forest pests – Page 21 – Center for Invasive Species Prevention

The New Year – Where We Are & What Needs to be Done

dying ash tree, Fairfax County, Virginia; photo by F.T. Campbell

According to Aukema et al. 2010 (see references at the end of this blog), by the first decade of the 21^st Century, the number of non-native insects and pathogens damaging our forests had risen to at least 475. Sixty-two of the insects, and all of the 17 pathogens, were judged to have “high impact”, with both economic and ecological ramifications. More than 181 exotic insects that feed on woody plants are established in Canada (USDA APHIS 2009). Especially hard-hit is the eastern deciduous broadleaf forest — there is an exotic pest threat to nearly every dominant tree species in this ecosystem type.

The situation is actually worse than this article and others based on it depict. Aukema et al. 2010 did not include several highly damaging forest pests that are native to regions of North America (e.g., goldspotted oak borer, thousand cankers disease); nor did they include pests on U.S. islands, such as `ohi`a rust and Erythrina gall wasp in Hawai`i. Aukema et al. 2010 also did not include pests that attack palms or cycads – which are significant components of some ecosystems on the continent as well as on America’s tropical islands. Finally, some invaders have come to our attention since the database on which these authors relied was compiled, e.g., polyphagous and Kuroshio shot hole borers and the rapid ohia death pathogen. (For a list of pests detected since 2003, see page 7 of Fading Forests III, available here; this list was compiled in 2014, so it does not include the most recently detected pests, such as rapid ohia death. For descriptions of most invaders discussed in this blog, go here.)

Of course, more important than numbers are impacts. Lovett et al. 2016 provide a summary of those impacts … but let’s get specific. Note that some of these species occupy wide ranges; it is not only the narrow endemics that are under threat.

Several tree species are severely depleted throughout their ranges: American chestnut, Fraser fir, Port-Orford cedar, butternut, Carolina hemlock, redbay and swamp bay, cycads on Guam
Other species or genera are already severely reduced in significant portions of their ranges and the causal agents are spreading to the remaining sanctuaries: whitebark pine.
In some cases, the causal agent has not yet spread, but threatens to: `ohi`a.
Some tree or shrub taxa are under severe attack across much of their ranges: ashes, eastern hemlock, American beech, dogwoods, tanoak, viburnums …

Many of America’s 300 species of oak face a variety of threats:

in the East, European gypsy moth, oak wilt, and – in some areas – winter moth;
in the South, oak wilt and Diplodia;
on the West coast, sudden oak death, goldspotted oak borer, the polyphagous and Kuroshio shot hole borers, Diplodia, and foamy bark canker.

(For more about threats to oaks, see my blog from last April.)

Other threats are – so far – confined to relatively small areas, but they could break out. These include the multi-host insects Asian longhorned beetle; polyphagous and Kuroshio shot hole borers; and spotted lanternfly. Tree genera containing species at risk to one or more of these insects include maple, elm, willow, birch, sycamore, cottonwood and poplar, sweet gum, oak. Only ALB and the lanternfly currently are the focus of federal and state programs aimed at eradication or containment. The widespread invasive tree, Ailanthus or tree of heaven, could support spread of at least the polyphagous shot hole borer and spotted lanternfly.

Of course, additional pests are likely to be introduced (or detected) in the future. Known threats include the various Asian subspecies of gypsy moth and ash dieback (Hymenoscyphus fraxineus – previously called Chalara fraxinea). If history is any guide, we are likely to be surprised by a highly destructive invader that we have either never heard of or dismissed based on its behavior elsewhere. See my earlier blogs for discussions of what should be done to reduce the introduction risk associated with wood packaging and imports of living plants.

What Should We Do?

2017 brings a new Administration and a new Congress. At a minimum, we need to educate all these decision-makers about both the high costs imposed by tree-killing insects and pathogens and effective strategies to minimize those costs. How will our concerns be received? We don’t know yet.

We might have opportunities arising from the skeptical attitude toward trade voiced during the campaign. Will newly elected or appointed agency and Congressional staffers be open to re-considering the plant health threats associated with international trade? On the other hand, will mainstream agriculture’s traditional strong support for exports continue to overwhelm calls to strengthen phytosanitary measures? Even if our message about risks associated with trade gains a hearing, will officials be willing to consider more rigorous regulations? Or higher funding levels for agencies responsible for plant pest prevention and response?

I hope you will join the Center for Invasive Species Prevention and others in coordinated efforts to take these messages to the next Secretary of Agriculture (who has not yet been named!) and key members of the Senate and House of Representatives. Opportunities in the Congress include Senate confirmation of the new Secretary and the three Under Secretaries that oversee APHIS, USFS, and ARS; annual appropriations bills; and early consideration of possible amendments to the Farm Bill (which is due for renewal in 2019).

See my post from a week ago for more suggestions for how Congress could improve U.S. invasive species management programs.

Expect to hear from me often in the coming year!

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

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, S.L. LaDeau, and T. Weldy. 2016. Nonnative forest insects and pathogens in the United States: Impacts and policy options. Ecological Applications, 0(0), 2016, pp. 1–19. DOI 10.1890/15-1176.1

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

Posted by Faith Campbell

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

Invasive insects cause tens of billions in damage

Formosan subterranean termite damage to a house in New Orleans; observed by Ed Freytag & Alan Lax; photo by Scott Bauer, USDA Agricultural Research Service; bugwood.org

A recent study documents the high costs imposed by invasive insects worldwide. The study, by Bradshaw et al. (source with link is at the end of this post) concluded that invasive insects cause at least $77 billion (US) in damage every year. This figure includes costs of $70 billion in estimates of damaged goods and service; and $6.9 billion in associated health costs.

What is more, this figure is “grossly underestimated” for a number of reasons:

There were few studies providing cost estimates. The authors started by reviewing more than 700 articles, but found that only 158 yielded usable economic estimates.
Most of the studies applied to North America and Europe; much of the globe is not included.
Ecosystem services eroded by invasive pests are rarely quantified.
The health cost estimate does not include the impact of malaria (in most areas, the vector is native rather than invasive), the Zika virus, or economic losses in tourism or productivity (these latter were too difficult to calculate).

While the most destructive of the insects identified in the reports was the Formosan subterranean termite, Bradshaw et al. question some of the economic data included in the single report on the termite. The most damaging insect for which they found “reproducible” economic estimates is the diamondback moth, a voracious consumer of cruciferous crops worldwide.

