Category: funding

Solutions Suggested by 30 Years’ Work

Faith Campbell receives award for activism from National Association of State Foresters; 2016

For nearly 30 years I have documented bioinvasion threats and gaps, first in three Fading Forests reports (available here), then in five years of blogging. Here I pull together that information and suggest — in most cases reiterate — steps to address these threats and gaps. I list sources of discussion of the underlying issues – other than my reports and blogs – in references at the end of this blog.

My first premise is: robust federal leadership is crucial:

  1. The Constitution gives primacy to federal agencies in managing imports and interstate trade.
  2. Only a consistent approach can protect trees (and other plants) from non-native pests.
  3. Federal agencies have more resources than state agencies individually or in any likely collective effort — despite decades of budget and staffing cuts.

My second premise is: success depends on a continuing, long-term effort founded on institutional and financial commitments commensurate with the scale of the threat. This requires stable funding; guidance by research and expert staff; and engagement by non-governmental players and stakeholders. Unfortunately, as I discuss below, funding has not been adequate or stable.

My third premise is that programs’ effectiveness needs to be measured, not just effort (see the NECIS document referenced at the end of the blog).

SPECIFICS 

Preventing new introductions continues to be the most effective action. Mitigating options decrease and damages increase once a non-native pest has entered the country – much less become established (see Lovett et al. 2016 and Roy et al. 2014). I recognize that preventing new introductions poses an extremely difficult challenge given the volume and speed of international trade and the strong economic forces supporting free trade. These challenges have been exacerbated over several decades by the political zeitgeist – the anti-regulatory ideology, the emphasis on “collaborating” with “clients” rather than imposing requirements through regulations. Although the current “America First” policy might reduce import volumes and therefore reduce the invasive species threat to some extent, the anti-regulatory stance has only strengthened.

containers at the Port of Long Beach, California

Decades of cutting key agencies’ budgets and personnel are another factor. However, the damage to America’s natural systems is so great that we must try harder to find more effective strategies (See the Fading Forest reports; my previous blogs; Lovett et al. 2016; and APHIS annual reports – e.g., the 2019 report here)

Prevention

  1. Despite adoption and implementation of new international and national regulations to stem pest introductions, introductions continue – although probably at a lower level than would otherwise be the case. Delays in adoption of regulations (documented in Fading Forests II and III and my two recent 30-years-in-review blogs have facilitated damaging introductions and spread.

Solutions 

  1. Stakeholders press USDA leadership to initiate rules intended to strengthen phytosanitary protection and expedite their completion
  2. APHIS promote and facilitate analysis of current programs and policies by non-agency experts to ensure the agency is applying most effective strategies (Lovett et al. 2016).
  • Adoption of insufficiently protective regulations (documented in FFII, FFIII, two 30-years-in-review blogs) – adopted in part because APHIS is trying to “balance” trade facilitation and phytosanitary protection – has further contributed to damaging pests’ introduction and spread.

Solutions:

  1. Boost priority of preventing pest introductions by amending the Congressional finding in the Plant Protection Act [7 USC 7701(3)] as follows

Existing language: “[I]t is the responsibility of the Secretary [of Agriculture] to facilitate exports, imports and interstate commerce in . . . commodities that pose a risk of harboring plant pests or noxious weeds in ways that will reduce, to the extent practicable, as determined by the Secretary, the risk of dissemination of plant pests and noxious weeds .… “

Amend to read as follows: “…. in ways that will reduce prevent, to the greatest extent practicable feasible, as determined by the Secretary, …” [emphasis added]

  • Adopt several actions to strengthen phytosanitary protections at the point of origin (Lovett et al. 2016)
  • Expand pre-clearance partnerships — as authorized for plants under Q-37 regulations and ISPM-36
  • Expand sentinel tree programs
  • Promote voluntary substitution of packaging made from materials other than solid wood.
  • APHIS doesn’t use the enforcement powers that it has under Plant Protection Act (see several of my past blogs)

Solutions:

CBP inspectors search for pests in a pallet; CBP photo
  1. APHIS follow the lead of Customs and Border Protection and begin penalizing importers on the first instance of their wood packaging not being in compliance with ISPM#15 (see blog here).
  2. APHIS prohibit use of wood packaging by countries and importers of categories of imports that – over the 13 years since implementation – have developed a record of frequent violations of ISPM#15.
  3. APHIS use its authority per revised Q-37 regulations to negotiate with countries that export plants to the U.S. to establish “integrated measures” programs aimed at minimizing the risk of associated pests being transported to the U.S.
  4. APHIS use its authority per revised Q-37 to place in the “Not Authorized for Import Pending Pest Risk Assessment (NAPPRA) “limbo” category genera containing North American “woody” plants  (see Roy et al. 2014; Lovett et al. 2016).

Spread within the U.S.

  1. The United States lacks a coordinated system to prevent pest spread within the country (see Fading Forests III Chapter 5). Even our strictest methods, like APHIS’s quarantines regulating interstate movement of goods, have failed to curtail spread of significant pests. The most obvious example is the emerald ash borer.

The regulations governing movement of the sudden oak death pathogen in the nursery trade have also failed: there have been periodic outbreaks in which the pathogen has been spread to nurseries across the country. Between 2003 and 2011, a total of 464 nurseries located in 27 states tested positive for the pathogen, the majority as a result of shipments traced from infested wholesalers. In 2019, plants exposed to the pathogen were again shipped to 18 states; eight of those states have confirmed that their plant retailers received infected plants (see my blog from summer here).

Another serious gap is the frequent failure of APHIS and states to adopt official programs targetting bioinvaders that will be difficult to control because of biological characteristics or cryptic natures – even when severe impacts are demonstrated. Recent examples include the laurel wilt disease complex, goldspotted oak borer, polyphagous and Kuroshio shot hole borers and associated pathogens, and even the spotted lanternfly (although the last has received significant funds from APHIS.)

redbay killed by laurel wilt disease, Georgia; photo by Scott Cameron

Solutions:

  1. APHIS apply much more stringent regulations to interstate movement, based on a heightened priority for prevention in contrast to facilitating interstate trade. E.g., prohibit nurseries on the West Coast from shipping P. ramorum hosts to states where the pathogen is not established.
  2. APHIS encourage states to adopt quarantines and regulations aimed at preventing spread of invasive pests to regions of the state that are not yet infested. For example, the sudden oak death pathogen in California and Oregon; the borers in southern California.
  3. APHIS abandon plans to deregulate emerald ash borer and step up its support for state  regulations on firewood.
  4. APHIS stop dumping pests it no longer wants to regulate onto the states through the “Federally Recognized State Manage Phytosanitary (FRSMP) program”.
  5. APHIS revise its policies so that the “special needs exemption” [7 U.S.C. 7756] actually allows states to adopt more stringent regulations to prevent introduction of APHIS-designated quarantine pests (see Fading Forests III Chapter 3).

To help fill the gaps, the states are trying to coordinate their regulations in some important areas. The most advanced example is the voluntary Systems Approach to Nursery Certification, or SANC program. APHIS has supported this initiative, including by funding from the Plant Pest and Disease Management and Disaster Program (see below). However, it is a slow process; USDA funds first became available in 2010. The states are trying to coordinate on firewood, but we don’t yet know what the process will be.

  • Funding shortfalls (See the three Fading Forests reports, my blogs about appropriations)
  • Increase APHIS’ access to emergency funds from the Commodity Credit Corporation by  amending the Plant Protection Act [7 U.S.C. 7772 (a)] to include this new definition of “emergency”:

the term “emergency” means any outbreak of a plant pest or noxious weed which directly or indirectly threatens any segment of the agricultural production of the United States and for which the then available appropriated funds are determined by the Secretary to be insufficient to timely achieve the arrest, control, eradication, or prevention of the spread of such plant pest or noxious weed.

  • Although APHIS has the most robust prevention program of any federal agency, its funding is still inadequate. Stakeholders should lobby the Congress in support of higher annual appropriations.

The Plant Pest and Disease Management and Disaster Program (now under Section 7721 of the Plant Protection Act) has provided at least $77 million for tree-pest programs (excluding NORS-DUC & sentinel plant programs and other programs) since FY 2008. Much useful work has been carried out with these funds. However, these short-term grants cannot substitute for stable, long-term funding. I reiterate my call for stakeholders to lobby the Congress to provide larger appropriations to the APHIS Plant Protection program and Forest Service Forest Health Protection and Research programs.

Long-term Responses to Bioinvasive Challenge

More stakeholders are advocating raising the priority of – and providing adequate resources to – such long-term solutions as biocontrol and breeding trees resistant to pests and restoring them to our forests. Advocates include the state forestry agencies of the Northeast and Midwest, some non-governmental organizations, some academics, and individual USFS scientists. One effort resulted in inclusion of language in the 2018 Farm Bill (see blog here) – although this approach has apparently run into a dead end. The new emphasis on breeding has so far not been supported by agency or Congressional leaderships.

test planting of an American chestnut bred to be resistant to chestnut blight

Solutions:

  1. USFS convene workshop of the federal, state, National Academy, academic, and NGO groups promoting resistance breeding in order to develop consensus on priorities  and general structure of program.

Explicitly include evaluation of the CAPTURE Project’s (see blog here) efforts to set priorities to guide funding allocations and policies; and proposals for providing needed supportive infrastructure – facilities, trained staff in various disciplines. (See my blogs here.)

