Surprise! USDA Through APHIS moves on NAPPRA regulations


USDA headquarters; F.T. Campbell

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

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

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

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

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

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

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


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

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


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

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

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

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


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

1) 2013 listing:

2) 2017 listing:

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


History of NAPPRA

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

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

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

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

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

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


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


Why does APHIS regulate by genus?

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


How do these new rules fit into international standards?

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


How long is importation of plants prohibited?

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


What is the meaning of “significant trade”?


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


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


What other protections does APHIS use?

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




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


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


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


Posted by Faith Campbell

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


Status of Phytopthoras in the United States & Europe: an update

tanoak killed by sudden oak death; Marin County, Calif. photo F.T. Campbell

Here is some interesting information from recent issues of the the California Oak Mortality Task Force’s bimonthly newsletter. I am updating my earlier blogs on the status of Phytophthoras and sudden oak death (SOD) in the United States and Europe.


More than 600 samples were taken from streams or ponds in nine states (Alabama, Florida, Georgia, Mississippi, North Carolina, Pennsylvania, South Carolina, Tennessee, and Texas) during 2016. Ten of the samples were positive: seven from three streams in Alabama and three from one stream in Mississippi. Each of these had tested positive before; none was a new positive location. [March newsletter]


  • The disease continues to spread in Oregon and California:

During 2016 and early 2017, sudden oak death and tanoak mortality continued to intensify within the officially designated quarantine zone in southwest Oregon. So far, no new outbreaks have been detected outside the quarantine zone.

In Oregon, there is growing concern about the disease and the paucity of funds to address it. As a result, Oregon state Representative David Brock Smith and U.S. Senator Jeff Merkley have formed an Oregon Sudden Oak Death Task Force. The Task Force is developing a collaborative action plan to secure enough funding to contain the infestations of the NA1 genetic strain (the one widespread in Oregon and California) and to eradicate the EU1 lineage (this is the only known site where this strain is established in the forest in North America; see my blog from August 2015, which explains the significance of these strains.)  [March newsletter]


In California, scientists have been surprised by the intensity of the disease in several parks on the eastern side of San Francisco Bay – an area that is drier than most forests that are infested. The severe drought of recent years has not prevented spread of the disease. Even more surprising, one park has very little California bay laurel – which is considered to be the primary source of infection. [March newsletter]


  • Native plant nurseries may be spreading various Phytophthoras (see my blog from last year here) or the presentations on “Phytophthora Detections in Native Plant Nurseries and Restoration Sites” posted here)

The National Ornamentals Research Site at Dominican University (NORS-DUC) sampled several types of native plant nurseries in fall 2016 to determine the extent of movement of Phytophthora species on plants they sell. Unfortunately, the report in the newsletter did not include results of the sampling. [January 2017]

CFDA photo of herbaceous plants with Phytophthora infection

Oregon and Washington authorities acted in response to the initial reports from the San Francisco area, and sampled nurseries in their states. They found a similarly high infestation rate in native plant nurseries in their states. Washington State University and Oregon State University have held several 2 ½-day workshops on “Preventing Phytophthora Contamination in Native Plant Nurseries and Restoration Sites”. [May newsletter]

For more information about Phytophthoras in native herbaceous plants in California, visit

  • Disease costs in England and Wales could top 1 billion dollars


Drake and Jones have estimated that damage by Phytophthora ramorum and P. kernoviae [link to Gallery] to non-extractive public use and non-use values at risk from uncontrolled spread of these diseases in England and Wales is £1.446 billion per year (approximately $US 1.82 billion). The greatest public value at risk (slightly more than one-third) is from an uncontrolled spread of these diseases to heritage gardens; lower risks are to the diseases’ spread to woodlands and heathlands. [March newsletter]


5) Ireland resembles Europe in numbers of Phytophthora species:


O’Hanlan and colleagues tested more than 11,000 samples from both “trade” environments (presumably, nurseries) and “non-trade” environments (presumably plantings or natural environments). They detected 19 species and 3 informally designated taxa of Phytophthora, including 8 new records for Ireland. Thus, Ireland’s situation is similar to that in Europe more broadly – a study last year by Junker and colleagues report the detection of 15 Phytophthora species in two commercial woody ornamental nurseries [link to blog about Phythophs in Europe] In Ireloand, P. ramorum was found on 30 hosts; P. syringae on 6 hosts; P. kernoviae on 3 hosts. Phytophthora species were most frequently detected on rhododendrons – (12 Phytophthora species). [January newsletter]




Drake, B. and Jones, G. 2017. Public Value at Risk from Phytophthora ramorum and Phytophthora kernoviae Spread in England and Wales. Journal of Environmental Management. 191: 136–144.


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


O’Hanlon, R.; Choiseul, J.; Corrigan, M.; Catarame, T.; and Destefanis, M. 2016. Diversity and Detections of Phytophthora Species from Trade and Non-Trade Environments in Ireland. EPPO Bull. 46: 594–602. DOI: 10.1111/epp.12331.



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.


Lobby House and Senate Agriculture Appropriations Subcommittees in support of increasing funding for two crucial APHIS programs


On May 19 I posted a blog asking you to lobby Congress in support of maintaining current funding levels for two programs aimed to eradicating or containing tree-killing pests.  These are the “tree and wood pest” and “specialty crop” programs operated by the USDA Animal and Plant Health Inspection Service (APHIS).

At the time, I had not seen the President’s budget proposal. Now I have seen the President’s budget – and, as anticipated, it calls for steep cuts in the “tree and wood pest” program. The President calls for cutting this program by 44% — from $54 million to $30 million. Specifically, the Asian longhorned beetle (ALB) eradication program would be cut by approximately 50% — $20.770. The emerald ash borer (EAB) containment program would also be cut by half — $3.127 million.

The President’s budget justifies these severe cuts by saying that states, localities, and industries benefit from eradication or containment of the ALB and EAB, so they should help pay for the containment program.  The Office of Management and Budget states that other beneficiaries should pay 50% of program costs.

For whatever reason, the budget does not propose to cut APHIS’ efforts to prevent spread of the European gypsy moth.

