Center for Invasive Species Prevention

Wood Packaging – Customs Efforts & Recent Detections

As noted in my blog of July 15, damaging pests continue to enter the country in wood packaging. The most comprehensive study indicates that tree-killing pests are found in an estimated 13,000 containers entering the country each year – or 35 per day.
These pests are present despite requirements adopted 9 or more years ago that wood packaging be treated.

Types of cargo packaged in wood are inspected by agricultural specialists within the Bureau of Customs and Border Protection , a division of the Department of Homeland Security. CBP agricultural specialists work at 167 sea, air and land ports of entry. See an article about CBP efforts to curb introductions of tree-killing pests posted at http://www.cbp.gov/frontline/2014/12/frontline-december-forest-prime-evil.

CBP agriculture specialists in Laredo, Texas, examine a wooden pallet for signs of insect infestation. [Note presence of an apparent ISPM stamp on the side of the pallet] Photo by Rick Pauza

According to the CBP in the above article, the types of commodities imported that have the highest rates of SWPM-related pest interceptions are metal and stone products (including tile), machinery (such as automobile parts and farm equipment), electronics, bulk food shipments and finished wood articles.
These imports have a long-standing record of pest presence – as described in Chapter 4 of my lengthy report on tree-killing pests.

According to the CBP , 48% of the wood packaging entering the country that does not comply with the treatment requirements comes from Mexico. Mexican maquiladoras are factories that import material and equipment duty-free, then assemble a wide range of products – auto parts, apparel, electronics, furniture, and appliances. Mexico’s 3,000 maquiladoras account for half of Mexico’s exports.
China has the second worst record.
Of course, we import lots of stuff from both countries! However, the China situation is particularly disturbing because the U.S. has required that wood packaging from China be treated since the beginning of 1999 – 16 years!
The ports receiving highest numbers of shipments with non-compliant wood packaging materials have consistently been those along the U.S.-Mexico border, especially in Texas: Laredo, Pharr, more recently Brownsville & Houston. Other ports receiving high volumes of non-compliant wood packaging include Blaine, Washington; Long Beach, California; and Romulus, Michigan.

USDA APHIS and CBP have cooperated in a program under which insect larvae found in wood packaging are identified as to species. In recent years, they have studied larvae detected in wood packaging from eight ports – Long Beach, Seattle; 2 ports in Florida; and three cities on the Texas-Mexico border. (Remember, there are 167 ports of entry across the country, so this sample represented 5% of all ports.) Found at these ports were an unreported total of insects, including 116 individuals in the same family as Asian longhorned beetle (Cerambycids). Forty-three were from China (including 5 ALB), 20 from Russia, and seven from Mexico (Philip Berger, APHIS, at the annual meeting of the Continental Dialogue on Non-Native Forest Insects and Diseases, November 2014)

Most familiar – and frightening! – examples of pests introduced via wood packaging include Asian longhorned beetle, emerald ash borer, redbay ambrosia beetle and its accompanying fungus, and possibly polyphagous shot hole borer and its accompanying fungus – all described here.

The prospect of receiving additional insects from Asia scares everyone. What if a new pest is as bad as the four we already have? The emerald ash borer has already caused the removal of an estimated 50 million trees and continues to spread to ash trees – and now white fringe trees – throughout America east of the Great Plains. Laurel wilt disease (transmitted by the redbay ambrosia beetle) is rapidly eradicating redbay trees in the southeast, including in Everglades National Park – one of the icons of the American conservation movement. The Asian longhorned beetle has already caused removal of more than 124,000 trees from our cities, suburbs, and nearby woodlands – at a cost to federal taxpayers of more than $500 million. If it escapes eradication programs, it threatens trees in 10% of America’s forests. The polyphagous shot hole borer threatens numerous tree species that, collectively, make up more than half the trees planted in urbanareas in Southern California.

While no one denies the threat from insects native to Asia, we should not be complacent about insects from Mexico. Although we are neighbors, our forests are separated by deserts – allowing insects to evolve there to which our trees are vulnerable. Three wood-boring beetles native to Mexico and possibly some U.S. border states are already causing havoc to U.S. trees – goldspotted oak borer, soapberry borer, and walnut twig beetle and its accompanying fungus (all described here). The first two were introduced to vulnerable forests through movement of firewood, not wood packaging. The third – the walnut twig beetle – might be native to California, although thousand cankers disease is killing native California walnuts throughout the state so something is different than it used to be.

goldspotted oak borer

When Customs officials detect wood packaging that does not comply with ISPM #15 (“noncompliance” means one of three things: the wood does not bear the ISPM #15 stamp; or the stamp appears to be fraudulent; or signs of pests are detected), that wood must be re-exported immediately, usually with the associated commodity. If any insects present pose an immediate risk of introduction, e.g., if adults are emerging, the shipment might need to be fumigated before re-export.
Re-exported shipments – and any treatments – cause importers to lose income and face costly delays. Still, the continuing presence of non-compliant wood packaging indicates that these inconveniences are insufficient to prompt importers to take all precautions possible to ensure that packaging used by their suppliers and brokers comply with the requirements.