Report results of meeting to USDA leadership, Congress, and stakeholders

Then ensure implementation of the accepted approach by both Research and Development and Forest Health Protection programs. Include provisions to provide sustainable funding.

These proposed actions still do not address ways to correct the provisions of the international phytosanitary agreements (World Trade Organization and International Plant Protection Convention) that complicate – or preclude – efforts to prevent introduction of pests currently unknown to science. This  issue is discussed in Fading Forests II. A current example is beech leaf disease (described here).

Continuing inadequate engagement by stakeholders

Most constituencies that Americans expect to protect our forests don’t press decision-makers to fix the problems I have identified above: inadequate resources, weak and tardy phytosanitary measures. Some of these stakeholders are other federal agencies, or state agencies – or their staffs. They face restrictions on how “political” they can be. But where are the professional and scientific associations, representatives of the wood products industry, forest landowners, environmental NGOs and their funders, urban tree advocates Efforts by me, USDA, and others to better engage these groups have had disappointing results.

As I have documented, groups of USFS scientists have made several attempts to document the extent of invasive species threats and impacts and to set priorities. So far, they have not gained much traction. Another USFS attempt, Poland et al. in press, will appear at the end of the year. Will this be more successful?

I detect growing attention to educating citizen scientists for early detection; but if there is an inadequate – or no – official response to their efforts won’t people become discouraged?

SOURCES

Lovett, G.M., M. Weiss, A.M. Liebhold, T.P. Holmes,  B. Leung, K.F. Lambert, D.A. Orwig, F.T. Campbell, J. Rosenthal, D.G. McCullough, R. Wildova, M.P. Ayres, C.D. Canham, D.R. Foster, SL. Ladeau, and T. Weldy. 2016. NIS forest insects and pathogens in the US: Impacts and policy options. Ecological Applications, 26(5), 2016, pp. 1437–1455

National Environmental Coalition on Invasive Species “Tackling the Challenge.”

Poland, T.M., Patel-Weynand, T., Finch, D., Miniat, C. F., and Lopez, V. (Eds) (2019), Invasive Species in Forests and Grasslands of the United States: A Comprehensive Science Synthesis for the United States Forest Sector.  Springer Verlag. (in press).

Roy, B.A., H.M Alexander, J. Davidson, F.T Campbell, J.J Burdon, R. Sniezko, and C. Brasier. 2014. Increasing forest loss worldwide from P&Ps requires new trade regulations. Front Ecol Environ 2014; 12(8): 457–465

30 years of Analyzing Forest Pest Issues

dead whitebark pine in Crater Lake National Park
photo by F.T. Campbell

I began studying and writing about the threat to North America’s forests from non-native insects and pathogens in the early 1990s – nearly 30 years ago. I reported my analyses of the evolving threat in the three “Fading Forests” reports – coauthored by Scott Schlarbaum – in 1994, 2003, and 2014. These reports are available here.

So what has changed over those 30 years? What remains the same? Why have both the changes and the stasis occurred? What can we do to fix the gaps, close unaddressed pathways, strengthen flabby policies? I will address these issues in this and following blogs.

experimental American chestnut planted in Fairfax County, VA
photo by F.T. Campbell

What has changed since the early 1990s:

  • Adoption and implementation of significant new international and national regulations and programs aimed at preventing introductions of non-native invasive species.
  • Despite the welter of new regulations, an alarming increase in numbers of highly damaging forest pests established in the country.  (By my count, about 50 new species have established on the continent, six on Pacific islands; see details below.)
  • Alarming spread of established pests to new geographic regions and new hosts (e.g., emerald ash borer in 35 states and 5 provinces; laurel wilt disease across the range of redbay and swamp bay; rapid ‘ōhi‘a death on three of the main Hawaiian islands).
  • Introductions via unexpected pathways and vectors far removed from phytosanitary agencies’ usual targets, e.g., ship superstructures, imported steel and stone …

What has remained the same since the early 1990s:

  • Inadequate resources provided to response and recovery efforts.
  • Available funding focused on only a few of the more than 90 species causing damage.
  • Adoption of insufficiently protective regulations that have failed to prevent introduction and spread of tree-killing pests.
  • Lengthy delays in implementing programs that tighten controls – another factor in continuing introductions and spread.
  • Continued importance of expected pathways – nursery stock and raw wood, especially crates, pallets, and other forms of wood packaging.
  • Federal and state agencies still choose not to take action on pests e.g., goldspotted oak borer, polyphagous and Kuroshio shothole borers, beech leaf disease.
  • Inadequate coordination despite several efforts to set priorities.
  • Spurts of attention by media and political decision-makers, contrasted by lengthy periods of inattention.
  • Failure of most stakeholders to support efforts to prevent and respond to introductions of tree-killing pests. 

Details: The Situations Then and Now

(Many of the individual species mentioned here are described more fully here.  Full citations of sources are at the end of blog.)

American elm on the National Mall, Washington, D.C.

photo by USDA Agricultural Research Service

In 1993:

  • The number of non-native forest pest species established in the U.S. was estimated at between 300 (Millers et al. 1993) and 380 (Mattson et al., 1994; Liebhold et al., 1995) .
  • The area suffering the greatest numbers and impacts was the Northeast.
  • Several highly damaging pests that had been established for decades, including chestnut blight, white pine blister rust, Port-Orford-cedar root disease, Dutch elm disease, hemlock woolly adelgid, butternut canker, and dogwood anthracnose were receiving some attention but continued to spread.
  • USDA Forest Service funding for management of exotic pest infestations was crisis-oriented, with “… priorities … set under political pressures for immediate answers, with too much regard for short-term problems and too little consideration for broader management objectives.” (NAS 1975)
  • Since few high-profile pests had been introduced in recent years, APHIS was not actively engaged. In FY92, APHIS spent $20 million on efforts to eradicate the Asian gypsy moth. The narrow focus is illustrated by the fact that in FY93, more than two-thirds of all USDA tree pest control funds were devoted to efforts to suppress or eradicate the European gypsy moth (See FFI).
  • Concern about possible new introductions had grown; it focused on proposals to import unprocessed wood from Siberia, New Zealand, and Chile. The USDA Forest Service, academic scientists, and therefore APHIS emphasized the risks of known Asian pests, e.g., Asian gypsy moth, to western coniferous forests (See FFI). While individual scientists had expressed concern about wood packaging material, there was little public discussion of this threat.
  • We would learn later that several of the most damaging pests were already present in the country but not yet recognized – Asian longhorned beetle, sudden oak death pathogen, probably emerald ash borer.

beech leaf disease

photo by John Pogacnik

In 2019:

  • Numbers of non-native insects and pathogens attacking trees in North America approach 500 species.  (In Fading Forests III, I calculated that by the first decade of the 21st Century, the number had risen to at least 475. Several more have been detected since 2014. More than 181 exotic insects that feed on woody plants had established in Canada. (Source: USDA APHIS. 2000. Wood packaging risk assessment.)
  • Of these, 91 are considered “serious” threats (Guo et al. 2019). This estimate excludes pests native to portions of North America that are causing severe damage in naïve hosts – e.g., goldspotted oak borer; pests of palms; and pests attacking trees on U.S. Pacific and Caribbean islands.
  • Introductions had continued.
    • Between 1980 and 2016, at least 30 non-native species of wood- or bark-boring insects (Scolytinae / Scolytidae) were newly detected in the U.S. (Haack and Rabaglia 2013; Rabaglia et al.  2019). A few of these are highly damaging, e.g. redbay ambrosia beetle, polyphagous and Kuroshio shothole borers.
    • In addition to these 30 new pests, other highly damaging tree-killing pests probably introduced since the 1980s include (on the continent):
      • Eight Cerambycids such as Asian longhorned beetle (Wu et al. 2017)
      • 7 Agrilus, including emerald ash borer and soapberry borer; plus goldspotted oak borer transported from Arizona to California (Digirolomo et al. 2019; R. Haack, pers. comm.)
      • Sirex woodwasp
      • Pests of palm trees, e.g., red palm mite, red palm weevil, South American palm weevil
      • Spotted lanternfly
      • Beech leaf disease
    • Also not included in the above estimate and lists are tree-killing pests on America’s Pacific Islands :
      • ‘ōhi‘a rust
      • Cycad scale
      • Cycad blue betterfly
      • Erythrina gall wasp
      • two Ceratocystis pathogens that cause rapid ‘ōhi‘a death
      • Coconut rhinoceros beetle
    • Authorities also carried out approximately 25 eradication programs targetting introductions of the Asian gypsy moth (USDA Pest Alert Asian Gypsy Moth plus additional outbreaks since 2014).
  • Impacts of exacerbated tree mortality rates linked to these introduced pests are seen across wide swaths of the country, and affect widespread species, genera, and families. 
dead redbay in Claxton, Georgia
photo by Scott Cameron

I will discuss the risk of continuing new introductions in a separate blog.

Trying to Develop the Big Picture and Set Priorities

In recent years, USDA Forest Service scientists have made several attempts to provide nation-wide assessments of the impact of these pests and criteria for establishing priorities.