In reality, states, localities, and industries are very unlikely to make up the difference in funding. We should remind the Congress that already, local governments across the country are spending more than $3 billion each year to remove trees on city property killed by non-native pests. Homeowners are spending $1 billion to remove and replace trees on their properties and are absorbing an additional $1.5 billion in reduced property values and reducing the quality of their neighborhoods. (See Aukema et al. article listed below.)

ash tree killed by EAB; Ann Arbor, MI; courtesy of Major Hefje


Cuts of the size proposed by the President’s budget will undermine the programs completely. Such a result is particularly alarming given the record of success in eradicating ALB populations – when resources are sufficient; and the urgent need to complete eradication programs in Massachusetts, New York, and Ohio. As I said in May, the ALB program has succeeded in eradicating 85% of the infestation in New York. (APHIS has just announced that a section of the borough of Queens is free of ALB.) However, the infestation in Massachusetts has been only 34% eradicated; that in Ohio has been only 15% eradicated. Crippling the program now will expose urban and rural forests throughout the Northeast to severe damage by this insect, which attacks a wide range of species.

The importance of continuing the EAB containment program has been re-emphasized by scientists’ recent determination that EAB can attack commercial olive trees as well as all species of ash.

The budget also does not recognize the need for APHIS to expand its program to address other tree-killing pests, including the spotted lanternfly, and polyphagous and Kuroshio shot hole borers.The shot hole borers attack hundreds of tree species, including California sycamore, cottonwoods, and several oaks. Many known hosts are either found across the Southeast, or belong to genera that are found across the Southeast – so the threat is national. The spotted lanternfly – now established in Pennsylvania — threatens agriculture – especially grapes, apples, plums, cherries, peaches, nectarines, apricots, and almonds; as well as oak, walnut, poplar, and pine trees.

More than 30 tree-attacking pests have been introduced in recent years. Additional species from these introductions might also require APHIS-led programs; one example is the velvet longhorned beetle.

velvet longhorned beetle;

The budget calls also for a 6% cut on the “specialty crops” program – from $158 million to $148 million.  It is not clear how such a reduction would affect APHIS’ program to prevent spread of the sudden oak death (SOD) via movement of nursery stock [link to earlier blogs & Gallery]. The SOD program has been funded at approximately $5 million in recent years.

Finally, additional challenges lie ahead because it is likely that new tree-killing pests will be introduced with rising import volumes. Each year, border inspectors detect more than 800 import shipments with pests infesting the crates and pallets. These represent a small proportion of the actual risk; one analysis estimated that 13,000 shipments with infested packaging enter the country each year. APHIS must have sufficient resources to respond when the inevitable newly introduced pests are detected.

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

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)

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.

Plan to Join the Continental Dialogue in Savannah, Georgia, in November 2017!

Spread of laurel wilt since 2003; source: USFS

Redbay mortality, Claxton, GA 2009

photo by Scott Cameron

The southeastern states have been invaded by a smaller number of non-native, tree-killing insects and pathogens than some other regions (see map below). But among these are highly damaging pests that show just how vulnerable this area’s native species and forests are, e.g., chestnut blight, laurel wilt, hemlock woolly adelgid, balsam woolly adelgid, and now emerald ash borer (all described here).

Join the Continental Dialogue on Non-Native Forest Insects and Diseases at its annual meeting in Savannah, GA, November 9 & 10, 2017 to learn about the issues outlined below and to build relationships to sustain action. The meeting will be in conjunction with the Annual Gypsy Moth Review, so we will also discuss the most recent developments pertaining to European and Asian gypsy moths. Visit to see the agenda and registration information (both to be posted soon).

The Southeast is at high risk for greater damage because:

  • The Port of Savannah is already the largest container port on the East Coast. Now, it moves 20,000 shipping containers per day and it is adding infrastructure to increase this volume.

Most of these containers – and their accompanying wood packaging material (for more on the risk from wood packaging, see my blog from the end of January; and fact sheets here) quickly move to distribution centers or their ultimate destinations – throughout the Southeast but as far away as Chicago. However, the port has storage for millions of containers on paved container yards that total 1,200 acres.  The storage yards are close to mixed forests.

Trees across road from stored containers at Port of Savannah;  photo by F.T. Campbell

More of these ships and containers will come directly from Asia – the major source of our most damaging invaders — now that the Panama Canal has been widened. When I visited the port in mid-May, the largest container ship ever to visit the U.S. East Coast was being unloaded – and re-loaded simultaneously!  The “Cosco Development” carries 13,200 TEUs (twenty-foot equivalent containers).

Unloading “Cosco Development” at Port of Savannah; photo F.T. Campbell

  • The sudden oak death pathogen (Phytophthora ramorum) has been found in streams and ponds in several southeastern states – Alabama, Florida, Georgia, Mississippi, North Carolina, South Carolina, and Texas. Positive samples were drawn from three streams in Alabama and one stream in Mississippi in 2016. Most of these water bodies are near nurseries that had received infested plants from West Coast suppliers. In addition, infested plants have been detected recently in nurseries or landscape plantings in Louisiana, Texas, and Virginia, as well as in other states farther north [link to 2015 blog]. These infested plants have been removed. What is the current scientific thinking about the implications of these detections? Last I heard, scientists thought the pathogen cannot survive in water; it needs some plant material. Yet scientists have not found on-going infestations on plants along the streams and ponds. For more information on SOD, visit


  • Over recent decades, a half dozen non-native insects that attack pine trees have become established in the continental United States. These include the Sirex woodwasp, common pine shoot beetle, golden (or red) haired pine bark beetle (Hylurgus ligniperda), Mediterranean pine shoot beetle (Orthotomicus erosus) — all described here. The mountain pine beetle (Dendroctonus ponderosae) has spread east of the Rocky Mountains and might eventually reach pine forests of the Midwest and East.


While none of these (other than the mountain pine beetle) has yet caused very much damage where they are established, should we continue to assume that they will not cause damage once they reach the “pine basket” of the Southeast? Even if plantations can be managed to minimize risk, what are the implications for natural pine forests so important to the ecosystems and protected areas of the region?


