forest pest insects – Page 14 – Center for Invasive Species Prevention

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

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

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

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

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

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

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

How Does APHIS Propose to Curtail EAB Spread?

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

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

Environmental and Economic Impacts: Not Adequately Assessed

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

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

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

Biological Control: Effective – or Not

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

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

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

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

Firewood: Outreach Only, No National Regulation

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

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

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

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

Imported Wood Will be Minimally Regulated

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

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

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

Lessons Learned

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

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

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

Posted by Faith Campbell

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

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

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

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

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

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

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

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

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

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

Weaknesses of the Risk Assessment Process

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

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

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

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

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

Questions re: some of specific pests in the analysis

3.2.1. Cerambycidae (Coleoptera)

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

trees removed for CLB eradication in Tukwila, Washington

3.2.2. Archips xylosteana (Lepidoptera: Tortricidae)

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

3.2.3. Meloinema kerongens

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

3.2.5. Helicobasidium mompa

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

Other Potential Pests

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

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

Posted by Faith Campbell

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

Ash Mortality Accelerates – Population Regeneration Will Not Reverse Collapse

dead ash along Accotink Creek, Fairfax County, Virginia photo by F.T. Campbell

As we all know, the emerald ash borer (EAB) has killed millions of ash trees in its invaded range across eastern North America. However, field studies have detected robust regeneration of ash seedlings and saplings in various invaded areas. Ward et al. 2021 (full citation at end of blog) set out to determine whether this regeneration will result in recovery of mature ashes that can perform their ecological role. They conclude that it will not. Instead, they say, the EAB invasion will probably alter successional patterns and composition of large areas of naturally regenerating forests, causing a cascade of ecological impacts in ash-containing ecosystems

Ward and colleagues used USDA Forest Service Forest Inventory and Analysis (FIA data) to quantify ash recruitment and regeneration across the entire eastern United States. Theirs is the first study to evaluate trends across the region, rather than specific locations or stands. They related the FIA recruitment data to EAB spread, as measured by USDA Animal and Plant Health Inspection Service’ (APHIS) record of the first EAB detection in each county.

FIA inventories in 2002-2007 and 2013-2018 show large numbers of ash seedlings and saplings in counties invaded in the first wave of invasion, 2002–2006. These areas had higher densities of both seedlings and saplings than plots in other counties. The earliest-invaded counties were in areas that had extraordinarily high densities of ash before the EAB invasion, so the numbers of seedlings and saplings probably reflected that abundant seed source.

However, by the 2013-2018 inventory ash trees in the smallest overstory class (12.7 cm dbh) were dying at faster rates than they were recruited from seedlings or saplings in all 362 counties recorded by APHIS as EAB-infested before 2013. Ward and colleagues found these negative population trajectories on plots that have been invaded for more than about 10 years. This trend suggests that ash will continue to decline in abundance and may become functionally extinct across the invaded range.

Some U.S. Forest Service biologists are more optimistic about ash recovery in response to biocontrol of the EAB. See their podcast here.

In the risk of functional extinction, ash trees are unfortunately not unique. The authors note similar impacts from the invasion of the hemlock woolly adelgid and beech bark disease.

Data Reveal History of Invasion (spread)

Ward and colleagues focused on the risk of mortality for young ashes as they developed from seedlings to saplings, and, eventually, to overstory trees. The youngest “overstory” trees are 12.7 to 17 cm dbh. FIA data show that even the largest trees in this class are 3 cm smaller than trees that produce seeds.

Mortality was initially uniformly low – less than 2.1% — as measured by the first FIA inventory (2002–2007). This is not surprising because EAB was detected only in 2002, and then in only few counties. (EAB had probably been present for a decade before it was detected.)

