invasive species policy – Page 14 – Center for Invasive Species Prevention

Interior’s Invasive Species Plan: Let’s Implement It!

Posted by Scott J. Cameron, former Acting Assistant Secretary for Policy Management and Budget , US Department of the Interior

locations in Hawaii Volcanoes National Park where ohia trees were infected by rapid ohia death pathogen in 2017

In 2019 Congress passed the John D. Dingell, Jr. Conservation, Management, and Recreation Act. Among other things, it directed the Department of the Interior to “develop a strategic plan that will achieve, to the maximum extent practicable, a substantive annual net reduction of invasive species population or infested acreage on land or water managed by the Secretary.” This provision triggered a year-long process of public involvement and inter-bureau coordination. The result was a plan published in January 2021. It represents the first attempt by Interior at a Department-wide multi-taxa, multi-year approach to invasive species. It has the potential to spur integration of invasive species work across the Department’s many bureaus and to focus each bureau’s efforts on a set of common goals, strategies, and performance metrics.

While Congress’ language is open-ended, any planning exercise is constrained by the most recent President’s budget and existing law. It is up to those of us who are not, or at least no longer, executive branch employees to advocate for plans unbound by those constraints.

In that spirit, I offer eight recommendations to improve invasive species management. Four are within existing authorities; four more are outside the current budgetary and statutory framework. Many more ideas are without a doubt worth pursuing.

*Opuntia* (prickly pear) cactus – common plant in western National parks and on Bureau of Land Management lands; under threat by cactus moth

First, within existing funding and legal authorities, the Department has unfinished business that it can act on now.

Secure approval of the package of categorical exclusions under the National Environmental Policy Act (NEPA) — now awaiting approval by the President’s Council on Environmental Quality (CEQ). Over many years agencies have documented how invasive species control improves, rather than harms, the environment. Absent an applicable NEPA categorical exclusion approved by CEQ, though, each such action needs to run the time- and money-consuming gauntlet of NEPA compliance. In the meantime, the invasive plants germinate, the invasive animals reproduce, and what might have been a localized and inexpensive problem has expanded geographically and in terms of cost and complexity. In the Fall of 2020 Interior submitted hundreds of pages of documentation on numerous practices proven to control invasive species without harming the environment. Due to time and staffing constraints at CEQ, these categorical exclusions still await action. Interior and CEQ should take prompt steps to finish them.

Allocate to the US Geological Survey at least $10 million of the roughly $90 million remaining available to the Secretary in CARES Act appropriations for research on invasive zoonotic diseases. These are diseases like COVID-19 and West Nile virus that can move from one species to another. Many zoonotic diseases fit the definition of invasive species, since they are not native to the United States and endanger human health. In the case of COVID-19 funding is available to the Secretary of the Interior, without need for further Congressional action, from funds appropriated by the CARES Act. The availability of these funds will expire at the end of September 2021, so Interior should provide this research funding to USGS as soon as possible.

Join the existing Memorandum of Understanding between the Western Governors Association (WGA) and the US Department of Agriculture’s Forest Service. These groups have established “a framework to allow the U.S. Forest Service (USFS) and WGA to work collaboratively to accomplish mutual goals, further common interests, and effectively respond to the increasing suite of challenges facing western landscapes.” This provides a forum to improve coordination between the States and the federal government on the management of invasive species, and Interior needs to be part of that team.

Interior should work with USDA to accelerate and intensify efforts to systematically improve coordination between the interagency Wildland Fire Leadership Council and the interagency National Invasive Species Council. Both Councils have member agencies that practice vegetation management using similar tools and techniques, although for different purposes. The two Councils should identify a select number of initiatives in FY21 where their efforts would benefit both wildland fire management and invasive plant management .

swamp bay trees in Everglades National Park killed by laurel wilt; photo by Tony Pernas

Four steps to implement the strategic plan outside the scope of current law and the President’s Fiscal Year 2021 budget. I offer the following:

Improve implementation of the Lacey Act program to list injurious species. There are both legislative and administrative elements to this proposal.

In a federal District Court decision on May 19, 2015, on a lawsuit filed by the Association of Reptile Keepers, the Court undid the longstanding Fish and Wildlife Service policy that the Lacey Act allowed FWS to ban interstate transport of injurious species. On April 7, 2017, the D.C. Circuit Court of Appeals upheld the District Court’s view. These rulings mean that FWS authority only applies to international commerce. Unfortunately, the court’s interpretation of the law and legislative history are reasonable, so Congress needs to amend the law to make it clear that FWS is explicitly authorized to regulate interstate commerce in injurious species. The Department of the Interior should work with the Department of Justice and the Office of Management and Budget to develop the necessary bill language and submit it to Congress.

At the same time, the FWS injurious species listing process is notoriously slow, even causing Congress to occasionally list species legislatively. The fact that these legislative initiatives have sometimes been promoted by Members of Congress who normally are opposed to more federal regulation signals just how awkward the current FWS process is. Thus there might well be strong bipartisan support to amend the Lacey Act on the interstate commerce matter. Acting on its own authority, FWS should procure an independent third party review of the injurious species listing process and ask the contractor to make suggestions for “business process reengineering” to improve and streamline current practices, along with evaluating whether higher funding or new technology is needed.

The Bureau of Reclamation, Department of the Interior, and the Office of Management and Budget should develop legislative language to submit to Congress for the 2022 Water Resources Development Act, that explicitly authorizes an aquatic nuisance species program in the Bureau of Reclamation. It could parallel the relatively new authority enjoyed by the Army Corps of Engineers and mandate increased coordination between the two water agencies.

Any climate change legislation pursued by Congress and the Administration should include provisions for addressing invasive species. Climate change will make some North American habitats more suitable for foreign organisms, as cold-intolerant species might be able to survive in more northern latitudes in the U.S. than previously was the case. Second, the disruptive effect of climate change on North American ecosystem structure and trophic relationships at any latitude will make those ecosystems more vulnerable to invasion. Finally, the spread of invasive species may in and of itself exacerbate climate change, such as through the increased carbon dioxide emissions from rangeland wildfires aggravated by the dominance of invasive cheatgrass.

The Senate Committee on Environment and Public Works and the House Natural Resources Committee should each hold oversight hearings on how best to help state and local governments detect and respond to new invasive species that are not within the statutory purview of USDA/APHIS. This is a complex topic, important for both ecological and financial reasons. Over the years several attempts to address it have failed. A thoughtful review by Congress and the Administration, which perhaps would lead to passage of new statutory authority and funding, is worth exploring.

The Author:

Scott Cameron recently left the federal government, where he had served as Acting Assistant Secretary for Policy, Management and Budget at the U.S. Department of the Interior. In that capacity he oversaw Department-wide budget, invasive species, natural resource damage assessment and restoration, environmental compliance and numerous administrative functions of this $14 billion agency with 65,000 employees. Previously, Scott held other civil service job (e.g., at the White House Office of Management and Budget) & political appointments in the federal government, on the staff of the Governor of California, and on Congressional staffs. While not in government, Scott led formation of the Reduce Risk from Invasive Species Coalition.

CISP welcomes 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.

Further information on the plant pests mentioned in the photo captions can be obtained at www.dontmovefirewood.org; click the “invasive species” button.

Invasive Plants in National parks – Progress?

Japanese stiltgrass in Shenandoah National Park; photo by Jake Hughes, NPS

The recent appearance of a study by National Park Service (NPS) scientists quantifying the threat posed by invasive plants prompted me to seek updates on this issue. In May 2018, I blogged about NPS’ Invasive Plant Program Strategic Plan, which was issued in 2016. At the time, I got the impression that the program was struggling to gain support from NPS leadership in Washington, as well as leaders of individual parks. Has the situation improved since then?