It is unclear whether the fact that the Secretary of Agriculture, Sonny Perdue, is a former governor of Georgia with a record of support for forestry will raise attention to some of these issues.  As you might remember (see my blog from March 28th), apparently no senators raised invasive pest issues during Secretary Perdue’s confirmation.

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 APHIS Tree-Pest Programs


Congress is now considering funding for various agencies and programs for Fiscal Year 2018 – which begins on October 1. Please contact your Representative and Senators and urge them to support adequate funding for key programs managed by the USDA Animal and Plant Health Inspection Service (APHIS). These are essential for keeping the nation’s forests healthy by preventing introduction and spread of invasive pests. While I would much prefer to increase funding for these programs, that is impossible at this time. So I suggest that you support maintaining last year’s  funding levels for two  budget“lines” under the USDA APHIS Plant Health program: $54 million for the “Tree and Wood Pests” line and $156 million for the “Specialty Crops” line.


I have blogged often about the impacts of non-native insects and pathogens inthe United States — which are enormous. (See Lovett et al. 2016 for a summery.)  As new pests are introduced and established pests spread, these costs will only continue to rise.


Moreover, since 1975, U.S. imports (excluding petroleum products) have risen almost six times faster than APHIS and Customs and Border Protection’s staff capability to inspect  them. As a result of this and other prevention failures, such as insufficiently protective regulations, more than a dozen new plant pests are detected in the United States each year. Since the beginning of the 21st Century, at least 20 woodboring beetles have been detected here, including:

  • Redbay ambrosia beetle / laurel wilt disease;
  • Sirex woodwasp;
  • Goldspotted oak borer;
  • Walnut twig beetle and thousand cankers disease ;
  • Soapberry borer;
  • Polyphagous & Kuroshio shot hole borers; and
  • Velvet longhorned beetle.


Another dozen tree-killing pests that are not wood borers have also been detected, including Spotted lanternfly.



APHIS Programs Target only a Few of the Damaging Pests in the Country


At least in part because of inadequate funding, APHIS currently funds comprehensive programs targeting only four of the  dozens of already- or potentially-serious tree-killing pests already in the country: gyspy moth (both European and Asian); Asian longhorned beetle; emerald ash borer; and sudden oak death.


APHIS also provides limited assistance to programs on  other pests through grants  under the Section 10007 of the 2014 Farm Bill. One example is research to determine host ranges and possible control method for the polyphagous and Kuroshio shot hole borers. However, these funds have not been sufficient to support comprehensive suppression or eradication programs despite the threat posed by these two shot-hole borers. They threaten to kill 26 million trees – more than a third of the trees growing in urban areas in California’s Inland Empire, Coastal Southern California, and Southwest Desert. Absent an active APHIS program to develop effective control measures, the municipalities and homeowners of these regions will be forced to absorb an estimated $36.2 billion (the costs of removing and replacing dead and dying trees) if they want to maintain valuable urban forest canopy.

willow killed by Kuroshio shot hole borer

in Tijuana River estuary, California

photo by John Boland

The shot-hole borers might also threaten trees across the American South. Box elder, sweetgum, and tree of heaven are reproductive hosts for the polyphagous shot hole borer; all are widespread in southern forests. California species of sycamore, oak, and willow are also reproductive hosts; other trees in these genera, which grow widely across the U.S., might also be vulnerable to the shot hole borers.


APHIS also has devoted Section 10007 funds to the spotted lanternfly, which is found in southeastern Pennsylvania. This insect feeds on several crop trees as well as oak, walnut, poplar, and pine trees. Pennsylvania authorities cannot complete eradication of this pest without additional federal funding – which so far is uncertain.


APHIS has helped with trace-forwards to find furniture infested by the velvet longhorned beetle, but has not adopted a program targetting this species in the several states where it appears to be established.


As these examples illustrate, even maintaining current funding levels means that several damaging non-native insects and pathogens continue to spread without a meaningful federal response. Any cuts would only exacerbate the failure of APHIS’ program to protect our forests from non-native insects and pathogens.


Remember, too, that additional introductions are likely in coming years. According to one study, perhaps 35 shipping containers entering the country each day carry damaging pests.

Unloading largest container ship to visit a U.S. East Coast port – “Cosco Development”; Savannah, GA  May 12, 2017; F.T. Campbell

At the same time, we cannot afford for APHIS to reduce its ongoing programs in order to address the other invaders. The  Asian longhorned beetle eradication program, at a cost of $35 – $40 million per year, has succeeded in eradicating 85% of the infestation in New York. (APHIS has just announced that a section of the borough of Queens is free of ALB.) However, the infestations in Massachusetts and Ohio still threaten to spread further into the forests. The $5 – $6 million per year allocated to the gypsy moth appears to be adequate, but APHIS must be prepared to eradicate any newly detected outbreaks, especially of the Asian gypsy moth on the west coast.


APHIS’ emerald ash borer program has received $7 million per year. To reduce future costs, the agency has cut back its regulatory program, so that it enforces regulations only at the infestation’s leading edge. In affected states, APHIS will continue surveys in unregulated areas, outreach, and coordination. These changes, taken together, undermine efforts to prevent the beetle’s spread to the vulnerable rural and urban forests in North Dakota, Oregon, and other states. APHIS is emphasizing production and dispersal of biocontrol agentsrather than regulatory measures

The sudden oak death program – targeting the pathogen Phytophthora ramorum — is under the “Specialty Crops” funding line. This must also be maintained at current levels because SOD threatens such important eastern forest tree species as northern red, chestnut, white, and pin oaks; sugar maple; and black walnut. APHIS regulates movement of nursery stock which could transport this pathogen from the West coast to vulnerable areas in the East. It was learned recently that APHIS needs to add the genus Magnolia to the “filthy five” group which is subject to the most careful regulation.

