten native tree species have been and continue to be introduced to the United States. These pests impose significant costs: Aukema et al. 2011 (full reference at the end of the blog) estimated

  • municipal governments spend more than $2 billion per year to remove trees on city property that have been killed by these pests.
  • homeowners spend $1 billion every year to remove and replace trees on their properties
  • homeowners absorb an additional $1.5 billion in reduced property values.

Costs are rising: the polyphagous and Kuroshio shot hole borers are projected to cost municipalities and homeowners in California $36.2 billion if their further spread is not prevented (McPherson 2017)

When you contact your Representative or Senators, tell them about the impact of non-native pests in your location!

The significant ecological impacts are poorly quantified.

USDA APHIS is responsible for preventing such pests’ entry, detecting newly introduced pests, and initiating rapid eradication programs. Yet, despite rising risks of pest introduction commensurate with rising import volumes, funding for APHIS’ program targetting the “tree and wood pests” associated with crates and pallets has remained at or below $55 million since FY2012 – until the modest increase last year to $60 million. Among the forest pests detected during this period are the spotted lanternfly and here and Kuroshio shot hole borer.

Among the pests probably introduced on a second pathway, imports of living plants, are the two pathogens threatening Hawaii’s most widespread tree, ʻōhiʻa lehua and here, and beech leaf disease and here in the Northeastern states. The better-funded “specialty crops” account could help fund responses to these damaging pathogens.

Ask your Congressional representatives to urge APHIS to apply part of the increased funding for the “tree and wood pest” program to continue the regulatory program for the emerald ash borer (EAB) and here. In September, APHIS has proposed to terminate the EAB regulatory program. Program termination would greatly increase the risk that EAB will spread to the mountain and Pacific Coast states. California has five native species of ash vulnerable to EAB. Ash trees provide a higher percentage (8%) of Los Angeles’ tree canopy than any other species. This proportion will rise as other tree species succumb to the polyphagous and Kuroshio shot hole borers. Oregon’s one native species of ash is widespread in riparian areas and many urban plantings consist of ash. Ash trees are the fifth most common genus among Portland’s urban trees. Many stakeholders have urged APHIS to continue to regulate movement of firewood and other materials that facilitate EAB’s spread.

The “Specialty Crops” program currently funds APHIS’ regulation of nursery operations to prevent spread of the sudden oak death pathogen. In future, this budget line would be the logical source of funds to manage the spotted lanternfly, which has been carried out through a combination of emergency funding under 7 U.S.C. §7772 and grants funded through the Plant Pest and Disease Management and Disaster Program (§7721 of the Plant Protection Act). (See below.)

Ask your Congressional representatives to support continued funding of APHIS’ “Methods Development” program at the FY19 level of $27.4 million. This program assists APHIS in developing detection and eradication tools essential for an effective response to new pests.  

Similarly, ask your Congressional representatives to support continued funding of the “Detection” budget line at the FY19 level of $20.7 million. This program supports the critically important collaborative state –federal program pest-detection program that is critical to successful eradication and containment programs.

APHIS’ Additional sources of funds

APHIS has always had authority to obtain “emergency” funds through 7 U.S.C. §7772. Emergency funds come from permanent USDA funding; they are not subject to annual appropriations. This authority has been tightly controlled by the Office of Management and Budget; I believe the last time APHIS obtained “emergency” funds for a tree pest was the emerald ash borer a decade or more ago. A year ago, APHIS accessed $17 million in emergency funding to address the expanding spotted lanternfly outbreak [USDA Press Release No. 0031.18 February 7, 2018] and OMB also requires that APHIS quickly transfer programs started with emergency funds to the regular budget. As I note above, response to the expanding spotted lanternfly outbreak should logically be shifted to the “specialty crops” budget account.

For a decade, APHIS has had access to a separate source of funds: the Plant Pest and Disease Management and Disaster Prevention Program. This program is also funded through permanent funds, not subject to the vagaries of annual budgeting and appropriations. Until last year, this program operated under Section 10007 of the 2014 Farm Bill; with passage of a new Farm Bill last year, it is now designated as Section 7721 of the Plant Protection Act. Beginning in Fiscal Year 2018, APHIS has authority to spend up to $75 million per year.

Funds are provided under a competitive grants program to universities, states, Federal agencies, nongovernmental organizations, non-profits, and Tribal organizations “to conduct critical projects that keep U.S. crops, nurseries, and forests healthy, boost the marketability of agricultural products within the country and abroad, and help us do right and feed everyone.” [USDA press release “USDA Provides $66 Million in Fiscal Year 2019 to Protect Agriculture and Natural Resources from Plant Pests and Diseases” February 15, 2019]

Over the decade since the program began, it has funded, but my calculation, about $77 million in projects targetting tree-killing pests. The proportion of total program funding allocated to tree-killing pests has risen in the most recent years, driven largely by funding to counter the spotted lanternfly outbreak which began in Pennsylvania but has since spread (see above). In the current year (FY2019), APHIS used this program to fund $10 million in projects to address the spotted lanternfly. The SLF funds equaled 57% of the total funding for tree pests provided under the program in FY2019.

Implications of the Tangle of Funding Sources

What is the significance of funding programs through the Plant Pest and Disease Management and Disaster Prevention Program as distinct from appropriated funds? Clearly, having access to $75 million that is not subject to the limits imposed by Administration budget priorities or Congressional appropriations allows considerable freedom. Does this freedom allow APHIS to support work on pests that might not qualify to be “quarantine” pests?  For example, under the Plant Protection Act, APHIS normally does not engage on pests found only in one state. The polyphagous and Kuroshio shot hole borers fall into this category. So did the spotted lanternfly for the first several years – until its detection in Delaware and Virginia in late 2017. If so, then the presence of the lanternfly in several states would seem now to indicate that funding sources should be shifted – at least in part – to appropriated funds. But would such a shift result in less funding – a result I think would be most unwise!

The beech leaf disease doesn’t clearly qualify for designation as a “quarantine pest” because of the uncertainty about the causal agent. So far, there has been no Section 7721 funding to support efforts to identify the causal agent or to improve detection or curtail spread of the disease.

a blight-resistant chestnut bred by the American Chestnut Foundation; photographed in Fairfax County, Virginia by F.T. Campbell

Funding for Resistance Breeding through NIFA

As we know, dozens of America’s tree species have been severely reduced or virtually eliminated from significant parts of their ranges by non-native insects and pathogens. Last year’s Farm Bill – the  Agriculture Improvement Act of 2018 – included an amendment (Section 8708) that establishes a new priority for an existing grant program to 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. Grant-receiving programs would incorporate one or more of the following components: collection and conservation of native tree genetic material; production of sufficiently numerous propagules to support landscape-scale restoration; and planting and maintenance of seedlings in the landscape.

In January a panel of the National Academies of Sciences, Engineering, and Medicine recommended that the U.S. apply multifaceted approaches to combat these threats to forest health. One component strategy is breeding of trees resistant to the pest.

Ask Congress to begin applying the Academies’ recommendation by providing $10 million to NIFA to fund 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.

I hope everyone will contact your Representative and Senators. If your Congressional representative is listed below, your contact is particularly helpful because these are the members of the House or Senate Agriculture Appropriations subcommittees – the people with the greatest influence over what gets funded:

House Agriculture Appropriations subcommittee members:

  • Sanford Bishop Jr., Chairman 
  • Rosa DeLauro                                      CT
  • Chellie Pingree                                     ME
  • Mark Pocan                                         WI
  • Barbara Lee                                         CA
  • Betty McCollum                                  MN
  • Henry Cuellar                                      TX
  • Jeff Fortenberry, Ranking Member      NE
  • Robert Aderholt                                               AL
  • Andy Harris                                         MD
  • John Moolenaar                                               MI

Senate Agriculture Appropriations subcommittee members:

  • John Hoeven, Chairman                                  ND
  • Mitch McConnell                                 KY
  • Susan Collins                                       ME
  • Roy Blunt                                            MO
  • Jerry Moran                                         KS
  • Cindy Hyde-Smith                               MS
  • John Kennedy                                     LA
  • Jeff Merkley                                        OR
  • Dianne Feinstein                                  CA
  • Jon Tester                                            MT
  • Tom Udall                                           NM
  • Patrick Leahy                                       VT
  • Tammy Baldwin                                  WI

SOURCES

Aukema, J.E., B. Leung, K. Kovacs, C. Chivers, K. O. Britton, J. Englin, S.J. Frankel, R. G. Haight, T. P. Holmes, A. Liebhold, D.G. McCullough, B. Von Holle.. 2011. Economic Impacts of Non-Native Forest Insects in the Continental United States PLoS One September 2011 (Volume 6 Issue 9)

McPherson, Gregory. September 28, 2017. Memorandum to John Kabashima re: Potential Impact of ISHB-FD on Urban Forests of Southern California

Spotted Lanternfly – Government Shut-Down Hampered Vital Effort at Crucial Time

spotted lanternfly; photo by Holly Raguza, Penn. Dept. of Agriculture

I last blogged about the spotted lanternfly (Lycorma delicatula) two years ago. At that time, this insect from Asia (where else?) was established in some portions of six counties in southeastern Pennsylvania. While its principal host is tree of heaven (Ailanthus altissima), it was thought to feed on a wide range of plants, especially during the early stages of its development. Apparent hosts included  many of the U.S.’s major canopy and undertory forest trees, e.g., maples, birches, hickories, dogwoods, beech, ash, walnuts, tulip tree, tupelo, sycamore, poplar, oaks, willows, sassafras, basswood, and elms. The principal focus of concern, however, is the economic damage the lanternflies cause to grapes, apples and stone fruits (e.g., peaches, plums, cherries), hops, and other crops.

In the two years since my first blog, the spotted lanternfly has spread – both through apparent natural flight (assisted by wind) and through human transport of the egg masses and possibly adults. By autumn 2018, detections of one or a few adults – alive or dead – had been found in six additional states: Connecticut, Delaware, Maryland, New Jersey, New York, and Virginia.

spotted lanternfly quarantines (blue) & detection locations (yellow)
prepared by Cornell University

How many of these detections signal an outbreak?  It is too early to know.

