Californians – regulate firewood! Protect your trees!

A new outbreak of the goldspotted oak borer raises again the question of why California does not outlaw the movement of untreated firewood.

goldspotted oak borer
goldspotted oak borer

This beetle – which has already killed more than 80,000 oak trees! – has been detected in the town of Green Valley, a small town in Los Angeles County north of the city, and inside the boundaries of the Los Padres National Forest. The first surveys found 27 coast live oak trees with symptoms of beetle attack.
The beetles in Green Valley are genetically identical to those in San Diego County – strongly indicating that the outbreak was started by people moving firewood out of the infested area.
As I noted in my blog dated July 15, the California Department of Food and Agriculture (CDFA) has so far refused to adopt regulations governing movement of firewood. While CDFA and other entities have sponsored billboards, flyers, and other outreach materials to educate people about the risk associated with firewood, the failure to ban firewood movement puts oaks throughout the state at risk.


areas of California in which oaks are at risk to GSOB
areas of California in which oaks are at risk to GSOB (redder areas at greatest risk)

A second pest – the polyphagous shot hole borer and its associated Fusarium fungi – threatens a much wider range of trees. It is currently established in Los Angeles, Orange, San Bernardino, Riverside, and San Diego counties. It is known to attack Coast live oak, valley oak, Engelmann oak, California sycamore, big leaf maple and box elder, cottonwood, alder, and ash. This beetle, too, can be moved in firewood.
Californians should ask Governor Brown to adopt regulations restricting movement of untreated firewood. Act now! to protect your trees from goldspotted oak borer, polyphagous shot hole borer, and other non-native insects.
Posted by Faith Campbell

APHIS has a tough job – and deserves praise

Carrying out a pest eradication program is a tough job – technically difficult, expensive, frustrating, and often generating opposition from various groups. But often eradication is crucial. It is the essential backup to the strategies aimed at preventing introduction in the first place.

Damage to red maple; photo by Michael Smith, USDA
Damage to red maple; photo by Michael Smith, USDA

USDA APHIS is responsible for developing and implementing eradication programs targeting non-native plant pests – including those that kill trees. APHIS just released an environmental impact statement covering its efforts to eradicate the Asian longhorned beetle (ALB) it is available here. The EIS justifies both the eradication program targeting this species, itself, as well as the specific measures used.
The ALB is one of the most damaging pests ever introduced to North America; it would kill trees in 12 genera which collectively grow in forests across the 48 continental states. In the Northeast (a 20-state area reaching from Minnesota south to Missouri and east to Maine and Virginia), trees vulnerable to ALB dominate two forest types that collectively make up 45% of all forests. Indeed, these vulnerable forests cover almost 20% of the entire land area of these states. For a longer description of the ALB threat, read about the pest in the Gallery of Pests and consider the map below.

Areas at risk to ALB; USGS. 2014. Digital representations of tree species range maps from “Atlas of United States Trees” by Elbert L. Little Jr. (and other publications).
Areas at risk to ALB;
USGS. 2014. Digital representations of tree species range maps from “Atlas of United States Trees” by Elbert L. Little Jr. (and other publications).

