The emerald ash borer (EAB) was first detected in European Russia in 2003, in Moscow. By 2020, EAB was recorded in 16 provinces [=‘oblast’] of European Russia, especially to the West of Moscow towards the borders with Belarus and Ukraine.
Russian scientists have documented that the emerald ash borer is spreading faster in the southwest of the country and in neighboring Ukraine than in the northwest (near St. Petersburg and the Baltic countries).
Despite an abundance of ash [both green ash (Fraxinus pennsylvanica) – native to North America – and European ash F. excelsior], EAB population density in the northwest remains low and damage is in scattered clusters.
However, in September 2020 officials detected an isolated outbreak in a St. Petersburg suburb, 520 km away from the apparent edge of the principal Russian population. The authors believe this outbreak has been present since 2015. They think it is the result of transport of EAB either by “insect-hitchhiking” on vehicles or by movement of plants for planting or other commodities.
The Petersburg population is only 130 km from Estonia and Finland – the border with the European Union.
A thousand kilometers to the south, in southwest Russian eastern Ukraine, an outbreak was reported in June 2019. By the next summer, EAB were detected more than 100 km to the West. While this outbreak is still 800 km from Ukraine’s border with eastern Europe (Poland, Slovakia, Hungary, Romania), the authors note that rapid spread is likely since F. excelsior and F. pennsylvanica have been extensively planted along roads, railways, field shelter belts, and urban greenings.
The slower spread in the North is attributed to colder temperatures, the local abundance of food, and possibly pressure by the native parasitoid Spathius polonicus Niezabitowski (note that USDA APHIS has approved two Spathius species as biocontrol agents in the U.S.). On the other hand, the climate is milder in Saint Petersburg (along the coast) than it is inland; and ash woodlands are common along the Baltic coast.
Noting that ash dieback (Hymenoscyphus fraxineus) has devastated more than 95% of European ash populations, the authors express concern about the future of ash.
SOURCE
Musolin, D.L.; Selikhovkin, A.V.; Peregudova, E.Y.; Popovichev, B.G.; Mandelshtam, M.Y.; Baranchikov, Y.N.; Vasaitis, R. North-Westward Expansion of the Invasive Range of Emerald Ash Borer, Agrilus planipennis Fairmaire (Coleoptera: Buprestidae) towards the EU: From Moscow to Saint Petersburg. Forests 2021, 12, 502. https://doi.org/10.3390/f12040502
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
Two USDA agencies lead efforts to protect U.S. wildland, rural, and urban forests from non-native insects and disease-causing pathogens:
USDA Animal and Plant Health Inspection Service (APHIS) has legal responsibility for preventing introduction of tree-killing pests, detecting newly introduced pests, and initiating eradication and containment programs intended to minimize the damage they cause.
USDA Forest Service (USFS)
Forest Health Management (FHM) program assists partner agencies to counter pests where they are first found – usually near cities – and when they spread. This work falls primarily to the Cooperative component of Forest Health Management program. The Federal lands component helps the USFS, National Park Service, and other federal agencies counter pests that have spread to more rural/wildland areas.
Research and Development (R&D) program supports research into pest-host relationships, introduction & spread pathways, management strategies (including biocontrol) and host resistance breeding
Since 2010, several new tree-killing pests have been detected in the US, including polyphagous and Kuroshio shot hole borers, spotted lanternfly, two rapid ʻōhiʻa death pathogens, and Mediterranean oak beetle. Over the same period. the Asian longhorned beetle has been detected in two new states – Ohio and South Carolina; the emerald ash borer expanded its range from 14 to 35 states; laurel wilt disease spread from five states to 11; a second strain of the sudden oak death fungus appeared in Oregon and California forests; and whitebark pine has been proposed by the US Fish and Wildlife Service for listing as Threatened under the Endangered Species Act. (I have blogged often about policy failures that have contributed to these introductions; today I am focused on agencies’ ability to respond.)
Funding agencies’ essential programs has fallen behind these calamities. APHIS funding has been steady or has risen slowly – at least not dropping – but not enough to deal with the growing threat.
Meanwhile, the key USFS programs have been cut by half or more. In 2010, USFS FHP and Research, together, allocated $32 million to efforts to understand and manage a dozen introduced pests: Asian longhorned beetle, emerald ash borer, sudden oak death, hemlock woolly adelgid, goldspotted oak borer, laurel wilt, thousand cankers disease, European gypsy moth, Port-Orford cedar root disease, Sirex woodwasp, and white pine blister rust (especially on whitebark pine). By 2021, this total had fallen to about $10 million. There was no indication that any USFS R&D funding has been allocated to recently detected, highly damaging pests, i.e., rapid ʻōhiʻa death, the polyphagous and Kuroshio shot hole borers, Mediterranean oak beetle, or beech leaf disease. USFS FHP has funded work on some of these pests through its “emerging pest” fund – but that fund is limited to $500,000 for the entire country.
At present, more than 228 tree species growing in the “lower 48” states are infested by an exotic pest. The 15 most damaging of the introduced species threaten 41.1% of the total live forest biomass in the 48 conterminous states. Additional trees on the Hawaiian and other Pacific islands are also being killed by non-native insects and pathogens. Non-native forest pests have caused a 5% increase in total mortality by tree volume nation-wide. The greatest increases in mortality rates have been a four-fold increase for redbay; and a three-fold increase each for ash, beech, and hemlock.
Introductions of tree-killing pests occur because we import things! The highly damaging wood-borers can arrive in crates, pallets, and other forms of packaging made of wood. Other pests – especially plant diseases – come here on imported plants. Gypsy moth and spotted lanternfly egg masses can be attached to virtually any hard surface, e.g., steel slabs, vehicles, stone, containers, or ship superstructures.
Imports from Asia pose a particularly high risk – illustrated by the Asian longhorned beetle, emerald ash borer, polyphagous and Kuroshio shot hole borers, sudden oak death, and spotted lanternfly.
U.S. imports from Asia rose almost a third between 2019 and 2020. No part of the country is safe. While nearly half of imports from Asia enter via Los Angeles/Long Beach, California, another 21% entered via New York – New Jersey and Savannah. Other ports in the “Top 10” were the Northwest Seaport Alliance of Seattle and Tacoma, Oakland, Norfolk, Houston, Charleston, Baltimore, and Mobile.
Pests don’t stay in the cities where they first arrive. Instead, they proliferate and spread to other vulnerable trees – often assisted by people moving firewood, plants or household goods. For example, less than 20 years after their first detections, the emerald ash borer has spread to 35 states, the redbay ambrosia beetle to 11.
[For more information, read my earlier blogs posted here or species-specific descriptions here.]
Please contact your Representative and Senators and urge them to push for increased funding for key programs managed by these two agencies. I describe funding needs below. I list members of the appropriate Congressional subcommittees at the end of this blog.
APHIS headquarters
USDA APHIS programs (all included under “Plant Protection and Quarantine”)
APHIS Program
FY 2020 (millions)
FY 2021 (millions)
FY 2022 ask
Tree & Wood Pest
$60.000
$60.456
$70 million
Specialty Crops
$192.000
$196.553
$200 million
Pest Detection
$27.446
$27.733
$30 million
Methods Development
$20.686
$20.844
$25 million
APHIS’ “Tree & Wood Pests” account has traditionally supported eradication and control efforts targeting only three insects: the Asian longhorned beetle (ALB), emerald ash borer (EAB), and gypsy moth. The program to eradicate the ALB has received about two-thirds of the funds — $40 million. There is encouraging progress in Massachusetts, New York, and Ohio. Clearly, this program must be maintained until final success is achieved. Plus the program must now counter the Charleston, South Carolina, outbreak, where more than 4,000 infested trees have been detected in an area of 58 square miles. (See my blog here, which describes the difficult conditions arising from wetlands in South Carolina.)