Why don’t importers use alternative packaging made from plastic, steel, or composites that would not harbor tree-killing insects? Plastic pallets also weigh much less than wooden ones, so transport costs are reduced. Customs has pointed out the advantages. … Still, packaging material made from wood is comparatively plentiful, cheap, easy to repair, biodegradable. So it continues to dominate the market.
What steps can be taken by the U.S. government and importers to minimize the presence of insects in packaging?
• U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with the regulations.
• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .
• USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.
• The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)
• Importer’ contracts with suppliers routinely specify penalties for delivery delays; the contracts should be amended to add penalties for noncompliant wood packaging.
• A decade ago, USDA APHIS funded research which developed an ingenious method for detecting mobile pests inside a container. It was an LED light attached to a sticky trap. Placed inside a container, the light attracted snails, insects and possibly other living organisms. The whole mechanism was attached to a mailing container that could be pre-addressed for sending to a lab that could identify the pests. Why was this tool never implemented?

Posted by Faith Campbell

Wood-borers in Wood Packaging: How Did We Get to This Crisis?

shipping container being unloaded at Long Beach

The rising numbers of tree-killing wood-boring insects introduced to the U.S. (see blogs from July 15 and August 3 & fact sheet and sources linked there) are a result of ballooning of trade volumes and use of wood packaging.

This irruption of trade was made possible by adoption of the shipping container to transport a wide range of goods.Moving from place to place are not just finished products but also components that originated in one country and that are to be assembled in another country.

How the shipping container revolutionized trade and manufacturing is detailed by Marc Levinson in his book, The Box: How the Shipping Container Made the World Smaller and the World Economy Bigger (Princeton University Press 2008). The transformation affected not only trade between countries, but also within countries, with some regional economies growing while others faltered.

Dr. Levinson recognizes that he has not addressed environmental damage caused by massive movement of cargo. While Dr. Levinson does not explain which damage he is thinking about, I doubt that he includes introductions of non-native wood-boring pests.

(I don’t know enough about the ballast water pathway to understand the impact of containerized shipping on introductions of aquatic invaders, but it seems likely to be an important factor through three factors: directing trade to new port areas; the ships’ huge size; and taking on of ballast water for those segments of a voyage carrying fewer filled cargo containers. On the other hand, Dr. Levinson says that a balance of cargo moving both ways on a trade route is an important factor in determining which ports thrive.)

Before containers, port costs represented the highest proportion of transport costs. Those costs are no longer an important consideration in determining manufacturing and transport choices. Nor is distance as important as before. What is most important are ports that can move large volumes of goods efficiently. The manufacturer or retailer at the top of the chain finds the most economical place for each step in the manufacturing and assembly process without regard to its location.

The containerization revolution was rapid. Containers were first used in international trade in 1966; within three years, nearly one-third of Japanese exports to the U.S. were containerized, half of those to Australia. In the decade after containers were first used in international trade, the volume of international trade in manufactured goods grew more than twice as fast as the volume of global manufacturing production, 2.5 times as fast as global economic output. Large numbers of specialized container ships were built, at ever-increasing sizes. The largest container ship in 1969 could carry 1,210 20-ft containers. By the early 2000s, ships being built to carry 10,000 20-foot containers; or 5,000 40-foot containers.

When Dr. Levinson wrote his book in 2005, the equivalent of 300 million 20-foot containers were crossing the world’s oceans each year.

The container revolution interacted with “just-in-time” manufacturing, which required rapid and reliable transport. Large companies signed written contracts with suppliers and shippers which included penalties for delays.

In the U.S., Long Beach quickly became the principal port because it (as well as Oakland and Seattle) had excellent rail connections to the interior. By 1987, one-third of containers from Asia destined for the East Coast landed at Long Beach and crossed the U.S. by rail. Perhaps counter to our expectation, only one-third of containers entering southern California in 1998 contained consumer goods. Most of the rest contained intermediate or partially processed goods as part of the new international supply and manufacturing chain.

Containers at Long Beach

On the East coast, Charleston SC and Savannah similarly grew because of transport connections – this time, primarily highways.

So, global trade is huge and growing; and the shipping container moves immense quantities of goods from one ecosystem to another and provide shelter for a vast range of hitchhiking living organisms (in addition to insects in the wood, there can be other insects’ eggs attached to the sides of the container, snails, weed seeds, even vertebrates – a raccoon once staggered out of a shipping container that had crossed the Atlantic from the U.S. to France!).

We need to imagine, test, and apply a variety of tools to suppress the numbers of living organisms traveling in shipping containers.

For example,
• if importer-supplier contracts specify penalties for delivery delays, we should ask why don’t importers amend the contracts to add penalties for non-compliant wood packaging?
• Might the Bureau of Customs and Border Protection incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program.
• A decade ago, USDA APHIS funded research which developed an ingenious method for detecting mobile pests inside a container. It was an LED light attached to a sticky trap. Placed inside a container, the light attracted snails, insects and possibly other living organisms. The whole mechanism was attached to a mailing container that could be pre-addressed for sending to a lab that could identify the pests. Why was this tool never implemented?

We can’t stop the trade, but we can be much more aggressive in adopting measures to minimize pest introductions.

