wood packaging – Page 5 – Center for Invasive Species Prevention

Sudden Oak Death – two informative articles

I am alerting you to two publications about our “favorite” tree-killing pathogen, Phytopthora ramorum (sudden oak death).

SOD-infected rhododendron in a nursery in Indiana; photo by Indiana Department of Natural Resources

The Role of Nurseries in Spreading SOD

The first article informs the general public and raises important questions: “The Diseased Rhododendrons That Triggered a Federal Plant Hunt” by Ellie Shechet in The New Republic.

Ellie reviews the 2019 episode in which P. ramorum-infected rhododendron plants were shipped to retailers in the East and Midwest. Her article is based on interviews with state plant health and APHIS officials, several scientists and advocates (including me), and the executive director of the Oregon Association of Nurseries (OAN). Ellie notes that infected plants were found at more than 100 locations across 16 states.

Ellie notes that despite the risk to native plants in the eastern deciduous forest and the financial cost of implementing control actions (14 million plants were inspected in Washington State alone), plants have a “green” reputation; they are not recognized as potentially causing environmental harm.

The politics of the situation also are reviewed. She writes that the OAN representative has testified that he helped write the more relaxed regulatory approach that APHIS adopted by “federal order” in 2014 and formalized in changes to the regulations in 2019. APHIS denies this. [The article does not include the information that during this period, state regulatory officials detected P. ramorum-infected plants in between four and ten Oregon nurseries each year.] Ellie notes that individual consumers buying plants have few tools to try to ensure that plants they buy are not infected by SOD or other pathogens.

The fact is that the climate in the coastal areas of California, Oregon, Washington, and British Columbia is conducive to SOD, so the risk of diseased plants being produced there and sold is constant. The current APHIS regulations do not adequately address this, in my view!

Science: High Risk of Phytophthora Introductions from Southeast Asia

The second article reports results of intense scientific effort: Thomas Jung, Joan Webber, Clive Brasier, and other European plant pathologists report more completely on searches for P. ramorum and other Phytophthora species in East Asia. See the full citation at the end of this blog. [I blogged about their preliminary report a little over a year ago.] Jung et al. conclude that P. ramorum probably originates from the laurosilva forests growing in an arc from eastern Myanmar, across northern Laos, Vietnam, and southwestern China (Yunnan) to Shikoku & Kyushu islands in southwest Japan. The article notes that two other Phytophtoras – P. lateralis (cause of fatal disease on Port-Orford cedar) and P. foliorum – appear to be from the same area. Field science by this team has found 38 previously unknown Phytophthora species in these same forests – and expect that more are present.

Clive Brasier in Vietnam; UK Forestry Research

They warn that the lack of information about potential pathogens in many developing countries presents a high risk of introduction to naïve environments through burgeoning horticultural trade – especially since the World Trade Organization requires that a species be named and identified as posing a specific threat before phytosanitary regulations can be applied. [I addressed the issue of international phytosanitary rules in Fading Forests II; see the link at the end of the blog.]

Other Pathogen Risks from the Region

Phytophthoras transported on imported plants are not the only pathogens that could come from Asia. The vectors and associated pathogens causing laurel wilt disease across the Southeast and Fusarium disease in California are believed also to originate in the same region of Asia. Unlike the Phytophthoras, which are transported primarily through the trade in plants for planting, these fungi travel with the vector beetles in wood packaging material. U.S. imports of goods from Asia – often packaged in wooden crates or pallets – have skyrocketed since July 2020. The ports of Los Angeles-Long Beach, which receive 50% of U.S. imports from Asia, handled 6.3 million TEU (twenty-foot equivalent containers) from Asia during the period July 2020 through February 2021. The average of close to 800,000 TEU per month for eight consecutive months is unprecedented. Other ports also saw increased import volumes from Asia during this period. [I discussed these shifts in my blog in January.] Imports from Asia in 2020 accounted for 67.4% of total US imports from the world. Imports from China specifically accounted for 42.1% of total US imports. [Data on import volumes is from several reports posted by the Journal of Commerce at its website: https://www.joc.com/maritime-news/]

SOURCE

Jung, T.; Horta Jung, M.; Webber, J.F.; Kageyama, K.; Hieno, A.; Masuya, H.; Uematsu, S.; Pérez-Sierra, A.; Harris, A.R.; Forster, J.; et al.. The Destructive Tree Pathogen Phytophthora ramorum Originates from the Laurosilva Forests of East Asia. J. Fungi 2021, 7, 226. https://doi.org/10.3390/ open access!