APHIS has terminated its emerald ash borer regulatory program, which had previously been funded at about $7 million per year. (See my blog). APHIS has said it will now focus on production and release of biocontrol agents, although it has not indicated the funding level. It is probable that EAB will now spread more rapidly to the mountain and Pacific Coast states, threatening both riparian woodlands and urban forests.
APHIS’ “Specialty Crops” program funds APHIS’ regulation of nursery operations to prevent spread of the sudden oak death pathogen. APHIS must improve that program to avoid a repetition of the 2019 incident, in which plants infected by the SOD pathogen were shipped to 14 states.
This budget line also supports efforts to manage the spotted lanternfly, which has spread from Pennsylvania to seven other mid-Atlantic states.
The “Pest Detection” budget line supports the collaborative state –federal program that detects newly introduced pests. Successful eradication and containment programs depend on early detection.
The “Methods Development” program assists APHIS in developing detection and eradication tools essential for an effective response to new pests.
USDA Forest Service
USFS PROGRAM
FY20
FY21
FY 22 ask
FHP Coop Lands
$32 M
$30.747M
$51 million (to cover both program work & personnel costs)
FHP Federal lands
$19 M
$15.485M
$25 million (ditto)
Research & Develop
$305 million
$258.7 million; of which about $3.6 million allocated to invasive species
$320 million; seek report language specifying $5 million for invasive species
The Mission of the USDA Forest Service is “To sustain the health, diversity, and productivity of the Nation’s forests and grasslands to meet the needs of present and future generations.” To achieve this mission, the Forest Service needs adequate funding to address the difficult challenge of containing the spread of introduced pests, protecting host tree species from mortality caused by those pests, and restoring decimated tree species to the forest. Meeting this challenge requires gaining scientific understanding of the pest’s and host’s biology and what motivates people to avoid activities that facilitate pests’ spread (e.g., transporting firewood that might harbor wood-boring insects).
Given the hundreds of damaging non-native pests, the Forest Service must set priorities. One attempt to do so is “Project CAPTURE” (Conservation Assessment and Prioritization of Forest Trees Under Risk of Extirpation). Priority species for forests on the continent are listed below. A separate study is under way for forests in Hawai`i, Puerto Rico, and U.S. Virgin Islands.
Florida torreya (Torreya taxifolia)
American chestnut (Castanea dentata)
Allegheny chinquapin (C. pumila)
Ozark chinquapin (C. pumila var. ozarkensis)
redbay (Persea borbonia)
Carolina ash (Fraxinus caroliniana)
pumpkin ash (F. profunda)
Carolina hemlock (Tsuga caroliniana)
Port-Orford cedar (Chamaecyparis lawsoniana)
tanoak (Notholithocarpus densiflorus)
butternut (Juglans cinerea)
eastern hemlock (Tsuga canadensis)
white ash (Fraxinus americana)
black ash (F. nigra)
green ash (F. pennsylvanica).
These 15 priority species should be the focus of both comprehensive gene conservation programs and tree breeding and restoration programs. Unfortunately, USFS programs do not reflect this recommendation.
Forest Health and Management Programs (FHM)
Despite severe cuts (see above), FHM has continued its commitment to projects addressing Port-Orford-cedar root disease, threats to whitebark pine, and thousand cankers disease; plus it is support for managing “lingering” ash which appear to survive EAB attack. However, I am concerned about past reductions in programs targetting laurel wilt and sudden oak death. And as I noted above, several highly-damaging pests lack a “program” at all. I applaud establishment of an “emerging pest” line. However, competition will be fierce for the $500,000 – pitting the invasive shot hole borers in California against the coconut rhinoceros beetle and rapid ‘ōhi‘a death in Hawai`i, against beech leaf disease in Ohio to Massachusetts.
And where is federal leadership on managing continued spread of the emerald ash borer, now that the USDA APHIS has terminated its regulatory program?
USDA Forest Service Forest and Rangeland Research Program
Effective programs to prevent, suppress, and eradicate non-native pests depend on understanding of the pest-host relationship gained through research. In recent years, about 1.5% of the USFS Research budget has been allocated to the non-native pests listed above. Past reductions have hit programs targetting hemlock woolly adelgid, white pine blister rust, sudden oak death, and the Sirex woodwasp. Programs targetting several other high-impact pests, including the Asian longhorned beetle, emerald ash borer, goldspotted oak borer, thousand cankers disease, and laurel wilt have been funded at a steady rate. I could find no documentation of USDA Forest Service research into beech leaf disease, rapid ʻōhiʻa death, or other pests currently killing trees.
Members of Key Congressional Committees
Note that some Representatives or Senators are members of subcommittees that fund both APHIS and the USFS. It is especially important that they hear from their constituents!
APHIS is funded through the Agriculture appropriations bill. Members of the House Subcommittee on Agriculture and Rural Development:
Sanford Bishop Jr., Chairman GA
Chellie Pingree ME
Mark Pocan WI
Lauren Underwood IL
Barbara Lee CA
Betty McCollum MN
Debbie Wasserman Schultz FL
Henry Cuellar TX
Grace Meng NY
Jeff Fortenberry, Ranking Member NE
Robert Aderholt AL
Andy Harris MD
David Valadao CA
John Moolenaar MI
Dan Newhouse WA
Members of the Senate Subcommittee on Agriculture and Rural Development:
Tammy Baldwin, Chair WI
John Merkley OR
Dianne Feinstein CA
Jon Tester MT
Patrick Leahy VT
Brian Schatz HI
Martin Heinrich NM
Ranking Republican John Hoeven ND
Mitch McConnell KY
Susan Collins ME
Roy Blunt MO
Jerry Moran KS
Cindy Hyde-Smith MS
Mike Braun IN
The USFS is funded through the Interior appropriations bill. Members of the House Subcommittee on Interior and Related Agencies: add states
Chellie Pingree, Chair ME
Betty McCollum MN
Derek Kilmer WA
Josh Harder CA
Susie Lee NV
Marcy Kaptur OH
Matt Cartwright PA
David Joyce, Ranking Member NC
Mike Simpson ID
Chris Stewart UT
Mark Amodei NV
Members of the Senate Subcommittee on Interior and Related Agencies:
Jeff Merkley, chair OR
Dianne Feinstein CA
Patrick Leahy VT
Jack Reed RI
Jon Tester MT
Chris van Hollen MD
Martin Heinrich NM
Ranking Rep. Lisa Murkowski AK
Roy Blunt MO
Mitch McConnell KY
Shelly Moore Capito WV
Cindy Hyde-Smith MS
Bill Hagerty TN
Marco Rubio FL
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
map showing spread of beech scale, which facilitates beech bark disease
I recently participated in the 2021 annual meeting of the Northeast Forest Pest Council (virtual, of course). Speakers – most of them from state forestry agencies, but including students – presented a disturbing picture. Numerous established insects and diseases continue to spread. In some cases, they are resurging after weather-caused slow-downs. There are also a few bright spots.
The Alarming
To me the most alarming situation is that for American beech – because all three threats continue to expand.
Beech bark disease Since 2000, BBD has spread across southern Quebec into Ontario, Michigan, and Wisconsin; the Blue Ridge in Virginia; and central New Jersey.