Other invasive insects cited as being associated with high damage levels are tree-killing pests familiar to readers of this blog: the brown spruce longhorn beetle, the European gypsy moth in North America, and the Asian longhorned beetle (write-ups on all three species can be read here. In my view, the high ranking of these insects reflects a (welcome!) effort by researchers to quantify tree pests’ impacts; although damages caused by agricultural pests are more easily reduced by pesticide applications.

The situation is likely to worsen in the future. According to the authors, climate change, rising human population densities, human mobility, and intensifying international trade will allow these costly insects to spread into new areas. Still, substantial savings could be achieved by increasing surveillance, containment and public awareness (my emphasis).

In an interview with Agence France Presse, one of the coauthors, Franck Courchamp said the best way to combat this growing threat — spread mainly through international commerce — is not more pesticides. Instead, “The solution is better ‘bio-security’,” he said. “This includes inspection of ship and air cargo from certain regions, legislation to ensure that high-risk imports must be treated and rapid eradication of new incursions.” (Interview is posted at http://www.bangkokpost.com/news/world/1102417/invasive-insects-cause-tens-of-billions-in-damage-study)

Source

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

Posted by Faith Campbell

What the new President & Congress Can Do re: Invasive Species

A new President and Congress take office in January. And outgoing President Obama recently amended the Executive Order on invasive species.

What might the new leaders do to improve America’s invasive species programs?

Here are a group of actions that I think would improve programs significantly:

amend the Lacey Act to strengthen controls over introduction and spread of invasive animals and animal diseases;
raise the political profile of invasive species issues by holding more frequent oversight hearings;
increase funding for invasive species prevention, containment, and control programs;
support proposals to amend the 2019 Farm Bill to strengthen on-the-ground programs, policies, and research aimed at minimizing invasive species introduction, spread, and damage;
during the confirmation process, Senators should ask President Trump’s nominees to leadership positions in the Departments of Agriculture and Interior about how they will address invasive species challenges.

Do we need new legislation mandating that federal land-managing agencies do X or Y with regard to invasive species? This was the focus of a hearing in May at which I testified.

Federal land-managing agencies are already authorized and – in some cases required – to act to control invasive species on lands and waters under their jurisdiction. Some of the existing statutes even authorize the agencies to apply fees paid by people who use the public lands for some purpose (e.g., livestock grazing, recreation) to management of invasive species.

Most of the statutes authorizing invasive species management incorporate that activity into the agency’s broader management goals for protection of wildlife, habitat, natural resources, historic or cultural sites, etc. For example, the USFS Manual §2900 lists 21 laws and 6 regulations or policies that govern the USFS’ management of invasive species. Some of these laws apply to all federal land-managing agencies, including:

Endangered Species Act (ESA) of 1973 (16 U.S.C. §§1531 et seq.)
Surface Mining Control and Reclamation Act of 1977 (30 U.S.C. 1201, 1201 (note), 1236, 1272, 1305). §515
North American Wetland Conservation Act 1989 (16 U.S.C. 4401 (note), 4401-4413, 16 U.S.C. 669b (note)). §9 [U.S.C. 4408]
Sikes Act (Fish and Wildlife Conservation) of September 15, 1960 (16 U.S.C. 670g-670l, 670o, P.L. 86-797), as amended. §201
National Historic Preservation Act of 1966 [16 U.S.C. §§470 et seq.]
Wilderness Act of 1964 (16 U.S.C. §§1131 et seq.

Other statutes apply only to resource management authorities of the USDA Forest Service; these include:

Organic Administration Act of 1897 (16 U.S.C. §§ 473 et seq.).
Fish and Wildlife Coordination Act (16 U.S.C. § 661 et seq.).
Knutson-Vandenberg Act of June 9, 1930 (16 U.S.C. 576, 576a-576b). §3 [16 U.S.C. 576b]
Bankhead-Jones Farm Tenant Act of 1937 (7 U.S.C. §§1010 et seq.)
Anderson-Mansfield Reforestation and Revegetation Act of October 11, 1949 (16 U.S.C. 581j (note), 581j, 581k)
Multiple-Use Sustained-Yield Act of 1960 (16 U.S.C. §§528 et seq.)
Forest and Rangeland Renewable Resources Planning Act (RPA) of 1974 as amended by the National Forest Management Act (NFMA) of 1976. §6
International Forestry Cooperation Act of 1990 (16 U.S.C. § 4501)
Healthy Forests Restoration Act of 2003 (H.R. 1904), [16 U.S.C. 6501-6502, 6511-18, 6541-42, 6571-78]
Wyden Amendment (P.L. 109-54, Section 434).

For brief descriptions of all these statutes, see the references and links at the end of this blog posting.

Advocates have tried before to legislate a specific requirement that federal agencies combat invasive species. The Federal Noxious Weed Act of 1974 (7 U.S.C. § 2801 note; 7 U.S.C. § 2814) was amended in 1990 to add §15, “Management of Undesirable Plants on Federal Lands”. This section requires each federal agency to

1) designate an office or person adequately trained to develop and coordinate an undesirable plants management program for control of undesirable plants on federal lands under the agency’s jurisdiction, and

2) establish and adequately fund an undesirable plants management program through the agency’s budgetary process,

3) complete and implement cooperative agreements with state agencies regarding the management of undesirable plant species on federal lands, and

4) establish integrated management systems to control or contain undesirable plant species targeted under cooperative agreements.

This approach hasn’t worked – no one is satisfied by the federal agencies’ “weed” management efforts.

What is missing is a political demand for action – and support for necessary staff and funding. Agencies under the secretaries of Agriculture and Interior bear most of the responsibility for managing invasive species. As long as these officials are not being pressed by key Congressional committees, the media, and key stakeholders to take more aggressive and effective action to curtail species introductions and suppress established populations of bioinvaders, they will continue to focus their attention on issues that do generate these kinds of political pressure.

I am not saying that the principal statutes governing invasive species management could not be improved. As noted above, several proposals have been put forward to strengthen laws which are the foundation for preventing introduction of invasive species. I will blog about specific proposals in the new year.

Sources

USFS Invasive Species Manual

ANSTF/NISC report “Federal Policy Options Addressing the Movement of Aquatic Invasive Species Onto and Off of Federal Lands and Waters. 2015. Committee on the Movement of Aquatic Invasive Species both onto and off of Federal Lands and Waters.