By the 2013-2018 FIA inventory, mortality had quadrupled to 8–11% in counties invaded during the 2002–2006 period. In the counties invaded during the 2007–2012 period, morality also rose to 3-5%. Both measurements included all diameter classes. Annual mortality rates in the FIA 2013-2018 inventory were still highest for the counties invaded during 2002–2006 except for the largest trees (those greater than 40 cm dbh). By the time of the 2013-2018 FIA survey, overstory ash densities near the epicenter had since declined substantially. They had been nearly eliminated in some counties in southeastern Michigan. There were still sufficient numbers of smaller trees in the region to exhibit an elevated mortality rate – more than 10% per year in several counties in Michigan, Indian, and Ohio. By contrast, in the most recently invaded areas – those counties recorded by APHIS as infested after 2013 – there was very little change in ash densities compared to the 2002-2007 period. This is hardly surprising since it takes years for mortality to reach levels observable by the FIA process.

dead ash on edge of Pohick Bay, Fairfax County, Virginia photo by F.T. Campbell

Considering trees just entering the overstory category (those with diameters of 12.7 cm dbh), annual mortality increased substantially across the region. Between the first FIA inventory (conducted in 2002-2007) and the second inventory (conducted in 2013-2018), their average annual mortality rose more than four-fold, from 0.08 trees per ha to 0.37 trees per ha. By 2013-2018, recruitment in the 2002–2006 invasion cohort was about 50% less than tree mortality levels; recruitment and mortality were about equivalent for the counties invaded in the 2007–2012 period. Recruitment was [still] significantly higher than mortality for the counties recorded as invaded in 2013–2018. However, Ward and colleagues expect mortality rates of this cohort to accelerate over the next five to 10 years – even in areas with lower ash densities.

Ward and colleagues note that many of the young ash trees were dying before they could reach reproductive age – which they estimated to be about 20 years with a dbh of about 20 cm.

As the invasion progresses and hosts are depleted, mortality rates could slow, but, for ash to persist, it is critical that sufficient numbers of trees reach reproductive age before succumbing to residual EAB populations.

Other factors that might influence ash include competition with trees in other genera. The biocontrol agents now becoming established in young ash forests might increase the likelihood of ash persistence. Still, seed production and seedling survival will need to be frequent and widespread if they are to offset expected mortality. Resilience might also vary depending on individual species’ vulnerability to changes in the climate and to EAB (green and black ash are more vulnerable than white ash).

SOURCE

Ward, S.F., A.M. Liebhold, R.S. Morin, S. Fei. 2021. Population dynamics of ash across the eastern USA following invasion by emerald ash borer. Forest Ecology and Management 479 (2021) 118574

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

Correcting Problems that Allow Woodborers to Enter – What We Can Do

U.S. phytosanitary policy is set by politicians – the Secretary of Agriculture, trade officials, and members of the House and Senate. Elected or appointed state officials determine how aggressively trees are protected in their jurisdictions. To fix the problems, those politicians need to hear from those of us who know about the pest risk associated with wood packaging and other imports.

Politics is how our country makes important decisions. And in politics, the squeaky wheel gets the grease.

Election seasons provide opportunities to raise issues. Politicians pay more attention to constituents’ concerns when they are courting our votes.

Further, if new people take up positions in January (whether elected or appointed), they will be more open to learning about issues new to them than were the people who have occupied an office for some time.

These messages need to be repeated periodically. Proctor and Gamble does not make its profits by asking us to buy their toothpaste once a year. We cannot duplicate a major corporation’s advertising budget – but we can speak up!

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 or diseases being spread by shipments of plants. Ask them to urge the USDA Secretary to take action to curtail introductions of additional tree-killing pests.
Ask your friends and neighbors to join you in communicating these concerns to their Congressional representatives and senators.
If you are a member of an association – a scientific or professional society, an environmental advocacy group, a homeowners’ association – ask your association and fellow members 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.

What should we say?

Our goal should be to hold foreign suppliers responsible for complying with ISPM#15. Here are five pieces of a comprehensive approach. It is best to advocate for all. However, if you feel more comfortable focusing on one or two specific actions, please do so!