The National Insect and Disease Forest Risk Assessment predicted the loss of basal area to various pests over the 15-year time period 2012 – 2027. The assessment predicted the following losses for specific species: 90% for redbay; 60% for whitebark pine; more than 40% for limber pine; 24% for tanoak; 11% for coast live oak; 6% for eastern and Carolina hemlock; 27% for eight species of ash; 20% for American elm; 19% for red oak; 18% for American beech (Krist et al. 2014).

A separate group of scientists found that, nation-wide, non-native forest pests are causing an approximate 5% increase in total mortality by tree volume (Randy Morin at NEFPC). For details on Dr. Morin’s findings, see my blog here.

A third approach to developing a nation-wide picture, Project CAPTURE, (and my blog here) utilized FIA data to develop priorities for conservation action. Fifteen species were placed in the highest priority category, including Florida torreya (Torreya taxifolia), American chestnut and Allegheny and Ozark chinquapins, redbay, five species of ash, two species of hemlock, Port-Orford cedar, tanoak, and butternut (Potter et al. 2019(b).

According to Project CAPTURE, the non-native pests affecting the largest number of hosts are the European gypsy moth, which attacks 65 hosts; and oak wilt (Bretziella fagacearum), which infects 61 hosts. The Asian longhorned beetle attacks 43 hosts (Potter et al. 2019(b).

I note that several other non-native pests also have high numbers of host species. In the Project CAPTURE study, these pests are ranked lower because the project limited its evaluation to the five agents with the greatest effect on any particular host. Thus, of the 18 native tree species that host one or both of the invasive shothole borers and associated Fusarium disease complex (PSHB website), the project included only six. Of the 22 tree species listed by APHIS as hosts of Phytophtora ramorum, the project included 12 (K. Potter, pers. comm. April 17, 2019).

SOD-killed tanoak on the Big Sur peninsula, California
photo by Matteo Garbelotto, University of California Berkeley

More extensive discussions of non-native pests’ impacts are provided in Lovett et al. 2006, Lovett et al. 2016, and Potter et al. 2019. A book-length discussion of invasive species impacts – ranging from feral hogs to invasive plants, is expected in December; look for Poland et al. (in press).

SOURCES

Aukema, J.E., D.G. McCullough, B. Von Holle, A.M. Liebhold, K. Britton, & S.J. Frankel. 2010. Historical Accumulation of Nonindigenous Forest Pests in the Continental United States. Bioscience. December 2010 / Vol. 60 No. 11

Digirolomo, M.F., E. Jendek, V.V. Grebennikov, O. Nakladal. 2019. First North American record of an unnamed West Palaearctic Agrilus (Coleoptera: Buprestidae) infesting European beech (Fagus sylvatica) in New York City, USA. European Journal of Entomology. Eur. J. Entomol. 116: 244-252, 2019

Guo, Q., S. Fei, K.M. Potter, A.M. Liebhold, and J. Wenf. 2019. Tree diversity regulates forest pest invasion. Proceedings of the National Academy of Sciences of the United States of America. www.pnas.org/cgi/doi/10.1073/pnas.1821039116

Haack, R.A. and R.J. Rabaglia. 2013. Exotic Bark and Ambrosia Beetles in the USA: Potential and Current Invaders. CAB International 2013. Potential Invasive Pests of Agricultural Crops (ed. J. Peña) 

Krist, F.J. Jr., J.R. Ellenwood, M.E. Woods, A. J. McMahan, J.P. Cowardin, D.E. Ryerson, F.J. Sapio, M.O. Zweifler, S.A. Romero 2014. National Insect and Disease Forest Risk Assessment. United States Department of Agriculture Forest Service Forest Health Technology Enterprise Team FHTET-14-01

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

Liebhold, A. M., W. L. MacDonald, D. Bergdahl, and V. C. Mastro.  1995.  Invasion by exotic forest pests:  a threat to forest ecosystems.  Forest Sci., Monograph 30. 49 pp.

Lovett, G.M., C.D. Canham, M.A. Arthur, K.C. Weathers, and R.D. Fitzhugh. Forest Ecosystem Responses to Exotic Pests and Pathogens in Eastern North America. BioScience Vol. 56 No. 5 (May 2006)

Lovett, G.M., M. Weiss, A.M. Liebhold, T.P. Holmes,  B. Leung, K.F. Lambert, D.A. Orwig, F.T. Campbell, J. Rosenthal, D.G. McCullough, R. Wildova, M.P. Ayres, C.D. Canham, D.R. Foster, SL. Ladeau, and T. Weldy. 2016. NIS forest insects and pathogens in the US: Impacts and policy options. Ecological Applications, 26(5), 2016, pp. 1437–1455

Mattson, W. J., P. Niemela, I. Millers, and Y. Ingauazo.  1994. Immigrant phytophagous insects on woody plants in the United States and Canada: an annotated list.  USDA For. Ser. Gen. Tech. Rep. NC-169, 27 pp.

Millers, I. United States Department of Agriculture, Forest Service Entomologist, Forest Health Protection Northeastern Area State and Private Forestry. Durham, NH. Personal communication to F.T. Campbell, 1993.

Morin, R. presentation at Northeastern Forest Pest Council 81st Annual Meeting, March 12 – 14, 2019,  West Chester, Pennsylvania

National Academy of Sciences. 1975. Forest Pest Control. Washington, D.C.

Poland, T.M., Patel-Weynand, T., Finch, D., Miniat, C. F., and Lopez, V. (Eds) (2019), Invasive Species in Forests and Grasslands of the United States: A Comprehensive Science Synthesis for the United States Forest Sector.  Springer Verlag. (in press).

Polyphagous shothole borer website https://ucanr.edu/sites/pshb/overview/About_PSHB/

Potter, K.M., M.E. Escanferla, R.M. Jetton, and G. Man. 2019. Important Insect and Disease Threats to US Tree Species and Geographic Patterns of Their Potential Impacts. Forests 2019, 10, 304.

Potter, K.M., Escanferla, M.E., Jetton, R.M., Man, G., Crane, B.S. 2019. Prioritizing the conservation needs of US tree spp: Evaluating vulnerability to forest insect and disease threats, Global Ecology and Conservation (2019), doi: https://doi.org/10.1016/

Rabaglia, R.J., A.I. Cognato, E. R. Hoebeke, C.W. Johnson, J.R. LaBonte, M.E. Carter, and J.J. Vlach. 2019. Early Detection and Rapid Response. A Ten-Year Summary of the USDA Forest Service Program of Surveillance for Non-Native Bark and Ambrosia Beetles. American Entomologist Volume 65, Number 1 

USDA, Animal and Plant Health Inspection Service. 2014. Asian gypsy moth pest alert https://www.aphis.usda.gov/publications/plant_health/content/printable_version/fs_phasiangm.pdf and pers. comm.

U.S. Department of Agriculture, Animal and Plant Health Inspection Service.  2009.  Risk analysis for the movement of wood packaging material (WPM) from Canada into the US.

Wu,Y., N.F. Trepanowski, J.J. Molongoski, P.F. Reagel, S.W. Lingafelter, H. Nadel1, S.W. Myers & A.M. Ray. 2017. Identification of wood-boring beetles (Cerambycidae and Buprestidae) intercepted in trade-associated solid wood packaging material using DNA barcoding and morphology  Scientific Reports 7:40316

Promising Biocontrol to Protect Some Cacti

Photo of infested cactus at Cabo Rojo National Wildlife Refuge, Puerto Rico. Taken August 20, 2018 by Yorelyz Rodríguez-Reyes

Three and a half years ago, I blogged about the threat to columnar cacti in Puerto Rico from the Harrisia cactus mealybug. The mealybug clearly threatens the endemic cacti of the Caribbean islands, and possibly some of the hundreds of other columnar cacti growing across two million square miles of desert ecosystems that straddle the U.S.-Mexico border region.

I am pleased to report that scientists continue efforts to find biocontrol agents to reduce this insect’s damage on Caribbean islands. Much of this work is being done by the Center for Excellence in Quarantine and Invasive Species at University of Puerto Rico. The team consists of Michael West Ortiz, Yorelys Rodrígues Reyes, Ferdinand Correa and Jose Carlos Verle Rodrigues.

As of February 2019, the Center is conducting host specificity tests on a primary parasitoid of the Harrisia Cactus mealybug — Anagyrus cachamai. This wasp was found as a result of almost a decade of searching in South America and other locations. It is native to Argentina and Paraguay (Triapitsyn et al. 2018; sources listed at the end of the blog).The Center also continues surveys and studies of other primary and secondary parasitoids of the mealybug.

The work to develop a biocontrol agent for the mealybug continues despite continuing uncertainty about the true species of the mealybug. At the time of its discovery on Puerto Rico, the mealybug was believed to belong to a species used as a biocontrol agent for invasive cacti in Australia and South Africa, designated as Hypogeococcus pungens. However, H. pungens is now thought to be a species complex, and the species in Puerto Rico differs from the earlier designation (Triapitsyn et al. 2018). 

Apparently the mealybug was introduced in Puerto Rico around 2000   — probably on the ornamental common purslane (Portulaca olerácea), an annual succulent. (Note: the introduction was on a host different from the vulnerable cacti.) Within five years of the first detection in San Juan, the mealybug was sighted on cacti on the other side of the island in the Guánica State Forest and Biosphere Reserve. By 2010, the mealybug was widely distributed in most dry districts. Surveys found it in all 11 municipalities surveyed in southern Puerto Rico. At some locations, infestation levels were extremely high – e.g., 86% of stems surveyed were infested at Guánica. Infestation rates were lower in other municipalities. As of 2010, infestations were estimated to be present on about 1,400 km2 on the southern coast; the rate of new infestations suggests that the mealybug was spreading rapidly (Segarra-Carmona et al. 2010).  I have been unable to obtain more recent estimates.