Posted by Faith Campbell

Asian Longhorned Beetle (ALB) – Newly Detected Infestation Shows Spread within Ohio

On November 18, Ohio authorities and APHIS announced the discovery of Asian longhorned beetle- infested trees in a section of Clermont County previously thought to be free of the insect. (The press release is not yet posted to the web; go here to see the most recent information).

The center of the newly discovered infestation is within the Williamsburg Township portion of the East Fork Wildlife Area, south of Clover Road. Tree inspection crews will continue to survey the area to determine the extent of the infestation. Any trees found to be infested will be removed as part of the eradication effort. Also, authorities will expand the ALB quarantine to include areas near the new infestation. When available, a map of the regulated areas will be posted at agri.ohio.gov.

This setback reminds us how difficult it is to contain or eradicate this insect.

ALB was first discovered in Tate Township in Clermont County, Ohio, in June 2011. That quarantine currently covers a 61-square miles area. According to the October 28 APHIS electronic newsletter, more than 2 million trees in the quarantine zone have been surveyed. The survey has detected 18,614 infested trees since 2011. 87,151 trees have been removed; Of these, 17,995 were infested and 69,156 were deemed at high-risk of either already being infested or likely to become infested in the immediate future.

Status of ALB in Other States

Massachusetts ALB was first detected in Worcester in 2008. The quarantine covers 110 square miles. At least 35,870 trees have been removed in the Commonwealth.

New York ALB was first detected in Queens in August 1996. APHIS and the state continue efforts to eradicate ALB from three separate infestations in Queens, Brooklyn, and Amityville. The quarantine covers a total of 137 square miles. The number of infested Trees for the entire New York program is 7,082. The number of trees removed is 23,731. Outbreaks in several sites have been declared eradicated:

Islip (Suffolk County) in 2011;
Manhattan and Staten Island in 2013.

In 2013, the Amityville area infestation was found to be larger than previously known.

The total number of trees removed in the Massachusetts, New York, and Ohio programs was 146,000. However, this is not the total for all the damage caused by the Asian longhorned beetle.

ALB outbreaks in Illinois (Chicago) and New Jersey were eradicated earlier, and their removals are not included in the total given above.

In Illinois, according to Haack et al. 2012, 1,771 trees were removed and 286,227 were treated with systemic pesticides (imidacloprid).

In New Jersey (again, according to Haack et al. 2009, 21,981 infested and high-risk trees were removed. Another 480,574 trees were treated. This total is not complete since the program had not yet succeeded in eradicating the ALB in New Jersey at the time of writing.

The total from all programs is 169,752.

The risk of new introductions remains.

During fiscal years 2010 – 2016, Customs (CBP) detected tree-killing pests in 4,984 shipments – an average of 807 shipments each year. (For the 2015 report, go here)
An analysis by Haack et al. (2014) concluded that one tenth of one percent of the wood packaging entering the U.S. after adoption of ISPM#15 still contained a tree-killing pest. Since the U.S. imports approximately 25 million shipping containers each year, and about half of these contain wood packaging, an “approach rate” of 0.1% equals 13,000 containers harboring pests that probably enter the country each year. That is 35 potential pest arrivals per day.
Customs send samples of intercepted wood packaging to an APHIS laboratory where the insect larvae are grown to adulthood and identified. The APHIS lab has received 1,068 insects from April 2012 through August 2016, taken from 786 separate interceptions of non-compliant wood packaging. Six of the insects were Asian longhorned beetles.

APHIS also detected 69 other pests in wood packaging sent from China.

The United States and Canada began requiring wood packaging from China to be treated in December 1998. (See my discussion of this regulation in Fading Forests II here. Since the Customs data begin in 2010, we can see that 11 to 16 years after the rule governing Chinese wood packaging went into effect, we are still receiving wood packaging with pests from that country.

Also, 700 pests arrived from 36 other countries, led by Mexico, Turkey, and Ukraine (see presentation here; search for “Nadel”)

What are APHIS & CBP doing about these flagrant violations of existing rules? Each violation exposes our forests to additional pest attack and our citizens to higher costs – either in local or federal taxes or personal costs to remove trees — as well as to mental anguish and health impacts.

The evidence is in. APHIS and Customs should tighten enforcement of ISPM#15 by:

Prohibiting imports in solid wood packaging (boards) from foreign suppliers which have a record of repeated violations over the 10 years ISPM#15 has been in effect. (It’s been 16 years for exporters from Hong Kong and mainland China). A reasonable number of violations should trigger this prohibition – perhaps eight over the entire period.

The U.S. should allow imports from those suppliers that are contained in other types of packaging materials, including plastic, metals, fiberboards …

Fining an importer for each new shipment found to be out of compliance with ISPM#15 if the foreign supplier of that shipment has a record of repeated violations (but fewer than the number that would trigger a ban) over the 10 years ISPM#15 has been in effect (16 years for exporters from Hong Kong & mainland China). The number of violations needed to trigger the fine might be five over the entire period – not just in one year.

Ensuring that exporting countries understand that foreign suppliers that change their names or take other steps to obscure their past import records will be prosecuted for fraud. This penalty should be severe so as to deter deliberate attempts to avoid the consequences of past actions.

References

Haack, R.A., F. Herard, J. Sun, J.J. Turgeon. 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.

Posted by Faith Campbell

Firewood: Important Progress — and a Troubling Stalemate

After years of work, the combined efforts of many staff at federal agencies and non-profits have succeeded in placing a firewood alert message on the Reservation.gov website for all of the 3,163 federal campgrounds managed by the National Park Service, USDA Forest Service, and Corps of Engineers for which visitors can reserve a spot in advance. Only 43 federal reserveable campgrounds remain without messaging. These are managed by the Bureau of Land Management, Bureau of Reclamation, and the US Fish and Wildlife Service.

As of October 2016, visitors reserving campgrounds through the services of Reserve America or Recreation.gov for any National parks, National forests, or Army Corps reservoirs will find new information in the “Know before you go” section – a message about not moving firewood.

The messages vary somewhat by agency, but basically say: “Don’t move firewood!” They often add “buy firewood at or near your destination and burn it on-site.” Some messages include a brief explanation about the aim — to prevent or limit spread of invasive tree-killing pests. Some include a message that some states regulate firewood movement. There is a link to either the national program — dontmovefirewood.org – or to the pertinent state program, e.g., the California Firewood Task Force for National Forest campgrounds in Region 5.