Impacts of the Government Shutdown

Unfortunately the federal government shutdown forced the cancellation of the annual USDA invasive species research meeting that occurs each January. The spotted lanternfly was to be the focus of six presentations. The most important of these was probably APHIS’ explanation of “where we are and where we are going.” The cancellation eliminated one of the most important opportunities for researchers to exchange information and ideas that could spur important insights. Equally important, the cancellation hampered communication of insights to practitioners trying to improve the pest’s management.

One pressing question was not on the meeting’s agenda, however. Would a much more aggressive and widespread response in 2014, when the lanternfly was first detected, have  eradicated this initial outbreak?  I have long thought that this question should be asked for every new pest program, so that we learn whether a too-cautious approach has doomed us to failure. However, authorities never address the issue – at least not in a public forum.

The shutdown also had an even more alarming impact. It interruptedaid by USDA APHIS and the Forest Service to states that should be actively trying to answer this question. Winter is the appropriate season to search for egg masses.  It is also the season to plan for eradication projects. 

spotted lanternfly egg mass; New York Department of Environmental Conservation

For the first several years, funding of studies of the lanternfly’s lifecycles and host preferences, research on possible biological or chemical treatments, and outreach and education came in the form of competitive grants under the auspices of the Farm Bill Section 10007.  This funding totaled $5.5 million to Pennsylvania.

This commitment pales compared to Asian longhorned beetle or emerald ash borer h— which were also poorly known when they were first detected in the United States.

At the same time, the Pennsylvania infestation spread. It is now known to be established in portions of 13 counties and outbreaks were detected in neighboring Delaware and Virginia. h

This spread – and resulting political pressure – persuaded APHIS to multiply its engagement. A year ago, USDA made available $17.5 million in emergency funds from the Commodity Credit Corporation (that is, the funds are not subject to annual Congressional appropriation). APHIS said it would use the additional funds to expand its efforts to manage the outer perimeter of the infestation while the Pennsylvania Department of Agriculture would focus on the core infested area. APHIS said it would use existing (appropriated) resources to conduct surveys, and control measures if necessary, in Delaware, Maryland, New Jersey, New York and Virginia.

Summary of Latest Status in the Seven States

(see also the write-up here)

Pennsylvania: infestation established (quarantine declared) in portions of thirteen counties (Berks, Bucks, Carbon, Chester, Delaware, Lancaster, Lebanon, Lehigh, Monroe, Montgomery, Northampton, Philadelphia, Schuylkill). The quarantine regulates movement of any living stage of the insect brush, debris, bark, or yard waste; remodeling or construction waste; any tree parts including stumps and firewood; nursery stock; grape vines for decorative or propagative purposes; crated materials; and a range of outdoor household articles including lawn tractors, grills, grill and furniture covers, mobile homes, trucks, and tile or stone. See the regulation here: https://www.agriculture.pa.gov/Plants_Land_Water/PlantIndustry/Entomology/spotted_lanternfly/quarantine/Pages/default.aspx

Delaware: The state had been searching for the insect since the Pennsylvania outbreak was announced. After detection of a single adult female in New Castle County in November 2017, survey efforts and outreach to the public were intensified. Another dead adult spotted lanternfly was found in Dover, Delaware, in October 2018.  

Virginia: infestation established (quarantine declared) in one county. Multiple live adults and egg cases of spotted lanternfly were confirmed in the town of Winchester, Virginia (Frederick County), in January 2018.   As noted in my earlier blog, this region is important for apple and other orchard crops and near Virginia’s increasingly important wine region.

New Jersey: The New Jersey Department of Agriculture began surveying for lanternflies along the New Jersey-Pennsylvania border (the Delaware River) once the infestation was known. It found no lanternflies before 2018. In the summer, however, live nymphs were detected in two counties, Warren and Mercer. In response, the state quarantined both those counties and one located between them, Hunterdon. The state planned to continue surveillance in the immediate areas where the species has been found as well as along the Delaware River border in New Jersey.  

New York: In 2017, a dead adult lanternfly was found in Delaware County. 

State authorities expressed concern about possible transport of lanternflies from the Pennsylvania infested area.

In Autumn 2018, New York authorities confirmed several detections, including a single adult in Albany and a second single adult in Yates County. In response, the departments of Environmental Conservation and Agriculture and Marketing began extensive surveys throughout the area. Initially they found no additional lanternflies.

However, a live adult was later detected in Suffolk County (on Long Island).

Connecticut:  a single dead adult was found lying on a driveway at a private residence in Farmington, CT, in October 2018. The homeowner was a state government employee educated about the insect. Relatives had recently visited from Pennsylvania (Victoria Smith, Connecticut Agricultural Experiment Station, pers. comm.). Searches found no other spotted lanternflies on the property. The state plans additional surveys in the area to confirm that no other spotted lanternflies are present.  

Maryland: A single adult spotted lanternfly (male) was caught in a survey trap in the northeast corner of Cecil County near the border of Pennsylvania and Delaware (an area of known infestation) in October 2018. Because of the lateness of the season and sex of the insect, the Maryland Department of Agriculture does not believe that the lanternfly has established there.

All the affected states are encouraging citizens to report any suspicious finds.

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.

National Academies Endorse Suite of Pest Control Programs — and a Brand New Regulatory System for Biotech Trees

a blight-resistant chestnut tree bred using traditional breeding techniques by The American Chestnut Foundation; photo by F.T. Campbell

Nearly one-third of the continental United States is covered by forests, more than 1 million square miles. As demonstrated by many authorities and – I hope! – in my blogs, these forests face increasing threats, including introduction of rising numbers of non-native insects and pathogens that kill or severely damage the tree species that comprise those forests.

One response has been a request by the U.S. Endowment for Forestry and Communities, the Environmental Protection Agency, and U.S. Department of Agriculture (Agricultural Research Service, Animal and Plant Health Inspection Service, U.S. Forest Service, and National Institute of Food and Agriculture) that the National Academies of Sciences, Engineering, and Medicine consider the potential for the use of biotechnology to mitigate these threats to forest health.

The resulting report was released in January 2019 (see full citation at the end of the blog). The report is 240 pages long, very thorough, and wide-ranging. It does have a 12-page summary, listing the Panel’s many conclusions and its recommendations. While the preponderance of the report concerns forests on the North American continent, the panel did seek information about threats to endemic trees in Hawai`i, which (to my mind) are especially severe. See earlier blogs here and here.

To me, one of the report’s most important conclusions is that while there are multiple options for dealing with forest pests, their feasibility and success vary widely. Saying that no single management practice is likely to be effective by itself, the report calls for increasing investment in the full range of strategies other than biotechnology, i.e.,

  • preventing arrival of non-native pests (recognized as the first line of defense and the most cost-effective strategy);
  • site management practices;
  • biocontrol; and
  • enhancement of genetic resistance naturally present in affected tree species (including developing  human capital in professions related to tree breeding).

The panel was not asked to examine the potential for biotech to reduce threats to forest health by altering the pests affecting North American tree species so it does not do so.

Summarizing the Threat

Citing Aukema et al. 2010 and other sources, the Academy panels reports that approximately 450 species of insects and at least 16 species of pathogens have been introduced and have established in continental U.S. forests. Of those, 62 insects and all of the pathogens are determined to have a high impact. A USDA Forest Service study estimates that 81.3 million acres (about 7% of all forested or treed land in the U.S.) are at risk of losing at least 25% of tree vegetation by 2027 due to insects and pathogens. These pests are both non-native, introduced species and native pests that are spreading to new regions as a result of climate change.

The Academy panel notes that loss of a tree species can have cascading adverse effects on the forest ecosystem and on the range of services it provides and the values it represents to human populations.

Part A. The Technology for Trees

The Academy panel was asked to assess the ecological, economic, and social implications of deploying genetically engineered trees. The experts also were asked to identify the knowledge needed to evaluate the ways such a tree might affect the prospects for forest health. The analysis was to include social and cultural impacts as well as impacts on forest and associated ecosystems – including their structure, composition, processes, function, productivity, and resilience.

This use of biotechnology to restore healthy forests differs from applications in industrial plantations or annual agricultural crops in that the biotech tree is intended to proliferate in a natural forest setting.

The authors chose four taxa — American chestnut (Castanea dentata), whitebark pine (Pinus albicaulis), ash (Fraxinus spp.), and poplars (Populus spp.) — to illustrate the variety of threats to forest health and efforts to date to protect the resource.

The committee defined forest health as:

A condition that sustains the structure, composition, processes, function, productivity, and resilience of forest ecosystems over time and space.

The panel says that “forest health” is assessed based on current knowledge and is influenced by human needs, cultural values, and land management objectives.

1. A Balanced Analysis

The report does not hype biotechnology for solving problems. The panel called for research on even the foundational question: whether resistance imparted to tree species through a genetic change will be sufficient to persist in trees that are expected to live for decades to centuries as well as in the generations they parent.

The report compares the two approaches to enhancing genetic resistance to pests, i.e., selective (traditional) breeding and relying on biotechnology. Both involve multiple steps, expense, and risks of pursuing what ultimately turn out to be dead ends.

Thus, in traditional selective breeding, scientists must complete the following steps:

1) Determine whether genetic resistance exists within the affected tree species’ population. According to the Academy report, while many tree species have some degree of resistance to particular native or non-native pests, finding suitable parent trees can be difficult, and even when they are found, not all the progeny will be resistant.

2) Evaluate the durability of resistance in order to protect trees over decades.

3) Propagate the resistant progeny in greenhouses or seed orchards to create sufficient resistant genotypes for restoration and reforestation. Many tree species are difficult to propagate using cell culture and regeneration.

In applying biotechnology techniques, scientists must complete the following steps:

1) Identify the genes carrying pertinent traits – which are to be modified, introduced, or silenced. Scientists don’t know what genetic mechanisms underlie important traits. This discovery process is more difficult for tree species than for agronomic crops due to the plants’ large size, long generation time, and (in the case of conifers) immense genomes. Another problem is that forest trees have high levels of heterozygosity due to their large population sizes and outcrossing breeding systems, which complicates genome assembly and modification. Still, recent technological improvements are making this identification process easier.

2) Insert the genes using various biotechnology tools such as transgenesis and genome editing.