The mealybug impacts seven of 14 native cactus species occurring in dry forests of the island, including three endemic and two endangered species in the subfamily Cactoideae. The two endangered species are Harrisia portoricensis and Leptocereus grantianus (USDA ARS). The tissue damage caused by the mealybug interferes with sexual reproduction and can cause direct mortality of the plant (Triapitsyn et al. 2018).  These cacti provide food or shelter for endemic bats, birds, moths and other pollinators (Segarra & Ramirez; USDA ARS). The mealybug is also now killing native cacti on the U.S. Virgin Islands (H. Diaz-Soltero pers. comm. August 2015).

 USDA Funds Conservation Efforts Despite Apparent Absence of a Constituency Calling for Such Action

Efforts to identify and test possible biocontrol agents targetting the Harrisia cactus mealybug received significant funds from the Plant Pest and Disease Management and Disaster Prevention Program. This is a competitive grant program managed by APHIS. It is permanently funded and thus not subject to the vagaries of annual appropriations. Until last year, this program operated under Section 10007 of the 2014 Farm Bill. With passage of a new Farm Bill, it is now designated as Section 7721 of the Plant Protection Act.

Since Fiscal Year 2018, APHIS has had authority to spend more than $60 million per year on this program.  In Fiscal Year 2017, , the program provided $120,000 to an unspecified federal agency, $70,000 to an academic institution in Puerto Rico (presumably the Center), $15,000 to another academic institution in California, and $3,000 divided among two APHIS facilities – for a total of $208,000. The next round of funds came in FY19, when the program provided $277,267 to an unspecified federal agency to continue work on biocontrol. In addition, the program provided $78,507 to an unspecified federal agency to “safeguard[e] genetic diversity of native and listed cacti threatened by Harrisia cactus mealybug in Puerto Rico”.

No Apparent Action on Threats to Opuntia Cacti

In my earlier blog, I also described the threat to flat-padded Opuntia (prickly pear) cacti from the cactus moth Cactoblastis cactorum. Various federal, state, and academic entities received $463,000 from the permanent fund in Fiscal Year 2016 and another $100,000 in FY2017. No cactus moth programs have received funds in more recent years.

SOURCES

Segarra-Carmona, A.E., A. Ramirez-Lluch. No date. Hypogeococcus pungens (Hemiptera: Pseudococcidae): A new threat to biodiversity in fragile dry tropical forests.

Segarra-Carmona, A.E., A. Ramírez-Lluch, I. Cabrera-Asencio and A.N. Jiménez-López. 2010.  FIRST REPORT OF A NEW INVASIVE MEALYBUG, THE HARRISIA CACTUS MEALYBUG HYPOGEOCOCCUS PUNGENS (HEMIPTERA: PSEUDOCOCCIDAE). J. Agrie. Univ. RR. 94(1-2):183-187 (2010)

Triapitsyn, Aguirre, Logarzo, Hight, Ciomperlik, Rugman-Jones, Rodriguez. 2018. Complex of primary and secondary parasitoids (Hymenoptera: Encyrtidae and Signiphoridae) of Hypogeococcus spp. mealybugs (Hemiptera: Pseudococcidae) in the New World. Florida Entomologist Volume 101, No. 3 411

USDA Agriculture Research Service, Research Project: Biological Control of the Harrisia Cactus Mealybug, Hypogeococcus pungens (Hemiptera:pseudococcidae) in Puerto Rico Project Number: 0211-22000-006-10 Project Type: Reimbursable

West Ortiz, M. pers. comm. February 2019

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.

Recent Developments on Stopping Emerald Ash Borer

post-EAB ash forest in southern Michigan; photo by Nate Siebert, USFS

1) The Risks of Reliance on Biological Control

An article published lately indicates yet another complication that might undercut reliance on biocontrol to counter mortality of eastern ash populations caused by the emerald ash borer (EAB) (See my blogs from November — here and here)  regarding APHIS’ proposal to eliminate EAB quarantines in favor of relying chiefly on biocontrol – with little data to back up the change.)

Olson and Rieske (full citation at the end of this blog) found that one of the principal biocontrol agents now in use, and on which APHIS proposes to rely, Tetrastichus planipennisi, does not parasitize EAB larvae living in white fringetree, Chionanthus virginicus. While this tree is a suboptimal host for EAB – lower numbers of the beetle survive – the white fringetree would support survival of some EAB – thereby undermining efficacy of the biocontrol program.

Since white fringetree grows a cross much of the eastern range of ash trees — from New York to Texas, as shown by the map posted here, the presence of this reservoir that can be exploited by EAB will challenge the efficacy of biocontrol.

Olson and Rieske believe the reason that T. planipennisi does not attack EAB living in white fringetree is that the fringetree’s wood is so dense that the wasp cannot detect the presence of EAB in the tree (T. planipennisi apparently relies on tactile and vibratory clues to find its prey).

2) A Possible New Biopesticide to Suppress EAB?

A presentation at the 81st Northeastern Forest Pest Council by Mark Ardis of C.D.G. Environment described tests in the United States and Canada of methods for killing EAB by contaminating the beetles with the fungus Beauveria bassiana. The company is testing traps in which male beetles enter, become covered by fungal spores, then they fly out. The males not only become ill themselves, they also contaminate females during mating. Average overall beetle mortality from several test sites is 25%.

Given the terrible impact of the EAB invasions, I find it exciting to contemplate development of additional tools to be used in suppressing the beetles. However, I worry about possible impacts on non-target insects which might also be exposed to the fungal spores. A decade ago, David Wagner identified 21 species of insects that were specialists on Fraxinus, and said he expected additional species would also be associated with ash trees (full citation at end of blog). Mr. Ardis assured me that they had detected no insects other than EAB in the traps. I wish to see additional research on this issue.

The  US Environmental Protection Agency would have to approve use of this biopesticide. I suggest that we all keep an eye on this process.

3) Citizen Scientists Searching for EAB- resistant “Lingering Ash”

Jonathan Rosenthal and Radka Wildova of the Ecosystem Research Institute have established a citizen science program to find ash trees that have survived the EAB invasion. These trees will become the foundation of efforts to breed more trees resistant to the EAB, which could be used to restore our forests.

The program is called “MaMa” – Monitoring and Managing Ash. So far, about 30 plots have been set up in New York, New Jersey, and Vermont where citizens are monitoring ash trees that have apparently survived the EAB invasion. The program seeks additional partners from other areas.

Searches for lingering ash must be strategically timed to ensure that the trees identified are truly resistant to EAB – not just late to become infested. But you can’t wait too long after the infestation wave has gone through an area, because the tree might die due to wind throw or human activity. Or, if a tree has just partial resistance (an important attribute for breeding!), it might eventually succumb. It is also imperative to avoid confusing stump sprouts with truly lingering ash. The conclusion: monitor the infestation and search for lingering trees two years after 95% of ash have been killed, or four years after 50% have been killed.

The MaMa program provides guidance, maps, electronic reporting systems … so you can help!

If you wish to participate – or to learn more – contact the program at monitoringAsh.org or 845-419-5229.

SOURCES

Olson, D.G. and L.K. Rieske. 2019. Host range expansion may provide enemy free space for the highly invasive emerald ash borer. Biol Invasions (2019) 21:625–635

Wagner, D.L. Emerald Ash Borer Threatens Ash-feeding Lepidoptera. 2007. News of the Lepidopterists’ Society. Volume 49, No. 1 (Spring 2007)

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.

USFS Lacks Sufficient Resources to Counter Threats to our Forests

We have long known that significant damage to our forests have been caused by non-native insects and diseases. Now USFS scientists have found that exacerbated mortality caused by these pests is showing up in official monitoring data – the Forest Inventory and Analysis (FIA) data. In a presentation at the 81st Northeastern Forest Pest Council, Randall Morin described the results of applying FIA data to determine  mortality levels caused by several of the most damaging invaders. He found an approximately 5% increase in total mortality volume nation-wide.

Morin also compared a map prepared by Andrew Liebhold showing the number of non-native tree-killing pests established in each county of the continent to the mortality rates for those counties based on the FIA data. (See two maps below.)

map showing number of non-native forest pests established in each county of the Continental States; from Liebhold/USFS
Dr. Randall Morin’s map showing levels of tree mortality, based on FIA data

Counties showing the highest mortality rates in FIA data do not align with counties with highest numbers of invasive species. Morin thinks the discrepancy is explained by such human factors as invasion pressure and the ease of pest movement through the good transportation network in the Northeast. He assigns less importance to habitat invasibility.

The increase in mortality above the background rate was the worst for redbay due to laurel wilt disease – the annual mortality rate rose from 2.6% to 10.9% — slightly more than a four-fold increase. Almost as great an increase in mortality rates – to approximately three-fold – was found for ash trees attacked by the emerald ash borer (from 2.6% to 10.9%); beech dying from beech bark disease (from 0.7% to 2.1%); and hemlock killed by hemlock woolly adelgid, hemlock looper, and other pests (from 0.5% to 1.7%).