Posted by Faith Campbell

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

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

Asian longhorned beetle – Eradication in South Carolina will be Extremely Difficult

arrows indicate red maples in the swamps of ALB regulated site in South Carolina
photo by David Coyle

The Asian longhorned beetle (ALB) is one of the most threatening of the hundreds of non-native insects and pathogens introduced to American forests since European colonization began 400 years ago. The ALB attacks about 100 species of trees in 12 or 13 genera; it prefers maples, poplars, willows, and elms. Forests with substantial components of susceptible species constitute 10% of forests on the U.S. mainland and nearly all of Canada’s hardwoods. Host trees species also make up a significant proportion of trees in urban areas. A two-decade old estimate is that ALB could cause more than $1.2 billion in damage to urban trees [Coyle et al. 2021; full citation at the end of the blog]. The contemporary estimate would be higher.

The ALB began showing up in imports and in warehouses less than a dozen years after the U.S. opened trade with China [see Chapter 3 of Fading Forests II; url provided at the end of this blog]. Now there is a new infestation in South Carolina that threatens to be the most difficult to eradicate. Given the level of resources and extended commitment this will demand from APHIS and South Carolina, I worry that the agencies and Congress will give up. To find more money, will the agency take funds from other pests that also need to be addressed? Will it seek – and receive – emergency funding? Congress is currently considering funding for APHIS for the fiscal year that begins in October. Let’s inform them of the need to ensure adequate resources to carry forward necessary eradication efforts.

ALB in the U.S.: 25 Years of Repeated Infestations and Eradications

The first established ALB population to be detected was that in Brooklyn, New York, in 1996. Since then, seven more outbreaks have been detected in the United States [Poland et al. 2021; South Carolina press release] plus two in Canada. Several populations have been eradicated: a single population in Illinois, several populations in New Jersey, three populations in New York; a small outlying population in Ohio (APHIS newsletter Feb 2021); and two Canadian outbreaks.

Despite the U.S. and Canada having adopted regulations requiring treatment of wood packaging from China effective January 1999, ALB larvae continue to be detected in wood packaging from that country. Between 2012 and 2017, the ALB was intercepted six times in wood packaging made of Populus wood – each time originating from a single wood-treatment facility in China (Krishnankutty et al. 2020 – full citation at the end of the blog).

Port of Charleston; photo by Walter Lagrenne, South Carolina Port Authority

ALB Near Charleston, S.C.: Recently Detected; Must be Eradicated

The most recent detection is near Charleston, South Carolina. As usual, a beetle was found by a member of the public. Dendrological studies indicate that this infestation was seven years old at the time of its detection in May 2020, meaning it began about 2013 (Coyle et al. 2021). As the authors note, it has proved impossible to determine whether the South Carolina outbreak resulted from transport of infested wood from the Ohio outbreak or from China directly. Lots of visitors travel from the Midwest to South Carolina every winter. The center of the primary area of infestation includes a railway and an RV park which might be utilized by such travelers. On the other hand, two ports that receive high volumes of incoming shipping containers including wood packaging are nearby — Charleston, SC and Savannah, GA (Coyle et al. 2021). Charleston imported almost 666,000 containers (measured as 20-foot equivalents, or TEUs) in 2013.

Even under the best circumstances, eradicating an ALB infestation is difficult. Eradicating the Chicago outbreak took ten years [Poland et al. 2021]; eradicating the Brooklyn infestation took 23 years [APHIS ALB newsletter]. Massachusetts might be on the verge of eradicating the Worcester outbreak twelve years after it was detected because only one infested tree was found in 2020 [Felicia Hubacz at Northeast Forest Pest Council meeting, March 2021]

Eradication entails removing large numbers of trees – more than 171,000 in the Northeast and Midwest; and pesticide treatment of at least 800,000 [Poland et al. 2021]. Tens of thousands of trees must be inspected – especially in areas with significant woodland areas like the South Carolina site. In Clermont County, Ohio, 3,500,000 trees have been surveyed in the regulated area – which is 56 square miles [APHIS newsletter]

