invasive species policy – Page 25 – Center for Invasive Species Prevention

Statement of the Center for Invasive Species Prevention on withdrawing its proposal to the U.S. Fish and Wildlife Service to add the red swamp crayfish to the Lacey Act for further analysis

On September 26, 2016, the Center for Invasive Species Prevention (CISP) petitioned the U.S. Fish and Wildlife Service (USFWS) to add 43 species to those regulated under the Lacey Act. Among these species was the red swamp crayfish (Procambarus clarkia). We now plan to withdraw and reconsider that species after we do more analysis.

We recognize that this crayfish species has major economic value. It is an important part of peoples’ livelihoods in Louisiana in particular. By no means do we want anyone in that business to feel threatened by the Petition.

Right now, the CISP Petition has no official status within the Federal government. It has not been published in the Federal Register nor has the USFWS indicated any intent to make it an official agency proposal. Even if it did, such a listing would not affect collecting, harvesting, rearing or selling crawfish directly within Louisiana or within other range States.

We would like to clear up some other confusion. It is true that the Lacey Act is used to prevent first-time imports of non-native “injurious wildlife” into the United States. The law has other provisions, though, that help prevent additional introductions of damaging species already in the country, that help stop harmful species’ interstate spread, and that apply to native species invading outside of their native ranges. These latter aspects can provide nationwide protection at a time when individual State’s laws are uneven. Populations of the red swamp crayfish are turning up in the wild. One can see how quickly it has become a nationwide problem in the wild on the animated map at the U.S. Geological Survey’s website. Approximately a dozen states have responded with their own prohibitions or other regulations.

We do think it is important to set a precedent that USFWS acts, in some way, on all species it determines to be of highest risk of invasiveness. Our Petition aimed to get this ball rolling. Much further analysis and public comment would go into any eventual decisions that USFWS makes on individual species. It could leave regulation of species in widespread trade to individual States. On the red swamp crayfish, CISP will withdraw that species from our Petition and reconsider what the best options are. Then we will consider whether a new Petition tailored to that species is warranted.

posted by Peter Jenkins

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

Support Effort to Declare UN “International Year of Plant Health”

Officials who carry out plant health programs around the world are trying to build public understanding and support for such programs by organizing an “International Year of Plant Health”. Such “international years” are designated by the United Nations General Assembly – so – as you can imagine – years of planning go into the effort.

So far, the proposal has been approved by the Council of Agricultural Ministers and will be considered by the Conference of the UN Food and Agriculture Organization in June 2017. If approved by the FAO, the proposal will then be put to the full United Nations by sponsoring nations’ diplomats. The General Assembly meeting in 2018 would consider the proposal – assuming FAO does forward it.

The goal of the proposed Year is to persuade decision-makers and the public that protecting plants by preventing and containing pests is an essential foundation for countries’ efforts to achieve food security, economic development, and environmental protection. Organizers also want people to know that plant protection is also a necessary component of policies to facilitate trade.

The events associated with the “International Year of Plant Health” will recognize plant health disciplines and the many people and organizations who contribute at the global, regional and national levels. It is not intended to celebrate specifically the International Plant Protection Convention, or the standards and other measures it has adopted.

Plant health professionals are concerned that funds and other resources dedicated to plant protection services are shrinking despite the growing threat to agricultural and natural resources from the spread of pests. Without more attention, they fear that resources will fall even farther behind the need as agencies confront demands from other global challenges. They intend to make the case that healthy plants help solve — rather than compete with – such other big problems as climate change, changing migration patterns, biosecurity concerns, and economic development.

The proponents specific objectives are to:

Raise awareness among political decision makers at global, regional, and national levels.
Build up plant health efforts and resources at all levels to better match growing needs linked to increasing trade and the new pest risks caused by climate change.
Educate the broader public so it better understands the importance of protecting plant health.
Enhance dialogue and stakeholder involvement in plant health.
Increase information about the state of plant protection in the world.
Promote partnerships on national, regional, and global levels.

It is hoped that success in raising awareness and understanding will result in sustainable funding of national plant health systems that will, in turn, enable

Improved capacity to take on more plant health related projects and programs
More effective collaboration and solutions at the global level
Better plant health situation in all countries.

I assume that readers of this blog are stakeholders in the global plant protection network. Most of you are professionally engaged in forest or nature conservation (perhaps through research), or are active conservation advocates. Some of you might be affiliated with trade and grower associations. Please consider how you can help educate political decision makers about the importance of protecting plants from non-native organisms that potentially threaten native ecosystems or agricultural and horticultural production. The first task is to ensure that the incoming Secretary of Agriculture actively supports the proposal both among his colleagues (e.g., with the Department of State) and at the FAO Conference in June. Please use your contacts in the government – including the Congress – and with other stakeholders to promote the idea.

Assuming that the International Year of Plant Health is approved, there will be many opportunities to lead or collaborate in the planned outreach efforts. Our engagement might help shape the message. For example, we need to ensure attention to the many challenges currently hindering plant health protection, as discussed in my blogs and in numerous peer-reviewed articles and reports. Also, we need to make certain that the environmental and biodiversity aspects of plant protection are prominent among considerations.

And if the Year is not approved? In my mind, that action would prove even more that we need to educate those who do not yet see why healthy trees and other plants matter!

Let me know what you think we might do – by sending me an email using the “contact us” button. Together, we can use this proposal to join coalitions with the goal of promoting stronger, more effective protection for our forests and other natural resources!

Posed by Faith Campbell

Asian Longhorned Beetle (ALB) – Newly Detected Infestation Shows Spread within Ohio

On November 18, Ohio authorities and APHIS announced the discovery of Asian longhorned beetle- infested trees in a section of Clermont County previously thought to be free of the insect. (The press release is not yet posted to the web; go here to see the most recent information).