The APHIS program – carried out with the help of the USDA Forest Service, other federal agencies, state agencies, local governments, and citizen volunteers – has succeed in eradicating ALB from six sites.
The EIS also makes clear what a tremendous effort such an eradication program demands. APHIS began trying to eradicate ALB 19 years ago, upon discovery of the outbreak in Brooklyn. Since then, APHIS has spent $500 million tackling outbreaks in five states, cut down more than 124,000 trees, and treated tens of thousands of additional trees with the systemic insecticide imidacloprid. Yet more work remains because large outbreaks in Worcester, Massachusetts and Clermont County, Ohio are not yet contained. Eradicating these outbreaks will take many years.
The EIS does not explicitly acknowledge the strong opposition that APHIS has faced from people who were understandably anguished over loss of their trees – especially the trees that were still healthy but posed a risk of enabling ALB to persist and spread across the Continent. Some of the opponents were further angered because they believed – based on misunderstandings or false information – that removing those trees was not a necessary action to protect trees across the Continent.
APHIS deserves our gratitude for persisting in its eradication efforts, despite vocal opposition, uncertainty over funding levels, and the many discouraging setbacks encountered while the agency was trying to improve methods to detect ALB and to contain pest populations.
I’m discouraged that the people who owe the most to APHIS don’t recognize the agency’s efforts. Unfortunately, many appear either to take these actions for granted or to ignore them completely. APHIS received only 27 comments on its notice that it would develop the EIS, and only 14 comments on the EIS itself.
Who should have commented? Everyone who cares about:
• The health of hardwood forests composed of maples, elms, ash, poplars, buckeyes, birch, or willows; these genera are most dense in forests of the Northeast, but – as the map above shows – they grow in forested areas throughout the “lower 48”.
• The health of urban forests and the ecosystem and public health benefits they provide. Cities with high proportions of trees vulnerable to ALB range from Seattle to Boston.
• Clean drinking water for. In the Northeast, 48% of the water supply originates on forestlands – and 45% of those forest lands are composed primarily of species that are vulnerable to ALB.
• The economy and jobs in the Northeast. Vulnerable hardwoods produce timber and maple syrup and are the foundation of the “leaf peeper” tourism industry.
Those who actually did provide comments included:
• Six state departments of Agriculture and their national association, the National Plant Board;
• Four officials in other state agencies (primarily forestry or environmental quality);
• Four officials from other federal agencies (three from National Park Service, one from Fish and Wildlife Service);
• About 20 representing the public, of which:
o Four were affiliated with the maple syrup industry;
o Six organizations focused on wildland or rural forests.

I hope that the next time APHIS seeks public input on its programs, the following organizations will provide thoughtful input:
• the national or regional representatives of state forestry departments;
• the many environmental organizations that engage so actively on other types of forest management issues;
• the organizations that advocate for planting and protecting urban forests;
• the groups that support recreation in forests and on associated lakes and streams;
• the organizations that advocate for protection of wildlife habitat.
APHIS tried hard to inform all who might be interested. APHIS posted the scoping notice and availability of the draft environmental impact statement in the Federal Register. Also, it posted alerts on its Stakeholder Registry (which contains almost 12,000 contacts); its e-newsletter; its Facebook and Twitter accounts; and the agency’s “news and information” and ALB-related web pages. In addition, APHIS notified ALB project managers in New York, Massachusetts, and Ohio and their state counterparts and asked that they notify their key contacts; tribal contacts; USDA Forest Service and U.S. Fish and Wildlife Service contacts; plus several specific partners and organizations. APHIS also issued a press release which it shared with federal and state partners.
Why does it matter that APHIS received so few comments? This silence gives political and agency leaders the impression that the American public does not support efforts to prevent the spread or to eradicate tree-killing insects and pathogens. I hope this is not true!
This negative impression remains even if there are many stakeholders who are pleased with the program’s direction and progress. Their choice not to voice their support meant that only those who object to at least some components of the program are heard in the policy arena.
I plead with you – get involved! Support those parts of APHIS’s eradication and containment programs that you think are wise. Criticize those components that you think should be strengthened or changed.
Posted by Faith Campbell

Wood Packaging – Customs Efforts & Recent Detections

As noted in my blog of July 15, damaging pests continue to enter the country in wood packaging. The most comprehensive study indicates that tree-killing pests are found in an estimated 13,000 containers entering the country each year – or 35 per day.
These pests are present despite requirements adopted 9 or more years ago that wood packaging be treated.

Types of cargo packaged in wood are inspected by agricultural specialists within the Bureau of Customs and Border Protection , a division of the Department of Homeland Security. CBP agricultural specialists work at 167 sea, air and land ports of entry.  See an article about CBP efforts to curb introductions of tree-killing pests posted at

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
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

According to the CBP in the above article, the types of commodities imported that have the highest rates of SWPM-related pest interceptions are metal and stone products (including tile), machinery (such as automobile parts and farm equipment), electronics, bulk food shipments and finished wood articles.
These imports have a long-standing record of pest presence – as described in Chapter 4 of my lengthy report on tree-killing pests.

According to the CBP , 48% of the wood packaging entering the country that does not comply with the treatment requirements comes from Mexico. Mexican maquiladoras are factories that import material and equipment duty-free, then assemble a wide range of products – auto parts, apparel, electronics, furniture, and appliances. Mexico’s 3,000 maquiladoras account for half of Mexico’s exports.
China has the second worst record.
Of course, we import lots of stuff from both countries! However, the China situation is particularly disturbing because the U.S. has required that wood packaging from China be treated since the beginning of 1999 – 16 years!
The ports receiving highest numbers of shipments with non-compliant wood packaging materials have consistently been those along the U.S.-Mexico border, especially in Texas: Laredo, Pharr, more recently Brownsville & Houston. Other ports receiving high volumes of non-compliant wood packaging include Blaine, Washington; Long Beach, California; and Romulus, Michigan.

