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Report to the Chairman, Committee on Resources, House of 
Representatives: 

April 2006: 

Invasive Forest Pests: 

Lessons Learned from Three Recent Infestations May Aid in Managing 
Future Efforts: 

GAO-06-353: 

GAO Highlights: 

Highlights of GAO-06-353, a report to the Chairman, Committee on 
Resources, House of Representatives. 

Why GAO Did This Study: 

Invasive forest pests have seriously harmed our environment and imposed 
significant costs upon our economy. The U.S. Department of Agriculture 
(USDA) is the lead agency for responding to forest pests. This report 
evaluates the federal response to three invasive forest pests—the Asian 
longhorned beetle, the emerald ash borer, and the pathogen Phytophthora 
ramorum (P. ramorum). Specifically, GAO describes (1) the status of 
efforts to eradicate these species, (2) the factors affecting the 
success of those efforts, (3) overall forest health monitoring 
programs, (4) coordination and communication of the three pest response 
efforts, and (5) USDA’s use of panels of scientific experts to aid in 
the response efforts. 

What GAO Found: 

On the basis of the available evidence, it appears that the Asian 
longhorned beetle will be eradicated in the three states that have 
infestations, although funding reductions have extended the likely 
completion date. In contrast, the emerald ash borer and P. ramorum—the 
pathogen that causes Sudden Oak Death—are likely to continue to infest 
and damage forest ecosystems in the Midwest and West Coast, 
respectively, despite efforts to control them. 

The success of the federal responses to these infestations has been 
affected by several factors. First, the unique biological 
characteristics of each species greatly influenced the ability to 
effectively control them. Second, several years elapsed between each 
pest’s arrival and its discovery, thereby giving it time to become 
established in the environment before control programs began. This 
situation cannot be fixed retroactively, but it could be avoided in the 
future with better monitoring. Third, quarantines have helped contain 
the spread of the pests, but implementation and enforcement have been 
difficult. Fourth, the only available method for eradicating these 
pests is to destroy the infested trees and plants—a costly and 
sometimes impractical approach. Lastly, despite budgeting over $420 
million on these pests, USDA program managers told GAO that funding has 
not been sufficient to fully implement their programs. 

USDA conducts a range of forest health monitoring programs, including a 
pilot project in some urban areas; however, these programs do not 
provide for comprehensive monitoring in urban forests or other 
locations considered at high risk from pest invasions. Monitoring in 
such areas is important because they are common destination points for 
internationally traded cargo that is a frequent pathway for pests. 

Federal and nonfederal stakeholders involved in these efforts told GAO 
that appropriate mechanisms to coordinate response efforts are 
generally in place, although many noted that better coordination among 
agriculture and natural resource agencies would have helped produce a 
more effective initial response. In addition, USDA’s P. ramorum control 
plan does not fully comply with a congressional requirement that it 
communicate future funding needs. Furthermore, USDA has not updated 
plans for the Asian longhorned beetle or emerald ash borer to 
communicate to decision makers or the public how it will modify its 
response efforts in light of fiscal years 2005 and 2006 funding 
reductions, and how those reductions have affected the long-term 
prospects for managing the pests. 

Panels of scientific experts have assisted USDA with each of the three 
pest responses, although GAO and stakeholders have some concerns about 
how they were formed or operated. For example, some stakeholders 
believed that the agency should have convened the panels more 
frequently and made the panel process more open to interested parties. 
GAO found that USDA does not have written procedures for forming and 
using science panels. 

What GAO Recommends: 

GAO recommends that the Secretary of Agriculture (1) expand efforts to 
monitor forest health conditions to include urban areas, particularly 
those deemed high risk for potential infestations; (2) regularly update 
and publish management plans for pests that include status information 
and funding needs; and (3) implement written procedures that broadly 
define when and how to operate science panels for specific pests. USDA 
did not directly disagree with GAO’s recommendations, but took issue 
with GAO’s presentation of some of the findings that supported the 
recommendations. GAO continues to believe that its findings fully 
support the three recommendations. 

[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-06-353]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Robin Nazzaro at (202) 
512-3841, or nazzaror@gao.gov. 

[End of Section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

Eradicating the Asian Longhorned Beetle Appears Likely, While Success 
on the Emerald Ash Borer and P. ramorum Is Less Promising: 

Efforts to Eradicate These Pests Have Been Affected by Several Factors 

Forest Health Monitoring Does Not Adequately Address Urban Forests: 

Coordination Problems Caused Concerns among Stakeholders, and 
Communication on the Status of Pest Responses Is Not Adequate: 

Science Advisory Panels Have Assisted with the Pest Response Efforts, 
but There Are Concerns about How They Were Formed and Operated: 

Conclusions: 

Recommendations: 

Agency Comments and Our Evaluation: 

Appendixes: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: Questions from Structured Interview Guide Administered to 
Stakeholders Involved with the Three Pest Response Programs: 

Appendix III: Review of Efforts to Control and Eradicate the Asian 
Longhorned Beetle: 

Origin and Potential Impacts of Asian Longhorned Beetle Infestations: 

Federal, State, and Local Roles in Controlling and Eradicating the 
Asian Longhorned Beetle: 

Management Structures and Methods Used to Control and Eradicate the 
Asian Longhorned Beetle: 

Status of Asian Longhorned Beetle Infestation: 

Funding for Asian Longhorned Beetle Eradication Efforts: 

Appendix IV: Review of Efforts to Control and Eradicate the Emerald Ash 
Borer: 

Origin and Potential Impacts of Emerald Ash Borer Infestations: 

Federal, State, and Local Roles in Controlling and Eradicating the 
Emerald Ash Borer: 

Management Structures and Methods Used to Control and Eradicate the 
Emerald Ash Borer: 

Status of Infestation: 

Funding for Emerald Ash Borer Control and Eradication Efforts: 

Appendix V: Review of Efforts to Control and Eradicate P. ramorum: 

Origin and Potential Impacts of P. ramorum: 

Federal, State, and Local Roles in Efforts to Control and Eradicate P. 
ramorum: 

Status of the P. ramorum Infestation: 

Funding of Efforts to Control and Eradicate P. ramorum: 

Appendix VI: Risk Analysis as a Tool to Address Invasive Forest Pests: 

Pest Risk Assessment Is an Essential Element of Risk Analysis: 

Risk Assessment Is a Tool for Risk Management: 

APHIS Has Conducted Risk Assessments for P. ramorum and the Asian 
Longhorned Beetle: 

Appendix VII: Comments from the Department of Agriculture: 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: Number of Stakeholders Who Were Administered the GAO 
Structured Interview, by Pest and Affiliation: 

Table 2: APHIS Budget Authority for the Asian Longhorned Beetle for 
Fiscal Years 1997 through 2006: 

Table 3: APHIS Budget Authority for the Emerald Ash Borer Program, by 
Funding Source and Fiscal Year: 

Table 4: Forest Service Budget Authority for Emerald Ash Borer 
Activities, by Funding Source and Fiscal Year: 

Table 5: Summary of USDA funding for P. ramorum, Fiscal Years 2000 
Through 2005: 

Figures: 

Figure 1: Asian Longhorned Beetle (Anoplophora glabripennis): 

Figure 2: Emerald Ash Borer (Agrilus planipennis Fairmaire): 

Figure 3: Cable Spools, an Example of Solid Wood Packing Material That 
Could Harbor Pests: 

Figure 4: Areas in New Jersey and New York Quarantined for the Asian 
Longhorned Beetle: 

Figure 5: Areas in Metropolitan Chicago, Illinois, Quarantined for the 
Asian Longhorned Beetle: 

Figure 6: Areas with Emerald Ash Borer Infestations in Indiana; 
Michigan; Ohio; and Ontario, Canada, as of January 2006: 

Figure 7: Approximate Range of North American Ash Tree Species: 

Figure 8: Map of Area Infested with P. ramorum in California and 
Oregon, as of December 12, 2005: 

Figure 9: Forest Service P. ramorum Risk Map: 

Figure 10: "Bleeding" on Tree Trunk Caused by P. ramorum: 

Figure 11: Citrus Longhorned Beetle (Anoplophora chinensis): 
Figure 12: APHIS Funding for the Asian Longhorned Beetle Program, by 
Source, for Fiscal Years 1997-2006: 

Figure 13: APHIS Funding for the Emerald Ash Borer Program, by Source, 
for Fiscal Years 2002-2006: 

Figure 14: APHIS Funding for the P. ramorum Program, by Source, for 
Fiscal Years 2001-2006: 

Figure 15: Number of Asian Longhorned Beetle-Infested Trees Identified 
in New York, Illinois, and New Jersey: 

Abbreviations: 

APHIS: Animal and Plant Health Inspection Service: 

CCC: Commodity Credit Corporation: 

CPHST: Center for Plant Health Science and Technology: 

DHS: Department of Homeland Security: 

FACA: Federal Advisory Committee Act: 

IPPC: International Plant Protection Convention: 

ISPM: International Standards for Phytosanitary Measures: 

OMB: Office of Management and Budget: 

PPD: Policy and Program Development: 

PPQ: Plant Protection and Quarantine: 

SPS: Sanitary and Phytosanitary: 

USDA: U.S. Department of Agriculture: 

Letter: 
April 21, 2006: 

The Honorable Richard Pombo: 
Chairman, Committee on Resources House of Representatives: 

Dear Mr. Chairman: 

Hundreds of nonnative, invasive insect and pathogen species have 
infested our nation's forests, causing damage to our environment and 
costing our economy billions of dollars in lost revenue and cleanup. 
For example, starting in the early 1800s, American chestnut trees were 
devastated by a succession of two nonnative pathogens--ink disease and 
chestnut blight. These trees were a major component of the nation's 
deciduous forests, were valuable to wildlife, and had wide use as a 
source of lumber. Today, chestnut trees still survive in much of their 
former range, but only as sprouts from the old root systems; 
unfortunately, these sprouts are struck down by the blight before they 
reach maturity. Gypsy moth is another serious invasive forest species 
that is still harming our nation's forests more than 130 years after 
its accidental release by an amateur entomologist studying silkworms. 
The caterpillar of the moth defoliates oak, birch, poplar, and other 
important tree species, sometimes leading to the death of the tree. 
Forest pests such as these are not limited to damaging trees in 
wildland forests but may also devastate trees in suburban and urban 
neighborhoods. When forest pests kill trees, they reduce the value of 
timberlands and residential property, harm businesses, increase the 
risk of wildfire, degrade ecosystems, and place upon homeowners and 
local governments the costly burden of removing dead trees before they 
become a safety hazard. While the pests previously described have been 
in the United States for over 100 years, they continue to have an 
impact on the environment and economy. 

The U.S. Department of Agriculture (USDA) has federal responsibility 
for protecting agricultural commodities and the health of the nation's 
public and private forests and grasslands and private forests from 
harmful pests and diseases. Within USDA, the Animal and Plant Health 
Inspection Service (APHIS) and the Forest Service have primary 
responsibility for managing forest pests. In doing so, these agencies 
often work with other federal, state, and local agencies to manage and 
eradicate invasive species infestations. The Secretary of Agriculture 
may also draw upon the expertise of people outside of the federal 
government when developing a: 

response plan for invasive species.[Footnote 1] Funding for pest 
management activities comes through annual appropriations and the 
Commodity Credit Corporation (CCC), which is a government-owned entity 
that finances farm commodity, conservation, and trade programs and 
provides funding for agricultural-related emergencies.[Footnote 2] The 
Secretary may transfer funds from the CCC (or other available USDA 
appropriations) for the arrest, control, eradication, and prevention of 
the spread of a plant pest and related expenses. 

This report evaluates the federal response to three invasive forest 
pests--the Asian longhorned beetle; the emerald ash borer; and 
Phytophthora ramorum (hereafter P. ramorum), the pathogen that causes 
Sudden Oak Death. Specifically, we reviewed (1) the status of efforts 
to eradicate these three species; (2) factors that have affected the 
success of the response programs; (3) overall forest health monitoring 
programs; (4) coordination of the three pest response efforts among 
federal and state agencies and other stakeholders, and communication 
about the response efforts; and (5) USDA's use of panels of scientific 
experts to aid the responses. We also discuss in appendix VI APHIS's 
use of risk assessments to support decisions about forest pest 
programs. When we use the term "forest pest," we are referring to 
species that negatively affect trees in forested and urbanized areas. 
When we use the term "natural environment," we are referring to places 
other than a plant nursery operation that have trees and plants 
vulnerable to a particular invasive species. These places could include 
forested and urbanized areas. 

To address these objectives, we conducted in-depth reviews of these 
three forest pests. These species were chosen because of their 
relatively recent discovery in the United States; their potential 
threat to the nation's forests; and the existence of a federally funded 
research, control, and management program for each species, and because 
they comprise a significant portion of USDA's efforts to address 
specific forest pests. To analyze the efforts to address each pest, we 
visited three of the areas currently infested by the species and 
observed program activities, such as detection, control, and 
inspections of regulated materials, and visited with regulated 
industries. To obtain opinions from key stakeholders, we also conducted 
structured interviews with 37 USDA, state, local, and nongovernmental 
officials. More specifically, we administered the interview to 9 Asian 
longhorned beetle stakeholders, 12 emerald ash borer stakeholders, and 
16 P. ramorum stakeholders. The government officials included federal, 
state, and local officials directly engaged in one of the pest 
management efforts. Nongovernmental officials included academic 
scientists with expertise in one of the pests and representatives from 
the nursery industry affected by one of the pests and by quarantine 
regulations. A more detailed description of our scope and methodology 
and questions from the structured interview guide are presented in 
appendixes I and II. We performed our work between May 2005 and 
February 2006 in accordance with generally accepted government auditing 
standards. 

Results in Brief: 

Evidence suggests that efforts to eradicate the Asian longhorned beetle 
appear likely to succeed, while the emerald ash borer and P. ramorum 
are likely to continue to infest and damage forest ecosystems 
indefinitely despite efforts to control them. The Asian longhorned 
beetle is a wood-boring insect from Asia that has caused separate 
infestations in parts of New York, New Jersey, and Illinois. Over 8,000 
trees infested with the beetle have been removed, and over 600,000 
trees have been chemically treated to protect against the beetle. As a 
result of these and other actions, federal and state agencies have been 
able to reduce the size of the infested areas. Program managers 
currently believe they could eradicate the beetle and end their program 
by 2014 if 2005 funding levels are maintained; however, fiscal year 
2006 funding has dropped significantly below the 2005 level. The 
emerald ash borer is also a wood-boring insect from Asia that has 
infested large areas in Michigan; Ohio; Indiana; and Ontario, Canada, 
killing an estimated 15 million trees. The pathogen P. ramorum is the 
causal agent of the disease known as Sudden Oak Death. It is of unknown 
origin and has infested large areas in central and northern coastal 
California and a small area in southern Oregon. Although federal and 
state agencies have taken steps to reduce the spread of these two 
species--including attempting to stop the spread caused by people 
inadvertently moving infested material--the infestations are growing 
and few managers with whom we spoke believed that these species can be 
removed from the natural environment because of the size of the areas 
that are already infested. 

Several factors have affected the success of the federal responses to 
these three forest pest species. Specifically: 

* The biology of each of the three forest pests greatly influences the 
potential successfulness of eradication efforts. The Asian longhorned 
beetle is a large, conspicuous bug that does not fly far from the core 
infestation. As a result, it is fairly noticeable and does not spread 
quickly. Conversely, the emerald ash borer and, in particular P. 
ramorum are more insidious and can spread over greater distances and 
more rapidly. 

* Delays in detection and identification allowed the three pests we 
reviewed to become established and spread before control efforts began. 
In each instance, several years elapsed between the arrival of the pest 
and its discovery, thereby giving the pest time to become firmly 
established in the environment. 

* Quarantines have been helpful in containing human-induced spread of 
these forest pests. Federal and state agencies have placed restrictions 
on the movement of potentially infested materials, such as nursery 
plants and firewood. They also have mounted large public education 
campaigns to inform the public about the need to refrain from 
activities that could spread the pests. While program managers with 
whom we spoke believed that the quarantines have limited the spread of 
each pest, managers of the emerald ash borer and P. ramorum programs 
also noted that the quarantines were difficult to establish and 
enforce, and that they have not completely stopped the movement of 
those pests. 

* Efforts to address the three forest pests are limited by the lack of 
cost-effective technologies for eradicating them. To date, the only 
method available to eradicate these pests in infested areas is to 
destroy the trees and plants that have been infested. Agencies have 
destroyed thousands of trees infested with the Asian longhorned beetle 
in New York, Illinois, and New Jersey and hundreds of thousands 
infested with the emerald ash borer in Michigan, Ohio, and Indiana. In 
the case of the ash borer, many more infested trees remain to be 
removed. On the West Coast, few trees infested with P. ramorum have 
been removed relative to the number infested because the pathogen is so 
widespread, but over 1 million nursery plants have been destroyed. 
Chemical treatments that can eradicate infestations of the three pests 
on a broad scale are not available, although they can be helpful in 
preventing the pests' spread. Such treatments have been used 
extensively for the Asian longhorned beetle; however, they are 
impractical in the cases of the emerald ash borer and P. ramorum 
because of the size of the infestations. Research on alternative 
control technologies is ongoing for all three pests. 

* While USDA has budgeted over $420 million on control programs for 
these pests, program managers told us that funding has not been 
sufficient to fully implement their programs. For example, according to 
managers of the Asian longhorned beetle program, reduced funding in 
fiscal years 2002, 2003, and 2006 delayed the estimated date of 
eradication from 2009 to as late as 2020 and increased the risk that 
the pest could spread to new locations during this time. In the case of 
the emerald ash borer, funding in fiscal year 2005 was about one-half 
of what the management team estimated was needed, while funding for 
fiscal year 2006 is less than one-third of the estimated need. As a 
result, state agencies have not been able to fully implement a tree 
removal plan recommended by the scientific advisory panel to contain 
the pest. 

USDA has monitored the health of the nation's public and private 
forests for decades. Some programs are focused on broad issues, such as 
tree species composition and general health conditions, while others 
are focused on identifying specific problems. However, for the three 
forest pests we reviewed, as well as others, delays in detection and 
identification that allowed the pests to become established and spread 
before control efforts began illustrate that forest health monitoring 
has not been adequate. This is particularly the situation in urban 
areas that are common destination points for internationally traded 
cargo--a frequent pathway for pests. For example, the Asian longhorned 
beetle is thought to have begun infesting trees in New York City in the 
mid-1980s. It had been intercepted at warehouses around the country and 
was known to be a problem in its native range. However, there was no 
specific effort to determine whether it had made its way into the 
natural environment. It was not detected in the natural environment 
until 1996, when a New York City homeowner noticed suspicious holes in 
one of his trees. While a citizen report is an important component of 
an early warning system, a thorough government monitoring program-- 
triggered by the detection of the beetle at U.S. ports--might have 
detected it sooner. The Forest Service and APHIS have taken steps in 
recent years to increase monitoring and otherwise improve their early 
warning system for forest pests, but these agencies could expand forest 
health monitoring in urban areas to further reduce the risk that new 
introductions will escape detection and result in substantial natural 
resource damage. Agency officials have estimated the cost of expanding 
existing programs to improve urban forest health monitoring to be about 
$3 to 4 million per year, and they believe that doing so could help 
avoid more costly pest impacts and management costs. We are 
recommending that the Secretary of Agriculture expand current efforts 
to monitor forest health conditions, particularly in urban areas that 
are at high risk of receiving invasive insects and diseases. 

For the three infestation response programs we reviewed, we found that 
coordination between federal and state agencies was initially lacking, 
and that USDA had not adequately kept management plans up to date to 
communicate with the public program accomplishments, strategies, and 
long-term funding needs, despite major changes in the programs. For 
each pest program we reviewed, a majority of the 37 stakeholders with 
whom we spoke told us that appropriate federal and state mechanisms are 
now in place to coordinate the work of multiple agencies and levels of 
government but highlighted weaknesses that had occurred and made 
suggestions for improvements. A common stakeholder complaint was that 
agriculture and natural resource agencies at either the federal or 
state level did not always work well together at the beginning of the 
response effort, thereby delaying management progress. Such problems 
could be averted in new pest response efforts if attention is paid to 
the lessons learned from the three pest management efforts we reviewed. 
Regarding communications about the response efforts, general principles 
of transparency and accountability, as well as the National Invasive 
Species Council's guidelines for rapid response programs, stress the 
importance of informing the public about the status of management 
programs, planned strategies, and funding needs. Along these lines, 
Congress passed a law in 2004 requiring that USDA, subject to the 
availability of appropriated funds, prepare a national plan for the 
control and management of Sudden Oak Death, which is caused by P. 
ramorum. The national plan is to include certain information. However, 
the agency published a plan in 2005 that did not include required cost 
estimates. Similarly, while the Asian longhorned beetle and emerald ash 
borer programs have publicly available management plans, the plans do 
not reflect the significant impacts that funding reductions have had on 
the prospects for controlling the infestations. We are recommending 
that the Secretary of Agriculture prepare, publish, and regularly 
update management plans for pests for which USDA has initiated a 
management program. 

USDA has convened panels comprising federal and nonfederal scientific 
experts to assist the agency in responding to each of the three pests 
we reviewed. While program managers believe that these panels have been 
useful, we and some stakeholders have concerns about how they were 
formed and are being operated. For example, some stakeholders believed 
that USDA should have convened specific panels more frequently and made 
the panel process more open and transparent to interested parties. We 
found that USDA does not have written procedures for how science 
advisory panels are to be formed and operated and when such panels 
should be chartered as federal advisory committees under the Federal 
Advisory Committee Act (FACA). There are certain principles in FACA 
that, if included in operational procedures for pest advisory panels, 
could address or minimize some of the concerns raised about their use. 
We are recommending that the Secretary of Agriculture implement written 
procedures that broadly define when and how to operate panels of 
scientific experts for the purpose of assisting pest management teams, 
including a discussion on how to determine when such panels should be 
chartered as advisory committees under FACA. 

USDA provided comments on a draft of this report and said that it was 
comprehensive and well written. However, USDA stated that it believed 
the report contained an overly critical tone regarding its response to 
the three infestations and expressed the view that the coalition of 
federal and nonfederal entities had done a reasonable job. We believe 
the report fairly captures the agency's performance recognizing the 
daunting challenges that USDA and its collaborators have faced in 
responding to the infestations, while also accurately portraying the 
comments and opinions of the government officials we interviewed. 
Unfortunately, despite considerable effort, the fact remains that two 
of the three pests are spreading and are not likely to be eradicated. 
Our intention is to draw lessons from these pest infestations that can 
be used to reduce the effects of future infestations. 

USDA also wrote that while it did not have major concerns about our 
recommendations, it did not completely agree with them. With regard to 
our recommendation that USDA expand forest health monitoring, the 
department suggested that we also examine the role that nonfederal 
entities play, their responsibilities, and the outcomes of their 
efforts. We recognize that nonfederal entities make important 
contributions to forest health monitoring; in fact, the USDA monitoring 
programs we discuss in this report are collaborative programs with 
nonfederal entities, including state forestry and agriculture agencies 
and private landowners. As the lead federal agency, USDA has an 
important leadership role to play with these nonfederal agencies. We 
believe that adopting our recommendations would enhance USDA's 
leadership position and help lead all responsible parties to more 
effective results. USDA commented that it supported our second 
recommendation to keep management plans up to date, but the agency also 
stated its belief that it had done a reasonable job on the plans for 
the three pests we reviewed, given competing demands for time and 
resources. USDA characterized our third recommendation as calling for 
putting "more rigor into how science panels are formed" and said that 
"seemed reasonable." It appears, however, that the agency interpreted 
our recommendation to imply that science panels should always be 
chartered under FACA. The agency stated that chartering panels under 
FACA would hamper their ability to address invasive species issues. We 
recognize that the FACA process requires that certain steps be taken 
that could slow the establishment of a science panel at a time when one 
is quickly needed. However, our recommendation does not state that 
science panels always be chartered under FACA, but rather that USDA 
develop written procedures that clarify when a science panel needs to 
be chartered under FACA. The letter from USDA is reprinted in appendix 
VII. 

Background: 

Invasive species pose significant risks for the United States and can 
cause serious economic and environmental damage. The U.S. Department of 
Agriculture (USDA) is the lead federal agency for protecting the 
nation's agriculture and public and private forests from harmful pests 
and diseases. USDA often collaborates with other federal, state, and 
local agencies in carrying out these duties. Three recent infestations-
-the Asian longhorned beetle; the emerald ash borer; and Phytophthora 
ramorum (hereafter P. ramorum), the pathogen that causes Sudden Oak 
Death--offer valuable illustrations of how the federal government 
manages the threats posed by invasive species. 

