Month: September 2018

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

EAB risk to Oregon & Washington

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

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

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

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

 

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

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

  • APHIS makes no attempt to analyze the costs to states, municipalities, homeowners, etc. if EAB spreads to parts of the country where it is not yet established – primarily the West coast. As a result, the “economic analysis” covers only the reduced costs to entities within the quarantined areas which would be freed from requirements of compliance agreements to which they are subject under the current regulations. APHIS estimates that the more than 800 sawmills, logging/lumber producers, firewood producers, and pallet manufacturers now operating under compliance agreements would save between $9.8 M and $27.8 million annually. This appears to be a significant benefit – but it loses any meaning absent any estimate of the costs that will be absorbed by governments and private entities now outside the EAB-infested area.
ash tree killed by EAB; Ann Arbor, MI; courtesy of former mayor of Ann Arbor, MI John Hieftje
  • APHIS does not discuss how it would reallocate the $6 – 7 million it spends on EAB.  Would it all go to EAB biocontrol? Would some be allocated to other tree-killing pests that APHIS currently ignores?

 

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

 

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

 

  • APHIS makes no attempt to analyze environmental impacts.

champion green ash in Michigan killed by EAB

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

 

I welcome your input on these issues.

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

 

Posted by Faith Campbell

 

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

 

 

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

 

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

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

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

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

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

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

Efforts of the IPPC Commission on Phytosanitary Measures

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

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

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

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

Framework 2020-2030: the IPPC Strategic Plan

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

The plan describes how plant pests threaten

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

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

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

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

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

 

Posted by Faith Campbell

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

 

New Efforts to Counter the Invasive Shot Hole Borers (ISHB) in California

willow tree killed by Kuroshio shot hole borer in Tijuana River estuary (John Boland photo)

 

I have blogged several times about damage caused to riparian trees in southern California by polyphagous (PSHB) and Kuroshio Shot Hole Borers (KSHB) (collectively known as invasive shot hole borers, or ISHB). The most recent blog – in July – reported the rising intensity of ISHB infestation in Orange County parks. The polyphagous shot hole borer and its associated Fusarium fungus have been found throughout Los Angeles, Orange, Riverside, San Bernardino, and Ventura Counties. The genetically distinct but morphologically indistinguishable Kuroshio shot hole borer occurs in San Diego, Orange, Santa Barbara, and San Luis Obispo Counties. New outbreaks continue to be detected – for example, one near San Juan de Capistrano.

The threat to wildland, rural, and urban hardwood forests in southern California is obvious (see the write-up here, but this is not the full extent of the peril. Preliminary research indicates that the ISHB can survive as far north as Tehama County (at the northern end of the Central Valley, south of Redding), and possibly in other parts of the country (see Greer et al., referenced below). The two beetles reproduce in more than five dozen tree and shrub species – both native and ornamental trees – that grow not just in California but across the country.

It is agreed that the ISHB do best in well-watered trees – e.g., trees in parks or other urban areas, and in riparian zones. Some fear that when the southern California drought ends, large areas of hardwood forests will become newly vulnerable. The role of water also raises the potential threat to the many species of reproductive host trees growing in the Gulf Coast and other warm and humid regions of the country.

What can people and agencies do now to counter these damaging pests? Several experts who have been working with ISHB in southern California have developed a management strategy for guiding and prioritizing actions and implementing control mechanisms targetting the beetles and their fungal symbionts that together cause the plant disease Fusarium dieback (FD). See Greer et al. Southern Calif Shot Hole Borers/Fusarium Dieback Management Strategy – full reference and link provided at the end of the blog.

This strategy attempted to advise managers on addressing outbreaks in both natural and urban landscapes at a period of rapid spread of the pests. It includes sections on establishing a leadership and coordination entity, inventory and monitoring, short-term management options, public outreach, and research to identify long-term management strategies. I don’t believe the plan’s proponents have secured funding to implement it.

Meanwhile, the California Department of Food and Agriculture and other state agencies have been officially charged by the state legislature with developing a management strategy and coordinating efforts (see another of my blogs from July). I have been told that the state agencies are working with the southern California experts in developing the state’s strategy.