Beech leaf disease Originally discovered near Cleveland in 2012, BLD has been spreading, primarily eastward.
BLD was detected for the first time in Massachusetts, in Plymouth and Bristol counties (on the coast North of Cape Cod). It might also be in Worcester. Both American and European beech trees of all sizes are affected; some of the largest are “on the verge” of death. (Felicia Hubacz)
The first detections in New Jersey are in Bergen and Essex counties – bordering southern New York. Both detections were by members of the public. Rosa Yoo says there is confusion about which state agency has the lead, so no official notices have been published (although the detection is recorded on the map). She hopes to establish long-term monitoring plots.
West Virginia now says that BLD is present in Tomlinson Run State Park in Hancock County. Kristen Carrington plans to focus detection efforts on the state’s norther panhandle which rises along the Pennsylvania border. She has established seven long-term monitoring plots.
Meanwhile, states where BLD was detected earlier continue to add new counties to the list of those infested. In New York, five new counties have been recorded. All the New York State finds have been on public lands, so the map doesn’t present the full picture (Carlson). In Connecticut, the disease is in all coastal counties and is more scattered in inland areas. Connecticut has set up some long-term monitoring plots. (Stafford)
New York is also trying to identify insect species associated with beech trees and beech litter – as a first step in trying to determine whether any vector the nematode that is thought to cause the disease. I suggest that it is also useful to understand which arthropod species might be at risk as beech decline. Don’t folks often lament the lack of this information for chestnut? Aren’t scientists praised for compiling initial lists for insects associated with ash?
Beech leaf mining weevil According to Jeff Ogden of the Nova Scotia Department of Lands and Forestry, this weevil has defoliated trees on 5987 hectares. First detected near Halifax in 2012, the weevil is now found throughout Nova Scotia. Some trees near Halifax have died. Ogden believes the weevil could be spread on movement of logs with bark and leaf litter. Camping is very popular in Nova Scotia, so the firewood risk appears real.
Also alarming is the resurgence of hemlock woolly adelgid across the region. HWA had been suppressed for a few years by harsh winters, but that reprieve is over. HWA is in 52 of 55 West Virginia counties (Kristen Carrington). Newly detected outbreaks are found across Pennsylvania and in the Adirondacks of New York. HWA continues to spread north – slowly – in New Hampshire and Vermont. In Nova Scotia, the outbreak detected in 2018 is spreading slowly to the West (Jeff Ogden).
All states are releasing a variety of biocontrol agents, often Laricobius nigrinus but also L. osakensis. Various agents have been released for decades — for example, Connecticut has released more than 125,000 agents over more than 20 years. I do hope the two Laricobius beetles prove to be more effective in controlling the agelgid.
Several states note that elongate hemlock scale (Fiorinia externa) is now at least as damaging as the adelgid.
Pennsylvania is growing hemlocks for restoration purposes; New Jersey has begun a similar program. See my earlier blog about efforts to breed hemlocks resistant to the adelgid, available here.
Spotted lanternfly is now established in nine states — from Ohio and West Virginia to Connecticut. It continues to spread. In the longer-established infestation areas of southeastern Pennsylvania, black walnut has been severely damaged by early instar larvae. In New Jersey, eight counties are under quarantine, but the insect has been detected much more broadly. The newest state is Connecticut, which found populations in several counties and is drafting quarantine regulations. Massachusetts, Maine, and Vermont have found some egg masses or evidence of infestation on goods entering from Pennsylvania, but not yet an established population.
The Not So Alarming — but Still Concerning
Asian Longhorned BeetleMassachusetts is consistently finding fewer trees infested by the ALB. In 2020, they found only one! It was isolated in the middle of a golf course. Intensive surveys and trapping in the vicinity found no other infested tree.
This is great news! However, I worry that resources will be withdrawn too soon – especially with APHIS’ need to fund an eradication program for the same pest in a swampy forest area in South Carolina where it will be difficult to work. Already Massachusetts reported that it has fewer traps and staff, and some difficulties accessing the lure.
Early Detection Efforts
New Jersey and West Virginia have carried out surveys of sassafras stands for the redbay ambrosia beetle (also here). West Virginia is also surveying for Phytophthora ramorum (the sudden oak death pathogen) and walnut twig beetle (vector of thousand cankers disease). Funding for surveys of the former probably came from USFS Forest Health Protection; for the latter, from APHIS. I applaud these “early detection” efforts.
Too Late for “Early Detection” but Getting Welcome the Attention
New Hampshire noted rising concern about Jumping worms. The state has received 48 complaints since 2017; 43 of these were in 2020. This led to a spirited discussion about invasive worms’ impacts. Don Eggen noted that concern focuses on soils in unglaciated regions. Non-native worms can destroy the duff layer. Most of the research has been carried out in the Midwest. See my earlier blogs about invasive earthworms here.
Tim Tomon reported that the USFS Morgantown WV research office has sampled the Allegheny NF. They have found other invasive earthworms but not jumping worms. Rosa Yoo of New Jersey alerted participants to the jumping worm research and management group – JWORM
Other Updates
Beech leaf disease
The USDA Forest Service has published a Pest Alert on BLD. Google it now. When a url becomes available I will update this notice. The flyer includes contact information for a site that provides both detection training and a place to record your finds.
Sudden Oak Death
The EU1 strain was detected in forest trees in Del Norte County, California in autumn 2020. This detection was both the first officially confirmed detection of P. ramorum in Del Norte County and the first detection of the EU1 strain in forest trees in California. The source is unclear. The nearest infestation is 12 miles away, along the Winchuk River in Curry County, OR; those trees are infected with the NA1 strain. The nearest known EU1 infestation is about 35 miles away. The site of the California EU1 infestation has minimal California bay laurel (Umbellularia californica). This detection has led to designation of Del Norte County as officially infested; it becomes the 16th California county so designated. [Information from the California Oak Mortality Task Force newsletter for December 2020, 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.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
Posted by Scott J. Cameron, former Acting Assistant Secretary for Policy Management and Budget , US Department of the Interior
locations in Hawaii Volcanoes National Park where ohia trees were infected by rapid ohia death pathogen in 2017
In 2019 Congress passed the John D. Dingell, Jr. Conservation, Management, and Recreation Act. Among other things, it directed the Department of the Interior to “develop a strategic plan that will achieve, to the maximum extent practicable, a substantive annual net reduction of invasive species population or infested acreage on land or water managed by the Secretary.” This provision triggered a year-long process of public involvement and inter-bureau coordination. The result was a plan published in January 2021. It represents the first attempt by Interior at a Department-wide multi-taxa, multi-year approach to invasive species. It has the potential to spur integration of invasive species work across the Department’s many bureaus and to focus each bureau’s efforts on a set of common goals, strategies, and performance metrics.
While Congress’ language is open-ended, any planning exercise is constrained by the most recent President’s budget and existing law. It is up to those of us who are not, or at least no longer, executive branch employees to advocate for plans unbound by those constraints.
In that spirit, I offer eight recommendations to improve invasive species management. Four are within existing authorities; four more are outside the current budgetary and statutory framework. Many more ideas are without a doubt worth pursuing.
Opuntia (prickly pear) cactus – common plant in western National parks and on Bureau of Land Management lands; under threat by cactus moth
First, within existing funding and legal authorities, the Department has unfinished business that it can act on now.