1) One approach is to penalize violators. APHIS should:

Fine an importer for each new shipment found to be out of compliance with ISPM#15 in those cases where the foreign supplier of that shipment has a record of repeated violations.
Prohibit imports in packaging made from solid wood (boards, 4 x 4s, etc.) from foreign suppliers that have a record of repeated violations.

Allow continued imports from those same suppliers as long as they are contained in other types of packaging materials, including plastic, metals, fiberboards.

APHIS has the authority to take these action under the “emergency action” provision (Sec. 5.7) of the World Trade Organization Agreement on Sanitary and Phytosanitary Standards. (See a lengthy discussion of the SPS agreement in Chapter III of Fading Forests II, available here.) http://treeimprovement.utk.edu/FadingForests.htm

USDA and CBP should take other steps to help importers comply with ISPM#15.

USDA should also step up efforts to help U.S. importers to determine – and then use – those foreign suppliers of wood packaging and dunnage have good compliance records.
APHIS should join the DHS CBP in providing incentives to importers to join an expanded Customs-Trade Partnership Against Terrorism program (C-TPAT) that would require participants to assume full responsibility for ensuring that their packaging complies with IPPC standards.

The Government should strengthen underlying regulations.

Once a new president is elected, urge him to instruct the Office of Management and Budget to allow APHIS to finalize regulations – proposed more than five years ago! – that would apply ISPM#15 to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)
USDA needs to understand the “approach rate” of pests in wood packaging in order to identify and fix weaknesses in its policies. To reach this understanding, APHIS should authorize Robert Haack to repeat the study documented in Haack et al. (2014). Furthermore, APHIS should collaborate with foreign counterparts to determine the relative importance of possible causes of the persistent pest presence problem – fraud, accidental misapplication of treatments, or other failures of treatment. Once the study has been completed, APHIS and its colleagues should work through the IPPC to fix the problems.

There are also recommendations of the Tree-Smart Trade program at www.tree-smart-trade.org Tree-Smart also has a Twitter account: @treeSMARTtrade

Posted by Faith Campbell

How to Fix the Wood Packaging Mess

I first blogged about wood packaging in July 2015 – it was my first blog! I have written 15 times about wood packaging since. To see the series, visit www.nivemnic.us, scroll down below “archives” to “categories”, click on “wood packaging”.

For five years, I have called upon USDA to act. It’s long past time to replace decade-old policies that have failed to prevent introductions. More recently, I have begun calling for revising the international phytosanitary system, too.

As I’ve demonstrated in my blogs – and documented by Aukema et al. 2011 and others—wood-boring beetles have been among the most damaging tree-killing pests introduced to the U.S. Local governments, homeowners, and businesses spend billions of dollars each year to manage dying and dead trees. Landowners bear added costs in reduced property values. The ecosystem impacts are substantial, but still poorly quantified.

International efforts – i.e., ISPM#15 – have apparently reduced the rate at which wood-borer pests approach our shores. However, the reduction has not been sufficient to prevent a tripling of the number of non-native wood-borers established in U.S. by 2050 (Leung et al. 2014) — as I have demonstrated over and over.

Also, I have documented again and again the continued presence of wood-borers in incoming wood packaging and resulting introductions (visit the “wood packaging” category in the blog archives).

Part of the blame for inadequate protection from pests might arise from the specific requirements of current international standards (see Nadel et al. 2016 and Krishnankutty et al. 2020b). But I think most of the blame falls on APHIS’ choice to be forgiving, rather than strict, in enforcing its own regulations that implement the international standard.

There is widespread evidence of exporters’ failures to implement international standards. The evidence is clear: we cannot rely on exporters to meet either international standards or importing country’s phytosanitary requirements. The same countries – and even individual exporting businesses! – fail to comply with ISPM#15 year after year (Haack et al. 2014; APHIS interception database). APHIS has not taken effective action to end imports from these scofflaws.