The center of the newly discovered infestation is within the Williamsburg Township portion of the East Fork Wildlife Area, south of Clover Road. Tree inspection crews will continue to survey the area to determine the extent of the infestation. Any trees found to be infested will be removed as part of the eradication effort. Also, authorities will expand the ALB quarantine to include areas near the new infestation. When available, a map of the regulated areas will be posted at agri.ohio.gov.

This setback reminds us how difficult it is to contain or eradicate this insect.

ALB was first discovered in Tate Township in Clermont County, Ohio, in June 2011. That quarantine currently covers a 61-square miles area. According to the October 28 APHIS electronic newsletter, more than 2 million trees in the quarantine zone have been surveyed. The survey has detected 18,614 infested trees since 2011. 87,151 trees have been removed; Of these, 17,995 were infested and 69,156 were deemed at high-risk of either already being infested or likely to become infested in the immediate future.

Status of ALB in Other States

Massachusetts ALB was first detected in Worcester in 2008. The quarantine covers 110 square miles. At least 35,870 trees have been removed in the Commonwealth.

New York ALB was first detected in Queens in August 1996. APHIS and the state continue efforts to eradicate ALB from three separate infestations in Queens, Brooklyn, and Amityville. The quarantine covers a total of 137 square miles. The number of infested Trees for the entire New York program is 7,082. The number of trees removed is 23,731. Outbreaks in several sites have been declared eradicated:

Islip (Suffolk County) in 2011;
Manhattan and Staten Island in 2013.

In 2013, the Amityville area infestation was found to be larger than previously known.

The total number of trees removed in the Massachusetts, New York, and Ohio programs was 146,000. However, this is not the total for all the damage caused by the Asian longhorned beetle.

ALB outbreaks in Illinois (Chicago) and New Jersey were eradicated earlier, and their removals are not included in the total given above.

In Illinois, according to Haack et al. 2012, 1,771 trees were removed and 286,227 were treated with systemic pesticides (imidacloprid).

In New Jersey (again, according to Haack et al. 2009, 21,981 infested and high-risk trees were removed. Another 480,574 trees were treated. This total is not complete since the program had not yet succeeded in eradicating the ALB in New Jersey at the time of writing.

The total from all programs is 169,752.

The risk of new introductions remains.

During fiscal years 2010 – 2016, Customs (CBP) detected tree-killing pests in 4,984 shipments – an average of 807 shipments each year. (For the 2015 report, go here)
An analysis by Haack et al. (2014) concluded that one tenth of one percent of the wood packaging entering the U.S. after adoption of ISPM#15 still contained a tree-killing pest. Since the U.S. imports approximately 25 million shipping containers each year, and about half of these contain wood packaging, an “approach rate” of 0.1% equals 13,000 containers harboring pests that probably enter the country each year. That is 35 potential pest arrivals per day.
Customs send samples of intercepted wood packaging to an APHIS laboratory where the insect larvae are grown to adulthood and identified. The APHIS lab has received 1,068 insects from April 2012 through August 2016, taken from 786 separate interceptions of non-compliant wood packaging. Six of the insects were Asian longhorned beetles.

APHIS also detected 69 other pests in wood packaging sent from China.

The United States and Canada began requiring wood packaging from China to be treated in December 1998. (See my discussion of this regulation in Fading Forests II here. Since the Customs data begin in 2010, we can see that 11 to 16 years after the rule governing Chinese wood packaging went into effect, we are still receiving wood packaging with pests from that country.

Also, 700 pests arrived from 36 other countries, led by Mexico, Turkey, and Ukraine (see presentation here; search for “Nadel”)

What are APHIS & CBP doing about these flagrant violations of existing rules? Each violation exposes our forests to additional pest attack and our citizens to higher costs – either in local or federal taxes or personal costs to remove trees — as well as to mental anguish and health impacts.

The evidence is in. APHIS and Customs should tighten enforcement of ISPM#15 by:

Prohibiting imports in solid wood packaging (boards) from foreign suppliers which have a record of repeated violations over the 10 years ISPM#15 has been in effect. (It’s been 16 years for exporters from Hong Kong and mainland China). A reasonable number of violations should trigger this prohibition – perhaps eight over the entire period.

The U.S. should allow imports from those suppliers that are contained in other types of packaging materials, including plastic, metals, fiberboards …

Fining an importer for each new shipment found to be out of compliance with ISPM#15 if the foreign supplier of that shipment has a record of repeated violations (but fewer than the number that would trigger a ban) over the 10 years ISPM#15 has been in effect (16 years for exporters from Hong Kong & mainland China). The number of violations needed to trigger the fine might be five over the entire period – not just in one year.

Ensuring that exporting countries understand that foreign suppliers that change their names or take other steps to obscure their past import records will be prosecuted for fraud. This penalty should be severe so as to deter deliberate attempts to avoid the consequences of past actions.

References

Haack, R.A., F. Herard, J. Sun, J.J. Turgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetle and Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46.

Haack, R. A., K. O. Britton, E. G. Brockerhoff, J. F. Cavey, L. J. Garrett, M. Kimberley, F. Lowenstein, A. Nuding, L. J. Olson, J. Turner, and K. N. Vasilaky. 2014. Effectiveness of the international phytosanitary standard ISPM no. 15 on reducing wood borer infestation rates in wood packaging material entering the United States. Plos One 9:e96611.

Posted by Faith Campbell

Firewood: Important Progress — and a Troubling Stalemate

After years of work, the combined efforts of many staff at federal agencies and non-profits have succeeded in placing a firewood alert message on the Reservation.gov website for all of the 3,163 federal campgrounds managed by the National Park Service, USDA Forest Service, and Corps of Engineers for which visitors can reserve a spot in advance. Only 43 federal reserveable campgrounds remain without messaging. These are managed by the Bureau of Land Management, Bureau of Reclamation, and the US Fish and Wildlife Service.

As of October 2016, visitors reserving campgrounds through the services of Reserve America or Recreation.gov for any National parks, National forests, or Army Corps reservoirs will find new information in the “Know before you go” section – a message about not moving firewood.