Secure approval of the package of categorical exclusions under the National Environmental Policy Act (NEPA) — now awaiting approval by the President’s Council on Environmental Quality (CEQ). Over many years agencies have documented how invasive species control improves, rather than harms, the environment. Absent an applicable NEPA categorical exclusion approved by CEQ, though, each such action needs to run the time- and money-consuming gauntlet of NEPA compliance. In the meantime, the invasive plants germinate, the invasive animals reproduce, and what might have been a localized and inexpensive problem has expanded geographically and in terms of cost and complexity. In the Fall of 2020 Interior submitted hundreds of pages of documentation on numerous practices proven to control invasive species without harming the environment. Due to time and staffing constraints at CEQ, these categorical exclusions still await action. Interior and CEQ should take prompt steps to finish them.
Allocate to the US Geological Survey at least $10 million of the roughly $90 million remaining available to the Secretary in CARES Act appropriations for research on invasive zoonotic diseases. These are diseases like COVID-19 and West Nile virus that can move from one species to another. Many zoonotic diseases fit the definition of invasive species, since they are not native to the United States and endanger human health. In the case of COVID-19 funding is available to the Secretary of the Interior, without need for further Congressional action, from funds appropriated by the CARES Act. The availability of these funds will expire at the end of September 2021, so Interior should provide this research funding to USGS as soon as possible.
Join the existing Memorandum of Understanding between the Western Governors Association (WGA) and the US Department of Agriculture’s Forest Service. These groups have established “a framework to allow the U.S. Forest Service (USFS) and WGA to work collaboratively to accomplish mutual goals, further common interests, and effectively respond to the increasing suite of challenges facing western landscapes.” This provides a forum to improve coordination between the States and the federal government on the management of invasive species, and Interior needs to be part of that team.
Interior should work with USDA to accelerate and intensify efforts to systematically improve coordination between the interagency Wildland Fire Leadership Council and the interagency National Invasive Species Council. Both Councils have member agencies that practice vegetation management using similar tools and techniques, although for different purposes. The two Councils should identify a select number of initiatives in FY21 where their efforts would benefit both wildland fire management and invasive plant management .
swamp bay trees in Everglades National Park killed by laurel wilt; photo by Tony Pernas
Four steps to implement the strategic plan outside the scope of current law and the President’s Fiscal Year 2021 budget. I offer the following:
Improve implementation of the Lacey Act program to list injurious species. There are both legislative and administrative elements to this proposal.
In a federal District Court decision on May 19, 2015, on a lawsuit filed by the Association of Reptile Keepers, the Court undid the longstanding Fish and Wildlife Service policy that the Lacey Act allowed FWS to ban interstate transport of injurious species. On April 7, 2017, the D.C. Circuit Court of Appeals upheld the District Court’s view. These rulings mean that FWS authority only applies to international commerce. Unfortunately, the court’s interpretation of the law and legislative history are reasonable, so Congress needs to amend the law to make it clear that FWS is explicitly authorized to regulate interstate commerce in injurious species. The Department of the Interior should work with the Department of Justice and the Office of Management and Budget to develop the necessary bill language and submit it to Congress.
At the same time, the FWS injurious species listing process is notoriously slow, even causing Congress to occasionally list species legislatively. The fact that these legislative initiatives have sometimes been promoted by Members of Congress who normally are opposed to more federal regulation signals just how awkward the current FWS process is. Thus there might well be strong bipartisan support to amend the Lacey Act on the interstate commerce matter. Acting on its own authority, FWS should procure an independent third party review of the injurious species listing process and ask the contractor to make suggestions for “business process reengineering” to improve and streamline current practices, along with evaluating whether higher funding or new technology is needed.
The Bureau of Reclamation, Department of the Interior, and the Office of Management and Budget should develop legislative language to submit to Congress for the 2022 Water Resources Development Act, that explicitly authorizes an aquatic nuisance species program in the Bureau of Reclamation. It could parallel the relatively new authority enjoyed by the Army Corps of Engineers and mandate increased coordination between the two water agencies.
Any climate change legislation pursued by Congress and the Administration should include provisions for addressing invasive species. Climate change will make some North American habitats more suitable for foreign organisms, as cold-intolerant species might be able to survive in more northern latitudes in the U.S. than previously was the case. Second, the disruptive effect of climate change on North American ecosystem structure and trophic relationships at any latitude will make those ecosystems more vulnerable to invasion. Finally, the spread of invasive species may in and of itself exacerbate climate change, such as through the increased carbon dioxide emissions from rangeland wildfires aggravated by the dominance of invasive cheatgrass.
The Senate Committee on Environment and Public Works and the House Natural Resources Committee should each hold oversight hearings on how best to help state and local governments detect and respond to new invasive species that are not within the statutory purview of USDA/APHIS. This is a complex topic, important for both ecological and financial reasons. Over the years several attempts to address it have failed. A thoughtful review by Congress and the Administration, which perhaps would lead to passage of new statutory authority and funding, is worth exploring.
The Author:
Scott Cameron recently left the federal government, where he had served as Acting Assistant Secretary for Policy, Management and Budget at the U.S. Department of the Interior. In that capacity he oversaw Department-wide budget, invasive species, natural resource damage assessment and restoration, environmental compliance and numerous administrative functions of this $14 billion agency with 65,000 employees. Previously, Scott held other civil service job (e.g., at the White House Office of Management and Budget) & political appointments in the federal government, on the staff of the Governor of California, and on Congressional staffs. While not in government, Scott led formation of the Reduce Risk from Invasive Species Coalition.
CISP welcomes 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.
Further information on the plant pests mentioned in the photo captions can be obtained at www.dontmovefirewood.org; click the “invasive species” button.
Japanese stiltgrass in Shenandoah National Park; photo by Jake Hughes, NPS
The recent appearance of a study by National Park Service (NPS) scientists quantifying the threat posed by invasive plants prompted me to seek updates on this issue. In May 2018, I blogged about NPS’ Invasive Plant Program Strategic Plan, which was issued in 2016. At the time, I got the impression that the program was struggling to gain support from NPS leadership in Washington, as well as leaders of individual parks. Has the situation improved since then?
The recent study, by Kathryn Miller and colleagues, focuses on National parks in the East, from Virginia to Maine. (I provide a full reference at the end of this blog.) I look forward to a planned follow-up article that will try to clarify drivers of invasion.
The Miller study appears to have been undertaken to partially fulfill one of the goals of the NPS’ 2016 Invasive Plant Program Strategic Plan. One of the actions under Goal 1 in the Plan was to quantify the invasive plant threat, the effort needed to manage it, and then to communicate the gap between needs and available resources. Miller et al. have quantified the threat to National parks in one region (not the entire country). However, they have communicated the gap between effort and need in only the most general way.
Protecting the forests in eastern National parks is valuable from many perspectives. The forests in these parks are older and have higher stand-level tree diversity than surrounding unprotected forests. Protecting their long-term condition also corresponds to the National Park Service’s (NPS) stated mission, as established in its Organic Act.
The study relied on National Park Service Inventory and Monitoring Program data from 1,479 permanent forest plots covering 39 eastern NP units located from Virginia to Maine. The data were collected over 12 years, in three survey cycles (2007–2010, 2011–2014, and 2015–2018).
The authors note that in forest ecosystems, invasive plants can reduce native diversity, alter forest structure, suppress tree regeneration, alter nutrient cycling, and modify disturbance regimes. Some – the shrubs and vines – also threaten human health by promoting increases in tick populations and associated Lyme disease risks.
Unsurprisingly, the data showed invasive plants to be widespread, and increasing. In 80% of the park units, there was a significant increase in at least one trend measuring abundance. Any decrease in plant invaders tended to be in herbaceous or graminoid species; that decrease was often counterbalanced by an approximately equivalent increase in invasive shrubs or vines. In 35 of the park units, more than half of the plots had at least one invasive plant species when the 2015-2018 survey began. In 10 parks (a quarter of those surveyed), every plot had at least one.