Some federal campgrounds do not use the Reservation.gov system and therefore require separate efforts to improve firewood messaging. This includes several popular water-based recreation sites in the central southern states, such as the Arkansas River National Recreation Area and Oachita National Forest. Many states in this region also do not regulate firewood. [See my earlier blog contrasting management of firewood with management of boats and attached mussels or aquatic plants here and the article by Frank Koch and colleagues, referenced below.]

Those who succeeded in achieving the widespread adoption of this outreach program deserve our thanks and praise! They worked long and hard for this.

On a Less Positive Note…

Unfortunately, efforts to put a firewood certification program into place appear to have stalled.

In March 2010, in response to increasing concern across the country, APHIS issued a first-ever firewood strategy, with a number of important elements. It proposed the following:

Outreach Strategies:

State and Federal agencies should convene a communications steering committee.
Develop an online hub of firewood outreach materials.
Prioritize the outreach activities.
Use diverse methods to get consistent messages out about the risk of moving firewood.
Support the voluntary and regulatory efforts.

Voluntary Strategies:

Large-scale producers and retailers adopt best management practices.
National producers and retailers adopt an industry-run national certification program with labeling and recordkeeping requirements based on best management practices.
Public and private campgrounds make local or treated firewood available.
Firewood consumers and small-scale local producers adopt best management practices.

Regulatory Strategies:

APHIS should promulgate regulations for the interstate movement of firewood as soon as possible with requirements for labeling, recordkeeping and treatment based on best management practices.
States should publish intrastate movement regulations with requirements similar to the Federal regulations for labeling, recordkeeping and treatment as needed. Moving firewood 50 miles or less would be exempt from intrastate regulations provided this does not violate any quarantine that may be in place.
State, Federal, and private parks, forests and campgrounds should institute policies that encourage campers to use local firewood and to not move firewood out of the local area.

What has been done over the six and one-half years since the Strategy was released?

There has been tremendous progress on the outreach and voluntary strategies, with the Nature Conservancy’s Don’t Move Firewood program providing support and advice. However, these voluntary programs are inadequate without regulatory backup.

There has been less progress on the more formal certification and regulatory strategies proposed in 2010.

Geoff Friedman – a firewood producer based in northern California – reports that he has developed the software for a certification program and worked with producers to get their acceptance. However, implementing the required wood treatments and – especially – staffing a third-party certification program – would raise the cost of firewood by 50%, according to Friedman. The major retailers which sell packaged firewood – the “big box stores” – are not willing to adopt the program because of this increased cost. In the absence or regulations requiring treatment of firewood, the program has stalled. (In the East, many states already regulate firewood. However, those states’ treatment requirements vary. Friedman seems to believe that this challenge can be worked out.)

APHIS has not adopted national regulations and does not appear to be on the verge of doing so. I believe APHIS wanted to tie its regulations to the certification program that has now stalled. Eleven of the 50 states currently have their own state-specific regulations limiting the movement of firewood from other states into their state. Only two more states are known to be potentially considering legislation in 2017. Many — but not all — federal agencies have now engaged on discouraging visitors from bringing their own firewood (see above). Some National parks actually restrict visitors bringing firewood to wood that is certified by USDA – including the park with the highest number of visitors, Great Smoky Mountains National Park. However, Yosemite and other National parks in California are not among them. And these are vulnerable to goldspotted oak borer and the polyphagous or Kuroshio shot hole borers (see species write-ups here).

Worse, APHIS is actively moving toward dropping regulations trying to prevent spread of the emerald ash borer (see species write-up here). APHIS argues that with EAB now present in 30 states (although in many cases, in only one or a few counties), it is too late to try to prevent the insect’s further spread. The regulatory effort is using resources that would be better put to other strategies, such as expanding the biocontrol program. I concede that funding is tight, and likely to be cut further; and that other approaches – and other pests! – need attention.

However, the legal and logical foundation for nearly all state regulations governing firewood is the emerald ash borer. The promised federal regulation and certification program also rest primarily on the EAB risk. Many states – as well as APHIS – must base their regulation on one or more specific pests. Will these state regulations and promised federal programs survive the loss of the federal EAB regulatory program?

In any case, we are a long way from what is needed to get control of the firewood pathway. Each of the “lower 48” states should have an external quarantine. Hawai`i might need one too, if it imports firewood. (Hawai`i does import other types of risky wood products, including Christmas trees.) Also, all 50 states need internal restrictions on the distance firewood is moved. So far, only a fraction have them.

The incoming Trump Administration strongly objects to regulations, so it is highly unlikely that we will see progress on these matters in the near future.

Reference:

Koch, F.H., D. Yemshanov, R.D. Magarey, and W.D. Smith. 2012. Dispersal of Invasive Forest Insects via Recreational Firewood: A Quantitative Analysis J. Econ. Entomol. 105(2): 438-450 (2012);

Posted by Faith Campbell

Leigh Greenwood helped check the facts and dates mentioned in this blog

The Latest on Phytophthoras

Phytopthora ramorum on tanoak in California; F.T. Campbell

Nine eastern states are participating in the 2016 USDA National Phytophthora ramorum Early Detection Survey of Forests. Those states are AL, FL, GA, MS, NC, PA, SC, TN, and TX. As of late August, streams in four locations were P. ramorum-positive. Three are in AL, one in MS. All had tested positive in previous years. Also, all have been associated with previously positive nurseries. (Reported in the California Oak Mortality Task Force newsletter for September.) It is reassuring that no new positive locations have been detected. However, on what substrate is the pathogen persisting? Scientists agree that the pathogen does not survive in water (although it is reliably detected by testing in water) but must survive on some plant material – perhaps roots.

P. ramorum also persists in nurseries. Seven California nurseries are participating in the APHIS federal P. ramorum program under which they are allowed to ship host plants interstate. Positive plants have been detected in two of them. One of these nurseries is undergoing the Confirmed Nursery Protocol clean-up. The other has completed the cleanup and has been allowed to resume shipping plants interstate. In both cases, the infected plants were not from the five “high-risk” genera which are the focus of monitoring for the regulatory system — Camellia, Kalmia, Pieris, Rhododendron, and Viburnum. (Reported in the California Oak Mortality Task Force newsletter for September.) I expressed concern about this too-narrow focus in a blog posted in July 2015 – http://nivemnic.us/2015/07/.

