hello, tree pest mavens!
As most of you probably know, APHIS has formally proposed to end its
regulatory program aimed at preventing / slowing spread of the emerald ash
borer. They propose to rely on biological control to reduce impacts and
-- possibly -- slow EAB's spread. I attach the proposal. Comments are due
19 November.
I am trying to formulate my position on this proposal. I recognize
that APHIS has spent considerable effort & resources trying to prevent
spread of EAB - with probably some success but overall not satisfactory (it is
known to be in 31 states + District of Columbia). I am one of those people who
badgers APHIS constantly about the need for it to address additional
tree-killing pests, e.g., polyphagous and Kuroshio shot hole borers, spotted
lanternfly, various Cerambycids that are in the country but not receiving
attention, pathogens attacking ohia and other Mertaceae in Hawai`i ...
I lobby for APHIS' appropriation every year and now how hard it has been
to hold funding steady (not counting inflation), much less to increase funding.
On the other hand, APHIS says EAB currently occupies 1/4 of the range of
ash trees in the U..S - an even smaller proportion once one considers the ash
in Canada and especially Mexico that are at risk.
The proposal lacks much of the information I want to see in order to
understand whether this proposal makes sense:
1) APHIS makes no attempt to analyze the costs to states,
municipalities, private entities, etc. if EAB spreads to parts of the country
where it is not yet established - primarily the West coast. As a result, the
"economic analysis" covers only the reduced costs to those entities
which would no longer be subject to compliance agreements - and thus no longer
required to carry out various treatments, etc.
2) APHIS does not discuss how it would re-allocate the $6-7 million it
currently spends on EAB. Would it all go to EAB biocontrol? Would some be
allocated to other tree-killing pests that APHIS currently ignores?
3) APHIS provides no analysis of the efficacy of biocontrol - it does
not even summarize studies that have addressed past and current releases.
4) APHIS says efforts are under way to develop programs to reduce the
pest spread threat from firewood movement - but does not explain what those
efforts are or why they are likely to be more effective than efforts undertaken
in conjunction with the Task Force that issued recommendations in (I think)
2010.
5) APHIS
makes no attempt to analyze environmental impacts.
I will be
trying to obtain information on these and other topics. I ask your
help! If you have information on the ecological or economic importance of
ash in the West, or the impact of biocontrol agent releases ... please point me
in the right direction!
Faith
703-569-8745
P.S. APHIS
also says nothing about possibly supporting efforts to breed ash trees
resistant to EAB, or to expand reproduction of "wild" ash that appear
to be resistant.