The most widespread species is Japanese stiltgrass (Microstegium vimineum). It is present in more than 75% of all park units and 30% of all 1,400 plots. This dominance is true despite the fact that stiltgrass does not extend north of Roosevelt-Vanderbilt National Historic Site in New York state (41o N latitude). Stiltgrass is also the most aggressive invader.
The second most widespread invaders are a group of shrubs and vines, including most notably Japanese barberry (Berberis thunbergii), Japanese honeysuckle (Lonicera japonica), multiflora rose (Rosa multiflora), and wineberry (Rubus phoenicolasius). I note – although the articles does not – that several of these have been deliberately planted – either to “enhance” ecosystems (multiflora rose) or as ornamentals (barberry). [Lehan et al. 2013 (full reference at end of blog) found that 95% of 125 shrub species introduced to the U.S. were introduced deliberately.] I know of no examples of deliberate planting of Japanese stiltgrass.
The most frequently detected non-grass herbaceous species is garlic mustard (Alliaria petiolata), which was detected in 20% of plots. Garlic mustard is found throughout the study area (Virginia to Maine). Tree-of-heaven (Ailanthus altissima) is the most common invasive tree. It is found in only 9% of plots and does not grow north of Roosevelt-Vanderbilt NHS. Again, both were intentionally introduced – and not noted as such in the article.
Because they could not identify the source populations for each plot, the study could not directly measure rates of establishment and expansion. The data did allow tracking rough trends in each park.
Parks with the highest abundance tended to be near densely populated areas. However, this pattern was not universal. For example, Prince William Forest Park in the outer Virginia suburbs of the District of Columbia metro area was one of two of the least invaded park units.
Prince William Forest Park
(note the prevalence of beech – I fear for the arrival of beech leaf disease!)
Total invasives increased significantly in 21 of the 39 parks for at least one metric. In 10 parks (a quarter of all parks), total invasives increased significantly in two of the three metrics. Antietam National Battlefield experienced the steepest increases.
The authors note that invasive plants continue to establish and expand, even in already heavily invaded forests. Thus they found little evidence of saturation. This finding conflicts with invasion theory. They also found antagonistic interactions between invasive species to be common.
The authors said managers should prioritize efforts to control Japanese stiltgrass and the shrubs and vinesdue to their widespread occurrence, rapid expansion, ability to suppress tree regeneration and understory diversity, and – in the case of the shrubs and vines, link to ticks.
The authors noted the need to better understand the drivers and impacts of invasive plants in eastern forests. They mentioned the overabundance of white-tailed deer (Odocoileus virginianus), latitude, climate change, fragmentation and urbanization. I have urged them to include analysis of deliberate planting of various species on lands within the park units or nearby. They have said that they will do so in the planned follow-up article.
The authors propose that deferred management of natural resources receive attention and sustained commitment on par with the attention to deferred maintenance of the park units’ infrastructure. The maintenance backlog has been addressed through recent legislation: the Great America Outdoors Act which provided $6.5 billion over five years to address deferred maintenance projects in all 419 national park units. I believe that these projects will not address invasive species, which are managed under the “Natural Resources” budget account, not “Maintenance”. Some “Maintenance” projects probably will include control of invasive plants. A former Interior Department official has suggested that resource management activities might be funded under another section of the legislation, which provides $900 million under the Land and Water Conservation program. I hope this is true.
National Park Service’ Overall Invasive Plant Program Now
In response to the mandate in the John D. Dingell, Jr. Conservation, Management, and Recreation Act (Public Law 116-9), the Department of Interior has issued a department-wide invasive species strategy. Will issuance of the new strategy provide impetus to the NPS to seek funding to implement its 2016 invasive plant strategic plan? Will Congress provide funds for this purpose?
Finding out the current status of National Park Service took a little effort. The NPS’ website has “popular” information about the efforts of individual regional Invasive Plant Management Teams (see links at the end of this blog). These posts provide only the briefest overview of program achievements and do not compare those accomplishments to the goals in the 2016 plan.
However, Terri Hogan, Invasive Plant Program Manager in the Biological Resources Division, provided following information:
NPS leadership now supports the agency’s invasive plant effort. The national Invasive Plant Program (IPP) contributes to the annual Natural Resource Stewardship and Science Directorate (NRSS)’ Biological Resource Division (BRD) work plan. All is guided by the “Four Pillars to Guide Natural Resource Activities and Investments”, adopted in 2016.
It is not clear that invasive species have the highest priority under this regime. The four “pillars” are
Holding the line – includes conserving biodiversity by removing invasive plants
Managing amid Continuous Change – includes conducting risk assessment and taking other actions to contain future exotic species
Leveraging for Conservation at Scale
Enhancing Stewardship and Science Access and Engagement
Cooperation with owners of neighboring private lands has been enhanced by engagement of the Western Governors Association and state and local political leaders. Many parks participate in Partnerships for Invasive Species Management (PRISMs), CISMS, and Cooperative Weed Management areas (CWMAs). This collaboration has been strengthened by adoption of the John D. Dingell, Jr. Act (see above).
In practice, the focus appears to still be on the Invasive Plant Management Teams (IPMTs). There are now 17 teams. Fifteen are funded through the national office. One is funded by an individual park; one funded through a regional office. Annual reports have been published for FYs 2017 and 2018. The FY19 report has been held up but should be posted soon.
The reports provide brief description of the overall program and vignettes of particular activities. There are more detailed – but still anecdotal – reports for each of the teams. It is difficult to determine whether there has been overall progress. For example, the reported total infested acreage increased from 133,658 acres in FY17 to 301,195 acres in FY18. This presumably reflects more intense monitoring as well as a probable increase in real infections. (The infested acreage figures do not address intensity of invasion on these acres.) The teams cumulatively treated 8,937 acres in FY 2017; 8,331 acres in FY 2018. They carried out inventory and monitoring projects on 169,057 acres in FY17, 210,000 acres in FY18.
Since the Miller article concerns the region from Virginia to Maine, I checked the FY17 and FY 18 reports from the Invasive Plant Management Teams from the Mid-Atlantic, National Capital Area, and Northeastern regions. The Mid-Atlantic team emphasized work on wavyleaf basketgrass and meadows in parks established to protect cultural or historic sites. The National Capital Area team emphasized partnerships and success eradicating Giant Hogweed (Heracleum mantegazzianum) on private land neighboring Rock Creek Park. The Northeastern Team serves 25 parks; the report emphasized leveraging resources and testing efficacy of pre-emergent herbicide for control of Japanese stiltgrass. With this exception, the teams do not appear to be prioritizing the species recommended for action by the Miller study.
Brief, “popular” articles about the NPS’ invasive plant effort are available here
Lehan, N.E., J.R. Murphy, L.P. Thornburn, and B.A. Bradley. 2013. Accidental Introductions are an Important Source of Invasive Plants in the Continental United States. American Journal of Botany 100(7): 1287–1293. 2013.