Some species are presumed to have an elevated mortality rate, but the pre-invasion “background” rate could not be calculated. These included American chestnut (mortality rate of 7%), butternut succumbing to butternut canker (mortality rate of 5.6%), and elm trees succumbing to “Dutch” elm disease (mortality rate of 3.5%).

The non-native pests and pathogens that have invaded the largest number of counties are white pine blister rust (955 counties), European gypsy moth (630 counties), dogwood anthracnose (609 counties in the East; the western counties were not calculated); emerald ash borer (479 counties); and hemlock woolly adelgid (432 counties).

The invaders posing the most widespread threat as measured by the volume of wood of host species are European gypsy moth (230.9 trillion ft3), Asian longhorned beetle (120.5 trillion ft3), balsam woolly adelgid (61 trillion ft3), sudden oak death (44.6 trillion ft3), and white pine blister rust (27.7 trillion ft3).

The proportion of the host volume invaded by these non-native pests is 94% for white pine blister rust, 48% for balsam wooly adelgid, 29% for European gypsy moth, 12% for sudden oak death, and one half of one percent for Asian longhorned beetle.

Of course, measuring impact by wood volume excludes some of the species suffering the greatest losses because the trees are small in stature. This applies particularly to redbay, but also dogwoods. Also, American chestnut was so depleted before FIA inventories began that it is also not included – despite the species’ wide natural range and large size.

[You can see the details for particular species by visiting the FIA “dashboards”. A particularly good example is that for hemlock woolly adelgid, available here.

USFS Response

Of course, the Forest Service has been trying to counter the impact of invasive insects and pathogens for decades, long before this study documented measurable changes in mortality rates.

Unfortunately, funding for the agency’s response has been falling for decades – with concomitant reduction in staffs needed to carry out the work. See the graph below from p. 108 of my report, Fading Forests III, available here.

The President’s FY2020 budget proposes additional cuts.

The proposal would cut funding for the USFS Research division by $42.5 million (14%); cut staff  by 212 staff years (12.5%). It would refocus the research program on inventory and monitoring; water and biological resources; forest and rangeland management issues, especially fire; forest products innovations; and people and the environment.

As shown by the above graph, this proposed cut follows years of loss of expertise and research capacity.

The President’s budget proposes to slash the State & Private Forestry account by 45.6% – from $335 million to just $182 million. The critically important Forest Health Management program is included under State & Private Forestry. The cuts proposed for FHM are 7% for work done on federal lands (from $44.9 million to $41.7 million; and 16% for work done on non-federal “cooperative” lands (from $38 million to $31.9 million). Staffing would be reduced by 4% for those working on federal lands, a startling 38% for those working on cooperative lands.

For details, view the USDA Forest Service budget justification, which can be found by entering into your favorite search engine “FY2020 USFS Budget”. Funding details begin on p. 12; staffing number details on p. 15.

These severe cuts are proposed despite the fact that the budget justification notes that pests (native as well as exotic) threaten more than four million acres and that those pests know no boundaries. The document claims that the Service continues to apply an “all lands” approach.

When considering individual invasive pest species, these proposed cuts exacerbate reductions in previous years. Some cuts are probably justified by changes in circumstances, such as improved understanding of a species’ life cycle resulting from past research. However, some are still troubling. (Again, for details, view the USDA Forest Service budget justification, which can be found by entering into your favorite search engine “FY2020 USFS Budget”. A table listing species-specific expenditures in recent years, and the proposed FY2020 levels, is on pp. 38-39.)

The budget proposes to eliminate spending to manage Port-Orford-cedar root disease – which was funded at just $20,000 in recent years but received $200,000 as recently as FY2016. Forest Health Management would cease funding restoration for whitebark pine pests, including white pine blister – despite widespread recognition of the ecological importance of this species. Research on blister rust would continue, but at just over half the funding of recent years. Spending on oak wilt disease would be cut by 45%; funding for protecting hemlocks by 40% (the latter received $3.5 million in FY16). Funding for management of sudden oak death is proposed to be cut by 31% . Cuts to these programs seem particularly odd given that much of the threat is on federal lands – the supposed priority of the Administration’s budget.

The budget calls for a 12% cut in funding for the emerald ash borer – at the very time that USDA APHIS plans to terminate its regulatory program and state agencies and conservationists are looking to the Forest Service to provide leadership.

According to Bob Rabaglia, entomologist for the Forest Health Management program, the proportion of the FHM budget allocated to invasive alien species (as distinct from native pests) has been rising in recent years. Some of this increase is handled through a new “emerging pest” account. Species targeted by these funds, I have been told, include beach leaf disease; goldspotted oak borer; and the invasive polyphagous and Kuroshio shot hole borers.

Unfortunately, the “emerging pest” account funds are not included in the table on pp. 38-39 of the budget justification. Nor have I been able to learn from program staff how much money is in the fund and how much has been allocated to these or other pest or disease threats.

Adequate funding of the USFS Research and Forest Health Management programs could allow the agency to support, inter alia, efforts by agency and academic scientists to breed trees resistant to the damaging pest. I am aware, for example, of efforts to find “lingering” ash, beech, hemlock, whitebark pine, and possibly also redbay. None is adequately funded.

Please contact your member of Congress and Senators and urge them to support adequate funding for these two Forest Service programs. Research should be funded at $310 million (usually 5% or less of these funds is devoted to invasive species); Forest Health should be funded at $51 million for cooperative lands and $59 million for federal lands. It is particularly important to advocate for funding for the “cooperative lands” account since both the Administration and many members of Congress think the Forest Service should focus more narrowly on federal lands.

It is particularly important to contact your member if s/he is on the Interior Appropriations subcommittees. Those members are: 

House:

  • Betty McCollum, Chair  (MN 4th)
  • Chellie Pingree (ME 1st)
  • Derek Kilmer (WA 6th)
  • José Serrano (NY 15th)
  • Mike Quigley (IL 5th)
  • Bonnie Watson Coleman (NJ 12th)
  • Brenda Lawrence (MI 14th)
  • David Joyce, Ranking Member  (OH 14th)
  • Mike Simpson (ID 2nd)
  • Chris Stewart (UT 2nd)
  • Mark Amodei (NV 2nd)

Senate:

  • Lisa Murkowski, Chair (AK)
  • Lamar Alexander (TN)
  • Roy Blunt (MO)
  • Mitch McConnell (KY)
  • Shelly Moore Capito (WV)
  • Cindy Hyde-Smith (MS)
  • Steve Daines (MT)
  • Marco Rubio (FL)
  • Tom Udall, Ranking (NM)
  • Diane Feinstein (CA)
  • Patrick Leahy (VT)
  • Jack Reed (RI)
  • Jon Tester (MT)
  • Jeff Merkley (OR)
  • Chris van Hollen  (MD)

Posted by Faith Campbell

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

Support Adequate Funding for Key USDA Programs

The people who work here work for us!!!

As I have written often, inadequate funding is a major cause of shortfalls in USDA APHIS’ efforts to detect new invasions by tree-killing pests and to respond to those invasions in effective ways. So, I ask you to contact your Representative and Senators in support of appropriations for APHIS and –National Institute for Food and Agriculture (NIFA) for the next fiscal year – (FY)2020.

APHIS’ efforts to detect and respond to non-native tree-killing pests were rudely interrupted by the five-week Government Shutdown from 22 December until late January. While inspection of incoming shipments continued, U.S.-based activities were halted. Chaos and confusion continued until 15 February, when the President signed legislation that funds APHIS (and other government agencies) until the end of September – the remainder of FY2919.

Surprise! The funding bill provides increased funds for two key APHIS programs:

  • $60 million for the “tree and wood pests” program — $4 million above the funding provided in recent years; and
  • $186 million for “specialty crop” pests (including sudden oak death) — $7.8 million above recent levels. 

I ask you to ask the Congress to maintain these funding levels for these budget “lines”.

I ask you also to support continuing the FY19 levels for two other programs:

  • Methods Development — $27.4 million; and
  • “Detection Funding” – $20. 7 million.

New this year, I hope you will support a $10 million appropriation to the National Institute of Food and Agriculture to fund a competitive grant program intended to restore to forests tree species significantly damaged by non-native insects and plant pathogens.

Justification for the Funding Requests

As we know, non-native insects and pathogens that threaten native tree species have been and continue to be introduced to the United States. These pests impose significant costs: Aukema et al. 2011 (full reference at the end of the blog) estimated

  • municipal governments spend more than $2 billion per year to remove trees on city property that have been killed by these pests.
  • homeowners spend $1 billion every year to remove and replace trees on their properties
  • homeowners absorb an additional $1.5 billion in reduced property values.

Costs are rising: the polyphagous and Kuroshio shot hole borers are projected to cost municipalities and homeowners in California $36.2 billion if their further spread is not prevented (McPherson 2017)

When you contact your Representative or Senators, tell them about the impact of non-native pests in your location!

The significant ecological impacts are poorly quantified.

USDA APHIS is responsible for preventing such pests’ entry, detecting newly introduced pests, and initiating rapid eradication programs. Yet, despite rising risks of pest introduction commensurate with rising import volumes, funding for APHIS’ program targetting the “tree and wood pests” associated with crates and pallets has remained at or below $55 million since FY2012 – until the modest increase last year to $60 million. Among the forest pests detected during this period are the spotted lanternfly and here and Kuroshio shot hole borer.