In South Carolina, APHIS and the state are already regulating 72.6 mi² — and that is before the full extent of the infestation has been delimited. This regulated area is larger than the Ohio and New York regulated areas, although smaller than that in Massachusetts (110 mi² Coyle et al.). As of February 2021, 4,425 infested trees have been identified (APHIS newsletter]. Ninety-eight percent are red maples; half of the others are willows (Coyle et al.) In May 2021, APHIS expanded the quarantine zone to 76.4 square miles (APHIS press release May 21, 2021).

So APHIS and South Carolina face a great deal of hard work. But acreage and numbers of trees affected don’t convey the real extent of the challenge.

The first challenge is anticipating the timing of events in the ALB life cycle. Scientists understand a great deal about the ALB life cycle. However, that knowledge all applies to areas with temperate climates such as the U.S. northeast, southern Canada, and Europe. South Carolina has a subtropical climate. How will the warmer climate affect the beetle’s speed of development, timing of emergence, etc. Already, dendrologial studies indicate that the ALB in South Carolina might complete development from egg to mature adult much faster – in less than a year rather than one to four years (Coyle et al.)

working conditions in the South Carolina swamps;
photo by David Coyle

An even bigger challenge will be trying to carry out searches for infested trees and standard responses. Removing infested trees and removing or applying pesticides to at-risk host trees is standard practice. Much of the regulated area has standing water and/or saturated soil. These conditions – plus the presence of venomous snakes and alligators – make visual surveys from the ground or by tree climbers difficult. Use of lifts and bucket trucks will be impossible. When infested trees are found, felling trees in swampy conditions presents a heighted risk for felling crews. And it will be impossible to operate the equipment needed to remove or chip infested trees (Coyle et al.). I believe it is impossible to use soil injection to treat at-risk trees under such conditions.

SOURCES

Coyle, D.R., R.T. Trotter, M.S. Bean, and S.E. Pfister. 2021. First Recorded Asian Longhorned Beetle (Coleoptera: Cerambycidae) Infestation in the Southern United States. Journal of Integrated Pest Management, (2021) 12(1): 10; 1–6

Krishnankutty, S., H. Nadel, A.M. Taylor, M.C. Wiemann, Y. Wu, S.W. Lingafelter, S.W. Myers, and A.M. Ray. 2020b. Identification of Tree Genera Used in the Construction of Solid Wood-Packaging Materials That Arrived at U.S. Ports Infested With Live Wood-Boring Insects. Commodity Treatment and Quarantine Entomology

Poland, T.M., T. Patel-Weynand, D.M. Finch, C.F. Miniat, D.C. Hayes, V.M. Lopez. 2021. Invasive Species in Forests and Rangelands of the United States. Springer.

USDA APHIS Asian longhorned beetle monthly newsletter for March 2021. Sign up here https://www.aphis.usda.gov/aphis/resources/pests-diseases/asian-longhorned-beetle/ALB-eNewsletter

Posted by Faith Campbell

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

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

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

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

CPB’s 2017 Improvement

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

CPB’s 2020 Improvement

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

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

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

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

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

Specific Minimum Security Criteria

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

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

The actual Minimum Security Criteria can be found here.

Training Powerpoints are here.

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

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

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

SOURCES:

CBP website

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

Posted by Faith Campbell

Rising Pest Danger to New Regions Parallels Rise in Imports

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

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

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

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

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

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

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

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

Government Agencies’ Involvement

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

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

SOURCES

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

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

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

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

Posted by Faith Campbell

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

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

So now is the time to suggest needed changes!

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

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

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

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

Actions Congress could take

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

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

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

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

Nursery Plant (“Plants for Planting”) Pathway

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

Other Actions

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

Posted by Faith Campbell

Imports Surge – Will Pests be Far Behind?