The recent study, by Kathryn Miller and colleagues, focuses on National parks in the East, from Virginia to Maine. (I provide a full reference at the end of this blog.) I look forward to a planned follow-up article that will try to clarify drivers of invasion.

The Miller study appears to have been undertaken to partially fulfill one of the goals of the NPS’ 2016 Invasive Plant Program Strategic Plan. One of the actions under Goal 1 in the Plan was to quantify the invasive plant threat, the effort needed to manage it, and then to communicate the gap between needs and available resources. Miller et al. have quantified the threat to National parks in one region (not the entire country). However, they have communicated the gap between effort and need in only the most general way.

Protecting the forests in eastern National parks is valuable from many perspectives. The forests in these parks are older and have higher stand-level tree diversity than surrounding unprotected forests. Protecting their long-term condition also corresponds to the National Park Service’s (NPS) stated mission, as established in its Organic Act.

The study relied on National Park Service Inventory and Monitoring Program data from 1,479 permanent forest plots covering 39 eastern NP units located from Virginia to Maine. The data were collected over 12 years, in three survey cycles (2007–2010, 2011–2014, and 2015–2018).

The authors note that in forest ecosystems, invasive plants can reduce native diversity, alter forest structure, suppress tree regeneration, alter nutrient cycling, and modify disturbance regimes. Some – the shrubs and vines – also threaten human health by promoting increases in tick populations and associated Lyme disease risks.

Unsurprisingly, the data showed invasive plants to be widespread, and increasing. In 80% of the park units, there was a significant increase in at least one trend measuring abundance. Any decrease in plant invaders tended to be in herbaceous or graminoid species; that decrease was often counterbalanced by an approximately equivalent increase in invasive shrubs or vines. In 35 of the park units, more than half of the plots had at least one invasive plant species when the 2015-2018 survey began. In 10 parks (a quarter of those surveyed), every plot had at least one.

The most widespread species is Japanese stiltgrass (Microstegium vimineum). It is present in more than 75% of all park units and 30% of all 1,400 plots. This dominance is true despite the fact that stiltgrass does not extend north of Roosevelt-Vanderbilt National Historic Site in New York state (41^o N latitude). Stiltgrass is also the most aggressive invader.

The second most widespread invaders are a group of shrubs and vines, including most notably Japanese barberry (Berberis thunbergii), Japanese honeysuckle (Lonicera japonica), multiflora rose (Rosa multiflora), and wineberry (Rubus phoenicolasius). I note – although the articles does not – that several of these have been deliberately planted – either to “enhance” ecosystems (multiflora rose) or as ornamentals (barberry). [Lehan et al. 2013 (full reference at end of blog) found that 95% of 125 shrub species introduced to the U.S. were introduced deliberately.] I know of no examples of deliberate planting of Japanese stiltgrass.

The most frequently detected non-grass herbaceous species is garlic mustard (Alliaria petiolata), which was detected in 20% of plots. Garlic mustard is found throughout the study area (Virginia to Maine). Tree-of-heaven (Ailanthus altissima) is the most common invasive tree. It is found in only 9% of plots and does not grow north of Roosevelt-Vanderbilt NHS. Again, both were intentionally introduced – and not noted as such in the article.

Because they could not identify the source populations for each plot, the study could not directly measure rates of establishment and expansion. The data did allow tracking rough trends in each park.

Parks with the highest abundance tended to be near densely populated areas. However, this pattern was not universal. For example, Prince William Forest Park in the outer Virginia suburbs of the District of Columbia metro area was one of two of the least invaded park units.

(note the prevalence of beech – I fear for the arrival of beech leaf disease!)

Total invasives increased significantly in 21 of the 39 parks for at least one metric. In 10 parks (a quarter of all parks), total invasives increased significantly in two of the three metrics. Antietam National Battlefield experienced the steepest increases.

The authors note that invasive plants continue to establish and expand, even in already heavily invaded forests. Thus they found little evidence of saturation. This finding conflicts with invasion theory. They also found antagonistic interactions between invasive species to be common.

The authors said managers should prioritize efforts to control Japanese stiltgrass and the shrubs and vinesdue to their widespread occurrence, rapid expansion, ability to suppress tree regeneration and understory diversity, and – in the case of the shrubs and vines, link to ticks.

The authors noted the need to better understand the drivers and impacts of invasive plants in eastern forests. They mentioned the overabundance of white-tailed deer (Odocoileus virginianus), latitude, climate change, fragmentation and urbanization. I have urged them to include analysis of deliberate planting of various species on lands within the park units or nearby. They have said that they will do so in the planned follow-up article.

The authors propose that deferred management of natural resources receive attention and sustained commitment on par with the attention to deferred maintenance of the park units’ infrastructure. The maintenance backlog has been addressed through recent legislation: the Great America Outdoors Act which provided $6.5 billion over five years to address deferred maintenance projects in all 419 national park units. I believe that these projects will not address invasive species, which are managed under the “Natural Resources” budget account, not “Maintenance”. Some “Maintenance” projects probably will include control of invasive plants. A former Interior Department official has suggested that resource management activities might be funded under another section of the legislation, which provides $900 million under the Land and Water Conservation program. I hope this is true.

National Park Service’ Overall Invasive Plant Program Now

In response to the mandate in the John D. Dingell, Jr. Conservation, Management, and Recreation Act (Public Law 116-9), the Department of Interior has issued a department-wide invasive species strategy. Will issuance of the new strategy provide impetus to the NPS to seek funding to implement its 2016 invasive plant strategic plan? Will Congress provide funds for this purpose?

Finding out the current status of National Park Service took a little effort. The NPS’ website has “popular” information about the efforts of individual regional Invasive Plant Management Teams (see links at the end of this blog). These posts provide only the briefest overview of program achievements and do not compare those accomplishments to the goals in the 2016 plan.

However, Terri Hogan, Invasive Plant Program Manager in the Biological Resources Division, provided following information:

NPS leadership now supports the agency’s invasive plant effort. The national Invasive Plant Program (IPP) contributes to the annual Natural Resource Stewardship and Science Directorate (NRSS)’ Biological Resource Division (BRD) work plan. All is guided by the “Four Pillars to Guide Natural Resource Activities and Investments”, adopted in 2016.

It is not clear that invasive species have the highest priority under this regime. The four “pillars” are

Holding the line – includes conserving biodiversity by removing invasive plants
Managing amid Continuous Change – includes conducting risk assessment and taking other actions to contain future exotic species
Leveraging for Conservation at Scale
Enhancing Stewardship and Science Access and Engagement

Cooperation with owners of neighboring private lands has been enhanced by engagement of the Western Governors Association and state and local political leaders. Many parks participate in Partnerships for Invasive Species Management (PRISMs), CISMS, and Cooperative Weed Management areas (CWMAs). This collaboration has been strengthened by adoption of the John D. Dingell, Jr. Act (see above).

In practice, the focus appears to still be on the Invasive Plant Management Teams (IPMTs). There are now 17 teams. Fifteen are funded through the national office. One is funded by an individual park; one funded through a regional office. Annual reports have been published for FYs 2017 and 2018. The FY19 report has been held up but should be posted soon.

