January 31, 2011
Rebecca A. Bech
Associate Deputy Administrator
Plant Protection and Quarantine
Animal and Plant Health Inspection Service
Our groups have come together with many others under the auspices of the Continental Dialogue on Non-Native Forest Insects and Diseases. The Continental Dialogue is a collaboration of diverse interests aimed at addressing the threat of non-native insects and diseases on America's forests.
The undersigned groups appreciate this opportunity to support the proposal to eliminate the current
exemption in 7 CFR §319.40-3, which allows wood packaging material from Canada to enter the United States without having been treated in accordance with requirements of the International Standard for Phytosanitary Measures (ISPM) 15. Under the proposal, wood packaging originating in Canada would become subject to the same requirements as wood packaging from any other country.
We wholeheartedly support the proposed elimination of the current exemption for wood packaging entering the country from Canada. Furthermore, our review of this proposal leads us to recommend that APHIS continue to pursue a method to control movement of pests domestically that would replace the patchwork of federal quarantines and state and local regulations to thus simplify compliance by the shipping industry.
Ending the exemption is important because of the huge volume of imports from Canada. Until 2009, the U.S. imported more goods from Canada than from any other country in the world. Canada is now a close second to China in providing imports to the U.S. Those goods move primarily on wood pallets to all parts of the U.S. Similarities of forest ecosystems facilitate pest establishment. Wood-inhabiting pests in wood packaging from Canada have been intercepted at the border, despite the fact that WPM from Canada is unregulated and so inspected only rarely.
The clearest need for this amendment is associated with pests introduced from other continents, such as Eurasia. While both the United States and Canada have extant populations of the introduced Asian longhored beetle (ALB), emerald ash borer (EAB), pine shoot beetle (PSB), and the European woodwasp, Sirex noctilio, important U.S. forest and urban forest resources vulnerable to these pests have so far escaped invasion. We applaud APHIS' past actions to protect these forests from potential infestation via transport of infested wood packaging or other pest vectors from whatever source, U.S. or Canadian. We recommend further that APHIS pursue adoption of a program governing domestic movement of wood packaging to curtail movement of these pests. Furthermore, Canada has some introduced pests, e.g. brown spruce longhorned beetle (BSLB), that are not yet found in the United States; APHIS should take action to prevent their introduction here.
We note that Canada is expected to institute reciprocal requirements for wood packaging from the United States, and support that action as well. Canada imported close to $187 billion (Canadian) worth of merchandise from the U.S. in 2009, including nearly $42 billion worth of machinery and mechanical appliances1 - heavy items that are likely to be transported in wooden crates and pallets. Wood packaging sent from the United States to Canada could harbor a wide range of pests, including the Eurasian species mentioned above and several additional pests of pines (Mediterranean pine engraver, Orthotomicus erosus; the redhaired pine bark beetle, Hylurgus ligniperda; and an unnamed roundhead borer Arhopalus syriacus). The goldspotted oak borer Agrilus auroguttatus and walnut twig beetle, Pityophthorus juglandis appear to be native to restricted areas of the United States - complicating management in this country. However, they are not considered native to Canada and thus pose a concern to that country. The banded elm bark beetle Scolytus schevyrewi has become established in four Canadian provinces as well as at least 29 U.S. states reaching from the Atlantic to the Pacific. Nevertheless, it is important to avoid contributing to its spread to those regions of Canada still free of it. The banded elm bark beetle appears better able to survive Canadian winters than the other introduced vector of Dutch elm disease, the European elm bark beetle; it could thus contribute greatly to disease spread in Canada. According to our understanding, all these beetles except A. syriacus would require the presence of bark. While the current regulations do not require removal of bark from wood packaging moving from the U.S. to Canada, ending the exemption will
also address this problem.
