Penalties for Importers Who Violate Wood Packaging Rules!

CBP inspection of wood packaging; CBP photo

On September 25, the DHS Bureau of Customs and Border Protection (CBP) announced that beginning on November 1, the agency would no longer eschew penalizing importers of non-compliant wood packaging until that importer had accumulated five such interceptions in the course of a year.

Beginning November 1, “responsible parties with a documented WPM violation may be issued a penalty under Title 19 United States Code (USC) § 1595a(b) or under 19 USC § 1592.”

As readers of this blog might remember, I have frequently fulminated against the “five strikes” policy.  The United States began full implementation of the international standard governing treatment of wood packaging (ISPM#15) 11 and ½ years ago. The U.S. and Canada began requiring China to treat its wood packaging nearly 18 years ago. Nevertheless, numerous shipments containing wood packaging that does not comply with the regulations continue to arrive at our borders – and to bring pests. As of February, only about 30 import shipments (out of nearly 21,000 shipments found to be in violation of ISPM#15 requirements) have received a financial penalty.

shipments of stone or tile are frequently supported by non-compliant wood packaging; photo (c) the Queen by right of Canada (CFIA)

In a blog I posted in February I described the continuing detections of pests in wood packaging. In summary, during Fiscal Years 2010 through 2016, CBP detected nearly 5,000 shipments of wood packaging that harbored a pest in a regulated taxonomic group. The APHIS interception database for the period FYs 2011 – 2016 contained 2,547 records for insect detections on wood packaging. The insects belonged to more than 20 families. A quarter were in the Cerambycid family; 11% were Buprestids. In a study of insect larvae removed from incoming wood packaging from the period April 2012 through August 2016, APHIS scientists evaluated 1,068 insects from 786 separate interceptions of non-compliant wood packaging. The wood packaging in all three datasets came from dozens of countries.

 

(Remember, the U.S. and Canada do not apply ISPM#15 to wood packaging moving between the two countries. Neither country inspects wood packaging from the other country at even the low rate of inspection applied to wood packaging coming from other countries – so we don’t know how many quarantine pests are moving in this high-volume trade.)

 

The Bureau of Customs’ action has partially fulfilled one of two recommendations that I made in the February blog. I applaud CBP’s action. However, neither CBP or APHIS has yet prohibited importers with records of repeat violations from using wood packaging – my second recommendation.

 

Note that the CBP decision applies Customs regulations; USDA has apparently not changed its policy of allowing importers to accumulate five (detected) violations in a calendar year before applying the civil penalties provided by the Plant Protection Act.  Why?

 

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.

Posted by Faith Campbell

Biological Control Approved for Invasive Black and Pale Swallow-wort!

black swallow-wort; photo by Leslie J. Mehrhoff, University of Connecticut

Help is on the way!

With funding support through the Northeast IPM Partnership, University of Rhode Island entomologist Richard Casagrande has been leading a team to find biological control agents for two invasive plant species. The target species, black swallow-wort (Vincetoxicum nigrum) and pale swallow-wort (Vincetoxicum rossicum), are native to Europe and members of the milkweed family Apocynaceae (previously Asclepiadaceae). In the U.S., their vigorous growth overtakes and smothers small trees, shrubs and other native plants and threatens the survival of the monarch butterfly whose larvae rely on milkweed for their development. They are currently found in the northeastern and mid-Atlantic states but could spread much farther.

(See Faith’s earlier blog about USDA speeding up approvals of biocontrols for invasive plants here.

U.S. native swallow-wort species belong to the genus Cynanchum and include a dozen or so rare and endangered plant species. It was essential to consider these native species in the investigations. Feeding tests would need to show definitively that the potential biocontrol species would not attack native swallow-worts or other native members of the milkweed family. And, Jennifer Dacey, Casagrande’s graduate student, wanted to find out how well the exotic swallow-worts might provide for monarch butterflies. The results were alarming.  All of the monarch larvae died when hatching on black swallow-wort.  “They stopped eating after a single bite,” says Casagrande.

pale swallow-wort; photo by Leslie J. Mehrhoff, University of Connecticut

Why biological control?

Small infestations of invasive swallow-wort, seedlings and young plants can be pulled up by hand, mature plants can be dug up, and frequent mowing can suppress populations in fields. However, most infestations are too extensive to control by hand. Systemic herbicides – those that are carried through the plant to the roots — can be used to control large infestations, using foliar sprays. Several years of treatment will likely be needed due to the persistence of swallow-wort seeds. These efforts can be part of an overall Integrated Pest Management strategy but the best long-range solution is biological control. Biocontrol relies on finding herbivores that have coevolved to feed on specific invasive plants in their native range that will not have a significant impact on non-target species. Graduate student Aaron Weed worked with Swiss scientists to identify a handful of specialist plant herbivores, mainly beetles and moths that evolved with black swallow-wort and pale swallow-wort in their native ranges in Europe and were highly unlikely to feed on other plant species.

Approval process.

All biological control agents must be approved for release by the U.S. Department of Agriculture, Animal and Plant Health Inspection Service (APHIS). APHIS sets up a Technical Advisory Group, or “TAG”, to review the research on feeding tests conducted by the researchers, called “no-choice” tests.  Potential biocontrol agents are tested for feeding on an extensive selection of native plant species and their relatives to ensure the agents are specific to the target species and won’t pose a threat to agriculture or to rare, threatened or endangered species or to other native species. The TAG list includes, naturally, most native milkweed relatives and even species more distantly related.

“Luckily, none of our native plants is closely related to the [invasive]swallow-worts,” says Casagrande. “That makes [swallow-wort] a great candidate for classical biological control.  The Tag list also includes a suite of Eurasian plants you might expect these specialists to nibble at now and then, and even plants that could host these specialists’ relatives. The bar is high for these no-choice tests: biocontrols must prove they’ll die before they switch.”

Casagrande’s team examined five possible biocontrol specialists in their quarantine lab, including two European moth species (Hypena opulenta and Abrostola asclepiadis) that feed on swallow-wort leaves in their native range. The researchers wanted to be sure these insects wouldn’t jump to non-target plants on the TAG list, since the last thing anyone wants is a new pest dominating the landscape, threatening agriculture, native ecosystems, and rare plants.

Results?

Both leaf-eating moths “passed the acid test,” says Casagrande. However, scientists have only petitioned for and received approval for Hypena opulenta, which was approved by the USDA in September 2017. They may seek approval for Abrostela in the future but for now are focused on rearing, releasing, and studying the effectiveness of Hypena.  Releases in Canada started in 2013 when Hypena was approved there. Since then, it has established and spread but it is too soon to evaluate its effectiveness.

Releases in the U.S.

Hypena opulenta was released on Naushon Island, Massachusetts, in early September 2017 – the only release in the United States – where both black and pale swallow-wort occur. The field release was carried out by placing about 400 larvae in each of 4 large cages containing both swallow-wort species in sun and shade locations. The larvae will be allowed to grow and develop in the cages for a little while before the cages are opened to allow the larvae to escape and start establishing on the island.

Next steps?

Funding will be sought to support rearing of Hypena at University of Rhode Island and other locations in the U.S. Dr. Lisa Tewksbury, Manager of Biological Control at URI, is running the program. It will take a few years to get to the point of having sufficient moths to distribute widely.  Best practices for releasing and monitoring will be developed.

Thanks to the Northeast IPM Partnership and the interest and dedicated efforts of Casagrande and his research team, we now have the most effective tool to use against two highly invasive plant species that will also protect our native species and natural ecosystems.

 

Posted by Jil Swearingen

Jil recently retired from the federal government and works as an invasive species consultant. She has 28 years of experience working on invasive species at the county, regional and national level in areas of education, outreach and management. Jil initiated and co-founded the Mid Atlantic Invasive Plant Council and serves on the board. Jil serves as the Coordinator for the Mid Atlantic Early Detection Network, a project she initiated and co-developed, and she continues to serve as Chair for the Plant Conservation Alliance’s Alien Plant Working Group and manager of the Weeds Gone Wild website. Jil is lead author of the book, Plant Invaders of Mid-Atlantic Natural Areas. She was recently elected to serve on the Board of Directors of the Maryland Native Plant Society

 

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.

 

Polyphagous shot hole borer attacks almond trees

I have written numerous times about the risk posed to urban and rural forests posed by the polyphagous and Kuroshio shot hole borers and their associated fungi. (Blog exploring risk to urban forests; discussion of need for regulation.)

Yet neither California authorities nor USDA APHIS has put significant effort into containing these insects – which continue to spread north in the state. Perhaps this will change in response to the U.S. Senate’s Agriculture appropriations report, which on p. 39 instructs the Secretary of Agriculture to report on steps being taken to “to minimize the spread of other pests such as the polyphagous and Kuroshio shot hole borers.”

Another possible spur to action is that scientists have now proved that the Fusarium euwallaceae fungus – the primary fungus transported by these beetles – can infect almond trees  — a major economic crop in the San Joaquin Valley of California. The polyphagous shot hole borer is known to be in Santa Barbara and San Luis Obispo counties – ever closer to the agricultural areas. California produces 82% of total global production of almonds. In 2015, the state’s almond production was valued at $5.33 billion. $5.14 billion (96%) of this production was exported (California Agricultural Production Statistics).

Already, the polyphagous shot hole borer threatens a wide range of native and horticultural trees in the region. (Damage to avocado trees is less than originally believed.) Together, the polyphagous and Kuroshio shot hole borers and their associated fungi threaten more than a third of trees in the urban forests in southern California, with a cost for the trees’ removal and replacement estimated at $36 billion.