The reports provide brief description of the overall program and vignettes of particular activities. There are more detailed – but still anecdotal – reports for each of the teams. It is difficult to determine whether there has been overall progress. For example, the reported total infested acreage increased from 133,658 acres in FY17 to 301,195 acres in FY18. This presumably reflects more intense monitoring as well as a probable increase in real infections. (The infested acreage figures do not address intensity of invasion on these acres.) The teams cumulatively treated 8,937 acres in FY 2017; 8,331 acres in FY 2018. They carried out inventory and monitoring projects on 169,057 acres in FY17, 210,000 acres in FY18.

Since the Miller article concerns the region from Virginia to Maine, I checked the FY17 and FY 18 reports from the Invasive Plant Management Teams from the Mid-Atlantic, National Capital Area, and Northeastern regions. The Mid-Atlantic team emphasized work on wavyleaf basketgrass and meadows in parks established to protect cultural or historic sites. The National Capital Area team emphasized partnerships and success eradicating Giant Hogweed (Heracleum mantegazzianum) on private land neighboring Rock Creek Park. The Northeastern Team serves 25 parks; the report emphasized leveraging resources and testing efficacy of pre-emergent herbicide for control of Japanese stiltgrass. With this exception, the teams do not appear to be prioritizing the species recommended for action by the Miller study.

Brief, “popular” articles about the NPS’ invasive plant effort are available here

Invasive Plant Management Teams – Biological Resources Division (U.S. National Park Service) (nps.gov)

NPS 20 Years of Invasive Plant Management

20 Years of Action in 2020: Invasive Plant Management Teams

20th Years of Action – The NPS IPMT Program

SOURCES

Lehan, N.E., J.R. Murphy, L.P. Thornburn, and B.A. Bradley. 2013. Accidental Introductions are an Important Source of Invasive Plants in the Continental United States. American Journal of Botany 100(7): 1287–1293. 2013.

Miller, K. M., B. J. McGill, A. S. Weed, C. E. Seirup, J. A. Comiskey, E. R. Matthews, S. Perles, & J. Paul Schmit. 2020. Long-term trends indicate that invasive plants are pervasive and increasing in eastern national parks. Ecology. 00(00):e02239. 10.1002/eap.2239

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.

For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm

Bureau of Customs Strengthens Programs Aimed at Preventing Insect Introductions in Wood Packaging

This February marks 15 years since USDA began full implementation of ISPM#15. It is 22 years since the U.S. and Canada began requiring China to treat wood packaging (in response to introductions of the Asian longhorned beetle). Nevertheless, numerous shipments containing wood packaging that does not comply with the international regulations continue to arrive at our borders – and to bring pests. During Fiscal Years 2010 through 2019, CBP detected 7,900 shipments of wood packaging that harbored a pest significant enough to be in a regulated taxonomic group. In 2020, 16.6 million TEU from Asia entered the U.S. (Mongelluzzo Jan 21). If pest approach rates are the same now as 10 years ago, perhaps 6,000 or more of these containers bore wood packaging infested by tree-killing insects.

The Bureau of Customs and Border Protection (CBP), in the Department of Homeland Security, has taken steps to strengthen its programs aimed at getting insects out of the wood packaging pathway (described here).

I wish USDA APHIS took a similarly active stance. You can help by contacting your Congressperson and senators to urge their support effective actions, such as those I suggested in my blog in January.

CPB’s 2017 Improvement

Until November 1, 2017, CBD allowed importers to escape punishment until they had been caught using wood packaging that did not comply with ISPM#15 five times in one year. On that date, CBD began issuing a penalty under Title 19 United States Code (USC) § 1595a(b) or under 19 USC § 1592 to any party responsible for a shipment with a documented wood packaging violation. At the time, I praised CBP’s action. I have tried to find out how many times over the past three years CBP has used that new provision to issue penalties, but CBP staff have not replied to my question.

CPB’s 2020 Improvement

CBD took another step forward in 2020. The agency incorporated measures to clean up solid wood packing material (SWPM) into its Customs-Trade Partnership Against Terrorism (CTPAT) program. I had been urging this since 2016. It took a while – but CBP used that time to ensure that its action would be integrated into the program and so stay in effect.

CTPAT is a voluntary public-private sector partnership engaging the principle participants in international supply chains — importers, carriers, consolidators, licensed customs brokers, and manufacturers.

By signing on, they agree to help CBP ensure the highest level of cargo security. Specifically, when an entity joins CTPAT, it agrees to work with CBP to protect the supply chain, identify security gaps, and implement specific security measures and best practices.

CTPAT member companies receive several benefits in return. Because they are considered to be of low risk, their shipments are less likely to be examined and delayed at a U.S. port of entry. When they are subjected to inspection, they go to the front of the line – again, reducing costly delays. The CTPAT web-based Portal system provides a library of training materials. (Information from the CBP website; full citation at end of the blog.)

At present, more than 11,400 certified partners have joined the program. These include U.S./Canada highway and rail carriers and Canadian manufacturers – who are not subject to the U.S.’ wood packaging regulation per se. Thus, CBD’s action seems to extend pest-prevention protection to a group of suppliers previously exempted from this phytosanitary program. Inclusion of many Mexican carriers and manufacturers is also welcome, since Mexican suppliers have always ranked high in numbers of shipments that violate the ISPM#15 requirements.

Specific Minimum Security Criteria

CBP’s action took the form of adding a long list of critical new agricultural components to the Minimum Security Criteria (MSC) it already used. These include:

Having written procedures for both security and agricultural inspections.
Carrying out CTPAT approved security and agricultural inspections of all conveyances and empty Instruments of International Traffic (e.g., shipping tanks, lift vans) prior to loading. The inspection must ensure that they are not contaminated with visible agricultural pests.
If visible pest contamination is found during the inspection, the partner business must wash or vacuum the conveyance to remove such contamination. The company must retain documentation demonstrating compliance for one year.
Vessels that visited Asian Gypsy Moth (AGM) high-risk areas during periods when the moths are flying must present a pre-departure AGM inspection certificate from an approved entity stating that the vessel is free of AGM life stages. The AGM inspections must be performed at the regulated port as close to vessel departure time as possible. CTPAT sea carriers must provide CPB with two-year port-of-call data at least 96 hours before arrival at a U.S. port.
Cargo staging areas, and the immediate surrounding areas, must be inspected on a regular basis to ensure these areas remain free of visible pest contamination.
CTPAT Members must have written procedures designed to prevent visible pest contamination to include compliance with ISPM#15 regulations. Visible pest prevention measures must be adhered to throughout the supply chain.
Members must establish and maintain a security training and awareness program to recognize and foster awareness of the security vulnerabilities to facilities, conveyances, and cargo at each point in the supply chain. The training program must be comprehensive and cover all of CTPAT’s security requirements. Personnel in sensitive positions must receive additional specialized training geared toward the responsibilities that the position holds.
Drivers and other personnel that conduct security and agricultural inspections of empty conveyances and Instruments of International Traffic (IIT) must be trained to inspect their conveyances/IIT for both security and agricultural purposes.
Training must be provided to applicable personnel on preventing visible pest contamination. Training must encompass pest prevention measures, regulatory requirements applicable to wood packaging materials, and identification of infested wood.

The actual Minimum Security Criteria can be found here.

Training Powerpoints are here.

(The summary of these criteria was provided by Stephen Brady, Senior Agriculture Operations Manager, Agriculture Programs and Trade Liaison, U.S. Customs and Border Protection.)

Inclusion of wood packaging in the CTPAT program should result in more efficient efforts to detect infested wood packaging before shipment — before the insect can reach North America. I believe it is fair to importers in that it requires action based on visible pest presence or damage. I applaud Customs and Border Protection for making the effort – internally and with the shipping industry — to add this protection.