Tree-killing pests native to one part of North America could cause immense damage if introduced to another, distant region. The Great Plains provides a particularly important biogeographic barrier which insects and pathogens are highly unlikely to cross without human assistance. An example of this threat is the mountain pine beetle, native to western parts of North America. Were it to be transported to the pine systems of the American southeast, it could cause considerable damage. It is thus incorrect to say that the fact that the U.S. and Canada share forest types along our border reduces the need to address this risk. Of course, such risk-reduction efforts need to address wood packaging in domestic as well as international use.
In our view, the U.S. and Canada should work more closely together to curtail movement of tree- killing pests from one area to a geographically separate region where they might encounter naïve hosts or other conditions that facilitate establishment at damaging levels. Since national, state, and provincial borders do not coincide with biogeographic realms, such cooperative efforts should not be constrained by such borders.
We note that the pest risk assessment that accompanies the proposal makes no mention of the most compelling recent example of a pathogen/insect vector being transported in wood packaging. That is laurel wilt disease, caused by the previously undescribed pathogen Raffaelea lauricola vectored by the ambrosia beetle Xyleborus glabratus. While this disease would seem to pose little threat to Canada because of probable climatic limitations, it has certainly been destructive in the United States. While most of the known hosts are found in warm temperate or tropical climates, sassafras (Sassafras albidum) does reach the Niagara region of Canada. Its vulnerability would depend on climatic factors and the unresolved question of whether sassafras proves suitable for widespread attack by the redbay ambrosia beetle.
In summary, the groups listed below wholeheartedly support the elimination of the current exemption in 7 CFR §319.40-3. Furthermore, we recommend that APHIS continue to pursue a method to control movement of pests domestically that would replace the patchwork of federal quarantines and state and local regulations to thus simplify compliance by the shipping industry.
John Ackerly, President, Alliance for Green Heat
Sally Anderson, President, Virginia Native Plant Society
Robert L. Bendick, Director of U.S. Government Relations, The Nature Conservancy
Tom Bruns, Professor, Department of Plant & Microbial Biology, University of California Berkeley
and President, Mycological Society of America
Robert K. Davies, New York State Forester and Director, Division of Lands & Forests, New York
State Department of Environmental Conservation
Jay Farrell, Executive Director, National Association of State Foresters
Marcia Galvin, Executive Director, Massachusetts Association of Campground Owners
Tom Harrington, Professor, Department of Plant Pathology, Iowa State University
Tom Harville, President, North Carolina Native Plant Society
Richard Hawley, Executive Director, Greenspace-the Cambria Land Trust
Daniel J. Hilburn, PhD, Administrator, Plant Division, Oregon Department of Agriculture
Ellen Honeycutt, President, Georgia Native Plant Society
William R. Jacobi, Professor of Tree Pathology and Extension Specialist, Department of
Bioagricultural Sciences and Pest Management, Colorado State University
Bart Jones, President, Tennessee Native Plant Society
Cynthia Maguire, 2011 President, Native Plant Society of Texas
Rick Marsh, President, North American Maple Syrup Council, Inc.
Tom Martin, President and CEO, American Forest Foundation
Joseph J. McCarthy, Senior City Forester, Department of Streets and Sanitation, City of Chicago
Bureau of Forestry
Jennifer L. Parke, Associate Professor, Senior Research, Department of Botany and Plant Pathology,
Oregon State University
Anand Persad, Regional Technical Advisor, The Davey Institute
Ken Rauscher, National Plant Board, Retired
Ann Redmond, President, Florida Native Plant Society
Christopher Reid, President, Louisiana Native Plant Society
Clifford S. Sadof, Professor, Department of Entomology, Purdue University
Lin Schmale, Senior Director - Government Relations, Society of American Florists
Bruce Scholnick, President/CEO, National Wooden Pallet and Container Association
Carl Schulze, President, National Plant Board
Tom Searles, President, American Lumber Standards Committee
Douglas Still, President, Society of Municipal Arborists
Dr. Steve Yaninek, Professor and Head, Department of Entomology, Purdue University