Category: forest health

The aim of the TPP is to further expand trade between the U.S. & Canada and other nations bordering the Pacific. (This does not include China, which is not a party to the pact). At same time, completion of a program to widen the Panama Canal means more huge container ships will travel directly to the East coast from Pacific countries. Clearly, rising trade with distant countries – especially those with similar plant genera – raises the risk of pest introductions. Stress federal and state agencies that are already struggling to counter this threat.

The question is whether the TPP agreement itself will exacerbate this threat. Is there language in the agreement that will further hamper adoption and deployment of effective phytosanitary programs?

Fortunately, I think largely not.

The TPP’s section on sanitary and phytosanitary programs – Chapter 7 largely reiterates or clarifies procedures already included in the WTO SPS Agreement and International Plant Protection Convention. TPP provides additional clarity on some points, e.g., transparency & communication.
(Unfortunately, I believe that the SPS Agreement and IPPC already hamper efforts to protect our trees from alien pests – especially those that are not yet known – the infamous “unknown unknowns”. For my analysis see Fading Forests II, available here. A more optimistic analysis of the SPS Agreement as an obstacle to preventing pest introductions is provided by Burgiel et al. 2006, available here.

I am quite pleased to see that the TPP explicitly allows importing countries to consider their level of confidence in the exporting country’s phytosanitary capability when deciding what measures to impose – a very important improvement! This occurs twice:
• Article 7.8: Equivalence

5. In determining the equivalence of a sanitary or phytosanitary measure, an importing Party shall take into account available knowledge, information and relevant experience, as well as the regulatory competence of the exporting Party. [emphasis added]

• Article 7.10: Audits

6. A decision or action taken by the auditing Party as a result of the audit shall be supported by objective evidence and data that can be verified, taking into account the auditing Party’s knowledge of, relevant experience with, and confidence in, the audited Party. This objective evidence and data shall be provided to the audited Party on request. [emphasis added]

I am also pleased that the TPP acknowledges the need to act proactively in the face of a threat. Under Article 7.1, Definitions, the definition of “emergency measure” reads:

“ … a sanitary or phytosanitary measure that is applied by an importing Party to another Party to address an urgent problem of human, animal or plant life or health protection that arises or threatens to arise in the Party applying the measure;” [emphasis added]

The TPP also puts protecting human, animal, or plant life or health first – before facilitating trade – when specifying the agreement’s objectives. See Article 7.2: Objectives, paragraph (a), which reads:
(a) protect human, animal or plant life or health in the territories of the Parties while facilitating and expanding trade by utilising a variety of means to address and seek to resolve sanitary and phytosanitary issues;

The TPP reiterates parties’ rights under the World Trade Organization’s SPS Agreement and IPPC to adopt more stringent regulations as long as they justify such action by both adopting a higher level of protection and conducting a risk assessment appropriate to the circumstances. See especially Article 7.9, paragraph 2:
2. Each Party shall ensure that its sanitary and phytosanitary measures either conform to the relevant international standards, guidelines or recommendations or, if its sanitary and phytosanitary measures do not conform to international standards, guidelines or recommendations, that they are based on documented and objective scientific evidence that is rationally related to the measures, while recognising the Parties’ obligations regarding assessment of risk under Article 5 of the SPS Agreement.

I do worry some about Article 7.11, Import Checks, paragraph 8, which states:

8. An importing Party that prohibits or restricts the importation of a good of another Party on the basis of an adverse result of an import check shall provide an opportunity for a review of the decision and consider any relevant info submitted to assist in the review. The review request and info should be submitted to the importing Party within a reasonable period of time.

How does this requirement apply to the U.S. policy of rejecting shipments in wood packaging that does not comply with ISPM#15? (For discussions of the role of wood packaging as a pathway for introduction of highly damaging pests, review my blogs posted on July 15, August 31, September 11, and October 30.) The U.S. does not currently consult with exporting country before denying entry to individual shipments. Nor do we want the U.S. to be required to do so!

Finally, Article 7.17: Cooperative Technical Consultations, paragraph 5 requires countries to involve “relevant trade and regulatory agencies” but says nothing about including other stakeholders, such as cities or homeowners whose trees are at risk to introduced pests.

Posted by Faith Campbell

It is important that officials responsible for phytosanitary protection, Congressional oversight committees, and stakeholders have access to key trade and pest data as well as independent analyses of them in order to evaluate programs’ effectiveness.

But we don’t have such access … and existing analyses cannot be used to detect trends.

My focus is on tree-killing insects and diseases, but these constitute a small fraction of the total number of all plant pests that have become established in North America since Jamestown was settled. According to Aukema et al. (2010), approximately 450 non-native insects have colonized forest and urban trees. This is about 17% (less than one-fifth) of the total of 3,540 non-native insects established in North America according to Yamanaka et al. (2015). The larger number includes ones apparently causing negligible harm, along with a significant proportion of insects and diseases affecting row crops.
What could we learn from comparisons of data on introduced tree-related vs. overall plant pests? Could we uncover new pathways? Identify more effective approaches to phytosanitary protection?
Unfortunately, neither published studies nor USDA/APHIS’ data allow comparisons and tracking of trends in pest establishment.

