Review of the U.S. Department of Agriculture's Animal and Plant Health Inspection Service Response to Petitions to Reclassify the Light Brown Apple Moth as a Non-Actionable Pest A Letter Report (2009) / Chapter Skim
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BACKGROUND
BACKGROUND
Pages 1-13
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on the basis of the argument that it is not an economically important pest and can be controlled by other means, including integrated pest management. 1 Early in the review process, the committee experienced confusion about important regulatory terms and their ramifications for pest management at state and federal levels.
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. The committee posed various questions to APHIS about its classification system for plant pests and how it is related to CDFA's system.
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The IPPC and Executive Order 13112 provide no quantitative basis for determining what constitutes economic importance or what is economically significant. The secretary of agriculture has broad authority under the PPA with regard to establishing the magnitude of potential economic or environmental damage needed to trigger a regulatory response and significant discretion with regard to what action to take against any plant pest.
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Prediction of Potential Geographic Distribution in the United States The analysis presented in Figure 1 of the Response purports to describe the probability of LBAM establishment in the conterminous 48 states and is the basis of the economic analyses. The model (NAPPFAST)
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on 10 x 10-km grids, in implementing the predicted distribution for economic analyses the model establishes that only a single 10 x 10-km grid needs to be flagged as suitable for LBAM establishment for an entire county to be considered at risk (Response, Table 1)
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Whether the new records from California document suitable new host plants that fully support LBAM development and reproduction, however, remains unclear. Finding 2: The biological data presented in the Response to support the invasive nature of LBAM, its history in California, and its potential geographic distribution in the United States are problematic and in some cases not based on sound, rigorous science.
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For example, there is substantial uncertainty about the ability of LBAM to spread geographically, about its host range, and about the severity of damage that it can inflict on host plants. At a minimum, the economic analysis should discuss potential limitations and cautions; otherwise, its results imply an unwarranted degree of certainty.
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. A more appropriate goal might be to contemplate a minimal justifiable geographic distribution and host range in view of the limited information that is available.
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Various trade scenarios could also be presented. For example, APHIS could use the quarantine list or exemptions list as a basis for judging the impact of more narrowly defined trade restrictions, or it could focus on the same set of major host crops considered in Fowler et al.
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The threat to endangered plant species appears to be based on the assumption that, inasmuch as LBAM is known to be a polyphagous feeder, a positive record for one plant species in a genus should lead to the interpretation that all members of the genus would be equally susceptible or good host plants. That assumption expands the potential environmental impacts on endangered plants dramatically (Response, Table 8)
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16, "The literature also suggests that natural control can be sporadic, and incapable of preventing economic losses." Inadequately documented statements weaken the credibility and clarity of the Response and eliminate opportunities to provide the public with critical information. In the Response, APHIS chose to focus entirely on the regulatory status of LBAM.
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Beyond the biological impacts, the agency acknowledges that "the greatest economic threat posed by LBAM is losses associated with trade restrictions on host plants and commodities in both international and interstate trade." Trade restrictions have been known to be imposed in ways that ignore basic biology; the recent trade restrictions on pork products in response to swine influenza are a case in point. 6 The use of language regarding pest status in the two petitions suggests that the petitioners do not fully understand APHIS criteria for designating quarantine-significant status, and it is incumbent on the agency to clarify regulatory language and practices and to distinguish among these terms in the Response.
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In responding to the petitions, APHIS would be well served by articulating the justification for its actions to the public clearly, and the Response should be revised accordingly. In addition, the LBAM regulations should be published for comment in the Federal Register.
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