Posted by Faith Campbell

Non-Native Pest Threat to Forests of the West Coast

As we Americans import more stuff, the risk of new pest introductions rises, too. Many tree-killing insects arrive as larvae living in crates, pallets, and other forms of wood packaging. While the USDA requires that incoming wood packaging be treated to prevent pests, this regulation has not prevented pests from entering the country on wood packaging.

piece of wood packaging with Cerambycid larva; detected in Oregon

A study has found that perhaps 35 shipping containers harboring tree-killing pests reach our ports each day (Haack et al. 2014). At this rate, in just 35 years, America might suffer invasion by more than 100 new wood-boring species. This would result in a tripling of borers introduced to U.S. (Leung et al. 2014).

Already, wood-boring beetles have been among the most damaging tree-killing pests introduced to the U.S. Our environment certainly doesn’t need invasions by three times as many new wood-borers!

West-coast ports receive lots of incoming shipping containers. Long Beach alone receives about half of the nearly 25 million shipping containers arriving at the U.S. each year. So it is alarming that high-risk insects, including the Asian longhorned beetle (ALB), continue to be found in wood packaging (Berger 2014).

Imported goods that are heavy are more likely to be packaged in wood and that thus pose the greatest pest risk. The highest risk commodities are
• machinery (including electronics) and metals;
• tile and decorative stone (such as marble or granite counter tops) (Harriger 2014).
The west coast ports of Seattle, Los Angeles/Long Beach, and San Francisco all rank in the top 15 out of 3,500 (1/2 of 1%) cities nation-wide for imports of tile and decorative stone, machinery and metals (Colunga-Garcia et al. 2009).

Not only do west coast cities import high volumes of risky goods; a significant proportion of the trees growing in those cities are vulnerable to these pests. Seattle’s three to four million trees belong to more than 300 species – although a mere seven genera constitute two-thirds of the trees (Ciecko et al. 2012). It has been estimated that just four non-native pests (ALB, gypsy moth, emerald ash borer, and “Dutch” elm disease) could cause $3.5 billion in damages. The ALB alone threatens 39.5% of all trees lining the city’s streets (City of Seattle 2013).

San Francisco has an estimated 669,000 trees; 12% are at risk to the ALB (Nowak et al. 2007). Apparently no one has yet estimated the numbers of trees at risk to sudden oak death (SOD), goldspotted oak borer (GSOB), or polypagous shot hole borer (PSHB).

It is essential that USDA APHIS act more aggressively to prevent additional introductions of pests via wood packaging. (For a longer discussion of the wood packaging pathway, visit my previous blog posted on July 15th). In brief:
• APHIS & the Bureau of Customs and Border protection should penalize all importers whose wood packaging does not comply with decade-old regulatory requirements.
• The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program
• APHIS should re-consider the advantages of requiring importers to switch to packaging made from materials other than wooden boards.
• The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the international standard’s treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)

SOURCES
Berger, P. Executive Director, PPQ Science and Technology, Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014

Ciecko, L., K. Tenneson, J. Dilley, K. Wolf. 2012. Seattle’s Forest Ecosystem Values: Analysis of the Structure, Function, and Economic Benefits; August 2012; GREEN CITIES RESEARCH ALLIANCE; City of Seattle Urban Forest Stewardship Plan 2013.

City of Seattle Urban Forest Stewardship Plan 2013.

Colunga-Garcia, M., R.A. Haack, and A.O. Adelaja. 2009. Freight Transportation and the Potential for Invasions of Exotic Insects in Urban and Periurban Forests of the US. J. Econ. Entomol. 102(1): 237-246 (2009); and raw data for the study provided by the authors.

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

Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (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(5): e96611. doi:10.1371/journal.pone.0096611

Harriger, K. 2014. Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014

Leung, B., M.R. Springborn, J.A. Turner, E.G. Brockerhoff. 2014. Pathway-level risk analysis: the net present value of an invasive species policy in the US. The Ecological Society of America. Frontiers of Ecology.org

Nowak, D.J., R.E. Hoehn III, D.E. Crane, J.C. Stevens, J. T. Walton. 2007. Assessing Urban Forest Effects and Values: San Francisco’s Urban Forest. USDA Forest Service. Northern Research Station. Resource Bulletin NRS-8.

posted by F.T. Campbell

Alarming Genetic Variability Appears in SOD in Oregon & – as of 2020 – in California

Oregon authorities have announced that a dying tanoak detected by an aerial survey in the quarantine zone in Curry County, Oregon has proved to be in the EU1 clonal lineage. This is the first report of the EU1 lineage in North American forests. All other isolates of the causative pathogen Phytophthora ramorum in North American forests are the NA1 lineage. [See below for a discussion of P. ramorum clonal lineages.]

Dying tanoak (in California). Photo by F.T. Campbell
The infected tree is near a small private nursery that had been reported infested with the EU1 lineage of P. ramorum in 2012. The nursery carried out the APHIS-mandated Confirmed Nursery Protocol, then closed. Genetic testing suggests this nursery is the probable source population for the EU1infestation of the tree.This incident conveys several lessons:

Discovery of the EU1 lineage of P. ramorum in the forest appears to confirm that nursery infestations can infect plants in the forest.
The importance of genetic testing of samples from every infestation to determine which clonal lineage is present.