U.S. phytosanitary policy is set by politicians. Politicians pay more attention to constituents’ concerns during election seasons – so NOW is the time to press for changes! I will discuss how to do this in an accompanying second blog.

U.S. imports have decreased significantly in recent years, especially from the two countries with the worst records of non-compliance with ISPM#15 (Mexico and China). But economic collapse is not a long-term strategy for reducing pest risk.

Quantifying Pest Risk for Wood Packaging: We Don’t Know

Here’s my best estimate of the pest risk associated with wood packaging. Remember, though, that key data remain missing.

Haack et al. published a landmark analysis of pest approach rates in 2014, using data from 2009. However, they did not include imports from China, Mexico, or Canada. Given the history of interceptions, it is probable that a recalculation of the approach rate that included China and Mexico would raise the estimate. It is more difficult to provide a more accurate estimate re: Canada, because CBP rarely inspects those shipments. (The U.S. and Canada do not require each other to treat wood packaging.)

As of mid-October 2019, CBP said it received 11 million containers at seaports annually (CBP website). If 75% of those incoming sea-borne containers have wood packaging (per Meissner et al. 2009), that equals 8,250,000 containers. If 0.1% of those containers with wood packaging is infested (per Haack et al. 2014), we are receiving 8,250 infested shipping containers via maritime shipping – even now, when imports have decreased substantially. This is more than 22 infested containers every day.

As of a decade ago, Chinese shipments were only half as likely to be enclosed in wood packaging as are shipments from other exporters. Perhaps this reflects a greater reliance on air shipments – air shipments globally are half as likely as maritime shipments to be encased in packaging made of wood (Meissner et al. 2009). Despite the lower proportion of wood packaging use, shipments from China still rank second (to Mexico) in the number of shipments detected as infested. In part, the data reflect inspection priorities: due to the great damage caused by Asian insects to North American trees and their record of poor compliance, CBP targets shipments from China for more intense scrutiny. Still, the high number of detections reflects continuing non-compliance by Chinese exporters. And remember: first, the U.S. and Canada began requiring treatment of wood packaging from China at the end of 1998 – 21 years ago! And second, APHIS almost never penalizes importers for poor compliance.

Understanding the pest risk from Mexico and Canada is important, because they are our second and third largest trading partners. As of October 2019, the numbers of shipping containers arriving overland (by truck or rail) from these countries annually were 13.7 million (CBP website). No one has estimated the proportion of these containers that contain wood packaging. If it is the same proportion as in maritime shipments, the approach rate would be another 10,275 infested containers per year – or 28 per day.

The total of maritime and land-based shipments that are probably infested (excluding air shipments) – would be 18,525 containers annually or 50 per day.

If I am right that shipments from China and Mexico have a higher pest-infestation rate than the 0.1% global estimate developed by Haack et al. (2014), the pest approach rate is probably higher than the 18,525 containers given above.

(I noted in my previous blog that insect species arriving from our neighbors pose a lower risk than the species from Asia or Europe – although the risk is not “0”. I addressed the Mexican woodborers in the previous blog. The risk from Canada could arise from non-native woodborers established in that country but not yet in the U.S. e.g., brown spruce longhorned beetle. Another risk is that shipments from off-shore origins might be transshipped through Canada and escape inspection because they are claimed to have been re-packaged there – as CBP staff have told me.)

The point is, we don’t know how many pests are reaching the U.S. daily. The current approach rate might be significantly higher or lower than Haack and colleagues estimated a decade ago due to

Exclusion of China, Mexico, and Canada from the original study.
Changes in the treatment requirements of ISPM#15.
Another decade of experience – which might have led to better compliance (however, see below).

Despite my urging, APHIS has not agreed to a study to update Haack’s estimate.

It is also true that shipping containers provide shelter for a vast range of hitchhiking organisms in addition to insects in the wood, e.g., other insects’ eggs attached to the sides of the container, snails, weed seeds, even vertebrates.