I have written about the widespread presence of various Phytophthoras in nurseries in blogs in April (for Europe http://nivemnic.us/2016/04/ ) and July (for California http://nivemnic.us/2016/07/ ). New publications add to this picture.

Junker and colleagues (see references below) report the detection of 15 Phytophthora species in two commercial woody ornamental nurseries (presumably in Europe, since the authors are Europeans). Twelve of the species are previously described but the DNA of three isolates did not match any of the known species. Detections were highest in puddles on nursery pathways; followed by plant residues;, wind-carried leaves; and water and sediment from runoff. The plant samples showed very low infection rates – a disturbing finding given the reliance until recently on inspection of plants to detect the pathogen. (Reported in the California Oak Mortality Task Force newsletter for September.)

New Phytophthora confirmed in U.S.

The United States has the first official confirmed detection of the pathogen Phytophthora quercina. It was found associated with oak trees planted on restoration sites in central coastal California. Although the California detection is the first officially confirmed detection of the pathogen in the U.S., a P. quercina ‘like’ organism has been reported to be associated with oak decline in forests in the Midwest. P. quercina is a pathogen associated with oak decline across Europe. It was rated as the species of highest concern in a USDA Plant Epidemiology and Risk Analysis Laboratory (PERAL) report. Another pathogen, P. tentaculata, was rated fifth on the same list. It was recently found in association with multiple native plant species in California’s native plant nurseries (see my July blog, linked above). See also California Oak Mortality Task Force newsletter at http://www.suddenoakdeath.org/news-and-events/current-newsletter/

Rapid Response Might Have Contained SOD – When will authorities learn this lesson?

Earlier this year, experts on modeling the epidemiology of plant disease concluded that the sudden oak death epidemic in California could have been slowed considerably if aggressive management actions – backed by “a very high level of investment” – had started in 2002. By then, there was sufficient knowledge about the disease to guide actions. Management actions should have focused on the leading edge of the epidemic (admittedly, that edge has proven difficult to detect). The study is by American and British scientists (Cunniffe, Cobb, Meentemeyer, Rizzo, and Gilligan). See reference and news report below.

The authors’ estimate documents the high costs of inaction. This is an important lesson – which has been repeated many times. If only officials from California and APHIS would take this to heart regarding several other forest pests. These include the polyphagous and Kuroshio shot hole borers and even the goldspotted oak borer (all described here).

References

https://www.sciencedaily.com/releases/2016/05/160502161111.htm?utm_source=feedburner&utm_medium=email&utm_campaign=Feed%3A+sciencedaily%2Fplants_animals%2Finvasive_species+%28Invasive+Species+News+–+ScienceDaily%29

Cunniffe, N.J., R.C. Cobb, R.K. Meentemeyer, D.M. Rizzo, and C.A. Gilligan. Modeling when, where, and how to manage a forest epidemic, motivated by SOD in Calif. PNAS, May 2016 DOI: 10.1073/pnas.1602153113

Junker, C., Goff, P., Wagner, S., and Werres, S. 2016. Occurrence of Phytophthora in commercial nursery production. Plant Health Progress. 17:64-75.

Posted by Faith Campbell

Europe moves to curtail forest pest introductions – but strongest measures are hampered by trade rules

ALB in Europe; photo by Doris Holling WSL

Maartje J. Klapwijk and several colleagues have recently taken a hard look at non-native forest pests in Europe. They conclude that current European legislation is inadequate to prevent forest/tree pest introduction, establishment and spread in the European Union. (A link to the article is provided at the end of this post.)

Some of the proactive steps that they recommend, however, will be difficult to enact. International trade rules (World Trade Organization, Agreement on the Application of Sanitary and Phytosanitary Measures – SPS Agreement) require that countries prove that the target commodity in trade presents a significant pest risk – proof that is difficult to obtain before damage has actually occurred.

(I have written extensively about this “Catch 22” – see Fading Forests II here)

Furthermore, European Union rules prevent countries from taking proactive measures to restrict potentially pest-infested plants or wood products being traded from one EU member country to another. However, member countries’ vary in their levels of concern about tree-killing pests. As a result, phytosanitary measures are quite weak in some countries. Once a pest-infested shipment enters a country with a weak phytosanitary system it can be moved freely to any other member country.

Thus, international and EU rules together create a significant risk that a pest will enter, establish, and then be spread by commerce to the rest of the Union.

The authors note that growing trade in living plants and wood products has brought a rise in non-native tree pests becoming established in Europe. The number of alien invertebrate species has increased two-fold since 1950; the number of fungal species has increased four-fold since 1900. Few studies have attempted to quantify the economic impacts of non-native tree-killing pests in Europe. But the authors say that the introduced pests will cause economic damage either directly by reducing the revenue of the country or imposing control costs; or indirectly through trade restrictions or reduced values of real estate.

Among the recent introductions are the pinewood nematode from North America; Asian and Citrus longhorned beetles and ash dieback fungus from Asia; and sudden oak death and other Phytophthora species. (I described the extent of Phytophtphora infestations in European nurseries in a blog posted on April 25.) As a partial response, EU countries have created a network of nurseries intended to serve as an early warning system against further introductions of alien tree pests. (Descriptions of these pests and where they are found are available on the website of the European and Mediterranean Plant Pest Organization (EPPO) here)

ALB introduction sites in Europe

The European Union regulates invasive species through the Environment Directorate-General (DG Environment). However, tree-killing pests and other plant health concerns are the responsibility of a different governmental body, the Directorate-General Health and Food Safety (DG SANCO).

Maartje J. Klapwijk and colleagues note the risk associated with:

crates, pallets, and other forms of wood packaging;
wood chips (Europe imports more than 4 million tons of wood pellets as fuel in order to meet its carbon emission reduction goals) ; and
especially – living plants.

They note that the international community has adopted two international related sanitary agreements : ISPM#15 (wood packaging) and ISPM#36 (living plants). The European Union requires certificates stating that imported plants are free from harmful organisms and that phytosanitary measures stipulated by the importing country have been applied. However, limited resources mean that only a small proportion of living plants, plant material, soil and wood products arriving in Europe can be inspected. “The main purpose of the inspections is to verify whether shipments comply with regulations, rather than to stop potentially harmful organisms …” (my emphasis). Reflecting the differences in levels of concern among EU member states noted above, there are large differences in inspection intensity among the EU member states.