The discovery has troubling implications: The EU1 lineage consistently is a more aggressive pathogen than the NA1 clonal lineage already present in forests in California and Oregon. The EU1 lineage kills several types of conifer trees in Europe, including western hemlock (Tsuga heterophylla).
Furthermore, the EU1 lineage is of the opposite mating type as NA1, creating at least a small potential for sexual reproduction and increased variability in the pathogen population. (Sexual reproduction in P. ramorum can only occur when opposite mating types meet; in the absence if opposite mating types, all reproduction is clonal.)
The Oregon Department of Forestry is attempting to eradicate this small infestation. Host plants on the infested site have been cut and piled and will be burned as soon as wildfire risk abates. (Burning of other, lower priority sites has been delayed by inadequate funding). Authorities will also continue intensive surveys and will monitor soil and vegetation before and after treatment. Some funding for this work will come from the USDA Forest Service Forest Health Protection program and USDA-APHIS.

LINEAGES:
The Phytophthora ramorum pathogen is known to have four separate genetic lineages. The NA1lineage is the form of the pathogen established in forests of California and Oregon. This lineage is also the most common lineage in U.S. nurseries. However, two other genetic lineages are also found in U.S. nurseries: NA2 and EU1 (Coats and Chastagener 2009; Mascheretti et al. 2009). Indeed, NA2 was the most common lineage in Canadian nurseries (Goss et al. 2011).
The EU1 strain is widespread in European nurseries and in tree plantations and wild heathlands of southwest England, Wales, parts of Scotland, and Ireland. In 2012, a new, fourth strain was detected in Northern Ireland and a small area in southwest Scotland. This strain is called EU2.This strain is attacking larch, beech, fir, and hemlock trees at these sites (California Oak Mortality newsletter 2015).

Most EU1 and all EU2 type isolates belong to the A1 mating type, whereas the two North American strains belong primarily to the A2 mating type (Hansen et al. 2003). While P. ramorum apparently reproduces sexually only rarely, the presence of both mating types – in nurseries and especially in forests – does increase the possibility that sexual reproduction will occur. Sexual reproduction would allow the pathogen to evolve and perhaps become more aggressive.

NEW SITUATION:

The EU1 strain was detected in forest trees in Del Norte County, California in autumn 2020. This detection was both the first officially confirmed detection of P. ramorum in Del Norte County and the first detection of the EU1 strain in forest trees in California. The source is unclear. The nearest infestation is 12 miles away in Curry County, Oregon; those trees are infected with the NA1 strain. The nearest known EU1 infestation is about 35 miles away. The site of the California EU1 infestation has minimal California bay laurel (Umbellularia californica). This detection has led to designation of Del Norte County as officially infested; it becomes the 16^th California county so designated. [Information from the California Oak Mortality Task Force newsletter for December 2020, available here.]

SOURCES

California Oak Mortality Task Force newsletter [http://www.suddenoakdeath.org/news-and-events/newsletter-archive/ ] April 2015.

Coats, K. and G. Chastagener. 2009. Understanding the mechanisms behind detections of Phytophthora ramorum in Washington State nurseries and streams utilizing microsatellite genotype information. Fourth Sudden Oak Death Science Symposium, June 15-18, Santa Cruz, CA.

Goss, E.M., M. Larsen, A. Vercauteren, S. Werres, K. Heungens, and N.J. Grünwald. 2011. Phytophthora ramorum in Canada: Evidence for Migration Within North America and from Europe. Phytopathology. January 2011, Volume 101, Number 1. Pages 166-171

Hansen, E.M., P.W. Reeser, W. Sutton, L.M. Winton, and N. Osterbauer. 2003. First Report of A1 Mating Type of Phytophthora ramorum in North America. Plant Disease, October 2003, Volume 87, Number 10. Page 1267.

Mascheretti, S., P.J.P. Croucher, M. Kozanitas, L. Baker, M. Garbelotto.2009.Genetic epidemiology of the Sudden Oak Death pathogen Phytophthora ramorum in Calif.Molecular Ecology 18: 4577-4590.

Posted by Faith T. Campbell

National Parks Failing to Protect Forests

Americans love their National parks and expect the National Park Service to ensure the parks’ natural resources are protected “unimpaired for future generations” – as is required by the Service’ founding law.
Despite these expectations, the National Park Service does not take obvious actions to protect trees in the parks from non-native tree-killing insects and plant diseases.

Horton House plantation ruins, Jekyll Island, GA. (Photo by F.T. Campbell) The two large redbay trees shading the house are now gone, killed by laurel wilt. Use your favorite web browser to see how stark the house is now, denuded of its trees.

At historic sites ranging from Horton House plantation on Jekyll Island, Georgia to the Presidio in San Francisco, trees that create atmosphere & maintain visible links to the past have died.

Even more important is the damage occurring to forests in the “crown jewel” wilderness parks:
• Whitebark pines at high elevations of Yellowstone, Glacier, and Crater Lake National parks have been killed by white pine blister rust (see photo below, of dead whitebark pine at Crater Lake). Photo by F.T. Campbell

• The forests of Great Smoky Mountains and Shenandoah National parks, already damaged by chestnut blight, hemlock woolly adelgid, beech bark disease, and gypsy moth, are now losing their ash trees to the emerald ash borer and their walnut trees to thousand cankers disease.
• Everglades National Park and Big Cypress National Preserve are losing their swamp bay trees to laurel wilt
• Tanoak trees in Muir Woods, Redwood National Park, and Pt. Reyes National Seashore have been killed by sudden oak death
• Ash trees in Sleeping Bear Dunes National Lakeshore in Michigan have been killed by the emerald ash borer.