Potential Economic and Environmental Impacts of Invasive Species: 

As we have previously reported, the impact of invasive species in the 
United States is widespread, and their consequences for the economy and 
the environment are profound.[Footnote 3] They affect people's 
livelihoods and pose a significant risk to industries such as 
agriculture, ranching, and fisheries. The cost to control invasive 
species and the cost of damages they inflict, or could inflict, on 
property or natural resources are estimated to total billions of 
dollars annually. Among the broad universe of invasive species are 
insects and pathogens that can harm trees, including trees that are 
important to industry, homeowners and communities, wildlife, and the 
environment. 

Federal and State Responsibilities: 

In 1999, President Clinton signed Executive Order 13112 creating the 
National Invasive Species Council, which now comprises the heads of 13 
departments and agencies, in part to coordinate federal efforts on 
invasive species. In 2001, the council issued a national management 
plan that contains numerous recommendations for managing invasive 
species, including several on improving early detection and rapid 
response to infestations. For example, in response to the management 
plan, the council issued in 2003 general guidelines for establishing 
and evaluating invasive species early detection and rapid response 
systems. 

Within USDA, the Animal and Plant Health Inspection Service (APHIS) is 
the lead agency for responding to forest pests and diseases that might 
harm U.S. agriculture. The Department of Homeland Security (DHS) also 
plays a critical role in protecting agricultural interests by 
inspecting ships, airplanes, vehicles, cargo, and passengers and their 
baggage for prohibited agricultural materials that may serve as 
carriers for pests and disease. USDA conducted some of these 
inspections in the past, but the Homeland Security Act of 2002 
transferred this function, among others, to DHS.[Footnote 4] This 
report does not address DHS pest inspection programs. However, we plan 
to issue a separate GAO report on inspection programs later this 
spring.[Footnote 5] 

This report focuses on USDA programs to address forest pests that have 
arrived in the United States despite preventive efforts. APHIS manages 
pests that have arrived by conducting detection surveys; issuing 
quarantines; directing eradication efforts, such as removing infested 
trees or applying pesticides; developing control technologies; and 
performing public outreach. The Forest Service--whose mission of forest 
protection extends to all public and private forest land--undertakes 
reforestation of areas affected by pests and plays an important role in 
surveys, research, and management. Other federal agencies may also be 
involved in some aspects of invasive species management, including 
managing federal lands that may be impacted by invasive species and 
administering programs to address them. 

State agencies also play an important role in managing invasive 
species. For example, state agencies impose quarantines to prevent the 
movement of infested materials within their state and take actions to 
eradicate pests. APHIS and the Forest Service enter into cooperative 
agreements with states to jointly carry out eradication programs and 
provide funding assistance for these programs. APHIS and the states 
also monitor for specific plant pests, including some that have already 
arrived in the country and others that have not. 

The Asian Longhorned Beetle: 

The Asian longhorned beetle was initially detected in the United States 
in Brooklyn, New York, in August 1996, and is suspected to have entered 
the country years before in solid wood packing material from Asia, 
where it is a pest of hardwood trees. Subsequent infestations were 
discovered in Chicago, Illinois, in July 1998, and in New Jersey in 
October 2002. The beetle was also discovered in Toronto, Canada, in 
September 2003. The beetle infestations have been limited to urban 
forests in New York; Illinois; New Jersey; and Ontario, Canada. 

While the natural spread of the Asian longhorned beetle has been very 
slow to nonexistent, the beetle represents a serious threat to forests 
and urban trees. The potential impact to forests is the loss of 71 
billion trees valued at over $2 trillion dollars. In addition, urban 
areas could lose as much as 35 percent of their tree canopy cover and 
30 percent of their trees (1.2 billion trees), with an estimated loss 
of value of $669 billion.[Footnote 6] Other potential adverse impacts 
could affect the forest products industry (lumber and furniture), maple 
syrup production, and fall foliage tourism, as well as decrease 
property values, cause aesthetic damage, and lessen the environmental 
benefits of trees. The potential also exists for the beetle to 
seriously alter the ecological diversity of the natural forests in 
North America, with additional impacts on wetlands. Figure 1 shows the 
beetle, and appendix III contains more detail on its infestation and 
the management program. 

Figure 1: Asian Longhorned Beetle (Anoplophora glabripennis): 

[See PDF for image] 

[End of figure] 

The Emerald Ash Borer: 

The emerald ash borer was initially detected in the United States in 
2002 in southeastern Michigan, but the insect is estimated to have 
arrived in the country in the early 1990s, in solid wood packing 
material. Emerald ash borer infestations cover roughly 40,000 square 
miles in Indiana; Michigan; Ohio; and Ontario, Canada, and the natural 
spread of the species continues. Surveys also regularly find new areas 
in the three states infested with beetles that inadvertently were moved 
by people. 

The emerald ash borer can kill all 16 species of North American ash 
trees and, as of November 2005, the pest had killed an estimated 15 
million trees. The potential economic impacts of the infestation are 
significant because ash trees represent billions of dollars in 
ornamental, industrial, and environmental value. Figure 2 shows the ash 
borer, and appendix IV contains more detail on its infestation and the 
management program. 

Figure 2: Emerald Ash Borer (Agrilus planipennis Fairmaire): 

[See PDF for image] 

[End of figure] 

P. ramorum: 

P. ramorum (the pathogen that causes Sudden Oak Death) was initially 
detected in the United States in 2000. While it is believed to have 
appeared in the country as early as the mid-1990s, how it arrived here 
is unknown. Currently, P. ramorum infects natural areas in 14 counties 
of California and part of Curry County, Oregon. The pathogen has also 
been inadvertently shipped to, and in most cases eradicated from, 
nurseries in 22 states. The natural and artificial spread of P. ramorum 
continues. However, improved detection of the pathogen in nurseries has 
led to a decrease in the number of detected interstate shipments of 
infected plants. For example, in 2005, 99 confirmed positive detections 
of P. ramorum were associated with nursery plants in 7 states, down 
from 176 positives in 22 states in 2004. 

P. ramorum affects oak trees and other host and associated host plants 
in natural areas and nurseries. P. ramorum can kill valuable oak trees 
in urban and natural environments and can infect and devalue, but not 
necessarily kill, ornamental plants such as rhododendron. Currently, 

P. ramorum is known to infect species in more than 50 plant 
genera.[Footnote 7] These plants are worth billions of dollars in 
ornamental, timber, wildlife, and environmental value. The pathogen has 
killed tens of thousands of trees and led to the destruction of 
hundreds of thousands of nursery plants. Appendix V contains more 
detail on the P. ramorum infestation and management program. 

The Asian longhorned beetle, the emerald ash borer, and other invasive 
species arrived in the United States in solid wood packing material 
accompanying cargo from overseas. This review did not address 
government regulations or practices aimed at preventing this from 
occurring. Following is a brief description of actions USDA has taken 
to reduce the risks posed by solid wood packing material. 

Figure 3: Cable Spools, an Example of Solid Wood Packing Material That 
Could Harbor Pests: 

[See PDF for image] 

[End of figure] 

Recent USDA Regulations for Solid Wood Packing Material Are Intended to 
Reduce Pest Introductions, but Some Have Questioned Their Future 
Effectiveness. 

A major pathway through which forest pests enter this country is solid 
wood packing material. This material includes pallets, crates, boxes, 
cable spools, and pieces of wood used to support or brace cargo. The 
Asian longhorned beetle and the emerald ash borer--as well as many 
other pests--are thought to have arrived in this country hidden in this 
type of material. We did not review the federal government's efforts to 
prevent the introduction of pests. However, one major development in 
this area bears noting. In December 1998, an APHIS interim rule took 
effect requiring that solid wood packing material arriving in the 
United States from China be treated to reduce the likelihood that it 
harbored live pests. In September 2004, APHIS published a final rule 
that adopted an international standard for treating solid wood packing 
material. The new standard requires that wood packing material from all 
places be treated either with heat or a fumigant known as methyl 
bromide. APHIS will phase in enforcement of the rule, with full 
enforcement by July 2006. According to APHIS, there has been a decrease 
in pests associated with solid wood packing material from China since 
APHIS began requiring that the material be treated prior to 
importation. The agency believes that the new and broader regulations 
will further reduce the introduction of new species. If the standard 
does add protections, the need for early detection and rapid response 
may decrease. Although, as a Forest Service entomologist noted to us, 
detection is still needed for pests that have arrived in recent years. 

However, solid wood packing material is not the only pathway by which 
new pests are introduced, and some interested parties commented during 
the rulemaking process that the new regulations are not protective 
enough to kill all pests. Comments included concerns that the heat 
treatment and fumigation standards are not adequate, and that it will 
be too difficult to ensure that those treatments were conducted. 
(Methyl bromide is also controversial because it contributes to 
stratospheric ozone depletion.) Others commented that a more protective 
approach would be to phase out the use of solid wood packing materials 
and replace them with other materials, such as manufactured wood or 
plastic. In September 2005, California, Connecticut, Illinois, and New 
York sued USDA, claiming that the new regulations are not adequately 
protective and seeking a court order directing the agency to examine 
more effective and less environmentally harmful methods of preventing 
destructive insects from entering the country. 

Eradicating the Asian Longhorned Beetle Appears Likely, While Success 
on the Emerald Ash Borer and P. ramorum Is Less Promising: 

Evidence suggests that the Asian longhorned beetle will be eradicated, 
while the emerald ash borer and P. ramorum are likely to continue to 
infest and damage forest ecosystems indefinitely, despite efforts to 
control them. When first discovered, the areas infested with the Asian 
longhorned beetle were tens of square miles. Although the known 
boundaries of the infested areas expanded as surveys were conducted, 
government efforts in Illinois, New Jersey, and New York have been able 
to reverse the trend and reduce the size of the infested areas. Program 
managers with whom we spoke believed they could eradicate the beetle 
and end their program by 2014 if funding remained at 2005 levels. 
However, recent funding reductions raise doubts about achieving their 
goal by that date. In contrast, the areas infested with the emerald ash 
borer and P. ramorum were already many hundreds, if not thousands, of 
square miles in size by the time the pests were identified. While 
government agencies have taken steps to reduce the human-induced spread 
of these two species, the infestations are still growing, and few 
officials we spoke with believed that the pests can be removed from the 
natural environment. 

Program Officials Believed That the Asian Longhorned Beetle Will Be 
Eradicated: 

Eight of the nine stakeholders we interviewed regarding the Asian 
longhorned beetle believed that it will be eradicated from Illinois, 
New Jersey, and New York.[Footnote 8] APHIS's current goals for 
Illinois and New Jersey are to confirm eradication and end the 
management programs in 2008 and 2011, respectively. The current goal 
for completing the program in New York is 2014, although that estimate 
is dependent upon consistent and adequate funding. 

The stakeholders' opinions on the likelihood of eradication are based 
on a number of factors, including the relatively small areas of 
infestation and the success to date in eradicating the beetle in nearly 
all of the Illinois locations and one of two locations in New Jersey. 
At their peak, quarantines covered 183 square miles in the three states 
(see figs. 4 and 5). 

Figure 4: Areas in New Jersey and New York Quarantined for the Asian 
Longhorned Beetle: 

[See PDF for image] 

[End of figure]

Figure 5: Areas in Metropolitan Chicago, Illinois, Quarantined for the 
Asian Longhorned Beetle: 

[See PDF for image]

[End of figure] 

After 2 years of surveys in these locations have shown no evidence of 
the beetle, program officials can begin removing the quarantines, and 
they have done so in some areas. According to agency guidelines, after 
4 years of negative surveys, program officials can declare that the 
beetle has been eradicated from these areas. 

Prior to the implementation of regulatory controls, the Asian 
longhorned beetle was spread artificially through the movement of wood 
products, such as firewood and wood debris. Program managers are 
confident that quarantines and other regulatory actions have stopped 
the artificial spread of the beetle. The natural spread of the Asian 
longhorned beetle has been very slow because it does not travel far 
from its original nesting site, unless forced to do so by a lack of 
food. In addition, adult beetles and the exit holes they create when 
they emerge from trees are relatively easy to see, and the public, 
having been educated about the beetle, has helped find new 
infestations. 

The damage to trees caused by the Asian longhorned beetle has been 
relatively minor in comparison to the threat USDA estimated it could 
pose and in comparison to the damage caused by the emerald ash borer 
and P. ramorum. The beetle attacks hardwood tree species that grow 
primarily in the eastern United States, including many that are valued 
in both urban and forested areas.[Footnote 9] While it appears that the 
beetle will be eradicated, according to USDA, if left unchecked the 
pest has the potential to do more damage to a wider range of hardwood 
tree species in North American forests than the Dutch elm disease, 
chestnut blight, and gypsy moth combined. Presently, the known beetle 
infestations have been confined to trees in large urban areas. For 
urban areas, USDA estimates that property owners and municipalities 
could lose 35 percent of their tree canopy cover and incur 30 percent 
tree mortality (1.2 billion trees), damage valued at $669 
million.[Footnote 10] Losses that are difficult to quantify include 
property value depreciation and the loss of the aesthetic and 
environmental benefits to property owners. If the beetle were to escape 
its current urban environment and establish itself in natural forests, 
USDA estimates that about 30 percent, or 71 billion trees on 
timberland, valued at over $2 trillion could be lost.[Footnote 11] 
(These are worst-case scenarios, and we present them to indicate the 
potential magnitude of the problem.) The $2 trillion does not include 
the adverse impact to such industries as forest products, maple syrup, 
and fall foliage tourism in the Northeast. Additionally, the spread of 
the Asian longhorned beetle could alter the ecological diversity of the 
natural forests in North America and significantly alter the tree 
makeup of wetlands. 

Other factors contributing to stakeholders' optimism about eradication 
of the Asian longhorned beetle include the existence of a focused and 
cooperative management team in each location and an effective mix of 
control measures, including good cooperative working relationships and 
an aggressive public outreach and education program. 

Eradicating the Emerald Ash Borer Does Not Appear Likely: 

None of the 12 stakeholders we interviewed believed that the emerald 
ash borer could be eradicated in the United States, given our current 
knowledge and level of effort. The areas infested with the emerald ash 
borer have exceeded 40,000 square miles in Michigan; Indiana; Ohio; and 
Ontario, Canada, and continue to grow (see fig. 6). The pest has spread 
by both natural and artificial means. Research has shown that ash 
borers, particularly mated females, are capable of flying several 
miles. Government studies have used the estimate that ash borer 
populations can spread 5 to 10 miles per year as they grow in number 
and search for new host trees. More dramatically, the artificial 
movement of the pest in infested logs, firewood, or nursery trees can 
start new infestations hundreds of miles away. 

Figure 6: Areas with Emerald Ash Borer Infestations in Indiana; 
Michigan; Ohio; and Ontario, Canada, as of January 2006: 

[See PDF for image] 

[End of figure] 

According to the Michigan Department of Agriculture, the ash borer has 
killed an estimated 15 million trees and has caused "staggering costs 
for tree removal, disposal, and replanting [that] have overwhelmed 
local units of government." There are16 species of ash trees in North 
America, and all are believed to be vulnerable to the ash borer (see 
fig. 7 for the geographic range of ash species).[Footnote 12] Several 
stakeholders with whom we spoke were concerned that all ash species in 
U.S. forest were at risk. USDA also estimated that the cost of removing 
and replacing dead ash trees in urban and suburban areas could reach $7 
billion over a 25-year period.[Footnote 13]: 

Figure 7: Approximate Range of North American Ash Tree Species: 

[See PDF for image] 

[End of figure] 

The current federal management approach calls for eradicating the ash 
borer in Indiana and Ohio and containing, but not eradicating, the ash 
borer in Michigan. This approach reflects the enormity of the task of 
trying to eradicate the pest in Michigan, given its widespread 
distribution and the lack of low-cost management tools. What it means, 
though, is that even if the program is able to contain the beetle 
within Michigan, the pest will continue to kill ash trees across the 
Michigan landscape and also continue to pose a threat to other states. 
While several stakeholders told us they believed that North American 
ash species are in danger of being eliminated as a component in 
forested areas, others suggested that it is possible to slow the spread 
of the ash borer as has been done with the European gypsy moth. A 
significant difference between those two pests, however, is that while 
the gypsy moth is a serious tree defoliator, it does not inevitably 
kill trees as the ash borer does. 

Eradicating P. ramorum--the Pathogen That Causes Sudden Oak Death--Does 
Not Appear Likely: 

None of the 16 stakeholders we interviewed believed that P. ramorum 
could be eradicated from California's natural environment because of 
the current size of the infestation, its potential for spread, and the 
lack of effective management tools.[Footnote 14] The area currently 
infested by P. ramorum has exceeded 19,000 square miles in central 
California and continues to grow as the pathogen is spread by both 
natural and artificial means (see fig. 8). 

Figure 8: Map of Area Infested with P. ramorum in California and 
Oregon, as of December 12, 2005: 

[See PDF for image] 

[End of figure] 

One stakeholder who is familiar with forest pathogens stated that no 
invasive forest pathogen has ever been eradicated from North American 
forests. Consistent with this belief, the USDA management strategy in 
California calls for control of P. ramorum in the natural environment, 
rather than eradication.[Footnote 15] APHIS and state agencies are, 
however, striving to eradicate the pathogen from nursery environments 
to reduce the risk that infected ornamental plants will spread the 
pathogen throughout the country. Six stakeholders--federal, state, and 
nursery officials--told us they believed the pathogen could be 
eradicated from nurseries, a belief bolstered by evidence of the 
control of other Phytophthoras in nurseries. 

In the United States, the only known forest infested with P. ramorum 
outside of California is a small area in Curry County, Oregon (see fig. 
8). Oregon, with assistance from APHIS and the Forest Service, is 
working to eradicate this infestation. Five of the 16 stakeholders-- 
federal, state, university, and nursery officials in Oregon--we 
interviewed told us that they believed small-scale eradication efforts 
such as this can succeed. 

Research has shown that the pathogen thrives in wet, moist weather, and 
spores from infected plants spread naturally in water, air, or soil. 
People and animals can also track spores into uninfected areas, and the 
movement of infected plants or soil could start new infestations across 
the country. P. ramorum is known to threaten and could potentially kill 
numerous species of oak in North America and kill other trees, such as 
tanoak (not a true oak species). P. ramorum can also infect, but not 
necessarily kill, other trees, including California bay laurel, as well 
as ornamental plants, such as rhododendron and camellia. P. ramorum has 
already killed tens of thousands of tanoaks, coast live oaks, and black 
oaks with a mortality rate as high as 85 percent in some areas of 
California. A preliminary risk map created by the Forest Service, on 
the basis of potential pathways, susceptible plant species, and 
favorable weather conditions, shows that the natural areas at highest 
risk for P. ramorum are in the coastal areas of California, Oregon, and 
Washington and the Appalachian Mountains (see fig. 9). 

Figure 9: Forest Service P. ramorum Risk Map: 

[See PDF for image] 

[End of figure] 

Many stakeholders believe that the tanoak--a valuable tree for 
wildlife, certain Indian tribes, and soil stability along steep 
inclines--is in danger of being eliminated as a component of the forest 
understory in California and Oregon because of P. ramorum. However, the 
same risk does not apply to true oak trees because they have shown 
greater resistance to the pathogen. Still, the potential threat to the 
commercial timber industry could exceed $30 billion dollars if P. 
ramorum were to become established in Eastern deciduous forests. 
California timberlands alone are valued at over $500 million for forest 
products. In addition to the timber industry, the potential impact of 
the pathogen on the U.S. nursery industry is high. Since detection of 
the pathogen in a Santa Cruz nursery in 2001, damage to the nursery 
industry has been estimated to be between $3 and $17 million, not 
including lost sales. The California Association of Nurseries and 
Garden Centers estimated that California nurseries lost $25 million in 
sales in the spring of 2004 alone when other states prohibited nursery 
shipments from California. In addition, the economic impact on 
homeowners is potentially significant if trees that contribute to 
property value are lost to the disease. The cost of removing infected 
trees, such as large ornamental oaks, is also high, anywhere from $500 
to $5,000 per tree. According to a Forest Service official, there are 
no government reimbursement programs to cover tree removal costs, 
except in Oregon where federal funds are used for eradication purposes, 
including tree removal on private lands in the Curry County quarantined 
area. 

Efforts to Eradicate These Pests Have Been Affected by Several Factors: 

Several factors have affected the federal response to these three 
infestations. First, specific biological characteristics of each 
species affect the ease with which the pest is detected and its ability 
to move across the landscape. Second, in each instance, several years 
elapsed between the arrival of the pest and its discovery, thereby 
giving the pest time to become firmly established in the environment. 
Third, quarantines have helped to slow the spread of the pests, but 
they are difficult to implement and enforce. Fourth, in all three 
situations, program managers have noted that they lack cost-effective 
technologies for controlling the pests. Finally, insufficient funding 
has (1) restricted program managers' ability to use the tools they do 
have to minimize the spread of the pests and (2) raised concerns among 
managers about being able to achieve future goals. 

Biological Characteristics of Each Species Greatly Affect the Success 
of Control Efforts: 

The three invasive forest pests we reviewed are quite different 
organisms, and those differences have affected the success of 
management programs. The most basic characteristic is that two of these 
pests are insects while the third--P. ramorum--is a pathogen. More 
important, however, is how species-specific characteristics affect the 
relative ease of their detection; their ability to reproduce and move 
across the landscape; and their vulnerability to safe, available 
pesticides. The Asian longhorned beetle exhibits fewer of the 
characteristics that hinder control efforts than do the emerald ash 
borer and P. ramorum; hence control of the beetle has been more 
successful. 

Asian longhorned beetle: 

The Asian longhorned beetle has some biological characteristics that 
make its detection difficult, but others that make its management 
generally feasible. The beetle is a wood-boring insect that spends most 
of its life within the inner wood of its host tree, thereby hindering 
their detection during much of the year. During these months, the 
beetle can be easily and unknowingly moved in firewood, live trees, or 
fallen timber, thereby contributing to its spread; the beetle is also 
less vulnerable to insecticide applications during this time. In 
addition, government researchers have not been able to develop a lure 
that will attract the beetle to a trap. 

On the other hand, when adult beetles emerge from the trunks of trees, 
they are relatively conspicuous because of their size (up to 1½ inches 
long), their shiny black body with white spots, and their long antennae 
that are banded with black and white stripes. After emerging, the adult 
beetles also leave behind a conspicuous, perfectly round exit hole 
somewhat larger than the diameter of a pencil. In addition, females 
chew a small hole into which they deposit their eggs. Although less 
conspicuous than exit holes, these holes--known as oviposition pits-- 
are nevertheless useful in intensive detection surveys and allow for 
the detection and removal of trees before the eggs hatch and beetles 
emerge and spread to other areas. Exit holes may ooze sap and deposits 
of frass (i.e., insect waste and sawdust) that may collect on the tree 
trunk and limbs. In fact, it was the beetle's size and coloring that 
piqued people's interest and led to private landowners' detection of 
the beetle in Illinois, New Jersey, and New York. According to Asian 
longhorned beetle management officials, public reports of beetle 
sightings soar after public service announcements that discuss the 
beetle. While many sightings reported by the public turn out to be 
false leads because the beetle is similar to some noninvasive beetles, 
other sightings have been productive. For example, shortly after 
hearing about the beetle on a radio show about gardening, a New Jersey 
resident called with a report that led to the detection of one of two 
infestations in the state. The beetle's dispersal habit is perhaps the 
most important biological factor contributing to management success. 
One program official noted that the beetle is "lazy" and tends to 
remain on the tree from which it emerged, unless, for example, the 
beetle is forced to move to another host due to a shortage of food. In 
short, the beetle does not naturally spread quickly over large areas. 
When taken together, these characteristics have made it easier for 
management teams to detect, contain, and eradicate infestations. On the 
other hand, according to one state Asian longhorned beetle program 
manager, less than 1 percent of potential host trees are infested, 
thereby making detection of the beetle more difficult. 

Emerald ash borer: 

A number of biological factors contributed to the lag time between the 
start of the emerald ash borer infestation and the positive 
identification of the pest. First, the ash borer spends most of its 
life hidden inside trees. Female beetles lay tiny eggs in bark 
crevices, thereby making them difficult to detect. Visible symptoms of 
infestation, such as branch dieback and epicormic shoots, do not appear 
until at least 1 year after attack and could be attributed to other 
causes.[Footnote 16] When adult beetles do emerge from a tree, they are 
relatively small and inconspicuous. 