Hosts native in southern California:

  • Box elder (Acer negundo)
  • Big leaf maple (Acer macrophyllum)
  • California Sycamore (Platanus racemosa)
  • Red Willow (Salix laevigata)
  • Arroyo willow (Salix lasiolepsis)
  • Goodding’s black willow (Salix gooddingii)
  • Coast live oak (Quercus agrifolia)
  • Engelmann Oak (Quercus engelmannii)
  • Valley oak (Quercus lobata)
  • Canyon live oak (Quercus chrysolepis)
  • Fremont Cottonwood  (Populus fremontii)
  • Black cottonwood (Populus trichocarpa) *
  • White alder (Alnus rhombifolia)
  • Blue palo verde (Cercidium floridum)
  • Palo verde (Parkinsonia aculeata)
  •  Mesquite (Prosopis articulata)
  • Mule Fat (Baccharis salicifolia)
  • California buckeye (Aesculus californica)

Hosts that are exotics but widespread in southern California:

  • Avocado (Persea americana)
  • Castor bean (Ricinus communis)
  • English Oak (Quercus robur)
  • London plane (Platanus x acerifolia)
  • Coral tree (Erythrina corallodendon)*
  • Brea (Cercidium sonorae)
  • Weeping willow (Salix babylonica)
  • Red  Flowering Gum  (Eucalyptus ficifolia)
  • Tree of heaven (Ailanthus altissima)
  • Kurrajong (Brachychiton populneus)
  • Black mission fig (Ficus carica)
  • Japanese beech (Fagus crenata)
  • Dense logwood/Shiny xylosma (Xylosma congestum)
  • Black Poplar (Populus nigra)
  • Carrotwood (Cupaniopsis anacardioides)
  • Kentia Palm (Howea forsteriana)
  • King Palm (Archontophoenix cunninghamiana)
  • Tamarix (Tamarix ramosissima)

Hosts that are native or widespread exotics in the Southeastern states:

  • Box elder (Acer negundo) (repeated from above)
  • Liquidambar (Liquidambar styraciflua)
  • Japanese wisteria (Wisteria floribunda)
  • Tree of heaven (Alianthus altissima)

Hosts that are sold interstate in the nursery trade (note that PSHB, at least, has attacked branches as small as 2.5 cm – Coleman, 2016):

  • Japanese maple (Acer palmatum)
  • Camelia (Camellia semiserrata)
  • Chinese holly (Ilex cornuta)

 

See also the writeup at www.dontmovefirewood.org

 

Source:

Moreno, K., J.D. Carrillo, F. Trouillas, A. Eskalen. 9/24/2017 Almond (Prunus dulcis) is susceptible to Fusarium euwallaceae, a fungal pathogen vectored by the Polyphagous Shot Hole Borer in Calif | Plant Disease. http://apsjournals.apsnet.org/doi/abs/10.1094/PDIS-07-17-1110-PDN 1/2

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.

 

Posted by Faith T. Campbell

Worldwide Study Confirms ISPM#15 is not Protecting Forests – What Do We Do Now About Pests in Wood Packaging?

 

You know that the continuing pest risk associated with imports of wood packaging is among my biggest concerns. See, for example, fact sheets here and blogs here and here.

A new book about the family Cerambycidae (edited by Wang 2017; reference at end of blog) confirms that longhorned beetles continue to be introduced to many countries via this pathway, more than a decade after widespread implementation of the international standard governing wood packaging (ISPM#15). Furthermore, data from several countries confirm that China continues to fall short … but that problems are more widespread.

The Wang book finds that 16 outbreaks of the Asian longhorned beetle (ALB) were detected between 2012 and 2015.

Unless otherwise noted, the information provided here comes largely from the book’s chapter on biosecurity coauthored by Dominic Eyre and Robert A. Haack (see link below). Opinions stated are mine, unless specified otherwise.

In some cases – which I will note – further details are from my earlier posts.

While I think the risk of introduction of highly damaging pests via the wood packaging pathway is well documented in Wang (2017) and other publications, no one can truly quantify this risk because of shortcomings in countries’ data. Available data come primarily from countries’ records of pest “interceptions” – usually at points of entry.  However, interception data are inadequate to conclusively establish the lack of a threat for a particular trade or to provide a fair comparison of the relative threat of particular trades. Most interception databases have the following shortcomings (Eyre and Haack are summarizing points made by a third scientist – Lee Humble – in an earlier article):

(1) interception databases are not based on random sampling, which is necessary to measure the “approach” or “infestation” rate;

(2) inspections which find no pests are not recorded, so we cannot know what proportion of incoming shipments are infested;

(3) once inspectors have discovered a quarantine pest in a shipment, the consignments may be destroyed without further inspection, and thus other exotic organisms can be missed;

(4) only a small percentage of individual shipments are inspected; and

(5) organisms often are not identified to species due to difficulty of identifying larvae.

Furthermore,

(1) trade volumes and sources can change rapidly;

(2) the number of consignments inspected varies from year to year in response to national and regional plant health and wider government priorities;

(3) the method and intensity of quarantine inspections can vary within and among countries and as well as over time; and

(4) different proportions of consignments from different trades can be inspected, reflecting the perceived quarantine risks of each trade.

Still, scientists try to analyze the available data because propagule pressure may be the most important factor in determining whether an exotic pest becomes established.

What have they found?

Data from both the United States and Europe document that problems of non-compliance continue in recent years – more than a decade after adoption of ISPM#15.

United States:

  • Since APHIS interception records began being computerized in 1985, Cerambycidae have been among the most frequently intercepted insect families associated with wood products and packaging. The top five countries for infested shipments during the period 1984 – 2008 were China, Italy, Mexico, Turkey and Spain. A country’s rank is linked in part to import volumes – which are very high for China, Canada, and Mexico. Because the  U.S. inspects very limited quantities of wood packaging from Canada, its absence from the top five may be misleading [discussed in my blog from February, here.

Another factor explaining these countries’ rankings is the continued – in fact increasing! – presence of pests in wood packaging accompanying imports of tile and quarry products (e.g., marble, slate). Many of these imports are from Italy, Spain, and Mexico. Interceptions on these imports increased significantly from the mid-1990s to 2008. The increase in these interceptions is most alarming because it shows USDA leaders have not yet taken effective action to curtail this risk, despite its being evident since record-keeping began.

 

  • Over the period Fiscal Years 2010 through 2016, the U.S. Bureau of Customs and Border Protection has detected nearly 5,000 consignments in which cases the wood packaging harbored a pest in a regulated taxonomic group. APHIS experts identified 2,500 insects taken from wood packaging during this period; a quarter were Cerambycids. A second APHIS analysis of a subset of the wood packaging-associated insects found examples from 39 countries, including 212 shipments from Europe; 130 shipments from Asia; and 341 shipments from the Americas – almost exclusively Mexico. [These detections are discussed in my blog from February, here.

 

Europe has had a similar experience.

  • Interception records included in EUROPHYT show 306 Cerambycidae interceptions on wood packaging over the period 1998 – 2013. The number of interceptions recorded in 2012 and 2013 are double those of all previous years. Each year, the majority are on wood packaging from China.
  • Most interceptions of ALB (distinct from detections of establishments) have occurred after the shipment cleared border inspection procedures, e.g., in warehouses.
  • As with the U.S., while the majority of non-compliant shipments are from China, the problem is worldwide: Europe has also found various species of longhorned beetles in wood packaging from various European countries (inside and outside the European Union), other Asian countries, Africa, Australasia, and the Americas.
  • Austria inspected 451 consignments of stone imports received April 1, 2013 – April 14, 2014. Forty-four consignments (9.8%) were found to be out of compliance with ISPM#15. Live Cerambycidae were found in 38 consignments (8%), including ALB. This finding confirms the widespread awareness that stone imports rank high for non-compliant wood packaging.

 

Regulatory Authorities’ Response (or lack thereof)

Europe

  • Since March 31, 2013, the European Union has required inspection of 90% of consignments of slate, marble, and granite and 15% of consignments of two other categories of stone imports.

CBP agriculture specialists in Laredo, Texas, examine a wooden pallet for signs of insect infestation. [Note presence of an apparent ISPM stamp on the side of the pallet] Photo by Rick Pauza
United States

  • As noted by Haack et al. (2014) (reference below), as of 2009, approximately 13,000 containers harboring pests probably enter the U.S. each year. That is 35 potential pest arrivals each day. [This issue is also discussed in the fact sheet and blogs here and here.
  • The United States has not specified an obligatory inspection rate for such high-risk imports as stone and tile. Instead, it relies on Customs and Border Protection to target import shipments suspected of being out of compliance based on past performance of importers, suppliers, and types of imports.
  • Several relevant issues are discussed in the blog in February 2017 (second blog linked to above). First, I noted that the U.S. Department of Homeland Security Bureau of Customs and Border Protection – over the seven-year period Fiscal Years 2010 through 2016 – has detected nearly 5,000 cases of wood packaging harboring a pest in a regulated taxonomic group. Comparing the estimate by Haack et al. 2014 with the CBP data indicates that Customs is detecting about 6% of all pest-infested shipments.
  • Furthermore, about 26% of infested wood pieces detected by CBP were found in wood that was marked as having been treated according to ISPM#15 requirements. What does this mean? Fraud? Accidental misapplication of the treatments? Or are the treatments less effective than hoped? What are USDA and other responsible agencies doing to clarify the causes?
  • CBP staff reported that only about 30 import shipments (out of nearly 21,000 shipments found to be in violation of ISPM#15 requirements) have received a financial penalty. How can USDA and Customs officials justify this failure to enforce the regulations?