3) Produce trees containing the desired gene sequence to regenerate plants from disorganized callus tissue. As noted above, many tree species are difficult to propagate using cell culture and regeneration. Even when this approach is possible, the regeneration of a plant from a single cell may not produce an individual that has the desired genetic change in every cell.

The time line for applying either approach to protect forest health will depend on several factors, including the biology of both the tree and the pest, and the environments in which the target tree species exists. It can vary from a few years to multiple decades.

2. Who Should Carry Out Genetic Improvement of Trees (and by implication, all long-term strategies to protect forest health)?

Trees provide private as well as public benefits, such as income from timber sales. However, the costs of developing a genetically resistant tree – whether achieved through traditional breeding or biotechnology processes – will be incurred up front and the benefits will follow later – often decades or even centuries later. Consequently, the sponsors need a long time horizon!  

The panel suggests that the public sector can have greater patience when it perceives that significant public benefits will be forthcoming. The private sector is not likely to invest in the protection of forest health because it cannot fully capture the benefits that may accrue. The authors define “public sector” to include government agencies and non-profit organizations.

Part B. Impacts, Ethics, and Policy

1. Impacts

The report provides careful analysis of the ecological impacts that should be considered in evaluating the use of biotechnology to maintain or improve forest health. The report emphasizes that if the modified trees are to spread and restore the species to its role in the ecosystem, the modified trees must be competitive in the ecosystem (while not being invasive!). The trees must be suited to the variety of climates and other biophysical conditions found throughout the tree species’ range. The report even said that establishing the rangewide patterns of distribution of the target species’ natural standing genetic variation should be researched before a project is begun aimed at inserting pest resistance genes.

2. Public attitudes and ethical considerations

The panel was charged to consider social, cultural, and ethical issues related to the potential use of biotechnology to develop trees resistant to pests. They devote 13 pages to examining this complex set of issues, which range from Native Americans’ use of black ash to concepts of “wildness” and competing models of “conservation”.  There have been few surveys or other studies of Americans’ attitudes. The panel also notes that the public lacks in-depth knowledge about genetic interventions and processes, so their attitudes are likely to change — for or against use of the technology — as they learn more or associate biotech with strongly held beliefs.

The Panel notes that important ethical questions fall outside any current “impact analysis” evaluation system, or any new analysis that focuses on “ecosystem services”.  It calls for additional research on societal response to biotechnology applied to forest health and development of new forms of engaging full range of stakeholders.

3. Need for a New Impact Assessment Framework

The panel concludes that the current regulatory system does not provide for consideration of most aspects of forest health in assessing the safety of a tree developed through biotechnology, including those described above. Consequently, the panel calls for an entirely new assessment process in order to evaluate both the ecological and social/ethical considerations.

The long-standing Coordinated Framework for the Regulation of Biotechnology relies on existing federal statutes. Under this system, the regulatory agencies (USDA Animal and Plant Health Inspection Service, Environmental Protection Agency, sometimes Food and Drug Administration) regulate specific products, not the process by which the products are produced. For example, USDA regulates only the small subset of biotech trees which were transformed via use of a bacterium, Agrobacterium tumefaciens, to insert the desired trait.

The panel says that an agency undertaking an environmental analysis under the terms of the National Environmental Protection Act would need to add an analysis of some components of forest health.

To rectify these analytical gaps, the panel suggests creation of an integrated impact assessment framework that combines ecological risk assessment with consideration of ecosystem services. This integrated framework would evaluate the effect of the pest threat – and responses to that threat – on forest processes –as well as on associated cultural and spiritual values. The impact assessment must make explicit the links between specific forest protections and their effects on important ecosystem services. The panel points to an EPA guidance document on economic impact analysis (see reference at the end of this blog) as a useful starting point. The panel suggests that this framework should be used to evaluate any forest health intervention, including use of selectively bred trees.

Because of the length of time until tree reproductive maturity and long life span of most trees, collecting data for an impact assessment might take years. The panel suggests adopting a tiered system which would allow field trials of low-risk transgenic trees to reach flowering stage so as to provide data on gene flow and climatic tolerances – data that are essential for a proper impact assessment that would evaluate the likelihood of ultimate success of the restoration effort.  Such experiments and carefully developed models must also identify sources of uncertainty.

Adoption of such a stepwise, iterative process requires abandonment of the current regulatory system, which does not permit the flowering of biotech trees in most cases. 

My Conclusions

The report makes clear several realities:

1) the magnitude of the threat to our forests from non-native pests – which warrants an effective response;

2) the strengths and weaknesses of the several response strategies – none of which can solve this problem in isolation;

3) the scientific challenges that need to be overcome to apply strategies aimed at enhancing tree species’ genetic resistance to pests;

4) the need for greatly expanded programs to implement the various strategies.

Also, the report shows how unprepared our country is to systematically assess the full impacts of new forms of tree breeding and forest health. To rectify this gap, the report also calls for a complete overhaul of the procedures by which the government currently evaluates the environmental risks associated with applying one of the strategies, genetic transformation of the plant host – which is defined (in the Glosssary) as including transgenesis, cisgenesis, RNA interference, genome editing, and insertion of synthetic DNA.

The recommended actions in this report – taken either individually or collectively – require a level of commitment by government and conservation organizations that far exceeds the current level.

I hope the Academies’ prestige can prompt such commitment. For example, development of a sufficiently robust coalition of groups could re-invigorate our society’s response to the invasive pest threat. The report has received some encouraging attention. It was reported in Nature and Scientific American. About 130 people tuned in live to the launch webinar on January 8th. So far, almost 1,200 people have downloaded the report.

The government shutdown has delayed the sponsoring agencies’ (USDA and EPA)  official reactions to the report. It probably curtailed some publicity efforts among all the sponsoring agencies. Also, the report will be only one item in the overflowing inboxes of agency scientists and managers after 35 days on furlough. I hope it won’t be lost, especially with the threat of a second shut-down.  

How can those of us in the public who care about our forests ramp up our activity to support these recommendations?

A reminder: Scott Schlarbaum and I addressed the need for a greatly expanded restoration component as part of a comprehensive response to non-native tree-killing pests in our report Fading Forests III, released five years ago. It is available here.

SOURCES

Aukema, J.E., D.G. McCullough, B. Von Holle, A.M. Liebhold, K. Britton, & S.J. Frankel. 2010. Historical Accumulation of Nonindigenous Forest Pests in the Continental United States. Bioscience. December 2010 / Vol. 60 No. 11

National Academies of Sciences, Engineering, and Medicine. 2019. Forest Health and Biotech: Possibilities and Considerations. Washington, DC: The National Academies Press. doi: https://doi.org/10.17226/25221.

U.S. Environmental Protection Agency. 2014. Guidelines for Preparing Economic Analyses. Washington, D.C.

Beech Leaf Disease Update

healthy American beech

A year ago, I alerted you to a new threat to American beech (Fagus grandifolia). In that blog I reported that conservation and park managers in northeastern Ohio had begun noticing troubling decline and mortality of beech saplings beginning in 2012. The problem was spreading: we now know that over the four years between 2012 and 2016, the apparent disease spread from an estimated 84 ha to 2,525 ha within Lake County, Ohio (Ewing et al. 2018; full citation provided at end of the blog).

By 2018, trees with symptoms had been detected in 24 counties across three states and one province: 10 counties in Ohio, 8 counties in Pennsylvania, 1 county in New York, and 5 counties in Ontario). A map is provided in Ewing et al.

The rate of decline within beech stands varies, suggesting that trees differ in susceptibility. This is a promising for breeding resistance (Ewing et al.).

Symptoms

A number of organizations have produced fact sheets and related material. I recommend the fact sheet available here.

Disease Progression

In Northeast Ohio, Cleveland Metroparks’ intensive monitoring program revealed a 4% mortality rate from 2015 to 2017. More than half of the plots now have dead trees  that had previously been only symptomatic. Most of the dead trees are small – less than 4.9 cm dbh. However, some larger trees have died and others bore only a few leaves this past summer. Leaves with light, medium, or heavy symptoms of infection – as well as asymptomatic leaves – can occur on the same branch of an individual tree.

The disease seems to spread faster between the stems of trees growing in beech clone clusters by spreading along the interlocking roots.

Serious science effort finally initiated – and funded!

The cause of beech dieback and mortality has still not been definitively determined. Most scientists agree that the cause is some kind of disease agent, not abiotic factors. A growing number of scientists from USDA’s Agriculture Research Service and Forest Service; Ohio’s Division of Forestry and Department of Agriculture; the Holden Arboretum; Ohio State University; and groups in Canada are researching possibilities.

The most promising candidate is a previously undescribed nematode detected by David McCann of the Ohio Department of Agriculture. That nematode has since been described by Japanese researchers on Japanese beech F. crenata (Kanzaki  et al.) and given the name Litylenchus crenatae. Thousands of live Litylenchus nematodes (at least 10,000) can swim out from a single leaf. Scientists at the USDA Agriculture Research Service and Holden Arboretum are waiting for bud break this spring to see whether plant material inoculated with the nematode develops disease symptoms.

Still, other possible disease agents could also play a role.

An international working group has been formed to continue studies of both disease agents and disease progression in seedlings, saplings, and mature trees.

Still, no regulation to counter long-range spread via nurseries!

Long range spread of the disease is probably assisted by anthropogenic transport, especially of nursery stock. As I reported in May, an Ontario retailer received – and rejected – a shipment of diseased beech from an Ohio nursery.

Despite the evident risk, no official agency has adopted regulations to prevent spread on nursery stock. None of the states or provinces in which the disease is present has adopted regulations. None of the neighboring states or provinces has acted to protect its nursery industry or forests. Neither USDA APHIS nor the Canadian Food Inspection Agency (CFIA) has adopted regulations. The disease was not mentioned during the annual meeting of the National Plant Board – which took place in Cleveland in August! Connie Hausman of Cleveland MetroParks did include the issue during her presentation on the extensive park complex to the group during the group’s field trip.

The absence of regulation is a puzzling omission because Lake County, Ohio, has many nurseries that grow and ship European beech — which can also be infected by beech leaf disease.