Once the ash borer was identified, scientists in the United States had 
little information to use in developing a control program. Only two 
short scientific papers were available from Asia that described the 
beetle's biology and habits. Similar to the Asian longhorned beetle, 
and in contrast to some other agricultural and forest pests, the ash 
borer is not known to respond to chemical lures. This appears to be 
typical of this family of beetle (Buprestidae) and has greatly hampered 
the management program's ability to define the extent of infestation. 

P. ramorum: 

Similar to the Asian longhorned beetle and the emerald ash borer, P. 
ramorum has several biological characteristics that have contributed to 
the pathogen's spread. First, unlike many forest pathogens, P. ramorum 
affects a wide range of host plants--ranging from common forest tree 
species, such as tanoaks and oaks, to common nursery species, such as 
rhododendron and camellias. P. ramorum infects species in more than 55 
plant genera, and the known number continues to grow as more research 
and monitoring is done. On the other hand, not all host plant species 
are equally vulnerable to the pathogen; while some species die from 
infections, others only show symptoms of ill-health. Infected plants 
act as carriers and help spread the pathogen to other plants. 

Another characteristic that makes managing P. ramorum difficult is that 
its symptoms can differ widely among host species and often resemble 
other diseases, making visual detection difficult. Symptoms appear 
seasonally and generally are of two types, bark cankers and foliar 
blights. Bark cankers, typically associated with oaks and tanoaks, 
often appear to be "bleeding" on the trunks of infected trees (see fig. 
10). The mortality caused by bark cankers can often resemble other 
conditions known as oak wilt and oak decline. 

Figure 10: "Bleeding" on Tree Trunk Caused by P. ramorum: 

[See PDF for image] 

[End of figure] 

The second type of symptom, foliar blight, appears on host plants--such 
as camellia and rhododendron--as spots or blotches on leaves, or shoot 
dieback. Foliar blight can serve as a reservoir of P. ramorum spores 
that may spread to other plants. Unlike bleeding cankers on oaks, hosts 
with foliar blight rarely die from the infection. Foliar blight can be 
confused with the symptoms caused by common fungi and other pathogens. 
Regardless of what host plant is suspected of having P. ramorum and 
regardless of what symptoms are seen, it is impossible to positively 
detect P. ramorum on-site. Samples of potentially infected plants found 
in nurseries must be sent to an APHIS-approved laboratory for 
diagnostic tests to confirm the presence of P. ramorum, which can be 
expensive and time-consuming. 

In addition to being difficult to detect, and therefore easily spread 
on nursery plants, P. ramorum is able to spread in water. Spores of the 
pathogen can travel in streams or even wind-driven rain or fog, making 
control of the spread very difficult, if not impossible, in the natural 
environment. 

Delays in Detecting and Identifying the Asian Longhorned Beetle, the 
Emerald Ash Borer, and P. ramorum Allowed These Pests to Become 
Established and Spread: 

For each of the three forest pests we reviewed, several years elapsed 
between the arrival of the pest and its discovery, thereby giving the 
pest time to become firmly established in the environment. 
Specifically: 

* Asian longhorned beetle: The Asian longhorned beetle is thought to 
have begun infesting trees in New York City in the mid-1980s. However, 
the beetle was not detected until 1996 by a homeowner who noticed 
suspicious holes in one of his trees. The homeowner thought the holes 
were the work of vandals, but upon investigation, government officials 
determined that the damage was caused by the Asian longhorned beetle. 
The beetle was known to APHIS port inspectors who had intercepted the 
beetle twice between 1985 and 1998 in solid wood packing material 
accompanying shipments from China. According to APHIS, inspectors 
probably intercepted Asian longhorned beetle larvae and the larvae of 
related species repeatedly before 1996, and would have taken mitigating 
actions to prevent their entry without needing to identify which 
species they were. However, despite its presence at U.S. ports and the 
potential for damage to natural resources, no systematic monitoring or 
surveys were performed to determine if the beetle had been introduced 
to the natural environment. Had such surveys been conducted, the pest 
might have been found years earlier. 

* Emerald ash borer: Government agencies misdiagnosed early symptoms of 
ash mortality in Michigan, thereby giving the emerald ash borer a 
running start that has greatly diminished the likelihood that control 
efforts will succeed. Scientists believe that the ash borer arrived in 
southeastern Michigan by the early 1990s in solid wood packing material 
accompanying products shipped from Asia. For several years prior to the 
detection of the insect, ash trees displayed high rates of sickness and 
death throughout metropolitan Detroit in southeastern Michigan. 
However, observers from government and academia attributed the 
mortality to other causes, including a native borer and a disease known 
as "ash yellows." A former forest health official with the Michigan 
Department of Natural Resources told us that the department did not 
focus its attention on monitoring the health of trees in developed 
areas within the state, such as suburban Detroit where the ash borer 
first appeared, but instead focused on state-owned forestland. The 
Michigan Department of Agriculture official leading the state's 
management program told us that agricultural inspectors did not 
identify the pest, in part, because they inspected trees in the fall 
after the ash borers had stopped flying and they did not see the 
inconspicuous exit holes that ash borers had made in the trees. It was 
not until June 2002 that state and university officials actually 
discovered that a nonnative insect was the cause of the tree mortality, 
and they sent a sample of the insect to an expert in Slovakia for 
positive identification. By then, however, the ash borer had already 
infested thousands of square miles. Following the new identification in 
Michigan, Canadian officials confirmed in August 2002 that the ash 
borer was also in Windsor, Ontario. 

* P. ramorum: Nearly 6 years elapsed between the first signs of tree 
mortality and the discovery of P. ramorum as the cause, in part because 
it initially affected trees that are not an economically valued 
resource. Scientists have not determined P. ramorum's source and do not 
know with precision when it arrived in central California. However, 
symptoms of declining health in tanoak trees were reported as early as 
1994. Tanoak is one of the main tree species that make up the 
understory of coastal redwood forests, and its acorns support abundant 
wildlife. However, tanoaks are not true oaks, and forestry officials 
generally consider them to be a weed species with little economical 
value. In 1997, when coast live oaks, an abundant and valuable 
landscape tree, began to show similar symptoms, local officials and the 
public called for a concerted effort to identify the cause. The Forest 
Service and the University of California provided the first funds for 
research in 1999. Initially, researchers believed that the symptoms 
pointed to other known possible causes, including insects or a 
condition known as standard oak decline. These possibilities needed to 
be ruled out before progress in addressing the disease could be made. 
Three forest pathologists now working on P. ramorum told us the lack of 
laboratories and forest pathologists at any level of government or in 
California's universities at the time contributed to the slow progress 
in ruling out these other potential causes and identifying the 
pathogen. Another delay came from resistance within the scientific 
community to accept the pathogen as a member of the genus Phytophthora, 
which typically affect a plant's roots and do not normally cause the 
symptoms that P. ramorum does. University researchers definitively 
identified P. ramorum as the causal agent in June 2000, but by then the 
pathogen had infested a widespread area. 

Although several years elapsed before government agencies identified 
these three pests, a recent case involving the citrus longhorned beetle 
in Washington State illustrates the value of early detection and rapid 
response. Following is a brief description of that situation. 

Figure 11: Citrus Longhorned Beetle (Anoplophora chinensis): 

[See PDF for image] 

[End of figure] 

Early Detection and Rapid Response Contributed to the Likely 
Eradication of the Citrus Longhorned Beetle. 

The value of early detection and rapid response is clearly demonstrated 
in the case of the citrus longhorned beetle (Anoplophora chinensis). In 
this instance, infested bonsai trees were inadvertently allowed into 
the country and shipped to a nursery. However, ongoing surveys appear 
to indicate that quick detection and response prevented the outbreak of 
a new invasive pest. This event also indicates the significant level of 
effort necessary to eradicate even a relatively small infestation. 

In August 2001, the owner of a nursery in Tukwila, Washington, found a 
citrus longhorned beetle in an imported maple bonsai tree being held at 
the nursery as part of routine 2-year plant disease quarantine. The 
beetle is native to parts of Asia and is not known to occur in the 
United States. It is related to the Asian longhorned beetle and is 
known to be a major pest of alder, maple, oak, poplar, and willow 
trees. It is also a pest of fruit trees, including apple and citrus. 

Washington State Department of Agriculture employees inspected the 
nursery and suspected that as many as five beetles, possibly including 
pregnant females, had flown from the quarantined trees to trees 
surrounding the nursery. USDA and the state formed a science advisory 
panel to address the issue of the beetle. The panel included personnel 
from USDA's Forest Service, Agricultural Research Service, and APHIS; 
Oregon's Department of Agriculture; and the University of Washington. 
The panel made recommendations to APHIS and Washington State in October 
2001. Citing the small area in which the beetle might be, the panel 
recommended control actions that it said might be considered 
unacceptably harsh if implemented at a larger scale, including removing 
known and potential host trees and treating remaining trees with 
insecticides. 

In November 2001, the Washington State Department of Agriculture 
quarantined all properties within a one-half mile radius of the 
nursery. On June 25, 2002, the Governor of Washington declared a state 
of emergency and authorized the state Department of Agriculture to use 
emergency measures to prevent or abate the infestation. In the summer 
of 2002, the state, in cooperation with APHIS, cut down and destroyed 
approximately 1,000 possible host trees within about one-eighth mile of 
the nursery. It also injected insecticide into about 1,500 potential 
host trees within one-quarter mile of the nursery. The state also 
implemented a revegetation program where the trees had been removed, 
which included giving vouchers to property owners. The state has done 
extensive surveying of the quarantined area in 2003, 2004, and 2005. 
For example, in 2005, state personnel surveyed more than 32,000 trees 
in and around the quarantined area and found no evidence of beetle 
activity. The state will continue to survey through 2006 and will end 
the program if it finds no evidence of the beetle. According to APHIS 
officials, the agency allocated about $2.2 million to Washington under 
a cooperative agreement in fiscal years 2002 through 2005, to carry out 
surveying, quarantine enforcement, and the eradication program. 

Stakeholders Believed That Quarantines Have Helped Slow the Spread of 
These Pests, but Implementation Is Difficult: 

Government quarantines have helped to slow the artificial spread of all 
three forest pests we reviewed by regulating activities that are 
possible conduits for transporting the pests. However, difficulties in 
quarantine implementation have minimized their effectiveness, 
particularly for the emerald ash borer and P. ramorum. Specific 
problems in implementation include a failure to quarantine the correct 
geographic area or all potentially infested materials in a timely 
fashion because of a lack of information about the pests or the extent 
of the infestations. In addition, because of the vast number of 
potential conduits for transporting the pests to new locations--namely, 
various seemingly benign actions of individuals--ensuring full 
compliance with quarantines is nearly impossible. Because of the nature 
of invasive species, even one quarantine violation may lead to a new 
infestation. As a result, enforcement efforts largely focus on public 
education and outreach as well as inspections. 

Quarantines Have Helped Limit the Artificial Spread of Pests: 

Officials involved with all three pests believed that quarantines have 
helped to reduce the spread of the pests. Quarantines help limit the 
spread of an invasive species by eliminating movement of potentially 
infested materials. However, few stakeholders involved with the emerald 
ash borer and P. ramorum programs (1 of the 11 and 2 of the 16 asked, 
respectively) believed that the quarantines had stopped all artificial 
movement of the pests. Stakeholders involved with the Asian longhorned 
beetle program were somewhat more optimistic about the effectiveness of 
the quarantines, with 4 of 9 stating that they have stopped the 
artificial spread, 2 saying that they have not, and 3 saying that they 
were uncertain. 

Under the Plant Protection Act, if APHIS considers it necessary to 
prevent the dissemination of a plant pest that is new to the United 
States or not known to be widely prevalent or distributed within and 
throughout the United States, the Secretary of Agriculture may take 
certain remedial measures, including quarantine of the plant pest, 
plant product, article, or means of conveyance that: 

"(1) is moving into or through the United States or interstate, or has 
moved into or through the United States or interstate, and the 
Secretary has reason to believe is a plant pest or is infested with a 
plant pest at the time of the movement or is in violation or has 
violated the Plant Protection Act; 

"(2) has not been maintained in compliance with a post-entry quarantine 
requirement; or: 

"(3) is the progeny of any plant, biological control organism, plant 
product, plant pest, or noxious weed that is moving into or through the 
United States or interstate, or has moved into the United States or 
interstate, in violation of the Plant Protection Act." 

In addition, APHIS may issue quarantines if it determines (1) that an 
extraordinary emergency exists because of the presence of a plant pest 
that is new to the United States or not known to be widely prevalent in 
or distributed within and throughout the United States and (2) that the 
presence of the pest or weed threatens U.S. plants or plant products. 
However, APHIS is only authorized to issue a quarantine under its 
extraordinary emergency authority upon finding, after review and 
consultation with the Governor or other appropriate official of the 
affected state, that measures being taken by the state are inadequate 
to eradicate the plant pest. Under state law, states might limit the 
movement of products within the state and, under certain circumstances, 
might regulate the importation of products from other states.[Footnote 
17] 

Quarantines have been used in each of the three forest pest 
infestations we reviewed. In each case, the quarantines identify 
specific geographic areas and plant materials to be regulated. For 
example, for the Asian longhorned beetle and the emerald ash borer, 
state and federal quarantines regulate or restrict the movement of 
regulated articles, such as firewood and wood debris, out of the 
quarantined areas. The areas include locations where the infestations 
have been found and a buffer area to account for potentially undetected 
spread of the pest. A key part of the federal and state quarantines for 
these pests has been education and outreach to the public and 
businesses that may unwittingly transport the pests. For example, 
firewood dealers, tree maintenance companies, and garden centers have 
been sent educational materials identifying particular pests and 
explaining the regulations and compliance issues. Much effort has also 
been put into educating the general public through displays at 
community fairs, homeowner association meetings, newspaper articles, 
and public service announcements. Program officials with whom we spoke 
believed that public education has helped to slow the spread of the 
pests and emphasized that it is critical to the success of the 
quarantines. 

Quarantines have played a vital role in containing the spread of P. 
ramorum through the movement and sale of nursery plants. The state and 
federal quarantines in California restrict the movement of regulated 
articles, such as certain plants, woody material, and logs, from a 14- 
county area that is known to have natural areas infested with the 
pathogen. The state and federal quarantines in Oregon are similar to 
the California quarantines, but they cover a much smaller area--22- 
square miles as of March 2006. In addition, under a USDA emergency 
order, APHIS now regulates all California, Oregon, and Washington 
businesses that want to ship plants susceptible to P. ramorum 
interstate; those businesses--regardless of whether they are in a 
quarantined area--must demonstrate that their products are free of the 
pathogen before being allowed to ship them. 

Quarantine Boundaries May Not Have Been as Inclusive as Needed Due to 
Limited Information: 

While officials believed that quarantines have helped to reduce the 
spread of the three forest pests, quarantine effectiveness is limited 
by the prevailing knowledge about a pest and the extent of the 
infestation. Quarantines must be based on sound scientific information 
because, as regulatory tools, they can have significant impacts on 
businesses, individuals, and the economy. For example, the quarantines 
on plant material from potential hosts to P. ramorum have resulted in 
the destruction of over $4 million worth of products in from one 
nursery in California. However, as we have previously discussed, much 
was unknown about the three pests when they were first discovered. As a 
result, quarantines were, in hindsight, conservative in their inclusion 
of areas to be regulated and, in the case of P. ramorum, in the plant 
material that was initially regulated. 

Regarding the Asian longhorned beetle, as surveys found new infested 
trees, the management team of federal, state, and local officials 
discussed and agreed upon new quarantine boundaries using protocols 
that accounted for known biological characteristics of the beetle and 
data on its dispersal patterns. Fortunately, the Asian longhorned 
beetle does not move quickly; therefore, infestations did not grow very 
rapidly during the time it took to definitively identify the extent of 
the infestations. This was not the case, however, with the emerald ash 
borer. Michigan imposed its initial quarantine for five counties in 
July 2002, not realizing that the infested area was already much larger 
than that. Similarly, USDA did not quarantine the interstate movement 
of ash material until October 2003, even though Ohio had discovered the 
beetle in February 2003, and it was likely to have been in Ohio for 
several years. Not having the infested area fully quarantined increases 
the chances that infested material will be moved to uninfested areas, 
either within the state or to new states. 

Although P. ramorum was detected from "bleeding" oaks and tanoaks in 
June 2000, Oregon issued an emergency quarantine for California in 
January 2001. California and APHIS imposed their first quarantines in 
May 2001 and February 2002, respectively.[Footnote 18] Program 
officials attributed at least part of the time lag in establishing the 
quarantines to the lack of knowledge about the pathogen--specifically, 
knowledge on how the pathogen was spread. State and federal governments 
must continue to adjust their quarantine regulations as scientists 
identify additional host and associated host plants in the natural 
environment. Initially, P. ramorum infestations were seen primarily in 
the natural environment, and stakeholders believed that if nurseries 
were infected it was because of exposure to infested natural areas. As 
a result, the original state and federal quarantines placed regulations 
on nurseries only within the quarantined area. These regulations 
required nurseries to enter into compliance agreements whereby they 
would certify that host and associated host plants were free of P. 
ramorum before shipping them outside of the quarantined area. At that 
time, nurseries outside of the quarantined area were not regulated and 
could freely ship host plants, because officials did not believe that 
they posed a high risk of artificially spreading P. ramorum. However, 
in May 2003, an investigation of infested camellias found within the 
quarantined area determined that the infected plants had come from a 
nursery outside of the quarantined area. The origin of the infestation 
in that nursery was unknown, and no P. ramorum was detected in the 
surrounding natural environment. Subsequent P. ramorum detections were 
made in nurseries outside of the quarantined areas in California and 
Oregon as well as the first case of P. ramorum in Washington (and 
British Columbia). Because surveys did not find the pathogen outside of 
these nurseries, the state and federal agencies did not establish 
quarantines in these areas. However, the finds did start a process that 
has led to restrictions on the interstate movement of nursery stock 
from nurseries outside of the quarantined areas. 

Enforcing Compliance with Quarantines Is Difficult: 

In each of the three forest pest species we reviewed, actions of 
individuals--such as moving firewood or even hiking--can result in 
transporting the pests to new locations. As a result, educating the 
public about activities that could spread the pests and then enforcing 
compliance with the quarantine are daunting tasks. For example, 
millions of ash trees in Michigan have died, creating a supply of 
firewood in a state where firewood is a large commodity. According to 
stakeholders with whom we spoke, the greatest risk of artificial 
movement of the emerald ash borer comes from the movement of firewood. 
The people likely to move firewood, including residents traveling to 
campgrounds or vacation homes and small firewood dealers, comprise a 
large and diverse population that is hard to define and reach with 
quarantine enforcement efforts. A similar situation exists in New 
Jersey and New York where movement of firewood or wood debris could 
easily spread the Asian longhorned beetle to new locations. 

Quarantines for P. ramorum are even more difficult to enforce because 
the pathogen can be spread in several ways. P. ramorum's natural 
infestation is in an area known as the wildland-urban interface, which 
is an area where houses meet or intermingle with undeveloped wildland, 
including several state and national parks, and that is estimated to 
have over 7 million residents. In addition to transporting infested 
firewood or debris, P. ramorum can also be spread in soil that is 
inadvertently moved on shoes, bike or car tires, or other equipment. 
Although state and federal agencies and nongovernmental organizations 
have produced several pamphlets to teach the homeowner, arborist, fire 
fighter, recreational land user, forest product gatherers, and others 
about how to decrease the risk of spreading the pathogen outside of the 
infested area, it is impossible to reach each individual who might come 
in contact with it. 

While stakeholders believed that outreach efforts have helped educate 
the public about the dangers of individual actions, such as moving 
firewood, it is not possible to stop all illegal or uninformed 
behavior. Potentially, all it takes is one piece of infested firewood 
or contaminated soil to start a new infestation. 

Agencies Lack Effective Technologies for Detecting and Eradicating 
These Forest Pests: 

Government agencies lack effective technologies to address the three 
forest pests we reviewed. Over three-fourths (29 of 37) of the pest 
managers we interviewed said that government agencies do not have the 
technological tools--such as detection, eradication, or prevention 
methods--to effectively manage these forest pests.[Footnote 19] 
Detection methods for these pests consist largely of visual 
observations and, in the case of P. ramorum, costly laboratory 
diagnostics. Such methods are not always effective, are time-consuming, 
and may have resulted in slower than desired management responses 
because of the time it takes to delineate infested areas. Current 
eradication methods for these three pests are limited to destroying 
infested trees and plant material--a resource-intensive action that is 
not practical on large infestations, such as the emerald ash borer or 
P. ramorum in California; destruction has been effective with the Asian 
longhorned beetle because many fewer trees have been infested. Although 
some preventative chemical treatments have been shown to be effective 
on the Asian longhorned beetle and emerald ash borer, these treatments 
are only used on the beetle because they are cost prohibitive when used 
on a larger scale. Research is under way to address these gaps. 

Delineating Infested Areas Is Resource Intensive and Not Always 
Reliable: 

Relying on visual detection has hampered thorough and rapid delineation 
of the infestations for all three forest pest species. For all three 
species, visual observations are the first sign of a potential problem. 
With the Asian longhorned beetle and the emerald ash borer, telltale 
signs include exit holes on tree trunks and branches. In addition, 
holes in which female Asian longhorned beetles lay eggs--known as 
oviposition sites--can also be a sign of infestation. However, in some 
cases, these visual signs of infestation may be very high in trees and 
not visible from the ground or inconspicuous because of their small 
size. As a result, ground-based surveys can often miss signs of 
infestations. For example, program officials stated that the 
effectiveness of visual observations of the Asian longhorned beetle 
from ground surveys were only about 30 percent accurate. Because of 
this, managers for the Asian longhorned beetle used bucket trucks and 
sought assistance from "smoke jumpers," (i.e., forest firefighters 
accustomed to climbing trees) and commercial tree climbers to improve 
surveying success. As a result, the effectiveness of visual inspections 
more than doubled. Surveys for the emerald ash borer also look for 
symptoms of infested trees, such as thinning crowns and dead branches. 
However, these symptoms appear gradually and may not provide rapid 
evidence of an infestation. In general, however, visual observations 
are still time-consuming and resource-intensive, particularly for 
widespread infestations, such as the emerald ash borer and P. ramorum. 
For P. ramorum, visual observations are just the first step in 
identifying potential infestations. To confirm the pathogen's presence, 
plant material must be sent to a laboratory for analysis. This process 
adds considerably to the time and cost required to make positive 
infestation determinations. Another option for identifying where pests 
occur is through the use of chemical lures that would attract beetles, 
borers, or other target pests if they were nearby. However, neither the 
beetle nor the borer responds to any known chemical lures. The emerald 
ash borer program uses what are known as "trap trees" to detect the 
pest. Trap trees are ash trees that have had a large strip of bark 
removed from the trunk. The premise is that wounded trees give off 
chemical signals that might attract the ash borer. The trees are later 
cut and inspected for ash borer larvae. However, government agencies 
have not clearly shown that trap trees attract the beetles. 

Research into traps, lures, acoustic devices, and remote sensing is 
ongoing to help with detection of the Asian longhorned beetle. Research 
is also under way to develop traps for the emerald ash borer that use 
chemical attractants. In addition, research is under way to develop 
better methods for detecting P. ramorum in the field. 

Methods for Eradicating Pests Are Limited to Destroying Infested 
Material: 

For each of the three forest pest species we reviewed, the only 
effective eradication method is to destroy the infested tree or plant 
material as well: 

as nearby trees and plants suspected of being infested.[Footnote 20] 
There are no chemical or biological treatments available to effectively 
kill the pests on a broad scale. In total, hundreds of thousands of 
trees and over 1 million nursery plants have been destroyed because of 
the three pests. For the emerald ash borer and the Asian longhorned 
beetle, infested trees are cut down, chipped to a very small size to 
kill any insect life stages that may be inside the tree, and then 
burned. This method is obviously very expensive and only practical on a 
relatively small scale. Due to the relatively small size of the Asian 
longhorned beetle infestations, cutting and burning has been used 
wherever infested trees were found. (Over 8,000 trees have been 
removed.) Conversely, for the emerald ash borer, managers have used 
cutting and burning selectively--although still removing hundreds of 
thousands of trees--by focusing on small, outlying infestations and at 
the perimeter of infestations in an attempt to contain the pest to 
specific areas. This approach lost momentum in January 2006, however, 
when the Indiana Department of Natural Resources announced that it no 
longer would require or fund the removal of infested trees because it 
did not believe that removal was working. Similarly, in February 2006, 
the Governor of Ohio announced that the state would be able to focus 
its eradication efforts only on extreme outlier infestations because of 
a lack of federal funding. 

