Category: invasive species policy

Progress in Combatting Invasives – with Caveats

Missouri Makes Progress in Eradicating Feral Hogs – Despite Sabotage

Feral hogs have expanded their range in the U.S. from 17 to 38 states over the past 30 years. Their populations grow rapidly because feral hogs can breed any time of the year and produce two litters of one to seven piglets every 12 to 15 months. [See MDC Press Release, January 25, 2019]

hog “sounder” in a trap in Missouri
Missouri Department of Conservation

Missouri’s program is increasingly successful: the numbers of hogs removed has risen from 5,358 in 2016, to 6,561 in 2017, to 9.365 in 2018. [See MDC Press Release, January 25, 2019] I have previously praised Missouri’s scientifically-based program to eradicate feral hogs – here and here (Missouri has extensive material on feral hogs posted here)  

According to the Missouri Department of Conservation’s feral hog elimination team leader, Mark McLain, said “This strategic approach is important because if we leave even a few feral hogs behind in an area, they can reproduce quickly and put us back where we started.”

According to McLain, hunting is not an effective method for eliminating feral hog populations. “For over 20 years, unregulated hunting of feral hogs was allowed in Missouri, during which time our feral hog population expanded from a few counties to over 30 counties,” he said.

In 2017, MDC, the Corps of Engineers, and the LAD Foundation established regulations against feral hog hunting on lands owned and managed by these three organizations. Other agencies have passed regulations similar to MDC’s to eliminate hog hunting on land they own.

However, illegal releases of feral hogs continue. The February 2019 press release (referenced below) describes several examples of the problems such releases cause. McLain said that those who release feral hogs face hefty fines. Hunting, especially with dogs, pushes the hogs onto neighboring property, which causes problems for neighbors. The hogs travel back and forth between the properties, escaping and causing more damage. Trapping with no hunting interference is the best method to eliminate them.

MDC advises landowners to seek help from the Department and USDA APHIS. These agencies providetechnical advice and training; conduct on-site visits; and loan equipment.

Are feral hog programs in other states using the same methods? Are they as successful?

SOURCES

Missouri Department of Conservation. More than 9,300 Feral Hogs Eliminated from Missouri in 2018. Press Release. January 25, 2019.

Missouri Department of Conservation. Interference with feral hog trapping sites costs trappers time, taxpayers money. Press Release. February 21, 2019.

Florida Looks to Biocontrol to Makes Progress Against Some of its Worst Invasive Plants

Brazilian peppertree tangle
John Randall, The Nature Conservancy
www.bugwood.org

Until recently, melaleuca (Melaleuca quinquenervia) was considered the worst invasive tree or shrub in Florida. It threatened to convert the everglades “sea of grass” into a thicket of exotic trees which could not support native wildlife. Thanks to the biocontrol agent Oxyops vitiosa, melaleuca is considered to be under maintenance control on public conservation land in the state. Still, melaleuca control demands about $2 million per year because of the huge area previously (and still) affected by the tree.

Now Florida is about to release biocontrol agents to attack Brazilian pepper (Schinus terebinthifolius). In Florida, Brazilian peppertree is found from Monroe County in the south to St. Johns, Levy, and Nassau counties in the north plus Franklin County in the Panhandle. An estimated 283,000 hectares of south and central Florida are invaded. The South Florida Water Management District alone is spending approximately $1.7 million per year (as of 2011) to control it.

Brazilian peppertree invades disturbed sites such as canal banks and fallow farmlands. Of greater concern to me are the many natural communities invaded – Brazilian peppertree infests more natural areas in Florida than any other invasive plant species. Invaded ecosystems include pinelands, hardwood hammocks, and critically important mangrove forests. The coastal mangroves are valued because of their high productivity, wildlife habitat, and shoreline protection and stabilization.

Brazilian peppertree infestation in the Everglades
Tony Pernas, USDI National Park Service
www.bugwood.org

Dense stands of Brazilian peppertree shade out and may kill food plants used by white-tailed deer – key prey for the endangered Florida panther. Other mammals and birds might be poisoned by toxic resins in the bark, leaves and fruits — although some birds feed extensively on the fruits – and thereby contribute to spread of the invasive plant.

Existing options for management of Brazilian peppertree, including chemical, mechanical, and physical control measures, have been used with some success against this weed. However, applying these strategies repeatedly to prevent regrowth is costly and labor intensive. Furthermore, such practices can be detrimental to native vegetation. For example, mangroves are particularly sensitive to both herbicides and the soil disturbances associated with mechanical control

After more than 20 years of searching, Florida hopes it has identified useful biocontrol agents. USDA APHIS is seeking public comment on the proposed release of two insect species, Calophya latiforceps  (a leaf galling psyllid) and Pseudophilothrips ichini (a thrips) as biological control agents targetting Brazilian pepper.