The Importance of American Beech – and Protecting

range of American beech

Our American beech is not a major timber species – in fact, the species is actively disliked by managers focused on timber production because beech bark disease kills trees before they reach commercial size. Beech trees also often have cavities which reduce their timber value – but which are valuable to wildlife.

However, American beech is extremely important ecologically in northern parts of the United States and in Canada east of the Great Plains. Beech is co-dominant (with sugar maple) in the Northern Hardwood Forest.  A summary of the species’ ecological importance can be found in Lovett et al. 2006. Beech nuts are a primary source of food for many woodland birds and mammals. In the central part of the northern hardwood forest – including in southern Canada – beech trees are the only source of hard mast. Furthermore, beech trees create a dense canopy; drastic defoliation modifies light levels at ground level, thereby affecting understory competition and other forest ecosystem services. Beech leaf litter decays more slowly than maple’s, which affects nutrient cycling. While beech leaf disease is unlikely to eradicate American beech, it could cause functional eradication of the species. Ohio alone has more than 17 million American beech trees, according to Tom Macy of the Ohio Department of Natural Resources (Ewing et al. 2018).

The threat appears to be widespread because both European (F. sylvatica) and Asian (F. orientalis) beech have shown symptoms. Ewing et al. 2018 call for detection efforts across Northern Hemisphere.

Of course, the species is already under threat from beech bark disease. Promising efforts to breed beech trees resistant to BBD now face the complication of having to incorporate resistance to this new disease (Ewing et al. 2018).

European Beech Weevil

I will remind you that last year I noted a third threat to beech trees – the European leaf weevil. Originally detected in Nova Scotia, it continues to spread. About 95% of beech trees in forest plots near Halifax are dead. In the city, half the beech trees have died and the rest are in severe decline. While neither the province nor CFIA has imposed a quarantine or other regulations to govern the movement of beech material, Canadian officials are exploring possible chemical treatments. They are working with European colleagues to explore biocontrol agents (Jon Sweeney, Natural Resources Canada, pers. comm.).

Conclusion

These new threats are getting far too little attention! Some can be blamed on the difficulty of regulating an unknown disease agent (e.g., beech leaf disease). Attempting this would stretch traditional policy practice and, possibly, legal authorities. And it has not yet been demonstrated that this disease can kill mature beech. However, neither of these caveats applies to the weevil, which is an identified species,  documented to kill mature trees, and a problem still not addressed.

Sources

Ewing, C.J., C.E. Hausman, J. Pogacnik, J. Slot, P. Bonello. 2018.  Beech leaf disease: An emerging forest epidemic. Short Communication. Forest Pathology 2018;e12488

Kanzaki, N.,  Y. Ichihara, T. Aikawa, T. Ekino, and H. Masuya. 2019. Litylenchus crenatae n. sp. (Tylenchomorpha: Anguinidae), a leaf gall nematode parasitising Fagus crenata Blume. Nematology. Volume 21: Issue 1

Lovett et al. 2006. Forest Ecosystem Responses to Exotic Pests and Pathogens in Eastern North America. BioScience Vol. 56 No. 5.

Sharon Reed’s presentation on YouTube  https://www.youtube.com/watch?v=tDBbik7cUrI

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.

2018 – More Bad News on Sudden Oak Death

Tanoak mortality at Big Sur photo by Matteo Garbelotto
  1. Outbreaks intensified in western North America and Western Europe (UK, France).
  2. Outbreaks are increasingly genetically diverse – raising the possibility of sexual reproduction and evolution.
  3. Evidence accumulated that eradicating Phytophthora ramorum from the environment once it is present is extremely difficult, if not impossible.

Meanwhile, APHIS proposed revisions that would weaken its regulation of nursery stock. See my earlier blog. Copies of all comments can be viewed here.

1) Intensifying Outbreaks

North America

According to the California Oak Mortality Task Force’s (COMTF) November 2018 newsletter, about 50 million trees have been killed by P. ramorum in California and Oregon. This breaks down to:

  • 29 – 44 million tanoaks (Notholithocarpus densiflorus) (1.6 – 2.5% of the species’ total population in California and Oregon);
  • 1.9 – 3.3 million coast live oaks (Quercus agrifolia) and Shreve oaks (Q. parvula var. shrevei), combined (0.4 – 0.7% of their populations); and
  • up to 1.1 million California black oaks (Q. kelloggii) (less than 0.17% of their population).

Of course, the oaks face additional threats from goldspotted oak borer and  polyphagous and Kuroshio shot hole borers hin more southern parts of California.

California bay laurel (Umbellularia californica) is not killed by P. ramorum but instead drives the spread of the outbreak in California. The state has an estimated 91.4 million infected California bay laurel trees.

These estimates are considered to be conservative. They are based only on trees that have been confirmed to be infected by direct, cultural isolation during the period up to 2014 — more than four years ago! And before a sharp intensification of infection (see below).

Data from a USDA Forest Service aerial detection survey – reported in COMTF’s September 2018 newsletter — detected a large increase in tanoak mortality in counties California counties reaching from Mendocino south to Monterey. This intensification in tree mortality was expected because the pattern is already well established: two seasons after a wet winter seasons, trees die. Such a wet and extended winter occurred in 2016-2017.

United Kingdom

Outbreaks of the EU1 strain of P. ramorum on larch (Larix kaempferi) in Scotland have also intensified. The infection is now found throughout much of Scotland, not just in the heavily infested zone in the the southwest part of the country. See updated map of outbreaks on Larch sites in woodland settings at https://scotland.forestry.gov.uk/supporting/forest-industries/tree-health/phytophthora- ramorum?highlight=WyJyYW1vcnVtIiwiJ3JhbW9ydW0iLCIncmFtb3J1bSciXQ

–

There is more on the status of P. ramorum in the the UK (England, Wales, Scotland and Northern Ireland) in a situation report posted by Forestry Commission England in 2018. Find it here: https://www.forestry.gov.uk/pdf/PRamorumSituationReport30June2018.pdf/$FILE/PRamorumSituationReport30June2018.pdfh

As in North America, the large number of outbreaks is attributed to favorable, wet conditions in the summer and fall of 2017. (This situation was summarized in COMTF’s September 2018 newsletter.

France

The outbreak on larch in France, first reported in 2015, is also spreading. This is particularly significant because, first, it is the first report of  P. ramorum outside of nurseries and ornamental settings in mainland Europe and, second, because it is a new genotype not tied to any other outbreak. By May 2018, about 80% of the trees in the Saint-Cadou larch plantations in Brittany (Northwest France) were symptomatic or dead in the more infected plots. A second outbreak has been detected a few kilometers away in a mixed forest stand of larch, oak, and sweet chestnut (Castanea sativa).  There, disease prevalence was much lower. Both stands have been removed.

(This was also  summarized in COMTF’s September newsletter.

2) Increasing Genetic Diversity

EU1 Strain in Oregon

As I have reported in the past, Oregon now has a second strain of Phytophthora ramorum – the “EU1” strain. This opens the possibility of sexual reproduction between it and the NA1 strain already established in forests in Oregon’s Curry County.

According to a presentation by Chris Benemann of the Oregon Department of Agriculture to the Continental Dialogue on Non-Native Forest Insects and Diseases, in 2018 – three years after the initial detection of one tree in 2015 – the number of trees infected by the EU1 strain has risen to 73. Oregon has prioritized removing these trees and treating (burning) the immediate area – now more than 355 acres. The legislature has provided $2.3 million for SOD treatments for 2017-2019. ODA believes that eradication of the EU1 outbreak is still possible.

3) But Is Eradication Possible?

According to the COMTF September newsletter, P. ramorum was detected by a water bait in a small pond downstream from a previously-infected botanical garden in Kitsap County, Washington. The garden undertook extensive mitigation efforts – including soil steaming –  and the pathogen had not been detected in this managed landscape for about 2 ½ years. Hundreds of samples of host plants were collected in September, with only one warranting further analysis to determine whether it was positive.  Surveys will continue in 2019.

In the East, USDA has baited streams to detect P. ramorum for several years. Seven states participated in the 2018 Spring National P. ramorum Early Detection Survey of Forests: Alabama, Georgia, Mississippi, North Carolina, Pennsylvania, South Carolina, and Texas. As reported in the COMTF’s September newsletter, h292 samples were collected from 48 sites. As in past years, positive samples were collected from streams associated with previously positive nurseries. These included three samples from two locations in Alabama; two samples from one location in Mississippi; and one sample from North Carolina. The Alabama and Mississippi sites have tested positive for approximately a decade.

So, the pathogen is persisting in water – but how? I have been told that P. ramorum requires plant material on which to survive – so how is it persisting without detectable infested plants? Also, does the presence of zoospores pose a threat of infesting streamside plant material? What studies are examining this issue?

Awareness through Art

Artists have transformed a SOD-infected tanoak tree into 7,000 pencils as part of their thoughtful “7,000 Marks” project. They  explore issues around global industrial trade, quarantine boundaries as a conservation tools, and the opposing concern that restricting trade can echo a rising tide of xenophobia. You can learn more (and buy pencils) here.

SOURCES

Cobb, R.; Ross, N.; Hayden, K.J.; Eyre, C.A.; Dodd, R.S.; Frankel, S.; Garbelotto, M. and Rizzo, D.M. 2018. Promise and pitfalls of endemic resistance for cultural resources threatened by Phytophthora ramorum . Phytopathology. Early view.

https://apsjournals.apsnet.org/doi/abs/10.1094/PHYTO-04-18-0142-R

Harris, A.R.; Mullett, M.S.; Webber, J.F. 2018. Changes in the population structure and sporulation behaviour of Phytophthora ramorum associated with the epidemic on Larix (larch) in Britain. Biological Invasions. 20(9): 2313–2328.

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.

Alarming Picture of Phytophthora Threats to Forests World-wide

Phytophthora dieback in West Australia


Prompted by the rising number of Phytophthora-caused diseases in forests on several continents, in 1999 the International Union of Forest Research Organizations (IUFRO) formed the IUFRO Working Party 7.02.09 ‘Phytophthora Diseases of Forest Trees’. Last spring This group published a global overview of Phytophthora diseases of trees (Jung et al. 2018; see full citation at the end of this blog).