In Oregon, trees infested with P. ramorum were first detected in 2001 
in a relatively small forest setting. According to the Oregon 
Department of Forestry, the infested acreage was initially determined 
to be 40 acres but has grown to 88 acres. This area was clearcut, and 
host plants were burned to destroy the pathogen. However, cutting and 
burning is not practical in California because the infested areas are 
so large and are intermixed with residential areas and old-growth 
redwood forests. In California, most tree removal is performed to 
remove dead and dying trees that pose safety hazards. One exception to 
this occurred in Humboldt County, California, in 2004 when a 
suppression project removed infected California bay laurel trees in an 
effort to limit the pathogen's spread. 

Destroying infested plants is routinely used to control P. ramorum in 
the nursery or "artificial" environment. There are more than 55 plant 
genera, many of which are sold to contractors and the public, which may 
transport the pathogen. If an infestation is found at a nursery or 
garden center, federal and state regulators inspect the facility to 
determine how much plant material needs to be destroyed to avoid 
spreading the pathogen to other locations. Such widespread destruction 
represents a huge loss to the nursery producer, particularly smaller 
operators. 

Research is ongoing in the area of chemical treatments to identify 
methods to kill these pests without requiring the removal and 
destruction of infested trees and plants. However, chemical treatments 
are problematic when used as a curative treatment for nursery plants 
against P. ramorum. For example, while fungicides are often used in 
nurseries to guard against pathogens and diseases, such treatments can 
retard the development of symptoms in already infected plants, thus 
effectively masking symptoms until such time that the effects of the 
treatments wear off. Consequently, such fungicides are not allowed on 
P. ramorum host plants that a nursery is holding to be destroyed 
because it may undermine detection of the pathogen. 

Research is under way to identify possible biological controls for the 
emerald ash borer, the Asian longhorned beetle, and P. 
ramorum.[Footnote 21] Some biological agents for the three pests show 
promise, but more research is needed. Biological controls have been a 
relatively effective treatment alternative to combat other invasive 
species, such as gypsy moth, on a large scale. However, it takes many 
years of testing before USDA will approve the use of biological 
controls with confidence that they will not prey on native species or 
create other problems. Research also is under way on all three species 
to better understand their biology and how they spread so that more 
effective management tools can be developed. 

Preventative Treatments Are Only Practical in Limited Applications: 

Chemical treatments are available that can be used on uninfested host 
trees surrounding an area that has been infested with any of the three 
forest pests we reviewed, in order to prevent or reduce subsequent 
infestation. These treatments have been used extensively by the Asian 
longhorned beetle program. To help ward off beetle infestation, a 
pesticide is injected into the ground or trunk of a tree near infested 
areas in the spring or fall; the process must be done on an annual 
basis for a minimum of 3 years to be effective. According to the 
national Asian longhorned beetle program manager, preventative chemical 
treatments provide effective control for the beetle when used as part 
of an integrated pest management approach. In contrast, preventative 
treatments have been used to just a limited extent on P. ramorum and 
the emerald ash borer, primarily by homeowners to protect valuable 
landscape trees, because the treatments are not practical or cost- 
effective on a larger scale. 

Insufficient Funding Has Delayed Eradication of the Asian Longhorned 
Beetle and Threatens Containment of the Emerald Ash Borer and P. 
ramorum: 

The federal government has provided the vast majority of the funds for 
controlling the three forest pests we reviewed, although funding 
limitations threaten the success of these programs. A large percentage 
of the federal funding for the pests has come from the Commodity Credit 
Corporation (CCC) to supplement congressional appropriations to APHIS's 
emerging plant pest program. However, program managers have noted that 
reductions in funding levels in both of these funding sources have 
pushed the expected eradication date for the Asian longhorned beetle 
out 5 years and have raised concerns about their ability to contain the 
emerald ash borer and P. ramorum. Reducing investments in control and 
eradication activities means that these pests will persist in the 
environment and may potentially spread to new locations, perhaps 
resulting in larger expenditures in the long run than if these 
infestations had been addressed more aggressively in the short term. 

Federal Funding for These Three Pest Programs: 

For the three pests we reviewed, the federal government has provided 
the majority of funding for programs to address the infestations, 
primarily through the CCC and appropriations to APHIS's emerging plant 
pest program. The Secretary of Agriculture, in connection with an 
emergency in which a plant pest threatens any segment of U.S. 
agricultural production, may transfer funds from CCC or other available 
USDA appropriations for the arrest, control, eradication, and 
prevention of the spread of the plant pest and related expenses. Use of 
CCC funds for pest management is significant. The Congressional 
Research Service reported that from 1998 through June 30, 2004, CCC 
transfers for all pest and disease management were more than the 
amounts appropriated for those activities ($1.52 billion versus $1.32 
billion). Over $420 million of federal funds have been budgeted for the 
three forest pests we reviewed (see figs. 12, 13, and 14). 

Figure 12: APHIS Funding for the Asian Longhorned Beetle Program, by 
Source, for Fiscal Years 1997-2006: 

[See PDF for image] 

Notes: 

For fiscal years 1997 and 1998, funding came from APHIS's contingency 
fund. 

The appropriation in fiscal year 2001 was from APHIS's Miscellaneous 
Pest line item. 

[End of figure] 

Figure 13: APHIS Funding for the Emerald Ash Borer Program, by Source, 
for Fiscal Years 2002-2006: 

[See PDF for image] 

Note: The Forest Service has also provided funding for emerald ash 
borer program activities, including tree planting, research, and 
projects intended to help businesses obtain economic value from ash 
trees before they become infested. From fiscal years 2002 through 2005, 
the Forest Service's State and Private Forestry Program and Research 
and Development Program allocated approximately $15.5 million for these 
activities. In fiscal year 2006, the Forest Service has about $3.1 
million in budget authority for these programs. 

[End of figure] 

Figure 14: APHIS Funding for the P. ramorum Program, by Source, for 
Fiscal Years 2001-2006: 

[See PDF for image] 

Notes: 

Congress appropriates funds to an APHIS contingency fund that the APHIS 
administrator has discretion to use for emerging problems. 

The Forest Service has provided funding for P. ramorum activities since 
fiscal year 2000. The focus at that time was on research to determine 
the causal agent of P. ramorum. From fiscal years 2000 through 2005, 
the Forest Service's State and Private Forestry Program and Research 
and Development Program have provided over $17 million for program 
activities, including research, risk analyses, and national monitoring 
and surveying efforts, and eradication efforts in Oregon. The Forest 
Service also has provided funding for the California Oak Mortality Task 
Force, a coalition of public and private stakeholders that provides 
public outreach and education efforts. For fiscal year 2006, the Forest 
Service has budgeted $2.7 million for continued P. ramorum program 
activities. In addition, other USDA agencies, such as the Agricultural 
Research Service and the Cooperative State Research, Education, and 
Extension Service, have provided over $3.5 million since fiscal year 
2002 for research and public education and outreach efforts for the 
program. 

[End of figure] 

States also provide funding for forest pest management actions, 
although it is generally much smaller than the federal investment. For 
the emerald ash borer, Indiana, Michigan, and Ohio have provided 
matching funds totaling about 2 percent of the funds that APHIS has 
provided from 2003 through 2005. For the Asian longhorned beetle, New 
York, New Jersey, and Illinois have contributed matching funds totaling 
about 17 percent of the funds that APHIS has provided from 1997 through 
2006. The P. ramorum program has obtained the largest nonfederal 
contribution as a percentage, with California contributing matching 
funds totaling about 34 percent of the funds that APHIS provided from 
2002 through 2006. 

All but 4 of the 37 stakeholders we interviewed believed that it is 
appropriate that the federal government bear the primary financial 
responsibility for dealing with these pests. A common comment from 
stakeholders was that APHIS is the nation's first line of defense in 
preventing invasive pests from entering the country, and if a pest 
should enter the country and become established, states should not be 
expected to bear the primary burden of addressing the consequences. 
However, stakeholders also believed that the states should bear part of 
the financial responsibility. Most did not have specific suggestions 
for what they believed would be an appropriate split between federal 
and state funding, although those that did have an opinion said that 
the state share should be anywhere from 0 to 50 percent. Others said 
that cost share arrangements should be based on the circumstances of a 
particular pest. In July 2003, APHIS published a proposed rule that 
would have established criteria for determining the federal share of 
the financial responsibility relative to states and other cooperators 
in a plant pest or animal disease emergency. However, the agency did 
not finalize the rule in accordance with a prohibition on the use of 
appropriated funds to finalize the proposed rule.[Footnote 22] 

Federal Funding Constraints Raise Concerns about Achieving Program 
Goals: 

Program officials involved with management of the three pests told us 
that either funding has not been what is needed or that they are 
concerned about the prospects for maintaining adequate programs because 
of funding constraints. Without sustained funding, containing the 
spread of the emerald ash borer and P. ramorum will be difficult, and 
eradicating the Asian longhorned beetle will take longer. In addition, 
the longer these pests are allowed to persist in the environment, the 
greater the risk that they may spread to new locations and the more 
expensive management programs could become. 

The Asian longhorned beetle program illustrates the consequences of 
inadequate and inconsistent funding on the time frames for and total 
cost of eradication. Specifically, in fiscal year 2002, program funding 
was cut by about $20 million and remained at close to that level in 
fiscal year 2003 (as shown in fig. 12). This caused program officials 
to terminate tree climbing and bucket surveys in New York, severely 
reduce chemical treatments of trees in New York from a planned 143,000 
trees to 17,570 actually treated (an 88 percent reduction), eliminate 
funding for restoration activities in Illinois and New York, and 
drastically reduce funds for research in fiscal year 2003. Program 
officials told us that this resulted in their target date for 
eradication being pushed out from 2009 to 2014. However, this assumes 
that they will receive about $48 million per year for each of these 
years. While funding was restored to nearly that level in fiscal year 
2005, the fiscal year 2006 appropriation is just under $20 million. 
Program managers told us that in addition to the risk of additional 
spread of the beetle during a longer eradication program, they have 
estimated significant cost savings if the beetle is eradicated sooner. 
They said that, compared with a $30 million funding level, sustaining 
funding at the $48 million per year level would (1) allow eradication 
by 2014 instead of 2020 and (2) save APHIS over $63 million; New York 
City about $36 million; and the state of New York about $12 million in 
avoided future costs, such as the disposal of wood debris from infested 
trees and the enforcement of quarantine restrictions. 

It appears that a similar situation is occurring with the emerald ash 
borer. Stakeholders we interviewed raised concerns that funding for the 
emerald ash borer program is not adequate to achieve the goal of 
limiting the infestation to Michigan. In fiscal year 2005, the program 
received just over one-half of what was estimated to be needed, and the 
outlook for fiscal year 2006 looks similar; Congress appropriated $10 
million to APHIS for the program, but it is unknown whether the 
Secretary of Agriculture will also transfer CCC funds. The $10 million 
appropriation is about one-third the amount that the program had 
estimated it would need. The APHIS national program manager for the 
emerald ash borer told us that funding shortfalls such as this limit 
tree cutting in infested sites, which would likely contribute to the 
artificial and natural spread of the pest. Program officials from 
Michigan and Ohio confirmed that their states will not be able to 
remove trees in key infested areas unless funding is increased. 

Nearly all stakeholders we interviewed also raised concerns that 
funding for the P. ramorum program has not been adequate to achieve the 
goal of limiting the infestation in either the natural or nursery 
environments. Funding for this program has varied significantly over 
the past several years in response to the resources needed to conduct 
intensive nursery surveys. For example, funding increased dramatically 
in fiscal year 2004 in response to the discovery that California 
nurseries had shipped infected plants to other states. Part of the 
reason for subsequent funding declines could be because fewer infested 
nursery shipments had been detected. The overall funding available from 
APHIS for fiscal year 2006 has dropped to about $3.1 million, and no 
CCC funding has yet been made available. This is the lowest level of 
funding since the nationwide shipment of infested plant materials in 
2004. However, program managers have not developed an estimate for 
funding needed to battle the pathogen. Therefore, it is unclear what 
impact this funding reduction will have on the program. 

In addition to the level of funding, some officials with whom we spoke-
-who were primarily involved with the emerald ash borer program-- 
discussed problems with the timeliness of when they actually received 
the funds. CCC funds can be transferred any time during the year, but 
program officials told us that they frequently received them after the 
optimal season to carry out certain preventive and control actions, 
such as tree removal or chemical treatments. For example, the national 
program manager for the emerald ash borer commented that if funding 
does not reach the program within the first few months of the fiscal 
year, it makes it very difficult to plan activities, contract for these 
activities, and hire and train personnel not knowing if the program 
will have sufficient funding received in a timely fashion. Another 
complaint about funding was the impact of the inconsistent amounts the 
programs receive from year to year. This reduces the ability of the 
managers to plan in advance for announcing contracts and securing 
labor. 

Finally, the extensive use of CCC funds for ongoing pest management 
programs has been debated within the federal government. In particular, 
the Office of Management and Budget (OMB) has expressed concerns with 
congressional appropriations committees for their not fully funding 
pest eradication programs, thereby necessitating the transfer of CCC 
funds.[Footnote 23] OMB has called the use of CCC funds for anything 
but unforeseen emergencies, and especially for ongoing eradication 
programs beyond the 1ST or 2ND year, "backdoor financing" that avoids 
the discipline of the budget process. In contrast, congressional 
appropriations committees have consistently reiterated that the 
Secretary should use the authority to transfer CCC funds for animal and 
plant health emergencies. One reason cited by Congress for continued 
use of the CCC fund is that the money is available for use until 
expended--so-called "no-year money"--whereas appropriated funds must be 
obligated within the fiscal year for which they are appropriated. This 
makes use of CCC funds more flexible in responding to the often dynamic 
situations in dealing with invasive species.[Footnote 24] Notably, as 
of February 2006, USDA had not announced any plans to transfer CCC 
funds to any of the three pest programs we reviewed for fiscal year 
2006. 

Forest Health Monitoring Does Not Adequately Address Urban Forests: 

USDA conducts a number of monitoring programs that are intended to 
identify forest health issues, including the presence of invasive 
species. However, because these programs do not adequately address 
urban forests, they did not detect the three forest pests we reviewed 
or other pests. Monitoring in urban areas is important because they are 
common destination points for internationally traded cargo that is a 
frequent pathway for pests. Delays in detection and identification 
allowed the three forest pests we reviewed to become established and 
spread before control efforts could begin. 

USDA Forest Health Monitoring Programs Cover a Variety of Geographic 
Areas and Forest Conditions: 

USDA has monitored the health of the nation's public and private 
forests for decades. Some programs are focused on broad issues, such as 
tree species composition and general health conditions, while other 
programs are focused on identifying specific problems. Key monitoring 
programs are described below: 

* Forest Health Monitoring Program: The Forest Service's Forest Health 
Monitoring Program is designed to determine the status, changes, and 
trends in indicators of forest condition on an annual basis; it has 
been conducted since 1990. The program uses data from ground plots and 
surveys, aerial surveys, and other resources to analyze forest health. 
In cooperation with state foresters, the agency conducts aerial surveys 
of more than 700 million acres per year to map tree mortality and 
defoliation. These surveys provide vital information for use in 
identifying, evaluating, and responding to the causes of forest health 
problems. According to the Forest Service, since 2001 the program has 
expanded its efforts in developing and implementing monitoring systems 
for undersampled populations (such as urban and riparian forests) and 
risk-based detection surveys for invasive forest pests such as P. 
ramorum. 

* Forest Inventory and Analysis Program: The Forest Service's Forest 
Inventory and Analysis Program--begun in 1930--now conducts a census of 
conditions on nearly all public and private forest lands in the United 
States. The program reports on status and trends in forest area and 
location; in the species, size, and health of trees; in total tree 
growth, mortality, and removals by harvest; in wood production and 
utilization rates; and in forest land ownership. Similar to the Forest 
Health Monitoring Program, the Forest Inventory and Analysis Program is 
implemented in cooperation with state agencies and private landowners. 
Traditionally, the Forest Inventory and Analysis Program was intended 
to provide information relevant to the forest products industry. In 
1999, the Forest Service merged the plot components of these two 
programs into a comprehensive monitoring framework that addresses a 
broad suite of forest health indicators. 

* Nonnative Bark Beetle Survey: In 2001, the Forest Service began a 
pilot of the Nonnative Bark Beetle Survey.[Footnote 25] The program 
targets 10 nonnative bark beetle species, although all bark beetles 
captured are identified. The former national coordinator for the 
program told us that the agency chose to focus on bark beetles for 
several reasons, including the fact that they are often intercepted at 
ports of entry. Risk assessments have shown that bark beetles cause 
problems in both their native range and in new locations, and that, in 
general, there are effective lures and traps for them. According to the 
Forest Service, funding for the program has increased from a starting 
point of $60,000 in fiscal year 2001 to $350,000 in each of fiscal 
years 2005 and 2006. 

Working with APHIS and state cooperators, the Forest Service has placed 
traps at more than 300 sites over the course of the program. Traps are 
typically kept at each site for 1 year. The sites have been in urban 
forests and forests around ports and wood-handling facilities and were 
chosen because of their relatively high risk for receiving insects from 
overseas. According to the Forest Service official who served as the 
national program coordinator from 2003 through 2005, the agency has 
shifted the placement of traps away from ports because it realized that 
cargo containers arriving from overseas are often shipped unopened 
further inland. Now, the program concentrates its traps near 
warehouses, landfills or recycling yards (where wooden pallets are 
handled), nurseries, and urban forests where pests that might be hidden 
in solid wood packing material are more likely to be released. He also 
said that APHIS is surveying near ports, so there was no need to 
duplicate its efforts. 

Since 2001, the project has detected six nonnative forest insects for 
the first time in the United States. According to the former national 
program coordinator, USDA has not taken management steps for the new 
finds, with the exception of additional surveying to define the extent 
of their infestations. He said that while the program has shown that 
new species can be detected using this method, it has not led directly 
to any successful management actions. On the contrary, the following 
two examples drawn from the six new species discoveries provide further 
evidence of the need for earlier detection and more rapid response. 

* In 2002, the bark beetle survey found a new wood-boring species in 
Georgia, known as Xyleborus glabratus. More traps were set out to 
delimit the extent of the infestation, but few of these beetles were 
found. According to the former national program coordinator, this 
species appears to be different from other bark beetles in that it does 
not respond well to known lures. That fact was not known at the time, 
however, and, according to the former coordinator, the beetle became a 
low priority for the Forest Service. However, in 2003, observers noted 
high mortality in Georgia and South Carolina for a common understory 
shrub known as red bay (Persea borbonia). This mortality was later 
attributed to a fungus associated with the beetle. Red bay is related 
to avocado, leading to concern that the beetle and fungus could affect 
that crop. According to the former coordinator, it is not possible to 
say whether the beetle could have been eradicated if a rapid response 
had been implemented after its discovery in 2002. He believed the 
beetle may have been in the country since the 1990s and was already 
widespread by the time it was detected. At any rate, he believed that 
it is now too late for eradication. 

* In 2003, the survey detected a beetle in Colorado and Utah known as 
the banded elm bark beetle (Scolytus schevyrewi). APHIS convened a New 
Pest Advisory Group in July 2003, which recommended conducting 
additional surveys for the beetle. By the fall of 2003, surveys had 
found the beetle in 13 states, and an examination of the state insect 
collection in New Mexico indicated that the pest had been in that state 
since at least 1998. This pest is known to infest many tree species in 
Asia, although it has been found only on elm in the United States. 
Significantly, the beetle could be a carrier of the pathogen that 
causes Dutch elm disease. APHIS has not implemented a management 
program for this species because it is so widespread. 

According to the Forest Service's director for forest health 
protection, the agency is considering expanding the Nonnative Bark 
Beetle Survey program so that one-third of all states would be 
participating in any given year. The former national coordinator for 
the program explained that some high-risk states would participate more 
often than once every 3 years, while low-risk states might participate 
once every 5 to 10 years. He estimated that a national program covering 
one-third of the states and averaging about 16 or 17 sites per state, 
would cost about $850,000 per year. This amount would cover the cost of 
supplies for traps, the salaries for surveying crews, the taxonomic 
expertise needed to identify the insects, and data management. He said 
that, in his opinion, a national program of that size would still be 
only "a drop in the bucket" compared with the need. Specifically, he 
said that there are far more high-risk sites that should be surveyed 
than would be covered by this program. He also noted that this program 
would survey for only bark beetles, and that additional funds would be 
needed to expand to include other insect groups. 

* The Cooperative Agricultural Pest Survey's National Exotic Woodborer/ 
Bark Beetle Survey. APHIS manages a survey program known as the 
Cooperative Agricultural Pest Survey. The agency cooperates with state 
departments of agriculture to survey for a specific list of plant 
pests, including insects, diseases, and weeds. The focus of the survey 
is on both agricultural and nonagricultural plant pest species. The 
list of species that APHIS and the states have agreed to survey for 
include at least 19 woodborers and bark beetles, including the emerald 
ash borer, the Asian longhorned beetle, and nine of the species 
targeted by the Forest Service program previously described. APHIS also 
encourages survey personnel to record and report detections of other 
forest pests made while conducting the prescribed woodborer and bark 
beetle survey. APHIS state plant health directors coordinate with state 
agencies to select high-risk sites to survey. These sites could include 
facilities that handle solid wood packing material, nurseries and 
dealers receiving shipments of foreign bonsai or other living woody 
plants, urban forests, parks, arboretums, and other high-risk 
locations. APHIS's survey procedures (1) call for routine reporting of 
survey data to the National Agricultural Pest Information System and 
(2) lay out specific steps for reporting new detections. 

* P. ramorum National Nursery Survey and National P. ramorum Survey of 
Forest Environments. In addition to inspections in regulated states, 
the P. ramorum National Nursery Survey and the National P. ramorum 
Survey of Forest Environments have contributed to the increased 
detection of infested nursery plant shipments. Started as pilot 
projects in fiscal year 2002, the P. ramorum National Nursery Survey 
and the National P. ramorum Survey of Forest Environments inspect high- 
risk nurseries that received plants from an infested West Coast nursery 
and forests adjacent to those nurseries as well as forests where host 
species are present.[Footnote 26] In fiscal year 2004, the Forest 
Service funded the forest surveys in 37 states and in 39 states for 
fiscal year 2005. Funding for the surveys increased dramatically in 
fiscal year 2004, following the shipment of thousands of infested 
plants from a nursery in Southern California. APHIS coordinates the P. 
ramorum National Nursery Survey with state agriculture departments, 
while the Forest Service works primarily with state forestry or natural 
resource agencies to conduct the National P. ramorum Survey of Forest 
Environments. Positive detections of the pathogen in nurseries trigger 
what are known as "trace backs" and "trace forwards," where inspectors 
attempt to locate either the origin of the infested plant or its 
destination if it was sold to a customer. In fiscal year 2005, the 
nursery survey identified 26 positive detections in 6 states, while the 
forest survey found no positive detections.[Footnote 27] According to 
the Forest Service director of forest health monitoring, the forest 
survey will be fully funded in fiscal year 2006. However, according to 
APHIS officials, the nursery survey may be limited in fiscal year 2006, 
due to a lack of funding. 

In addition to monitoring forest health issues, the Forest Service 
developed an early warning system in 2004 that can be used to quickly 
disseminate information in the event of a major forest pest 
occurrence.[Footnote 28] This warning system was established pursuant 
to a requirement in the Healthy Forest Restoration Act of 2003 to 
provide a comprehensive early warning system for potential catastrophic 
environmental threats to forests to (1) increase the likelihood that 
forest managers will be able to isolate and treat the threat before it 
gets out of control and (2) prevent epidemics that could be 
environmentally and economically devastating to forests.[Footnote 29] 
This system aims to integrate the various resources, programs, and 
jurisdictions with relevant authorities and expertise, including 
several agencies within USDA, the Department of Homeland Security, the 
Department of the Interior, the National Oceanic and Atmospheric 
Administration, state agencies, arborists, and others. The warning 
system does not create any new monitoring or management program; 
rather, it simply coordinates existing efforts. The Forest Service's 
Forest Health Protection Program runs the early warning system with 
assistance from a steering committee comprising representatives from 
key organizations and agencies. One purpose of the steering committee 
is to identify steps that are needed to improve the early warning 
system. 