The messages vary somewhat by agency, but basically say: “Don’t move firewood!” They often add “buy firewood at or near your destination and burn it on-site.” Some messages include a brief explanation about the aim — to prevent or limit spread of invasive tree-killing pests. Some include a message that some states regulate firewood movement. There is a link to either the national program — dontmovefirewood.org – or to the pertinent state program, e.g., the California Firewood Task Force for National Forest campgrounds in Region 5.

Some federal campgrounds do not use the Reservation.gov system and therefore require separate efforts to improve firewood messaging. This includes several popular water-based recreation sites in the central southern states, such as the Arkansas River National Recreation Area and Oachita National Forest. Many states in this region also do not regulate firewood. [See my earlier blog contrasting management of firewood with management of boats and attached mussels or aquatic plants here and the article by Frank Koch and colleagues, referenced below.]

Those who succeeded in achieving the widespread adoption of this outreach program deserve our thanks and praise! They worked long and hard for this.

On a Less Positive Note…

Unfortunately, efforts to put a firewood certification program into place appear to have stalled.

In March 2010, in response to increasing concern across the country, APHIS issued a first-ever firewood strategy, with a number of important elements. It proposed the following:

Outreach Strategies:

State and Federal agencies should convene a communications steering committee.
Develop an online hub of firewood outreach materials.
Prioritize the outreach activities.
Use diverse methods to get consistent messages out about the risk of moving firewood.
Support the voluntary and regulatory efforts.

Voluntary Strategies:

Large-scale producers and retailers adopt best management practices.
National producers and retailers adopt an industry-run national certification program with labeling and recordkeeping requirements based on best management practices.
Public and private campgrounds make local or treated firewood available.
Firewood consumers and small-scale local producers adopt best management practices.

Regulatory Strategies:

APHIS should promulgate regulations for the interstate movement of firewood as soon as possible with requirements for labeling, recordkeeping and treatment based on best management practices.
States should publish intrastate movement regulations with requirements similar to the Federal regulations for labeling, recordkeeping and treatment as needed. Moving firewood 50 miles or less would be exempt from intrastate regulations provided this does not violate any quarantine that may be in place.
State, Federal, and private parks, forests and campgrounds should institute policies that encourage campers to use local firewood and to not move firewood out of the local area.

What has been done over the six and one-half years since the Strategy was released?

There has been tremendous progress on the outreach and voluntary strategies, with the Nature Conservancy’s Don’t Move Firewood program providing support and advice. However, these voluntary programs are inadequate without regulatory backup.

There has been less progress on the more formal certification and regulatory strategies proposed in 2010.

Geoff Friedman – a firewood producer based in northern California – reports that he has developed the software for a certification program and worked with producers to get their acceptance. However, implementing the required wood treatments and – especially – staffing a third-party certification program – would raise the cost of firewood by 50%, according to Friedman. The major retailers which sell packaged firewood – the “big box stores” – are not willing to adopt the program because of this increased cost. In the absence or regulations requiring treatment of firewood, the program has stalled. (In the East, many states already regulate firewood. However, those states’ treatment requirements vary. Friedman seems to believe that this challenge can be worked out.)

APHIS has not adopted national regulations and does not appear to be on the verge of doing so. I believe APHIS wanted to tie its regulations to the certification program that has now stalled. Eleven of the 50 states currently have their own state-specific regulations limiting the movement of firewood from other states into their state. Only two more states are known to be potentially considering legislation in 2017. Many — but not all — federal agencies have now engaged on discouraging visitors from bringing their own firewood (see above). Some National parks actually restrict visitors bringing firewood to wood that is certified by USDA – including the park with the highest number of visitors, Great Smoky Mountains National Park. However, Yosemite and other National parks in California are not among them. And these are vulnerable to goldspotted oak borer and the polyphagous or Kuroshio shot hole borers (see species write-ups here).

Worse, APHIS is actively moving toward dropping regulations trying to prevent spread of the emerald ash borer (see species write-up here). APHIS argues that with EAB now present in 30 states (although in many cases, in only one or a few counties), it is too late to try to prevent the insect’s further spread. The regulatory effort is using resources that would be better put to other strategies, such as expanding the biocontrol program. I concede that funding is tight, and likely to be cut further; and that other approaches – and other pests! – need attention.

However, the legal and logical foundation for nearly all state regulations governing firewood is the emerald ash borer. The promised federal regulation and certification program also rest primarily on the EAB risk. Many states – as well as APHIS – must base their regulation on one or more specific pests. Will these state regulations and promised federal programs survive the loss of the federal EAB regulatory program?

In any case, we are a long way from what is needed to get control of the firewood pathway. Each of the “lower 48” states should have an external quarantine. Hawai`i might need one too, if it imports firewood. (Hawai`i does import other types of risky wood products, including Christmas trees.) Also, all 50 states need internal restrictions on the distance firewood is moved. So far, only a fraction have them.

The incoming Trump Administration strongly objects to regulations, so it is highly unlikely that we will see progress on these matters in the near future.

Reference:

Koch, F.H., D. Yemshanov, R.D. Magarey, and W.D. Smith. 2012. Dispersal of Invasive Forest Insects via Recreational Firewood: A Quantitative Analysis J. Econ. Entomol. 105(2): 438-450 (2012);

Posted by Faith Campbell

Leigh Greenwood helped check the facts and dates mentioned in this blog

The Latest on Phytophthoras

Phytopthora ramorum on tanoak in California; F.T. Campbell

Nine eastern states are participating in the 2016 USDA National Phytophthora ramorum Early Detection Survey of Forests. Those states are AL, FL, GA, MS, NC, PA, SC, TN, and TX. As of late August, streams in four locations were P. ramorum-positive. Three are in AL, one in MS. All had tested positive in previous years. Also, all have been associated with previously positive nurseries. (Reported in the California Oak Mortality Task Force newsletter for September.) It is reassuring that no new positive locations have been detected. However, on what substrate is the pathogen persisting? Scientists agree that the pathogen does not survive in water (although it is reliably detected by testing in water) but must survive on some plant material – perhaps roots.