The study covers 13 different outbreaks of Phytophthora-caused disease in forests and natural ecosystems of Europe, Australia and the Americas.

The picture is alarming!

Jung et al. state definitively that the international movement of infested nursery stock and planting of reforestation stock from infested nurseries have been the main pathway of introduction and establishment of Phytophthora species in these forests.  

The Picture: A Growing List of Diseases, Species, and Places Affected,

Jung et al. note that, during the past six decades, the number of previously unknown Phytophthora declines and diebacks of natural and semi-natural forests and woodlands has increased exponentially. The vast majority of these disease complexes have been driven by introduced invasive Phytophthora species. In 1996, 50 Phytophthora species were known. In the 20 years since then, more than 100 new Phytophthora species have been described or informally designated. One study (Tsao 1990) estimated that more than 66 % of all fine root diseases and more than 90 % of all collar rots of woody plants are caused by Phytophthora spp. Many of these had previously been attributed to abiotic factors or secondary pathogens. One example – surprising to me, at least – is that decline of mature beech trees in Central Europe is linked to Phytophthora rather than beech bark disease!

Several of the disease complexes described in Jung et al. 2018 are causing heartrending destruction of unique floras, e.g., jarrah, tuart, and other communities of western Australia and kauri forests of New Zealand. The authors expect increasing damage to the Mediterranean maquis in the future. They list these among other examples:

  1. Ink disease of chestnuts worldwide
  2. Oak declines and diebacks in Europe and North America
  3. Decline and mortality of alders (Alnus species) in Europe
  4. Decline and mortality of Port-Orford cedar (Chamaecyparis lawsoniana) in Europe and North America
  5. Kauri dieback in New Zealand link to earlier blog
  6. Decline and mortality of Austrocedrus chilensis and Juniperus communis in Argentina and Europe
  7. Diebacks of natural ecosystems in Australia
  8. Decline and dieback of the Mediterranean maquis vegetation
  9. Decline and dieback of European beech in Europe and the US
  10. Dieback and mortality of southern beech (Nothofagus species) in the United Kingdom and Chile
  11. ‘Sudden Oak Death’ and ‘Sudden Larch Death’ in the US and United Kingdom
  12. Leaf and twig blight of holly (Ilex aquifolium) in Europe and North America
  13. Needle cast and defoliation of Pinus radiata in Chile

Several of the Phytophthoras are causing severe damage on several continents:

  • P. cinnamomi in Europe, North America, and Australia
  • P. austrocedri in South America, Europe, and western Asia
  • P. ramorum in Europe and North America
  • P. lateralis in North America and Europe.

Often, the genetic makeup of the Phytophtoras species varies in these different locations. These differences indicate separate introductions and the existence of sexual reproduction and continuing evolution in response to conditions.

Why Phytophthoras are Spreading via the Plant Trade and Nursery Practices

First, Phytophthora species are able to survive unsuitable environmental conditions over several years as dormant resting structures in the soil or in infected plant tissues. When environmental conditions become suitable, the resting spores germinate – often prolifically. Since visible symptoms might not appear for considerable time after infection because the mechanism is progressive destruction of the fine root system, detection of the disease is delayed, further undermining control.

Second, most of the Phytophthora species causing  disease complexes were unnoticed as co-evolved species in their native environment. Often they were unknown to science before their introduction to other continents – where they become invasive on naïve plant species. Consequently, these species are not captured by the international plant health system, which is based on lists of recognized “pest” species.

Third, the common nursery practice of applying fungicides or fungistatic chemicals masks the presence of pathogens – another way plants pass unnoticed through phytosanitary controls. These chemicals do not, however, kill the pathogen. 

Fourth, the importation into receiving nurseries of plants from around the world provides ample opportunity for the introduced Phytophthoras to hybridize. The interspecific hybrids may differ in host range and virulence from the parent species, thus making predictions about the potential effects of an ongoing invasion even more difficult.

Fifth, the nurseries or plantings in gardens or restoration projects also provide suitable environments for prolific germination and spread.

All of these risks were first enumerated by the eminent British pathologist Clive Brasier a decade ago! (See Brasier et al. 2008 citation at the end of the blog.)

As Jung et al. 2018 point out, the scientific community has repeatedly urged regulators to require the use of preventative system approaches for producing Phytophthora-free nursery stock (see references in the article). Scientists have provided research-based guidance to reduce the risk of infestation. Such measures are being implemented by only some nurseries in the US. For example, USDA APHIS has specific requirements for nurseries that ship hosts of P. ramorum in interstate commerce after the nurseries or the plants have tested positive.  More broadly, APHIS, the states, and the nursery industry are in the second round of pilot testing of an integrated measures approach to managing all pests under the Systems Approach to Nursery Certification (SANC) program

At the international level, the International Plant Protection Convention has adopted ISPM#36, which also envisions greater reliance on systems approaches.  However, the preponderance of international efforts to protect plant health continue to rely on visual inspections that look for species on a list of those known to be harmful. Yet we know that most damaging Phytophthoras were unknown before their introduction to naïve ecosystems.

Furthermore, use of fungicides and fungistatic chemicals is still allowed before shipment.

As pointed out by several experts beginning with Dr. Brasier but including  Liebhold et al. 2012, Santini et al. 2013, Jung et al. 2016, Eschen et al. 2017, this approach has failed to halt spread of highly damaging pathogens. (I note that the list of such pathogens is not limited to Phytophthoras; see the description of ohia rust in Hawai`i, Australia, and New Zealand).

Jung et al. 2018 also call for increasing the genetic resistance of susceptible tree species. The authors regard this as the most promising sustainable management approach for stabilizing declining natural ecosystems and for reintroducing susceptible tree species at sites with high disease impact. See my blogs about efforts to enhance U.S. tree-breeding posted earlier this year.


SOURCES

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

Jung T, Orlikowski  L, Henricot B, et al. 2016. Widespread Phytophthora infestations in European nurseries put forest, semi-natural and horticultural ecosystems at high risk of Phytophthora diseases. Forest Pathology 46: 134–163.

Jung, T., A. Pérez-Sierra, A. Durán, M. Horta Jung, Y. Balci, B. Scanu. 2018. Canker and decline diseases caused by soil- and airborne Phytophthora species in forests and woodlands. Persoonia 40, 2018: 182–220   Open Access!

Liebhold AM, Brockerhoff  EG, Garrett  LJ, et al. 2012. Live plant imports: the major pathway for forest insect and pathogen invasions of the US. Frontiers in Ecology and Environment 10: 135–143.

Santini A, Ghelardini L, De Pace C, et al. 2013. Biogeographic patterns and determinants of invasion by alien forest pathogens in Europe. New Phytologist 197: 238–250.

Tsao PH. 1990. Why many Phytophthora root rots and crown rots of tree and horticultural crops remain undetected. Bulletin OEPP/EPPO Bulletin 20: 11–17

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.

New Study of Why People Move Firewood – and Its Relation to EAB Deregulation

We know that people moving firewood long distances is cause for great concern because of the likelihood that tree-killing pests will be transported to new and previously uninfested locations. This concern has been heightened by the USDA APHIS proposal to deregulate the emerald ash borer (EAB). As the principal federal “quarantine pest” transported by firewood, the EAB provides the legal foundation for most federal and state firewood regulations. (Of course, the EAB regulations also govern other articles that could transport wood-boring pests). (See earlier blogs here and here.)

Most forest pest professionals agree that the greatest risks are associated with individuals who transport firewood for recreational camping or summer homes. These people have proven to be the most difficult to regulate and the most likely to not see – or to ignore – messages intended to discourage them from moving firewood. The Nature Conservancy manages the “Don’t Move Firewood” program. It has done polling on messages and impact and concludes that the percentage of U.S. voters who have heard a “don’t move firewood” message remains steady and that those who have heard that message are less likely to transport firewood, especially over distances greater than 50 miles. More details are here

A recently published study by several academics and one forest service scientist reinforces The Conservancy’s earlier conclusion about the importance of outreach efforts as an essential component of programs intended to manage wood-boring pests. On the other hand, the new study points to additional nuances in crafting messages that will be effective in changing people’s behavior.

 

Findings

 

Daigle et al. 2018 (see full citation at the end of the blog) surveyed 272 people who were camping in public (state) or private campgrounds in three New England states in 2013 – four years after each of those states adopted regulations prohibiting out-of-state firewood and began their outreach efforts. Some campers apparently feel a strong connection to the place they are visiting, as shown by the fact that 84% of the 79 campers at private campgrounds had spent two or more nights camping in the same state in the previous year. That emotional connection might provide a motivation that could be activated to persuade those campers to stop transporting firewood (see below).

The authors found that slightly more than 25% of the 272 respondents reported that they often or always brought firewood from home for camping. More discouraging is that they found that people might not comply even when informed about the risks. Instead, compliance depended largely on the individual’s motivation and commitment level rather than knowledge. Worse yet, campers categorized as “highly involved” in the forest pest issue were just as likely to transport firewood from home as were others. Apparently, these non-compliant campers did not fully “connect the dots” between their concerns about forest health and their own actions. See below for Daigle et al.’s suggestions for ways to help people make those connections.

To understand the role of motivation, Daigle et al. tried to assess the strength of each camper’s beliefs about the relationship between tree-killing pests and the transport of firewood by recreational campers.

Overall, 25% of respondents were very highly involved with tree pest issues; another 22% were highly involved. Respondents’ perception of the relationship between damaging tree pests and transport of firewood differed significantly based on their levels of involvement. Respondents with a low level of involvement were less likely to agree with three statements (listed below) that firewood-associated pests pose a serious threat. Campers with very high levels of involvement strongly disagreed with three other statements that either downplayed the threat or portrayed the respondent’s compliance as “useless” as long as others continue to transport firewood.

Perception questions against which respondents’ agreement or disagreement was measured:

  • “There is not much one individual can do about invasive pests brought in by firewood”
  • “I don’t think invasive pests brought in by firewood are very important.”
  • “The threat of invasive pests brought in by firewood is serious.”
  • “As long as other people continue to bring firewood from home, my efforts to prevent invasive pests are useless.”
  • “The invasive forest pest risk from firewood is exaggerated.”
  • “In the long run, things will balance out with invasive pests.”