The first step of the early warning system is to identify potential 
threats before they invade new ecosystems. In its early warning system 
document, the Forest Service noted several ways in which a variety of 
agencies' programs identify these threats, including maintaining 
databases on potential pests that have not arrived; conducting risk 
assessments to evaluate the likelihood that a specific organism may be 
introduced and become established; studying potential pests in their 
native environments so that if they do arrive in this country, more is 
known about how to manage them; and identifying pathways by which 
invaders may spread, such as solid wood packing material and live 
plants. The program steering committee concluded that one way to 
identify potential threats before they invade is to learn more about 
how potential invasive species will behave or react when they encounter 
probable host trees in the United States. The steering committee 
suggested that one method to do this would be to find or even plant 
trees native to the United States in other countries and then survey 
them to find any pests that attack them. 

The second step of the early warning system is detection of actual 
threats. We discussed several detection programs in previous text. The 
program steering committee identified the need to provide managers 
responsible for responding to pest outbreaks with improved 
communication regarding potential pest-caused damages found during 
regular surveys. The steering committee suggested that the early 
warning network could link surveillance efforts to the risks of 
introduction and establishment to address this need. The steering 
committee also noted that additional taxonomic expertise is needed to 
ensure that pests are being adequately identified. These observations 
are directly relevant to situations such as those created by the three 
pests we reviewed. 

Surveys for Potentially Harmful Forest Pests Do Not Adequately Cover 
Urban Areas: 

Many forest pests, including at least two of the three we reviewed, 
were first introduced in urbanized environments. However, while some of 
USDA's monitoring programs may cover these areas, they do not provide 
adequate coverage. Forest experts with whom we spoke said that, 
historically, urban forests have not been adequately monitored. In 
addition, in 1997 and 2004, the National Association of State Foresters 
passed resolutions stating that there is no systematic inventory and 
assessment of the nation's urban forest resource. In 1997, the 
association resolved that criteria and standards be established for a 
nationwide initiative to periodically gather comprehensive information 
relating to the inventory and assessment of our urban and community 
forests. In 2005, the association joined with the Forest Service in 
convening a task force of forestry stakeholders to (1) evaluate current 
urban forest inventory efforts, (2) investigate a national continuous 
urban forest inventory and assessment protocol, and (3) propose an 
implementing strategy. The task force has not yet produced a report or 
proposed strategy. 

Following the 1997 resolution by the state foresters, the Forest 
Service initiated a pilot project in 1999 in several states designed to 
improve urban forest health monitoring. The purpose of the project is 
to acquire information about the urban forest, while at the same time 
establishing a nationwide system of urban forest pest detection and 
forest monitoring and assessment. The project has two components. The 
first component seeks to extend the sampling grid of the Forest 
Inventory and Analysis, which has traditionally not sufficiently 
sampled urban forests. The second component seeks to implement a 
roadside tree assessment using plots established within public rights- 
of-way in urban areas.[Footnote 30] To date, the Forest Service has 
implemented pilot projects for one or more of these stages in Colorado, 
Indiana, Maryland, Massachusetts, New Jersey, Tennessee, and Wisconsin. 
According to the Forest Service's national program manager for forest 
health monitoring, the agency budgeted $850,000 from fiscal years 2001 
through 2005, and received a one-to-one match from the states for the 
pilot. The program manager told us the Forest Service projects a 
$175,000 budget for fiscal year 2006. Funding has come from both the 
Urban and Community Forestry Program and the Forest Health Monitoring 
Program. 

Since only seven states were covered by this pilot, systematic 
monitoring in urban areas is still not adequate. The director of the 
Urban and Community Forestry Program told us that one way to improve 
urban monitoring would be to survey Forest Inventory and Analysis plots 
that are in urban areas but that are not now surveyed because the 
Forest Service classifies them as "nonforest," even though they may 
have trees. The Forest Service estimates that extending the Forest 
Inventory and Analysis to urban sites on a rotating basis would cost 
about $2.5 million per year. The Urban and Community Forestry Program 
director said that there are no guarantees that new pests would be 
found by expanding the inventory, but that there is a strong case to be 
made for doing so because the potential costs of dealing with pests, 
such as the emerald ash borer, once they are established are 
staggering. Another, and perhaps a more likely, benefit of expanded 
urban monitoring is gathering better information on what trees comprise 
urban forests. Knowing what tree species are where will help prepare 
risk assessments related to specific pests. For example, knowing the 
extent of ash trees in urban settings is necessary to be able to 
calculate the potential for losses caused by the emerald ash borer. 

Coordination Problems Caused Concerns among Stakeholders, and 
Communication on the Status of Pest Responses Is Not Adequate: 

For each of the three pests, while a majority of the 37 stakeholders 
with whom we spoke told us that appropriate coordination mechanisms are 
now in place, many raised concerns about appropriate affected parties 
not being involved in or informed about key decisions early in the 
response effort. A common theme among the comments was that better 
early coordination would have strengthened the response efforts. New 
pest response efforts could avoid such concerns if attention is paid to 
the lessons learned from the three pest management efforts we reviewed. 
In addition, we note that USDA's management plans for the three pests 
do not adequately communicate current information to decision makers 
and the public about how recent developments, including funding 
reductions and the extent of the infestations, will affect the 
prospects for success. 

Stakeholders Generally Believed Appropriate Coordinating Mechanisms 
Exist, but Suggested Improvements That Could Aid Future Management 
Efforts: 

While the majority of the stakeholders we interviewed about each of the 
three pests believed that appropriate coordinating mechanisms were now 
in place, a majority also believed that improvements could be made to 
address problems that were encountered during the pest management 
efforts.[Footnote 31] (By coordinating mechanisms, we mean such things 
as interagency and intergovernmental management teams and panels of 
federal and nonfederal scientists.) Of the 37 stakeholders we 
interviewed, 30 stated that the federal and state governments had 
created appropriate coordinating mechanisms to respond to the three 
pest infestations. Of the 7 who stated that appropriate federal 
coordinating mechanisms were not in place, 5 were commenting on the P. 
ramorum program and included stakeholders from federal, state, and 
nursery organizations. While generally satisfied, the majority of 
stakeholders also believed that improvements could be made to federal 
coordinating mechanisms (29 of 37) and state coordinating mechanisms 
(22 of 37) to address concerns that they identified.[Footnote 32] 
Implementing actions to address these concerns could benefit the 
management of future pest response efforts. 

The most commonly suggested area for improvement concerned coordination 
among state agencies. Three of the Asian longhorned beetle 
stakeholders, 7 of the emerald ash borer stakeholders, and 8 of the P. 
ramorum stakeholders made comments about state agency coordination. 
While state agriculture agencies typically have primary responsibility 
at the state level for addressing invasive pest infestations, the 
management of those infestations may involve other state agencies, 
including departments of natural resources, forestry, and the 
environment. Several stakeholders commented on the need for state 
departments of agriculture and natural resources to work more closely 
together. For example, one state department of natural resources 
official commented that his department could not convince the state 
department of agriculture to survey for infestations in outlying areas. 
The result was a delay in the discovery of what turned out to be a 
large number of well-established outlying infestations. An APHIS state 
program manager commented that the departments of agriculture and 
natural resources in his state could have worked together better on a 
program designed to harvest trees for productive purposes before they 
fell victim to the pest. Doing so could have helped reduce the spread 
of the pest. One state official commented that he would like to see 
more work done by state agencies in addition to the department of 
agriculture, and that it would be helpful to have one person directing 
the work of all the state agencies. An APHIS official echoed this by 
observing that it was not clear which state agency has been in charge 
in dealing with one of the pests. Two state officials, 2 Forest Service 
officials, and 2 university research scientists suggested that states 
need to have a systematic response plan in place before an emergency 
occurs. Some of these officials said that such plans should identify 
who would be involved, what their roles and responsibilities would be, 
and how they would be funded. Having such a plan would facilitate a 
more rapid response to new infestations. 

Eleven of the 37 stakeholders commented that coordination among federal 
agencies--primarily, coordination between APHIS and the Forest Service-
-could have been improved during the initial phases of the pest 
responses. Most of these comments--8 of 11--came from P. ramorum 
stakeholders. Across the three pests, stakeholders attributed 
coordination concerns in part to the differing missions of the two 
agencies. For example, 1 state official said that, in the case of the 
Asian longhorned beetle program, the Forest Service "tends to sit back 
and watch when the agency should be proactive in working with APHIS in 
addressing invasive pests." Somewhat in contrast, an APHIS official 
working on the emerald ash borer commented that the management team had 
not made good use of the possible contributions of the Forest Service 
regarding a program intended to harvest and use trees before they 
became infested. This official also said that the management team could 
have made better use of the USDA's cooperative extension agents to 
educate the public about the pest and its potential impact.[Footnote 
33] An academic research scientist commented that APHIS did not become 
involved with P. ramorum until the pathogen showed up in nurseries, but 
then did not seek input from the Forest Service in the regulatory 
process. 

Two local government stakeholders also raised a concern about the 
organization of the Asian longhorned beetle program in New York. They 
commented that APHIS had established three work units in New York City, 
with one each in Manhattan, Queens, and Brooklyn. According to these 
stakeholders, the three offices do not consistently record or report 
data on the surveying operations or tree infestations. The local 
officials said that they had difficulty obtaining data from these work 
units for their own analysis. In response to this comment, the APHIS 
national program manager for the Asian longhorned beetle said that, 
because of its size and complexity, there are three work units in New 
York City managed by state and federal supervisors acting as a unified 
command. The geographic areas those work units cover represent unique 
challenges that at times require different approaches. The local 
officials also expressed the opinion that APHIS should have one 
regional management board for New York and New Jersey. Considering the 
close proximity of these infestations, the stakeholders suggested that 
a single regional management team could have sufficed and provided more 
transparency and consistency in managing the beetle. They noted that 
multiple management teams sometimes took inconsistent actions that were 
noticed and questioned by citizens. The APHIS national program manager 
noted that there are separate management boards consisting of federal, 
state, and local cooperators overseeing the programs in New York, New 
Jersey, and Illinois, and that APHIS program managers are represented 
on all of the boards to ensure coordination and consistency. Within 
each state, strategic actions are impacted by state and local 
authorities that may lead to differences in the approach used to 
execute the eradication protocols in each state. 

Ten of the 37 stakeholders commented that improvements are needed in 
coordination between federal and state agencies. The 10 stakeholders 
were evenly split between the emerald ash borer and P. ramorum 
programs. Some of their comments reflect the challenge of obtaining a 
consensus among different levels of government on how to carry out the 
management program. For example, APHIS officials commented on 
variations in which state agencies regulate the use of pesticides. 
Specifically, they noted that they had more success coordinating 
pesticide use with state departments of agriculture than with a state 
environmental protection agency. Delays in pesticide application could 
hamper efforts to slow the spread of the pest. Those same APHIS 
officials observed that state officials were at times reluctant to use 
what authority they might have to inspect trees on private property 
because of concerns over "political fallout." Again, such delays could 
hamper the program's ability to detect and treat infestations. Another 
APHIS official complained of not getting strong state support for 
"routine" regulatory matters. Two APHIS officials commented that the 
agency should make better use of its cooperative agreements with states 
to direct those states' activities. Developing more specific 
cooperative agreements would require better coordination between the 
parties and would increase accountability for how federal funds are 
spent. A state department of agriculture manager told us that closer 
coordination with his APHIS counterpart could have reduced differences 
in interpretation of quarantine provisions and, therefore, could have 
improved enforcement. 

Eight of the 37 stakeholders also said that they believed coordination 
would be improved if a wider range of stakeholders were involved in the 
management response to the infestation. Of the 8 stakeholders, 4 were 
speaking about P. ramorum coordination, 2 about the emerald ash borer, 
and 2 about the Asian longhorned beetle. An opinion expressed by some 
of these stakeholders was that responses to pest infestations are more 
effective when all affected or potentially affected parties participate 
in the decision-making process regarding their management. The primary 
mechanism APHIS uses to bring affected parties together and coordinate 
an appropriate pest response is to establish a management team 
comprising federal, state, and local officials as appropriate. 
Stakeholders for each of the pests in our review noted that key 
affected parties were not adequately included in this management 
process. Some of the affected parties that stakeholders believed should 
be more involved include the following: 

* other states that are at risk of receiving pests from the infested 
states; 

* industries that are at risk if the pests are not contained, such as 
nurseries and maple syrup; 

* local officials who can educate their citizens about the pests and 
the harm that they can cause if left unmanaged, thereby gaining citizen 
cooperation in addressing the pests; and: 

* nonprofit groups that are involved in forestry activities and can 
assist in pest surveys and public education and outreach. 

In response to these comments, the national program manager for the 
emerald ash borer program noted that other states were included in the 
management team as soon as it became clear that the infestation was not 
confined to Michigan, and that adjacent states and affected industries 
were notified of the potential threat. 

The Status, Direction, and Resource Needs of Pest Response Efforts Are 
Not Clear from Publicly Available Management Plans: 

Because the success of efforts to control invasive species depends, in 
some part, on public participation, the National Invasive Species 
Council's guidelines on early detection and rapid response systems 
stress the importance of providing timely information to decision 
makers and the public.[Footnote 34] The council identified access to 
the most recently updated scientific and management information as some 
of the fundamental elements of a rapid response system. While much of 
this information remains static once a certain level of knowledge on 
the pest has been reached, specific program information--such as 
strategic plans, program goals and objectives, status of activities, 
planned future activities, estimated eradication date, and identified 
funding needs--are dynamic and should be updated regularly in order to 
reach decision makers and the public in a timely manner. 

The P. ramorum, Asian longhorned beetle, and emerald ash borer programs 
have all issued management plans that are described in the bulleted 
text below; however, timely updates to plans, including estimated 
funding needs, and the status of program efforts have not always been 
available for the three species. For example, plans outlining 
suppression or eradication goals are outdated or incomplete for the 
three pests. In addition, the P. ramorum management plan does not 
contain required cost estimates for the implementation of future 
efforts necessary to control and manage Sudden Oak Death caused by P. 
ramorum. 

* In December 2004, Congress required APHIS--subject to the 
availability of appropriated funds--to develop a national plan for the 
control and management of Sudden Oak Death caused by P. 
ramorum.[Footnote 35] USDA was required to address the following three 
issues in the plan: (1) information on ongoing efforts to identify P. 
ramorum hosts and survey the extent to which Sudden Oak Death exists in 
the United States; (2) past and current efforts to understand the risk 
P. ramorum poses and the results of control and management efforts 
regarding Sudden Oak Death; and (3) future efforts considered necessary 
to control and manage Sudden Oak Death, including cost estimates for 
the implementation of such efforts. In September 2005, USDA released 
its strategic plan for P. ramorum that sets a goal of controlling the 
pathogen by prohibiting its introduction into noninfested regions of 
the country, not by eradication. The plan outlines a risk management 
option that identifies preventing the artificial spread of the pathogen 
through commerce, with regulations and quarantines as the most 
effective technique to combat P. ramorum. The plan also identifies the 
agencies responsible for identifying hosts, conducting national 
surveys, and assessing risks--elements of the first two requirements of 
the law.[Footnote 36] However, although the plan includes a summary of 
prior federal and state funding for P. ramorum, it does not include an 
estimate of the cost of anticipated activities. USDA stated in the plan 
that future resource needs were difficult to project due to the 
"interaction of complex circumstances" but did not identify in the plan 
what future scenarios could take place, the activities associated with 
those scenarios, or their estimated costs. 

* The Asian longhorned beetle management plan for Illinois and New 
York, released in 2000 and available on APHIS's Web site, estimated 
eventual eradication of the beetle in 2008 for Illinois and 2009 for 
New York. These program goals were based on a series of multiyear 
strategies to contain, control, deregulate, and eventually eradicate 
the beetle, beginning in fiscal year 2001. However, a significant 
decrease in funding in fiscal year 2002, combined with a similar level 
of funding in fiscal year 2003, delayed the multiyear strategies for 
several years in New York, leading APHIS to revise the estimated 
eradication date for New York to 2014 or 2020, depending on funding 
levels. As we have previously discussed, the fiscal year 2006 
appropriation for the Asian longhorned beetle is significantly lower 
than the agency believes is necessary to meet either the 2014 or 2020 
date. However, APHIS has not updated the plan for the Asian longhorned 
beetle to reflect this change or to incorporate recently identified 
infestations in New York City, nor does it contain information on the 
agency's revised estimate of funding needs. According to the national 
program manager for the Asian longhorned beetle, APHIS is in the 
process of updating the strategic plan and anticipates a final version 
will be available by mid-2006. However, the plan is not likely to 
include information on projected funding needs. 

In 2002, following the identification that year of new infestations in 
Jersey City, New Jersey, APHIS developed a separate plan calling for 
eradication in this location by 2008. This APHIS plan--which is not 
available on the agency's Web site--does not include an estimate of 
funding needs for the work in New Jersey. Because APHIS has not updated 
the 2002 plan, it does not reflect the detection in 2004 of an 
additional large infestation in Middlesex and Union Counties, New 
Jersey. (APHIS has told us that it has established 2011 as the target 
eradication date for these two counties.) The passage of time and the 
changes in the extent of the infestations and actual funding levels 
have caused the latest agency plans for New Jersey and New York to be 
significantly out of date. Without a unified plan that reflects those 
changes, decision makers and the public do not have an accurate picture 
of the status and future of the Asian longhorned beetle management 
program. 

* APHIS's emerald ash borer program posted on its Web site in May 2005 
a management plan that spelled out the goal of removing trees infested 
with the pest in three strategically placed gateways: one on Michigan's 
eastern border with Canada, one along Michigan's southern border with 
Indiana and northern Ohio, and one south of the Mackinac Bridge leading 
to the Upper Peninsula of Michigan. The immediate objective of this 
strategy is to eradicate the pest in Indiana and Ohio and keep it 
contained within the Lower Peninsula of Michigan. The APHIS plan 
contained an estimate that a long-term eradication program could be 
completed in Indiana and Ohio by 2016, and in Michigan by 2018, 
assuming certain levels of funding. The plan included estimates that 
over $384 million would be needed to achieve the objective, including 
$43 million in fiscal year 2005 and $34 million in fiscal year 2006. 
However, two developments have raised doubts about the agency's 
estimates. One development is that actual funding in fiscal years 2005 
and 2006 has not reached the levels APHIS believed were needed, and the 
states were not able to complete planned eradication projects. The 
other development is that the program has found additional 
infestations, including some beyond the gateway areas. Given these 
circumstances, in addition to the lack of adequate control 
technologies, none of the emerald ash borer stakeholders we 
interviewed--including members of the management team--believed that 
eradication is possible. Despite these conditions, the management team 
has not issued an updated plan with revised objectives, timetables, or 
funding needs. One change that the team did make was to remove the 
timetable and cost estimates from the publicly available strategic 
plan, although this does little to convey the government's approach and 
expectations for the program. 

Science Advisory Panels Have Assisted with the Pest Response Efforts, 
but There Are Concerns about How They Were Formed and Operated: 

Program managers believed that the panels comprising federal and 
nonfederal scientific experts to help the agency respond to each of the 
three pests we reviewed have been useful. USDA does not have specific 
procedures for how the panels should operate, and the agency operated 
the panels for the three pests quite differently. The USDA management 
programs for the emerald ash borer and the Asian longhorned beetle 
created science panels that were tasked with giving advice on 
management approaches. The emerald ash borer team has met at least 
annually for 4 years, while the Asian longhorned beetle team met once 
in 1996 but has not met since then. The director of APHIS's emergency 
pest program told us that the Asian longhorned beetle advisory panel 
met the objectives of the management team when it operated in 1996, and 
that the management team did not need it in subsequent years. He also 
said that the management team has consulted directly with appropriate 
scientific experts when needed and could call the advisory team back 
together if necessary. In contrast, the APHIS P. ramorum program 
created a science panel that had the charge of providing information 
but not recommendations. In June 2004 in Raleigh, North Carolina, APHIS 
convened a panel of approximately 75 federal and nonfederal scientists 
and regulators from North America and Europe with expertise in 
Phytophthora species. The APHIS national program manager for P. ramorum 
told us that he believed that the panel was helpful, but that a panel 
charged with providing advice and recommendations, perhaps under the 
requirements of FACA, was also needed because of the evolving science 
concerning the pathogen.[Footnote 37] 

While the panels have generally been helpful, some stakeholders raised 
concerns about their operation and use. Specifically, 10 of the 37 
stakeholders commented that the use of the panels could have been 
improved. Five stakeholders, collectively addressing all three of the 
panels, stated they thought improvements were needed in how the science 
panels communicated with management teams and with others. For example, 
1 stakeholder criticized USDA for not explaining why the Asian 
longhorned beetle advisory panel was used only at the very beginning of 
the management program. Four stakeholders (including 1 of the 5 just 
mentioned), also collectively addressing all three panels, thought that 
more frequent meetings were needed. One panel member, a federal 
research scientist, told us that a lesson he has learned is that for 
pests about which little is known, there needs to be significant input 
and consultation from scientific experts. He believed that in the case 
of the emerald ash borer, the panel has needed to meet more often than 
in other pest situations because so little is known about this pest. 

USDA did not choose to charter the emerald ash borer and Asian 
longhorned beetle advisory panels under FACA, and the scope of our work 
did not include making a legal judgment on whether they should have. 
However, there are certain principles in FACA that, if included in 
operational procedures for pest advisory panels, could help to minimize 
criticism of the sort that we heard. Specifically, the act requires 
that all committees have a charter, and that each charter contain 
specific information, including the committee's scope and objectives, a 
description of duties, the estimated annual operating costs, and the 
estimated number and frequency of meetings. FACA advisory committee 
charters generally expire at the end of 2 years, unless renewed by the 
agency or by Congress. This encourages the agencies to reexamine 
whether the committees are still needed. FACA also contains general 
requirements that committees be fairly balanced in terms of points of 
view represented and the functions to be performed by the committee, 
and FACA generally requires that committee meetings be open to the 
public. 

Conclusions: 

Forest pests have caused substantial damage in the past and continue to 
pose a serious threat to the nation's environment and economy. We 
recognize that forest pest managers face a host of challenges--some of 
which are daunting--that constrain their ability to successfully 
eradicate new pests. These challenges include the unique biological 
characteristics of particular species and the lack of existing 
eradication technologies. However, information derived from past 
infestations and the three forest pests we reviewed makes it clear that 
early detection and rapid response to new infestations are critical to 
improving the likely success of effectively controlling invasive forest 
pests. More specifically, it is likely that without broader early 
detection systems, especially in urban areas because they are at high 
risk of receiving invasive insects and diseases, future infestations 
that are costly and difficult to eradicate will occur. We also found 
that the status of the three pest response efforts was not clearly 
communicated to the public and other key stakeholders, particularly 
information regarding the setbacks that the programs will face due to 
recent funding reductions. Additionally, it was also not clear to us 
and stakeholders how science advisory panels were used and operated in 
the pest response efforts. Clear and current communication on these 
efforts is important since infestations affect many agencies, 
businesses, and individuals, and the control efforts rely on the 
actions of many entities beyond just the federal players. 

Recommendations: 

To improve federal efforts to detect, manage, and eradicate 
infestations of invasive forest pests, we are recommending that the 
Secretary of Agriculture take the following three actions: 

* Expand current efforts to monitor forest health conditions, 
particularly in urban and suburban areas that are at high risk of 
receiving invasive insects and diseases. USDA's monitoring program 
should incorporate guidance on early detection issued by the National 
Invasive Species Council in 2003. 

* Prepare, publish, and regularly update management plans for pests for 
which the department has initiated a management program. The plans and 
their updates should incorporate and describe changes in the extent of 
infestation; progress to date in control and eradication efforts; 
schedules for future control and eradication efforts, given known 
levels of funding; and future long-term funding needs. For the P. 
ramorum program in particular, an updated management plan should 
include the elements called for by law that were not included in USDA's 
2005 plan, such as an estimate of the cost of anticipated activities. 

* Implement written procedures that broadly define when and how to 
operate panels of scientific experts for the purpose of assisting pest 
management teams, including a discussion on how to determine when such 
panels should be chartered as advisory committees under FACA. 