P. ramorum also persists in nurseries. Seven California nurseries are participating in the APHIS federal P. ramorum program under which they are allowed to ship host plants interstate. Positive plants have been detected in two of them. One of these nurseries is undergoing the Confirmed Nursery Protocol clean-up. The other has completed the cleanup and has been allowed to resume shipping plants interstate. In both cases, the infected plants were not from the five “high-risk” genera which are the focus of monitoring for the regulatory system — Camellia, Kalmia, Pieris, Rhododendron, and Viburnum. (Reported in the California Oak Mortality Task Force newsletter for September.) I expressed concern about this too-narrow focus in a blog posted in July 2015 – http://nivemnic.us/2015/07/.

I have written about the widespread presence of various Phytophthoras in nurseries in blogs in April (for Europe http://nivemnic.us/2016/04/ ) and July (for California http://nivemnic.us/2016/07/ ). New publications add to this picture.

Junker and colleagues (see references below) report the detection of 15 Phytophthora species in two commercial woody ornamental nurseries (presumably in Europe, since the authors are Europeans). Twelve of the species are previously described but the DNA of three isolates did not match any of the known species. Detections were highest in puddles on nursery pathways; followed by plant residues;, wind-carried leaves; and water and sediment from runoff. The plant samples showed very low infection rates – a disturbing finding given the reliance until recently on inspection of plants to detect the pathogen. (Reported in the California Oak Mortality Task Force newsletter for September.)

New Phytophthora confirmed in U.S.

The United States has the first official confirmed detection of the pathogen Phytophthora quercina. It was found associated with oak trees planted on restoration sites in central coastal California. Although the California detection is the first officially confirmed detection of the pathogen in the U.S., a P. quercina ‘like’ organism has been reported to be associated with oak decline in forests in the Midwest. P. quercina is a pathogen associated with oak decline across Europe. It was rated as the species of highest concern in a USDA Plant Epidemiology and Risk Analysis Laboratory (PERAL) report. Another pathogen, P. tentaculata, was rated fifth on the same list. It was recently found in association with multiple native plant species in California’s native plant nurseries (see my July blog, linked above). See also California Oak Mortality Task Force newsletter at http://www.suddenoakdeath.org/news-and-events/current-newsletter/

Rapid Response Might Have Contained SOD – When will authorities learn this lesson?

Earlier this year, experts on modeling the epidemiology of plant disease concluded that the sudden oak death epidemic in California could have been slowed considerably if aggressive management actions – backed by “a very high level of investment” – had started in 2002. By then, there was sufficient knowledge about the disease to guide actions. Management actions should have focused on the leading edge of the epidemic (admittedly, that edge has proven difficult to detect). The study is by American and British scientists (Cunniffe, Cobb, Meentemeyer, Rizzo, and Gilligan). See reference and news report below.

The authors’ estimate documents the high costs of inaction. This is an important lesson – which has been repeated many times. If only officials from California and APHIS would take this to heart regarding several other forest pests. These include the polyphagous and Kuroshio shot hole borers and even the goldspotted oak borer (all described here).

References

https://www.sciencedaily.com/releases/2016/05/160502161111.htm?utm_source=feedburner&utm_medium=email&utm_campaign=Feed%3A+sciencedaily%2Fplants_animals%2Finvasive_species+%28Invasive+Species+News+–+ScienceDaily%29

Cunniffe, N.J., R.C. Cobb, R.K. Meentemeyer, D.M. Rizzo, and C.A. Gilligan. Modeling when, where, and how to manage a forest epidemic, motivated by SOD in Calif. PNAS, May 2016 DOI: 10.1073/pnas.1602153113

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

Posted by Faith Campbell

Europe moves to curtail forest pest introductions – but strongest measures are hampered by trade rules

ALB in Europe; photo by Doris Holling WSL

Maartje J. Klapwijk and several colleagues have recently taken a hard look at non-native forest pests in Europe. They conclude that current European legislation is inadequate to prevent forest/tree pest introduction, establishment and spread in the European Union. (A link to the article is provided at the end of this post.)

Some of the proactive steps that they recommend, however, will be difficult to enact. International trade rules (World Trade Organization, Agreement on the Application of Sanitary and Phytosanitary Measures – SPS Agreement) require that countries prove that the target commodity in trade presents a significant pest risk – proof that is difficult to obtain before damage has actually occurred.

(I have written extensively about this “Catch 22” – see Fading Forests II here)

Furthermore, European Union rules prevent countries from taking proactive measures to restrict potentially pest-infested plants or wood products being traded from one EU member country to another. However, member countries’ vary in their levels of concern about tree-killing pests. As a result, phytosanitary measures are quite weak in some countries. Once a pest-infested shipment enters a country with a weak phytosanitary system it can be moved freely to any other member country.

Thus, international and EU rules together create a significant risk that a pest will enter, establish, and then be spread by commerce to the rest of the Union.

The authors note that growing trade in living plants and wood products has brought a rise in non-native tree pests becoming established in Europe. The number of alien invertebrate species has increased two-fold since 1950; the number of fungal species has increased four-fold since 1900. Few studies have attempted to quantify the economic impacts of non-native tree-killing pests in Europe. But the authors say that the introduced pests will cause economic damage either directly by reducing the revenue of the country or imposing control costs; or indirectly through trade restrictions or reduced values of real estate.