 

Rationale

Respondents’ most frequent explanations for why they take firewood from home when they go camping were cost, quality, and convenience. The most frequently cited reason for not transporting firewood was that the respondent knew that it was not allowed.

Level of pest awareness:

While nearly all respondents (92%) had heard something about non-native pests killing trees, but 57% could not recall the name of a specific pest in the absence of a prompt. When asked about the emerald ash borer and Asian longhorned beetle, more respondents had heard about the ALB (77% v. 52%). Most said the principal source of information was a state agency.

 

Suggested Actions

Daigle et al. conclude that authorities need to increase citizens’ exposure to outreach materials in order to activate concern and bring about desired actions to curtail risk of pests in firewood.

One clear need is to counter many campers’ belief that their wood is safe so it is okay to transport it regardless of the regulations. Often they based that belief on the fact that their home is not in a designated quarantine zone. Daigle et al. suggested that educational material should try to counter this belief by emphasizing the time lag between a pest’s establishment and its detection.

To help “connect the dots” between campers’ concerns about forest health and the implications of their actions (transporting firewood), survey respondents suggested using more visuals showing the destruction caused by the invasive forest pests, especially in areas they care about – close to home or favorite recreation areas. Daigle et al. thought such pictures would “help the campers with high involvement to trigger activation of attitudes with the association of forest pests and firewood transport.”

Other suggestions for strengthening outreach were to ensure that the message

  • Is novel – that it does not simply reiterate a camper’s initial belief system.
  • Produces agreement by the recipient without generating counterarguments.
  • Is relevant to the audience’s concerns.

They also suggested that campgrounds (public and private) help motivate campers to leave firewood at home by coordinating with local firewood vendors to provide competitively priced firewood at the campground or by including the cost of providing some firewood in the camping fee.

Daigle et al. made two other suggestions that call for stronger actions.

First, they suggested that outreach programs incorporate incentives or rewards to engage people who don’t have a high level of involvement in forest health issues.

Second, they suggested that authorities reinforce the educational message by using “more direct” actions, such as

  • confiscating illegally transported firewood at check stations,
  • issuing warnings about such actions, or
  • administering fines for moving non-compliant firewood.

The authors suggest that state agencies should consider taking these actions – but I see no reason why federal agencies should not also.

EAB; David Cappaert

Conclusions re APHIS’ Proposal to Deregulate EAB

Daigle et al. conclude that outreach efforts aimed at curtailing movement of firewood need to be continued. They are a critical component of overall management programs targetting non-native tree-killing pests – programs developed through decades of research and trials. The motive is clear: more effectively delaying these pests’ spread provides large benefits to municipalities and homeowners.

These are the same points made by many who opposed APHIS’ proposal to deregulate the emerald ash borer.

In its comments to APHIS, The Nature Conservancy noted that the domestic EAB quarantine had been effective in limiting spread of the pest through two of the most important pathways – firewood and nursery stock. The resulting slower spread had protected three-quarters of the ash range in the United States and bought time to develop mitigation measures.

Further, eliminating the federal quarantine would not only unleash this pathway for long-range movement of EAB but undermine the many federal, state, regional, tribal, private, and non-profit  partners’ efforts to curtail movement of all invasive forest pests in firewood.

Many other commenters, including several state agencies, the National Association of State Foresters and Southern Group of State Foresters called for APHIS to continue leading national efforts to curtail spread of EAB and other pests through careless movement of infested firewood. The Montana Department of Natural Resources and Conservation and NASF specifically urged that APHIS reinstate the National Firewood Task Force (which APHIS led in 2009-2010).

The Don’t Move Firewood program has a more informal blog on this topic, available here.

 

Source

Daigle, J.J., C.L. Straub, J.E. Leahy, S.M.De Urioste-Stone, D.J. Ranco, N.W. Siegert. How Campers’ Beliefs about Forest Pests Affect Firewood Transport Behavior An Application of Involvement Theory. Forest Science XX(XX):1-10  https://academic.oup.com/forestscience/advance-article/doi/10.1093/forsci/fxy056/5232804

 

South African report: Rigorous, Honest, and a Model for U.S. and Others

Density of invasive plants in South Africa

map available here

 

Last month, in my blog about the US Geological Survey’s report on invasive species  I announced release of a report by South Africa on its invasive species management programs – available here.  Because this report is unusual in both its rigor and its honesty, I’m returning to it here. I think it is a model for our country and others.

The report provides the basics. That is, it analyzes pathways of introduction and spread; number, distribution and impact of individual species; species richness and abundance of alien species in defined areas; and the effectiveness of interventions. Of the 775 invasive species identified to date, 556, or about 72%, are listed under some national regulatory program. Terrestrial and freshwater plants number 574 species; terrestrial invertebrates number 107 species. A different set of 107 species, or about 14%, are considered by experts to be having major or severe impacts on biodiversity and/or human wellbeing. The highest numbers of alien species are in the savanna, grassland, Indian Ocean coastal belt, and fynbos biomes. South Africans are particularly focused on the reductions in surface water resulting from plant invasions. Much of the control effort is under the egis of the decades-old “Working for Water” program.

Also, the report has features that are all-too-rare in work of its kind. First is the authors’ focus on rigor – of data sources and interpretation of those data using standardized criteria. Second – and even more important – is their call for analyzing the efficacy of the components of invasive species program. They insist on the need to measure outcomes (that is, results), not just inputs (resources committed) and outputs (“acres treated”, etc.). Inputs are far easier to measure and are, unfortunately, the mainstay of how most U.S. efforts are tracked – if they are tracked at all.

As they note, measure of inputs and outputs are not useful because they provide no guidance on the purpose of the action or treatment or of its effectiveness in achieving that purpose.

(For earlier CISP advocacy of measuring outcomes, visit the National Environmental Coalition on Invasive Species and read the bullet points under “Recommendations for a Comprehensive National Response”.)

The report has been praised by international conservationists, including Piero Genovesi – chair of the IUCN’s Invasive Species Specialist Group. British ecologist Helen Roy says that, to her knowledge, it is “the first comprehensive synthesis of the state of invasive species by any country.”

 

How well are programs working?

The authors’ focus on rigor includes being scrupulously honest in their assessments of current program components. They note deficiencies and disappointments, even when the conclusions might be politically inconvenient. To be fair, all countries struggle to achieve success in managing bioinvasions. And South Africa is, in many ways, a developing country with a myriad of economic and social challenges.

So it is probably not surprising that, for most factors analyzed, the authors say data are insufficient to determine the program’s impact. Where data are adequate, they often show that programs fall short. For example, they conclude that control measures have been effective in reducing populations of established invasive species, usually plants, in some localized areas but not in others. While the situation would arguably have been worse had there been no control, current control efforts have not been effective in preventing the ongoing spread of IAS when viewed at a national scale. Only one of South Africa’s 72 international ports of entry has consistent inspection of incoming air passengers and cargo – and even those inspections are not carried out outside of regular working hours (e.g., nights and weekends).

The authors are even critical of the “Working for Water” program – which is the basis for most control efforts in South Africa and enjoys wide political support. WfW has two goals: providing employment and development opportunities to disadvantaged individuals in rural areas, and managing invasive alien plants. Despite substantial funding, the WfW program has supported control teams that have reached only 2% – 5% of the estimated extent of the most important invasive plants. Furthermore, programs structured to provide employment have not ensured use of the most efficient control strategies.

 

What’s needed in South Africa — and around the world

The authors conclude that South Africa needs new processes to monitor and report on bioinvasions in order to achieve evidence-based policy and management decisions. They call for (1) more research to determine and assess invasive species impacts; (2) better monitoring of the effectiveness of current control measures; and (3) the development of methods to look at the impact of bioinvasions and their management on society as a whole.

The authors say it is important for South Africa to improve its management of invasive species because their impacts are already large and are likely to increase significantly. They note that improving management efficiency will require difficult choices and trade-offs. They recommend a focus on priority pathways, species, and areas. They also stress return on investment.

 

I don’t know how this report has been received in South Africa. I hope government officials, media observers, landowners, political parties, and other stakeholders appreciate the honesty and expertise involved. I hope they take the analyses and recommendations seriously and act on them.

(Preparation of the report was was overseen by a team of editors and contributing authors employed by the South African National Biological Diversity Institute (SANBI) and the DST-NRF Centre of Excellence for Invasion Biology at (C.I.B). Drafts were widely circulated to contributing authors and other stakeholders for comments. An independent review editor will be appointed to assess the review process and recommend any ways to strengthen the process for future reports.)

 

Meanwhile, how do we Americans apply the same rigor to analyzing our own efforts?

 

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.

 

 

APHIS’ Strategic Plan – Focus on Deregulation & Trade Facilitation

APHIS’ headquarters building

USDA APHIS released its Strategic Plan for fiscal years 2019-2023 just after Thanksgiving. The report is 21 pages long. There is no evidence that any stakeholders were asked for input or review.

The Plan has a disappointing – but not surprising – emphasis on deregulation and “customer service”. A second – and more surprising weakness is the lack of attention to plant pests – even those of agriculture, much less natural resources. The emphasis is clearly on animal pests and diseases – including zoonotics.

APHIS’ mission is “To safeguard the health, welfare and value of American agricultural and natural resources.” To accomplish this mission, APHIS has set three goals:

  • Deliver efficient, effective, and responsive programs.
  • Safeguard American agriculture.
  • Facilitate safe U.S. agricultural exports.

Most references to protecting natural resources relate to finding more environmentally sensitive approaches for the program under which APHIS reduces human-wildlife conflicts (e.g., birds being struck by airplanes).

In the Plan, APHIS Administer Kevin Shea writes in his opening message that achieving APHIS’ difficult mission of protecting the health and value of America’s agriculture and natural resources cannot be accomplished by APHIS alone. Instead, the agency must work collaboratively with other government agencies and industry, and consult regularly with partners and stakeholders regarding programs’ effectiveness. Administer Shea also highlights the importance of “delivering our programs and services efficiently, effectively, with integrity, …” The agency promises to modernize information technology, data management, methods of communication with collaborators, exporters and importers, etc., in order to give good return on expenditure of taxpayer resources. APHIS also pledges to make decisions based on science. There are seven references to basing decisions on scientific data.