The USDA Animal and Plant Health Inspection Service (APHIS) has been instructed by the Congress (in the report accompanying appropriation of funds for the Department of Agriculture) to enhance its engagement with ISHB – beyond funding provided in the past under Section 10007 of the Farm Bill. APHIS has created a Federal Task Force which is focused on three shot hole borers – in addition to the Kuroshio and polyphagous shot hole borers, also the tea shot hole borer. Several USDA agencies in addition to APHIS — Forest Service, Agriculture Research Service – as well as the U.S. Fish and Wildlife Service are developing an outline of federal agencies’ roles and responsibilities in light of state actions. The work is at an early stage.

I look forward to learning more about how each of these players plans to proceed.

Certainly, managing ISHB infestation and spread is extremely difficult. Current options in production agriculture (avocados are damaged by the pest/disease complex) and urban forests focus on the use of pesticides and removal of infested material. Then the wood and bark must be safeguarded against insects’ escape until the wood can be chipped and the insect larvae killed, for example, by using heat from solar radiation (solarization). Management options in the natural setting are limited to removal, chipping, and solarization of infested material. In any habitat, there are many logistical challenges when managing large amounts of wood.

The pest-derived difficulties have been magnified by the absence until recently of the official agencies with responsibility for managing “plant pests” (as I have complained in many blogs over the years). I hope the state and federal agencies now becoming involved will coordinate their efforts – among themselves and with the many academics, locally based agency staffs, and volunteers who have been working so hard over the past several years to counter these invaders. [To learn about these efforts, visit here.]

You have an opportunity to learn more about the shot hole borers by participating in the upcoming annual meeting of the Continental Dialogue on Non-Native Forest Insects and Diseases in November. Our meeting this year is in Irvine, California – in the infestation zone. The meeting will follow the general schedule below:

  • Nov 5th: Travel day with informal evening social for those arriving early
  • Nov 6th: Dialogue Meeting all day (8am – 5pm)
  • Nov 7th: Joint CFD / Arbor Day Meeting and Field Trips (including one focused on ISHB) (8am- 5pm), Networking Reception (6-8pm).

Here are the quick links of interest:

Some of you might also participate in the periodic workshops about the several tree-killing pests invading southern California. UC Cooperative Extension San Diego will host an Invasive Tree Pests Workshop on Friday, October 19, 2018 in Mission Beach San Diego from 9:00am-2:45pm. This workshop will focus on Goldspotted Oak Borer, Invasive Shot Hole Borers, South American Palm Weevil, and pesticide law & regulation. CEU’s have been requested from the California Department of Pesticide Regulation and Western Chapter International Society of Arboriculture. Registration is $30/person and lunch will be provided. Go to GSOB.org.

Reference

Greer, K., K. Rice, S.C. Lynch. Southern Calif Shot Hole Borers/Fusarium Dieback Management Strategy for Natural and Urban Landscapes. July 2018

http://www.southcoastsurvey.org/static_mapper/fieldguide/Southern%20California%20Shot%20Hole%20Borers-Fusarium%20Dieback%20Management%20Strategy%20for%20Natural%20and%20Urban%20Landscapes%20-%20updated%20July%202018.pdf

P.S. The polyphagous shot hole borer has been detected at numerous sites in South Africa. One of several web-based sources of information is 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.

 

 

APHIS’ Proposed Sudden Oak Death Rule – Ignored by Too Many Stakeholders!

P. ramorum-infected seedlings in a nursery; photo by USDA APHIS

As I blogged on 2 August, the USDA Animal and Plant Health Inspection Service (APHIS) is proposing to update its regulations intended to prevent spread of the sudden oak death (SOD) pathogen (Phytophthora ramorum) via movement of nursery stock. The proposal is to incorporate into formal regulations several changes made through temporary “Federal Orders” issued in 2014 and 2015. This might sound boring – but it was actually an important opportunity to press APHIS to correct weaknesses in its current regulatory system. Whether APHIS’ ultimate program is weak or strong will affect how well we protect our forests against every kind of pest, not just SOD.