Among the recent introductions are the pinewood nematode from North America; Asian and Citrus longhorned beetles and ash dieback fungus from Asia; and sudden oak death and other Phytophthora species. (I described the extent of Phytophtphora infestations in European nurseries in a blog posted on April 25.) As a partial response, EU countries have created a network of nurseries intended to serve as an early warning system against further introductions of alien tree pests. (Descriptions of these pests and where they are found are available on the website of the European and Mediterranean Plant Pest Organization (EPPO) here)

ALB introduction sites in Europe

The European Union regulates invasive species through the Environment Directorate-General (DG Environment). However, tree-killing pests and other plant health concerns are the responsibility of a different governmental body, the Directorate-General Health and Food Safety (DG SANCO).

Maartje J. Klapwijk and colleagues note the risk associated with:

crates, pallets, and other forms of wood packaging;
wood chips (Europe imports more than 4 million tons of wood pellets as fuel in order to meet its carbon emission reduction goals) ; and
especially – living plants.

They note that the international community has adopted two international related sanitary agreements : ISPM#15 (wood packaging) and ISPM#36 (living plants). The European Union requires certificates stating that imported plants are free from harmful organisms and that phytosanitary measures stipulated by the importing country have been applied. However, limited resources mean that only a small proportion of living plants, plant material, soil and wood products arriving in Europe can be inspected. “The main purpose of the inspections is to verify whether shipments comply with regulations, rather than to stop potentially harmful organisms …” (my emphasis). Reflecting the differences in levels of concern among EU member states noted above, there are large differences in inspection intensity among the EU member states.

The pertinent European legislation is Directive 2000/29/EC. It relies on a ‘‘black-list’’ of plants and plant products that are banned from import and specifies procedures to apply when any of these banned products is found in the EU. According to Klapwijk and colleagues, these quarantine lists provide insufficient protection because harmful organisms that enter the EU often are unknown prior to establishment.

Aware of the current system’s inadequacies, the EC has proposed a new regulation which would simplify and harmonize plant passports, allow for stricter measures against pests, and address emerging risks from certain living plant imports from some non-EU countries. Instead of listing harmful plant pests, the proposed regulation “sets out the conceptual nature of quarantine pests” and empowers the Commission to adopt measures to control certain pests.

Klapwijk and colleagues praise these actions as a significant step forward. However, they note that the new rules still don’t provide for precautionary assessments of high-risk commodities. Nor do they restrict import of the highest-risk commodities, such as imports of large plants or plants in soil. (my emphasis)

The authors note that other countries take a more pro-active, precautionary stance. Australia and New Zealand require that all imported plant products be assessed and proved safe before import. The U.S. restricts the size of imported plants and does not allow imported plants to be in soil. (The U.S. has proposed a new approach that relies increasingly on integrated measures or systems approaches rather than port-of-entry inspection. However, this proposal has been pending for more than three years. (APHIS explains its proposal here)

The question is, do trade rules allow Europe to apply the same restrictions as other countries? As Klapwijk and colleagues note, the EU cannot adopt more rigorous phytosanitary measures without providing scientific evidence for this necessity. Preparing a risk assessment to make this case will involve considerable work. As part of this process, Europe should announce that it wishes to raise its “level of protection” and that more stringent phytosanitary measures are needed to achieve that new goal.

Meanwhile, the EU can enhance its active detection efforts and “rapid response” capabilities. The new EC directive will require countries in which a new pest is detected to eradicate or contain the pest. However, the response continues to depend on investments and actions by individual Member States – which have often been insufficient.

Klapwijk and colleagues endorse the suggestion by Hulme et al. (2009) that the European Commission establish a single agency to respond to introductions of any kind of invasive species (not just tree pests) – modeled on the European Centre for Disease Prevention and Control.

Finally, Klapwijk and colleagues note the importance of engaging the public. Citizens’ participation can enhance early detection and strengthen public support for management strategies.

CONCLUSIONS

We Americans are very lucky that the U.S. Department of Agriculture had fairly stringent rules governing plant imports before the World Trade Organization and SPS Agreement were negotiated in the 1990s. We don’t have the burden of proving that imports of large plants (small trees!) in soil is too risky. (This not to say that U.S. regulations should not be tightened further for the most high-risk imports. See Fading Forests III here). Europeans should be able to build their case for more restrictive trade rules on existing risk assessments and practices utilized by the U.S., Australia, New Zealand, and others; on the numerous studies published in recent years that describe recent introductions to Europe and the pathways by which they entered; and by the number of those introductions alone. (To see what has been introduced, visit the website of the European and Mediterranean Plant Pest Organization (EPPO) here)

One important step in improving U.S. rules would be to finalize the proposal – put forward in 2013 – to depend more on integrated measures or systems approaches rather than inspection at the port of entry. Join with me in urging the Secretary of Agriculture to finalize this proposal before he leaves office in January. Contact me via the “contact us” button on the webpage to learn how you can help.

The United Kingdom has voted to leave the European Union. This means that the U.K. has the opportunity – and burden – of developing its own phytosanitary regulations. The U.K. has some of the leading forest pathologists and entomologists. The risk is obvious to all – especially Phytophthora ramorum in larch plantations and ash dieback disease in many areas of the country. I hope that the British will seize this opportunity to adopt really effective phytosanitary regulations that can serve as a model for the rest of Europe – and possibly even the U.S.

Sources

Maartje J. Klapwijk, Anna J. M. Hopkins, Louise Eriksson, Maria Pettersson, Martin Schroeder,A°ke Lindelo¨w, Jonas Ro¨nnberg, E. Carina H. Keskitalo, Marc Kenis. 2016. Reducing the risk of invasive forest pests and pathogens: Combining legislation, targeted management and public awareness. Ambio 2016, 45(Suppl. 2):S223–S234 DOI 10.1007/s13280-015-0748-3

Hulme, P.E. 2009. Trade, transport and trouble: Managing invasive species pathways in an era of globalization. Journal of Applied Ecology 46:10-18

Posted by Faith Campbell

On the Road to Extinction, Invasive Plants Do Have Significant Impacts

KONICA MINOLTA DIGITAL CAMERA — Lantana camarata

No studies have documented extinction of a native plant species caused by invasive ones. This has led to questions about whether invasive plants have truly significant impacts. (Of course, species extinction is not the only important impact).