Fair enough. Such emphases were to be expected from Trump Administration and prefigured by USDA Secretary Sonny Perdue during his nomination hearing, e.g., facilitating exports, supporting better information technology.

However, the Plan refers to “customer service” or “customer experience” 34 times. An additional seven references are made to reducing regulatory burdens. The Plan also speaks of the need to “protect the health, welfare, and value of American agriculture and natural resources. … at a reasonable cost. … Easing regulatory burdens makes it easier to create jobs and promote economic growth.” (Emphasis added.)

Perhaps the recent proposal to deregulate the emerald ash borer is driven in part by the emphasis on minimizing costs to regulated industries and seeking alternative approaches? (Although the deregulation has been under discussion for several years, predating the Trump Administration.)

from APHIS PPQ website

The imbalance in attention to animal versus plant pests and disease is striking. Each of the 14 goals is supported by a number of specific tactics. There are a total of 100 “tactics” under the two goals most directly relevant to preventing or managing pest introductions. These goals are: “Protecting America’s agriculture” and “Promoting U.S. agricultural exports.” Of the 100 tactics, only ten are clearly related to plant pests; 19 are pretty clearly activities that apply to both plant and animal pests and diseases; and five are unclear as to whether they include plant pests as well as animal diseases. Thus, only a third of the tactics apply!

[In making this calculation, I did not include 43 tactics listed under the first goal (“Deliver efficient, effective, and responsive programs”) or three objectives under the goal of “Protecting American agriculture” that apply explicitly to wildlife management, regulating genetically engineered organisms, or ensuring humane treatment of animals.]

Specific examples of such lack of balance include the six examples illustrating the declaration (on p. 4) that “Pest and disease events are more frequent, more complex, and less predictable.” Five of the examples are animal diseases, the sixth is the insect-vectored human disease caused by the Zika virus.

In discussing its efforts to balance its safeguarding efforts against increasing requests for market access by international trading partners, APHIS mentions some activities pertinent to plant as well as animal pest management, e.g., examining disease and pest risks and inserting mitigation strategies into international agreements and interstate movement protocols. However, the only specific action it mentions is helping countries to build capacity to implement the Global Health Security Agenda.

The only reference to forest pests is under one of the 24 tactics associated with Goal 2. Safeguard American agriculture, Objective 2.1: Prevent damaging plant and animal pests and diseases from entering and spreading in the United States to promote plant and animal health. This tactic calls for strengthening the North American perimeter against pest threats from outside the region to prevent introduction of agricultural, forest, and other invasive pests.

Why are Plant Pests slighted?

Perhaps plant-related efforts were left out because they are less “sexy”? Or because they are more distantly linked to human health? The Plan does state that “The tactics in this plan represent only a portion of APHIS activities and by no means embody all the important work APHIS does to fulfill its mission.”

Who knows what was left out?

How will adoption of this strategy affect future efforts to address tree-killing insects and pathogens – both those already present in the country and those yet to be introduced?

Might PPQ Fill in the Gaps?

In 2014 APHIS Plant Protection and Quarantine issued its own strategic plan. This supplementary plan made frequent mentions of safeguarding natural resources. Indeed, the third of the plan’s seven goals stated:                              

Goal 3: Protect forests, urban landscapes, rangelands and other natural resources, as well as private working lands from harmful pests and diseases

Several “tactics” under each goal also directly applied to protecting natural resources. I list them below:

1) Prevent the entry and spread of ag pests and diseases.

  • Coordinate with Canada to implement an effective multi-national system that reduces the threat of tree pests arriving from Asia and other parts of the world (e.g. AGM).

3: Protect forests, urban landscapes, rangelands and other natural resources, as well as private working lands from harmful pests and diseases

  • Maintain EAB regulatory framework to focus on the leading edge of infestations while minimizing impacts on regulated businesses in quarantined areas.
  • Evaluate the effectiveness of biocontrol releases in states and combining both regulatory & outreach activities to address the risks of moving logs, firewood, and nursery stock.
  • Examine detection technologies and partnering with states to determine and apply the most effective strategies to survey & eradicate the Asian longhorned beetle
  • Partnering with federal and state agencies to enact measures such as a public outreach campaign to mitigate the movement of forest pests through firewood.
  1. Ensure the safe trade of ag products, creating export opportunities for U.S. producers
  • play a leadership role in revising ISPM#15
  1. Protect the health of U.S. agricultural resources, including addressing zoonotic disease issues and incidences, by implementing surveillance, preparedness and response, and control programs
  • Strengthen partnerships with Tribal Nations to develop a robust surveillance and early detection system for detecting and reporting invasive species.
  • Work with all stakeholders to coordinate all-hazards agriculture and natural resources response support.
  • Develop science-based programs in collaboration with industry and academia to jointly identify practices that will mitigate pest damage. E.G., SANC program http://sanc.nationalplantboard.org/ [a Systems Approach to Nursery Certification] implemented jointly with the National Plant Board and nursery industry

Dare we hope that PPQ adopts an updated strategic plan that fills in some of the gaps in the overall APHIS plan?

 

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.

 

Comments on EAB deregulation show costs would be too high

Kelly Church (Grand Traverse Band Ottawa Chippewa) with baskets she wove from black ash

 

As you know, in September APHIS published a proposal to alter management of the emerald ash borer (EAB). Under the proposal, APHIS would no longer regulate movement of firewood, nursery stock, or other items that can transport EAB to new areas. Instead, APHIS proposed to rely on biological control to reduce impacts and – possibly – slow EAB’s spread. I have posted two blogs about the weaknesses of the underlying analysis and the decision by the Center for Invasive Species Prevention to oppose the proposal. The proposal, accompanying “regulatory flexibility analysis,” and 150 comments by the public are posted here.

The Don’t Move Firewood program has provided links to the individual organizations’ comments here.

 

Here I summarize major points made by those commenting on the proposal.

Most state agriculture departments accepted the proposal. Few commented at all, leaving that to the National Plant Board. The NPB letter consisted of only four paragraphs. In contrast, several state forestry agencies commented.

Several organizations, including the National Plant Board and AmericanHort, agreed with APHIS that the quarantine has not worked primarily because detection tools are so poor. As a result, EAB is able to firmly establish for several years and spread in a new area before authorities detect it and take action.

It is clear from the comments that deregulating EAB might save APHIS money and effort, but the action will exacerbate the already substantial burden on many other U.S. entities – ranging from federal agencies such as USDA Forest Service and National Park Service to homeowners; woodlot owners to (potentially) exporters of all sorts of products; to Native Americans. The economic components of this potential burden surely deserve more serious evaluation as required under several Executive orders.

Comments Categorized

1) The quarantine has slowed the spread of EAB and it remains valuable in granting communities time to prepare

Several of the commenters wished to counter the proposal’s inference that quarantines had failed; rather, they insisted that quarantine has slowed spread of the EAB and that this strategy is still valuable because it gives un-infested areas more time to prepare. Those voicing this view included the National Association of State Foresters; Maine Department of Agriculture, Conservation and Forestry; Montana Department of Natural Resources and Conservation; Fond du Lac Band of Lake Superior Chippewa in Wisconsin; several bands of Native Americans in Maine (Houlton Band, Penobscot, an individual member of the Penobscot); The Nature Conservancy; a man who is both park superintendent for the City of Kalispell, Montana and Chair of the Montana Urban and Community Forestry Association; three local conservancies in Oregon (West Multnomah Soil and Water Conservation District;  Four-County Cooperative Weed Management Area from Clackamas, Clark, Multnomah and Washington counties in the greater Portland Metro area; Tualatin Soil and Water Conservation District); Jefferson County Colorado Invasive Species Management team; Maine Mountain Collaborative; Blue Hill Heritage Trust of Maine; a small woodland owner in Maine; and a Professor in the School of Forest Resources at the University of Maine.

Oregon’s Department of Environmental Quality Water Quality Division opposed the APHIS proposal. The Division noted that EAB spread in the east was facilitated greatly by the continuity of ash habitats whereas ash habitats are much more patchy in the West. Given this situation, human transport is the most likely means by which EAB will reach the West – either from infested portions of the U.S. or via trans-Pacific trade.

A few entities that supported APHIS’ proposal – e.g., the Southern Group of State Foresters and – in a separate letter – Texas Forest Service – also said the quarantine had been helpful.

As The Nature Conservancy said in its comments, the quarantine effectively limits two of the most important pathways, firewood and nursery stock. The result has been to protect much of the country from the pest and buying time to develop mitigation measures.

 

2) APHIS’ dismissal of quarantine is a worrying message (see also discussion of firewood below)

Several of the commenters expressed concern that APHIS too curtly dismissed the value of quarantine – both as it functioned to slow spread of EAB and as a tool used against a wide range of pests. Commenters raising issues about the proposal’s apparent undermining of quarantine as a strategy included the Kansas Forest Service; Maine Department of Agriculture, Conservation and Forestry; Vermont Agency of Agriculture, Food and Markets and the Department of Forests, Parks, and Recreation; and Wisconsin Department of Natural Resources Division of Forestry. The Vermont and Wisconsin agencies asked APHIS to clarify to affected parties what it expects to achieve by the proposed deregulation. The Fond du Lac Band of Chippewa warned that the public might interpret the dropping of regulations as signaling that EAB is no longer important.

Five organizations unified under the banner of the Coalition Against Forest Pests noted that APHIS had set a precedent of dropping regulations when quarantines appear to fail.

A subset of these comments focused on a lack of clarity by APHIS as to its future strategy.

Several commenters said that APHIS had not outlined a coherent strategy for the future. The Kansas Forest Service even called the proposal an agency “exit strategy” rather than a coherent plan. Others raising this issue included the Maine Department of Agriculture, Conservation and Forestry; South Dakota Department of Agriculture and Department of Game, Fish and Parks; and the Coalition Against Forest Pests. Maine noted that the proposal would shift the burden of regulation to the states. Maine and South Dakota said that APHIS, as the responsible federal regulatory agency, should provide a clear and consistent process for regulation of potentially infested products across state lines.