I think fairness would be further served by CBP and APHIS adopting a program to inform importers which foreign suppliers of wood packaging have a record of providing “clean” vs. “infested” wood packaging. The U.S. importers would then be better able to avoid both contributing to the pest risk and being exposed to violation-associated delays.

SOURCES:

CBP website

Mongelluzzo , B. US imports from Asia hit record December level. Jan 19, 2021

Posted by Faith Campbell

Rising Pest Danger to New Regions Parallels Rise in Imports

container ship in Savannah harbor- capacity 6,188 containers; photo by F.T. Campbell

As I have blogged recently U.S. imports have soared since the summer. US imports from Asia during the first 11 months of 2020 were 2% higher than the figure from the first 11 months of 2019, despite the crash in imports in the spring.

The increased volume is not distributed evenly. Asian imports moving through the twin ports of Long Beach and Los Angeles (LA/LB) were 26.5% higher in November 2020 compared to November 2019. As a result, the ports’ marine terminals, longshore labor force, drayage truckers, and import distribution centers cannot keep up. As of early January, 62 container ships were at LA/LB – 29 being offloaded and 33 ships at anchor awaiting berths. Nineteen additional arrivals were scheduled within a few days. This is the largest backup in Southern California since the disruptions associated with the 2014-15 West Coast longshore labor dispute (Mongelluzzo, B. January 4, 2021).

As a result of the long delays at LA/LB, plus port expansion under way at other ports, the volume of imports entering elsewhere is rising – with a commensurate increase in the pest risk associated with wood packaging material there.

Imports from Asia through the Northwest Seaport Alliance (NWSA) of Seattle and Tacoma increased 9.9% in November 2020 compared to November 2019. Imports through Oakland were up 2.2% year over year (Mongelluzzo, B. January 4, 2021). These ports’ proportion of imports from Asia should rise even higher in the future. One company has begun a premium service from China directly to Oakland and Seattle. Shippers are expected to welcome this as an opportunity to avoid the congestion at LA/LB. Oakland also offers access to the large and affluent San Francisco Bay area, as well as rail transport to inland hubs such as Chicago, Memphis, Dallas, and Kansas City.

The principal disadvantage is that these ports can handle only ships carrying 3,500 to 6,500 TEU capacity [twenty-foot equivalent units; a standard measurement that counts incoming volume as though contained in twenty-foot-long containers] (Mongelluzzo, B. January 04, 2021). Other ports, e.g., LA/LB and Savannah, routinely handle ships carrying 10,000 or more TEUs.

As I have noted in earlier blogs, US Gulf Coast ports are expanding capacity significantly to handle vessels larger their current10,000 TEU limit. The Port of Houston is adding a new deepwater container berth and expanding its ship channel. At New Orleans, the U.S. Army Corps of Engineers is dredging the lower reaches of the Mississippi River. The Port of Mobile also has a dredging project under way. Tampa Bay plans to double its capacity over the next five years (Angell, January 4, 2021).

The Port of Savannah currently has 9 berths served by 36 cranes. The Port plans to increase capacity by 45% over the next decade – from 5.5 million TEUs to 8 million TEUs per year (https://gaports.com/facilities/port-of-savannah/).

Government Agencies’ Involvement

These port expansions are partially funded by U.S. government agencies. The Department of Transportation funds development of onshore facilities, while the U.S. Army Corps of Engineers carries out dredging of the waterways. We should insist that the environmental impact statements evaluating these projects include consideration of the invasive species risks associated with increased ship traffic. Potential harm comes from a wide range of organisms, which put an equally wide range of ecosystems at risk. For example, ship traffic has brought our country ruinous aquatic invertebrates in ballast water and sessile organisms on hulls; as well as costly Asian gypsy moths on ships’ superstructures and a series of tree-pest larvae in wooden dunnage and other packaging material (e.g., Asian longhorned beetle, emerald ash borer, redbay ambrosia beetle, possibly the invasive shot hole borers …).

The surge in imports from Asia has continued through the first half of 2021. Over this period, imports from Asia to the California ports of Los Angeles and Long Beach totaled 9,523,959 TEU, up 24.5% from the 7,649,095 TEU in the same period of 2019 (Mongelluzzo, B. July 12, 2021).

SOURCES

Angell, M. Outlook 2021: US Gulf Coast ports moving forward with major capacity expansions. Journal of Commerce January 04, 2021 https://www.joc.com/port-news/us-ports/outlook-2021-us-gulf-coast-ports-moving-forward-major-capacity-expansions_20210104.html?utm_campaign=CL_JOC%20Port%20Newsletter%201%2F6%2F21__e-production_E-85987_TF_0106_0900&utm_medium=email&utm_source=Eloqua

Mongelluzzo, B. CMA CGM’s new Asia service to give Oakland long-sought first call. Journal of Commerce January 04, 2021 https://www.joc.com/maritime-news/container-lines/cma-cgm%E2%80%99s-new-asia-service-give-oakland-long-sought-first-call_20210104.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%201%2F5%2F21%20_JOC%20Daily%20Newswire_e-production_E-85981_TF_0105_0617

Mongelluzzo, B. Strong US imports from Asia in June point to a larger summer surge. July 12, 2021.

https://www.joc.com/maritime-news/container-lines/strong-us-imports-asia-june-point-larger-summer-surge_20210712.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%207%2F13%2F21_PC00000_e-production_E-106057_KB_0713_0617

Posted by Faith Campbell

Decision!! California Department of Food & Agriculture Upgrades Ranking of Phytophthora occultans

In January 2021, the California Department of Food and Agriculture announced the pest rating for Phytophthora occultans, one of two species of Phytophthora it was reviewing. (Once at the website, click on “comment” – next to name Heather Sheck.)

I blogged about this action in December.

Five people or organizations submitted comments. The most comprehensive comments were submitted by Elizabeth Bernhardt, Ph. D. and Tedmund Swiecki Ph.D. of Phytosphere Research. Another scientist was Tyler Bourret, who had been the first to detect P. occultans in California when working as a student in 2015-16. The third scientist was Jennifer Parke, a plant pathologist at Oregon State University who has worked with Phytophthora species in agriculture and wildland settings for 36 years. Additional comments were submitted by the Phytophthoras in Native Habitats Work Group and me.

All commenters raised some issues. First was the lack of information on the true distribution of P. occultans in California. CDFA restated that it that relies on official records and survey information, and that those records support a “low” rating.

Several issues relate to the definitions that CDFA applies in assigning ranks. They are so restrictive that – in my view – they result in underestimates of pathogens’ potential impacts.

One example is how CDFA recognizes first detections of a pathogen. As Bernhardt and Swiecki point out, CDFA’s consideration of only “official” samples prevents timely action to protect California’s agriculture and native vegetation. In the case of P. occultans, CDFA took no action for two years after the pathogen was first reported in the state. This detection had been confirmed by a CDFA laboratory.

A second example is host range. CDFA says it assigns a host range rating of “wide” (rating of “3”) only to pathogens that have host ranges of hundreds of species. This means that pathogens with dozens of known hosts across several plant families are given a ranking of “moderate” (2). Furthermore, the agency considers only “official” samples in defining hosts. This approach precludes consideration of the high probability that additional hosts would be found in future, including federally listed species in the genera Ceanothus and Arctostaphylos. Bernhardt and Swiecki named two additional hosts based on field work. CDFA responded to the second point by adding a reference to the likely expansion of the host range in the “Uncertainty” section of the document.

Similarly, CDFA gives a reproductive potential rating of “3” only to pathogens spread by a vector or that infect seeds.