Whom to Contact

Please ask your Senators and Representative to support maintaining – or even increasing – funding for these APHIS programs. Your contact is especially important if you are represented by one of the members of the House or Senate Appropriations Committee’s Subcommittees on



* Robert Aderholt, Alabama, Chairman

* Kevin Yoder, Kansas

* Tom Rooney, Florida

* David Valadao, California

* Andy Harris, Maryland

* David Young, Iowa

* Steven Palazzo, Mississippi

* Sanford Bishop, Georgia, Ranking Member

* Rosa DeLauro, Connecticut

* Chellie Pingree, Maine

* Mark Pocan, Wisconsin



John Hoeven, North Dakota

Thad Cochran, Mississippi

Mitch McConnell, Kentucky

Susan Collins, Maine

Roy Blunt, Missouri

Jerry Moran, Kansas,

Marco Rubio, Florida

Jeff Merkley, Oregon

Diane Feinstein, California

Jon Tester, Montana

Tom Udall, New Mexico

Patrick Leahy, Vermont

Tammy Baldwin, Illinois




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  available at


Additional recent sources of information on tree-killing pests not being addressed by APHIS:

Article about the damage caused by the goldspotted oak borer:


GSOB at Irvine Regional Park in OC

Goldspotted Oak Borer video

The Los Angeles Times has published two recent articles about the shot hole borers at



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


Posted by Faith Campbell


CISP Starts Focus on Emerging Wildlife Diseases in Large Collaboration


A new CISP effort is underway: we are pleased to announce support for our work on emerging wildlife diseases. Funding for this collaborative effort was provided by the BAND Foundation, a charitable foundation whose mission includes conservation of wildlife and plant species and combatting wildlife diseases. The grant, managed by the Association of Fish & Wildlife Agencies (AFWA), will provide support through 2017 and 2018. The scope of the project is described in the following AFWA announcement. We will provide more information on the project as it develops.


Washington D.C. (May 4, 2017) – The Association of Fish & Wildlife Agencies is pleased to announce a partnership focused on fish and wildlife health, in collaboration with Bat Conservation International, the Amphibian Survival Alliance, the Amphibian and Reptile Conservancy, the Center for Invasive Species Prevention, and five universities in the United States.

 Disease is rapidly emerging as a major threat to wildlife globally. While wildlife diseases are not new, human actions are dramatically increasing their spread and impact. The partnership between the BAND Foundation and the Association will lead to more effective responses to emerging wildlife diseases.  Three specific emerging pathogens that affect bats (White-nose syndrome (WNS)), salamanders (Batrachochytrium salamandrivorans (Bsal)) and sea stars (Sea Star Wasting Disease (SSWD)) are of immediate concern in the United States. These families of animals play vital roles as ecosystem engineers across a range of habitats from agricultural landscapes to forests to intertidal zones. This project provides funding for critical research and monitoring to better understand the diseases that threaten them, aims to catalyze a public policy framework for tackling wildlife disease more broadly and strategically, and seeks to leverage additional dollars to address this critical issue.

 “State fish & wildlife agencies are on the front lines of wildlife disease prevention. This much needed funding will go a long way to prevent and prepare for disease outbreaks through the United States,” said Nick Wiley, President of the Association of Fish & Wildlife Agencies.

A conference to bring together experts in science and management of various wildlife diseases will be convened in 2018, to help further identify needs and improve communication and responses.

at: file:///C:/Users/Owner/Downloads/PR-%20AFWA%20Partners%20with%20the%20BAND%20Foundation.pdf .


Posted by Peter Jenkins

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.



Bill aimed at controlling invasive species on the ground advances

whitebark pine in Crater Lake National Park killed by white pine blister rust; photo by F.T. Campbell

In the first days of April, the Senate Environment and Public Works Committee  adopted the Wildlife Innovation and Longevity Driver Act (S. 826) (the WILD Act).

Title II of this legislation would amend the Fish and Wildlife Coordination Act by inserting language very similar to the Federal Land Invasive Species Control, Prevention, and Management Act (S. 509).  I blogged last year about that  bill and a hearing about it here.

Our concerns at the time focused on:

  • The provision allowing invasive control projects to proceed without first being evaluated by an environmental impact statement or environmental assessment. Lack of careful analysis could expose the environment to additional damage. For example, use of herbicides or grazing to control invasive plants can lead to suppression of native forbs. Suppressing invasion by one set of plants – whatever the strategy used – often facilitates a secondary invasion.
  • The mandatory funding allocations – which severely limit funds available to support research, outreach, and strategic planning and coordination – could undercut activities crucial to development and implementation of effective strategies and management tools.
  • The mandatory goal of reducing invasive species populations by 5% per year is unrealistic.
  • New requirements on reporting and coordination might divert already-thin resources and delay needed action.
  • Priority-setting. Managing invasive species on national lands should reflect national goals and perspectives, not be set by states’ governors.

Caroline Murphy of The Wildlife Society and I have reviewed Title II of the new WILD Act and find that it differs from last year’s invasive species control bill in several important ways:

  • The bill now applies to a wider range of agencies. The Secretary of the Army (who supervises the Corps of Engineers) is included explicitly; he joins the secretaries of Interior and Agriculture (as supervisor of the Forest Service). In addition, the bill also applies to the head of “any federal agency” having duties related to planning or treatment of invasive species “for the purpose of protecting water and wildlife on land and in water.”
  • Most important, projects are no longer granted a “Categorical Exclusion” from preparing environmental impact analyses. Instead, under an “Expedited Action” provision, the Secretaries are instructed to use all existing legal tools and flexibilities to expedite projects and activities.
  • The bill still requires that 75% of invasive species funds be allocated to “on-the-ground control and management of invasive species.” But such activity now may include “the use of appropriate methods to remove invasive species from a vehicle or vessel capable of conveyance.” I wish the language also included efforts to prevent invasive species from being present in or on the vehicle or vessel.
  • The bill has dropped the requirement that invasive species’ populations be reduced by 5% annually. The bill now requires the Secretaries to develop a strategic plan “to achieve, to the maximum extent practicable, a substantive annual net reduction of invasive species populations or infested acreage on land or water” that the Secretary manages. It is still not clear whether that reduction should apply to some or all of the invasive species there.