The pertinent European legislation is Directive 2000/29/EC. It relies on a ‘‘black-list’’ of plants and plant products that are banned from import and specifies procedures to apply when any of these banned products is found in the EU. According to Klapwijk and colleagues, these quarantine lists provide insufficient protection because harmful organisms that enter the EU often are unknown prior to establishment.

Aware of the current system’s inadequacies, the EC has proposed a new regulation which would simplify and harmonize plant passports, allow for stricter measures against pests, and address emerging risks from certain living plant imports from some non-EU countries. Instead of listing harmful plant pests, the proposed regulation “sets out the conceptual nature of quarantine pests” and empowers the Commission to adopt measures to control certain pests.

Klapwijk and colleagues praise these actions as a significant step forward. However, they note that the new rules still don’t provide for precautionary assessments of high-risk commodities. Nor do they restrict import of the highest-risk commodities, such as imports of large plants or plants in soil. (my emphasis)

The authors note that other countries take a more pro-active, precautionary stance. Australia and New Zealand require that all imported plant products be assessed and proved safe before import. The U.S. restricts the size of imported plants and does not allow imported plants to be in soil. (The U.S. has proposed a new approach that relies increasingly on integrated measures or systems approaches rather than port-of-entry inspection. However, this proposal has been pending for more than three years. (APHIS explains its proposal here)

The question is, do trade rules allow Europe to apply the same restrictions as other countries? As Klapwijk and colleagues note, the EU cannot adopt more rigorous phytosanitary measures without providing scientific evidence for this necessity. Preparing a risk assessment to make this case will involve considerable work. As part of this process, Europe should announce that it wishes to raise its “level of protection” and that more stringent phytosanitary measures are needed to achieve that new goal.

Meanwhile, the EU can enhance its active detection efforts and “rapid response” capabilities. The new EC directive will require countries in which a new pest is detected to eradicate or contain the pest. However, the response continues to depend on investments and actions by individual Member States – which have often been insufficient.

Klapwijk and colleagues endorse the suggestion by Hulme et al. (2009) that the European Commission establish a single agency to respond to introductions of any kind of invasive species (not just tree pests) – modeled on the European Centre for Disease Prevention and Control.

Finally, Klapwijk and colleagues note the importance of engaging the public. Citizens’ participation can enhance early detection and strengthen public support for management strategies.

CONCLUSIONS

We Americans are very lucky that the U.S. Department of Agriculture had fairly stringent rules governing plant imports before the World Trade Organization and SPS Agreement were negotiated in the 1990s. We don’t have the burden of proving that imports of large plants (small trees!) in soil is too risky. (This not to say that U.S. regulations should not be tightened further for the most high-risk imports. See Fading Forests III here). Europeans should be able to build their case for more restrictive trade rules on existing risk assessments and practices utilized by the U.S., Australia, New Zealand, and others; on the numerous studies published in recent years that describe recent introductions to Europe and the pathways by which they entered; and by the number of those introductions alone. (To see what has been introduced, visit the website of the European and Mediterranean Plant Pest Organization (EPPO) here)

One important step in improving U.S. rules would be to finalize the proposal – put forward in 2013 – to depend more on integrated measures or systems approaches rather than inspection at the port of entry. Join with me in urging the Secretary of Agriculture to finalize this proposal before he leaves office in January. Contact me via the “contact us” button on the webpage to learn how you can help.

The United Kingdom has voted to leave the European Union. This means that the U.K. has the opportunity – and burden – of developing its own phytosanitary regulations. The U.K. has some of the leading forest pathologists and entomologists. The risk is obvious to all – especially Phytophthora ramorum in larch plantations and ash dieback disease in many areas of the country. I hope that the British will seize this opportunity to adopt really effective phytosanitary regulations that can serve as a model for the rest of Europe – and possibly even the U.S.

Sources

Maartje J. Klapwijk, Anna J. M. Hopkins, Louise Eriksson, Maria Pettersson, Martin Schroeder,A°ke Lindelo¨w, Jonas Ro¨nnberg, E. Carina H. Keskitalo, Marc Kenis. 2016. Reducing the risk of invasive forest pests and pathogens: Combining legislation, targeted management and public awareness. Ambio 2016, 45(Suppl. 2):S223–S234 DOI 10.1007/s13280-015-0748-3

Hulme, P.E. 2009. Trade, transport and trouble: Managing invasive species pathways in an era of globalization. Journal of Applied Ecology 46:10-18

Posted by Faith Campbell

Campbell Wins Award from State Foresters

We are delighted to note that CISP Vice President Dr. Faith Campbell recently received the John Shannon Current Achievement Award for Partnerships from the National Association of State Foresters (NASF).

She was among nine individuals honored on September 21, 2016, at the group’s annual meeting in Savannah, Georgia. All recipients “have made outstanding contributions in wildland fire protection, urban and community forestry, forest management and overall leadership” according to NASF. Each was nominated by the organization’s members and partners for accomplishments in promoting, supporting and strengthening the forestry community nationwide. “Every year we are inspired by the achievements of so many leaders and partners in the forestry community, who are working to ensure the future sustainability of our nation’s trees and forests,” said Wisconsin State Forester Paul DeLong and NASA President.*

The Association noted that Faith has spent more than twenty years working on invasive species issues for several environmental or conservation organizations, including The Nature Conservancy, American Lands, and the Natural Resources Defense Council.

We at CISP couldn’t agree more that Faith is an inspiring and long-standing leader. She has extraordinary expertise regarding the non-native forest pests that threaten our Nation’s forests. Her voice is forthright and insistent — urging us ever onward to strengthen national and international policy to limit these burgeoning threats.

Please join us in congratulating her on this much-deserved honor.

Peter Jenkins

Phyllis Windle

* NASF press release at: http://www.stateforesters.org/2016-state-forestry-awards-recognize-excellence-forestry

Invaders Put Another Bird at Risk

i`iwi; photo by James Petruzzi; courtesy of American Bird Conservancy

As noted in an earlier blog (“When Will Invasive Species Get the Respect They Deserve?” May 2016), invasive species can cause extinctions – especially on islands. I have posted other blogs about the invasional meltdown in Hawai`i (“Hawaii’s unique forests now threatened by insects and pathogens” October 2015).

A further demonstration of the meltdown is the decision by the US Fish and Wildlife Service (USFWS) to propose listing another Hawaiian honeycreeper (bird) – the i`iwi (Drepanis (Vestiaria) coccinea) as a threatened species. Already, some 20 Hawaiian forest birds are protected under the Endangered Species Act. Many, although not all, are threatened by the same factors as the i`iwi.