CDFA staffers who manage specific pests lack authority to change these too stringent ranking criteria. The agency leadership need to adopt more realistic criteria.

CDFA responded by accepting many of the additional factors raised primarily by Bernhardt and Swiecki. This resulted in raising the overall score from 11 to 14, and changing the ranking from “C” to “B”.

Posted by Faith Campbell

APHIS Deregulates Emerald Ash Borer – Now it is up to the States

APHIS formally proposed to stop regulating movement of firewood, nursery stock, and other articles that can transport the emerald ash borer (EAB) in 2018; I blogged in opposition to this proposal at the time. Now APHIS has evaluated the 2018 comments on its proposal and has decided to proceed with its plans.

I recently blogged about the current and probable future status of ash. A study confirmed that robust regeneration of ash seedlings and saplings seen in various invaded areas will not result in recovery of mature ashes that can perform their ecological role.

APHIS received 146 comments on the proposal. Twenty-five supported the proposal as written; 121 raised concerns. Many of the latter were a few sentences without supporting information. These comments and the final rulemaking can be read here.

How has APHIS responded to the serious questions raised? Dismissively.

I certainly concede that EAB has been difficult to manage and has spread rapidly. However, I continue tobelieve that maintaining the quarantine serves important purposes and the analysis APHIS provides does not justify terminating of the regulatory program. I remain concerned.

Neither the proposal nor the final regulation tells us how much money and staff resources have been dedicated to detection or enforcement of the regulations in recent years. Therefore we don’t know how many resources are now available for supporting other activities that the agency thinks are more effective. APHIS also refuses to provide specific information on how it will allocate the freed-up resources among its (minimal) continuing efforts. For example, APHIS has supported resistance-breeding programs. Will it help them expand to additional species, e.g., black and Oregon ash?

How Does APHIS Propose to Curtail EAB Spread?

APHIS states in the final rule that it is ending the domestic quarantine regulation so that it can allocate resources to more effective strategies for managing and containing EAB. The agency wants to reallocate funds “to activities of greater long-term benefit to slowing the spread of EAB … These activities include further development and deployment of EAB biocontrol organisms; further research into integrated pest management of EAB that can be used at the local level to protect an ash population of significant importance to a community; and further research, in tandem with other Federal agencies, into the phenomenon of “lingering ash … ”

However, APHIS has not funded detection efforts since 2019. (Detection methods were only partially effective, but they gave us some information on where EAB had established.) APHIS is now ending regulation of the movement of vectors. APHIS concedes that biocontrol agents cannot be effective in preventing pest spread. So – what efforts – other than continued support for the “Don’t Move Firewood” campaign – will APHIS make to slow the spread of EAB?

Environmental and Economic Impacts: Not Adequately Assessed

Second, APHIS still has not analyzed the economic or environmental impact of the more rapid spread of EAB to the large areas of the country that are not yet infested – especially the West Coast – that are likely to result from deregulation. As even APHIS concedes, the EAB is currently known to occupy only 27% of the range of native Fraxinus species within conterminous US. There are additional large ash populations in Canada and Mexico – although neither country commented on the proposal — unfortunately!

Instead, APHIS largely restates its position from the proposal that it is too difficult to calculate such impacts. Furthermore, that it is APHIS’ “experience that widely prevalent plant pests tend, over time, to spread throughout the geographical range of their hosts …” In other words, APHIS denies the value of delaying invasions – yet that has always been a premise underlying any quarantine program.

The final regulation refers to an updated economic analysis, but no such document is posted on the official website. The rule does not mention costs to homeowners, property owners, municipal governments, etc. I believe it would not be so difficult to estimate costs to these entities by applying costs of tree removal in the Midwest to tree census data from major West Coast cities. Also, it might have been possible to provide some estimate of the ecological values in riparian forests by analogy to data from the Midwest developed by Deborah McCullough and others.

Biological Control: Effective – or Not

In the final regulation, APHIS concedes that the biocontrol agents currently being released have geographic and other limitations. However, APHIS does not address concerns raised by me and others about their efficacy. APHIS does say explicitly that it has not [yet?] begun efforts to find biocontrol agents that might be more effective in warmer parts of the ash range, especially the Pacific Northwest and riparian areas of the desert Southwest. However, APHIS has conceded that these areas are almost certain to be invaded – so should it not take precautionary action?

APHIS states several times that it cannot promise specific funding allocations among program components or strategies – such as resistance breeding – that might be pursued in the future. The agency stresses the value of flexibility.

U.S. Forest Service biologists have higher expectations; see their podcast here.

I wish to clarify that I do not oppose use of biocontrol; I strongly supported then APHIS Deputy Administrator Ric Dunkle’s decision to initiate biocontrol efforts for EAB early in the infestation. My objections are to overly optimistic descriptions of the program’s efficacy.

Firewood: Outreach Only, No National Regulation

As noted, APHIS has promised to continue support for public outreach activities, especially the “Don ‘t Move Firewood” campaign. The program’s message will continue to encourage the public to buy firewood where they burn it and to refrain from moving firewood from areas that are under Federal quarantine for other pests of firewood (e.g., Asian longhorned beetle). This campaign and the new National Plant Board guidelines link stress that firewood is a high-risk pathway for many pests of national or regional concern; they do not focus on any particular species. Leigh Greenwood, director of Don’t Move Firewood, thinks this is a good approach.

In 2010, the National Firewood Task Force recommended that APHIS regulate firewood at the national level. APHIS does explain why the agency did not do so. The agency says national regulations would be overly restrictive for some states and that requiring heat treatment would not be feasible in the winter for producers in Northern states. Finally, a Federal regulation would not address a significant non-commercial pathway – campers. [I have serious questions about APHIS’ assertion that it can regulate only commercial movement of vectors across state lines. Contact me directly for details on this.]

Perhaps APHIS is not required to analyze the probable overarching efficacy of the several efforts of 50 states. Given the states’ many perspectives and obvious difficulty in coordinating their actions on phytosanitary and other policies, I fear a scattered approach that will result in faster spread of EAB. I hope the National Plant Board guidelines on firewood regulation and outreach can overcome the history.

Most federally-managed recreation areas adopted an education campaign on firewood in autumn 2016; I blogged about it then.

Imported Wood Will be Minimally Regulated

APHIS clarifies that it will take enforcement actions against imports of ash wood only if inspectors detect larvae but can identify them just to family level and not below. APHIS will allow the importation if the larvae can be identified as EAB specifically. This policy reflects international standards, which do not allow a country to erect restrictions targetting a pest from abroad if that pest is also present inside the country and is not under an official control program. (See my discussion of the WTO Agreement on Sanitary and Phytosanitary Standards in Chapter 3 and Appendix 3 of Fading Forests II, available here.)

APHIS does not discuss how it will react to pests identified to the genus – several other Agrilus also pose pest risks. (See here and here.)

APHIS recommends that states leery of accepting yet more EAB-infested wood from abroad petition the agency under the Federally Recognized State Managed Phytosanitary Program (FRSMP) program, under which APHIS would take action to prevent movement of infested material to that particular state.

Lessons Learned

Finally, one commenter asked whether APHIS would analyze the program to learn what could have improved results. APHIS replies that the agency “tend[s] to reserve such evaluations for particular procedures or policies in order to limit their scope …” I hope APHIS is serious about “considering” doing a “lessons learned” evaluation. It is important to understand what could have been done better to protect America’s plant resources.