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

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

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

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

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

Pacific Coast Ports

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

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

Ports in the Southeast

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

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

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

Vessels Carry More Containers

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

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

Imports from Geographic Regions Other Than Asia

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

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

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

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

SOURCES

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

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

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

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

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

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

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

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

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

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

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

Posted by Faith Campbell

Pests Associated with Imports: Rising Risk for Gulf States

Port of Mobile, Alabama Photo by Port of Mobile Authority

In August and September I blogged about the rapid increase in volumes of imports from Asia, especially China, in 2020. At the time, the information available to me focused on the Pacific coast ports, especially Long Beach and Los Angeles.

In the earlier blogs, I mentioned three concerns:

1. Had the collapse in trade and travel during spring 2020 so reduced user fees that Department of Homeland Security Bureau of Customs and Border Protection (CBP) had to furlough Agriculture Quarantine Inspectors? AQI inspections provide important incentives for importers to follow U.S. and international rules to reduce the risk that pests will be present in imports, for example, in wood packaging.

2. The list of imports from China in the first half of 2020 includes $1 billion worth of nursery stock. This is down about 7% from 2019. However, from the perspective of preventing plant diseases and pests, these imports continue to be high risk and are still not adequately addressed by U.S. policy.

3. Other Asian regions are gaining in import share. Thus we can expect to see more pests arriving from countries other than China, like Vietnam.

Cutbacks in Numbers of Inspectors?

CBP staff have told me that they are shifting AQI inspectors from covering incoming passengers – which are still far fewer than before the Pandemic – to inspecting cargo. By doing so, CBP has avoided cutting back on the total number of inspections of imported goods and associated wood packaging.

This is fortunate since Congress has not passed a new Covid-19 financing bill that might have included an increase in the appropriation for DHS CBP. The Continuing Resolution currently in effect funds the government only until December 11. So we have another chance to ask for an increase in appropriated funds for CBP (and APHIS!) for the remainder of Fiscal Year 2021 (which ends on October 1, 2021).

Volumes of Imports from Asia – Especially China

As I reported in the earlier blog, while U.S. imports from China declined significantly in 2019 and early 2020 compared to earlier years, by the summer imports had rebounded — more than doubled (by value) between March and July.

Shifts in U.S. Ports

According to the Journal of Commerce, there is a gradual shift away from the twin ports of Los Angeles and Long Beach in the proportion of imported goods entering the country. LA-LB handled 37.7% of the loaded twenty-foot equivalent containers (TEUs) entering the United States in 2018. This fell to 33.5% in July 2020. The initial reason was a decrease in imports from East Asia (including China, Hong Kong, Japan, South Korea, and Taiwan) compared to Southeast Asia, Europe, then South America and, finally, South Asia (primarily India).

Other source regions – e.g., the Caribbean, Middle East, Pacific, Africa, and Atlantic – were all below 2% of total numbers of TEU in all three years, and changed minimally over this period.

Another reason for the shift in ports utilized by importers is congestion and delays at North American Pacific coast ports, especially Los Angeles-Long Beach. U.S. imports from Asia moving through LA-LB increased 22% in both September and August from the same months last year – 828,880 TEU in September after 832,210 TEU in August.

Congestion is also a problem at the Canadian ports of Vancouver and Prince Rupert – which have actually seen small decreases in numbers of incoming containers.

One result is a small but significant shift to Gulf Coast ports, which have become more accessible through the widening of the Panama Canal in 2016. Before the Canal was widened, these ports handled less than 3% of total US imports from Asia. In the first nine months of 2020, US Gulf ports handled 608,387 TEU from Asia – or 5.2% of total US imports from Asia. This was a 5% increase from the same period last year.

These ports, stretching from Houston to Tampa, benefit from easy and relatively cheap rail transport to inland U.S. and even Canadian cities. Another factor is the heavy presence of Walmart – which has major distribution centers in Mobile and Houston.

The Gulf coast ports are expected to expand their importance as gateways for Asian imports as ocean carriers add more capacity between the two regions and ports upgrade and expand. New Orleans and Houston plan major expansions. Port Tampa Bay notes its proximity to markets around the Southeast. Already, import volumes into Tampa during the first nine months of 2020 were nearly double the prior year’s level. Tampa hopes to double its capacity over the next five years.