These questions have been answered in a recent article by Paul Downey (of the Institute for Applied Ecology, University of Canberra) and David Richardson (of the Centre for Invasion Biology at Stellenbosch University, South Africa). A link to the article is provided at the end of this blog.

Downey and Richardson argue that studies have documented instances of invasive plant species putting native plants on the path – or trajectory – to extinction. Furthermore, plants go extinct more slowly than animals, often over centuries. As result, current approaches to analyzing impacts of invasive plants underestimate the damage that non-native species cause because they assume extinction will not result.

The authors name six “thresholds” along the trajectory to plant extinction. Each is affected by invasive plants:

Plants die more quickly than they can be replaced by their offspring in some locations.
Plants disappear from some locations entirely, but seeds or spores remain that could regenerate a new cohort of individuals.
Some locations lose both individual plants and their propagules. This is a local extinction.
The last locations hosting a species lose their individual plants, but in some places seeds or spores remain in the soil.
The species is entirely lost in the wild with no individuals or propagules. The only survivors are held in botanic collections.
Extinction. The remaining plants are lost, and the remaining seeds or spores are no longer capable of becoming new plants.

By focusing purely on full extinction — step six — plant conservationists lose sight of the threats to species as they occur and accumulate at each stage of the process. Without such attention we fail to act on opportunities to protect the species and counter the wider impacts of its disappearance.

Downey and Richardson note that plant invasions affect each component of a plant species’ population dynamics: fecundity (seed production); death; immigration; and emigration (dispersal). Yet they could find no studies that have explored the effects of alien plants for all four components collectively.

A second explanation for scientists’ not documenting any extinctions caused by invasive plants is that it is extremely difficult to prove that every last individual or propagle of a plant species is dead . Many plant species have long-lived seed banks in the soil, or can regenerate from underground structures – so it is hard to know when that species is truly gone. This is especially true since seed banks are rarely monitored.

Furthermore, many of the conditions needed to demonstrate that alien plants have caused the extinction of native plant species have either not been measured, or have been examined for too short a time. The IUCN definition of extinction requires that data be collected over “a period that is appropriate for the life cycle of the species” (IUCN. 2014. Guidelines for using the IUCN Red List categories and criteria. Version 11. Prepared by the Standards and Petitions Subcommittee. Switzerland). Given the long persistence of plant species, the “appropriate period” exceeds the timeline almost all of even the few long-term studies in invasion ecology.

Downey and Richardson say that relying on changes in species richness to assess the impacts of alien plants will not adequately predict or describe the effects of invasion. Such analysis especially will not provide evidence for a species crossing from Threshold 1 to 2 or 3 . Indeed, they assert, collective species richness measures could mask losses of some species in instances where additional species are also recorded (i.e. the losses are off-set by additions).

The authors have found abundant evidence of invasive plants driving native plants along this extinction trajectory. They cite several examples of an invasive plant causing a “threshold effect” – that is, increases in alien plant cover or density result in decreased native plant species diversity or richness. They define this as the native species crossing from Threshold 1 to 2. Among the examples provided are several species in Australia and New Zealand and Lonicera maackii in the United States.

The authors also provide examples of species causing “extinction debts” – that is, a significant time lag between the introduction of an alien species initiating a native species’ movement along the trajectory and its actual extinction. One mechanism is by reducing native plants’ seed production. Again, Lonicera maackii is cited.

Downey and Richardson also note the potential downsides of invasive plant control measures.

In the end, the authors urge that scientists “… shift attention away from the end point of the extinction trajectory … to give due consideration of the full series of processes that drive declines of populations of native species.”

As Richardson has said in an interview with Oxford University Press, “… There is absolutely no doubt that alien plant invasions are eating away at native plant biodiversity. Many native plant species — probably HUNDREDS of species — are precariously close to being functionally extinct and survive as the ‘living dead’.’”

Source: Downey, P.O., D.M. Richardson. 2016. Alien plant invasions and native plant extinctions: a six-threshold framework. AoB Plants, 2016; 8: plw047 DOI: 10.1093/aobpla/plw047 ; open access, available at http://aobpla.oxfordjournals.org/

Posted by Faith Campbell

Campbell Wins Award from State Foresters

We are delighted to note that CISP Vice President Dr. Faith Campbell recently received the John Shannon Current Achievement Award for Partnerships from the National Association of State Foresters (NASF).

She was among nine individuals honored on September 21, 2016, at the group’s annual meeting in Savannah, Georgia. All recipients “have made outstanding contributions in wildland fire protection, urban and community forestry, forest management and overall leadership” according to NASF. Each was nominated by the organization’s members and partners for accomplishments in promoting, supporting and strengthening the forestry community nationwide. “Every year we are inspired by the achievements of so many leaders and partners in the forestry community, who are working to ensure the future sustainability of our nation’s trees and forests,” said Wisconsin State Forester Paul DeLong and NASA President.*

The Association noted that Faith has spent more than twenty years working on invasive species issues for several environmental or conservation organizations, including The Nature Conservancy, American Lands, and the Natural Resources Defense Council.

We at CISP couldn’t agree more that Faith is an inspiring and long-standing leader. She has extraordinary expertise regarding the non-native forest pests that threaten our Nation’s forests. Her voice is forthright and insistent — urging us ever onward to strengthen national and international policy to limit these burgeoning threats.

Please join us in congratulating her on this much-deserved honor.