I am still concerned that

  • Projects are to use least-cost methods. This requirement is likely to favor reliance on chemical controls, which could have significant non-target impacts and might not provide lasting control. This incentive might be counter-balanced by the requirement that the methods be effective, based on sound scientific data. However, the bill’s focus on measuring annual results rather than long-term efficacy will add to pressures to rely on short-term approaches that could undermine long-term effectiveness.
  • Leadership of the projects – especially setting priorities – will be in hands of state governments, not the federal agencies which have the responsibility under federal law to manage the lands and waters that are to be protected. A partial counter-balance is the requirement that the appropriate federal agency Secretary determine which lands or waters need immediate action to address the invasive species risk.  Furthermore, the expedited actions are to be carried out in accordance with agency procedures, including any applicable land or resource management plan

I welcome the requirement that the Secretaries, in developing their strategic plans, must take into consideration the ecological as well as the economic costs of acting or not acting.

As before, the projects are to be carried out through collaboration with wide range of partners, including private individuals and entities – apparently including non-governmental organizations such as state or local invasive plant coalitions.

The rest of the WILD Act would reauthorize the Partners for Fish and Wildlife Program, some Multinational Species Conservation Fund Programs, and create several conservation-related competitive grant programs to be managed by the National Fish and Wildlife Foundation, one of which is for the management of invasive species.

Now that these provisions are incorporated into a wider bill, and Senator Barasso is chairman of the full committee, adoption of some version of this legislation now seems more likely than I thought last year.  Apparently there is still no action in House on the parallel bill.

While I am heartened by some of the changes in the bill since last year, I continue to think that America’s public lands would be better protected by a more comprehensive approach that includes prevention, mapping, early detection, research, prioritization, coordination and outreach aimed at engaging key stakeholders.  Such an approach was outlined in a document developed a couple of years ago by the National Environmental Coalition on Invasive Species (NECIS) – available here.

Posted by Faith Campbell

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

Injurious species ruling could lead to more invasions​


CISP and I are mentioned in this Newsweek article of April 12 ​about a court ruling that undercut ​ ​the past 28 years of the ​U.S. ​Fish and Wildlife Service’s ​(FWS)​ program of regulating “injurious species” under the Lacey Act at the level of interstate transportation within the 49 continental States.


Dr. Skip Snow, National Park Service Herpetologist, Everglades National Park, examines python captured in the Park; NPS photo


​ ​
What happened? In 201​3​, in ​DC ​District Court, the U.S. Association of Reptile Keepers (USARK) brought a suit that, among other arguments, claimed ​the Government (the ​USFWS), lacked statutory authority under the Lacey Act to regulate interstate commerce in large constrictor snakes among the 49 continental States​. The DC District Court agreed and that issue was ​prompt​ly appealed to the DC Circuit Court of Appeals​. Its ​April 7th ​opinion frames the issue like this (pp. 2-3):​


When a species is designated as injurious, the Act prohibits any importation of the species into the United States or its ​p​ossessions or territories. 18 U.S.C. § 42(a)(1). The Act additionally bars “any shipment” of the species“ ​​between the continental United States, the District of Columbia, Hawaii, the Commonwealth of Puerto Rico, or any possession of the United States.” Id.

​    ​

This case concerns the proper interpretation of the latter provision, which we will refer to as the shipment clause. All agree that the clause bars shipments of injurious species between each of the listed jurisdictions—for instance, shipments of animals between “Hawaii” and “the continental United States,” or between “the Commonwealth of Puerto Rico” and a “possession of the United States.” But what about ​shipments between the states making up “the continental United States”—for instance, shipments between Virginia and Maryland? Does the clause prohibit those shipments as well?​


The Court ​of Appeals ​answered the last question with a convincing “no”.​ 


It is important to note the effect is only on ​interstate commerce (“​IC ​”)​ among the 49 States and it does not change the FWS’ authority to regulate commerce between those named locations, that is, ​Hawaii, DC, PR, the possessions and the 49 States considered as one block​.  Also, the ruling does not ​at all ​affect the FWS’ authority to regulate imports of injurious species from other nations.


Was it unexpected? No. The USARK attorneys did outstanding legal work in revealing the early Legislative history ​ of the 1960 Lacey amendments at issue​ and the fact that,​ from 1960 through 1989, the FWS itself interpreted the statute not to allow it to regulate IC. The FWS only began regulating IC in its ​Lacey ​injurious species listings ​in​ about 1989, but it has continued to do that in every listing since 1989, ​under the last 5 Presidential administrations. The long delay in the Court challenge was largely due to lack of enough economic incentive for a regulated industry to bring a lawsuit to challenge ​the FWS changed approach​. It was not until USARK was motivated to raise a vast amount of contributions from its members to pays it large legal fees that a challenge was organized.


How broad is the ruling? Sweeping. It is n​either​ limited to the parties in th​e​ case ​n​or ​to the ​snakes involved. The opinion makes clear that the correct legal interpretation by the FWS from now on must be not to regulate IC among the continental 49 States, with this statement on p. 22:


   we …. hold as a matter of law that the government lacks authority under the shipment clause to prohibit shipments of injurious species between the continental States.     


Will there be more proceedings in the District Court? Likely yes, as USARK had brought other legal arguments claiming that the entire listings of their snakes (including regulation of foreign imports too) was illegal. Now that the pressing issue of the IC restriction ​for injurious species under the Lacey Act ​has been resolved, USARK can still make those arguments back in the District Court. My judgment ​as an attorney ​is those were all weak arguments and ultimately the listing of the snakes and trade restrictions will be upheld as legal by the Courts as far as ​regulating ​foreign imports and the commerce among the listed locations.


Is the ruling disallowing IC restrictions likely to have more appeals? No. It is theoretically possible that the Government could seek review from the Supreme Court, but doubtful that the Government will do that or that the Supreme Court would take the case.  Both the District Court Judge and the DC Circuit Court of Appeals (3 Judges) wrote very well-reasoned opinions, and there is no dissenting opinion or conflicting decision from any other Court. Given those circumstances, it is not the sort of case the Supreme Court would take, so the DC Circuit’s opinion should be considered the final word unless Congress changes the law.