U.S. imports from Asia in October were 22.6% higher than a year ago. Imports through the East and Gulf coast ports jumped 14.6% and 48.4% from September 2020. Houston and Baltimore saw the greatest increases since September. There were also shifts in Pacific ports. Still, the Los Angeles-Long Beach port complex handled 49% of total US imports from Asia in October 2020.

Pest Risks to the Gulf Coast from Southeast Asia

Rising volumes of imports into the Gulf Coast present new opportunities for non-native insects and pathogens. The warm, wet climate of the region might be far more suitable to some insects and pathogens from tropical and subtropical Asia than the dry climate of southern California (except for areas that are irrigated artificially, such as golf courses, parks, and plant nurseries!).

redbay grove killed by laurel wilt; Photo by Scott Cameron

Already, the redbay ambrosia beetle and its associated pathogenic fungus has decimated native redbay and swamp bay trees and now threatens sassafras (see write-up under the “invasive species” tab here.)

Another Southeast Asian ambrosia beetle – the polyphagous shot hole borer with its associated pathogenic fungus – might also find the Gulf Coast states more inviting than southern California. In California, it is causing the greatest damage to trees that are artificially irrigated. Numerous tree species native to or grown in the Gulf states are known hosts, e.g., box elder, sweetgum, and southern magnolia. (PSHB is described under the “invasive species” tab here.) Both ambrosia beetles apparently were introduced via wood packaging material.

Southeast Asia is also the place of origin of other pathogens which – in this case – would more probably be introduced on imported plants rather than wood. These include the numerous species of Phytophthora recently detected in Vietnam.

As this region receives more goods from Asia, and as those goods arrive more rapidly so more likely to arrive alive, it is imperative that all stakeholders increase their vigilance to detect new invaders. And that they join others pressing for improved policies aimed at preventing introductions.

Posted by Faith Campbell

Trade, Pests, Inspections … & China

Recent information raises several troubling/worrisome issues:

1. The overall collapse in trade and travel has severely cut into the collection of user fees. These fees pay for Agriculture Quarantine Inspectors, putting jobs at risk. Their inspections provide important incentives for importers to follow U.S. and international rules to limit pests.

2. The list of imports from China in 2020 includes $1 billion worth of nursery stock. This is down about 7% from 2019. However, from the perspective of preventing plant diseases and pests, these imports continue to be high risk and still not adequately addressed by U.S. policy.

3. Other Asian regions are gaining in import share. Thus we can expect to see more pests arriving from countries other than China, like Vietnam.

Loss of User Fees Could Mean Loss of Inspectors

The collapse of trade and travel has a more troubling result: severe reductions in user fees collected from travelers and importers to fund DHS/Customs and Border Protection Agriculture Quarantine Inspectors. In a recent opinion piece, several former administrators of APHIS warn that current user fee collections are insufficient to sustain inspectors’ employment. A reserve fund will also be depleted this month. APHIS estimates that it will require an appropriation of $630 million to fund these agricultural inspections through the next fiscal year (October 2020 – September 2021).

Agricultural inspectors focus on plant and animal imports – including horticultural stock, seeds, fruits, and vegetables – both in commercial shipments and in passengers’ baggage. They are also called in when CBP inspectors suspect pests are present in wood packaging.

I do not consider inspection to be the most effective strategy to prevent introductions. That is, I think inspections are less effective than regulations requiring treatments and pre-shipment pest-mitigation measures. However, losing inspectors – even temporarily – will undermine detection and enforcement as an incentive for importers to comply with U.S. and international rules. This funding crisis is therefore a serious concern. Please ask your senators and member of Congress to support increasing the appropriation for DHS CBP by $650 million to keep these inspectors on the job.

Imports from Asia Skyrocket

New data show that containerized US import volumes from Asia rocketed 91% between March and August. During the same five-month period a year ago, import volumes rose only 36% — so the 2020 increase is more than double the earlier pace. Numbers of incoming containers from Asia nearly doubled at the ports New York/New Jersey; Los Angeles/Long Beach, California; and Savannah, Georgia. The California ports are reported to be working nearly at capacity. This has resulted in higher handling costs and delays in trucking imports out of the port to their destinations.

Import volumes from Vietnam and India continue outpace the market generally.