Much as I sympathize – Brazilian peppertree is a highly damaging invasive plant and there are no other effective control measures – I have questions. First, the psyllid is sedentary; dispersal would be by wind. Would this limit its efficacy?

More troubling is host specificity. The Environmental Assessment (available here) reveals that the thrips can reproduce in low numbers on several non-target plant species, including the Hawaiian sumac Rhus sandwicensis. True, the proposal is to release the biocontrol agents on the continent, not on Hawai`i. But insects have often been transported inadvertently to Hawai`i – and the islands’ plant species have often proved highly vulnerable to attack by non-native species (I confess that the most recent examples are pathogens, e.g., ‘ōhi‘a rust and rapid ‘ōhi‘a death.)

APHIS is accepting comments on the Environmental Assessment until March 29. Please consider providing your views. Again, the document is available here.

RESULTS

In June 2019, APHIS announced that it would issue permits for release of the two biocontrol agents on the continent – starting in Florida – without any restrictions. APHIS dismissed my concerns about the potential threat to native Hawaiian plants — Rhus sandwicensis and Dodonaea viscosa. See the agency’s responses in Appendix 7.

As regards the potential threat to the two Hawaiian species from the thrips Pseudophilothrips ichini APHIS chose to ignore my two greatest concerns:

1) that insects are introduced accidentally to Hawai`i frequently – so the threat from this thrips must be considered.

2)  if introduced to Hawai`i, P. ichini would have ample resources to maintain high population levels and so could put constant pressure on Rhus sandwicensis and Dodonaea viscosa even ‘though neither plant itself supports more than one generation of the thrips.

In response to my query as to who in Texas would be consulted re: possible release of the biocontrol agents in that state, APHIS replied the chief state plant regulatory official (head of plant pest issues in the state Department of Agriculture) and the APHIS representative in the state. No conservation authorities are designated. Nor would APHIS prepare a new environmental assessment – although the current one cites data almost exclusively for Florida.

One good response: in response to my concerns that the psyllid Calophya latiforceps is too sedentary to spread through the hundreds of thousands of acres invaded by Brazilian pepper, APHIS clarifies that a mass rearing and release program is under development.

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.

Invasive Species Policy: Will New Law Empower Agencies? Or Hinder Strategic Planning, Research, and Engaging the Public through Outreach?

Much-Heralded Major Conservation Legislation — S. 47 – Mandates “On-the-Ground” Actions 

Senate bill S. 47 enjoyed strong support from the conservation community because it expanded protection for several National parks and wilderness areas, mandated easier access to public land for hunters and anglers, and provided permanent status for the most important program that funds purchase of lands and waters for recreation and other purposes – the Land and Water Conservation Fund. It passed the Senate on February 12, 2019 by a vote of 92 for, 8 against. The bill passed the House of Representatives on February 26, 2019 by a vote of 363 for, 62 against. Everyone expects President Trump to sign it into law.

The new language had previously been a stand-alone bill introduced in two previous sessions of Congress. The first version, S. 2240, was introduced in 2016; I blogged about a hearing on that legislation in May 2016, describing my reservations. The bill was not enacted in that Congress. It was reintroduced in 2017, when it was called the “WILD Act” (S. 826).

Title VII of the new legislation now expected to become law governs programs implemented by the Departments of Interior, Agriculture (specifically the Forest Service) and the U.S. Army Corps of Engineers. It also applies to the head of “any federal agency” having duties related to planning or treatment of invasive species “for the purpose of protecting water and wildlife on land and in water.”

Title VII takes the form of an amendment to the Fish and Wildlife Coordination Act (16 U.S.C. 661 et seq.)

As in the original 2016 bill (S. 2240), the new law – at Title VII, §10(c)(2)(C) – agencies are required to adopt strategic plans for their invasive species programs. The priorities in the federal agencies’ invasive species plans will be set by state governors – not the federal agency charged with managing that land unit and its resources.

  • Under§10(a)(4)(C), tribal, regional, State, or local authorities are authorized to weigh in on the determination of which terrestrial or aquatic species fit the definitions of ‘invasive’ and ‘alien’ species.
  • Under §10(c)(3).the Secretaries are required, in developing their strategic plans, to take into consideration the ecological as well as the economic costs of acting or not acting, I welcome this provision.

Like the original 2016 bill (S. 2240), the new law – at Title VII, §10(g) – (i)  – requires land-managing agencies to allocate their invasive species funds according to the following formula: 75% for on-the-ground activity; 15% for combined research and outreach; 10% or less for administrative costs.