Agency Comments and Our Evaluation: 

We provided a copy of our draft report to USDA. The department provided 
written comments (see app. VII). Overall, USDA said that the report was 
comprehensive and well written. However, the department expressed the 
viewpoint that the tone of the report was overly critical and gave an 
unfavorable impression of the work done by the agencies to respond to 
the three forest pests. USDA also offered comments on our 
recommendations. With respect to the tone of the report, the department 
emphasized that little was known about these pests before their arrival 
in the United States, and that federal and state agencies did a 
reasonable job under those circumstances. We agree with USDA's comments 
that P. ramorum was unknown to science before its arrival and that 
little was known about the emerald ash borer, and we made those points 
in the report. We disagree that the Asian longhorned beetle was unknown 
as a potential threat before its arrival. As we describe in the report, 
larvae of the beetle or closely related species had been intercepted 
many times at U.S. ports of entry prior to its detection in 1996. In 
relation to this point, the APHIS national program manager for the 
Asian longhorned beetle told us that all larvae similar in appearance 
to Asian longhorned beetle larvae are invasive and require mitigating 
action. In general, we agree that the agencies have worked hard to 
control the three pests and believe that our report describes the 
difficult tasks that the agencies face in attempting to eradicate them 
from the environment and accurately portrays the status of those 
efforts. Nonetheless, the fact of the matter is that 2 of the 3 pests 
will likely not be eradicated. In summary, we believe the report fairly 
presents the overall challenges as well as the results of USDA's 
efforts. 

USDA commented that it did not have major concerns about the three 
recommendations but did not completely agree with them. With regard to 
the recommendation to increase monitoring of forest health conditions, 
particularly in urban and suburban areas, USDA noted that the draft 
report focused only on federal government agencies. The department 
pointed out that state, university, tribal, business, and 
nongovernmental organizations have a role to play in combating invasive 
species. We agree that these entities have a role, and the report does 
indicate that federal agencies collaborate with nonfederal entities on 
forest health monitoring. Given that existing Forest Service and APHIS 
monitoring programs entail collaboration with nonfederal entities, it 
would not be unexpected that any expansion of these monitoring programs 
would also involve those partners. As the lead federal agency, USDA has 
an important leadership role to play in developing and supporting the 
forest health monitoring capabilities of nonfederal entities to achieve 
more effective results. 

USDA commented that the second recommendation that addresses keeping 
management plans up to date is "a sound business practice which we 
support." The department stated its belief that a reasonable job was 
done in these instances, given the pressures to accomplish work "on the 
ground." We agree that the program management teams carried a large 
workload, but continue to believe that more should have been done to 
keep the public informed about the programs' status and direction. We 
also continue to believe that these and other pest management programs 
should regularly update management plans, and that those plans should 
contain specific information listed in our recommendation. In light of 
the heavy workload that pest management teams are likely to face when 
responding to an infestation, the department may wish to consider 
developing a standardized reporting instrument that would ease the 
burden on program managers, while still providing essential information 
to the public and decision makers about such variables as the overall 
spread of the pest, the location of infestations, the schedule for 
eradicating those infestations, and funding needs. 

USDA commented that the third recommendation regarding the need for 
written procedures that broadly define when and how to operate panels 
of scientific experts seemed reasonable. However, the department said 
that the draft report incorrectly implied that, in the three situations 
we reviewed, important people with information to share were not heard. 
We did not independently assess whether the three science panels 
included the correct expertise. However, some stakeholders we 
interviewed believed that the process was not as inclusive or open as 
it should have been, and we concluded that written procedures for the 
panels could help avoid that problem in the future. USDA also commented 
that chartering a committee under FACA would hamper its flexibility in 
dealing with invasive species issues, and, therefore, it disagreed that 
panels should be chartered under FACA. In fact, we did not specifically 
recommend that committees be chartered under FACA, and we agree with 
USDA that the FACA process may hamper an expeditious scientific 
response to a new infestation. Nevertheless, panels of nonfederal 
experts called on to provide advice to USDA may fall under the 
obligations of FACA, and we continue to believe that the department 
should develop procedures that clarify when and how scientific panels 
can be used in pest response efforts and identify under what 
circumstances a panel should be chartered under FACA. 

As agreed with your office, unless you publicly announce the contents 
of this report earlier, we will plan no further distribution until 30 
days from the report date. At that time, we will send copies of this 
report to other interested congressional committees and the Secretary 
of Agriculture. We will also make copies available to others upon 
request. In addition, the report will be available at no charge on 
GAO's Web sites at [Hyperlink, http://www.gao.gov.] 

If you or your staff have any questions, please call me at (202) 512- 
3841 or nazzaror@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Key contributors to this report are listed in 
appendix VIII. 

Sincerely yours, 

Signed by: 

Robin M. Nazzaro: 
Director, Natural Resources and Environment: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

This report evaluates the federal response to three invasive forest 
pests--the Asian longhorned beetle; the emerald ash borer; and 
Phytophthora ramorum (hereafter P. ramorum), the pathogen that causes 
Sudden Oak Death. Specifically, we reviewed (1) the status of efforts 
to eradicate these three species; (2) factors that have affected the 
success of the response programs; (3) overall forest health monitoring 
programs; (4) the coordination of the three pest response efforts among 
federal and state agencies and other stakeholders, and communication 
about the response efforts; and (5) the Department of Agriculture's 
(USDA) use of panels of scientific experts to aid the responses. We 
also discuss in appendix VI APHIS's use of risk assessments to support 
decisions for forest pest programs. 

We selected a nonprobability sample of these three species because they 
were discovered in the United States relatively recently; they pose a 
large potential threat to the nation's forests; and the federal 
government has established a program to research, control, and manage 
them.[Footnote 38] We also deliberately chose both insect and disease 
pests to learn whether they pose different management challenges. 
Finally, we took into consideration the fact that the three pests are 
in different parts of the country. We considered this criterion to be 
potentially important because states play a major role in responding to 
pest outbreaks. 

To determine what federal entities implement projects to address 
invasive forest pests and what sources of funding these entities have, 
we interviewed relevant officials from USDA and the National Invasive 
Species Council and reviewed forest pest literature and Web sites. 
Within USDA, we focused our review on the Animal and Plant Health 
Inspection Service (APHIS) and the Forest Service, the agencies that 
primarily contribute to the prevention and control of invasive forest 
pests. We also obtained relevant information on research activities 
conducted by USDA's Agricultural Research Service and Cooperative State 
Research, Education, and Extension Service. We recognize that invasive 
forest pests may affect other federal agencies, such as the Department 
of the Interior. However, we focused on APHIS and the Forest Service 
because these two agencies play a larger role in the management of 
these forest pests. 

To analyze the federal responses to the three pests, we reviewed 
applicable laws and regulations pertaining to plant protection and 
quarantines. We also reviewed agency documents pertaining to scientific 
research, regulations and quarantines, program expenditures, 
cooperative agreements, strategic plans, and risk assessments, which 
included estimates of past and potential economic and environmental 
damage. We interviewed national, regional, and state program managers 
at APHIS; state agriculture department officials responsible for 
implementing the response program; Forest Service and state forestry 
officials; science advisory panel members; and researchers from 
academia. 

We gathered information about invasive forest pest expenditures by 
federal and nonfederal entities from a variety of sources. These 
included the structured interviews and documents provided by agency 
officials in response to our request for funding information. In the 
instances where officials provided us with information through the 
interview guide, we asked if their answers were based on a documented 
estimate. We independently corroborated the data the officials provided 
in answer to our questions, to the extent possible, using other 
documentation, such as cooperative agreements with states and 
appropriations language. We determined that these data were 
sufficiently reliable for the purposes of this report. 

For each of the three pest programs, we contacted officials at federal, 
state, and local government agencies, as well as at nongovernmental 
organizations. We did not attempt to identify or contact all federal, 
state, and local agencies engaged in invasive forest pest management in 
each example. For the three invasive pests we reviewed, we sought to 
contact officials representing APHIS and the Forest Service, state 
agriculture and forestry or natural resources agencies, and local 
governments as well as scientists and other researchers involved with 
program efforts. In addition, for the P. ramorum program, we also 
interviewed representatives from the nursery industry; for the emerald 
ash borer program, we met with individuals in the forest products and 
firewood industries to gain their opinions on federal quarantine 
regulations. 

We used a structured interview guide to obtain information from 
federal, state, local, and nongovernmental officials, including 9 
stakeholders involved with the Asian longhorned beetle, 12 with the 
emerald ash borer, and 16 with P. ramorum. The federal officials 
included APHIS and Forest Service employees directly involved in the 
management programs. The state officials included department of 
agriculture and department of forestry or natural resources employees 
directly involved in the management programs. We administered the 
structured interview to New York City and Chicago government officials 
involved in the Asian longhorned beetle program, because of the major 
role those city governments have had in that program. Nongovernmental 
officials included representatives from the nursery industry affected 
by P. ramorum and the Asian longhorned beetle, and university 
scientists with expertise related to one of the forest pests. Table 1 
lists the three pests that we reviewed and the number and affiliations 
of the stakeholders we interviewed with the structured interview guide. 

Table 1: Number of Stakeholders Who Were Administered the GAO 
Structured Interview, by Pest and Affiliation: 

Forest pests reviewed: Asian longhorned beetle; 
Number of stakeholders, by affiliation: Federal agency::: APHIS: 1; 
Number of stakeholders, by affiliation: Federal agency:: Forest 
Service: 1; 
Number of stakeholders, by affiliation: State agency:: Agriculture 
agency: 3; 
Number of stakeholders, by affiliation: State agency: Forestry or 
natural resources: 0;  
Number of stakeholders, by affiliation: Local government agency: 2; 
Number of stakeholders, by affiliation: University: 1; 
Number of stakeholders, by affiliation: Nursery industry: 1; 
Number of stakeholders, by affiliation: Total: 9. 

Forest pests reviewed: Emerald ash borer; 
Number of stakeholders, by affiliation: Federal agency::: APHIS: 4; 
Number of stakeholders, by affiliation: Federal agency:: Forest 
Service: 2; 
Number of stakeholders, by affiliation: State agency:: Agriculture 
agency: 3; 
Number of stakeholders, by affiliation: State agency: Forestry or 
natural resources: 2;  
Number of stakeholders, by affiliation: Local government agency: 0; 
Number of stakeholders, by affiliation: University: 1; 
Number of stakeholders, by affiliation: Nursery industry: 0; 
Number of stakeholders, by affiliation: Total: 12. 

Forest pests reviewed: P. ramorum; 
Number of stakeholders, by affiliation: Federal agency::: APHIS: 3; 
Number of stakeholders, by affiliation: Federal agency:: Forest 
Service: 3;  
Number of stakeholders, by affiliation: State agency:: Agriculture 
agency: 4; 
Number of stakeholders, by affiliation: State agency: Forestry or 
natural resources: 2;  
Number of stakeholders, by affiliation: Local government agency: 0; 
Number of stakeholders, by affiliation: University: 2; 
Number of stakeholders, by affiliation: Nursery industry: 2; 
Number of stakeholders, by affiliation: Total: 16. 

Forest pests reviewed: Total; 
Number of stakeholders, by affiliation: Federal agency::: APHIS: 8; 
Number of stakeholders, by affiliation: Federal agency:: Forest 
Service: 6; 
Number of stakeholders, by affiliation: State agency:: Agriculture 
agency: 10; 
Number of stakeholders, by affiliation: State agency: Forestry or 
natural resources: 4;  
Number of stakeholders, by affiliation: Local government agency: 2; 
Number of stakeholders, by affiliation: University: 4; 
Number of stakeholders, by affiliation: Nursery industry: 3; 
Number of stakeholders, by affiliation: Total: 37. 

Source: GAO. 

[End of table] 

The structured interview guide asked the officials for their opinions 
on a variety of topics, including state and federal coordinating 
mechanisms, quarantines, public education and outreach, management 
tools and research, funding responsibility, funding needs, risk 
assessment, potential for eradication, impact to the environment, and 
recommended contacts. The structured interview guide consisted of 21 
questions asking for a "yes," "no," or "uncertain" answer and 29 
questions asking for open-ended answers. For some of the "yes" or "no" 
questions, respondents gave two answers based on their opinion of the 
overall program as well as their opinion on a more specific issue 
within the program. For example, in response to a question about the 
potential for eradication for P. ramorum, several officials responded 
that eradication was not possible for the entire infested area but was 
possible for a smaller area, such as a less-infested state. At times, 
in answering one question, a respondent would also provide an answer to 
a subsequent question. In our analysis, we assigned their answers to 
the appropriate question. In some instances, respondents did not give 
clear answers to specific questions, and we asked additional follow-up 
questions that were not part of the guide in order to clarify. We also 
asked the stakeholders to recommend other people to interview. Appendix 
II contains the questions from the structured interview guide. 

We developed our structured interview guide with the assistance of a 
GAO methodologist. The practical difficulties of asking questions may 
introduce other types of errors (e.g., differences in how a particular 
question is interpreted or the sources of information available to 
respondents can introduce unwanted variability into the responses). We 
included steps in the development of our interview guides to minimize 
such errors, including pretesting the content and format of the 
interview guides with two individuals and making minor changes as 
appropriate. 

In addition to using the structured interview guide, we also 
interviewed other federal and nonfederal officials in a less formal 
way. We conducted some of these interviews prior to preparing the 
interview guides. In other instances, we used an informal interview 
method because we did not believe that the guides were appropriate for 
the interviewee. In our report, we present information obtained from 
the informal interviews, but do so separately from our presentation of 
information we obtained through the interview guides. 

We made site visits to New Jersey, New York, Michigan, and California 
to observe program activities, such as detection and control efforts 
and inspections of regulated materials. For example, in Michigan we 
observed emerald ash borer trap trees and tree removal operations on 
both public and private land in the gateway between the United States 
and Canada. We also accompanied state and federal officials as they 
inspected a sawmill operation for compliance with emerald ash borer 
quarantine regulations. In California, we observed in a wholesale 
nursery the use of best management practices to reduce the threat of 
spreading P. ramorum among plants being readied for shipment. 

We also discussed APHIS's use of risk assessments to support decisions 
for invasive species programs. To develop appendix VI on risk analysis, 
we conducted a computerized literature search and identified and 
reviewed articles, as well as domestic and international guidelines, 
relevant to risk analysis for invasive forest pests. To learn about the 
complex network of roles and responsibilities regarding the risk 
analysis process and risk-based management within USDA, we studied 
information on organizational structure provided on APHIS Web sites; 
conducted interviews with officials in APHIS's Plant Protection and 
Quarantine office, USDA's Office of Budget and Program Analysis, and 
USDA's Economic Research Service; and followed up on the interviews 
with additional questions through e-mails. In addition, we reviewed 
published reports evaluating APHIS's roles and responsibilities in this 
regard. Finally, we used all sources previously mentioned to identify 
specific risk analysis studies by APHIS for the three pests we reviewed 
in our report. As reported in appendix VI, we found only two such 
studies by APHIS that were related to pests of interest. 

[End of section] 

Appendix II: Questions from Structured Interview Guide Administered to 
Stakeholders Involved with the Three Pest Response Programs: 

The structured interview guide that we administered to stakeholders 
consisted of the following questions: 

Federal and State Coordination: 

1. Do you believe that the federal government has created the 
appropriate coordinating mechanisms to respond to the infestation? (By 
coordinating mechanisms, we mean such things as interagency and 
intergovernmental management teams and science advisory panels.) 

2. Do you believe that there are improvements that could be made with 
respect to those federal coordinating mechanisms? 

3. If so, what are they? 

4. Do you believe that the state government(s) has/have created the 
appropriate coordinating mechanisms to respond to the infestation? (By 
coordinating mechanisms, we again mean interagency management teams and 
advisory panels.) 

5. Do you believe that there are improvements that could be made with 
respect to those state coordinating mechanisms? 

6. If so, what are they? 

7. Please describe any lessons, either positive or negative, that you 
have learned from your experiences with these coordinating mechanisms.: 

Imposition and Enforcement of Quarantines: 

8. Do you believe that the state(s) have imposed quarantines for the 
correct geographic areas to achieve the goal of stopping the artificial 
spread of the pest? 

9. What do you believe should have been done? 

10. Do you believe that the state(s) imposed the quarantines in a 
timely fashion to achieve the goal of stopping the artificial spread of 
the pest? 

11. What do you believe should have been done? 

12. Do you believe that the federal government has imposed quarantines 
for the correct geographic areas to achieve the goal of stopping the 
artificial spread of the pest? 

13. What do you believe should have been done? 

14. Do you believe that the federal government imposed the quarantines 
in a timely fashion to achieve the goal of stopping the artificial 
spread of the pest? 

15. What do you believe should have been done? 

16. Do you believe that the quarantines have stopped the artificial 
spread of the pest? 

17. If not, what is most needed to improve the quarantines? 

18. Do you have any suggestions for legal or procedural changes that 
could improve the quarantine process? 

19. Please describe your suggestions. 

20. Please describe any lessons, either positive or negative, that you 
have learned from your experiences with the quarantines for the pest.: 

Education and Outreach: 

21. Do you believe that the state and federal efforts to educate the 
public about this pest have helped stop its spread? 

22. If not, why not? 

23. What do you believe should have been done? 

24. Please describe any lessons, either positive or negative, that you 
have learned from your experiences with education and outreach for this 
pest. 

Management Tools and Research: 

25. Do government agencies have the tools they need to manage the pest? 
(When we speak of tools, we include understanding the biology of the 
organism, detection techniques, eradication methods, and other such 
knowledge or technology.) 

26. What additional tools are needed? 

27. Is research underway to develop those tools? 

28. Please describe any lessons, either positive or negative, that you 
have learned from your experiences with the technological research for 
managing the pest. 

Funding Responsibility: 

29. Do you believe that the federal government should bear the primary 
financial responsibility for addressing an invasive species problem 
such as this? 

30. Please explain your answer. 

31. Do you believe that the states should bear any of the financial 
responsibility? 

32. If so, what do you believe would be a fair cost-sharing arrangement 
between the federal government and the states to address a situation 
such as this pest? 

33. Do you believe that the resources devoted to controlling this pest 
have achieved the goal of stopping its spread? 

34. What level of funding do you believe is needed per year, regardless 
of the source, to eradicate the pest? 

35. What level of funding do you believe is needed in total, regardless 
of the source, to eradicate the pest? 

36. What is the basis of your answers for Questions 34 and 35? 

37. If your answers to Questions 34 and 35 are based on documented 
estimates, please provide copies or citations. 

Funding Mechanisms: 

38. Do you believe that any improvements are needed in the mechanisms 
or processes through which funding is delivered to the states? 

39. If so, please provide any suggestions you have for improvements. 

Risk Assessment and Funding Needs: 

40. Have the federal or state governments conducted risk assessments to 
estimate the likely costs and benefits associated with managing the 
pest? 

41. If yes, please provide sources or citations. 

42. Please describe how the risk assessments have been used in making 
resource allocation decisions. 

43. Please provide any observations you have on how to improve the 
preparation and use of risk assessments. 

Prospects for Success: 

44. Do you believe it is possible to eradicate the pest? 

45. Do you believe that the federal government should strive to 
eradicate this pest? 

46. Do you believe that the pest can be eradicated from the entire 
infested area given our current knowledge and level of effort? 

47. If not, what do you believe is most necessary to achieve 
eradication? 

48. If you do not believe that eradication is possible, what do you 
think is the likely outcome? 

49. Please offer any other comments you might have regarding the 
management of this pest. 

50. Who do you recommend we should contact to ask these questions? 
(Additional contacts could, for example, be from your state, from your 
agency, or from stakeholder groups.) 

[End of section] 

Appendix III: Review of Efforts to Control and Eradicate the Asian 
Longhorned Beetle: 

Our review of the efforts to control and eradicate the Asian longhorned 
beetle includes a discussion of the origin and spread of the 
infestation in the United States and its potential impacts. We also 
review the roles of federal, state, and local government agencies in 
addressing infestations and describe the management structures and 
methods they have used to control and eradicate this forest pest. 
Finally, we discuss the current status of the Asian longhorned beetle 
infestation and outline the funds spent to date on controlling and 
eradicating the pest. 

Origin and Potential Impacts of Asian Longhorned Beetle Infestations: 

The Asian longhorned beetle is a large, eye-catching, wood-boring 
beetle that is black with small white spots and long, spotted 
antennae.[Footnote 39] It is native to countries in Asia, such as 
Japan, Korea, and China. The beetle spends most of its life within the 
inner wood of a variety of hardwood trees tunneling and feeding on the 
cambium layer, eventually killing the tree. APHIS officials believe 
that the beetle arrived in the United States sometime in the mid-1980s 
in solid wood packing material accompanying cargo shipments originating 
in China and destined for warehouses located throughout the country. 
While inspections have discovered adult beetles at about 30 warehouses 
across the country, the only established infestations have been found 
in a few urban locations. The beetle was first detected in Brooklyn, 
New York, in August 1996. However, APHIS officials believe that the 
beetle had been established in Brooklyn for about 10 years prior to its 
detection. Subsequent infestations were detected in other parts of New 
York; in Illinois (July 1998) and New Jersey (October 2002); and in 
Toronto, Canada (September 2003). Many of the sightings leading to the 
detection of infestations have been by citizens who had been exposed to 
public outreach efforts regarding the beetle. 

Researchers note that the Asian longhorned beetle is a serious threat 
to hardwood trees in both urban and natural forests, and that it has no 
known natural predator in the United States.[Footnote 40] In a 2000 
study of the urban forests of nine large U.S. cities, researchers 
estimated that the beetle could destroy as much as 35 percent of U.S. 
cities' tree canopy cover and 30 percent of their trees (1.2 billion 
trees), with an estimated loss of value of $669 billion.[Footnote 41] 
These estimates do not include the potential adverse impacts on the 
forest products industry (lumber and furniture), maple syrup 
production, fall foliage tourism, as well as the impacts from decreased 
property values; aesthetic damage; and lessened environmental benefits, 
such as cleaning air and water and providing energy-conserving shade. 
If the beetle spreads out of its current urban environment, researchers 
note that it also has the potential to seriously alter the ecological 
diversity of the natural forests in North America, with additional 
impacts on wetlands. Researchers estimate that if the beetle enters 
natural forests, the potential loss could be 71 billion trees, with a 
value greater than $2 trillion. One researcher noted that the beetle 
has the potential to cause more damage than Dutch elm disease, chestnut 
blight, and gypsy moth infestations combined. 

Federal, State, and Local Roles in Controlling and Eradicating the 
Asian Longhorned Beetle: 

A number of federal, state, and local agencies are involved in managing 
and eradicating the Asian longhorned beetle in the United States, with 
USDA's APHIS Plant Protection and Quarantine (PPQ) group taking the 
lead. APHIS works with other federal agencies through the use of 
interagency agreements and with state and local governments through the 
use of cooperative agreements. Both the interagency and cooperative 
agreements lay out in detail the roles and responsibilities of each 
government party as well as other matters. The basic roles of the 
federal, state, and local governments are described as follows: 

* Federal government: APHIS's PPQ group works to protect the country 
from the entry of invasive pests and to manage and eradicate invasive 
pests once they are established. PPQ is the lead federal agency 
responsible for surveys, regulatory quarantines, control actions, 
public awareness efforts, and technology development. USDA's Forest 
Service undertakes forest restoration, research, and public awareness 
and has tree climbers who assist in surveys. USDA's Agriculture 
Research Service engages in research on management tools. Other USDA 
agencies have also provided personnel to the Asian longhorned beetle 
program to assist in survey and control activities. 

* State governments: The Department of Agriculture and Markets in New 
York and the Departments of Agriculture in Illinois and New Jersey 
survey, regulate, control, and increase public awareness about the 
Asian longhorned beetle. The New York Department of Environmental 
Conservation regulates pesticides and restores forests. The Illinois 
Department of Agriculture also regulates pesticides. The New Jersey 
Division of Parks and Forestry restores forests. 

* Local governments: New York City Department of Parks and Recreation, 
Forestry and Horticulture conducts data management, debris disposal, 
and restoration, facilitating the program within the city. The 
Department of Streets and Sanitation, Bureau of Forestry, conducts data 
management, tree removal, surveying, and restoration, facilitating the 
program within Chicago. Municipal and city governments located in Long 
Island, the suburbs of Chicago, and New Jersey dispose of wood debris 
and conduct public awareness activities. Some local community 
organizations also contribute to public awareness activities. 

Management Structures and Methods Used to Control and Eradicate the 
Asian Longhorned Beetle: 

Following the August 1996 detection of the Asian longhorned beetle in 
Brooklyn, an APHIS New Pest Advisory Group met in September 1996 to 
discuss management options and make recommendations regarding actions 
that should be taken to address the infestation. The advisory group 
recommended that APHIS continue to survey for infested trees in 
Brooklyn, impose a quarantine to prevent the spread of the beetle, 
convene a science advisory panel, establish a joint federal/state/local 
operational team, and begin a public outreach campaign in addition to 
other actions. The following month, APHIS convened a science advisory 
panel to discuss the beetle infestations and recommend actions that 
should be taken to control its spread. While recommending actions 
similar to those set out by the New Pest Advisory Group, the science 
panel also recommended that APHIS expand its surveys for the Asian 
longhorned beetle to a national level, pursue research on the beetle's 
behavior and management tools to control it, and seek complete 
eradication of the beetle. Following the detection of beetle 
infestations in each of the three states, APHIS/PPQ established 
management teams comprising APHIS, state, and local officials to 
discuss, plan, and carry out an eradication plan. 