Miller, K. M., B. J. McGill, A. S. Weed, C. E. Seirup, J. A. Comiskey, E. R. Matthews, S. Perles, & J. Paul Schmit. 2020. Long-term trends indicate that invasive plants are pervasive and increasing in eastern national parks. Ecology. 00(00):e02239. 10.1002/eap.2239
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
This February marks 15 years since USDA began full implementation of ISPM#15. It is 22 years since the U.S. and Canada began requiring China to treat wood packaging (in response to introductions of the Asian longhorned beetle). Nevertheless, numerous shipments containing wood packaging that does not comply with the international regulations continue to arrive at our borders – and to bring pests. During Fiscal Years 2010 through 2019, CBP detected 7,900 shipments of wood packaging that harbored a pest significant enough to be in a regulated taxonomic group. In 2020, 16.6 million TEU from Asia entered the U.S. (Mongelluzzo Jan 21). If pest approach rates are the same now as 10 years ago, perhaps 6,000 or more of these containers bore wood packaging infested by tree-killing insects.
The Bureau of Customs and Border Protection (CBP), in the Department of Homeland Security, has taken steps to strengthen its programs aimed at getting insects out of the wood packaging pathway (described here).
I wish USDA APHIS took a similarly active stance.You can help by contacting your Congressperson and senators to urge their support effective actions, such as those I suggested in my blog in January.
CPB’s 2017 Improvement
Until November 1, 2017, CBD allowed importers to escape punishment until they had been caught using wood packaging that did not comply with ISPM#15 five times in one year. On that date, CBD began issuing a penalty under Title 19 United States Code (USC) § 1595a(b) or under 19 USC § 1592 to any party responsible for a shipment with a documented wood packaging violation. At the time, I praised CBP’s action. I have tried to find out how many times over the past three years CBP has used that new provision to issue penalties, but CBP staff have not replied to my question.
CPB’s 2020 Improvement
CBD took another step forward in 2020. The agency incorporated measures to clean up solid wood packing material (SWPM) into its Customs-Trade Partnership Against Terrorism (CTPAT) program. I had been urging this since 2016. It took a while – but CBP used that time to ensure that its action would be integrated into the program and so stay in effect.
CTPAT is a voluntary public-private sector partnership engaging the principle participants in international supply chains — importers, carriers, consolidators, licensed customs brokers, and manufacturers.
By signing on, they agree to help CBP ensure the highest level of cargo security. Specifically, when an entity joins CTPAT, it agrees to work with CBP to protect the supply chain, identify security gaps, and implement specific security measures and best practices.
CTPAT member companies receive several benefits in return. Because they are considered to be of low risk, their shipments are less likely to be examined and delayed at a U.S. port of entry. When they are subjected to inspection, they go to the front of the line – again, reducing costly delays. The CTPAT web-based Portal system provides a library of training materials. (Information from the CBP website; full citation at end of the blog.)
At present, more than 11,400 certified partners have joined the program. These include U.S./Canada highway and rail carriers and Canadian manufacturers – who are not subject to the U.S.’ wood packaging regulation per se. Thus, CBD’s action seems to extend pest-prevention protection to a group of suppliers previously exempted from this phytosanitary program. Inclusion of many Mexican carriers and manufacturers is also welcome, since Mexican suppliers have always ranked high in numbers of shipments that violate the ISPM#15 requirements.
Specific Minimum Security Criteria
CBP’s action took the form of adding a long list of critical new agricultural components to the Minimum Security Criteria (MSC) it already used. These include:
Having written procedures for both security and agricultural inspections.
Carrying out CTPAT approved security and agricultural inspections of all conveyances and empty Instruments of International Traffic (e.g., shipping tanks, lift vans) prior to loading. The inspection must ensure that they are not contaminated with visible agricultural pests.
If visible pest contamination is found during the inspection, the partner business must wash or vacuum the conveyance to remove such contamination. The company must retain documentation demonstrating compliance for one year.
Vessels that visited Asian Gypsy Moth (AGM) high-risk areas during periods when the moths are flying must present a pre-departure AGM inspection certificate from an approved entity stating that the vessel is free of AGM life stages. The AGM inspections must be performed at the regulated port as close to vessel departure time as possible. CTPAT sea carriers must provide CPB with two-year port-of-call data at least 96 hours before arrival at a U.S. port.
Cargo staging areas, and the immediate surrounding areas, must be inspected on a regular basis to ensure these areas remain free of visible pest contamination.
CTPAT Members must have written procedures designed to prevent visible pest contamination to include compliance with ISPM#15 regulations. Visible pest prevention measures must be adhered to throughout the supply chain.
Members must establish and maintain a security training and awareness program to recognize and foster awareness of the security vulnerabilities to facilities, conveyances, and cargo at each point in the supply chain. The training program must be comprehensive and cover all of CTPAT’s security requirements. Personnel in sensitive positions must receive additional specialized training geared toward the responsibilities that the position holds.
Drivers and other personnel that conduct security and agricultural inspections of empty conveyances and Instruments of International Traffic (IIT) must be trained to inspect their conveyances/IIT for both security and agricultural purposes.
Training must be provided to applicable personnel on preventing visible pest contamination. Training must encompass pest prevention measures, regulatory requirements applicable to wood packaging materials, and identification of infested wood.
The actual Minimum Security Criteria can be found here.
(The summary of these criteria was provided by Stephen Brady, Senior Agriculture Operations Manager, Agriculture Programs and Trade Liaison, U.S. Customs and Border Protection.)
Inclusion of wood packaging in the CTPAT program should result in more efficient efforts to detect infested wood packaging before shipment — before the insect can reach North America. I believe it is fair to importers in that it requires action based on visible pest presence or damage. I applaud Customs and Border Protection for making the effort – internally and with the shipping industry — to add this protection.
I think fairness would be further served by CBP and APHIS adopting a program to inform importers which foreign suppliers of wood packaging have a record of providing “clean” vs. “infested” wood packaging. The U.S. importers would then be better able to avoid both contributing to the pest risk and being exposed to violation-associated delays.
Mongelluzzo, B. US imports from Asia hit record December level. Jan 19, 2021
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
In January 2021, the California Department of Food and Agriculture announced the pest rating for Phytophthora occultans, one of two species of Phytophthora it was reviewing. (Once at the website, click on “comment” – next to name Heather Sheck.)
Five people or organizations submitted comments. The most comprehensive comments were submitted by Elizabeth Bernhardt, Ph. D. and Tedmund Swiecki Ph.D. of Phytosphere Research. Another scientist was Tyler Bourret, who had been the first to detect P. occultans in California when working as a student in 2015-16. The third scientist was Jennifer Parke, a plant pathologist at Oregon State University who has worked with Phytophthora species in agriculture and wildland settings for 36 years. Additional comments were submitted by the Phytophthoras in Native Habitats Work Group and me.
All commenters raised some issues. First was the lack of information on the true distribution of P. occultans in California. CDFA restated that it that relies on official records and survey information, and that those records support a “low” rating.
Several issues relate to the definitions that CDFA applies in assigning ranks. They are so restrictive that – in my view – they result in underestimates of pathogens’ potential impacts.
One example is how CDFA recognizes first detections of a pathogen. As Bernhardt and Swiecki point out, CDFA’s consideration of only “official” samples prevents timely action to protect California’s agriculture and native vegetation. In the case of P. occultans, CDFA took no action for two years after the pathogen was first reported in the state. This detection had been confirmed by a CDFA laboratory.
A second example is host range. CDFA says it assigns a host range rating of “wide” (rating of “3”) only to pathogens that have host ranges of hundreds of species. This means that pathogens with dozens of known hosts across several plant families are given a ranking of “moderate” (2). Furthermore, the agency considers only “official” samples in defining hosts. This approach precludes consideration of the high probability that additional hosts would be found in future, including federally listed species in the genera Ceanothus and Arctostaphylos. Bernhardt and Swiecki named two additional hosts based on field work. CDFA responded to the second point by adding a reference to the likely expansion of the host range in the “Uncertainty” section of the document.