Forests in other “crown jewel” parks are not yet under attack, but are threatened by nearby pests:
• The black oak trees of Yosemite National Park’s signature Valley are at risk to goldspotted oak borer, which has killed more than 100,000 trees in San Diego county.
The threat is obvious … yet the National Park Service dropped efforts to develop a strategy for addressing it. And the NPS has not adopted a national policy requiring campers to obtain their firewood either in the Park or from nearby vendors.

As explained on the Don’t Move Firewood website, firewood is a highly dangerous commodity, since it can transport tree-killing pests to new, vulnerable areas [see also the report Fading Forests III. Some National parks – including Great Smoky Mountains and Shenandoah – have adopted regulations prohibiting visitors from bringing firewood from long distances. However, other parks – including Yosemite – only ask visitors to avoid bringing firewood. In all cases, the firewood regulation or appeal is buried deep within the park’s website. On a more positive note, campers who reserve a campground on such federal websites as www.reserve.gov receive warnings about firewood when they finalize their reservation.

The National Park Service has developed a Manual providing guidance to park managers that describes the threat from firewood and laws and regulations that relate to natural resource protection. However, the Service has left the decision whether to take action to the individual parks’ superintendents.

I think that such a passive stance betrays the Service’ statutory obligation, as laid out in the Organic Act of 1916: the purpose of the National Park Service is
“to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” [emphasis added]

Next year, the National Park Service celebrates its Centenary. I think it should celebrate this anniversary by adopting regulations requiring visitors to obtain firewood locally and finalizing a strategy for combating tree-killing pests.

SOD in the East

At present, sudden oak death (SOD) is killing trees and shrubs in forests along the Pacific coast from far southern Oregon to Monterey County in California – a stretch of more than 400 miles.

However, numerous tree and shrub species native to forests in the East also are vulnerable to the pathogen. These include several oak trees (northern red, chestnut, white, and pin oaks), sugar maple, black walnut; and such shrubs as mountain laurel and rhododendrons.

While no infestations of SOD have been found in the wild in the East, the pathogen is already present in some nurseries and continues to be transported to disease-free parts of the Southeast in shipments of nursery plants – as described in my previous blog.

Nine eastern states monitor streams to detect the pathogen in water. These states are AL, FL, GA, MS, NC, NY, PA, SC, & TX. As of 2013, six states had detected the pathogen in a total of 11 streams and ponds; all were outside nurseries that had previously had infested plants. These positive streams were distributed as follows: AL-4; FL-1; GA-2; MS-1; NC-1; TX-2.

In 2014, only four states (instead of six) detected the SOD pathogen in at least one stream: AL-4; FL-1; MS-2; and NC-2. Two of these streams were new – one each in AL and FL.

One of the AL detections is in a stream associated with a nursery that had not previously been determined to have infested plants. Authorities plans to sample vegetation near this stream. In the past, once a stream had tested positive, it remained positive in all subsequent years. However, the testing methods are not perfect so some variation in findings can be expected.

Infested plants were found growing in the ground (outside a nursery) at three sites: one each at homes in CT and MA; and a commercial business site in LA. These searches were undertaken because officials knew that these residents or businesses had bought plants from an infested nursery in earlier years.

As noted in my previous blog, SOD has been detected in eight nurseries in the East: ME-1, NY-2, TX-1, VA-4). The TX nursery became infested by plants received from a California nursery. I am very concerned about the presence of the pathogen in four Virginia nurseries, because the Commonwealth falls in the geographic region thought to be most vulnerable to the pathogen [see risk maps in the SOD writeup at http://www.dontmovefirewood.org/gallery-of-pests or in Chapter 5 of Fading Forests III.

Is the Government Preventing Movement of Sudden Oak Death (SOD) to Vulnerable Areas in the East?

Are the Rules Working?

APHIS adopted a new approach to regulating interstate trade in SOD hosts in early 2014. One year later, spring 2015, it is too soon to provide a thorough evaluation of whether this approach is effective in ending the risk that the disease will be moved to new areas on nursery plants. But some problems have already shown up, suggesting that the approach has serious weaknesses and will not succeed as intended.

1) APHIS’s new program is unlikely to find either new or cryptic infestations quickly.

When APHIS put its program into force in March 2014, 23 nurseries in California, Oregon, and Washington that had tested positive for the pathogen in the previous three years signed up to participate in the program – thus complying with the requirements for continuing to ship SOD host plants interstate. By the end of 2014, three of those nurseries had dropped out – so they can now ship plants only to retailers/purchasers within their states. A fourth nursery was expelled from the program because of its continuing inability to eradicate the pathogen from its premises. This nursery is no longer allowed to ship SOD hosts out of state.

At the same time, two additional nurseries joined the program. So as of the end of 2014, 21 nurseries were participating. Seven participating nurseries are in California; all have tested free of the pathogen in spring 2015. Ten participating nurseries are in Oregon; four of these nurseries tested positive for the pathogen in spring 2015.

Many more nurseries in the three states that had been tested for the pathogen over the past three years and found not to be infested are now allowed to ship plants interstate without being subject to the new APHIS requirements. (For example, in 2013 California tested plants in 1,575 nurseries; only one positive nursery was found.) The issue now is whether these nurseries are truly clean of the pathogen, and will remain so. Since the SOD pathogen was extremely difficult to detect in plants (the system relied upon before 2014), I am concerned that nurseries that tested “clean” before 2014 might have harbored a cryptic infestation that escaped detection.