USDA APHIS and CBP have cooperated in a program under which insect larvae found in wood packaging are identified as to species. In recent years, they have studied larvae detected in wood packaging from eight ports – Long Beach, Seattle; 2 ports in Florida; and three cities on the Texas-Mexico border. (Remember, there are 167 ports of entry across the country, so this sample represented 5% of all ports.) Found at these ports were an unreported total of insects, including 116 individuals in the same family as Asian longhorned beetle (Cerambycids). Forty-three were from China (including 5 ALB), 20 from Russia, and seven from Mexico (Philip Berger, APHIS, at the annual meeting of the Continental Dialogue on Non-Native Forest Insects and Diseases, November 2014)

Most familiar – and frightening! – examples of pests introduced via wood packaging include Asian longhorned beetle, emerald ash borer, redbay ambrosia beetle and its accompanying fungus, and possibly polyphagous shot hole borer and its accompanying fungus – all described here.

The prospect of receiving additional insects from Asia scares everyone. What if a new pest is as bad as the four we already have? The emerald ash borer has already caused the removal of an estimated 50 million trees and continues to spread to ash trees – and now white fringe trees – throughout America east of the Great Plains. Laurel wilt disease (transmitted by the redbay ambrosia beetle) is rapidly eradicating redbay trees in the southeast, including in Everglades National Park – one of the icons of the American conservation movement. The Asian longhorned beetle has already caused removal of more than 124,000 trees from our cities, suburbs, and nearby woodlands – at a cost to federal taxpayers of more than $500 million. If it escapes eradication programs, it threatens trees in 10% of America’s forests. The polyphagous shot hole borer threatens numerous tree species that, collectively, make up more than half the trees planted in urbanareas in Southern California.

While no one denies the threat from insects native to Asia, we should not be complacent about insects from Mexico. Although we are neighbors, our forests are separated by deserts – allowing insects to evolve there to which our trees are vulnerable. Three wood-boring beetles native to Mexico and possibly some U.S. border states are already causing havoc to U.S. trees – goldspotted oak borer, soapberry borer, and walnut twig beetle and its accompanying fungus (all described here).  The first two were introduced to vulnerable forests through movement of firewood, not wood packaging. The third – the walnut twig beetle – might be native to California, although thousand cankers disease is killing native California walnuts throughout the state so something is different than it used to be.

goldspotted oak borer
goldspotted oak borer

When Customs officials detect wood packaging that does not comply with ISPM #15 (“noncompliance” means one of three things: the wood does not bear the ISPM #15 stamp; or the stamp appears to be fraudulent; or signs of pests are detected), that wood must be re-exported immediately, usually with the associated commodity. If any insects present pose an immediate risk of introduction, e.g., if adults are emerging, the shipment might need to be fumigated before re-export.
Re-exported shipments – and any treatments – cause importers to lose income and face costly delays. Still, the continuing presence of non-compliant wood packaging indicates that these inconveniences are insufficient to prompt importers to take all precautions possible to ensure that packaging used by their suppliers and brokers comply with the requirements.

Why don’t importers use alternative packaging made from plastic, steel, or composites that would not harbor tree-killing insects? Plastic pallets also weigh much less than wooden ones, so transport costs are reduced. Customs has pointed out the advantages. … Still, packaging material made from wood is comparatively plentiful, cheap, easy to repair, biodegradable. So it continues to dominate the market.
What steps can be taken by the U.S. government and importers to minimize the presence of insects in packaging?
• U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with the regulations.
• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .
• USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.
• The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)
• Importer’ contracts with suppliers routinely specify penalties for delivery delays; the contracts should be amended to add penalties for noncompliant wood packaging.
• A decade ago, USDA APHIS funded research which developed an ingenious method for detecting mobile pests inside a container. It was an LED light attached to a sticky trap. Placed inside a container, the light attracted snails, insects and possibly other living organisms. The whole mechanism was attached to a mailing container that could be pre-addressed for sending to a lab that could identify the pests. Why was this tool never implemented?

Posted by Faith Campbell