Similarly, CDFA gives a reproductive potential rating of “3” only to pathogens spread by a vector or that infect seeds.
CDFA staffers who manage specific pests lack authority to change these too stringent ranking criteria. The agency leadership need to adopt more realistic criteria.
CDFA responded by accepting many of the additional factors raised primarily by Bernhardt and Swiecki. This resulted in raising the overall score from 11 to 14, and changing the ranking from “C” to “B”.
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
APHIS formally proposed to stop regulating movement of firewood, nursery stock, and other articles that can transport the emerald ash borer (EAB) in 2018; I blogged in opposition to this proposal at the time. Now APHIS has evaluated the 2018 comments on its proposal and has decided to proceed with its plans.
I recently blogged about the current and probable future status of ash. A study confirmed that robust regeneration of ash seedlings and saplings seen in various invaded areas will not result in recovery of mature ashes that can perform their ecological role.
APHIS received 146 comments on the proposal. Twenty-five supported the proposal as written; 121 raised concerns. Many of the latter were a few sentences without supporting information. These comments and the final rulemaking can be read here.
How has APHIS responded to the serious questions raised? Dismissively.
I certainly concede that EAB has been difficult to manage and has spread rapidly. However, I continue tobelieve that maintaining the quarantine serves important purposes and the analysis APHIS provides does not justify terminating of the regulatory program. I remain concerned.
Neither the proposal nor the final regulation tells us how much money and staff resources have been dedicated to detection or enforcement of the regulations in recent years. Therefore we don’t know how many resources are now available for supporting other activities that the agency thinks are more effective. APHIS also refuses to provide specific information on how it will allocate the freed-up resources among its (minimal) continuing efforts. For example, APHIS has supported resistance-breeding programs. Will it help them expand to additional species, e.g., black and Oregon ash?
How Does APHIS Propose to Curtail EAB Spread?
APHIS states in the final rule that it is ending the domestic quarantine regulation so that it can allocate resources to more effective strategies for managing and containing EAB. The agency wants to reallocate funds “to activities of greater long-term benefit to slowing the spread of EAB … These activities include further development and deployment of EAB biocontrol organisms; further research into integrated pest management of EAB that can be used at the local level to protect an ash population of significant importance to a community; and further research, in tandem with other Federal agencies, into the phenomenon of “lingering ash … ”
However, APHIS has not funded detection efforts since 2019. (Detection methods were only partially effective, but they gave us some information on where EAB had established.) APHIS is now ending regulation of the movement of vectors. APHIS concedes that biocontrol agents cannot be effective in preventing pest spread. So – what efforts – other than continued support for the “Don’t Move Firewood” campaign – will APHIS make to slow the spread of EAB?
Environmental and Economic Impacts: Not Adequately Assessed
Second, APHIS still has not analyzed the economic or environmental impact of the more rapid spread of EAB to the large areas of the country that are not yet infested – especially the West Coast – that are likely to result from deregulation. As even APHIS concedes, the EAB is currently known to occupy only 27% of the range of native Fraxinus species within conterminous US. There are additional large ash populations in Canada and Mexico – although neither country commented on the proposal — unfortunately!
Instead, APHIS largely restates its position from the proposal that it is too difficult to calculate such impacts. Furthermore, that it is APHIS’ “experience that widely prevalent plant pests tend, over time, to spread throughout the geographical range of their hosts …” In other words, APHIS denies the value of delaying invasions – yet that has always been a premise underlying any quarantine program.
The final regulation refers to an updated economic analysis, but no such document is posted on the official website. The rule does not mention costs to homeowners, property owners, municipal governments, etc. I believe it would not be so difficult to estimate costs to these entities by applying costs of tree removal in the Midwest to tree census data from major West Coast cities. Also, it might have been possible to provide some estimate of the ecological values in riparian forests by analogy to data from the Midwest developed by Deborah McCullough and others.
Biological Control: Effective – or Not
In the final regulation, APHIS concedes that the biocontrol agents currently being released have geographic and other limitations. However, APHIS does not address concerns raised by me and others about their efficacy. APHIS does say explicitly that it has not [yet?] begun efforts to find biocontrol agents that might be more effective in warmer parts of the ash range, especially the Pacific Northwest and riparian areas of the desert Southwest. However, APHIS has conceded that these areas are almost certain to be invaded – so should it not take precautionary action?
APHIS states several times that it cannot promise specific funding allocations among program components or strategies – such as resistance breeding – that might be pursued in the future. The agency stresses the value of flexibility.
U.S. Forest Service biologists have higher expectations; see their podcast here.
I wish to clarify that I do not oppose use of biocontrol; I strongly supported then APHIS Deputy Administrator Ric Dunkle’s decision to initiate biocontrol efforts for EAB early in the infestation. My objections are to overly optimistic descriptions of the program’s efficacy.
Firewood: Outreach Only, No National Regulation
As noted, APHIS has promised to continue support for public outreach activities, especially the “Don ‘t Move Firewood” campaign. The program’s message will continue to encourage the public to buy firewood where they burn it and to refrain from moving firewood from areas that are under Federal quarantine for other pests of firewood (e.g., Asian longhorned beetle). This campaign and the new National Plant Board guidelines link stress that firewood is a high-risk pathway for many pests of national or regional concern; they do not focus on any particular species. Leigh Greenwood, director of Don’t Move Firewood, thinks this is a good approach.
In 2010, the National Firewood Task Force recommended that APHIS regulate firewood at the national level. APHIS does explain why the agency did not do so. The agency says national regulations would be overly restrictive for some states and that requiring heat treatment would not be feasible in the winter for producers in Northern states. Finally, a Federal regulation would not address a significant non-commercial pathway – campers. [I have serious questions about APHIS’ assertion that it can regulate only commercial movement of vectors across state lines. Contact me directly for details on this.]
Perhaps APHIS is not required to analyze the probable overarching efficacy of the several efforts of 50 states. Given the states’ many perspectives and obvious difficulty in coordinating their actions on phytosanitary and other policies, I fear a scattered approach that will result in faster spread of EAB. I hope the National Plant Board guidelines on firewood regulation and outreach can overcome the history.
Most federally-managed recreation areas adopted an education campaign on firewood in autumn 2016; I blogged about it then.
Imported Wood Will be Minimally Regulated
APHIS clarifies that it will take enforcement actions against imports of ash wood only if inspectors detect larvae but can identify them just to family level and not below. APHIS will allow the importation if the larvae can be identified as EAB specifically. This policy reflects international standards, which do not allow a country to erect restrictions targetting a pest from abroad if that pest is also present inside the country and is not under an official control program. (See my discussion of the WTO Agreement on Sanitary and Phytosanitary Standards in Chapter 3 and Appendix 3 of Fading Forests II, available here.)
APHIS does not discuss how it will react to pests identified to the genus – several other Agrilus also pose pest risks. (See here and here.)
APHIS recommends that states leery of accepting yet more EAB-infested wood from abroad petition the agency under the Federally Recognized State Managed Phytosanitary Program (FRSMP) program, under which APHIS would take action to prevent movement of infested material to that particular state.
Lessons Learned
Finally, one commenter asked whether APHIS would analyze the program to learn what could have improved results. APHIS replies that the agency “tend[s] to reserve such evaluations for particular procedures or policies in order to limit their scope …” I hope APHIS is serious about “considering” doing a “lessons learned” evaluation. It is important to understand what could have been done better to protect America’s plant resources.