Such cryptic pre-existing infestations – and any new infestation that establishes in a nursery not currently subject to the regulation due to a previous infestation – will probably escape detection for months because, under the current APHIS program, the presence of SOD in these nurseries will be detected only under one of the following conditions:

The nursery owner reports symptoms of infestation;
The state detects symptomatic plants during a routine state inspection; or
The nursery is identified as the source of infested plants purchased by someone (this is called a trace-back investigation).

Some nurseries that had been shipping SOD host plants interstate under the previous APHIS regulations chose to stop shipping host plants interstate and so did not agree to abide by the new requirements. I know that five Oregon nurseries opted out; APHIS has not told me how many nurseries in California and Washington also opted out.

picture of infested rhododendron plant;

courtesy of Jennifer Parke, Oregon State University

The risk that nursery plants will spread SOD continues.

How large is this risk? One measure is how many nurseries are infested with the disease – either through a new introduction or as a result of an earlier infestation that was not detected.

During 2014, state inspectors detected the SOD pathogen in 19 nurseries – almost the same number as in 2013, and slightly more than half the number in 2012. (For a discussion of the SOD pathogen in nurseries in recent years, read Chapter V in Fading Forests III. Eleven of these nurseries were in the three west-coast states that have been regulated most tightly in the past (CA-1, OR-8, WA-2); eight nurseries were in other parts of the country (ME-1, NY-2, TX-1, and VA-4).

Fourteen of the 19 nurseries had tested positive for the pathogen during the previous three years. Consequently, they had been subject to the new regulation from its implementation.

However, two nurseries had tested positive before 2011, but not during the key 2011-2013 period. Under the terms of the 2014 regulation, these nurseries were not subject to APHIS’s new regulation and they continued to ship plants. This raises concerns about whether infestations in some nurseries might not be detected under the new regime before they ship plants to disease-free areas.

Eight of the 19 infested nurseries were interstate shippers (CA-1; OR-4; WA-1; TX-1; VA-1). Six had shipped plants in the previous six months.

Five of these infested interstate shippers stayed in the new APHIS program, carried out Critical Control Point Assessments, and adopted specific mitigation actions that were approved by APHIS and state officials. They continue to ship SOD host plants interstate.

Four of the eight infested nurseries left the program, either voluntarily or by compulsion. Nurseries not in the APHIS program may now ship SOD host plants only to destinations within their states; they are subject to regulation by their state agencies (usually, departments of agriculture).

Eleven of the nurseries detected to be infested by the SOD pathogen in 2014 shipped only to retailers within their own states; these nurseries are regulated by the appropriate state rather than by APHIS.

Strengths and Weaknesses of the New Regime

So, what do I see as the strengths of the new regulatory regime? Most important, inspectors test the soil, water, and pots, not just symptomatic plants. This approach, recommended by scientists for years before APHIS adopted it, is paying off: inspections detected the pathogen twice in potting media, six times in a nursery’s soil, and 15 times in water on nursery premises.

The greatest weakness is the three-year cutoff for including nurseries in the APHIS program; as demonstrated already, nurseries can be clean for three years and then again be found to be infested. It has always been difficult to determine whether these “repeat” nurseries were infested all along, but somehow escaped detection; or have become infested through a new introduction of the pathogen.

Questions also arise because of the reliance on state regulation of nurseries shipping only within the state. Some state agencies appear to be much more aggressive than others in searching for symptoms of infestation and requiring cleanup.

Another possible problem is that the regulatory inspection effort focuses on five genera — Camellia, Kalmia, Pieris, Rhododendron, and Viburnum — but plants in other genera are also hosts. During 2014, detections were made on the following genera that are not among the “high-risk” hosts — Gaultheria, Prunus, Syringa and Vaccinium; and seven new host species were detected in the forest or in nurseries. One of these apparently new hosts, Vinca, is a widely planted ground cover (“periwinkle”) shipped in flats of often sad-looking rooted cuttings.

One good sign is that the nursery trade and state agricultural agencies are seeking ways to decrease the movement of plant pests via the nursery trade. Examples of such pest movement are not limited to SOD or other tree-killing pests; for example, boxwood blight was first detected in the United States in 2011; by 2013 it was known to be in nine eastern states and Oregon.

The nursery trade (through their trade associations, AmericanHort and the Society of American Florists), state agencies, and APHIS have developed a voluntary program called Systems Approach to Nursery Certification, or SANC. The collaborating organizations devoted several years to developing an agreed-upon set of standards and procedures aimed at making their facilities as free of disease and pests as possible. Now they are testing whether the program works in practice. Eight plant growers from across the country – and the appropriate state agencies – have agreed to:

Assess the facility for situations and practices that create a risk of pest infestation;
Identify best management practices that will mitigate those risks; and
Develop new facility-management manuals that apply those practices.

The SANC managers expect the pilot program to take 3 years (2018).