  • Fortunately, “on-the-ground” activities have been expanded to include
    • detection and monitoring.
    • “the use of appropriate methods to remove invasive species from a vehicle or vessel capable of conveyance.” 
    • “investigations regarding methods for early detection and rapid response, prevention, control, or management of the invasive species.”
    • It is unclear whether “on-the-ground” activities include the salaries of staff who manage such programs from desks (as distinct from people who work in the field).
  • Unfortunately, the definition of “prevention” is unnecessarily limited by §10(a)(6) (B). This clause authorizes agencies ‘‘to impede the spread of the invasive species … by inspecting, intercepting, or confiscating invasive species threats prior to the establishment of the invasive species onto land or water of an eligible State.” This clause reflects too narrow an understanding of prevention actions. They are not limited to (inefficient) inspection and seizure programs at “borders”. It is much more efficient to apply measures intended to prevent the presence of a pest in the transported good in the place of production. One example is APHIS’ requirements governing nursery stock intended to be shipped interstate so as to prevent the spread of the sudden oak death pathogen.

Following the revised 2017 version of the bill (text here; see my blog here) the law requires the agencies to make “substantive annual net reduction of invasive species populations or infested acreage …”  (The original bill mandated an annual reduction of 5%.) It is unclear whether this mandate applies to all invasive species on the affected acreage, or only those designated by a flawed process (see below) and included in the agency’s strategic plan [Title VII, §10(c)(1)].

Under Subsection (d), the plan is to prioritize the use of methods that are effective (as determined by the Secretary, based on sound scientific data); that minimize environmental impacts; and control and manage invasive species in the least costly manner. I worry that this requirement, combined with the mandate to achieve “annual net reductions” in invasive species numbers, will promote the use of chemical pesticides.

Under Section (f), agencies are to apply all available tools and flexibilities to expedite invasive species control projects and activities. Those projects are to be located in an area that is at high risk for invasive species introduction, establishment, or spread; and determined by the Secretary to require immediate action to address that risk. These actions are to be carried out in accordance with applicable agency procedures, including any applicable land or resource management plan. This language apparently replaces earlier efforts to exclude invasive species control projects from analysis under NEPA. How this mandate interacts with state governors’ setting priorities under §10(c)(2)(C) is unclear.

Remember that under the funding allocations specified in Title VII, §10(g) – (i), “… not more than 10% may be used for administrative costs incurred to carry out those programs, including costs relating to oversight and management of the programs, recordkeeping, and implementation of the strategic plan …”. At the same time, §§10(e), (j), and (l) require economic analyses and reports detailing compliance with requirements and results of projects. In other words, the new law restricts expenditure of funds for “administrative costs” but imposes significant additional administrative duties.

Fortunately, Title VII §10(k)(1) states that “Nothing in this section precludes the Secretary concerned from pursuing or supporting, pursuant to any other provision of law, any activity regarding [invasive species]  control, prevention, or management …, including investigations to improve the control, prevention, or management of the invasive species.

In all iterations, the bills called for the projects to be carried out through collaboration with wide range of partners, including private individuals and entities – apparently including non-governmental organizations such as state or local invasive plant coalitions.

Earlier in Congressional consideration of the new law’s provisions, the National Environmental Coalition on Invasive Species (NECIS) responded by adopting its own description of an effective, comprehensive invasive species program.  Under the title “Tackling the Challenge of Invasive Species,” the coalition makes the following major points:

  • Focus prevention efforts on pathways of introduction. Until they are closed, managing established infestations will be a never-ending burden.
  • Broader and more aggressive efforts to control existing invaders is a solid investment, but should not be at the expense of other aspects of a comprehensive national response.
  • Close loopholes in the “Injurious Wildlife” sections of the Lacey Act to provide agencies with more agile processes for regulating the importation and transport of harmful invasive species.
  • Enhance funding for invasive species control and management projects; prioritize efforts to reduce invasive species’ spread at landscape scales.
  • Ensure that federal actions do not inadvertently promote the introduction or spread of harmful invasive species; use caution when promoting nonnative species for biofuels, bioenergy, or other
  • purposes.
  • Adopt metrics to gauge the effectiveness of efforts to prevent the introduction and spread of new invasives and to achieve long-term control or removal of existing invaders.
  • Support robust research and outreach programs, which are essential to improving the efficacy of federal, state, and local invasive species prevention and control efforts.

Given the new legislation’s focus on land-managing agencies, I point to the importance the coalition gave to research on the invasion processes utilized by various species and education of land and water users  so as to gain their cooperation. These recommendations are directly counter to the new law’s stringent limitations on research and “outreach”.

I think particularly pertinent are the recommendations on metrics to measure programs’ efficacy. Proper metrics should metrics address outcomes and program effectiveness re:

  • efforts to prevent species introduction and spread
  • activities that target pathways or vectors
  • the effectiveness of treatments in eradicating or reducing the target invasives.

Potential additional metrics include, but are not limited to:

  • Rate of new invasions; possibly categorized by type of invader or geography
  • Acres infested and changes in infestations over time
  • Acres protected, based on projections of future spread avoided by eradication
  • Economic impact of invasive species
  • Number of species intercepted.

The full document is available here .

Posted by Faith Campbell

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

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.

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.