Among the pests probably introduced on a second pathway, imports of living plants, are the two pathogens threatening Hawaii’s most widespread tree, ʻōhiʻa lehua and here, and beech leaf disease and here in the Northeastern states. The better-funded “specialty crops” account could help fund responses to these damaging pathogens.

Ask your Congressional representatives to urge APHIS to apply part of the increased funding for the “tree and wood pest” program to continue the regulatory program for the emerald ash borer (EAB) and here. In September, APHIS has proposed to terminate the EAB regulatory program. Program termination would greatly increase the risk that EAB will spread to the mountain and Pacific Coast states. California has five native species of ash vulnerable to EAB. Ash trees provide a higher percentage (8%) of Los Angeles’ tree canopy than any other species. This proportion will rise as other tree species succumb to the polyphagous and Kuroshio shot hole borers. Oregon’s one native species of ash is widespread in riparian areas and many urban plantings consist of ash. Ash trees are the fifth most common genus among Portland’s urban trees. Many stakeholders have urged APHIS to continue to regulate movement of firewood and other materials that facilitate EAB’s spread.

The “Specialty Crops” program currently funds APHIS’ regulation of nursery operations to prevent spread of the sudden oak death pathogen. In future, this budget line would be the logical source of funds to manage the spotted lanternfly, which has been carried out through a combination of emergency funding under 7 U.S.C. §7772 and grants funded through the Plant Pest and Disease Management and Disaster Program (§7721 of the Plant Protection Act). (See below.)

Ask your Congressional representatives to support continued funding of APHIS’ “Methods Development” program at the FY19 level of $27.4 million. This program assists APHIS in developing detection and eradication tools essential for an effective response to new pests.  

Similarly, ask your Congressional representatives to support continued funding of the “Detection” budget line at the FY19 level of $20.7 million. This program supports the critically important collaborative state –federal program pest-detection program that is critical to successful eradication and containment programs.

APHIS’ Additional sources of funds

APHIS has always had authority to obtain “emergency” funds through 7 U.S.C. §7772. Emergency funds come from permanent USDA funding; they are not subject to annual appropriations. This authority has been tightly controlled by the Office of Management and Budget; I believe the last time APHIS obtained “emergency” funds for a tree pest was the emerald ash borer a decade or more ago. A year ago, APHIS accessed $17 million in emergency funding to address the expanding spotted lanternfly outbreak [USDA Press Release No. 0031.18 February 7, 2018] and OMB also requires that APHIS quickly transfer programs started with emergency funds to the regular budget. As I note above, response to the expanding spotted lanternfly outbreak should logically be shifted to the “specialty crops” budget account.

For a decade, APHIS has had access to a separate source of funds: the Plant Pest and Disease Management and Disaster Prevention Program. This program is also funded through permanent funds, not subject to the vagaries of annual budgeting and appropriations. Until last year, this program operated under Section 10007 of the 2014 Farm Bill; with passage of a new Farm Bill last year, it is now designated as Section 7721 of the Plant Protection Act. Beginning in Fiscal Year 2018, APHIS has authority to spend up to $75 million per year.

Funds are provided under a competitive grants program to universities, states, Federal agencies, nongovernmental organizations, non-profits, and Tribal organizations “to conduct critical projects that keep U.S. crops, nurseries, and forests healthy, boost the marketability of agricultural products within the country and abroad, and help us do right and feed everyone.” [USDA press release “USDA Provides $66 Million in Fiscal Year 2019 to Protect Agriculture and Natural Resources from Plant Pests and Diseases” February 15, 2019]

Over the decade since the program began, it has funded, but my calculation, about $77 million in projects targetting tree-killing pests. The proportion of total program funding allocated to tree-killing pests has risen in the most recent years, driven largely by funding to counter the spotted lanternfly outbreak which began in Pennsylvania but has since spread (see above). In the current year (FY2019), APHIS used this program to fund $10 million in projects to address the spotted lanternfly. The SLF funds equaled 57% of the total funding for tree pests provided under the program in FY2019.

Implications of the Tangle of Funding Sources

What is the significance of funding programs through the Plant Pest and Disease Management and Disaster Prevention Program as distinct from appropriated funds? Clearly, having access to $75 million that is not subject to the limits imposed by Administration budget priorities or Congressional appropriations allows considerable freedom. Does this freedom allow APHIS to support work on pests that might not qualify to be “quarantine” pests?  For example, under the Plant Protection Act, APHIS normally does not engage on pests found only in one state. The polyphagous and Kuroshio shot hole borers fall into this category. So did the spotted lanternfly for the first several years – until its detection in Delaware and Virginia in late 2017. If so, then the presence of the lanternfly in several states would seem now to indicate that funding sources should be shifted – at least in part – to appropriated funds. But would such a shift result in less funding – a result I think would be most unwise!

The beech leaf disease doesn’t clearly qualify for designation as a “quarantine pest” because of the uncertainty about the causal agent. So far, there has been no Section 7721 funding to support efforts to identify the causal agent or to improve detection or curtail spread of the disease.

a blight-resistant chestnut bred by the American Chestnut Foundation; photographed in Fairfax County, Virginia by F.T. Campbell

Funding for Resistance Breeding through NIFA

As we know, dozens of America’s tree species have been severely reduced or virtually eliminated from significant parts of their ranges by non-native insects and pathogens. Last year’s Farm Bill – the  Agriculture Improvement Act of 2018 – included an amendment (Section 8708) that establishes a new priority for an existing grant program to support restoration to the forest of native tree species that have suffered severe levels of mortality caused by non-native insects, plant pathogens, or other pests. Grant-receiving programs would incorporate one or more of the following components: collection and conservation of native tree genetic material; production of sufficiently numerous propagules to support landscape-scale restoration; and planting and maintenance of seedlings in the landscape.

In January a panel of the National Academies of Sciences, Engineering, and Medicine recommended that the U.S. apply multifaceted approaches to combat these threats to forest health. One component strategy is breeding of trees resistant to the pest.

Ask Congress to begin applying the Academies’ recommendation by providing $10 million to NIFA to fund the Competitive Forestry, Natural Resources, and Environmental Grants Program under Section 1232(c)(2) of the Food, Agriculture, Conservation, and Trade Act of 1990 (16 U.S.C. 582A-8, as amended.

I hope everyone will contact your Representative and Senators. If your Congressional representative is listed below, your contact is particularly helpful because these are the members of the House or Senate Agriculture Appropriations subcommittees – the people with the greatest influence over what gets funded:

House Agriculture Appropriations subcommittee members:

  • Sanford Bishop Jr., Chairman 
  • Rosa DeLauro                                      CT
  • Chellie Pingree                                     ME
  • Mark Pocan                                         WI
  • Barbara Lee                                         CA
  • Betty McCollum                                  MN
  • Henry Cuellar                                      TX
  • Jeff Fortenberry, Ranking Member      NE
  • Robert Aderholt                                               AL
  • Andy Harris                                         MD
  • John Moolenaar                                               MI

Senate Agriculture Appropriations subcommittee members:

  • John Hoeven, Chairman                                  ND
  • Mitch McConnell                                 KY
  • Susan Collins                                       ME
  • Roy Blunt                                            MO
  • Jerry Moran                                         KS
  • Cindy Hyde-Smith                               MS
  • John Kennedy                                     LA
  • Jeff Merkley                                        OR
  • Dianne Feinstein                                  CA
  • Jon Tester                                            MT
  • Tom Udall                                           NM
  • Patrick Leahy                                       VT
  • Tammy Baldwin                                  WI

SOURCES

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

McPherson, Gregory. September 28, 2017. Memorandum to John Kabashima re: Potential Impact of ISHB-FD on Urban Forests of Southern California

Spotted Lanternfly – Government Shut-Down Hampered Vital Effort at Crucial Time

spotted lanternfly; photo by Holly Raguza, Penn. Dept. of Agriculture

I last blogged about the spotted lanternfly (Lycorma delicatula) two years ago. At that time, this insect from Asia (where else?) was established in some portions of six counties in southeastern Pennsylvania. While its principal host is tree of heaven (Ailanthus altissima), it was thought to feed on a wide range of plants, especially during the early stages of its development. Apparent hosts included  many of the U.S.’s major canopy and undertory forest trees, e.g., maples, birches, hickories, dogwoods, beech, ash, walnuts, tulip tree, tupelo, sycamore, poplar, oaks, willows, sassafras, basswood, and elms. The principal focus of concern, however, is the economic damage the lanternflies cause to grapes, apples and stone fruits (e.g., peaches, plums, cherries), hops, and other crops.

In the two years since my first blog, the spotted lanternfly has spread – both through apparent natural flight (assisted by wind) and through human transport of the egg masses and possibly adults. By autumn 2018, detections of one or a few adults – alive or dead – had been found in six additional states: Connecticut, Delaware, Maryland, New Jersey, New York, and Virginia.

spotted lanternfly quarantines (blue) & detection locations (yellow)
prepared by Cornell University

How many of these detections signal an outbreak?  It is too early to know.