In April 2000, APHIS officials published APHIS's revised Asian 
longhorned beetle New Pest Response Guidelines, providing guidance and 
action steps for eradicating infestations. In September of that same 
year, following consultation with state and local officials, APHIS 
released a plan for eradicating the beetle in New York and Illinois. 
After detecting infestations in New Jersey in 2002, APHIS released a 
separate plan for New Jersey that same year. On the basis of various 
guidelines and plans for addressing the beetle, the management teams' 
efforts to eradicate it have focused on the following: 

* Overarching strategy: The strategy of the federal Asian longhorned 
beetle program is to contain and eventually eradicate the pest from its 
current urban and suburban locations through a combination of 
inspections, quarantines, harvesting of infested trees, treating 
uninfested trees with insecticides, and public education. 

* Surveys: Surveys serve the following three purposes: (1) detect 
infestations, (2) determine or delimit the extent of infestations, and 
(3) evaluate the effectiveness of control strategies employed to 
achieve eradication. For the Asian longhorned beetle, surveys have 
consisted of visual inspections of public and private property done 
from the ground or by tree climbers and with bucket trucks. 

* Quarantines: State and APHIS officials established what they term 
"parallel quarantines" where state and APHIS officials met to determine 
the quarantine boundaries and items to be regulated. The state 
established a quarantine allowing state officials to use their 
authority to regulate items that contribute to the spread of the 
beetle. The federal government followed with a federal quarantine to 
prevent the interstate spread of the beetle through the movement of 
infested wood and wood debris. Initial state and federal quarantine 
boundaries were set, based on current research, as small as possible to 
lessen their impact on affected parties but large enough to prevent the 
spread of the beetle. As government officials gained more knowledge 
about the beetle, a protocol was established for establishing and 
expanding quarantine boundaries. Because the initial quarantine 
boundaries were small, government officials expanded the quarantine 
boundaries to account for infestations that were larger than initially 
identified, in accordance with the new protocols. Beginning in 2004, 
APHIS and state officials have been removing quarantines in Illinois 
and New Jersey as survey results of the infested areas over 3 years 
have shown no signs of the beetle's presence. 

* New York: New York imposed an initial quarantine in December 1996, 
which was followed by a federal quarantine in March 1997, for areas in 
the boroughs in Brooklyn and Queens and a small area in Amityville on 
Long Island. APHIS expanded the New York quarantines on six other 
occasions as additional infestations were detected. In total, officials 
quarantined approximately 132 square miles of infested area, covering 
portions of the boroughs of Brooklyn and Queens, small areas in 
Manhattan, and two areas on Long Island. 

* Illinois: Illinois established an initial quarantine in July 1998 and 
declared the beetle a nuisance in August 1998.[Footnote 42] APHIS 
followed with a federal quarantine in November 1998. Illinois expanded 
the quarantine 8 times over the next 6 years to account for additional 
detections of the beetle. Beginning in 2004, APHIS and state officials 
began reducing some quarantine boundaries in light of 3 consecutive 
years of negative surveys in those quarantined areas. In total, 
officials quarantined approximately 35 square miles of infested area. 

* New Jersey: New Jersey imposed two quarantines, one in October 2002 
for an area in Jersey City, and one in August 2004 for portions of 
Middlesex and Union Counties. APHIS followed with federal quarantines 
in May 2003 for Hudson County (including Jersey City) and in January 
2005 for Middlesex and Union Counties. APHIS removed the quarantine for 
Hudson County in October 2005. In total, state officials quarantined 
approximately 20.5 square miles covering a small area of Jersey City 
and Hoboken in Hudson County and parts of four smaller cities adjacent 
to one another in Middlesex and Union Counties. 

* Public education and outreach: According to APHIS, state, and local 
officials, one of the critical components in detecting and eradicating 
the Asian longhorned beetle was an aggressive program of public 
education and outreach directed at parties directly affected by the 
quarantines, local officials, local plant organizations, and citizens. 
Several detections of the beetle infestations were a result of citizens 
seeing and reporting the pest following a public outreach effort or 
event. For example, within 2 hours of a radio show about the beetle, a 
New Jersey resident called in a sighting of the pest, which led to the 
detection of an infestation. 

* Removal of infested trees: Since the beetle has no known natural 
predators in the United States and state and local laws restrict the 
use of insecticides in urban areas, the only way to prevent the spread 
of the beetle has been to cut down, chip, and burn infested trees. 
Government agencies have contracted with private companies to remove 
and dispose of the trees. As of the end of 2004, government officials 
had removed and destroyed over 8,000 infested trees. New York City 
established a free curbside pick-up program to remove residential wood 
debris within the quarantined zones to prevent the spread of the 
beetle. In Illinois and New Jersey, government agencies established 
disposal sites and wood grinders to handle wood debris gathered by both 
commercial entities and residents within the quarantined areas. 

* Chemical treatment of noninfested host trees: For trees that are 
susceptible, but not yet infested, APHIS and state agencies have 
contracted with tree companies to treat the trees with an insecticide 
that will kill the beetle in the early stages of its life cycle while 
it is still inside the tree or as an adult feeding on the leaves and 
twigs. Over 600,000 noninfested host trees have been chemically treated 
to kill the beetle during its larvae life stage to prevent the beetle 
from spreading. 

* Replantings: The Forest Service, in cooperation with state and city 
forestry agencies, has provided residents with the option of replacing 
infested trees removed from their properties with a tree species that 
is not a host for the beetle. 

* Research: Research to date by government and university scientists 
has focused on the biology and dispersal of the beetle (used to 
establish survey and quarantine boundaries), quality assurance studies 
of survey methods that led to the use of bucket trucks and tree 
climbers, and the development of a trunk injection chemical treatment 
to augment tree removal. Research on lures and traps for the beetle has 
not yet proven successful. Ongoing research into controlling and 
eradicating methods include the following: rearing large numbers of 
beetles for research purposes; effective exclusion technologies to 
detect and eliminate the beetle from foreign cargo entering the 
country; testing an acoustical detection device; a uniform data 
management system; a system for injecting insecticide into the soil to 
supplement tree trunk injection; and alternatives to chemical 
treatments, such as biological control agents. 

Status of Asian Longhorned Beetle Infestation: 

Starting in 2000, the data indicated a downward trend in the number of 
infested trees identified each year, except for New Jersey where a 
large infestation was detected in 2004. Figure 15 shows the 
distribution over time of the infested trees identified among New York, 
Illinois, and New Jersey. 

Figure 15: Number of Asian Longhorned Beetle-Infested Trees Identified 
in New York, Illinois, and New Jersey: 

[See PDF for image] 

[End of figure] 

The quarantines in combination with solid management teams and 
aggressive public outreach and education have resulted in the beetle 
slowly being eradicated in the infested states. APHIS and Illinois have 
removed all but one of the Illinois quarantines and plan to remove the 
last in the spring of 2006. APHIS and Illinois state officials expect 
to complete the management program in 2008. APHIS and New Jersey state 
officials have removed the quarantined area in Hudson County and expect 
to remove the other quarantines in the next several years. APHIS and 
New Jersey officials expect to complete the management program in 2011. 
Although government officials expected complete eradication in New York 
by 2009, that date has been moved to perhaps as late as 2020 due to the 
detection of new, but small infestations; the sheer size of the 
infestations; the difficulty of working in the New York urban 
environment; and inadequate funding. All but one of the government 
officials involved in the Asian longhorned beetle program that we 
interviewed believed that it will be completely eradicated if adequate 
and consistent funding is provided to complete the program. 

Funding for Asian Longhorned Beetle Eradication Efforts: 

In its initial response to the Asian longhorned beetle detections, 
APHIS drew money from its contingency funds to pay for research and 
surveys to determine the extent of the infestations. Several years into 
the program, APHIS began including part of its funding needs in its 
appropriations requests. APHIS has received $229 million in fiscal 
years 1996 through 2005 on the beetle eradication program, using a mix 
of APHIS contingency funds, Commodity Credit Corporation (CCC) 
transfers, and other appropriations. APHIS has estimated that, in 
total, $578 million will be needed to eradicate the beetle. As 
previously noted, a federal funding shortfall in fiscal year 2002 
resulted in the cancellation of tree removal and insecticide treatment 
contracts. Because insecticide treatments need to be performed for 3 
years to be effective, the shortage of funding had a significant effect 
on the treatment schedule. Specifically, it caused APHIS and New York 
state officials to extend the eradication goal in New York from 2009 to 
2014 or 2020, depending on future funding levels. However, for fiscal 
year 2006, Congress appropriated $20 million for the beetle program, an 
amount that raises doubts about the program's ability to meet even the 
2020 date, unless USDA uses its emergency authority to transfer funds 
from CCC or other available USDA appropriations. 

As of fiscal year 2006, over $249 million has been provided for the 
eradication of the beetle since it was first detected. Table 2 provides 
detail on federal funding toward eradication of the Asian longhorned 
beetle. 

Table 2: APHIS Budget Authority for the Asian Longhorned Beetle for 
Fiscal Years 1997 through 2006: 

Dollars in millions. 

Fiscal Year: 1997[A]; 
Dollars in millions: Funding source: $0.0; 
Funding source: Emerging Plant pests appropriations: $0.8; 
Funding source: Total: $0.8. 

Fiscal Year: 1998[A]; 
Dollars in millions: Funding source: 0.0; 
Funding source: Emerging Plant pests appropriations: 1.3; 
Funding source: Total: 1.3. 

Fiscal Year: 1999; 
Dollars in millions: Funding source: 6.9; 
Funding source: Emerging Plant pests appropriations: 0.0; 
Funding source: Total: 6.9. 

Fiscal Year: 2000; 
Dollars in millions: Funding source: 14.1; 
Funding source: Emerging Plant pests appropriations: 2.1; 
Funding source: Total: 16.2. 

Fiscal Year: 2001[B]; 
Dollars in millions: Funding source: 49.6; 
Funding source: Emerging Plant pests appropriations: 2.1; 
Funding source: Total: 51.7. 

Fiscal Year: 2002; 
Dollars in millions: Funding source: 14.6; 
Funding source: Emerging Plant pests appropriations: 16.9; 
Funding source: Total: 31.5. 

Fiscal Year: 2003; 
Dollars in millions: Funding source: 7.0; 
Funding source: Emerging Plant pests appropriations: 26.2; 
Funding source: Total: 33.2. 

Fiscal Year: 2004; 
Dollars in millions: Funding source: 12.9; 
Funding source: Emerging Plant pests appropriations: 30.0; 
Funding source: Total: 42.9. 

Fiscal Year: 2005; 
Dollars in millions: Funding source: 14.6; 
Funding source: Emerging Plant pests appropriations: 30.0; 
Funding source: Total: 44.6. 

Fiscal Year: 2006; 
Dollars in millions: Funding source: 0.0; 
Funding source: Emerging Plant pests appropriations: 20.0; 
Funding source: Total: 20.0. 

Fiscal Year: Total; 
Dollars in millions: Funding source: $119.7; 
Funding source: Emerging Plant pests appropriations: $129.5; 
Funding source: Total: $249.2. 

Source: APHIS. 

[A] APHIS funded fiscal years 1997 and 1998 from its contingency fund. 

[B] APHIS funded fiscal year 2001 from its Miscellaneous Pest fund. 

[End of table] 

The state of New York has provided over $12 million toward personnel 
costs for state employees devoted to the Asian longhorned beetle 
eradication program, management of tree removal contracts, tree 
replanting, and implementation of state quarantines. New York City 
provided $18 million toward tree replanting, public outreach, and a 
woody debris disposal program for private residents within the 
quarantined area. Additionally, a few municipalities within infested 
areas have paid for services such as traffic control during tree 
removal. 

[End of section] 

Appendix IV: Review of Efforts to Control and Eradicate the Emerald Ash 
Borer: 

Our review of the efforts to control and eradicate the emerald ash 
borer includes a discussion of the origin and spread of the infestation 
in the United States and its potential impacts. We also review the 
roles of federal, state, and local government agencies in addressing 
infestations and describe the management structures and methods they 
have used to control and eradicate this forest pest. Finally, we 
discuss the current status of the emerald ash borer infestation and 
outline the funds spent to date on controlling and eradicating the 
pest. 

Origin and Potential Impacts of Emerald Ash Borer Infestations: 

Emerald ash borers are metallic green beetles small enough to fit on a 
penny.[Footnote 43] They are native to China and other countries in 
eastern Asia. The beetle spends most of its life in tunnels it creates 
in the outer layer--known as the cambium--of ash trees. The tunnels cut 
off the flow of water and nutrients through the cambium and eventually 
kill the tree, usually within 2 to 4 years. Scientists believe that ash 
borers arrived in the Detroit metropolitan area of southeastern 
Michigan by the early 1990s in solid wood packing material accompanying 
products shipped from Asia. Ash trees had displayed severe decline for 
several years in Michigan. However, observers attributed the mortality 
to other causes, including a native borer and a disease known as "ash 
yellows." It was not until June 2002 that government and university 
officials realized that a nonnative insect was the cause. 

Armed with information about a new identification in Michigan, Canadian 
officials confirmed in August 2002, that the ash borer was also in 
Windsor, Ontario. The insect was found in Ohio in February 2003, and in 
Indiana in April 2004, but may have been in those states for several 
years. In 2003, small infestations caused by the illegal movement of 
nursery stock from Michigan were also found in Maryland and Virginia. 
Many of the infestations in states other than Michigan were caused by 
people accidentally moving the beetle in infested firewood, logs, or 
nursery trees. In addition, because ash borer populations are able to 
spread an estimated 5 to10 miles per year on their own, they are 
naturally moving into Ohio and Canada from southeastern Michigan. 

The emerald ash borer is thought to have caused the death of 
approximately 15 million ash trees, primarily in Michigan. There are 16 
species of ash trees in North America, and all are believed to be 
vulnerable to the borer. According to Forest Service data, there are 
approximately 850 million ash trees in Michigan, 279 million in Ohio, 
and 147 million in Indiana, not counting those planted in communities, 
residential yards, or along public rights-of-way. The Forest Service 
estimates that there are approximately 8 billion ash trees in forests 
across the country. 

Ash trees have been widely planted by homeowners and city governments, 
often to replace elm trees lost to Dutch elm disease. APHIS estimated 
that the total value of urban ash trees in the United States was 
between $20 and $60 billion. The Forest Service estimated that if not 
contained and eradicated, the borer could cause approximately $7 
billion in additional costs to state and local governments, as well as 
landowners, for removing and replacing dead and dying ash trees in 
urban and suburban areas over the next 25 years.[Footnote 44] In 
addition to being a popular ornamental tree, ash lumber is used to make 
furniture, tool handles, flooring, and sports equipment. USDA estimated 
that the value of ash timber grown in the eastern United States is 
$25.1 billion. Ash trees also (1) serve an ecological role by providing 
habitat and food for wildlife and (2) provide other environmental 
functions, such as producing oxygen and providing energy-conserving 
shade. 

Federal, State, and Local Roles in Controlling and Eradicating the 
Emerald Ash Borer: 

* Federal government: As with the Asian longhorned beetle program, 
USDA's APHIS/PPQ group has the lead for managing the emerald ash borer. 
APHIS surveys for the pest; regulates its movement; and conducts 
control, public awareness, and technology development activities. The 
Forest Service conducts restoration and research, and has assisted with 
surveying. USDA's Agricultural Research Service has also conducted 
research on the ash borer. 

* State governments: The departments of agriculture in Michigan and 
Ohio and the department of natural resources in Indiana are the state 
agencies managing the emerald ash borer control program at the state 
level. APHIS has entered into cooperative agreements with these 
agencies through which it funds survey, regulatory, control, and public 
awareness activities. 

* Local governments: Municipal agencies, such as departments of public 
works or forestry, remove dead and dying ash trees from public land. 
This has been a large task primarily in the core-infested area of 
Michigan, where APHIS and the state have not carried out large tree 
removal projects. The Forest Service has funded local governments' 
replanting efforts to replace ash trees. 

Management Structures and Methods Used to Control and Eradicate the 
Emerald Ash Borer: 

USDA and Michigan, Ohio, and Indiana have formed several organizational 
bodies to address the emerald ash borer problem. In July and August 
2002, APHIS convened two New Pest Advisory Group teleconferences for 
the emerald ash borer.[Footnote 45] The advisory group noted that 
eradicating the beetle was not a viable option because it was too 
widespread. The group also noted that a decision to eradicate would 
only make sense if Canada also decided to eradicate. Instead, it 
recommended taking steps to slow the ash borer's spread while 
conducting research on management techniques. 

In 2002, APHIS formed an emerald ash borer management team to implement 
the control program. The team consists of representatives from APHIS; 
the Forest Service; the departments of agriculture from Michigan, 
Indiana, and Ohio; and universities in the three states. APHIS and the 
Forest Service also developed and cochair a tristate committee made up 
of the state plant pest regulatory officials and state foresters. The 
primary purpose of the committee is to help ensure that state foresters 
have a "seat at the table" and to identify where the state forests can 
play an active role to contain and eradicate the pest. 

APHIS also formed a science advisory panel to examine the ash borer's 
threat in more detail, and to make recommendations to the management 
team.[Footnote 46] The panel met in October 2002, October 2003, January 
2004, December 2004, January 2005, and December 2005 and provided 
recommendations to the federal management team after each meeting. 
Throughout this period, the panel has stressed the need for aggressive 
measures to control the pest. For example, in October 2002, the panel 
stated its belief that urgent action was critical if the insect 
populations were to be contained, reduced, and ultimately eradicated 
with cooperation from Canada. The panel also recognized that the effort 
would be long and complicated, requiring substantial commitment for 
success. The alternative would be the potential loss of North American 
ash as landscape and forest trees. 

Additionally, each of the three affected states has formed a task force 
to support state emerald ash borer management programs. The teams 
typically comprise representatives from the state department of 
agriculture, the state department of natural resources, universities, 
and relevant USDA agencies. The state management programs design and 
carry out regulatory and control activities in consultation with USDA. 
While the states have their own authorities to take steps to address 
the ash borer, USDA provides funding for those activities through 
cooperative agreements. These agreements spell out the financial 
support that USDA is to provide and the activities that the states have 
agreed to conduct. 

Finally, the following methods have been or are being used in efforts 
to control and eradicate the emerald ash borer. 

* Overarching strategy: The current goal of the APHIS emerald ash borer 
program is to eradicate the pest in Ohio and Indiana and keep it 
contained within the Lower Peninsula of Michigan. As APHIS and the 
Science Advisory Board learned more about the extent of infestation, 
the government response has evolved to what is known as the "gateway 
approach." Drawing upon the geography of Michigan, APHIS identified 
three gateways to defend: (1) the boundary between southern Michigan 
and northern Ohio and Indiana; (2) the Straits of Mackinac between the 
Lower and Upper Peninsulas of Michigan; and (3) the St. Clair River 
separating the eastern portion of Michigan and the southwestern portion 
of Ontario, Canada. However, the emerald ash borer has spread outside 
of the Lower Peninsula of Michigan and into each of the three gateways, 
and in some cases beyond. The strategy calls for focused attention on 
the gateways to keep more ash borers from spreading beyond them and to 
push current infestations back toward them. This approach is being 
implemented in a variety of ways, including surveying, regulatory 
enforcement, eradication, and public education. In the meantime, the 
strategy calls for little work--such as surveying or eradication--in 
the core-infested area of southeastern Michigan. 

* Surveys: Following the ash borer's identification in 2002, the 
federal and state governments have conducted a wide range of detection 
and surveying activities to determine the extent of infestation. The 
Science Advisory Panel recommended that Indiana and Ohio survey in a 
band running 50 miles south of Michigan, while Michigan needed to 
survey throughout the state except for in the 20 southeastern counties 
already known to be infested. APHIS, the Forest Service, and the states 
use two basic techniques to survey for ash borers. Visual surveys 
consist of looking for symptoms of infested trees, including thinning 
crowns, dead branches, cracked bark, new sprouts from the base of the 
tree, and exit holes. Visual surveys were also enhanced by the use of 
tree climbers or bucket trucks to examine tree crowns. Agencies are 
also visually inspecting sites considered to be at high risk of 
infestation, including nurseries, campgrounds, firewood dealers, and 
sawmills. For example, Michigan reported that in 2004, it conducted 
1,032 "high-risk" inspections of businesses and other entities and 
surveyed 1,068 public and private campgrounds in the Upper Peninsula 
alone. 

The second method of surveying is to use "trap trees." Healthy trees 
are girdled, meaning that bark is stripped from a section of the tree 
trunk. The girdling is thought to stress the tree and cause it to emit 
chemical signals that might attract the insect. After a period of time, 
the tree is cut down and debarked to determine whether borers have 
infested it. The Ash Borer Science Advisory Panel recommended varying 
the density of trap trees from 4 per township to as many as 36 per 
township, with the larger number placed in the gateways. Townships vary 
in size, but 36 square miles is the norm. Therefore, even the most 
densely surveyed townships may have only 1 trap tree per square mile. 
In 2005, Michigan set 10,500 trap trees, while Indiana and Ohio set 
1,500 and 1,400, respectively. Other states have also added the emerald 
ash borer to the list of pests that they survey for as part of their 
APHIS-funded Cooperative Agricultural Pest Survey. The Canadian 
government also conducts surveys in Ontario. 

Federal and state officials with whom we spoke do not consider either 
surveying technique to be very effective. For most of the year, the ash 
borer is hidden inside the tree, and exit holes are inconspicuous. 
Furthermore, government agencies are not certain that trap trees 
actually attract ash borers any more than ungirdled ash trees do. A 
major shortcoming of the ash borer program is that scientists have not 
developed a lure for the insect that would help find the leading edge 
of infestation and new outliers. 

* Quarantines: Michigan, Ohio, Indiana, and USDA have imposed a series 
of quarantines over an expanding area in an attempt to stop or reduce 
the artificial movement of the emerald ash borer into new locations. In 
general, the quarantines have regulated ash trees, ash lumber, ash 
logs, and hardwood firewood. Under state quarantines, a person or 
business may move regulated items, such as firewood or trees, inside a 
quarantine area but not outside that area unless the material is 
certified to be uninfested. Federal quarantines regulate the movement 
of the same types of materials across state lines. USDA and state 
regulatory officials are in charge of enforcing the quarantines. This 
enforcement includes identifying businesses, such as nurseries, 
sawmills, and firewood dealers, that handle regulated products. 
Businesses that want to ship regulated products outside of the 
quarantined area generally must first obtain approval, via a 
certificate or limited permit, from the state or federal government. 
These businesses are subject to regular inspections. A major objective 
of the quarantines is to stop people from moving firewood, because 
residents commonly take firewood to summer homes or campsites in 
uninfested parts of the states. State and federal regulatory officials 
have set up so-called "firewood blitzes" during which they check 
motorists at highway rest stops to make sure that they are not carrying 
firewood in violation of the quarantine. Michigan has also assigned 
inspectors to watch for firewood being moved across the Mackinac Bridge 
to the Upper Peninsula. A major element of the quarantines is public 
education. Stakeholders from all three states emphasized the importance 
of educating the public about the dangers of moving firewood, a message 
that the states have publicized using highway billboards, press 
releases, radio public service announcements, and mass mailings. While 
program officials with whom we spoke believed that their efforts have 
reduced the movement of potentially infested material, they concede 
that it is not possible to prevent all such movement, particularly of 
firewood. They believed that firewood is the most likely means by which 
ash borers will be moved to new locations. Quarantines imposed in 
Michigan, Ohio, and Indiana and by USDA are discussed in the following 
text: 

* Michigan: Michigan issued its first quarantine regulations in July 
2002, regulating the movement of ash-related items in 5 counties in the 
Detroit area. Michigan added a 6TH county in October 2002. As surveys 
found that the infestation was more widespread than originally 
believed, Michigan quarantined 7 more counties in August 2003, and 
another 7 in December 2004. As it added entire counties to the 
quarantine, the state also added so-called "outlier" locations to the 
quarantine. These are portions of counties where surveyors have found 
small infestations. As of January 2006, there were 21 entire counties 
and 31 outlier locations under quarantine, with quarantines pending in 
other outlying locations. Additionally, in July 2004, Michigan revised 
its internal quarantine to prohibit the sale and/or transportation of 
ash nursery stock into, within, or out of the state's Lower Peninsula. 
On May 20, 2005, Michigan issued a regulation banning the movement of 
untreated nonconiferous (hardwood) firewood[Footnote 47] out of the 
state's Lower Peninsula--regardless of whether the wood came from a 
quarantined area--and allowing the movement of ash logs and ash lumber 
with bark out of the Lower Peninsula only under a compliance agreement 
with the state department of agriculture. 