 

 

What Can Be Done to Close Down the Wood Packaging Pathway

 

I suggest that our goal should be to hold foreign suppliers responsible for complying with ISPM#15. One approach is to penalize violators. APHIS and Customs might

  • Prohibit imports in packaging made from solid wood (boards, 4 x 4s, etc.) from foreign suppliers which have a record of repeated violations over the 11 years ISPM#15 has been in effect (17 years for exporters from Hong Kong & mainland China). Officials should allow continued imports from those same suppliers as long as they are contained in other types of packaging materials, including plastic, metals, or fiberboards.
  • Fine an importer for each new shipment found to be out of compliance with ISPM#15 in cases when the foreign supplier of that shipment has a record of repeated violations.

 

There would need to be a severe penalty to deter foreign suppliers from simply changing their names or taking other steps to escape being associated with their violation record.

 

At the same time, the agencies should work with non-governmental organizations and importers to promote creation of an industry certification program that would recognize and reward importers who have voluntarily undertaken actions aimed at voluntarily exceeding ISPM#15 requirements so as to provide a higher level of protection against invasive species that would otherwise potentially be introduced into the United States.

 

What You Can Do

  • Tell your member of Congress and Senators that you are worried that our trees are still being put at risk by insects arriving in wood packaging. Ask them to urge the USDA Secretary Sonny Perdue to take the actions outlined above in order to curtail introductions of additional tree-killing pests.
  • Talk to your friends and neighbors about the threat to our trees. Ask them to join you in communicating these concerns to their Congressional representatives and Senators.
  • Write letters to the editors of your local newspaper or TV news station.

 

Use your knowledge about pests threatening trees in your state or locality in your communications!

 

Other Introduction Pathways for Cerambycids

tree removals in Tukwilla, WA to eradicate citrus longhorned beetle; photo by Washington State Department of Agriculture

Plants for planting

Other studies have confirmed that importation of living plants (called by regulators “plants for planting”) is a high-risk pathway for introducing tree-killing pests. See the Eyre and Haack chapter for a summary.

This is as true for highly damaging Cerambycids as for other types of plant pests. One of the most damaging is the citrus longhorned beetle (CLB) (Anoplophora chinensis). CLB [https://www.dontmovefirewood.org/invasive-species/] poses an even greater threat to North American forests than ALB – it has a wider host range and climate-matching models show that it could establish across most of the United States. CLB were detected in a nursery in Tukwilla, Washington, in 2001; the pest was eradicated. Nine CLB outbreaks have been detected in Europe; three are considered eradicated (Eyre & Haack 2017).

Eyre and Haack (2017) report that in Europe of the 455 Cerambycidae intercepted over the period 1998 – 2013, 54 were on imported in living plants. These included probably 49 citrus longhorned beetle (CLB). Most were detected primarily on maple nursery stock that originated China (32), with smaller numbers from other countries, including Netherlands (8), and Italy (where CLB has been established).

New Zealand has intercepted 74 CLB on plants for planting over the 28 year period 1980 – 2008.  One third of this total was intercepted in 2008.

 

Authorities’ Responses (or lack thereof)

Europe

  • Since 2012, the European Union has required that 10% of CLB host plants imported into the European Union should be destructively sampled (that is, dissected to see whether insects are present internally).
  • This requirement supplements a broader requirement that plants for planting be treated as a high risk commodity. Member states are required to inspect all incoming P4P consignments. This requirement is, however, undermined by much more lenient requirements regarding movement of plants among EU member states – some genera are not regulated … others are controlled by Plant Passports – an industry-led scheme.  [For more on this issue, see my blog from October 2016 here.

 

United States

  • APHIS issued a Federal order tightly restricting imports of CLB hosts from Europe in 2013 – four years after a CLB outbreak was detected in a part of the Netherlands which is a center for the production of hardy ornamental nursery stock for European and probably American markets.
  • APHIS proposed to revise its overall plant importation regulations (the “Q-37 regulations) to rely more on integrated management by the exporting nurseries in contrast to port inspections. This rulemaking has stalled. [See my blog about this here.]

 

Finished Wood Products

While no country is keeping comprehensive records, finished wood products have transported longhorned beetles.  Eyre and Haack (2017) concluded that upholstered furniture presents one of the highest risk among the finished wood products – partly because imports are rising rapidly, partly because insect-damaged wood can be hidden under the upholstery. New Zealand found that some Asian manufacturers place good quality wood on visible surfaces and poor quality timber (insect damaged and bark covered) in internal sections. Officials inspected 49 couches and found that 30 had wood with bark, 19 had insect contaminants, and 32 had visible insect damage. Fungal samples were isolated from 11 of the couches. They found 4 longhorned beetles.

 

References

Wang, Q. (Ed.). 2017. Cerambycidae of the world: biology and pest management.  Boca Raton, FL: CRC Press

The chapter on biosecurity is available here:  http://treesearch.fs.fed.us/pubs/54552

A chapter on Cerambycid impacts in urban and rural forests is available here: http://treesearch.fs.fed.us/pubs/54543

 

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.

 

Posted by Faith Campbell

Feral hog eradication – making progress by doing it the right way

large_hog_damage (MO)

feral hogs in Missouri

As I wrote in my blog of March 2016, introduced wild hogs (Sus scrofa) threaten ecosystems across the continent and on islands ranging from Hawai`i to the Caribbean.

According to an environment impact statement prepared by APHIS (see reference below), these highly adaptable, prolific, large and powerful animals cause immense damage by rooting for plant parts and invertebrates in the soil, and by wallowing to cool themselves and fend off biting insects. Pigs may root to depths of three feet below the surface. Wallows are commonly located in or adjacent to riparian or bottomland habitats. Feral hogs out-compete other animals for hard mast and also consume algae, fungi, soil invertebrates, worms, crustaceans, and bird and reptile eggs. They even feed on small vertebrate animals.

Rising feral hog populations and spread to new areas has raised concern. insert map  According to John J. Mayer (reference below), the number of states with established wild boar populations is now 37. They might number as many as 11.3 million. Texas has the largest numbers, 30 to 41% of the U.S. total. Other states with high numbers are Alabama, Arkansas, California, Florida, Georgia, Louisiana, Mississippi, Oklahoma, and South Carolina.

 

Poison them?

One proposed response was to poison the hogs using the anticoagulant drug Warfarin – which is widely used as a rodent poison. The U.S. Environmental Protection Agency (EPA) approved the use of warfarin as a bait – Kaput® Feral Hog Bait – in January 2017 after only 16 months of review – an unprecedented brief period for a toxin. Many expressed concern, especially about possible poisoning of non-target wildlife. The National Environmental Coalition on Invasive Species was one of several groups to ask EPA to reconsider.  Principal concerns raised: black bears and other wildlife could open the bait dispenser; spilled bait could be eaten by a wide variety of wildlife; scavengers could be exposed when they feed on the carcasses of poisoned pigs; hunters could also be exposed to contaminated meat. Several states considering use of the bait – including Louisiana and Texas – decided to reconsider. The Arkansas Game and Fish Commission also asked the state Plant Board to take care pending additional study of the secondary effects.

Missouri Program Expands

Meanwhile, Missouri is finding success with its aggressive and scientifically-based program, which began  years ago in response to growing public concern about hog damage. As I noted in my earlier blog, in 2016, the Missouri Conservation Commission prohibited hunting of feral hogs on lands owned, leased, or managed by the Missouri Department of Conservation. Missouri took this action because hunting does not significantly reduce feral hog populations. Instead, it causes the animals to disperse – making them even more difficult to control. (Missouri has extensive material on feral hogs posted here  .

The Missouri Department of Conservation is working with several partners – including other government agencies, non-government organizations, agricultural organizations and many landowners. The program has included private lands since the 1990s. However, there is an increased effort to engage more private landowners so as to place traps on more lands in the state. The outreach includes landowner workshops and presentations to various groups, as well as information provided at fairs and similar events. MDC relies largely on landowners contacting the agency when they have feral hog problems and visits to individuals.

The outreach is working; the number of landowners asking for assistance is rising.

The numbers of hogs removed has also risen. During 2016, 5,358  were removed as part of the program. During the first seven months of 2017, From January 1 through July 31, 2017 MDC and its partners removed 4,703 feral hogs.  This is more than a thousand more than had been removed during the same period in 2016.

The program is not cheap; the Conservation Commission approved $1.8 million for fiscal year 2018. These funds cover primarily trapping and killing activities. Costs for MDC staff time and fuel are not included. Most of the MDC staff assisting the program do so as an additional duty. Recently, MDC has hired Mark McLain as the Feral Hog Elimination Team Leader to coordinate MDC feral hog elimination efforts statewide.

Information for this blog came in part from an MDC press release here  and Alan Leary and Mark McLain of the Missouri Department of Conservation. However, the views presented here are those of the Center for Invasive Species Prevention, not the Missouri Department of Conservation.

Update:

The Missouri program removed a total of 6,561 feral hogs in 2017. From January through July 2018, the program removed 7,339 hogs (MDC press release November 2018).

Mark McLain, the MDC lead on hog eradication, said “We’ve been very strategic in our efforts, focusing on removal of whole groups of feral hogs at a time, before moving onto another area. 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.”