Peter Jenkins

Phyllis Windle

* NASF press release at: http://www.stateforesters.org/2016-state-forestry-awards-recognize-excellence-forestry

CISP files multi-species listing petition with US Fish & Wildlife Service – per Lacey Act

Alburnus alburnus photo by David Perez

Update as of December 7, 2016: the Petition was amended to delete one species red swamp crayfish (Procambarus clarkia), for which we decided it needed more analysis. We will consider whether to re-propose it for an “injurious species” listing and/or other measures later

Last Friday morning, I delivered a Petition to the Secretary of the Interior’s office the roots of which go back 15 years to 2001. The title: Petition: To Amend 50 CFR §16.13 to List 43 High Risk Fish, Crayfish, and Mollusk Species as Injurious Species under the Lacey Act. (For a copy of the petition, use the “contact us” button on the CISP webpage.) I was really excited to file this on CISP’s behalf because it is the logical expansion of a more proactive approach to preventing introductions of invasive, disease-carrying, or otherwise “injurious” non-native animals that we don’t want running around in the United States. We already have scores of invaders (starlings, red lionfish, Burmese pythons, feral hogs, Asian carps, zebra and quagga mussels, tegus and on and on). We need to start doing multi-species listing proposals in order to change what has been an extremely slow process into one that works at a pace that can actually protect our nation’s resources – and people – from the risks of this age of vast globalized trade in live fish and wildlife.

Back in 2001, the National Invasive Species Council adopted its first Management Plan. One element in it was to adopt a science-based screening method aimed at identifying the highest risk non-native animals that we should keep out of the country. This was to have been completed by about 2006. I was appointed long ago (so far back I can’t remember the year) to the committee tasked with this responsibility. The Committee went through fits and starts and sometime in the mid-2000s just crashed into nothingness and stopped meeting. But, a dedicated U.S. Fish and Wildlife Service (FWS) biologist in the Midwest Region — Mike Hoff — kept at it for years on a shoestring budget and around 2011 he got some real funding and was able to get his animal screening project staffed. Lo and behold, they started developing lists of high-risk species based on robust scientific predictions. I won’t go into the models he used and the peer-review he had to go through. Suffice it to say that process took about 3 more years before Mike Hoff and his colleagues could convince the FWS to actually start publicly posting the results of their screening work. But, starting in 2014 they posted several and in late 2015 they posted them in earnest. Now there are 150 Ecological Risk Screening Summaries (ERSSs) on the bureau’s website.

Out of the 150 species, 63 pose a “high” overall risk of invasiveness/injuriousness. For funding and historical reasons most are aquatic species that could invade in the Great Lakes region, but even so it is a great beginning. The 63 species include 46 fishes, 8 crustaceans, and 9 mollusks. One fish on the website (mrigal, Cirrhinus cirrhosus) appears to be labeled “high risk” in error and one of the mollusks (zebra mussels, genus Dreissena) is already listed under the Lacey Act. Also, Interior already has formally proposed that 11 of the 63 species on the website should be listed as “injurious”. That is, almost exactly one year ago the agency proposed to add 10 of the non-native fish and one crustacean. Thus, those 11 are not included in this new Petition. The FWS needs to take action on them soon.

UPDATE: On Sept. 29th the FWS finalized its rule listing all 11 of those species. The regulation and the detailed FWS explanation for it published in the Federal Register set a strong precedent and a useful template for listing the 43 species in the Petition as well.

Now this Petition, which I co-wrote with my CISP colleague Phyllis Windle, PhD., should be the USFWS’ next multi-species listing. The 43 “high risk” species proposed in it are listed at the end of this blog. The Petition excludes 7 species with posted ERSSs that were “high: overall,” but were below a high rating for either their history of invasiveness or climate match. As a result, the 43 below represent the highest range of the FWS’s identified high risks. Species like the Devil firefish, virile crayfish and the bleak – just their names makes me not want them here – pose unacceptable risks.

While the voluntary program promoted by the FWS on its webpages along with the ERSSs is a commendable hope, a “please do not import” approach cannot be relied upon. Administrations and websites change and some industry outliers won’t follow voluntary measures anyway – some even see them as creating a business opportunity. As I have watched (and supported), Mike Hoff and the FWS invested a significant amount of funds and staff time over the last 10 years to develop this screening process and research and write the scores of posted ERSSs. Other experts were involved in designing the process and providing peer reviews at different stages. It would be a significant waste of taxpayer resources were the FWS not to follow through and take regulatory action for species posing a clearly high risk. None offers an essential benefit that outweighs its harm to the United States. Minimal to zero stakeholder opposition is expected to prohibiting them. So what are we waiting for? The listing Petition needs to get posted in the Federal Register for public comment and action started as soon as possible. This one is virtually a “no brainer”.

The proposed list additions are below. For a copy of the full Petition, use the “contact us” button the the CISP webpage.

Mollusks

(A) Bithynia tentaculata (faucet snail).

(B) Corbicula fluminea (Asian clam).

(D) Limnoperna fortune (golden mussel).

(E) Potamopyrgus antipodarum (New Zealand mudsnail).

(F) Sinanodonta woodiana (Chinese pond mussel).

Fish

(A) Acanthogobius flavimanus (yellowfin goby).

(B) Alburnus alburnus (bleak).

(D) Cichlasoma bimaculatum (black acara).

(E) Coregonus lavaretus (powan).

(F) Ctenopharyngodon idella (grass carp).

(G) Cyprinella lutrensis (red shiner).

(H) Cyprinus carpio (common carp).

(I) Gymnocephalus cernua (ruffe).

(J) Hypomesus nipponensis (wakasagi).

(K) Ictalurus furcatus (blue catfish).

(L) Misgurnus anguillicaudatus (Oriental weatherfish).

(M) Morone americana (white perch).

(N) Neogobius melanostomus (round goby).

(O) Odontesthes bonariensis (Argentinian silverside).

(P) Oreochromis aureus (blue tilapia).

(Q) Oreochromis mossambicus (Mozambique tilapia).

(R) Oreochromis niloticus (Nile tilapia).

(S) Parachromis managuensis (Jaguar guapote).

(T) Poecilia reticulate (guppy).

(U) Pterois miles (Devil firefish).