My take: the EAB experience proves, once again, that quarantine zones must extent to probable locations – beyond the known locations. The pest is almost always more widely distributed than documented. This has been true for EAB, sudden oak death, ALB, citrus canker … Failure to regulate “ahead” of the pest guarantees failure. I recognize that adopting this stance probably requires a change in the law (or at least understanding of it) and of current international standards adopted by the International Plant Protection Convention (IPPC). However, absent a more aggressive approach, programs are doomed to be constantly chasing the pest’s posterior.

Finally, let us mourn the loss of ash so far, the future losses … and opportunities missed.

Posted by Faith Campbell

Let’s shape the Biden Administration’s & New Congress’ Policies on Non-Native Forest Pests!

We have a great opportunity to shape future efforts to counter non-native forest pests and diseases. Administration officials are most open to new ideas when they first take office. The same is true of new Congressional leadership.

So now is the time to suggest needed changes!

The USDA Secretary-designate is Tom Vilsack. Of course, he was USDA Secretary during the Obama Administration … so he is not entirely “new” to the issues. However, perspectives and priorities have changed, so now is a good time to urge him to consider new approaches. Furthermore, the Senate Agriculture Committee will hold confirmation hearings for him; we can ask the Senators to advocate for our views during this proceeding.

The House Agriculture Committee has a new Chair, David Scott – from the suburbs of Atlanta, Georgia. Again, this provides an opportunity to suggest new approaches and topics for hearings.

I assume you all are knowledgeable about the numbers and impacts of non-native forest insects and pathogens in the United States, and of the pathways by which they are introduced and spread. If you are not, peruse my blogs about wood packaging or plants as vectors (click on the appropriate “categories” listed at the bottom of the archive of blogs). Or read Fading Forests III (see the link at the end of this blog) and the article I coauthored early this year on improving forest pest management programs.

On the basis of my long experience, I suggest that you encourage USDA Secretary-designate Vilsack, Senators on the Agriculture Committee, and House Agriculture Committee Chair David Scott to consider the following recommendations:

Actions Congress could take

Congress could amend the Plant Protection Act [7 U.S.C. §7701, et seq. (2000)] to prioritize the protection of natural and agricultural resources over the facilitation of trade. This might be done by amending the “findings” section of the statute to give higher priority to pest prevention.
The Agriculture Committees of both the House and Senate could hold hearings on the importation of forest pests. They could determine if the USDA is doing an adequate job protecting the country from insect pests and diseases, and how our defenses could be strengthened. One component of the hearings could focus on whether current funding levels and mechanisms are adequate to support vigorous responses to new pest incursions.
Congress could commission a study of the feasibility, costs and benefits of establishing a “Center for Forest Pest Control and Prevention” to coordinate research and policy on this issue.
Congress could increase funding for the appropriate USDA APHIS and Forest Service programs and activities to enable vigorous containment and eradication responses targeting introduced forest pests and diseases.
Congress could increase funding for USDA research on detection of insects and pathogens in shipping; insect and disease monitoring/surveillance; biological control; alternatives to packaging made from wooden boards; management of established pests; and resistance breeding to enable restoration of impacted tree species.

Actions Secretary-designate Vilsack could initiate without legislative action (once he is confirmed)

Introductions of pests in the wooden crates, pallets, etc., goods come in

APHIS could take emergency action to prohibit use of wood packaging by importers of goods from countries with a record of poor compliance with ISPM#15. This action is allowed under authority of the Plant Protection Act [7 U.S.C. §7701, et seq. (2000)] and Article 5.7 of the World Trade Organization’s Agreement on the Application of Sanitary and Phytosanitary Measures.
APHIS could strengthen enforcement of current regulations by aggressively prosecuting repeat offenders. For instance, APHIS could begin imposing administrative financial penalties on importers each time their wood packaging is non-compliant with ISPM#15.
APHIS could work with Department of Homeland Security Bureau of Customs and Border Protection (CBP) to improve information available to U.S. importers about which foreign suppliers of SWPM and shippers have good vs. bad records of compliance with ISPM#15.
DHS CBP could release information on country of origin and treatment facility for ISPM#15-stamped SWPM that is found to be infested with pests.
USDA APHIS could begin a phased transition from solid wood packaging to alternative materials that cannot carry wood-boring pests. APHIS could initiate a pest risk assessment to justify making such an action permanent. Imports could be packaged in alternative materials, e.g., manufactured wood products (e.g. plywood), metal, or plastic.

Nursery Plant (“Plants for Planting”) Pathway

APHIS could apply authorities under NAPPRA and other existing authorities to curtail imports of plants that pose a high risk of introducing insects and pathogens that would threaten tree species that are important in natural and urban forests in the U.S. At a minimum, APHIS should restrict imports of live plants that are in the same genus as native woody plants of the U.S.
APHIS could work with the Agriculture Research Service and National Institute of Food and Agriculture to determine which taxa of woody vegetation native to the U.S. are vulnerable to pathogens present in natural systems of trade partners. Particularly important would be the many Phytophthora species found by Jung and colleagues in Vietnam, Taiwan, Chile, and other countries. Once the studies are sufficiently complete, APHIS could utilize authority under NAPPRA to prohibit importation of plants from those source countries until effective phytosanitary measures can be identified and adopted.

Other Actions

APHIS could develop procedures to ensure the periodic evaluation of pest approach rates associated with wood packaging and imports of “plants for planting” and highlight areas of program strengths and weaknesses. A good place to start would be to update the study by Haack et al. (2014), which estimated the approach rate in wood packaging a decade ago.
The USDA could expand early detection systems for forest pests, such as the APHIS CAPS program and the Forest Service EDRR program. These programs should be better coordinated with each other and should make better use of citizen observations collected through smartphone apps, professional tree workers such as arborists and utility crews, and university expertise in pest identification and public outreach. An effective program would survey for a broad range of pests as well as for suspicious tree damage, and would be focused on high-risk areas such as forests around seaports, airports, plant nurseries, and facilities such as warehouses that engage in international trade.
The USDA could initiate a “Sentinel Plantings“ network of US tree species planted in gardens abroad and monitored for potential pests and diseases.

Posted by Faith Campbell

Beech leaf disease found in four new states, 31 new counties

On the first day of winter, Daniel Volk, Forest Health Project Coordinator for Cleveland (OH) Metroparks reported that a coordinated survey has confirmed the presence of beech leaf disease link to DMF in four new states — Massachusetts, New Jersey, Rhode Island, and West Virginia. In all, the disease is now known to be established in 71 counties in the US and Canada. Funding was provided by the USFS Forest Health Management “emerging pest” program.

2021 survey efforts will focus on high risk counties adjacent to affected counties.

Cleveland Metroparks has several resources available on its website and will continue to post updated information there as it becomes available.

I posted a blog urging recipients to participate in these searches last June link I hope you will do so again in 2021.

Posted by Faith Campbell

Imports Surge – Will Pests be Far Behind?

In August I blogged that import volumes had crashed … US imports from Asia declined each month from January through June (Mongelluzzo Dec 14; full citations at end of blog). However, the economic rebound over the summer brought a surge in imports that continues. Given our concern about introductions of tree-killing pests, it is not good news that imports from Asia are driving the growth in imports.

US imports from Asia during the first 11 months of 2020 were 2% higher than the figure from the first 11 months of 2019. In November alone, the U.S imported 1.6 million TEUs [twenty-foot equivalent units; a standard measurement that counts incoming volume as though contained in twenty-foot-long containers] worth of goods from Asia. Imports in December are projected to remain high (Mongelluzzo Dec 14; full citation at end of blog).