McLain noted that over the 20 years when hunting feral hogs was unregulated, they spread from a few counties to over 30 counties.  He warned people who continue to release feral hogs are acting illegally and will be fined.

SOURCES

Mayer, J.J. 2014. Estimation of the Number of Wild Pigs Found in the Unted States. August 2014 SRNL-STI-2014-00292, Revision 0.

Missouri Department of Conservation. 2018. Press Release: MDC and partners eliminate more than 7,300 feral hogs from Missouri’s landscape in 2018 so far. https://mdc.mo.gov/newsroom/mdc-and-partners-eliminate-more-7300-feral-hogs-missouri%E2%80%99s-landscape-2018-so-far

U.S. Department of Agriculture Animal and Plant Health Inspection Service Final Environmental Impact Statement. Feral Swine Damage Management: a National Approach May 27, 2015 https://www.aphis.usda.gov/regulations/pdfs/nepa/2015%20Final%20EIS%20Feral%20Swine%20Damage%20Management%20-%20A%20National%20Approach.pdf

 

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.

 

Posted by Faith Campbell

California – volunteers make major efforts

polyphagous shot hole borer exit holes on box elder; photo source http://ucanr.edu/

I have posted many blogs criticizing California state authorities for not acting to counter several highly damaging tree-killing pests, such as the goldspotted oak borer and invasive shot hole borers.

I should have made it clear that many Californians – academics, employees of local, state, and federal agencies, concerned citizens – are working very hard to develop scientific knowledge, test strategies, educate stakeholders and those whose activities facilitate the insects’ spread. These people have carried forward a wide range of dedicated efforts that do much to make up for the lack of state or federal agencies’ engagement.

More than 60 stakeholder entities now participate in one or more of nine working groups focused on shot hole borers, promoting research, education and outreach. Some of these activities receive advice (but apparently no funding) from California Department of Food and Agriculture. Outreach to the media has resulted in some good coverage. Master Gardeners and other potential citizen scientist groups have been trained. See here.

A smaller but older group is carrying out similar activities targetting goldspotted oak borer; visit here.

 

Here I summarize some of the most recent activities.

1) Scientists have released a pocket-sized guide for identifying trees infested by polyphagous or Kuroshio shot hole borers (For summaries of the threat posed by these insects and their associated fungi, visit here). The guide can be downloaded here.

The Guide is useful for people outside as well as inside California, since some host species grow across the continent: box elder (Acer negundo), sweetgum (Liquidambar styraciflua), tree of heaven (Ailanthus altissima), mimosa or silk tree (Albizia julibrissin).

Other hosts are common in horticulture: camellia (Camellia semiserrata), Japanese maple (Acer palmatum), Japanese wisteria (Wisteria floribunda), London plane (Platanus x acerifolia), mimosa, and weeping willow (Salix babylonica).

The shot hole borers could be present outside the six California counties known to contain infestations because one or both of these beetles could have been spread via movement of wood, greenwaste, or nursery stock; or they could have entered other parts of the country on plants or wood from Asia.

 

2) Scientists are testing possible pesticide treatments to protect trees from polyphagous shot hole borer

The polyphagous shot hole borer (a still undescribed beetle in the Euwallacea genus), attacks more than 200 host tree species in southern California, including many important native and urban landscape trees. Forty-nine species from more than 20 families are known to be reproductive hosts. Trees are dying in parks, residential neighborhoods, other public landscapes, and riparian areas.  John Boland of Southwest Wetlands Interpretive Association has documented that 88% of the willows in the Tijuana River Valley have been infested by the Kuroshio shot hole borer – although many of the trees regrow into four-foot-tall shrubs. Dr. Boland estimates that more than two billion KSHB hatched in the valley during 2015-2016.

Confronted by such threats, home owners, park managers, and arborists are desperate for management tools.

As reported by Jones et al. 2017 (see reference below), scientists tested the effectiveness of insecticides, fungicides, and insecticide–fungicide combinations for controlling continued PSHB attacks on previously infested California sycamore trees. The combination of a systemic insecticide (emamectin benzoate), a contact insecticide (bifenthrin), and a fungicide (metconazole) provided the best control over the six months of the study period. The biological fungicide Bacillus subtilis provided short-term control.

Efficacy of the treatment combination is not yet settled. First, the polyphagous shot hole borer actively oviposits year-round, and both adults and larvae may be found in an infested tree at any time of year. Furthermore, the shot hole borers are active throughout the sapwood, not just in the phloem and cambium tissues. These differences in behavior may make timing and efficacy of systemic insecticides more difficult to predict. In addition, it is extremely difficult to detect infestations at an early stage, when treatment is most likely to be effective. Finally, the treated trees should be monitored over several years, rather than for six months, to evaluate true efficacy.

 

3) Efforts to gain official actions re: Invasive Shot Hole Borers

Some people are trying to promote state engagement. They are focused on getting adoption of a strategy under the auspices of the California Invasive Species Council to create a system to respond to bioinvaders that don’t fall within the California Department of Food and Agriculture’s definition of its responsibilities – e.g., the shot hole borers. The invasive shot hole borers are included in the interagency “Charting the Pest Prevention System in California” plan.

 

4)  On-the-Ground Efforts

Some entities are compiling and publicizing their costs for responding to the several wood borers. For example, the University of California Irvine reports spending close to $2 million to manage trees on campus that have been attacked. The Orange County parks agency has spent $1.7 million on shot hole borer surveys, tree inventory, public outreach materials, staff training, and some research. These costs are rising – in the first half of 2017, Orange County parks agency has already spent $348,000 on tree treatment and removal.

UC Cooperative Extension for San Diego County organized a Green Waste-Wood Biomass Symposium in February aimed at educating industry and public agency waste-management practitioner.

Goldspotted Oak Borer

Three National forests are treating high-value oaks in specific sites:

  1. Cleveland NF sprayed 248 oak trees with the contact insecticide, carbaryl. The Forest hopes to continue the treatments yearly dependent on funding and need.
  2. The Angeles NF removed 50 GSOB-infected oaks in Green Valley. They then tagged about 1,000 oak trees in the area so their changing conditions can be monitored.
  3. San Bernardino NF is felling and debarking GSOB-infested oaks on the periphery of the communities of Idyllwild and Pine Cove.

Orange County removed highly infested trees at Weir Canyon; now spraying another 1,672 oaks, including both lightly infested and neighboring trees, with carbaryl  … monitoring has not detected any other infested trees in Weir Canyon or neighboring Blind Canyon.

 

Summarized from the San Diego County update (reference below).

In the absence of legal mechanisms to stop the movement of infested firewood, collaborating organizations have focused on public education and outreach programs for the firewood industry, tree care professionals, and the public. Still, some infested wood continues to be moved – probably to uninfested areas.

The Update also reports the following impacts of the goldspotted oak borer in San Diego County:

  • Eight San Diego County Parks have suffered loss of habitat, diminished recreational value, and direct costs associated with tree removal and grinding and insecticidal treatments. More than 5,000 trees have been lost in just one park, William Heise Park.
  • One California State Park lost nearly $500,000 in campground and day-use fees when areas were closed for tree removal. GSOB has been discovered at two more State parks in recent years.
  • The Cleveland National Forest has suffered negative environmental, economic and aesthetic impacts; removed more than 200 trees and treated 248 high-value trees on developed sites.
  • Tribal lands have lost oaks of great cultural value as well as reduced habitat, shade, and recreational enjoyment.
  • Urban and rural residential homeowners are faced with removal and disposal costs averaging $1,500 per tree.
  • Fire, transportation, and public works agencies are dealing with higher fuel loads and hazard trees along rights of way.

 

GSOB activists are collaborating with those working on the invasive shot hole borers to seek state and federal support.

 

SOD-infected tanoak; photo by F.T. Campbell

UPDATE ON SUDDEN OAK DEATH

Eight California nurseries were found late this spring to be infected by the sudden oak death pathogen (Phytophthora ramorum).  (As of May, only two nurseries were known to be positive.) Seven of the positive nurseries are located in counties with disease in the natural environment. Given the wet winter and spring in California, this upswing is probably not surprising. Still, this sudden upsurge raises questions about the efficacy of nursery regulations. One of the nurseries was detected as a result of a trace-back investigation – not through the annual inspection.

SOURCES

California Oak Mortality Task Force newsletter, July 2017

Goldspotted Oak Borer and Oak Mortality Quarterly Situation Report April 1 through June 30, 2017

Status of Goldspotted Oak Borer – July 2017 Update Goldspotted Oak Borer Steering Committee www.GSOB.org Email: gsobinfo@ucdavis.edu

 Invasive Shot Hole Borer (Polyphagous and Kuroshio)/Fusarium Dieback Quarterly Situation Report January 1 through March 31, 2017

Jones, M.E., J. Kabashima, A. Eskalen, M. Dimson, J.S. Mayorquin, J.D. Carrillo, C.C. Hanlon, and T.D. Paine. 2017. Evaluations of Insecticides and Fungicides for Reducing Attack Rates of a new invasive ambrosia beetle (Euwallacea Sp., Coleoptera: Curculionidae: Scolytinae) in Infested Landscape Trees in Calif. Journal of Economic Entomology, 110(4), 2017, 1611–1618 doi: 10.1093/jee/tox163 Advance Access Publication Date: 5 July 2017

 

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.