When does it take effect? Immediately​, unless it is somehow blocked​. While the appeal was from a preliminary injunction, the ruling need not go back to the District Court now as far as the IC issue – that is decided as a matter of law. As the opinion pointed out ​(​pp. 7-8​)​​:​


      We reach a definitive judgment on the shipment clause’s meaning in order to “save the parties the expense of future l​itigation​”.​


What is the effect on existing Lacey Act injurious species listings? All existing injurious species listing regulations that claim to regulate IC must from now on be interpreted not to regulate IC. The FWS may re-issue some new listing regulations to make its lack of authority more clear, but even if the FWS delays in doing that the language in those regulations on regulating IC is now a nullity, that is, ​that language​  should be treated as if it does not exist.


It should be noted that ​ for​ the ​now​ 2​8​ different injurious species listing ​ decisions​ (some of which take in large numbers of species ​ totaling ~ 300 or up to ~700 species if the disease regulations are included​) th​e​ impact of this listing will vary greatly.  ​In reality​ only ​5 or 6​listings are significantly harmed ​now ​by the ruling. Most of the Lacey species listed are not in the US yet, ​e.g., Racoon dog, ​so the elimination of the IC restriction will have no effect currently and the continuing regulation of ​importation is all that is needed ​, unless the species does appear somewhere within the ​49 continental States​.

One ​listed species​, zebra mussel, ​is so widespread in the US ​already ​and/or ​its​ movement is generally unintentional s​o​ that the IC restriction has ​generally​ been unenforceable as a practical matter ​ (with some ​important ​exceptions to that)​.


One listing — the “all-salmonids pathogens” listing — was by its terms limited to regulating foreign imports and not IC, so it was not affected ​at all ​by the ruling.


But, for ​the ​listings ​​of​ the large constrictor snakes, the ​4 ​Asian carps​,​ the Northern snakehead​ and some others​, the Court ruling eliminating IC regulation will greatly weaken Federal control over the ​many ​species ​ within those listings​. ​Several​ of them are already fairly widespread ​in the country ​with captive and/or wild breeding populations to draw stock from. So ​just ​regulating their foreign importation is almost meaningless –  it is IC that is their most important risk. So​,​ we are more likely to see more invasions ​by those species i​n more States due to more ​unregulated ​IC unless that legal gap is filled.


Bsal regulation effect:​ The Bsal-prevention salamander ​foreign import ​regulation has been successful in keeping the Bsal pathogen out of the US (it appears​,​ based on monitoring so far), but the IC restriction had provided​ important ​insurance​ in the event that the pathogen is ​in fact ​here but just has yet to be detected. Or if the pathogen were to arrive, the IC restrictions would ​have ​facilitate​d​ a stronger preventative response, ​blocking or ​slowing spread from one State to another. ​Now, ​if the pathogen arrives with ​no IC restrictions in place, interstate trade in ​infected ​salamanders could rapidly spread a potentially devastating, nationwide, ​Bsal outbreak.


What is the effect on existing permits for interstate movement of listed species? To the extent the permits relate to foreign imports or movements between Hawaii, DC, ​PR, ​the ​possessions/​

territories or the continental States  considered as a whole​, the permit system is still in effect. As far as permits ​for movements ​within the continental 49 States, it should be expected that the FWS will modify their terms. Until the FWS does that or provides clarification​,​ the permit holders should ​follow​ the terms of their permits.


What might Congress do in response? Congress could pass a law filling the gap and returning ​the ​FWS IC regulation ​program ​to the status quo that has exist​ed​ since 1989. Such a law could be quite narrow, targeting only the IC gap, or it could be broader, including an IC gap fix within a broader new law. Or Congress could take no action, leaving the effect of the Court ruling in place.


What might State fish and wildlife agencies do in response? Unless it appears that Congress will fill the IC gap quickly, then concerned States may wish to promptly ​adopt ​their own new laws ​/regulations​ restricting commerce into their States of the species involved. This seems ​the ​highest priority for the States most at risk from the species whose IC has been most liberalized by the ruling, that is, the large constrictor snakes, the ​4​ Asian carps​,​ the Northern snakehead and ​the ​salamanders that the FWS listed as potentially carrying Bsal. (Some States already may have such restrictions on the books.)


​ Note that Hawaii is well-protected as a specially-designated State and need take no action, as is also true for DC, PR and the territories.​


It is too soon to know what the policy responses may be, but the FWS, State agencies and stakeholders likely are evaluating options now. ​


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

​Posted by Peter Jenkins


USDA needs to utilize the NAPPRA Process to Prevent New Introductions



America’s imports of plants to serve various purposes have been a major pathway for introduction of invasive species – both some of the plant species imported intentionally and insects and pathogens associated with those plant imports.

Examples of the former include numerous forage grasses, Callery pear (just past its peak bloom here in the MidAtlantic region), autumn and Russian olive, kudzu, shrub and vining euonymus, iceplant, … [see my blogs from January 2016  and March 2016 for more about invasive plants].

Pests introduced on imported plants range from chestnut blight and white pine blister rust at the beginning of the 20th Century to sudden oak death in the 1980s and probably the polyphagous and Kuroshio shot hole borers more recently. All these pests are described briefly here.

For lengthy discussions of the “plants for planting” pathway of introduction for insects and pathogens, read my report Fading Forests III available here; or the Liebhold et al. article referenced at the end of this blog.

A new article by Barry Yeoman describes the effects on wildlife species of these introductions. “Going Native: Exotic garden plants can wreak unexpected havoc with indigenous species and ecosystems” can be read here .

dogwood anthracnose; Robert L. Anderson. courtesy of

Yeoman notes that birds and other wildlife that feed on the fruits of native dogwood can’t utilize the fruits of the introduced kousa dogwood. Furthermore, native dogwoods have been decimated by dogwood anthracnose  – probably introduced on imports of kousa dogwood! Another pest example cited by Yeoman is the loss of eastern hemlock to hemlock woolly adelgid.