(V) Pterois volitans (red lionfish).

(W) Pterygoplichthys pardalis (Amazon sailfin catfish).

(X) Pterygoplichthys multiradiatus (Orinoco sailfin catfish).

(Y) Pterygoplichthys disjunctivus (vermiculated sailfin catfish).

(Z) Pylodictis olivaris (flathead catfish).

(AA) Rhodeus ocellatus (rose bitterling).

(BB) Sarotherodon melanotheron (blackchin tilapia).

(CC) Scardinius erythrophthalmus (rudd).

(DD) Tilapia mariae (spotted tilapia).

(EE) Tilapia zillii (redbelly tilapia).

Crayfish

(A) Oronectes limosus (spiny-cheek crayfish).

(B) Oronectes propinquus (northern clearwater crayfish).

(D) Oronectes virilis (virile crayfish).

(E) Pacifastacus leniusculus (signal crayfish).

(F) Procambarus clarkia (red swamp crayfish).

Posted by Peter Jenkins

Let’s Work Together to Curtail Threat to Our Forests from Non-Native Pests

Dear Forest Pest Mavens,

I believe you agree with me that non-native insects, pathogens, earthworms … and other organisms! … pose significant threats to North America’s tree species and the complex ecosystems of which they are such important components.

I hope you also agree that our society’s efforts to counter this threat fall far short of what is needed.

Official phytosanitary policies are not as strong as needed to prevent introduction and spread of these tree-killing pests.
Worse, those policies are not always enforced assertively – as I documented in my blog about a shipment of auto parts posted on 9 August.
The Congress does not provide sufficient funds and other resources to support active detection and response programs – either early in an invasion or later.
Businesses that import or trade in goods or packaging that can transport pests are not held responsible for taking actions aimed at reducing the likelihood of such transport or supporting recovery efforts. Opposing free trade has become a hot button election issue but one of its worst impacts — wholesale movement of pests — is never mentioned.

As I noted in my earlier blog, a key reason we see these weaknesses is because those who want stronger programs have not had an effective voice in educating federal policy-makers – the USDA secretary, senators, and members of Congress – about the damage caused by introduced tree-killing pests and the governmental actions needed to counter those impacts.

The election provides both a deadline and an opportunity.

The deadline: we should try to finalize some APHIS-proposed actions before this Administration leaves office. Outgoing officials often feel freer to take bold actions at this time.

The opportunities:

New officials who take office in January might be open to addressing “new” issues. We must begin efforts now to get our “asks” on their agenda. Specifically, we should approach the senators who will question appointees to USDA Secretary and Under Secretary positions during their confirmation processes. We should urge them to ask candidates how they would address plant pests and to make firm, specific commitments to do so
Also, Congress is beginning to consider provisions to include in the next Farm Bill (due to be passed by 2019).

Several coalitions work to raise the political profile of non-native, tree-killing pests, i.e., the Coalition Against Forest Pests; Sustainable Urban Forestry Coalition; Reduce Risk from Invasive Species Coalition; Continental Dialogue on Non-Native Forest Insects and Diseases. Many of the nation-wide forest-related organizations are members of one or more of these coalitions and I work hard for many of them. They are absolutely essential. . .

However, such “big tent” coalitions are unlikely to press for truly bold solutions, especially if new policies involve serious costs to economic interests or industries that are part of their membership. There is nothing nefarious in this; it is the way coalitions operate. In the case of forests pest issues, though, the absence of more forceful and nimble groups leaves a policy vacuum that no one currently fills.

Furthermore, these coalitions don’t offer an opportunity to concerned individuals and smaller organizations to learn about phytosanitary threats or provide them with opportunities to influence policy.

In the past, I have tried to provide this information through my one-way emails and blog postings. I would like now to upgrade these communications and to provide you with a way to interact with me and others, as well as to form joint positions. The goal is to re-balance the politics of phytosanitary policy – so that our political leaders understand and support both adoption and enforcement of strong, effective phytosanitary measures.

I suggest that we form a new, loose “coalition of the willing” who are ready to speak up and seek ways to stay abreast of developments and opportunities and to coordinate their actions with those of like-minded people. I suggest a loose structure –

I undertake to set up an email network that everyone could use. It would:
- communicate information about pest threats and opportunities to engage;
- communications could be initiated by anyone in the group (either through a “reply all” function or my promise to re-send any email sent to me — with the request that I do so);
- encourage people to work together – with my assistance – to form joint positions;
- provide lists of key contacts for specific issues — perhaps with specific talking points, letter templates, etc., to help in reaching out;
There would be no cost to participants;
Participants could take part anonymously if they wish – either generally or on specific issues;
If there is sufficient interest or need, we could form a steering committee to streamline and help guide the work;
Our goal would be communications that are straight-forward and clear — to each other and to policymakers — while avoiding gratuitous insults or insinuations.

Examples of issues on which I believe a new group could productively engage (and which the “big tent” coalitions likely will avoid) are:

Helping APHIS finalize its proposal to require that wood packaging coming from Canada conform to ISPM#15 standards (see blog posted on 9 August). We need to press the USDA leadership to approve the proposal; then press the Office of Management and Budget to approve it.
Press USDA to take two steps to improve enforcement of ISPM#15:
- End the policy of not fining importers for non-compliant wood packaging until they have five (!) non-compliances within a single year.
- Declare wood packaging to be a high-risk import and thus subject to mandatory inspection by Customs
Press Customs and Border Protection to include wood packaging compliance under its Customs-Trade Partnership Against Terrorism (C-TPAT) program.
Seek agreement on a strategy to encourage importers to shift to packaging made from materials other than solid wood boards. Proposals range from new regulatory requirements to C-TPAT to green certification-type voluntary programs.

I welcome suggestions for other topics we might explore!

Please let me know that you would like to join this coalition. Please feel free to forward this message and to invite others to join in.

[use the “contact” button on the www.cisp.us website]

Faith