Update: Imports from China Continue to Decline Relative to Other Source Regions

In August I posted a blog reporting a significant reduction in imports from China recently – first as a result of new tariffs in 2019, and second, as a result of the global economic crash associated with the Covid-19 virus.

Imports from China decreased by 16% in 2019 compared to 2018, then rose slightly in the first months of 2020. My focus then – and now – is on declining imports of heavy goods — the types of imports most likely to be packaged in wooden crates or on wooden pallets that can transport pests.

Import volumes from China rose later in the year, as the U.S. economy began to rebound. Official data from the U.S. Bureau of the Census shows US imports from China had more than doubled (by value) since March — from $19.8 billion in March to $40.7 billion in July. Still, imports of heavy items and most consumer items – other than computers – have decreased in 2020 compared to 2019.

Included in this list of imports is $1 billion worth of nursery stock – down about 7% from 2019. Nursery stock imports are rarely included in Census reports, so I value this information. Of course, these imports – even ‘though declining – still represent a series plant pest risks. One study showed that imported plants carry a pest risk 12 times higher than wood packaging material (Liebhold et al. 2012; see full reference at end of blog).

rhododendron infected by sudden oak death – photo courtesy of Jennifer Parke

Important Shifts in Sources of U.S. Imports

Data show a broad and years-long decline in the share of U.S. imports that come from China. This decline is best seen in declining volumes of imports arriving at the ports of Los Angeles, Long Beach, Northwest Sea Alliance and another port in the region. Imports arriving at these ports declined 5.3% in May 2019 compared to May 2018. At that time, this decline was blamed on importers having stocked up in advance of threatened US tariffs on goods from China. Bureau of the Census data show a 2% reduction in loaded twenty-foot-long containers (TEUs) entering Long Beach in calendar year to date 2019 compared to calendar year to date 2020 (through August).

Commercial data sources indicate even larger declines. According to the Journal of Commerce, the twin ports of Los Angeles and Long Beach handled 37.7% of the loaded TEUs entering the United States in 2018. This fell to 33.5% in July 2020 — a drop of 4.2 percentage points in just 18 months. The author of this article said the reason was a fall in imports from East Asia (including China, Hong Kong, Japan, South Korea, and Taiwan) compared to Southeast Asia, Europe, then South America and, finally, South Asia (primarily India). The article provides a table quantifying shifting sources of U.S. imports:

Total US Market Share Imports by Source Region

SOURCE 2018 2019 2020YTD 2018-2020 change

East Asia 61.6% 58% 54.5% -7.1%

Europe 14.9% 15.8% 16.9% +1.9%

Southeast Asia 8.3% 10.5% 11.9% +3.6%

South America 8.2% 10.5% 11.9% +3.6%

South Asia 2.7% 3.1% 3.1% +0.5%

Other source regions – e.g., the Caribbean, Middle East, Pacific, Africa, and Atlantic – were all below 2% of total numbers of TEU in all three years, and changed not at all or minimally over this period.

As I noted in the earlier blog, the pest risk persists. First, imports from China continue, and the most recent data (for the period 2011-2016) indicate significant numbers of shipments continue to be in violation of requirements for wood packaging (APHIS database / pers. comm). Remember, USDA passed up an opportunity to raise the issue of non-compliant wood packaging with Chinese phytosanitary officials.

Plus other regions also are the source of pests. I wrote about the risk from Mexico in the previous blog. The region of Southeast Asia has already been the source of highly damaging pests, e.g., redbay ambrosia beetle and polyphagous shot hole borer.

distribution of laurel wilt, carried by redbay ambrosia beetle

Scientists have also detected numerous known and previously unknown species of the brown alga genus Phytophthora in Vietnam and Taiwan. Of course, this is the genus that includes the pathogens that cause sudden oak death, black ink disease, potato blight, and numerous other plant diseases. APHIS has not accepted my urging to undertake rapid assessments of the vulnerability of North American trees to these newly discovered microbes.

SOURCE

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

Posted by Faith Campbell

Reminder: comment on ALB EA

Reminder: Friday is the deadline for commenting on APHIS’ draft environmental assessment for the Asian longhorned beetle eradication program in South Carolina. Comments should be submitted at https://beta.regulations.gov/commenton/APHIS-2020-0086-0001

The draft EA can be downloaded from https://www.aphis.usda.gov/aphis/newsroom/federal-register-posts/sa_by_date/sa-2020/alb-draft-ea

The Center for Invasive Species Prevention submitted comments that supported the eradication effort because of the well-documented threat that the ALB poses to the forests of North America. We also supported the preferred alternative in the EA.