Impacts of the Government Shutdown

Unfortunately the federal government shutdown forced the cancellation of the annual USDA invasive species research meeting that occurs each January. The spotted lanternfly was to be the focus of six presentations. The most important of these was probably APHIS’ explanation of “where we are and where we are going.” The cancellation eliminated one of the most important opportunities for researchers to exchange information and ideas that could spur important insights. Equally important, the cancellation hampered communication of insights to practitioners trying to improve the pest’s management.

One pressing question was not on the meeting’s agenda, however. Would a much more aggressive and widespread response in 2014, when the lanternfly was first detected, have  eradicated this initial outbreak?  I have long thought that this question should be asked for every new pest program, so that we learn whether a too-cautious approach has doomed us to failure. However, authorities never address the issue – at least not in a public forum.

The shutdown also had an even more alarming impact. It interruptedaid by USDA APHIS and the Forest Service to states that should be actively trying to answer this question. Winter is the appropriate season to search for egg masses.  It is also the season to plan for eradication projects. 

spotted lanternfly egg mass; New York Department of Environmental Conservation

For the first several years, funding of studies of the lanternfly’s lifecycles and host preferences, research on possible biological or chemical treatments, and outreach and education came in the form of competitive grants under the auspices of the Farm Bill Section 10007.  This funding totaled $5.5 million to Pennsylvania.

This commitment pales compared to Asian longhorned beetle or emerald ash borer h— which were also poorly known when they were first detected in the United States.

At the same time, the Pennsylvania infestation spread. It is now known to be established in portions of 13 counties and outbreaks were detected in neighboring Delaware and Virginia. h

This spread – and resulting political pressure – persuaded APHIS to multiply its engagement. A year ago, USDA made available $17.5 million in emergency funds from the Commodity Credit Corporation (that is, the funds are not subject to annual Congressional appropriation). APHIS said it would use the additional funds to expand its efforts to manage the outer perimeter of the infestation while the Pennsylvania Department of Agriculture would focus on the core infested area. APHIS said it would use existing (appropriated) resources to conduct surveys, and control measures if necessary, in Delaware, Maryland, New Jersey, New York and Virginia.

Summary of Latest Status in the Seven States

(see also the write-up here)

Pennsylvania: infestation established (quarantine declared) in portions of thirteen counties (Berks, Bucks, Carbon, Chester, Delaware, Lancaster, Lebanon, Lehigh, Monroe, Montgomery, Northampton, Philadelphia, Schuylkill). The quarantine regulates movement of any living stage of the insect brush, debris, bark, or yard waste; remodeling or construction waste; any tree parts including stumps and firewood; nursery stock; grape vines for decorative or propagative purposes; crated materials; and a range of outdoor household articles including lawn tractors, grills, grill and furniture covers, mobile homes, trucks, and tile or stone. See the regulation here: https://www.agriculture.pa.gov/Plants_Land_Water/PlantIndustry/Entomology/spotted_lanternfly/quarantine/Pages/default.aspx

Delaware: The state had been searching for the insect since the Pennsylvania outbreak was announced. After detection of a single adult female in New Castle County in November 2017, survey efforts and outreach to the public were intensified. Another dead adult spotted lanternfly was found in Dover, Delaware, in October 2018.  

Virginia: infestation established (quarantine declared) in one county. Multiple live adults and egg cases of spotted lanternfly were confirmed in the town of Winchester, Virginia (Frederick County), in January 2018.   As noted in my earlier blog, this region is important for apple and other orchard crops and near Virginia’s increasingly important wine region.

New Jersey: The New Jersey Department of Agriculture began surveying for lanternflies along the New Jersey-Pennsylvania border (the Delaware River) once the infestation was known. It found no lanternflies before 2018. In the summer, however, live nymphs were detected in two counties, Warren and Mercer. In response, the state quarantined both those counties and one located between them, Hunterdon. The state planned to continue surveillance in the immediate areas where the species has been found as well as along the Delaware River border in New Jersey.  

New York: In 2017, a dead adult lanternfly was found in Delaware County. 

State authorities expressed concern about possible transport of lanternflies from the Pennsylvania infested area.

In Autumn 2018, New York authorities confirmed several detections, including a single adult in Albany and a second single adult in Yates County. In response, the departments of Environmental Conservation and Agriculture and Marketing began extensive surveys throughout the area. Initially they found no additional lanternflies.

However, a live adult was later detected in Suffolk County (on Long Island).

Connecticut:  a single dead adult was found lying on a driveway at a private residence in Farmington, CT, in October 2018. The homeowner was a state government employee educated about the insect. Relatives had recently visited from Pennsylvania (Victoria Smith, Connecticut Agricultural Experiment Station, pers. comm.). Searches found no other spotted lanternflies on the property. The state plans additional surveys in the area to confirm that no other spotted lanternflies are present.  

Maryland: A single adult spotted lanternfly (male) was caught in a survey trap in the northeast corner of Cecil County near the border of Pennsylvania and Delaware (an area of known infestation) in October 2018. Because of the lateness of the season and sex of the insect, the Maryland Department of Agriculture does not believe that the lanternfly has established there.

All the affected states are encouraging citizens to report any suspicious finds.

Posted by Faith Campbell

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

Is EAB deregulation necessary? Is it helpful? What is at risk?

EAB risk to Oregon & Washington

USDA APHIS has formally proposed to end its regulatory program aimed at slowing the spread of the emerald ash borer (EAB) within the United States.  APHIS proposes to rely on biological control to reduce impacts and – possibly – slow EAB’s spread.  The proposal and accompanying “regulatory flexibility analysis” are posted here.

Public comments on this proposed change are due 19 November, 2018.

I will blog more fully about this issue in coming weeks. At present, I am on the fence regarding this change.

On the one hand, I recognize that APHIS has spent considerable effort and resources over 16 years trying to prevent spread of EAB – with less success than most would consider satisfactory. (EAB is known to be in 31 states and the District of Columbia now). While APHIS received tens of millions of dollars in emergency funding in the beginning, in recent years funding has shrunk. Over the past couple of years, APHIS has spent $6 – $7 million on EAB out of a total of about $54 million for addressing “tree and wood pests.” (See my blogs on appropriations by visiting www.cisp.us, scrolling down to “topics,” then scrolling down to “funding”). Funding has not risen to reflect the rising number of introduced pests. Presumably partly in response, APHIS has avoided initiating programs targetting additional tree-killing pests. For example, see my blogs on the shot hole borers in southern California and the velvet longhorned beetle by visiting www.cisp.us, scrolling down to “categories,” then scrolling down to “forest pest insects”. I see a strong need for new programs on new pests and money now allocated to EAB might help fund such programs.

 

On the other hand, APHIS says EAB currently occupies a quarter of the range of ash trees in the U.S. Abandoning slow-the-spread efforts put at risk trees occupying three quarters of the range of the genus in the country. (See APHIS’ map of infested areas here.) Additional ashes in Canada and Mexico are also at risk. Mexico is home to 13 species of ash – and the most likely pathway by which they will be put at risk to EAB is by spread from the U.S. However, APHIS makes no mention of these species’ presence nor USDA’s role in determining their fate.

I am concerned by the absence of information on several key aspects of the proposal.

  • APHIS makes no attempt to analyze the costs to states, municipalities, homeowners, etc. if EAB spreads to parts of the country where it is not yet established – primarily the West coast. As a result, the “economic analysis” covers only the reduced costs to entities within the quarantined areas which would be freed from requirements of compliance agreements to which they are subject under the current regulations. APHIS estimates that the more than 800 sawmills, logging/lumber producers, firewood producers, and pallet manufacturers now operating under compliance agreements would save between $9.8 M and $27.8 million annually. This appears to be a significant benefit – but it loses any meaning absent any estimate of the costs that will be absorbed by governments and private entities now outside the EAB-infested area.

ash tree killed by EAB; Ann Arbor, MI; courtesy of former mayor of Ann Arbor, MI John Hieftje

  • APHIS does not discuss how it would reallocate the $6 – 7 million it spends on EAB.  Would it all go to EAB biocontrol? Would some be allocated to other tree-killing pests that APHIS currently ignores?

 

  • APHIS provides no analysis of the efficacy of biocontrol in controlling EAB. It does not even summarize studies that have addressed past and current releases of EAB-specific biocontrol agents. (I will report on my reading of biocontrol studies in a future blog.)

 

  • APHIS says efforts are under way to develop programs to reduce the risk of pest spread via firewood movement. APHIS does not explain what those efforts are or why they are likely to be more effective than efforts undertaken in response to recommendations from the Firewood Task Force issued in 2010.

 

  • APHIS makes no attempt to analyze environmental impacts.

champion green ash in Michigan killed by EAB

  • APHIS says nothing about possibly supporting efforts to breed ash trees resistant to EAB.

 

I welcome your input on these issues.

I will inform you of my evolving thinking, information obtained in efforts to fill in these gaps, etc. in future blogs.

 

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.

 

 

Challenges to Phytosanitary Programs are International, Not Just in the U.S. How Should We Join Efforts to Defend Them?

 

dead ash killed by emerald ash borer; photo by Dan Herms, The Ohio State University; courtesy of Bugwood.com

I have blogged often about the funding crisis hampering APHIS’ efforts to protect our forests from damaging insects and pathogens (visit www.cisp.us, scroll down to “categories”, then scroll down to “funding”). Apparent results of this funding crisis include APHIS’ failure to adopt official programs to address several tree-killing pests (e.g., polyphagous and Kuroshio shot hole borers, goldspotted oak borer, spotted lanternfly …) and its proposal this month to end the regulatory program intended to slow the spread of the emerald ash borer (available here.)  (All these tree-killing pests are described here.)