For example, a study by Work et al. (2005) estimated that during the late 1990s, approximately 10 new phytophagous insects were established each year. The authors considered all phytophagous insect pests, not just tree-killing pests; but they did not include pathogens or insects that feed on dead wood (e.g., termites).

The Work team’s number is about four times larger than the estimated rate of establishment provided by Aukema et al. (2010), which estimated that approximately 2.5 new tree-killing insects and pathogens became established each year from 1860 to 2006. The Aukema study did not attempt to track establishments of all pests that use arboreal hosts. On the other hand, it did include pathogens. So the two studies’ findings are not truly comparable.

In its 2009 Implementation Plan for Section 10201 of the Food, Conservation and Energy Act of 2008, APHIS reported that between 2001 and summer 2008, 212 plant pests had been reported as new to the United States – an average of 30 new pest establishments detected each year. This estimate does include pathogens … but not insects that do not feed on living plants. So it is not comparable to the Yamanaka study. Still, the APHIS figure is 12 times higher than the Aukema et al. estimate for tree-killing pests.

I am unaware of a publicly available estimate for more up-to-date establishment rates.

An internal USDA APHIS database was made available to me. It lists about 90 new species of plant pests (of all types, ranging from insects to nematodes to fungal pathogens) with populations that were detected in the U.S. during the four-year period 2009 – 2013. The rate of detection of “new” species established during this four-year period was approximately 22 per year. This establishment rate is higher than the estimate of approximately 10 new phytophagous insects per year during the late 1990s put forward by Work et al. — not surprising since taxa other than insects are included. However, this estimate is lower than the 30 new pest introductions each year estimated by USDA APHIS for 2001-2008.

So what is the current rate? How has the establishment rate been affected by changing volumes of imports over this 20-year period (imports rose until 2008, then fell because of the Great Recession)? How has the reported number of new establishments been affected by changes in monitoring program criteria and funding levels?
Do the databases include sufficient information about dates of probable establishment, likely pathways of introduction, etc., to allow a more complete analysis of at least the new insect species?
I have not seen the database compiled by Yamanaka’s team so I don’t know.

The USDA database from 2009-2013 does not specify the probable pathways by which these pests entered the United States. I have concluded that the viruses, fungi, aphids and scales, whiteflies, and mites were probably introduced via imports of plants, cuttings, or cut foliage or flowers. These pests number 37 – or 41% of the total.

The database on tree-killing insects and pathogens compiled by the Aukema team includes both date of probable introduction and likely pathway; and articles by this team discuss trends in introduction rates. Thus, Liebhold et al. 2012 reports that approximately 69% of the pests in the database were introduced via the trade in live plants. This figure is one-third higher than the proportion I calculated from the USDA database (which, I remind you, includes all plant pests, not only those that attack trees).

Many of the pests associated with imports of plants in the Liebhold study were introduced decades ago, before the U.S. adopted phytosanitary regulations. Does the difference in the proportion of pests associated with plant imports in the 2009-2013 period compared to the earlier period covered by Liebhold et al. reflect a reduced risk from this pathway as the result of tighter regulations and shifts in the market? I doubt anyone can say – beyond the acknowledged increase in wood-borers associated with wood packaging.

Without better, and more readily available, data, we won’t ever be able to answer key questions. It is urgent that APHIS make available its data on trade volumes, pest interceptions, newly established pests, etc., for analysis by academics, other agencies, and stakeholders. And certainly it would be helpful if both APHIS and other researchers used more consistent approaches so to make possible longitudinal studies that can disclose trends.

Sources:

Aukema, J.E., D.G. McCullough, B. Von Holle, A.M. Liebhold, K. Britton, & S.J. Frankel. 2010. Historical Accumulation of Nonindigenous Forest Pests in the Continental United States. Bioscience. December 2010 / Vol. 60 No. 11

Liebhold, A.M., E.G. Brockerhoff, L.J. Garrett, J.L. Parke, and K.O. Britton. 2012. Live Plant Imports: the Major Pathway for Forest Insect and Pathogen Invasions of the US. www.frontiersinecology.org

Work, T.T.; McCullough, D.G.; Cavey, J.F.; Komsa, R. 2005. Arrival rate of nonindigenous species into the United States through foreign trade. Biological Invasions7: 323-3

Yamanaka, T., N. Morimoto, G.M. Nishida, K. Kiritani, S. Moriya, A.M. Liebhold. 2015. Comparison of insect invasions in NoAm, JP and their Islands Biol Invasions DOI 10.1007/s10530-015-0935-y
Posted by Faith Campbell

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

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

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

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