The Tennessee Forest Health Coordinator called for an analysis of EAB program successes that might point to ways in which APHIS could support alternative strategies. A professor of forestry in Maine said APHIS should evaluate and assess techniques specifically to optimize the effectiveness of education and outreach.

Among entities which supported APHIS’ proposed new approach, the Southern Group of State Foresters, Texas Forest Service, and two Vermont agencies – Agency of Agriculture, Food and Markets and the Department of Forests, Parks, and Recreation – urged APHIS to champion a national, multi-agency approach to managing EAB, including creation of a national, voluntary treatment standard and label for firewood; redirecting all savings to research & management – including state surveys. These groups also advocated funding increases for APHIS, the USDA Forest Service, and state EAB programs; and support for states to carry out their enlarged responsibilities for survey, outreach, education, and assistance to affected parties.

The Vermont agencies wrote that EAB “is a nationally significant pest, … which warrants a significant federal role.” Because EAB impacts on communities, forest health, and the forest economy continue to expand, a decision to discontinue regulatory activities should be accompanied by increased federal support for research and management.

The National Association of State Foresters also called for APHIS to champion a national, multi-agency approach, with a somewhat longer list of components. These should include support state research and management efforts, the biocontrol program, identifying genetic strains of ash trees that are resistant to EAB, maintain national treatment criteria for wood products (including firewood), and reconvene the National Firewood Task Force. NASF also urged the USDA Forest Service to develop a cooperative management program to sustain and replace ash trees killed by EAB.

Dr. David Orwig of Harvard Forest also called for funding not just biocontrol but also research areas like silviculture, chemical control, ash utilization, and management guidelines.

This pattern of asking for continued or expanded federal engagement – beyond biocontrol – is quite apparent.  Some entitites that said they supported APHIS’ proposal nevertheless called for the agency to continue detection and response components of the program – expressly contrary to the proposal itself.

Thus, AmericanHort, the two Vermont agencies, Wisconsin Department of Natural Resources Division of Forestry, and two Maine departments called for APHIS to continue or increase its engagement in EAB detection and other management activities – including biocontrol, outreach to explain the change in strategy, and engaging the National Park Service and Forest Service in promulgating a consistent firewood policy.

Others who asked for similar commitments were straightforward in opposing the proposal. Thus the North Dakota Department of Agriculture and North Dakota Forest Service – in separate letters – asked that APHIS continue to provide resources to help states monitor EAB presence and respond to any new detections. The Oregon Department of Forestry asked that federal agencies continue to fund research and development of early detection and rapid response strategies for EAB; conservation of ash genetic resources and promotion of natural resistance; research on uses of dead ash; as well as classical biocontrol once EAB is established in a new area.

Several commenters said that they had considered APHIS to be a critically important partner in countering the EAB and were disappointed that the agency is backing away. Native Americans in particular considered the proposal to be a betrayal of the Federal government’s treaty responsibilities vis a vis recognized tribes. The Fond du Lac Band of Wisconsin wrote that upholding a federal EAB regulation is vital to the protections of important cultural and natural resources both on the Reservation and within territories ceded to the Band by several 19th Century treaties. The tribe cited EO 13175 issued by President Clinton. The Houlton Band of Maine said APHIS has a mission to defend federally recognized tribes against invasive species.  The federal government should not make a decision so contrary to its fiduciary trust responsibility to federally recognized tribes.

 

3) Need for continued APHIS leadership on firewood regulation

The importance of APHIS continuing to lead national efforts to curtail spread of EAB (and other pests) through careless movement of infested firewood was stressed by many commenters. Voicing this need were many of the entities which opposed the proposal, including Maine Department of Agriculture, Conservation and Forestry; Montana Department of Natural Resources and Conservation; Southern Group of State Foresters; Texas Forest Service; the two Vermont agencies; The Nature Conservancy; and the National Association of State Foresters. As noted above, the NASF, Southern Group, Texas, and Vermont all said APHIS should support creation of a national, voluntary treatment standard & label for firewood. TNC said eliminating the EAB quarantine – the best known and understood firewood regulation – will exacerbate difficulties of outreach. Public outreach and education work best when they are backed up by core consistent rules. Montana Department of Natural Resources and Conservation and NASF called for reinstating the National Firewood Task Force (which APHIS led in 2009-2010).

Several entities that supported the proposal also called for continued APHIS engagement on firewood. One, the Wisconsin DNR Division of Forestry, urged APHIS to work with the National Park Service and Forest Service to create a consistent firewood policy. A second, the NPB, noted that it is developing guidance to states interested in initiating regulations, best management practices, or outreach programs. The NBP added that it welcomes any assistance from APHIS.

As The Nature Conservancy and Tennessee Forest Health Coordinator pointed out, the firewood effort – federal regulations, state regulations, education and outreach under the “Don’t Move Firewood” campaign – all helped curb movement of several tree-killing pests, not just EAB.

 

4) Others Pointed Out the Importance of Consistent Regulations to Keep Markets Open

A smaller number of entities addressed the similar importance of consistent rules governing interstate and US-Canadian trade in other types of vectors that can transport EAB and which are to be deregulated under the proposal. These included the NASF.  Several private groups from Maine and the Maine Department of Agriculture, Conservation and Forestry noted the importance of reaching agreement with Canada, which is a major market for their wood products. The two South Dakota departments also expressed concerns.

The National Wooden Pallet and Container Association raised the prospect of truly tremendous disruption of trade. At present, the United States and Canada exempt wood packaging originating in either country from requirements that it be treated in accordance with international standards (ISPM No. 15). Canada has many reasons to fear that crates and pallets carrying exports from the U.S. might be infested by EAB once APHIS stops enforcing quarantine regulations. If Canada responds by ending the exemption and requiring wood packaging from the U.S. to comply with ISPM#15, that action would affect a wide range of U.S. exports – from fruits to auto parts. In 2017, the U.S. exported $282 billion worth of goods to Canada (Office of the U.S. Trade Representative)

 

5) The Economic Analysis Underlying the Proposal was Inadequate

Several commenters criticized the adequacy of the economic analysis. The most specific criticisms were put forward by the California Forest Pest Council; CISP; the five organizations commenting under the banner of the Coalition Against Forest Pests; and the National Wooden Pallet and Container Association. The latter two cited specific Executive orders and the Paperwork Reduction Act in calling for a review of the proposal by the Office of Management and Budget & USDA Office of General Counsel to reassess whether it meets the conditions for the reduced economic analysis. As noted above, the NWPCA mentioned specifically a fear that Canada might discontinue the mutual exemption under which wood packaging may move between the two countries without being treated in accordance with ISPM#15. The possibility of such an action would certainly push the proposal over the $100 million threshold for completing much more rigorous economic analyses.

Other economic concerns not adequately addressed in the view of the commenters relate to costs arising earlier due to the faster spread of EAB to un-infested western states. Costs imposed earlier than would otherwise be the case are considered relevant in regulatory decisions. Furthermore, businesses in these and possibly other states will face new regulations adopted by states to fill the void left by federal deregulation. Finally, the lack of consistency arising from separate state regulations will impede interstate or US-Canada commerce.

Non-regulatory costs – death of trees and associated removal costs – costs to the forest industry, plus municipalities and home owners in areas not currently affected by infestation – were also not discussed in the proposal.

Several commenters said that APHIS had underestimated the ecological and cultural values threatened by spread of EAB. These included the Fond du Lac Band, Penobscot band, TNC, the Oregon soil conservation district and weed management area; Maine Mountain Collaborative and Woodland Owners, as well as several individuals.

The Nature Conservancy noted that three-quarters of the native ash range of the conterminous United States and 14 of vulnerable species in the U.S. and Mexico are still free of EAB as a result of the quarantine.

A Minnesota community’s Parks Commission noted that loss of trees to EAB can lead to other problems and costs. Consequently, the goal of “saving money” will not be achieved. In short, EAB-caused tree mortality “affects communities, including residents, homeowners, and taxpayers. Funding should be directed both to slowing the spread of the pest and to treatment of affected trees.”

A small woodland owner in Maine asked why APHIS did not evaluate economic impacts to landowners & municipalities.

Oregon’s Department of Environmental Quality Water Quality Division added that pesticides used to control EAB might cause negative impacts in riparian and aquatic environments.

 

6) Several Commenters questioned whether freed-up funds would support biocontrol – or whether they should

As noted in my earlier blogs, there are questions about whether biocontrol will be efficacious in protecting forests across the continent. CAFP echoed these questions. Blue Hill Heritage Trust of Maine called biocontrol experimental.

The Fond du Lac Band pointed out that most tribes don’t accept biocontrol on their reservations – so spending all available funds on this approach doesn’t help Native Americans.

The Maine government and the Penobscot Band of Maine expressed doubt that increased funding would actually materialize.

 

7) Comments that do not fit neatly into these categories.

The California Department of Agriculture said that it intends to promulgate a state exterior quarantine to protect its agriculture (olive trees are hosts of EAB) and environment.

The South Dakota Department of Agriculture and Department of Game, Fish and Parks concluded that interstate regulatory options should be a higher priority than other methods of control.

The Houlton Band of Maine said that maintaining the domestic quarantine is the only federal action that can adequately address the universally agreed fact that human activities cause the rapid spread of EAB.

The Western Governors Association described the region’s vulnerability to EAB spread and, citing recent Association policy resolutions, said a decision of this magnitude should be made only after substantive consultation with Western Governors.

The National Association of State Foresters pointed out that a decline in federal funding for EAB detection surveys will significantly reduce state forestry agencies’ capacity to monitor and respond to EAB spread.

The Jefferson County, Colorado Invasive Species Management team recommended retaining the quarantine using either the 100th Meridian or Continental Divide as the containment boundary. It cited as a justifications the “culture of vigilance” created by strong quarantines. This vigilance saves financial resources and protects natural and agricultural resources.

Finally, the Fond du Lac Band of Lake Superior Chippewa said that abandoning methods that are in place for the prevention of EAB’s spread, such as federal and state quarantines, and favoring only options that focus on rehabilitating a site after it has undergone a severe infestation, presents a large and unnecessary ecological risk. Invasive species programs have always focused on “prevention” being the key.

 

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.