Yeoman goes on to report the impacts on wildlife species of such invasive plant species as Japanese knotweed, autumn olive, Chinese tallowtree, and Japanese barberry. The last is even linked to higher populations of the ticks that spread Lyme disease.

Yeoman writes that the United States has “a feeble system of regulating garden imports. Each new species is presumed harmless until proven otherwise—and by the time a verdict arrives, the harm is often beyond repair.”  He criticizes our government’s reliance on a modified blacklist system – a short list of “noxious weeds” .  This approach allows potential invaders to enter the country without scientific evaluation.


As Yeoman describes in the article, the noxious weed list is supplemented by a small “graylist” of plant species that could potentially cause harm and are temporarily barred until they can be evaluated. Yeoman does not describe the program under which this “graylist” has been created. In May 2011, USDA APHIS  created a temporary holding category, called “Not Authorized (for importation) Pending Pest Risk Analysis,” or NAPPRA. With this authority, APHIS may temporarily prohibit import of certain types of plants, from specific countries of origin, that it considers to pose a particular risk. The risk might be invasiveness of the plant species itself, or pests associated with the plants. The temporary prohibition on imports of those species gives APHIS time to complete a pest risk analysis and then enact appropriate safeguards to ensure that the imported plants will not be invasive or present as low a pest risk as possible.


For a more complete description of the graylist process, called NAPPRA, read Fading Forests III here .


The NAPPRA process holds the promise of providing substantial protection by curtailing imports of high-risk plants.  However, its implementation has stalled. APHIS last proposed additions to the list of plant species prohibited entry temporarily in May 2013 – almost four years ago!  APHIS should revive the NAPPRA process and utilize prompt listing of plants under this authority to minimize the risk that new pests will be introduced.



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


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


Posted by Faith Campbell

Pest threat to West Coast confirmed – authorities should respond to this information by taking protective measures

 Numbers of non-native pests in counties of the 49 continental states; Map prepared by Andrew Liebhold, USFS in 2014. More recent introductions are not represented; nor are insects native to some part of North America

Currently, the Northeast and Midwest have the highest number of non-native, tree-killing insect and pathogen species (see map above). However, Pacific coast states have two-thirds the numbers of pest species of the Northeast – and are catching up. Two articles modeling the likelihood of new pest introductions point to the particular vulnerability of the Pacific Coast states – especially California – to pest introductions from Asia.


Koch et al. 2011 (see reference at the end of the blog) utilized various sources of information about volumes of imports likely to be associated with wood-boring pests — stone; raw wood and wood products (including crates & pallets); metals; non-metallic minerals; auto parts; etc. From this, the authors estimated both a nationwide establishment rate of wood-boring forest insect species and the likelihood that such insects might establish at more than 3,000 urban areas in the contiguous U.S. While their estimate was based on 2010 imports, they also projected rates for 2020.


See my blog from March 10  for various scientists’ estimates of  the overall, nationwide rate of introduction.  Koch et al. estimated the nation-wide introduction rate at between 0.6 and 1.89 forest insects and pathogen species per year for the period 2001–2010 and 0.36 and 1.7 species per year for 2011–2020.  In other words, we should expect a new alien forest insect species to become established somewhere in the United States every 2–3 years. If one-tenth of these new introductions turn out to cause significant damage, then we can expect a “significant” new forest pest every 5–6 years.


Pacific coast states – especially California – are at highest risk. 

Koch et al. evaluated the introduction risk for 3,126 urban areas across the country. The metropolitan area with the highest risk is Los Angeles–Long Beach–Santa Ana, California. For both 2010 and 2020, the predicted rates for a new pest establishing there is every 4–5 years.


Looking ahead to 2020, the situation worsens for three California metro areas – Los Angeles–Long Beach–Santa Ana; San Diego; and Riverside-San Bernardino. At San Francisco-Oakland, the predicted establishment rates remain steady. Most of the rest of the top 25 urban areas show decreases in establishment rate between 2010 and 2020.


This rising risk to California urban areas is driven by the growth of imports from Asia. For the four California urban areas, the establishment rate of Asian species is projected to increase 6–8% between 2010 and 2020. The Los Angeles–Long Beach–Santa Ana area could potentially expect the establishment of an alien forest insect species originating specifically from Asia alone (not the entire world) every 4–5 years.

[The polyphagous and Kuroshio shot hole borers are examples of recently introduced pests from Asia.  Both are described, inter alia, here; a distribution map for PSHB is available here.]

Koch et al. note that the Los Angeles metropolitan area has a dense human population with corresponding high demand for goods and materials, so a substantial proportion of imports clearing the port remains in the areas.  Furthermore, widespread planting of non-native plants provides a range of potential hosts that can support invaders that would not otherwise become successfully established.


A second source also indicates a heightened risk to Pacific Coast states. Yemshanof et al. used similar modeling techniques to evaluate the risk of tree pest introductions to Canada … and to the U.S. in the form of transshipped goods.  (See my earlier blog.)


The Yemshanof et al. model showed that 8% of all forest pests introduced to the U.S. on imported wood or wood packaging — as estimated by Koch et al. — would come through goods transshipped through Canada. The risk is highest to the Pacific Coast states since they are the most likely to receive Asian goods transiting through Canada.


Note that the phytosanitary agencies in both the U.S. and Canada proposed in 2010 that wood packaging originating in one of the countries and shipped to the other be required to meet the international regulations under ISPM#15. However, APHIS was unable to adopt this regulation under the Obama Administration, and such an action seems even less likely under the Trump Administration. Canada is unlikely to adopt the new rules without a coordinated U.S. action.


Southern California also imports lots of plants – another pathway for pest introductions.


Koch et al. suggest that authorities use these models to prioritize border control efforts (e.g., commodity inspections), post-border surveillance, and rapid-response measures.  I see some problems with these suggestions.  First, enhanced commodity inspections are not likely to measurably diminish the risk of introduction to the region. Second, rapid-response measures require both increased funds – which are expected to decrease; and political will. I have blogged several times about California’s decisions to not implement official, regulatory responses to recently detected pests.