The proposal, which summarizes an extensive supporting report, is available here. USFWS is accepting comments on the proposal that are submitted to the USFWS’ website before November 21.

The proposal documents the tragedy of Hawai`i. The i`iwi was once almost ubiquitous on the islands, from sea level to the tree line. Today the bird is missing from Lanai; and reduced to a few individuals on Oahu, Molokai, and west Maui. Remaining populations of i`iwi are largely restricted to forests above ~ 3,937 ft (1,200 m) on Hawaii Island (Big Island), east Maui, and Kauai.

In the past, hunting for the bird’s striking red feathers and agricultural conversion doubtless affected the i`iwi’s populations. Since the early 20^th Century, though, the threats have all been invasive species.

The USFWS has concluded that the principal threat is disease: introduced avian malaria — caused by the protozoan Plasmodium relictum and vectored by introduced mosquitoes (Culex quinquefasciatus). A second disease, Avian pox (Avipoxvirus sp.), is also present but scientists have not been able to separate its effects from those of malaria. Both vectored by the southern house mosquito.

I`iwi are very susceptible to avian malaria; in lab tests, 95% of birds died.

I’iwi on `ohi`a blossom at Hakalau NWR; photo by Daniel J. Lebbin; courtesy of American Bird Conservancy

I`iwi alive now have survived because they live in forests at sufficiently high elevations; there, cooler temperatures reduce the numbers of mosquitoes, and thus transmission of the disease. However, the birds must fly to lower elevations in certain seasons to find flowering plants (the i`iwi feeds on nectar) – and then becomes exposed to mosquitoes.

Worse, climate change has already caused warming at higher elevations, and is projected to have a greater impact in the future. The rising temperatures predicted to occur – even if countries meet their commitments from the December 2015 meeting of the UN Framework Convention on Climate Change – will result in upslope movement of mosquitoes. As a result, according to three studies reviewed by the USFWS, the i`iwi will lose 60 – 90% of its current (already limited) disease-free range by the end of this century, with significant effects occurring by 2050.

I`iwi occur primarily in closed canopy, montane wet or montane mesic forests composed of tall-stature `ohi`a (Metrosideros polymorpha) trees or in mixed forests of `ohi`a and koa (Acacia koa) trees. The i`iwi’s diet consists primarily of nectar from the flowers of `ohi`a and several other plants, with occasional insects and spiders.

Hakalau National Wildlife Refuge; USFWS photo

The i`iwi’s dependence on `ohi`a creates another peril, because `ohi`a trees are vulnerable to alien diseases – both ohia rust and, especially, rapid ohia death or Ceratocystis ohia wilt. (Read descriptions of both diseases here. As of September 2016, rapid ohia death has been found only on Hawai`i – the “Big Island”. However, 90% of all i`iwi currently reside on the Big Island! Worse, in future the relatively large area of high-elevation `ohi`a dominated forest on the Big Island was expected to be the principal refuge of the i`iwi from the anticipated climate-driven up-slope movement of malaria. However, as just noted, the Big Island’s trees are now being killed by disease. If rapid ohia death continues to spread across the native `ohi`a forests – on Hawai`i and potentially on the other islands – it will directly threaten i`iwi by eliminating the limited, malaria-free native forest areas that remain for the species.

Rapid `ohi`a death (ROD) is caused by two distinct strains of the widely introduced pathogen Ceratocystis fimbriata. It was first detected in the Puna District of Hawai`i in 2012. The disease has since been detected across a widening area of the Big Island, including on the dry side of island in Kona District (See map here. The total area infested has increased rapidly, from ~6,000 acres in 2012 to 38,000 acres in June 2016. Since symptoms do not emerge for more than a year after infection, the infested area is probably larger. ROD kills `ohi`a in all size and age classes. There is no apparent limit based on soil types, climate, or elevation. O`hi`a growing throughout the islands appears to be vulnerable, from cracks in new volcanic areas to weathered soils; in dry as well as mesic and wet climates. The pathogen is probably spread by spores sticking to wood-boring insects and – over short distances – wind transport of insect frass.

Federal and state agencies are spending $850,000 on research on the disease, possible vectors, and potential containment measures. Additional funds would be needed to implement any strategies, and to expand outreach to try to limit human movement of infected plants or soil.

The Hawaii Department of Agriculture adopted an interim rule in August, 2015 which restricts the movement of `ohi`a plants, plant parts, wood, and frass and sawdust from Hawai`i Island to neighboring islands. Soil was included in the interim rule with an effective date of January 1, 2016. In March 2016, HDOA approved permit conditions for movement of soil to other islands. The interim rule is expected to be made permanent at a meeting of the Board of Agriculture on 18 October.

Other invasive species threatening the i`iwi are feral ungulates, including pigs (Sus scrofa), goats (Capra hircus), and axis deer (Axis axis). All degrade `ohi`a forest habitat by spreading nonnative plant seeds and grazing on and trampling native vegetation. Their impact is exacerbated by the large number of invasive nonnative plants, which prevent or retard regeneration of `ohi`a forest. Drought combined with invasion by nonnative grasses have promoted increased fire frequency and the conversion of mesic `ohi`a woodland to exotic grassland in many areas of Hawaii.

The feral pigs pose a particular threat because by wallowing and overturning tree ferns (Cibotium spp.) they create pools of standing water in which the mosquitoes breed. The US FWS has concluded that management of feral pigs – across large landscapes – might be a strategic component of programs aimed at managing avian malaria and pox.

One possible source of hope: research into genetic manipulation of the mosquito disease vector by using tools from synthetic biology and genomics (see draft species status report . Considerable research is probably necessary before such a tool might be implemented.

Plant Pest Threat to Endangered Animals is Not Limited to Hawai`i

The USFWS is struggling to deal with the threat posed by plant pests to listed species. In San Diego, California, FWS personnel are trying to decide how to address the threat posed by the Kuroshio shot hole borer (read description here to willows which constitute essential riparian habitat for the least Bell’s vireo.

Numerous cactus species that have been listed as endangered or threatened might be attacked by two insects from Argentina, the cactus moth and Harissia cactus mealybug (see my blog from October 2015; or read descriptions here .