The principal sources for the information in this blog are the monthly newsletters prepared by the California Oak Mortality Task Force (COMTF), found at http://www.suddenoakdeath.org/ and the USDA APHIS program updates found at http://www.aphis.usda.gov/wps/portal/aphis/ourfocus/planthealth/sa_domestic_pests_and_diseases/sa_pests_and_diseases/sa_plant_disease/sa_pram/ct_phytophthora_ramorum_sudden_oak_death/

Funding Shortfalls Threaten Our Trees – & Are Becoming Worse

Experts have recognized for two decades that funding of federal programs intended to prevent or respond to introductions of invasive species is inadequate. As regards tree-killing insects and pathogens, there have been spikes in the past, spurred by, first, detection of Asian longhorned beetle and emerald ash borer, then by federal spending increases to support recovery from the Great Recession.

But with renewed pressure to reduce the federal budget, programs operated by APHIS and the USDA Forest Service have suffered significant cuts in spending. For a history of these cuts, read Chapter 3 in Fading Forests III .

Funding for key programs continue. Most alarming is that these cuts are suggested by the Administration! in its annual budget sent to Congress. I don’t know whether the cuts are suggested by the agencies, or instead are imposed by higher-ups in the Department of Agriculture or at the President’s Office of Management and Budget.

Certainly there is competition for the available funds. APHIS is funded by the Agriculture Appropriations bill, which also funds agriculture programs that enjoy strong lobbying support as well as food stamps. The Forest Service is being squeezed by the ever-higher costs of managing wildfires.

Still, these cuts threaten to expose our wildland, rural, and urban forests to permanent destruction by non-native, tree-killing insects and pathogens.

Congress determines the final funding levels through the appropriations process.

Members of Congress work for us!!

Ask your member of Congress & senators to support adequate funding for APHIS & USFS programs that counter invasive, non-native tree-killing pests.

Congress’ actions are at the following stage as of the third week in July:

APHIS

The House Subcommittee on Agricultural Appropriations bill had cut funding for “tree and wood pest” group – although the bill did increase funding for the “specialty crops” program.

In both cases, groups with which I work had asked to maintain the FY15 level.

The Senate bill, adopted by the full Appropriations Committee on 16 July, has restored funding to the “tree and wood pest” line! Possibly because of this increase, it holds the “specialty crops” program funding to the FY15 level.

Funding specifics:

HOUSE Agriculture appropriations bill maintains overall funding for APHIS at the FY15 level ($871 million). This is $15 million above the President’s request in his budget; and about the same as the level of funding for the current fiscal year (FY 2015). Within this amount, the following is allocated to programs that address tree-killing pests:

$158,000,000, to remain available until expended, for specialty crop pests

(a very small proportion of this account, about $5 million, goes to sudden oak death management)

$45,500,000, to remain available until expended, for tree and wood pests (e.g., ALB, EAB)

SENATE Agriculture appropriations bill raised overall funding for APHIS to $876 M — $20 million above the President’s budget request and $5 M above both the current year and House level. Within this amount, the following is allocated to programs that address for tree-killing pests:

$156,000,000, to remain available until expended, for specialty crop pests
$54,000,000, to remain available until expended, for tree and wood pests

As I said above, it is disturbing that these programs do not enjoy sufficient support within the Administration. We all need to increase our lobbying of USDA – both at the APHIS level and above; and at OMB.

USDA Forest Service

Both the House and Senate Interior Appropriations subcommittee bills cut USFS funding for both research and forest health management.

The House interior appropriations bill provides only $207 million for research other than Forest Inventory and Assessment. The Senate interior appropriations bill provides $211 million for research other than FIA. Both figures are below the $220 million allocated for the current year (FY2015) and higher levels in previous years.

The House bill provides only $99 million for forest health management (on both federal and non-federal or “coop” lands). The Senate bill provides $100.7 million. Again, both figures are below the $104.6 million provided in FY15 and higher levels in previous years.

Funding for all USFS programs is under extreme pressure by the growing cost of fighting wildfires. Until this problem is resolved, it will be extremely difficult to obtain additional funds for other programs – even in the face of rising numbers of tree-killing pests across the country. There are also questions within OMB and among some advocacy groups about whether the USFS should assist states and cities in containing tree-killing pests. Some argue that the USFS should confine its efforts to pests that are attacking trees in National forests. My reply: if you wait for ALB or other pests to reach National forests before responding, you have thrown away any chance of containing the outbreak.

California Government Ignores Threats to State’s Hardwood Trees

CDFA Fails to Regulate Movement of Firewood

Many of California’s hardwood trees are threatened by two introduced insects – the goldspotted oak borer (or here) and the polyphagous shot hole borer or here. Both are established in southern California, but threaten trees throughout the state.

One of the most likely pathways by which these insects can be moved to vulnerable areas is by the transport of firewood. Yet the California Department of Food & Agriculture (CDFA) has not regulated firewood movement.

goldspotted oak borer

Two Tree-Killers

California’s oaks – including California black oak, canyon live oak, coast live oak, Engelmann oak, Shreve’s oak, and valley oak – are threatened by one of both of these insects. The goldspotted oak borer (GSOB) is established in San Diego County with additional outbreaks in Riverside and Orange counties. In less than 20 years, GSOB has killed nearly 100,000 black oaks in these counties. GSOB also kills coast live and canyon oaks. These oaks growing throughout the state are at risk to GSOB.

areas of California at risk to goldspotted oak borer

The polyphagous shot hole borer (PSHB) carries a fungus. The beetle-disease complex has been found in areas of Los Angeles, Orange, San Bernardino, Riverside, and San Diego counties. The insect attacks more than 300 species of trees, shrubs, and vines; the fungus survives in more than 100 of these.