Enforcement: One Agency Steps Up

When ISPM#15 was adopted, APHIS expected that importers would clean up their supply chains in order to avoid the lost income and costly delays that result from CBP interception of a non-compliant shipment. However, the data clearly show that this disincentive to violate ISPM#15 is insufficient to prompt companies to fix the problem. We need to find a more efficacious approach.

Clearly, enforcement in the form of penalties had been rare before 2017. CBP staff reported that as of January 2017 (before the agency strengthened its own enforcement effort), only about 30 of the nearly 21,000 non-compliant import shipments had received a financial penalty. CBP staff cited two reasons for the low penalty rate: 1) USDA policy requires that an importer be caught five times in a year with non-compliant wood packaging before imposing a fine; and 2) APHIS had not designated wood packaging as a high-risk commodity. After CBP initiated more aggressive enforcement in November 2017, enforcement actions rose by 400% (John Sagle, CBP. pers. comm) – although from a very low starting point!

Data on CBP interceptions in 2019 (Harriger) show decreases in the number of non-compliant shipments from earlier years in all categories: a 19% decrease below the 2010-2018 average of shipments intercepted; a 13% decrease in number of shipments intercepted because the wood packaging lacked the ISPM#15 mark; a decrease of 6% in the number of shipments intercepted that had a quarantine pest. Still, percentages based on absolute numbers don’t tell the whole story. They can be affected by inspection effort and other variables. So while these decreases are encouraging, it is still too early to determine the impact of CBP’s enforcement upgrade.

Unfortunately, there has not yet been the substantive/overall change needed in federal policy. At a minimum, APHIS continues to allow importers five violations per twelve month period.

While the cities that import the most goods – especially from Asia – would seem to be at particular risk, experience shows that pests can be introduced anywhere. This is demonstrated by establishment of the Asian longhorned beetle in semi-rural Clermont County, Ohio and the velvet longhorned beetle in Utah (Krishnankutty, et al. 2020a).

“Treated” Wood Still Transports Pests

According to interception data provided to me by CBP (Harriger), 97% of pest-infested shipments detected over a period of 6 years (FYs 2010 – 2015) bore the stamp indicating they’d been treated in compliance with ISPM#15. These shipments came from all importing countries. Unfortunately, CBP has not provided the necessary breakdown of its data in more recent years to calculate this proportion.

Krishnankutty et al. (2020b) analyzed wood packaging from 42 countries intercepted by CBP over six years (April 2012 – January 2018). They found that 87% of the infested wood packaging included in this study bore the ISPM mark. This is a lower non-compliance rate than that shown by CBP data, but still too high.

European scientists carried out an intensive survey of wood packaging associated with shipments of stone from China to the 28 European Union countries during 2013-2016. They also found that 97.5% of consignments that harbored pests bore the ISPM#15 mark (Eyre et al. 2018). The problem did not decrease over time.

The possible causes of this problem are long-known. What effort is APHIS making to determine their relative importance? Is it fraud? Is it accidental misapplication of the treatments? Is it that the treatments do not work as well as necessary?

By comparing Haack’s estimate with the CBP data, I estimate that CBP is detecting and halting the importation of 4 – 8% of the shipments that actually contain pest-infested wood. Wu et al. (2020) concurred that the majority of infesting larvae would probably not be intercepted – despite CBP’s best efforts – and would be transported to the cargo’s intended destinations.

Since CBP inspects only about 2% of incoming shipments, this detection rate demonstrates the value of CBP’s program to target likely violators. It deserves praise. But it is obviously too low a “catch” rate to provide an adequate level of protection for our forests. I do not believe that increasing the inspection workforce and effort will result in substantial improvement in this rate. Instead, we need action to curtail imports of wood packaging from countries and exporters with records of non-compliance.

What Federal Agencies Are Doing to Better Prevent Introductions

Other than CBP’s welcome newly rigorous enforcement policy, most actions have focused on educating exporters, importers, shippers, customs brokers, and exporting countries’ phytosanitary agencies.