However, we found the environmental assessment (EA) to be deficient in several ways:

the EA does not identify the host species present in the program area – not even of the 5,800 trees inspected by the program as of mid-August.
the EA provides no estimate of the proportion of deciduous trees and shrubs in the area that are host species. Conifers dominate the area. This means that any fauna dependent on deciduous trees and shrubs for food and shelter already contend with limited resources. Consequently, while we concur with the EA that any impacts will be localized, they might be exacerbated by the relative rarity of hardwood species in the local area. It is particularly important that the EA address this question since the Programmatic EIS was written under the assumption that forests at risk to the ALB are like those in the Northeast and Midwest, where hardwoods dominate.

Without knowing the proportion of deciduous flora comprised of host species, no one can evaluate the amount of wildlife food that could be removed or treated by pesticides. Some wildlife species are potentially vulnerable, including those that feed on pollen and nectar (i.e., bees and other pollinators) and those that feed on insects and other invertebrates. The latter include two species listed federally as threatened species: the frosted flatwood salamander (Ambystoma cingulatum) and northern long-eared bat (Myotis septentrionalis). Also vulnerable are birds, 96% of which feed their young on insects and other invertebrates. I worry about sublethal effects and possible bioaccumulation. Aquatic organisms, especially invertebrates, might also be affected.

The information gaps in the EA highlight weaknesses in the Programmatic EIS, on which it relies. The most important gap is the dearth of pesticide dose/mortality data for terrestrial amphibians. Apparently, EPA has not required such studies before approving pesticides.

Posted by Faith Campbell

APHIS Drops the Ball on China’s Wood Packaging

APHIS has apparently passed up an opportunity to pressure China to clean up its wood packaging – although China ranks among the countries that most often violates ISPM#15 and sends wood packaging infested by quarantine pests. (See the blogs under the category “wood packaging” on this site.)

In May, a large delegation of APHIS employees met (virtually) with an equally large delegation of its Chinese counterpart to negotiate “technical protocols” linked to the Phase 1 trade agreement with China. The focus of the negotiations was on Chinese phytosanitary barriers that block exports of US products to China.

The two countries have now signed technical protocols to allow the United States to export to China a wide range of commodities estimated to be worth between $700 million and $760 million annually when the agreement is fully implemented. These commodities include barley for processing, hay, some fruits (blueberries, avocados, nectarines), almond meal, and chipping potatoes.

Some of the agreements cap years of effort. The example cited is chipping potatoes. Negotiations continue on some other U.S. exports to China, including logs.

An article in APHIS’ online newsletter reports that “On the import side, we are working on the requirements for China’s requested commodities….” Presumably these would be exports to the U.S. The examples listed were all fruits.

I inquired whether wood packaging was part of the negotiation.

Andrea B. Simao, Assistant Deputy Administrator and Director of PPQ’s Phytosanitary Issues Management unit, replied that SWPM was not raised “since there has [sic] not been significant issues.”
Instead, she detailed efforts in the ongoing negotiations to persuade China that U.S. phytosanitary treatments are sufficient to control various pathogens in logs: oak wilt, phosphine on conifers, pinewood nematode.

Apparently the focus was fully on US exports and nobody raised US concerns about the risks of imports from China. This approach fits the Administration’s emphasis on exporting agricultural commodities to China. However, this is not reality. Over the past five years, I have frequently cited USDA’s own data – which demonstrate the likelihood that wood packaging will transport tree-killing pests from China to the U.S.

APHIS PPQ Deputy Administrator Osama El-Lissy & Chinese counterpart Li Jainwei sign agreement (APHIS photo)

Please inform your Member of Congress and Senators (or candidates for House or Senate) about how you feel about this failure of USDA to protect America’s natural resources. We must raise the political heat in order to pressure USDA into placing as high a priority on protecting US natural resources as it does on supporting agricultural exports.

Posted by Faith Campbell