Imports from Asia were 1.626 million TEU in December – up 29.9% from December 2019 (although still lower than October and August). December imports were pushed by record e-commerce sales and shipments of personal protective equipment (PPE) and medical supplies. For all of 2020, imports from Asia totaled 16.6 million TEU, up 4.1% from 2019 (Mongelluzzo Jan. 19)

This surge in imports – which began in late June — is certain to continue at least for the next two months as retailers ship more merchandise before some factories in Asia close for the Lunar New Year (Mongelluzzo Jan 19).

Because of the history of tree-killing pests introduced from Asia, I have blogged most often about the situation at West Coast ports. However, in 2020 there has been a noticeable shift to East and Gulf Coast ports because of the congestion and delays at West Coast ports. Thus, in November 2020, West Coast ports handled 60.2% of imports from Asia; East Coast ports handled 33.7%; Gulf Coast ports handled 5.7%. The East Coast figure is 30% higher than over the same period in 2019. At New York-New Jersey specifically, the increase was 35.1% (Mongelluzo Dec 16). Imports to Gulf Coast ports continue to rise; Gulf Coast ports handled only 4.8% of total US imports from Asia during the first nine months in 2019 and less than 3% before the widening of the Panama Canal (in 2016) (Angell October 28). Link to blog #203 midNov (In future, goods shipped from Asia across the Arctic Ocean to the U.S. east coast could add to the pest risk confronting our already hard-hit Eastern Deciduous Forest.)

Pacific Coast Ports

According to Mongelluzzo (December 9), the Los Angeles-Long Beach port complex (LA-LB) set records for US imports from Asia in August and again in October. The port complex handled 2.5 million TEU of imports from Asia in the three-month period of August through October. Despite shippers’ concern about delays, LA-LB is expected to continue to handle the bulk of Asian goods entering the country in coming months.

The ports of Los Angeles-Long Beach handle 50% of US imports from Asia. From July 2020 through February 2021, these ports received an average of 791,838 TEU each month – a 23% increase over the 2019 average of 642,000 TEU per month (Mongeluzzo April 2021).

Ports in the Southeast

As reported by Ashe (December 10), several ports in the southeast US are seeing record import volumes caused by retailers’ restocking, e-commerce, and Christmas shopping. November import volumes hit all-time highs in Savannah and Port of Virginia, while they were up year over year in Charleston. The three port authorities say the surge is the result of demand for furniture, bedding, refrigerators, freezers, and air conditioners – reflecting Americans’ current focus on improving their homes. Imports also include artificial Christmas trees (which have been a vector of pests in the past – as has furniture).

offloading cargo at Savannah; photo by F.T. Campbell

The volume of imports into Savannah from all sources surged 34% over the November 2019 volume. Imports from Asia rose 36%. Imports of furniture rose 42% in August and September. “Hardware, home goods, machinery, and appliances from Asia were up double digits,” according to Georgia Port Authority CEO Griff Lynch. Import volumes from Asia rose 36% in Virginia and 32% in Charleston.

Vessels Carry More Containers

Another threat of increased pest introductions arises from the increasing size of container ships. Increasing proportions of vessels with the capacity to carry more than 10,000 containers are arriving. Since 2010, the proportion of such ships arriving at West Coast ports has risen from 1.1% to 75.5%. The proportion arriving at East Coast ports has grown since the opening of the widened Panama Canal in 2017. The proportion of high-capacity ships visiting East Coast ports has risen from 3% in 2017 to 15% during the first 10 months of 2020. Gulf Coast ports receive few such vessels because the serve a smaller share of the U.S. market. The largest ships serve the trade from Asia primarily (Mongelluzzo Dec. 21, 2020). Of course, arrival of ten to fifteen thousand containers at once surely strains Custom’s inspection staff.

container ship in Savannah; Photo by F.T. Campbell

Imports from Geographic Regions Other Than Asia

Imports (from all sources) through New York and New Jersey ports were 22% percent higher in October 2020 than in October 2019 (Angell November 10). As noted above, most of the higher volume of imports originated in Asia.

According to Journal of Commerce staff (November 30), containerized imports from the Caribbean and Central America grew a negligible 0.1% over the same period last year. Principal ports for this trade are in Florida and along the Gulf Coast, but include Wilmington, DE, and Philadelphia.

According to JOC staff (November 2), containerized cargo import volumes from all regions flowing through the busiest US Gulf Coast ports declined 2.3% in the first seven months of 2020 compared to the same period in 2019.

Non-containerized cargoes — i.e., dry bulk, liquid bulk, roll-on/roll-off (ro-ro), and oversized/heavy-lift freight — are not included in these data. Dry bulk cargo through Houston has been reported to suffer problems in infested dunnage (wood used to brace non-containerized cargo, such as steel beams). Link to blog 173 February 2020

SOURCES

Angell, M. US Gulf pulls more Asian imports amid West Coast congestion Oct 28, 2020 https://www.joc.com/port-news/us-ports/us-gulf-pulls-more-asian-imports-amid-west-coast-congestion_20201028.html

Angell, M. Railroads send railcars to NY-NJ as import pressure mounts Nov 10, 2020 https://www.joc.com/port-news/us-ports/railroads-send-railcars-ny-nj-import-pressure-mounts_20201110.html?utm_campaign=CL_JOC%20Port%20Newsletter%2011%2F18%2F20%20-%20With%20R__e-production_E-81883_AK_1118_1200&utm_medium=email&utm_source=Eloqua

Ashe, A. Import surge at Southeast ports tightens chassis availability Dec 10, 2020 https://www.joc.com/port-news/us-ports/southeast-closing-out-2020-surging-volumes_20201210.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%20Newswire%2012%2F11%2F2020__e-production_E-84440_KB_1211_0617

JOC Staff JOC Rankings: Resins buoy US Gulf Coast ports during COVID-19 Nov 02, 2020 https://www.joc.com/port-news/us-ports/joc-rankings-resins-buoy-us-gulf-coast-ports-during-covid-19_20201102.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%20Newswire%2011%2F3%2F2020%20__e-production_E-80030_TF_1103_0617

JOC Staff. JOC Rankings: US–Carib/Central America trade tumbles in 2020 Nov 30, 2020 https://www.joc.com/maritime-news/joc-rankings-slowing-us%E2%80%93caribcentral-america-trade-tumbles-2020_20201130.html?utm_campaign=CL_JOC%20Port%20Newsletter%2012%2F2%2F20%20__e-production_E-83092_TF_1202_0900&utm_medium=email&utm_source=Eloqua

Mongelluzzo, B. Import deluge fills LA-LB terminals to capacity Dec 09, 2020 https://www.joc.com/port-news/us-ports/import-deluge-fills-la-lb-terminals-capacity_20201209.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%20Newswire%2012%2F10%2F2020__e-production_E-84332_KB_1210_0617

Mongelluzzo, B. Asia-US import surge slowing slightly, but spreading to East, Gulf coasts Dec 14, 2020 https://www.joc.com/maritime-news/container-lines/asia-us-import-surge-slowing-slightly-spreading-east-gulf-coasts_20201214.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%20Newswire%2012%2F15%2F2020__e-production_E-84893_KB_1215_0617

Mongelluzzo, B. US East Coast ports avoid gridlock despite rising volumes. Dec 16, 2020. https://www.joc.com/port-news/us-ports/us-east-coast-ports-avoid-gridlock-despite-rising-volumes_20201216.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%20Newswire%2012%2F17%2F2020__e-production_E-85162_KB_1216_2139

