Reminder: Friday is the deadline for commenting on APHIS’ draft environmental assessment for the Asian longhorned beetle eradication program in South Carolina. Comments should be submitted at https://beta.regulations.gov/commenton/APHIS-2020-0086-0001
The draft EA can be downloaded from https://www.aphis.usda.gov/aphis/newsroom/federal-register-posts/sa_by_date/sa-2020/alb-draft-ea
The Center for Invasive Species Prevention submitted comments that supported the eradication effort because of the well-documented threat that the ALB poses to the forests of North America. We also supported the preferred alternative in the EA.
However, we found the environmental assessment (EA) to be deficient in several ways:
- the EA does not identify the host species present in the program area – not even of the 5,800 trees inspected by the program as of mid-August.
- the EA provides no estimate of the proportion of deciduous trees and shrubs in the area that are host species. Conifers dominate the area. This means that any fauna dependent on deciduous trees and shrubs for food and shelter already contend with limited resources. Consequently, while we concur with the EA that any impacts will be localized, they might be exacerbated by the relative rarity of hardwood species in the local area. It is particularly important that the EA address this question since the Programmatic EIS was written under the assumption that forests at risk to the ALB are like those in the Northeast and Midwest, where hardwoods dominate.
Without knowing the proportion of deciduous flora comprised of host species, no one can evaluate the amount of wildlife food that could be removed or treated by pesticides. Some wildlife species are potentially vulnerable, including those that feed on pollen and nectar (i.e., bees and other pollinators) and those that feed on insects and other invertebrates. The latter include two species listed federally as threatened species: the frosted flatwood salamander (Ambystoma cingulatum) and northern long-eared bat (Myotis septentrionalis). Also vulnerable are birds, 96% of which feed their young on insects and other invertebrates. I worry about sublethal effects and possible bioaccumulation. Aquatic organisms, especially invertebrates, might also be affected.
The information gaps in the EA highlight weaknesses in the Programmatic EIS, on which it relies. The most important gap is the dearth of pesticide dose/mortality data for terrestrial amphibians. Apparently, EPA has not required such studies before approving pesticides.
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