Posted by Faith Campbell

Invasive “hot spot” study confirms vulnerable places, causes of introductions

removing Miconia from Hawaiian forest; courtesy of the Nature Conservancy of Hawai`i

A recent article by Wayne Dawson and 24 coauthors (see reference at the end of this blog) provides the first-ever global analysis of established alien species. They studied the diversity of established alien species belonging go eight taxonomic groups – amphibians, ants, birds, freshwater fish, mammals, reptiles, spiders and vascular plants – across 609 regions (186 islands or archipelagos, and 423 mainland regions).

The analysis found that the highest numbers of established alien species in these taxonomic groups were in the Hawaiian Islands, New Zealand’s North Island and the Lesser Sunda Islands of Indonesia. The Hawaiian Islands have high numbers of invasive species in all of the eight groups studied. In New Zealand, the highest numbers were invasive plants and introduced mammals that prey on the native birds.

Florida is the top hotspot among mainland regions. Florida is followed by the California coast and northern Australia.

Burmese python in the Florida Everglades; photo by U.S. Fish & Wildlife Service

Patterns

 Invasive species hotspots were found mainly on islands and in coastal regions of mainland areas. The lead author, Dr. Wayne Dawson, a researcher at Durham University’s Department of Biosciences, suggested that the greater invasive species richness in coastal regions probably results from higher rates of species introductions to port areas compared to interior regions.

Island regions have, on average, higher cross-taxon invasive species richness. This cross-taxon richness on islands tends to be higher for those islands further from continental landmasses. The authors suggest that such oceanic islands might be more likely to import large quantities of goods from foreign sources than islands close to continents, thus experiencing higher propagule pressure.

 

Associations

Regions with greater wealth (measured as per capita GNP), human population density, and area have higher established alien richness. These effects were strongest on islands. The authors suggest that wealth and human population density might correlate with higher numbers of species being brought to the region through trade and transport.

On mainlands, cooler regions have higher richness. I think this might reflect history – centuries of colonial powers importing plants and animals. However, colonial powers also introduced species to tropical regions.  In contrast, on islands warmer and wetter regions have higher richness of invasive species.

 

Drivers

The authors conclude that cumulative numbers of invasive species at a particular location are driven to a greater extent by differences in area and propagule pressure than by climate. The model that best explains cross-taxon invasive species richness combines per capita GDP, population density and sampling effort. Other important factors are area of the region, mean annual precipitation, and whether a region is on a mainland or island(s).

The study results show that, per unit increase in area, per capita GDP, and population density, invasive species richness increases at a faster rate on islands than on mainlands. This might be confirmation of the longstanding belief that islands are more readily invaded than mainlands, although the authors caution that a rigorous test of this explanation would require data on failed introductions.

The authors call for additional research to understand whether these effects arise because more species are introduced to hotspot regions, or because human disturbance in these regions makes it easier for the newcomers to find vacant spaces and opportunities to thrive.

 

I think it would be helpful to compare the findings on invasive species richness in specific regions to data on historic patterns of trade and colonization to strengthen our understanding of the importance of propagule pressure in determining invasion patterns.

 

Increasing Confirmation of Significance and Breadth of Invasive Species Threat

The Dawson et al. study is the latest in a series of analyses of global or regional patterns in invasive species. I have blogged previously about several of these:

  • Bradshaw et al. 2016 concluded that invasive insects alone cause at least $77 billion in damage every year, a figure they described as a “gross underestimate”.
  • A study by Hanno Seebens and 44 coauthors showed that the rate of new introductions of alien species has risen rapidly since about 1800 – and shows no sign of slowing down. Adoption of national and international biosecurity measures have been only partially effective, failing to slow deliberate introductions of vascular plant species, birds, and reptiles, and accidentally introduced invertebrates and pathogens. Like Dawson et al, Seebens et al. found a strong correlation between the spread of bioinvaders introduced primarily accidentally as stowaways on transport vectors or contaminants of commodities (e.g., algae, insects, crustaceans, molluscs and other invertebrates) and the market value of goods imported into the region of interest.
  • Liebhold et al. 2016(see reference below) studied insect assemblages in 20 regions around the world. They found that an insect taxon’s ability to take advantage of particular invasion pathways better explained the insect’s invasion history than the insects’ life-history traits. (The latter affect the insect’s ability to establish in a new ecosystem.)
  • Maartje J. Klapwijk and several colleagues note that growing trade in living plants and wood products has brought a rise in non-native tree pests becoming established in Europe. The number of alien invertebrate species has increased two-fold since 1950; the number of fungal species has increased four-fold since 1900.
  • Jung et al. (2015) studied the presence of Phytophthora pathogens in nurseries in Europe. They found 59 putatively alien Phytophthora taxa in the nurseries. Two-thirds were unknown to science before 1990. None had been intercepted at European ports of entry when they were introduced. Nor have strict quarantine regulations halted spread of the quarantine organism ramorum.
  • A report by The World Conservation Union (IUCN) on World Heritage sites globally found that invasive species were second to poaching as a threat to the sites’ natural values. Of 229 natural World Heritage sites examined, 104 were affected by invasive species. Island sites – especially in the tropics – were most heavily impacted.
  • Another report by IUCN found that invasive species were the second most common cause of species extinctions – especially for vertebrates.

Conclusions

These studies demonstrate that

  • Invasive species have become a significant threat to biological diversity and ecosystem services around the world – one that continues to grow.
  • The recent spate of studies originating in Europe probably reflects recent recognition of the continent’s vulnerability – as seen, inter alia, in the proliferation of tree-killing Phytophthoras.
  • Human movement of species – propagule pressure – whether deliberately or due to inadequate efforts to manage trade-related pathways – explain the bulk of “successful” introductions.
  • Economic activity drives introductions, so areas at highest immediate risk are urban areas and other centers receiving high volumes of imports and visitors. Among troubling trends in the future is rapid global urbanization – along with rising economic interdependency.
  • Efforts to curb these movements – at the national, regional, and international levels – have failed so far to counter the threat posed by invasive species of nearly all taxonomic groups.

In my view, the requirements that phytosanitary measures “balance” pest prevention against trade facilitation results in half measures being applied – and half measures achieve halfway results. For example, the U.S. does not require that packaging be made from materials that cannot transport tree-killing pests. The USDA has moved far too slowly to limit imports of plant taxa that pose a risk of either being invasive themselves or of transporting pests known to be damaging.

 

Conservationists should focus on building political pressure to strengthen regulations and other programs intended to curtail this movement. No other approach will succeed.

 

Sources

Bradshaw, C.J.A. et al. Massive yet grossly underestimated global costs of invasive insects. Nat. Commun. 7, 12986 doi: 10.1038/ncomms12986 (2016). (Open access)

Dawson, W., D. Moser, M. van Kleunen, H. Kreft, J. Perg, P. Pyšek, P. Weigelt, M. Winter, B. Lenzner, T.M. Blackburn, E.E. Dyer, P. Cassey, S.L. Scrivens, E.P. Economo, B. Guénard, C. Capinha, H. Seebens, P. García-Díaz, W. Nentwig, E. García-Berthou, C. Casal, N.E. Mandrak, P. Fuller, C. Meyer and F. Ess. 2017. Global hotspots and correlates of IAS richness across taxon groups. Nature Ecology and Evolution Vol. 1, Article 0186. DOI: 10.1038/s41559-017-0186 | www.nature.com/natecolevol

 

Jung,T., L. Orlikowski, B. Henricot, P. Abad-Campos, A.G. Aday, O. Aguin Casa, J. Bakonyi, S.O. Cacciola, T. Cech, D. Chavarriaga, T. Corcobado, A. Cravador, T. Decourcelle, G. Denton, S. Diamandis, H.T. Doggmus-Lehtijarvi, A. Franceschini, B. Ginetti, M. Glavendekic, J. Hantula, G. Hartmann, M. Herrero, D. Ivic, M. Horta Jung, A. Lilja, N. Keca, V. Kramarets, A. Lyubenova, H. Machado, G. Magnano di San Lio, P.J. Mansilla Vazquez, B. Marais, I. Matsiakh, I. Milenkovic, S. Moricca, Z.A. Nagy, J. Nechwatal, C. Olsson, T. Oszako, A. Pane, E.J. Paplomatas, C. Pintos Varela, S. Prospero, C. Rial Martinez, D. Rigling, C. Robin, A. Rytkonen, M.E. Sanchez, B. Scanu, A. Schlenzig, J. Schumacher, S. Slavov, A. Solla, E. Sousa, J. Stenlid, V. Talgø, Z. Tomic, P. Tsopelas, A. Vannini, A.M. Vettraino, M. Wenneker, S. Woodward and A. Perez-Sierra. 2015. Widespread Phytophthora infestations in European nurseries put forest, semi-natural and horticultural ecosystems at high risk of Phytophthora disease. Forest Pathology.

 

Klapwijk, M.J., A.J.M. Hopkins, L. Eriksson, M. Pettersson, M. Schroeder, A. Lindelo¨w, J. Ro¨nnberg, E.C.H. Keskitalo, M. Kenis. 2016. Reducing the risk of invasive forest pests and pathogens: Combining legislation, targeted management and public awareness. Ambio 2016, 45(Suppl. 2):S223–S234  DOI 10.1007/s13280-015-0748-3  [http://www.nature.com/articles/ncomms14435 ]

 

Liebhold, A.M., T. Yamanaka, A. Roques, S. Augustin, S.L. Chown, E.G. Brockerhoff, P. Pysek. 2016. Global compositional variation among native and nonindigenous regional insect assemblages emphasizes the importance of pathways. Biological Invasions (2016) 18:893–905

 

Seebens, H. et al., 2017. No saturation in the accumulation of alien species worldwide. Nature Communications. January 2017. [http://www.nature.com/articles/ncomms14435 ]

 

 

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.