Since upgrading its enforcement actions, CBP has expanded its long-standing educational efforts. APHIS co-sponsored workshops for agricultural agencies and exporters in Asia and the Americas earlier in the decade.

APHIS also planned to host international symposia on wood packaging issues as part of events recognizing 2020 as the International Year of Plant Health. These symposia have been postponed by travel and other restrictions arising from the coronavirus pandemic.

Posted by Faith Campbell

SOURCES

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

Eyre, D., R. Macarthur, R.A. Haack, Y. Lu, and H. Krehan. 2018. Variation in Inspection Efficacy by Member States of SWPM Entering EU. Journal of Economic Entomology, 111(2), 2018, 707–715)

Haack, R. A. 2006. Exotic bark- and wood-boring Coleoptera in the United States: recent establishments and interceptions. Can. J. For. Res. 36: 269–288.

Haack, R.A., F. Herard, J. Sun, J.J. Burgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetle and Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46.

Haack, R. A., K. O. Britton, E. G. Brockerhoff, J. F. Cavey, L. J. Garrett, M. Kimberley, F. Lowenstein, A. Nuding, L. J. Olson, J. Turner, and K. N. Vasilaky. 2014. Effectiveness of the international phytosanitary standard ISPM no. 15 on reducing wood borer infestation rates in wood packaging material entering the United States. Plos One 9:e96611.

Kevin Harriger, US CBP. Presentation to the annual meetings of the Continental Dialogue on Non-Native Forest Insects and Diseases, over appropriate years. See, e.g., https://continentalforestdialogue.org/continental-dialogue-meeting-november-2018/

Krishnankutty, S.M., K. Bigsby, J. Hastings, Y. Takeuchi, Y. Wu, S.W. Lingafelter, H. Nadel, S.W. Myers, and A.M. Ray. 2020a. Predicting Establishment Potential of an Invasive Wood-Boring Beetle, Trichoferus campestris (Coleoptera) in the United States. Annals of the Entomological Society of America, XX(X), 2020, 1–12

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

Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org

Meissner, H., A. Lemay, C. Bertone, K. Schwartzburg, L. Ferguson, L. Newton. 2009. Evaluation of Pathways for Exotic Plant Pest Movement into and within the Greater Caribbean Region. Caribbean Invasive Species Working Group (CISWG) and USDA APHIS Plant Epidemiology and Risk Analysis Laboratory

Nadel, H. S. Meyers, J. Molongoski, Y. Wu, S. Lingafelter, A. Ray, S. Krishnankutty, A. Taylor. 2017. Identification of Port Interceptions in Wood Packing Material Cumulative Progress Report, April 2012 – June 2017

Oregon Department of Agriculture, Plant Protection & Conservation Programs. 2019. Annual Report 2019.

USDA APHIS interception database – pers. comm. January 2017.

U.S. Department of Transportation, Maritime Administration, U.S. Waterborne Foreign Container Trade by U.S. Customs Ports (2000 – 2017) Imports in Twenty-Foot Equivalent Units (TEUs) – Loaded Containers Only at https://ops.fhwa.dot.gov/freight/freight_analysis/nat_freight_stats/docs/06factsfigures/fig2_9.htm

U.S. Department of Transportation. Port Performance Freight Statistics in 2018 Annual Report to Congress 2019 https://rosap.ntl.bts.gov/view/dot/43525

Wu, Y., S.M. Krishnankutty, K.A. Vieira, B. Wang. 2020. Invasion of Trichoferus campestris (Coleoptera: Cerambycidae) into the United States characterized by high levels of genetic diversity and recurrent intros. Biological Invasions Volume 22, pages1309–1323(2020)

CBP website – https://www.cbp.gov/border-security/ports-entry/cargo-security#:~:text=Each%20year%2C%20more%20than%2011,and%202.7%20million%20by%20rail.