The lack of adequate resources plagues phytosanitary programs in many countries as well as at the international and regional level. As we know, the threat of introduction and spread of plant pests is growing as a result of increasing trade volume and transportation speed; increasing variety of goods being traded; and the use of containers. All countries and international bodies should be expanding efforts to address this threat, not cutting back.

Assuming you agree with me that preventing and responding to damaging plant pests is important – a task which falls within the jurisdiction of phytosanitary institutions – what more can we do to raise decision-makers’ and opinion leaders’ understanding and support? Should we join phytosanitary officials’ efforts – e.g., the International Year of Plant Health – or act separately?

How do we encourage greater engagement by such entities as professional and scientific associations, the wood products industry, state departments of agriculture, state phytosanitary officials, state forestry officials, forest landowners, environmental organizations and their funders, urban tree advocacy and support organizations. (The Entomological Society of America has engaged on invasive species although it remains unclear to me whether ESA will advocate for stronger policies and higher funding levels.)

There is one group making serious, multi-year efforts to respond. Here, I describe efforts by the International Plant Protection Convention’s (IPPC) governing body, the Commission on Phytosanitary Measures. The Commission has recognized the crisis and is attempting to reverse the situation through a coordinated strategy. I invite you to consider how we all might take part in, and support, its efforts.

Efforts of the IPPC Commission on Phytosanitary Measures

The Commission’s goal is to ensure that strong and effective phytosanitary programs “become a national and global priority that justifies and receives appropriate and sustainable support.”  It seeks to achieve this by convincing decision-makers that protecting plant health from pest threats is an essential component of efforts to meet other, more broadly accepted goals, specifically the United Nations’ 2030 Sustainable Development Agenda and the Food and Agriculture Organization’s (FAO) related goals (described here).

The IPPC Commission also sees that, to succeed, it must more effectively support member countries in improving their programs to curtail pests’ spread and impacts. IPPC plans to streamline operations and integrate more closely with other FAO work in order to save money.

The following are among Commission efforts, although all are hampered by the lack of funding:

  • Working with member countries, the Commission has persuaded the United Nations to declare 2020 the International Year of Plant Health. (I blogged about this campaign in December 2016.
  • Describing links between plant health and other policy goals. The Commission is mid-way through a multi-year program. One outcome has been presentations to member states’ phytosanitary officials attending the Commission’s annual meetings, each focusing on one specific aspect. In 2018, presentations focus on links between plant health and environmental protection (presentations from April 2018 are available here). (Did you know 2018 was the year of plant health and the environment?  I didn’t!) In 2016, the topic was plant health’s link to food security; in 2017, plant health and trade facilitation; in 2019, capacity development for ensuring plant health.)
  • Adopting a Communications Strategy. It has four broad objectives (available here).
  • increase global awareness of the importance of the IPPC and of the vital importance to the world of protecting plants from pests;
  • highlight the IPPC’s role as the sole international plant health standard setting organization aimed at improving safety of trade of plants and plant products and improving market access;
  • improve implementation of IPPC’s international standards (ISPMs); and
  • support the activities of the IPPC Resource Mobilization program.
  • Ramping up efforts to support implementation of its international standards. Since this 2014 decision, the Commission has conducted some pilot projects, restructured the Secretariat, and formed the Implementation and Capacity Development Committee. (I have blogged frequently about issues undermining one of those standards, the one on wood packaging material – ISPM#15. Visit www.cisp.us, scroll down to “categories”, then scroll down to “wood packaging”.)

Framework 2020-2030: the IPPC Strategic Plan

The IPPC is now finalizing its strategic plan (Framework 2020-2030), which is available here. APHIS circulated this plan in July for comment; I admit did not take the opportunity to comment because I could think of nothing to add. But now I want to link the international and domestic U.S. funding crises.

The plan describes how plant pests threaten

  • food production at a time rising human population and demand;
  • sustainable environments and ecosystem services at a time when recognition is growing of their importance for managing climate change and meeting food production goals;
  • free trade and associated economic development;

The plan notes that interactions between climate change and pests’ geographic ranges and impacts complicate efforts to address both threats. Also, it outlines the need for, and barriers hindering, collaborative research on plant pest. It suggests creation of an international network of diagnostic laboratories to support reliable and timely pest identifications.

The plan states several times that the IPPC is “the global international treaty for protecting plant resources (including forests, aquatic plants, non-cultivated plants and biodiversity) from plant pests …” (emphasis added). The Commission is attempting to improve its efforts to protect the environment through expanding its collaboration with the Convention on Biological Diversity, Global Environmental Facility and the Green Climate Fund. Much of the attention to environmental concerns is focused on interactions with climate change, followed by concerns about pesticide use. Indeed, the strategic plan states that “Political weight and subsequent funding for phytosanitary needs on national, regional and international level will only be available when phytosanitary issues are recognized as an important component of the climate change debate.”

The Plan describes other ways that the Commission and regional plant protection organizations might help countries overcome the major problems arising from their lack of capacity and resources. Another area of hoped-for activity is promoting collaborative research. All these proposals depend on finding funding.

However, the Strategic Plan does not reveal the extent to which its 2013 Communications Strategy has been implemented. Nor does it reveal the extent to which the effort to improve ISPM implementation has resulted in concrete progress.

 

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.

 

Farm Bill Update – Please Thank Your Senators Right Away!

U.S. Senate

In May I blogged about adoption by the House of Representatives of its version of the Farm Bill, which will govern a wide range of policies for the next five years. I reported that the bill included weakened versions of a provision CISP has been seeking to establish programs to support long-term strategies to counter non-native, tree-killing insects and pathogens, e.g., biocontrol and breeding of trees resistant to pests.

I also reported that the House Farm bill contains provisions to which there is significant opposition from the larger environmental community. Several would gut some of our country’s fundamental environmental laws which have protected our health and natural resources since the early to mid-1970s. These provisions would:

  • Allow the U.S. Forest Service and the Interior Department’s Bureau of Land Management to decide for themselves whether an activity might “jeopardize” an endangered species (eliminating the need to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service) (Section 8303 of the House Bill);
  • Allow the U.S. Forest Service and Bureau of Land Management to avoid preparing an environmental assessment under the National Environmental Policy Act (NEPA) for a long list of actions which currently must be assessed. That is, they could claim a “categorical exclusion” when taking a wide variety of “critical” actions aimed at addressing several goals. These include countering insect and disease infestations, reducing hazardous fuel loads, protecting municipal water sources, improving or enhancing critical habitat, increasing water yield, expediting salvage of dead trees following a catastrophic event, or achieving goals to maintain early successional forest. These “categorical exclusions” would apply to projects on up to 6,000 acres. (Sections 8311 – 8320); and
  • Require the EPA Administrator to register a pesticide if the Administrator determines that the pesticide, when used in accordance with widespread and commonly recognized practices, is not likely to jeopardize the survival of a species listed under the Endangered Species Act or to alter critical habitat. That is, the Administrator would not be required to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service when making such determinations unlike under current law. (Section 9111).

The Senate passed its version of the Farm Bill in late June. Unfortunately, the Senate bill does not include the long-term restoration program CISP seeks. However, it doesn’t include the above attacks on environmental laws, either.

With the current Farm Bill set to expire on September 30th, there is considerable pressure to adopt a final version soon.  House and Senate staffers have been meeting to find common ground. Representatives and Senators who are on the joint Conference Committee – charged with working out the final bill – will hold their first meeting next week, on September 5th.

In preparation for the meetings of the Conference Committee, 38 Senators have written to their two colleagues who will lead the Senate conferees. Their letter voices strong opposition to changing long-standing environmental law:

“These harmful riders, spread throughout the Forestry, Horticulture, and Miscellaneous titles of the House bill, subjected the legislation to unnecessary opposition on the House floor and now complicates [sic] the bipartisan cooperation needed to pass a final conference report.

Again, we write to express our strong opposition to gutting bedrock U.S. environmental and public health protections with provisions that threaten our air, water, lands, and wildlife.”

Senators signing the letter are:

California: Feinstein & Harris;    Colorado: Bennet;    Connecticut: Murphy & Blumenthal;    Delaware: Carper & Coons;    Florida: Nelson;    Hawai`i: Hirono & Schatz;    Illinois: Durbin & Duckworth;    Maryland: Cardin & Van Hollen;    Massachusetts: Warren & Markey;    Minnesota: Klobuchar &  Smith;    Michigan: Peters;    Nevada: Cortez Masto;    New Hampshire: Shaheen & Hassan;    New Jersey: Menendez & Booker;    New Mexico: Udall & Heinrich;    New York: Gillibrand;    Oregon: Wyden & Merkley;    Pennsylvania: Casey; Rhode Island:    Reed & Whitehouse;    Vermont: Sanders;    Virginia: Warner & Kaine;    Washington: Murray & Cantwell;    Wisconsin: Baldwin.

If your Senators signed the letter, please email, call, or write to thank them immediately. If your Senators didn’t  – please urge them to express their support for its content.

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.