Unfortunately, few organizations seized this opportunity. Comments were submitted by only five organizations and three individuals. The organizations were the Center for Invasive Species Prevention, California Oak Mortality Task Force, several nursery industry associations in a joint comment, and the state departments of agriculture from Florida and Pennsylvania. It is most unfortunate that the other states appear to have given up on influencing APHIS’ decisions and did not comment. (Given the long history of APHIS failure to support states trying to adopt protective regulations – as described in Chapter 3 of my report Fading Forests III, available here – perhaps this is understandable.)

The Pennsylvania Department of Agriculture (DoA) was quite critical of the proposal in its comments. It complained that APHIS is not consistent in the way it regulates various quarantine pests and the vectors on which they might be transported. Allowing shipping nurseries to submit fewer samples for testing and providing less regulatory oversight does not help protect receiving states such as Pennsylvania.

The Pennsylvania DoA noted that the Plant Protection Act has a preemption clause which prevents states from adopting regulations more stringent than those instituted by APHIS. While the law allows for exceptions if the state can demonstrate a special need, none of the five applications for an exemption pertaining to P. ramorum has been approved. (The Environmental Law Institute addressed this issue in 2011; see source at end of the blog.)

Copies of all comments can be viewed here.  Their main critiques of APHIS’ proposal include:

1) APHIS should mandate sampling at all nurseries selling SOD host or associated host plant species.

While any nursery that contains or sells host or associated host plant species can become infected, APHIS does not have any system for detecting P. ramorum in such nurseries which have been infection-free for three years. This point was made by CISP and the California Oak Mortality Task force (COMTF).

1(a) Risk associated with Nurseries in the Quarantine Zone

The Florida Department of Agriculture (FDACS) objected to allowing interstate shipment of any plants – both host and non-host species – from nurseries in the quarantine zones of California and Oregon. FDACS notes that where P. ramorum is in the natural environment, it is essentially impossible to be certain that available inoculum is not in the water column or soil and thus potentially to being shipped with containerized plants.

2) Level of risk.

APHIS says that the current regulations have reduced the risk of spread of P. ramorum via the nursery trade to a low risk. APHIS cites the fact that over a nine-year period (2004 – 2013), P. ramorum was detected at a “very small percentage—usually no more than 3 percent annually” of nurseries inspected under the current program. To the contrary, I (on behalf of CISP) argue that an annual level of risk of three percent is not a low level of risk, the nursery industry’s comments accept this level of risk as “low”.

3) Inspection, Sampling, and Certification Protocols

The Pennsylvania Department of Agriculture objects that while APHIS admits the pathogen might be transmitted in media, soil, water, potted material and containers, the proposed rule does nothing to assist states in protecting themselves from pathogen transport via these vectors. Pennsylvania DoA asked APHIS to provide greater oversight so as to ensure consistency in inspection and certification procedures.

I, on behalf of CISP, said all decisions should be based on sampling and testing of water, soil, growing media, pots, and plants (leaves, stems, roots). They should not rely only on visual inspection of plants.

The Florida Department of Agriculture did not address the certification procedure directly, but objected to allowing shipment of lots of plant material determined to be free of P. ramorum from a nursery in which infected plants have been detected. FDACS pointed out that infected plants could slip through because they were asymptomatic at the time of inspection or because leaves dropped from nearby infected plants contaminated the soil.

 

4) Updates to the List of Hosts Should Be Comprehensive

As I noted in my previous blog, APHIS’ proposed update does not include more than a dozen species growing in the wild or in gardens in the Pacific Northwest that scientists have identified as hosts of P. ramorum; and would designate Japanese larch (Larix kaempferi) as only an “associated” host.

The California Oak Mortality Task Force raised similar issues and warned that unexplained gaps in the host list cause unnecessary confusion and undermine the scientific foundation of regulations.

 

Source

Porter, R.D. and N.C. Robertson. 2011. Tracking Implementation of the Special Need Request Process Under the Plant Protection Act. Environmental Law Reporter. 41.

 

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.