Endangered Species Agencies Need to Coordinate with Phytosanitary Agencies

A growing number of species listed under the Endangered Species Act are being threatened by damage to plants from non-native plant insects and pathogens. This growing damage affects not just listed plants – such as the cacti mentioned in this and the October blogs; but also plants that are vitally important habitat components on which listed animals depend. The USFWS needs to engage with other federal and state agencies and academic institutions which are working to prevent introduction of additional plant pests, slow the spread of those already in the United States, and develop and implement strategies intended to restore plant species that have been seriously depleted by such pests. The USFWS should, therefore, work more closely with USDA Animal and Plant Health Inspection Service and Forest Service. USFWS must, of course, continue to work with experts in wildlife and wildlife disease.

Similarly, state wildlife agencies also need to coordinate their efforts with their counterparts in state departments of Agriculture and divisions of Forestry.

Many agencies in Hawai`i play crucial roles in protecting the Islands’ unique plant and animal communities:

U.S. Department of the Interior: Fish and Wildlife Service, National Park Service, United States Geological Service Biological Resources Division
US. Department of Agriculture: APHIS, Forest Service, Agriculture Research Service, National Institute of Food and Agriculture
US. Department of Homeland Security Bureau of Customs and Border Protection.
Hawai`i State Department of Agriculture and Department of Land and Natural Resources

Hawaiians of all types – federal and state employees and agencies, academics, and conservationists – deserve our thanks for promptly taking action of rapid ohia death. All parties should make every effort to obtain the remainder of the funds needed to carry forward crucial research on ROD and avian malaria. Those of us from the mainland need to support and help their efforts.

Posted by Faith Campbell

Let’s Work Together to Curtail Threat to Our Forests from Non-Native Pests

Dear Forest Pest Mavens,

I believe you agree with me that non-native insects, pathogens, earthworms … and other organisms! … pose significant threats to North America’s tree species and the complex ecosystems of which they are such important components.

I hope you also agree that our society’s efforts to counter this threat fall far short of what is needed.

Official phytosanitary policies are not as strong as needed to prevent introduction and spread of these tree-killing pests.
Worse, those policies are not always enforced assertively – as I documented in my blog about a shipment of auto parts posted on 9 August.
The Congress does not provide sufficient funds and other resources to support active detection and response programs – either early in an invasion or later.
Businesses that import or trade in goods or packaging that can transport pests are not held responsible for taking actions aimed at reducing the likelihood of such transport or supporting recovery efforts. Opposing free trade has become a hot button election issue but one of its worst impacts — wholesale movement of pests — is never mentioned.

As I noted in my earlier blog, a key reason we see these weaknesses is because those who want stronger programs have not had an effective voice in educating federal policy-makers – the USDA secretary, senators, and members of Congress – about the damage caused by introduced tree-killing pests and the governmental actions needed to counter those impacts.

The election provides both a deadline and an opportunity.

The deadline: we should try to finalize some APHIS-proposed actions before this Administration leaves office. Outgoing officials often feel freer to take bold actions at this time.

The opportunities:

New officials who take office in January might be open to addressing “new” issues. We must begin efforts now to get our “asks” on their agenda. Specifically, we should approach the senators who will question appointees to USDA Secretary and Under Secretary positions during their confirmation processes. We should urge them to ask candidates how they would address plant pests and to make firm, specific commitments to do so
Also, Congress is beginning to consider provisions to include in the next Farm Bill (due to be passed by 2019).

Several coalitions work to raise the political profile of non-native, tree-killing pests, i.e., the Coalition Against Forest Pests; Sustainable Urban Forestry Coalition; Reduce Risk from Invasive Species Coalition; Continental Dialogue on Non-Native Forest Insects and Diseases. Many of the nation-wide forest-related organizations are members of one or more of these coalitions and I work hard for many of them. They are absolutely essential. . .

However, such “big tent” coalitions are unlikely to press for truly bold solutions, especially if new policies involve serious costs to economic interests or industries that are part of their membership. There is nothing nefarious in this; it is the way coalitions operate. In the case of forests pest issues, though, the absence of more forceful and nimble groups leaves a policy vacuum that no one currently fills.

Furthermore, these coalitions don’t offer an opportunity to concerned individuals and smaller organizations to learn about phytosanitary threats or provide them with opportunities to influence policy.

In the past, I have tried to provide this information through my one-way emails and blog postings. I would like now to upgrade these communications and to provide you with a way to interact with me and others, as well as to form joint positions. The goal is to re-balance the politics of phytosanitary policy – so that our political leaders understand and support both adoption and enforcement of strong, effective phytosanitary measures.

I suggest that we form a new, loose “coalition of the willing” who are ready to speak up and seek ways to stay abreast of developments and opportunities and to coordinate their actions with those of like-minded people. I suggest a loose structure –

I undertake to set up an email network that everyone could use. It would:
- communicate information about pest threats and opportunities to engage;
- communications could be initiated by anyone in the group (either through a “reply all” function or my promise to re-send any email sent to me — with the request that I do so);
- encourage people to work together – with my assistance – to form joint positions;
- provide lists of key contacts for specific issues — perhaps with specific talking points, letter templates, etc., to help in reaching out;
There would be no cost to participants;
Participants could take part anonymously if they wish – either generally or on specific issues;
If there is sufficient interest or need, we could form a steering committee to streamline and help guide the work;
Our goal would be communications that are straight-forward and clear — to each other and to policymakers — while avoiding gratuitous insults or insinuations.

Examples of issues on which I believe a new group could productively engage (and which the “big tent” coalitions likely will avoid) are:

Helping APHIS finalize its proposal to require that wood packaging coming from Canada conform to ISPM#15 standards (see blog posted on 9 August). We need to press the USDA leadership to approve the proposal; then press the Office of Management and Budget to approve it.
Press USDA to take two steps to improve enforcement of ISPM#15:
- End the policy of not fining importers for non-compliant wood packaging until they have five (!) non-compliances within a single year.
- Declare wood packaging to be a high-risk import and thus subject to mandatory inspection by Customs
Press Customs and Border Protection to include wood packaging compliance under its Customs-Trade Partnership Against Terrorism (C-TPAT) program.
Seek agreement on a strategy to encourage importers to shift to packaging made from materials other than solid wood boards. Proposals range from new regulatory requirements to C-TPAT to green certification-type voluntary programs.

I welcome suggestions for other topics we might explore!

Please let me know that you would like to join this coalition. Please feel free to forward this message and to invite others to join in.

[use the “contact” button on the www.cisp.us website]

Faith