Mongelluzzo, B. Increasing vessel sizes a red flag for US ports. Dec 21, 2020 https://www.joc.com/maritime-news/container-lines/increasing-vessel-sizes-red-flag-us-ports_20201221.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%2012%2F22%2F20_JOC%20Daily%20Newswire_e-production_E-85422_KB_1222_0617

Mongelluzzo, B. US imports from Asia hit record December level. Jan 19, 2021 https://www.joc.com/maritime-news/container-lines/us-imports-asia-hit-record-december-level_20210119.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%201%2F20%2F21_PC00000_e-production_E-87262_KB_0120_0617

Mongeluzzo, B. Additional port capacity alone can’t solve congestion issues: LA-LB. Journal of Commerce. April 2021 https://www.joc.com/port-news/us-ports/additional-port-capacity-alone-can%E2%80%99t-solve-congestion-issues-la-lb_20210407.html?utm_source=Eloqua&utm_medium=email&utm_campaign=CL_JOC%20Daily%204%2F8%2F21_PC00000_e-production_E-95420_KB_0408_0837

Posted by Faith Campbell

Korea seeks (again!) to export high-risk trees to America

dwarfed *Ulmus davidiana*; photo by Krzsztof Zianek; Wikipedia Commons

USDA APHIS is seeking public input on a risk assessment that is intended to evaluate the risk of allowing importation of dwarf elm trees (bunjae) from South Korea. Importation of these trees is currently prohibited under APHIS’ authority to require a risk assessment before importation under the NAPPRA program. Upon receiving the Korean request, APHIS must decide whether to maintain the prohibition, or alter it. The risk assessment can be obtained here. Comments are due January 11, 2021.

I urge those with expert knowledge about phytophagous insects, nematodes, and fungal and other pathogens to prepare your own comments to APHIS.

[A year ago, Korea sought permission to export dwarfed maple trees to the U.S. CISP commented on APHIS’ risk assessment at that time; see my blog here. I believe APHIS has not yet decided whether to allow such imports. Many of the same issues apply here.]

After reviewing the risk assessment, I conclude that there are too many high-risk pests to support removing the taxon from the current restrictions. The history of introductions on dwarfed trees in the past supports this conclusion. The most conspicuous is the citrus longhorned beetle (Anoplophora chinensis) – the reason for the original NAPPRA listing – but there have been others, too.

The risk assessment has some strengths. I applaud the assessors for noting in each pest review that since the proposed imports are propagative material, all the pests will arrive on living hosts. The assessment then discusses – briefly! – the mechanisms by which the pest or pathogen could disperse to infest new trees – e.g., flight, rain splash, irrigation water. However, I think the assessment is sometimes too cautious in describing probable invasive risks.

I also find several important weaknesses in both the risk assessment process generally and specific findings.

Weaknesses of the Risk Assessment Process

The assessors do not discuss the potential efficacy of pest-management actions taken by the exporter or by USDA at ports of entry. They outlined production and harvesting practices that they assumed would apply to the exported plants. They warned that the risk assessment finding could not be applied to plants produced or handled other under conditions.

I am troubled by the assessors’ decision not to consider the plants’ ages and sizes. There is evidence that age and size are very important in determining the likelihood of pest presence. Perhaps the decision reflects the assumption that the exported plants would be less than four years old. Still, the assessors should have been transparent about the reasoning behind this decision.

The assessment underestimates “uncertainty”. One manifestation is the decision to provide little information about whether pests or pathogens known to attack several Eurasian species of Ulmus might also attack North American elm species. This gap arises, I believe, from the International Plant Protection Organization (IPPC) and APHIS requirement that risk analysts consider only pest-host relationships described in the literature or inferred from port interception data. I find this narrow approach to be a weakness, given how many unknown pest-host relationships have proved to be highly damaging. This issue arises specifically in the reviews of the nematode Meloinema kerongense and several powdery mildews (Erysiphe kenjiana, E. ulmi and Podosphaera spiralis) – all of which are identified as affecting at least some elm species.

Perhaps the missing information has fewer consequences here, since the NAPPRA process does not require that APHIS prove the pest-host relationship for every pest evaluated in order to justify retaining the prohibition on importation. The well-documented history of detecting the citrus longhorned beetle in artificially dwarfed trees and as a pest of the Ulmus genus provides more than sufficient justification to retain trade restrictions. Still, if APHIS is conducting a formal risk assessment, it should be thorough. Anything else sets an unfortunate precedent.

Finally, in cases when some of the hosts considered are commercial crops – e.g., fruit trees – the assessment often does not include forest trees as economically important resources at risk.

Questions re: some of specific pests in the analysis

3.2.1. Cerambycidae (Coleoptera)

The risk assessment notes the minimal information available regarding several cerambycid beetles present in Korea that are capable of feeding on elm trees. Collectively, these beetles have a wide host range — Acer, Alnus, Citrus, Ficus, Hibiscus, Juglans, Malus, Morus, Quercus, Populus, Prunus, Pyrus, Salix, Sorbus, and Ulmus. The beetles can thrive in the climate present across most of the Lower 48 states (USDA Plant Hardiness Zones 6-9). The risk assessment does mention the risk to urban and forest trees. It also mentions British detection of A. chinensis larvae in twigs of imported maple trees, but for some reason does not mention past U.S. detections and introductions of this beetle in maple bonsai/bunjae trees in Tukwila, Washington. Is this because the detections were 20 years ago? Does the passage of time make the detections any less relevant?

trees removed for CLB eradication in Tukwila, Washington

3.2.2. Archips xylosteana (Lepidoptera: Tortricidae)

The analysis of this tortricid moth notes its broad host range, including Abies, Acer, Betula, Fraxinus, Populus, Quercus, Salix, Sorbus, Tilia, and Ulmus. Yet the analysis makes no mention of the potential impact of moth larval feeding on the buds and flowers of forest trees. Nor does it discuss the moth’s impact in Canada, where it is established. The Canadian experience seems quite pertinent and is an obvious omission.

3.2.3. Meloinema kerongens

This nematode is present on elms in Korea. The assessors could find no information on the damage it causes to its hosts there. Again, there is no discussion of possible vulnerability of American elms. Apparently the nematodes are considered likely to survive the importation process, when the trees will be bare root. The assessors say that since the dwarfed trees (once imported) are likely to be planted in pots, that might limit the nematodes’ dispersal into native soil habitats and ability to infect new trees. This finding is troubling because it is likely that nematodes or their eggs could be present in the pots’ soil, and if that soil leaks from the pot or is disposed of during repotting or with other actions, pests could become established in native soil.

3.2.5. Helicobasidium mompa

This fungus causes root rot on multiple genera in 44 plant families. The list of hosts includes Pinus spp., Populus spp., Prunus spp., and Quercus spp. It appears to thrive in a wide climatic range covering virtually the entire Lower 48 states (USDA Plant Hardiness Zones 2-11). The fungus is spread via rain or irrigation water. I note that experience with the Phytophthora genus of brown algae has demonstrated how difficult it can be to control pathogens that spread in rain or irrigation water – in both nurseries and the wild.

Other Potential Pests

I urge experts to review the long list of pests not analyzed—especially the nematodes that inhabit the root and rhizosphere. Analysts did not analyze them because they are ectoparasites; they decided that ectoparasites were unlikely to remain with the dwarfed trees when they are shipped bare-root.

I also wonder whether the mistletoe Viscum album – a parasitic plant – might be spread onto the dwarfed trees by birds perching on branches or shelter structures above the production facilities. Assessors thought that dormant mistletoe on the plants would not be easily detected during visual inspection at the ports.

Posted by Faith Campbell