 

Posted by Faith Campbell

 

 

How we can strengthen programs to protect trees from invasive pests

USDA; photo by F.T. Campbell

Every five years, Congress adopts a new Farm Bill. The House and Senate Agriculture committees are  holding hearings and considering proposals for the Farm Bill due to be adopted in 2019. Now is the time for people concerned about the continuing introductions of forest pests and weakness of our government’s response to pests that have become established to ask their Representative and Senators to adopt legislative language to strengthen relevant USDA programs. I suggest specific proposals below – which I hope you will urge your representatives to support.

The Farm Bill supports our Nation’s largest soil and water conservation programs. The Farm Bill can also be used to create new programs that address other issues – such as pest prevention and response.

The Farm Bill already has been used to strengthen APHIS’ phytosanitary programs. For example, Section 10007 of the 2014 Farm Bill provides more than $50 million annually for the Plant Pest and Disease Management and Disaster Prevention Program. These funds have supported numerous vitally important research and management programs targetting polyphagous shot hole borer, spotted lanternfly, velvet longhorned borer, thousand cankers disease, emerald ash borer, as well as more general goals such as improving traps for detecting wood-borers and outreach about emerald ash borer to Native American tribes. With APHIS’ annual appropriations falling far short of the resources needed to respond to invasions by numerous plant pests, Section 10007 has provided essential supplements to the agency’s programs.

The new Farm Bill to be adopted by the Congress offers opportunities to strengthen other components of USDA programs with the goal of protecting the tree species comprising our wildland, rural, and urban forests.

The Center for Invasive Species Prevention and Vermont Woodland Owners Association have developed several proposals that we hope will be incorporated into the 2019 Farm Bill. These proposals have been endorsed by the Reduce Risk from Invasive Species Coalition.  The amendments have also been endorsed by the Weed Science Society of America. CISP submitted testimony summarizing these proposals to the Senate Committee on Agriculture, Nutrition, and Forestry in early July, when the Committee held a hearing on the Farm Bill’s conservation and forestry programs. (For a copy of our testimony, contact us using the “contact us” button.)

You can help by contacting your Representative and Senators and asking them to support these proposed amendments to the 2019 Farm Bill.

These proposed amendments seek to address the following needs.

  • Do you wish to strengthen APHIS’ commitment to pest prevention in the face of a competing mandate to facilitate trade?

Then you might want to support a proposed amendment to Section 3 of the Plant Protection Act. The new language would read as follows:

“(3) It is the responsibility of the Secretary to facilitate exports, imports and interstate commerce in agricultural products and other commodities that pose a risk of harboring plant pests or noxious weeds in ways that will reduce prevent, to the greatest extent practicable feasible, as determined by the Secretary, the risk of dissemination of plant pests and noxious weeds.”

  • Do you wish to increase funding for APHIS’ programs responding to recently-detected plant pests?

Then you might want to support a proposed amendment that would expand APHIS’ access to emergency funds by enacting a broad definition of “emergency”. Under the new definition, “emergency” would mean “any outbreak of a plant pest or noxious weed which directly or indirectly threatens any segment of the agricultural production of the United States and for which the then available appropriated funds are determined by the Secretary to be insufficient to timely achieve the arrest, control, eradication, or prevention of the spread of such plant pest or noxious weed.”

This amendment would help APHIS evade the downward push of its declining annual appropriation and enable the agency to tackle more of the tree-killing pest that have entered the U.S.

Customs inspecting wood packaging

  • Do you wish to promote stronger measures aimed at minimizing the presence of pests in wood packaging material? (I have blogged repeatedly about the continuing pest risk associated with the wood packaging pathway.)

Then you might want to support a proposed amendment that would establish a non-governmental Center for Agriculture-Trade Partnership Against Invasive Species. That Center would promote industry best practices, encourage information-sharing, and create an industry certification program under which importers would voluntarily implement pest-prevention actions that are more stringent than current regulations (ISPM#15) Link require.

American Chestnut Foundation chestnut in experimental planting in Fairfax County, Virginia; photo F.T. Campbell

  • Do you wish to strengthen efforts to develop programs that would provide long-term funding to support 1) research and development of long-term pest-control strategies such as biological control and breeding of trees resistant to insects or pathogens and 2) testing, development, and implementation of strategies to restore to the forest native tree species that have been severely depleted by non-native pests?

Then you might want to support a pair of proposed amendments that would:

  1. Establish a fund, to be managed by the National Institute of Food and Agriculture, to provide grants under which eligible institutions would carry out research intended to test and develop strategies aimed at restoring such tree species. Such strategies might include finding, testing, and deploying biological control agents or breeding of trees resistant to pests.
  2. Amend the McIntyre-Stennis Act to establish a fund to provide grants to support programs to eligible institutions to conduct experimental plantings aimed at restoring such tree species to the forest.

You can obtain copies of the proposed amendments, in legislative language, by contacting us using the “contact us” button.

Your efforts will be valuable in any case … but if your Representative or Senator is on the agriculture committee, contacting that Member will be most important!

Members of the Senate Committee on Agriculture, Nutrition, and Forestry:

Republicans (majority):

  • Pat Roberts, KS, Chairman
  • Thad Cochran, MS
  • Mitch McConnell, KY
  • John Boozman, AR
  • John Hoeven, ND
  • Joni Ernst, IA.
  • Chuck Grassley, IA
  • John Thune, SD.
  • Steve Daines, MT
  • David Perdue, GA
  • Luther Strange, AL

Democrats (minority):

Members of the House Committee on Agriculture

Republicans (majority):

Democrats (minority):

 

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.

Posted by Faith Campbell

Insects & Pathogens Introduced Via Plant Imports – Let’s Collaborate to Understand Risk

 

map showing locations in Hawaii Volcanoes National Park of ʻōhiʻa infested by rapid ʻōhiʻa death; NPS map available here

The U.S. Department of Agriculture’s adoption of a new list of plant species barred from importation pending pest risk assessment after a four-year wait (NAPPRA) [see my previous blog from June 21, here] prompts me to review what I know about pests associated with plant imports – and to appeal for collaboration among non-USDA scientists to improve our understanding of current  risks. Therefore I’m sharing some pest import and establishment data. I welcome the opportunity to work with experts to evaluate the level of risk and other matters that might be extracted from these data. Contact me to explore how we might work together.

As was pointed out by Eschen et al. 2015 (see list of sources at the end of this blog), most countries’ data on the “plants for planting” pathway are inadequate to allow an assessment of phytosanitary measures’ efficacy in preventing pest introductions. The authors stressed the need for data on:

  1. plant imports at the level of genus, including plant type and origin;
  2. pest arrival rates on each of these categories of plant imports; and
  3. pest establishments.

In the apparent absence of agencies’ efforts to close these data gaps, I propose that we work together, using available information, to improve our understanding of the current level of risk. Perhaps we can agree on which pest species are real red flags; decide which pathways most need new policy approaches; and reach conclusions about the implications of holes in the data.

  1. What Do We Know About Plant Imports?

The U.S. imports approximately 2.5 billion plants each year. The plants most likely to transport insects or pathogens that would attack North American trees and shrubs are woody plants. According to Rebecca Epanchin-Niell, during the period FY2010-FY2012, Americans imported each year more than 300 million woody plant units, belonging to about 175 genera.

Marcel Colunga-Garcia and colleagues analyzed plant import data for the period 2010-2012. They studied maritime (ship-borne) containerized plant imports, which represented 64.4 percent of the total value of all “plants for planting” imported into the U.S. in 2010, excluding imports from Mexico and Canada. The types of plants shipped in this way include rooted plants in pots; bare root plants; bulbs and tubers; root fragments, root cuttings, rootlets or rhizomes; rooted cuttings; unrooted cuttings; and budwood/graftwood.

Measuring by the plants’ import values, Colunga and colleagues determined that New York and Los Angeles metropolitan areas together import 60 percent of these plants; not all plant imports are routed through Miami – as is often assumed.

Second, these data show which states are the ultimate destination for relatively large volumes of certain types of plants. Thus, the top five states for receipt of rhododendrons and azaleas were Michigan, Oregon, California, New York, and New Jersey. Michigan received almost twice as many plants (measured by value) as New Jersey. The top three states for receipt of “fruit and nut trees and shrubs” were Florida, Louisiana, and Washington – all at nearly $1 billion or higher. California and North Carolina ranked fourth and fifth, but at values of only $200,000. It is clear from these data that contaminated plants could deliver pests virtually anywhere in the country.

Because my focus is on insects or pathogens that threaten native trees, I wish to separate those from pests that attack primarily herbaceous plants. (Of course, herbaceous plants are important components of ecosystems, as well as premier agricultural and horticultural crops! I do not mean to imply that pest threats to herbaceous plants are not important.)

About nine million of the 300 million woody plants imported to the U.S. each year belong to genera which also contain species of trees native to North America. A larger number of plants – 224 million – were in the same family as a North American native tree (Epanchin-Niell 2017). In other words, about 75% of the woody plants imported each year were in the same family as at least one species of tree native to North America.