My take: the EAB experience proves, once again, that quarantine zones must extent to probable locations – beyond the known locations. The pest is almost always more widely distributed than documented. This has been true for EAB, sudden oak death, ALB, citrus canker … Failure to regulate “ahead” of the pest guarantees failure. I recognize that adopting this stance probably requires a change in the law (or at least understanding of it) and of current international standards adopted by the International Plant Protection Convention (IPPC). However, absent a more aggressive approach, programs are doomed to be constantly chasing the pest’s posterior.
Finally, let us mourn the loss of ash so far, the future losses … and opportunities missed.
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
On the first day of winter, Daniel Volk, Forest Health Project Coordinator for Cleveland (OH) Metroparks reported that a coordinated survey has confirmed the presence of beech leaf disease link to DMF in four new states — Massachusetts, New Jersey, Rhode Island, and West Virginia. In all, the disease is now known to be established in 71 counties in the US and Canada. Funding was provided by the USFS Forest Health Management “emerging pest” program.
2021 survey efforts will focus on high risk counties adjacent to affected counties.
Cleveland Metroparks has several resources available on its website and will continue to post updated information there as it becomes available.
I posted a blog urging recipients to participate in these searches last June link I hope you will do so again in 2021.
range of American beech
Posted by Faith Campbell
We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.
For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
Arctostaphylos uva-ursi (bear berry); photo by Sten Porse, Commons.Wikipedia
The California Department of Food and Agriculture (CDFA) is seeking input on proposed pest ratings for two species of Phytophthora: Phytophthora occultans and Phytophthora quercetorum. Each has the potential for being a serious pest in California and being spread throughout the United States. Therefore it is important to weigh in on this process. The first deadlines for comments is December 18.
These risk rating proposals can be found at https://blogs.cdfa.ca.gov/Section3162/ The website also has instructions for sending comments. This process can be clumsy so, if it doesn’t work, send your comments directly to the webmaster.
In general, the State assigns each potential pest a rating of A, B, or C. Those rated “A” are most likely to cause harm and also most subject to State regulation. Under “B”, the County Agricultural Commissioners have discretion to take regulatory actions. Pests ranked at “C “are not subject to any State enforced regulatory actions. The “C” rating is supposed to be assigned to pests that are widely distributed in the state and are expected to have a “medium” to “low” impact on vegetation (cultivated or wild) in the state.
Phytophthora occultans
Proposed for risk rank “C “. Comments are due December 18th.
Phytophthora occultans is a recently described species found in nurseries in Europe and in some U.S. states (including Oregon). It was recently detected in the San Francisco area of California.
The State proposes to rate Phytophthora occultans as a level “C” pest. This is insufficient. A rank of “B” is more appropriate, for the following reasons.
1) The data presented in the CDFA proposal are too limited to judge the species’ distribution in California. The proposal refers to only “two detections, two years apart, in San Francisco County.” By ranking it “C”, CDFA seems to assume the pathogen is widespread, based on detections in Europe and other states, without U.S. evidence
The available record does not indicate that CDFA made any attempt to determine the extent of the P.occultans infestations — no survey of other plants at the contractor’s nursery or at other nurseries and no consultation with a larger group of stakeholders.
2) CDFA limits discussion of possible impacts to hosts listed in the literature –which belong to multiple plant families. It makes no mention that additional hosts are likely to be discovered (as has often happened with regard to the host ranges of other pathogens in the Phytophthora genus). If the host range expands, as I expect it will, the impact to restoration activities, rare plants, wildlands and nurseries is more likely to be significant, not medium to low.
Furthermore, several of the known host species are congeners of species that are federally listed as endangered or threatened, i.e., species in the genera Ceanothus and Arctostaphylos. I think it is highly unwise to disregard in risk assessments the probability that listed species will prove to be hosts.
In conclusion, please submit comments to California Department of Food and Agriculture urging it to assign a risk rating of “B” to Phytophthora occultans.
Instructions are contained in the proposal. If this process doesn’t work (sometimes it is clumsy), send your comments directly to the webmaster.
Over the past 5 years, P. quercetorum has been detected in association with oak trees, primarily coast live oak (Quercus agrifolia), in four counties in California, two in the Central Valley (Fresno, Sacramento), two on either side of the San Francisco Bay (Alameda, San Francisco). There have been no interceptions of the species by CDFA border inspectors. The species had earlier been associated with oak roots and rhizosphere soil of oak forests in the eastern and north central US. Its pathogenicity is said to be unknown – and difficult to separate from impacts of other, often co-occuring Phytophthoras. CDFA assigns a rank of “high” with regard to economic impact, although it says there are no reports quantifying economic losses in plant production facilities.
CDFA believes that the species is likely to be able to establish wherever its hosts can grow (a rank of “high”). Hosts include red maple (Acer rubrum), English ivy (Hedera helix), several eastern oaks, and a second California oak, interior live oak (Q. wislizeni). CDFA assigns this a rank of “moderate” host range.
The environmental impact is ranked as “high” since the pest could lower biodiversity, disrupt natural communities, or change ecosystem processes; and the pest significantly impacts cultural practices, home/urban gardening or ornamental plantings.
The overall ranking for the “Consequences of Introduction” is “high”.
However, the recommended ranking is “C”, which – again – means the pest is not subject to any State enforced regulatory actions. “C” rated pests are widely distributed in the state and are expected to have a “medium” to “low” impact on vegetation (cultivated or wild) in the state.
Why would CDFA recommend “no action” for yet another Phytophthora species that is known to attack two of the state’s most ecologically important oaks and possibly many more species? Even when the exact impacts are unclear … Especially when the principal means of spread is planting trees in restoration areas – a deliberate human action.
According to the USDA Forest Service, coast live oak (Quercus agrifolia) is a conspicuous tree in lower-elevation oak woodlands of California, which collectively occupy about 10 million. It is co-dominant in the southern oak woodlands. CLO trees generally occur on mesic sites such as north slopes, alluvial terraces, canyon bottoms, or upper streambanks. Coast live oak woodlands are some of the most important habitats to wildlife in California; they provide habitat for black bear, black-tailed deer, rodents and lagomorphs, and various upland game and nongame birds – including those that feed on acorns and cavity nesters. The birds including the federally endangered least Bell’s vireo and least tern.
Coast live oak is more fire resistant than other California oak species.
Coast live oak is favored for use in rehabilitation projects throughout its range. It is used in watershed improvement, restoration, and wildlife habitat rehabilitation projects.
CLO is already under pressure by predation by deer and cattle; sudden oak death (SOD; causal agent Phytophthora ramorum); goldspotted oak borer (GSOB – Agrilus auroguttatus); and sometimes the polyphagous shot hole borer (PSHB; Euwallaceawhitfordiodendrus) and its associated Fusarium fungus. [These three non-native organisms are described here.]
range of Q. wislizeni; USDA Forest Service map
According to the USDA Forest Service, interior live oak (Quercus wislizeni) occurs over about 16% of California’s landscape, especially in the Inner Coast Ranges, the foothills of the southern Cascade Range, and the Sierra Nevada. Among California’s red oaks, interior live oak has the highest tolerance for xeric conditions. It usually dominates the “scrub” or “live oak” chaparral vegetation types in the Inner Coast Ranges and the Sierra Nevada.
CNPS Calscape lists several insects associated with the species.
Posted by Faith Campbell
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For a detailed discussion of the policies and practices that have allowed these pests to enter and spread – and that do not promote effective restoration strategies – review the Fading Forests report at http://treeimprovement.utk.edu/FadingForests.htm