Trees attacked by PSHB include: 11 species native to southern California; 13 agriculturally important trees, such as avocado; and 53 species that, cumulatively, constitute more than half of all trees planted in urban areas of southern California. While PSHB might not be able to reproduce in all these hosts, it is known to reproduce in five types of maples, five types of oaks, a couple of willows, as well as a poplar, a sycamore, and an alder.

areas of southern California where polyphagous shot hole borer is established

Many of the vulnerable tree species are important components of riparian communities in southern California. PSHB apparently attacks only trees that receive enough water to support the fungus – hence the threat to riparian areas. Since PSHB comes from tropical Southeast Asia, its spread to the north and upslope would probably be limited by winter cold. Nevertheless, a wide variety of trees in large parts of the state appear to be at risk.

Among the natural areas at risk to one or both of these pests is Yosemite National Park. The oak trees growing in Yosemite Valley are black oaks, vulnerable to GSOB.

Both State & National Park Service have Failed to Act

Despite the threat to natural and even agricultural resources throughout the state, CDFA has not adopted regulations governing the movement of firewood – the pathway most likely to spread these pests. CDFA has funded outreach efforts, including flyers, posters at campgrounds, and highway billboards. Broad coalitions – made up of academics; county agriculture and parks officials; federal forestry and public lands staff; and others –are educating the public and firewood vendors about the risk and asking them not to move firewood. But when people ask whether there is a law against moving firewood, these volunteers must answer, “no”. This undermines their message!

Yosemite and the other National parks in the region also have not adopted regulations prohibiting visitors from bringing in firewood obtained outside the park. While the National Park Service discourages people from bringing firewood into the Park from farther than 50 miles away, this request is buried in the detailed description of camping regulations or here.

The other National parks in California also do not regulate visitors’ movement of firewood.

It is past time for state and federal agencies to accept their responsibility to protect priceless natural and agricultural resources by adopting regulations to control the movement of firewood.

Government Should Act Now! to Shut Wood Packaging Pathway

Revise Decade-Old Policies that Do Not Prevent Introductions

Despite regulations adopted 9 or more years ago, tree-killing insects continue to enter the U.S. in wood packaging. Aggressive enforcement is needed now to prevent further huge ecological and economic losses.

Disasters already introduced via this pathway

As Americans import more stuff, the risk rises that larvae of tree-killing insects will be enter the country hiding in wooden crates, pallets, etc. – called “solid wood packaging” or SWPM. For more information on this threat, the agencies responsible, and actions taken or proposed, visit here.

Damaging pests still found in SWPM

USDA APHIS (for more information about APHIS, read “Invasives 101” at www.cisp.us) required treatment of wood packaging from China 15 years ago, and treatment of wood packaging from other trade partners 9 years ago! Yet, a small proportion of incoming wood packaging still carries tree-killing pests. As many as 13,000 shipping containers harboring tree-killing pests probably enter the country each year – or 35 each day. [i] The Asian longhorned (illustrated below) is among the pests still detected in wood packaging from China. [ii]

Cities that import the most goods from Asia are at particular risk – New York, Chicago, Los Angeles and Long Beach. Others are also at risk: Washington, D.C.; Virginia Beach; Jacksonville. [To see a more complete list, visit here]

What the Government Has Done

While USDA APHIS has cracked down on U.S. producers of wood packaging who cheat and is promoting workshops to educate our trade partners on wood packaging treatment requirements (see write-up on www.CISP.us referenced above), the government should do more to protect our forests.

What More Can be Done

At present, U.S. policy allows an importer to be caught 5 times in 1 year with wood packaging that does not comply with the regulatory requirements. Requirements adopted a decade or more ago should be enforced strictly! The Bureau of Customs and Border Protection and USDA APHIS should instead penalize all importers whose wood packaging does not comply with regulatory requirements.
The Bureau of Customs and Border Protection should incorporate the wood packaging requirements into its “Customs-Trade Partnership Against Terrorism” (C-TPAT) program .
USDA APHIS should re-examine the economic pros and cons of requiring importers to switch to packaging made from materials other than wooden boards. The new review should incorporate the high economic and ecological costs imposed by insects introduced via the wood packaging pathway.
The President’s Office of Management and Budget should allow APHIS to finalize regulations – proposed in 5 years ago! – that would apply the same treatment requirements to wood packaging used in trade between the US and Canada. (Canada has been ready to adopt this measure for several years.)

[i] Haack RA, Britton KO, Brockerhoff EG, Cavey JF, Garrett LJ, et al. (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(5): e96611. doi:10.1371/journal.pone.0096611

[ii] Haack, R.A., F. Herard, J. Sun, J.J. Turgeon. 2009. Managing Invasive Populations of Asian Longhorned Beetleand Citrus Longhorned Beetle: A Worldwide Perspective. Annu. Rev. Entomol. 2010. 55:521-46; these authors report six separate introductions; after the article was published, a seventh was detected in Clermont County, Ohio; and a new outbreak was detected near Toronto, Ontario. Also, Philip Berger, Executive Director PPQ Science and Technology, Presentation to the Continental Dialogue on Non-Native Forest Insects and Diseases, November 3, 2014