Instead, people in the region should actively build alliances and press their regional political leaders – governors, mayors, senators, members of Congress – to demand that the U.S. Department of Agriculture and the Congress adopt policies that will strengthen protection for the region’s trees.


New pest detected in California!


California authorities have detected a new woodboring beetle – the olive wood borer (Phloeotribus scarabaeoides). It was detected in an olive tree in a grape vineyard in Riverside County. This is the first detection of the species in the Western Hemisphere. Known or suspected hosts include several trees in the olive family (Oleaceae), including olive trees, privet, ash, and common lilac; as well as oleander (Apocynaceae).


Since this new pest is native to the Mediterranean region, it does not appear to be an example of the risk to California from Asia …  The source (Diagnostic Network News; see below) does not speculate on the pathway by which the introduction occurred.



What Can We Do?


Ask your state’s Governor to

  • Communicate to the USDA Secretary the need to amend policies & regulations

(Coordinate this effort with governors of other states.)

  • Put forest pest issue on the agenda of National Governors’ Association
  • Ask your state’s Congressional delegation to pressure USDA Secretary to amend policies and regulations
  • Communicate concern about these pests to the media — and propose solutions.


Ask your state’s agricultural and forestry agency heads to

  • Ask their national associations to support proposals to USDA Secretary & Congress. These associations include
    • National Association of State Departments of Agriculture (NASDA)
    • National Association of State Foresters (NASF) or its Western regional group, the Council of Western State Foresters
  • Communicate to the media both the agency’s concern about tree pest threats and proposed solutions.


We can also act directly.

  • Ask mayors and officials of affected towns and counties to
  • Push proposals at regional or National Conference of Mayors or National Association of Counties
  • Instruct local forestry staff to seek support of local citizen tree care associations, regional and national associations of arborists, Arbor Day & “Tree City” organizations, Sustainable Urban Forest Coalition, etc.
  • Reach out to local media with a message that includes descriptions of policy actions intended to protect trees — not just damage caused by the pests
  • Ask stakeholder organizations of which you are a member to speak up on the issue and support proposed solutions; e.g.,
    • Professional/scientific associations
    • Wood products industry
    • Forest landowners
    • Environmental NGOs
    • Urban tree advocacy & support organizations


  • Encourage like-minded colleagues in other states to press the agenda with their state & federal political players, agencies, & media.
  • Communicate to the media both your concern about tree pest threats and proposed solutions.


What Specific Actions Should We Suggest be Taken?

I suggest a coordinated package.  However, you might feel more comfortable selecting a few to address each time you communicate with a policymaker. Choose those on which you have the most expertise; or that you think will have the greatest impact.

  • Make specific proposals, not vague ideas (see below for suggestions)
  • Always include information about how the pests arrive/spread (pathways such as imports of crates & pallets, or woody plants for ornamental horticulture) and what we can do to clean up those pathways  (Don’t just describe the “freak of the week”)
  • Always point out that the burden of pest-related losses and costs falls on ordinary people and their communities. (Aukema et al. 2011 provides backup for this at the national level; try to get information about your state or city.)
  • We need to restore a sense of crisis to prompt action – but not leave people feeling helpless! We need also to bolster understanding that we have been and can again be successful in combatting tree pests.


Specific actions that will reduce risk that pests pose to our trees:

  • Importers switch from packaging made from solid wood (e.g., boards and 4”x4”s) to packaging made from other materials, e.g., particle boards, plastic, metal …
  • Persuade APHIS to initiate a rulemaking to require importers to make the shift. This can be done – although international trade agreements require preparation of a risk assessment that justifies the action because it addresses an identified risk (see my earlier blogs about wood packaging).
  • Create voluntary certification programs and persuade major importers to join them. One option is to incorporate non-wood packaging into the Department of Homeland Security Bureau of Customs and Border Protection’s (CBP) existing Customs-Trade Partnership Against terrorism (C-TPAT) program.


  • Tighten enforcement by penalizing shipments in packaging that does not comply with the current regulations
  • Persuade CBP and/or USDA to end current policy under which no financial penalty is imposed until a specific importer has been caught five times in a single year with non-compliant wood packaging. APHIS has plenty of authority to penalize violators under the Plant Protection Act [U.S.C. §7734 (b) (1)].
  • Restrict imports of woody plants that are more likely to transport pests that threaten our trees
  • In 2011, APHIS adopted regulations giving it the power to temporarily prohibit importation of designated high-risk plants until the agency has carried out a risk assessment and implemented stronger phytosanitary measures to address those risks. Plants deserving such additional scrutiny can be declared “not authorized for importation pending pest risk assessment,” or “NAPPRA”. A list of plants posing a heightened risk was proposed nearly 4 years ago, but it has not been finalized – so imports continue. APHIS should revive the NAPPRA process and utilize prompt listing of plants under this authority to minimize the risk that new pests will be introduced.
  • APHIS should finalize amendments to the “Q-37” regulation (proposed nearly 4 years ago) that would establish APHIS’ authority to require foreign suppliers to implement integrated programs to minimize pest risk. Once this regulation is finalized, APHIS could begin negotiating agreements with individual countries to adopt systems intended to ensure pest-free status of those plant types, species, and origins currently considered to pose a medium to high risk.


  • Strengthen early detection/rapid response programs by
  • Providing adequate funds to federal & state detection and rapid response programs. The funds must be available for the length of the eradication program – often a decade or more.
  • Better coordinate APHIS, USFS, state, & tribal surveillance programs.
  • Engage tree professionals & citizen scientists more effectively in surveillance programs.





Koch, F.H., D. Yemshanov, M. Colunga-Garcia, R.D. Magarey, W.D. Smith. Potential establishment of alien-invasive forest insect species in the United States: where and how many? Biol Invasions (2011) 13:969–985


Western Plant Diagnostic Network First Detector News. Winter 2017. Volume 10, Number 1.


Yemshanov, D., F.H. Koch, M. Ducey, K. Koehler. 2012.  Trade-associated pathways of alien forest insect entries in Canada. Biol Invasions (2012) 14:797–812


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

Posted by Faith Campbell