Since plants in the same genus are more likely to transport damaging pests that would attack North American trees and shrubs, some have suggested that all such imports should be prohibited temporarily, using the NAPPRA process.

  1. What Do We Know About Pest Arrivals? (Including Detection Difficulties)

Liebhold et al. 2012, relying on 2009 data, found that about 12 percent of incoming plant shipments had symptoms of pests – a rate more than 100 times greater than that for wood packaging — a pathway that has received far more international and U.S. regulatory attention for years. This finding is similar to that of a study in New Zealand, which found that 14 percent of consignments of plants were infested – primarily with pathogens (Epanchin-Niell 2017). Worse, though, Liebhold et al. found that a high percentage of pests associated with a plant shipment is not detected by the inspectors, although APHIS has disputed this finding.

 

At my request, APHIS analysts compiled a list of imported woody plant genera on which pests were detected during fiscal years 2011-2016. Of the 360 quarantine pests listed, only 34 were designated as “disease” (nine percent of the total). I suspect this is significantly below the actual number entering the country.

 

Table 1. Overall number of pest detections recorded*

Fiscal Year # of records # of countries of origin for shipments found to be infested
2011 133 16
2012 110 14
2013 42 12
2014 27 9
2015 45 12
2016 14 5

 

* My totals do not include shipments from Puerto Rico; there were six pest detections on plants from the Commonwealth.

I cannot explain why the total number of detections shown in Table 1 nor – especially – the number of countries from which these infested shipments arrived fell so dramatically in FY2016. If APHIS was focused on inspecting the highest-risk shipments in FY15 and FY16, shouldn’t the number of interceptions have risen?

 

Pathogens are probably undercounted in Table 2 because inspectors experience great difficulty in detecting pathogens during port-of-entry inspections. For example, the genus Phytophthora does not appear in the database of port interceptions, yet we know that Phytophthora are being introduced. Also, the database does not contain the genus Rhododendron. It seems unlikely that no quarantine pests were detected on a shipment of Rhododendron over that six-year period.

 

Table 2. Types of Pests Intercepted

Disease                        34

Insect                           290

Mite                             20

Mollusk                       23

Nematode                    2

 

 

APHIS’s interception records are not designed as a statistically valid sample for determining the total number of pests on shipments because, for example, inspection priorities and resultant inspection criteria  change over time. Since 2015 APHIS has focused more on higher-risk shipments. Before, a specified percentage of all imports was inspected. For these reasons, interception records cannot be used to evaluate the overall risk of pests being imported along with “plants for planting” in any given year. Nor can APHIS’ interception records be compared over time.

Obviously, the numbers of pests detected on a specific type of import will reflect several factors, especially the volume of imports and the intensity of inspection. This bias in the data is reflected in the high number of pest interceptions from Central American countries – from which the U.S. imports very large volumes of plants. Two hundred twenty of the 385 pest detections recorded over the six-year period (57 percent) were on plants shipped from Costa Rica or Guatemala. Canada ranked third, with 35 pest detections (nine percent of the total).

That said, each record reflects a detection of a taxon of animal or pathogen that APHIS considers to be a “plant pest”. Each time a particular species is detected in a shipment, it is recorded. If more than one species is detected in a shipment, each species is reported separately. Therefore,

  • the number of detection records does not equal the number of shipments found to be infested;
  • the records do not reveal the number of specimens of each named taxon – either in an individual shipment or in total; and
  • the number of times a taxon appears in the database does indicate how many shipments were found to be infested by that taxon.

 

 

  1. Principal Threats to North America’s Native Trees and Shrubs

APHIS and I agree that our focus should be on those pests likely to have significant consequences if they are introduced. This risk of impact depends on climate, presence of probable hosts in the U.S., and other factors. Among the highest risk sources of imports for most the U.S. will be temperate countries, like those below. APHIS assigns a lower rating of risk to pests that are likely to be established in the U.S. already or to establish naturally – e.g., pests native to northern Mexico near the U.S. border.

 

Table 3. Main Temperate Countries of Origin for Infested Shipments by Year

FY2011:  Germany, Japan, Turkey, Netherlands, France, Pakistan, Canada, New Zealand

FY2012:  Israel, Canada, South Korea, China, Chile, Netherlands

FY2013:  France, Canada, Belgium, China

FY2014:  China, Canada, South Africa, Portugal

FY2015:  China, Germany, Netherlands, Canada, France, Australia

FY2016:  Canada

 

 

We can also look at the host plants on which pests are being intercepted to think about threats. Table 4 shows these. Presumably, the volume of trade in these genera, from the countries concerned, is sufficient to preclude any listing of these hosts under the NAPPRA regulatory process (see blog from June 21).

 

Table 4. Host Genera on which Pests Were Intercepted, Including only Genera Native

to North America or U.S. Islands or Important in Ornamental Plantings

 Plant genus                 # records — countries of origin — types of pests

Acer                             7 — primarily Canada; also Netherlands & Korea – 2 disease, 4 insect, 1 mite

Buxus                           3 – all Canada – 2 insect, 1 mollusk

Camellia                      2 – France – 1 disease, 1 mite

Chamaecyparis                        1 – Canada; mite

Cycas revoluta             8 – Honduras, Costa Rica, Dom. Rep. – insects

Fagus                          6 – Netherlands, Belgium; insects (aphids primarily)

Hibiscus                       4 – France, Tahiti, Canada – 1 disease, 1 insect, 1 mite, 1 mollusk

Ilex                              3 – Canada & NL – 2 insects, 1 disease

Liriodendron               2 – Canada – insects

Magnolia grandifolia  1 – South Africa – insect

Opuntia                       6 – Mexico – insects

Picea                           7 – Canada – insects (primarily aphids)

Thuja                           6 – Canada – insects

Tilia                             2 – Canada – mollusk

 

  1. What Else Do We Know?

If we look at pests introduced via all pathways, unlike those above, U.S. pest-establishment data show that plant pests continue to be introduced, but at a slower pace in recent years. In its Implementation Plan for Section 10201 of the Food, Conservation and Energy Act of 2008, USDA APHIS said that between 2001 and summer 2008, 212 pests were reported as new to the United States – an average of 30 new pest introductions each year. An APHIS database of plant pests “newly detected” during fiscal years 2009 – 2013 listed approximately 90 new taxa of plant pests as detected during this period – approximately 22 each year. In its annual report for 2016, the agency reported detecting 16 species of plant pests not previously detected in the U.S.

I think that approximately 37 of the 90 “new” pests detected over the 2009-2013 period were probably introduced via imports of plants, cuttings, or cut foliage or flowers. These include all the viruses, fungi, aphids and scales, whiteflies, and mites. I have asked APHIS to give me a database of newly detected plant pests for fiscal years 2014-2015, but the agency has not done so.

Among tree-killing pests introduced over the past 160 years, approximately 69% were introduced via the live plant trade. Liebhold et al. 2012 found that 95% of sap feeders, 89% of foliage-feeding insects, and 47% of pathogens were introduced via this pathway.

Pathogens are probably undercounted here, too, since those that do not cause massive damage are probably overlooked. Of the approximately 90 pests newly detected  2009-2013, ten were fungi, four were viruses, and two were rusts (18 percent of the total).

The genus Phytophthora does not appear in the database of “newly detected” pests. Yet we know that Phytophthora are being introduced. We know that, in 2012 a Phytophthora new to the United States — Phytophthora tentaculata — was detected on nursery-raised herbaceous plants in California. Follow-up studies have detected several additional Phytophthora taxa that might be new to the United States. One, P. quercina, had previously been reported only in Europe and Western Asia. The other putatively new taxa are still being evaluated as to whether they are previously unknown species or hybrids, and whether they are native to California or elsewhere in the United States, or are of alien origin.

 

The presence of the EU1 strain of Phytophthora ramorum in several nurseries in Washington, California, and most recently Oregon is also evidence that introductions of this species have continued since it was designated as a regulated pest in 2003.

 

Another pathogen that has apparently not been included in the official data is the fungus which causes rapid ʻōhiʻa death – a strain of Ceratocystis fimbriata. Scientists do not yet know whether this strain was introduced directly to Hawai`i on a recently-imported, asymptomatic plant; or whether the strain evolved from one or more different strains introduced to Hawaiʻi recently or longer ago.

 

Can you help evaluate the level of risk associated with various plant taxa, types, and origins? and other matters that might be extracted from these data. Perhaps we can agree on which pest species cause greatest concern; decide which pathways most need new policy approaches; and reach conclusions based on holes in the data. Can we use the data on pest taxa that underlie this summary – data which I have – to strengthen the case for USDA to promptly finalize revision of its “plants for planting”  (“Q-37”) regulations (see my blog from June 21 and Chapter 4 of the Fading Forests report?

 

Contact me to explore how we might work together.

 

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.

 

SOURCES

 

Colunga-Garcia M, Haack RA, Magarey RD, Borchert DM (2013) Understanding trade pathways to target biosecurity surveillance. In: Kriticos DJ, Venette RC (Eds) Advancing risk assessment models to address climate change, economics and uncertainty. NeoBiota 18: 103–118. doi: 10.3897/neobiota.18.4019

 

Epanchin-Niel, R.S. 2017. Presentation to 28th USDA Interagency Research Forum on Invasive Species. January 2017.

 

Eschen, R., K. Britton, E. Brockerhoff, T. Burgess, V. Dalley, R.S. Epanchin-Niell, K. Gupta, G. Hardy, Y. Huang, M. Kenis, E. Kimani, H.-M. Li, S. Olsen, R. Ormrod, W. Otieno, C. Sadof, E. Tadeau, M. Theyse. 2015. International variation in phytosanitary legislation and regulations governing importation of plants for planting. Environmental Science and Policy 51 (2015) 228-237

Liebhold, A.M., E.G. Brockerhoff, L.J. Garrett, J.L. Parke, and K.O. Britton. 2012. Live Plant Imports: the Major Pathway for Forest Insect and Pathogen Invasions of the US. www.frontiersinecology.org

 

 

Surprise! USDA Through APHIS moves on NAPPRA regulations

 

USDA headquarters; F.T. Campbell

To my complete surprise, USDA APHIS has finalized a four-year-old proposal to temporarily prohibit importation of 56 taxa of plants: 22 that are likely to be invasive and 34 that are hosts of eight insects, pathogens, or other types of plant pests.

On June 19, APHIS published a notice in the Federal Register announcing that APHIS had finally acted on a proposal initially published on May 6, 2013. To view the datasheets APHIS prepared and the comments APHIS received, go here.

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

Section 319.37–2a authorizes APHIS to identify those plant taxa whose importation is not authorized pending pest risk analysis (NAPPRA) in order to prevent their introduction into the United States. As regards plant taxa that have been determined to be probable invasive species, such importation is restricted from all countries and regions. For taxa that have been determined to be hosts of a plant pest, the list includes (1) names of the taxa, (2) the foreign places from which the taxa’s importation is not authorized, and (3) the quarantine pests of concern.

The plant taxa now regulated because they host various types of plant pests are listed in two parts.

1) Species designated during the first round of action were proposed in 2011 and finalized in 2013 =

https://www.aphis.usda.gov/import_export/plants/plant_imports/Q37/nappra/downloads/HostsofQuarantinePests.pdf

2)  Species proposed in 2013 and finally designated on June 19, 2017 =

https://www.aphis.usda.gov/import_export/plants/plant_imports/Q37/nappra/downloads/hosts-quarantine-pests-round2.pdf

 

In summary, the second round of NAPPRA seeks to prevent introduction of the following specific pests by prohibiting imports of their associated plants from most countries. Imports from Canada are often excepted and those from the Netherlands less often.

  • Asian longhorned beetle (ALB, Anoplophora glabripennis) – Celtis, Cercidiphyllum (katsura), Koelreuteria, Tilia
  • Great spruce bark beetle (Dendroctonus micans) – Pseudotsuga
  • Japanese pine sawyer (Monochamus alternatus) – Cedrus
  • Phytophthora kernoviae 17 genera, including Camellia, Fagus, Hedera, Ilex, Leucothoe, Liriodendron, Magnolia, Pieris, Quercus, Rhododendron, Sequoia, Vaccinium
  • Boxwood blight (Puccinia buxi) – Buxus (boxwood)

 

There are other restrictions on plant imports related to pests, which predate the most recent NAPPRA listing. These include =

  • Acer is already listed on the previous NAPPRA list for all countries except Canada, Netherlands, and New Zealand.
  • Longstanding regulations prohibit the importation of Abies species from all countries except Canada. The genera Larix, Picea, and Pinus were added to the NAPPRA list in the April 2013 NAPPRA notice.
  • Camellia was also listed in 2013 from all countries, except Canada, to prevent introduction of the citrus longhorned beetle (CLB, Anoplophora chinensis); the genus is also regulated for Phytophthora ramorum. The most recent action now adds restrictions because Camellia is also a host of Phytopththora kernoviae. Plants from Canada are exempt because of longstanding “significant trade” volumes.
  • While plants in the genus Cercidiphyllum (katsura) may be imported from the Netherlands – despite the presence in the country of both ALB and CLB – a 2013 Federal Order (DA–2013–18) specifies mitigation actions which exporting countries must take to prevent transport of these insects via trade in this or other genera.
  • Hedera was added to the NAPPRA list via the first round of proposals in April 2013 as a host of CLB. Under the 2013 proposal, the genus is also listed as host of Phytophthora kernoviae.
  • Vaccinium are consistently exported only from Canada and Australia. The genus is listed because it is a host of Phytophthora kernoviae.

As APHIS notes in its explanation in the Federal Register, P. kernoviae has been reported in England, Ireland, and New Zealand; APHIS considers this to be evidence of spread of the pathogen through the global movement of plants. APHIS notes further that the pathogen has a large number of confirmed hosts and there is currently no effective control measure. APHIS does not note that the native range of P. kernoviae is unknown.

APHIS received considerable pushback on its proposal to restrict importation of Callistephus, Chrysanthemum, and Eustoma spp. to prevent introduction of several pathogens, including chrysanthemum stem necrosis virus (CSNV) and chrysanthemum white rust.  In response, APHIS has withdrawn these three genera from the new NAPPRA listing while it conducts a commodity import evaluation document (CIED) for Chrysanthemum.

 

I have not discussed here NAPPRA as it applies to invasive plants. In April I blogged about the need for APHIS to act. Plants listed because of their invasive potential are posted here =

1) 2013 listing: https://www.aphis.usda.gov/import_export/plants/plant_imports/Q37/nappra/downloads/QuarantinePestPlants.pdf

2) 2017 listing: https://www.aphis.usda.gov/import_export/plants/plant_imports/Q37/nappra/downloads/quarantine-pest-plants-round2.pdf

Again, I welcome USDA’s finalization of this second round of regulations and look forward to new proposals.

 

History of NAPPRA

In December 2004 APHIS published in the Federal Register an Advance Notice of Proposed Rulemaking, or ANPR which outlined a strategy for reducing pest introductions via the “plants for planting” pathway. The strategy had two major steps.

First, the agency would create a temporary holding category for plants suspected of transporting insects or diseases. This would allow APHIS to suspend imports of particular plants, from certain countries, until a full risk assessment was completed.

Second, APHIS would issue regulations establishing a general framework to minimize the presence of pests. Using this, the agency would negotiate country-specific requirements for imported plants, working toward an approach that would rely on “integrated measures” (also called “integrated pest management”).

APHIS formally proposed to create the temporary holding category – the NAPPRA program – in 2009. The regulations were finalized in May 2011 – six and one half years after the intention to take this action was announced in the ANPR. In adopting the NAPPRA rule, APHIS reiterated the need to encourage, but not require, the plant import trade either to rely on low-risk plant materials or to adopt pest-reduction methods.

In July 2011, APHIS published the initial list of species proposed for inclusion in the NAPPRA category.  This list was finalized in April 2013. A second list of species proposed for NAPPRA listing was published in May 2013.

This history – with citations – can be found in chapter 4, “Invasion Pathways”, in my report Fading Forests III, available here.

 

Meanwhile, here are a few related FAQs about NAPPRA as it is being implemented.

 

Why does APHIS regulate by genus?

APHIS regulates pests’ hosts at the genus level because when a new species is identified as a host, additional scientific studies often identify other host species within that genus. Therefore, regulating all species within the genus is the preferred course of action until a formal Pest Risk Analysis (PRA) is conducted. Uncertainties are worked out then.

 

How do these new rules fit into international standards?

APHIS notes in the Federal Register notice that  the “plants for planting” pathway is recognized as posing a high risk  for the introduction of pests. For this reason, the International Plant Protection Convention recommends that countries require a pest risk analysis before allowing importation of a plant taxon from a new country or region.

 

How long is importation of plants prohibited?

NAPPRA listing does not prohibit the importation of taxa indefinitely. Imports are held up until a pest risk analysis can be conducted to identify appropriate mitigation measures. Furthermore, an importer may apply for a controlled import permit to import small quantities of a prohibited or restricted taxon for developmental purposes.

 

What is the meaning of “significant trade”?

 

If a taxon that is a host of a quarantine pest has been imported in ‘‘significant’’ quantities from a specific exporting country, it is not eligible for the NAPPRA prohibition. Currently APHIS defines “significant trade” as the importation of 10 or more plants of a taxon in each of the previous three fiscal years. At the urging of one commenter, APHIS is considering whether to alter that definition by looking at import volumes over three out of five years – although the agency said if it took that action, it would most likely also consider raising the base number of plants from 10 to a higher level.

 

In the case of “significant trade” in a taxon that is a host of a quarantine pest, APHIS specifies other measures to address the pest risk.

 

What other protections does APHIS use?


A “Federal order” is used to rapidly take action to prevent the introduction of a quarantine pest, and is generally followed by notice and an opportunity for public comment. This is a separate action from the NAPPRA process.

 

OTHER PENDING USDA RULES

 

The Overhaul of Regulations for “Plants for Planting (P4P) (the “Quarantine-37” or “Q-37” regulations) – Will It Also Be Finalized?

 

Another important APHIS action aimed at improving control over introductions of pests on imported plants has also been unresolved for four years. This is the revision to the agency’s overall plant import regulations, which was also proposed in May 2013. The revision would restructure the current regulations by moving specific restrictions on the importation of taxa from regulations to the Plants for Planting Manual. That transfer would allow specific restrictions to be changed without going through the full public notice and comment process required for amending formal federal regulations. The proposed revision would also add a framework for requiring foreign plant suppliers to implement integrated pest management measures to reduce pest risk. Experts believe that depending on integrated measures will better prevent pest introductions than the current reliance on a visual inspection at the time plants are shipped.

 

Again, for a history of and rationale for the proposed regulatory change, read chapter 4, “Invasion Pathways”, in my report Fading Forests III, 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.