* Ohio: In September 2003, Ohio issued the first of a series of 
quarantines for ash and related products. As of November 2005, Ohio had 
quarantines in place in portions of 11 counties. Ohio also prohibits 
the movement of regulated materials into the state from Michigan. 

* Indiana: In April 2004, Indiana issued the first of a series of 
quarantines for ash and related products. The state began by regulating 
one township in Steuben County. Subsequent amendments throughout 2004 
and 2005 have added new townships to the list of quarantined areas. As 
of January 2006, Indiana had quarantined 9 townships in 4 counties. 

* USDA: The federal government's first emerald ash borer quarantine 
took effect on October 8, 2003, and covered 13 Michigan counties. USDA 
stated that federal regulations were necessary to prevent the spread of 
the ash borer to other states. On January 5, 2005, USDA amended its 
federal quarantine, effective December 28, 2004, to add areas in 
Michigan, Indiana, and Ohio, noting that recent surveys had revealed 
infestations outside the 13-county quarantined area in Michigan. USDA 
added more areas in Michigan, Ohio, and Indiana to the list of 
quarantined areas, effective February 25, 2005, and even more areas 
effective October 25, 2005. 

* Removal of infested or potentially infested trees: The primary method 
for controlling emerald ash borer is to cut, chip, and burn infested or 
potentially infested trees. To date, government agencies have cut 
hundreds of thousands of trees in the three states.[Footnote 48] 
However, the management team and Science Advisory Panel have agreed 
that the priority for tree removal is in the gateway areas and outlying 
areas, rather than in the core-infested area of southeastern Michigan. 

The Science Advisory Panel currently recommends tree removal projects 
that strive to cut all ash trees within a 0.5 mile radius of a tree 
known to be infested in an outlying area. The highest priorities are 
those outlying areas in or near one of the gateways.[Footnote 49] 
However, the management program has not been able to complete 
eradication projects in all of the gateway infestations because of 
inadequate funding. As a result, these infestations are likely to 
continue to pose a risk to those gateways. 

Michigan has recently completed or begun removing trees at 3 of the 15 
infested sites in the northern and southern gateway areas. According to 
the state's program manager, the state will complete the work at these 
sites by May 1, 2006. He also said that the state could have completed 
work at the other 12 sites in the two gateways by May 1, 2006, if 
adequate funds were available. May is a significant target date because 
that is about the time adult ash borers emerge from the trees. To 
prevent their emergence and possible flight to new locations, trees 
should be removed by then. Michigan completed a 0.5-mile eradication in 
2005 at 1 site outside of the gateways; this was a site in the Upper 
Peninsula beyond the northern gateway. As of December 2005, Ohio had 
delineated 11 infested sites but had been able to complete the 0.5-mile 
eradication at only 6 of them. Because of funding shortages, the state 
only planned eradication cuts in 2 counties (Delaware and Auglaize). 
Those infestations were the furthest south from the leading edge of 
infestation, and the state hoped to complete them by the end of March 
2006. If additional funds are available, the state will focus on the 
furthest east infestations in Erie and Lorain Counties. This would 
still leave numerous infestations in Defiance, Fulton, Hancock, Lucas, 
Ottawa, and Wood counties. As of December 2005, Indiana had been able 
to complete 0.5 mile eradication projects at 2 of the 8 infested sites 
within the southern gateway, according to the State Entomologist. At 
that time, he told us that additional eradication activities were 
planned for 2006.[Footnote 50] However, on January 25, 2006, the 
Indiana Department of Natural Resources announced that the state will 
no longer require nor fund the removal of trees in an infested area. A 
department press release quoted the State Entomologist as saying "the 
removal of ash trees surrounding an infested area has not proved to be 
an effective approach to controlling the emerald ash borer because of 
the near impossibility in detecting a new infestation." 

While APHIS and Michigan have worked to harvest trees in outlying 
areas, they also created locations where homeowners and local 
governments in the core-infested counties could bring dead ash trees 
for disposal. To help handle the volume of woody debris, by 2004 
Michigan had operations at 8 sites in quarantine areas to grind and 
dispose of ash material. The Michigan Department of Agriculture 
reported that the facilities have disposed of over 300,000 tons of ash. 
The facilities were supported with federal funding, which originally 
enabled the state to offer the service to municipalities and property 
owners at no charge. However, due to funding constraints in 2005, the 7 
sites still in operation began to charge fees that varied depending 
upon the type of material. 

* Research: All of the officials with whom we spoke regarding the 
emerald ash borer noted that government agencies do not have adequate 
tools with which to manage the pest. Over the years since the program 
began, APHIS, the Forest Service, the Agricultural Research Service, 
and universities have conducted approximately 50 research projects to 
support emerald ash borer management. In December 2004, the Science 
Advisory Panel identified several research areas needing continued or 
additional attention, including: (1) survey and detection tools; (2) 
control techniques, including insecticidal control; (3) emerald ash 
borer behavior and biology; (4) host range and host resistance; and (5) 
treatment techniques for ash logs and firewood. 

Research on the use of insecticides indicates that there are treatments 
that can be effective at protecting healthy ash trees from being 
attacked by the ash borer. However, these treatments are expensive to 
apply. While it may be feasible for individual landowners to use the 
treatments to protect individual trees, these insecticides cannot be 
practicably used on a large scale in a forest environment and do not 
appear to have a significant benefit for trees already infested. 
Research on biological controls indicates that there may be Asian 
parasites that could be introduced to prey upon emerald ash borer. 
Stakeholders we spoke with believe that successful management of the 
ash borer will depend upon discovery of a biological control that can 
be used widely and inexpensively across the landscape. Typically, it 
takes many years for such technologies to be developed and approved for 
use. 

* Restoration efforts: While little can be done directly to restore 
forested areas affected by the ash borer, the Forest Service has 
allocated funds to help local communities replace trees killed by the 
pest. For example, in 2004, Michigan used Forest Service funds to 
provide more than $855,000 in grants to communities within the 
quarantined counties to plant about 10,700 trees to replace ash trees 
that had been removed. The state also provided 10 grants totaling more 
than $200,000 to communities located in outlier areas to plant more 
than 3,500 trees. In 2005, the state awarded another 80 grants to 
communities--primarily in the quarantined areas--to pay for the 
planting of approximately 13,000 trees. These trees are small in size 
and number in comparison to the dead trees removed. 

Status of Infestation: 

The emerald ash borer now infests an estimated 40,000 square miles in 
three states plus Ontario, Canada. Government surveyors continue to 
find new infestations, including some that scientists estimate began 
several years ago. While program managers believe that quarantines have 
helped to slow the artificial spread of the pest, most do not believe 
that quarantines have completely stopped the public from moving the 
pest. Movement in firewood is a particular concern. In addition, 
populations of the pest are able to naturally spread on their own. 
Considering these circumstances and the lack of cost-effective 
management tools, program officials with whom we spoke were not 
optimistic that the infestation can be eradicated. In December 2005, 
the ash borer Science Advisory Panel concluded that current resources 
available to the program are inadequate to achieve the long-or short- 
term goals of the program. 

Funding for Emerald Ash Borer Control and Eradication Efforts: 

From fiscal years 2002 through 2006, the federal government has 
allocated about $107 million for the emerald ash borer program. The 
primary source of funding for the emerald ash borer program has been 
USDA APHIS, which has had budget authority of over $93 million from 
fiscal years 2002 through 2006 (see table 3). The Forest Service has 
been the other major source of federal funding, with budget authority 
of close to $19 million during that time period (see table 4). The 
Secretary of Agriculture has allocated funds to the program from the 
emergency CCC and congressionally appropriated pest management and 
forest management programs. Funds support work done by the states as 
well as by federal employees assigned to work on the program. 

Table 3: APHIS Budget Authority for the Emerald Ash Borer Program, by 
Funding Source and Fiscal Year: 

Fiscal year: 2002; 
Funding source: Commodity Credit Corporation funds: $0.0; 
Funding source: Other appropriated funds: $0.2; 
Funding source: Total: $0.2. 

Fiscal year: 2003; 
Funding source: Commodity Credit Corporation funds: 14.6; 
Funding source: Other appropriated funds: 0.0; 
Funding source: Total: 14.6. 

Fiscal year: 2004; 
Funding source: Commodity Credit Corporation funds: 43.4; 
Funding source: Other appropriated funds: 1.5; 
Funding source: Total: 44.9. 

Fiscal year: 2005; 
Funding source: Commodity Credit Corporation funds: 18.8; 
Funding source: Other appropriated funds: 5.0; 
Funding source: Total: 23.8. 

Fiscal year: 2006; 
Funding source: Commodity Credit Corporation funds: 0.0; 
Funding source: Other appropriated funds: 10.0; 
Funding source: Total: 10.0. 

Fiscal year: Total; 
Funding source: Commodity Credit Corporation funds: $76.8; 
Funding source: Other appropriated funds: $16.7; 
Funding source: Total: $93.5. 

Source: APHIS. 

[End of table] 

Table 4: Forest Service Budget Authority for Emerald Ash Borer 
Activities, by Funding Source and Fiscal Year: 

Dollars in millions. 

Fiscal Year: 2002; 
Funding source: Commodity Credit Corporation appropriations: $0.00; 
Funding source: State and private forestry appropriations: $0.04; 
Funding source: Research and development appropriations: $0.00; 
Funding source: Total: $0.04. 

Fiscal Year: 2003; 
Funding source: Commodity Credit Corporation appropriations: 2.80; 
Funding source: State and private forestry appropriations: 0.95; 
Funding source: Research and development appropriations: 0.70; 
Funding source: Total: 4.45. 

Fiscal Year: 2004; 
Funding source: State and private forestry appropriations: 4.59; 
Funding source: Research and development appropriations: 0.80; 
Funding source: Total: 5.39. 

Fiscal Year: 2005; 
Funding source: Commodity Credit Corporation appropriations: 0.00; 
Funding source: State and private forestry appropriations: 4.49; 
Funding source: Research and development appropriations: 1.13; 
Funding source: Total: 5.62. 

Fiscal Year: 2006 (anticipated); 
Funding source: Commodity Credit Corporation appropriations: 0.00; 
Funding source: State and private forestry appropriations: 1.90; 
Funding source: Research and development appropriations: 1.25; 
Funding source: Total: 3.15. 

Fiscal Year: Total; 
Funding source: Commodity Credit Corporation appropriations: $2.80; 
Funding source: State and private forestry appropriations: $11.97; 
Funding source: Research and development appropriations: $3.88; 
Funding source: Total: $18.65. 

Source: Forest Service. 

[End of table] 

APHIS issued a strategic plan in 2005 that projected $383,750,000 would 
be needed from fiscal years 2005 through 2018 to eradicate emerald ash 
borer. Of that total, $162,900,000 would be needed in Michigan, 
$87,250,000 in Ohio, and $31,050,000 in Indiana. However, actual 
funding levels in fiscal years 2005 and 2006 have been considerably 
lower than what APHIS believed was needed--$23.8 and $10.0 million 
versus $43 and $34 million, respectively--raising doubts about those 
long-term estimates. 

[End of section] 

Appendix V: Review of Efforts to Control and Eradicate P. ramorum: 

Our review of the efforts to control and eradicate Phytophthora ramorum 
(P. ramorum) includes a discussion of the origin and spread of the 
infestation in the United States and its potential impacts. We also 
review the roles of federal, state, and local government agencies in 
addressing infestations and describe the management structures and 
methods they have used to control and eradicate this plant pathogen. 
Finally, we discuss the current status of the P. ramorum infestation 
and outline the funds spent to date on controlling and eradicating the 
pathogen. 

Origin and Potential Impacts of P. ramorum: 

P. ramorum is a recently introduced plant pathogen of unknown origin 
currently found in natural and nursery environments in North America 
and Europe. It is unclear how the pathogen arrived in the United 
States. The pathogen is the causal agent of the plant disease known as 
Sudden Oak Death and has caused the death of tens of thousands of 
tanoak and true oak trees throughout central coastal 
California.[Footnote 51] P. ramorum has also infected thousands of 
shrubs and herbaceous plants in natural and nursery environments. The 
pathogen can spread via spores that move through water, moist soil, 
wind-blown rain, and the movement of infected plant materials. Moisture 
seems to be an important factor for the pathogen's survival and spread, 
and the natural infestation appears along the path of the coastal fog 
belt in California. In addition, detecting infected plants can be 
difficult due to the variability of symptoms by species. The large 
range of hosts and the varying symptoms have added to the difficulty in 
managing P. ramorum. 

In the mid-1990s, hikers noticed the apparent sudden death of tanoaks 
in the populated, wildland-urban interface environments of Marin, Santa 
Cruz, and Monterey counties in California. Despite the public reporting 
of observed tree mortalities, no action was taken to determine the 
cause until coast live oaks began to show signs of decline in 1997. By 
the end of 2001, the infestation had spread to 9 California counties 
and was found on 40 acres in Curry County, Oregon.[Footnote 52] Since 
that time, the pathogen has continued to spread in California's natural 
environment and now infests 14 central counties. 

The Forest Service constructed a preliminary risk map of the United 
States in 2002, to determine the highest risk natural areas for 
potential P. ramorum infestations on the basis of potential pathways, 
susceptible plant species, and weather conditions favorable to the 
spread and survival of the pathogen. (See fig. 9 in the letter of this 
report.) The map indicates that the Appalachian Mountains and the 
coastal areas of California, Oregon, and Washington are at the greatest 
risk of possible infestation. The map suggests areas of lower risk, 
based on moisture and temperature, among other factors, that may serve 
as a barrier to P. ramorum's natural spread between the western and 
eastern United States. The risk map also demonstrates the threat posed 
by the artificial spread of the pathogen to the oak forests of the 
eastern United States. The first detection of the pathogen on a nursery 
plant--a rhododendron--occurred in January 2001, in a California 
nursery surrounded by a heavily P. ramorum-infested forest. However, 
the discovery did not raise much concern within the nursery industry or 
the scientific community in California since the pathogen was still 
perceived to be primarily a threat to the natural landscape. This was 
despite the presence of a different population and mating type of P. 
ramorum infesting European nurseries and garden centers. In March 2004, 
the APHIS P. ramorum National Nursery Survey discovered the pathogen on 
camellias in a large nursery in Los Angeles County, California, an area 
considered to be low risk for the spread of P. ramorum. Agency 
officials determined that the nursery had shipped potentially infected 
plants to over 1,200 establishments in 39 states. By the end of 2004, 
APHIS confirmed P. ramorum at 176 sites in 22 states, and over 1 
million nursery plants were destroyed as a result of the detections. 

The long-term environmental impacts of P. ramorum are not well 
quantified. Government agencies estimate that P. ramorum has killed 
tens of thousands of trees in California and hundreds in Oregon, 
although the true number of mortalities is unknown. The extent of P. 
ramorum infestation in the natural environment is oftentimes difficult 
to determine since the distribution of mortality within the landscape 
is patchy. Also, secondary pests often infect P. ramorum-infected 
trees, making diagnosis difficult. However, in some areas, mortality 
can be as high as 85 percent. The Forest Service is conducting an 
analysis to determine the number of tree mortalities, but the results 
are still pending. Oak species are important for forest and woodland 
biodiversity, and tree mortality resulting from P. ramorum can lead to 
the loss of food and habitat for wildlife, increase the risk of fire, 
and cause soil erosion. 

The economic impacts associated with P. ramorum affect several 
stakeholder groups, including the forest and horticultural industries. 
The oak hardwood forest is the largest forest type in the United States 
and is an important commodity in the timber products industry. The 
Forest Service has estimated the potential threat to commercial timber 
production could potentially exceed $30 billion dollars if P. ramorum 
were to become established in the eastern deciduous forests. 
California's timberlands alone are valued at over $500 million for 
forest products. Furthermore, live oaks play a more important role in 
the local ecology as one of the key drought tolerant species and are 
widely prevalent as a landscape tree, adding to property values in 
upscale communities. In addition to the timber industry, the potential 
impact of the pathogen to the U.S. nursery industry is high. Since the 
pathogen was detected in nurseries in 2002, damage to the nursery 
industry has been estimated to be between $3 and $17 million, including 
costs associated with inventory management, green waste disposal, and 
insurance. This estimate does not, however, include lost sales. 

Despite affecting an area with a population of more than 7 million 
people, the true social impact of P. ramorum has yet to be determined. 
Affected stakeholders include homeowners, Native American tribe 
members, arborists, and firefighters. For example, the Kashia tribe, 
currently the only Native American tribe with P. ramorum on their 
lands, has historically used the tanoak acorn as one of the main 
staples in their diet. Tanoak acorns and other host plants are also 
used in ceremonial dress and baskets. The sociocultural impact of the 
loss of tanoak trees on this community is difficult to quantify. 
Likewise, it is equally difficult to quantify the impact of the loss of 
coast live oaks to neighborhoods in which they are a primary ornamental 
species. 

Federal, State, and Local Roles in Efforts to Control and Eradicate P. 
ramorum: 

At the federal level, APHIS regulates the interstate movement of host 
and associated host plants and other regulated articles from 
quarantined areas in California and Oregon. In addition to funding 
inspections in regulated states, APHIS has also coordinated inspections 
at nurseries in states across the country. To date, the Forest 
Service's primary activities have included sponsoring extramural 
research projects and coordinating surveys of forested areas. 

State agriculture departments in California and Oregon regulate the 
intrastate movement of regulated articles, monitor quarantines, and 
undertake eradication efforts that take place within their own state. 
Through cooperative agreements with APHIS, regulated states also 
inspect nurseries that ship hosts and associated host plants 
interstate. In California, the state agriculture department contracts 
with the county agriculture inspectors to inspect interstate shipments 
and conduct annual nursery inspections. Other state agriculture 
departments participate in the P. ramorum National Nursery Survey by 
sampling high-risk nurseries in their state. In addition, state 
forestry and natural resource departments inspect forests for the 
National P. ramorum Survey of Forest Environments in partnership with 
the Forest Service. 

In contrast to California's control program, Oregon is attempting to 
eradicate the pathogen from a small portion of Curry County with 
assistance from the Forest Service. Aerial surveys first detected 
symptoms of the pathogen in July 2001, and subsequent extensive ground 
surveys of the area determined the infestation to be limited to 40 
acres within a 9-square mile area. Oregon and the Forest Service 
established an eradication program that clearcut and burned host trees 
and plants in the infested area. As of December 2005, the program had 
identified 51 infested sites in Oregon covering a total of 88 acres and 
increased the quarantine area to 22 square miles in early 2006. 

Efforts to Control and Eradicate P. ramorum: 

* Overarching strategy: Because there is no cure, minimizing the 
artificial spread of P. ramorum is the primary management action in 
California. Based on the widespread natural area currently infested by 
P. ramorum along the central California coast, containment of the 
pathogen through quarantine regulation is the only feasible alternative 
since the current level of infestation is too widespread to attempt 
large eradication efforts. However, in areas where the infestation is 
not considered to be widespread, more aggressive, slow-the-spread or 
eradication efforts can be implemented. For example, in addition to the 
eradication effort in Curry County, Oregon, the Forest Service is 
coordinating a slow-the-spread project in Humboldt County, California, 
where the infestation is relatively small. These efforts include early 
detection and monitoring of the area, selectively removing host plants 
to limit pathogen spread, eradicating hot spots, and using various 
fungicides to inhibit sporulation of P. ramorum on tanoaks. For 
nurseries with confirmed positive detections, APHIS's regulatory 
protocol is to destroy all host and associated plats and plant parts 
within a specific block area. However, this destruction does not ensure 
eradication and several nurseries have had subsequent outbreaks. APHIS 
is revising the protocol in an effort to prevent these reoccurrences. 

* Surveys: APHIS and the Forest Service have joined with state agencies 
across the country to survey for P. ramorum in nurseries and forest 
environments. APHIS coordinates the P. ramorum National Nursery Surveys 
with state agriculture departments. The agency's goal is to survey high-
risk nurseries in all 50 states to determine whether the pathogen has 
been spread artificially through infected nursery stock. Any positive 
detection of the pathogen in nurseries would trigger further 
investigations to determine the movement of potentially infected plants 
between nurseries and customers. The Forest Service has conducted 
aerial and ground surveys in California and Oregon to identify 
infestations, and is coordinating the National P. ramorum Survey of 
Forest Environments with state forestry agencies to inspect forests 
near nurseries that have received plants from areas that are considered 
high-risk. 

* Quarantines: Although Oregon and California took action to prevent 
the pathogen's artificial spread through intra-and interstate 
quarantines and regulations beginning in 2001, the federal government 
was slower to enact regulations. In February 2002, APHIS issued an 
interim rule quarantining 10 counties in California and part of Curry 
County, Oregon, and regulating nurseries that operated within the 
quarantined counties that shipped host or associated host plants or 
other regulated articles outside of the area. At that time, knowledge 
of the pathogen's life cycle was limited, and it was believed that 
areas in Southern California would be inhospitable due to the dryness 
and heat. In March 2004, it came as a surprise when the P. ramorum 
National Nursery Survey confirmed detections of the pathogen in a 
Southern California nursery well over 400 miles from the nearest known 
infested forest. Shipments from this nursery were traced to over 1,200 
establishments in 39 states. Within 1 month, 15 states imposed their 
own quarantines on nursery products and some states banned outright all 
California nursery stock shipments. California nurseries were estimated 
to have suffered $4.3 million in lost sales for March 2004. 

APHIS responded to the positive nursery detections by issuing an 
emergency order extending the quarantine to 2 additional California 
counties on April 9, 2004, requiring all California nurseries shipping 
host and associated articles interstate from nonquarantined counties to 
be visually inspected and tested before shipping occurred. However, 
after meetings with the National Plant Board and the National 
Association of State Departments of Agriculture, APHIS amended the 
emergency order on April 22, 2004, to require California nurseries in 
the nonquarantined counties that shipped P. ramorum hosts and 
associated articles interstate to be inspected by a regulatory 
official, sampled, and tested for the disease before shipping. 

Despite the federal quarantines and order, some states continued to 
quarantine nursery products from California. Five states requested a 
Special Needs Exemption from the federal regulations in July 2004, but 
APHIS denied those requests.[Footnote 53] In addition, California and 
the nursery industry requested that APHIS take measures against the 
states that were imposing quarantines more stringent than the federal 
government's. APHIS, however, did not take action against these states. 
In July 2004, the California Association of Nurseries and Garden 
Centers filed a suit against the Commissioner of the Kentucky 
Department of Agriculture and others claiming the state violated the 
Supremacy Clause of the United States Constitution and the federal 
Plant Protection Act by regulating California nursery stock for P. 
ramorum in a manner that is inconsistent with and exceeds federal 
regulation. The lawsuit was settled the same month and the court 
entered a consent order under which the Kentucky defendants agreed to a 
permanent injunction prohibiting implementation or enforcement of any 
regulations, orders, policies, or quarantines for P. ramorum that are 
inconsistent with or in excess of USDA's regulation of the pathogen. 

Also in July 2004, APHIS conducted a review of its P. ramorum 
management program to analyze current USDA policy, the regulatory 
responses, and the status of P. ramorum in the United States. In a 
memorandum to the APHIS Administrator, the PPQ Deputy Administrator 
wrote that while eradication in the natural environment is likely not 
viable because that pathogen is too widespread, quarantine regulations 
should continue. Another outcome was the decision to expand the federal 
order when needed on the basis of each situation's specific risk of 
spreading P. ramorum in interstate trade. 

After much deliberation with stakeholders, APHIS issued an emergency 
federal order on December 21, 2004, that went into effect on January 
10, 2005, replacing the earlier emergency order. The order--which 
expires in January 2008--requires all nurseries in California, as well 
as Oregon and Washington, that ship host and associated plant nursery 
stock interstate to have their nursery stock inspected, sampled, 
tested, and certified free of P. ramorum. In addition, nurseries in a 
quarantined area that ship nonhost plants interstate must undergo an 
annual visual inspection. APHIS will decide what further actions need 
to be taken to control P. ramorum when the emergency order expires in 
2008. 

Status of the P. ramorum Infestation: 

At this time, there is no known cure for plants infected with P. 
ramorum. Although a number of fungicides are being tested, there is no 
chemical treatment available to eliminate P. ramorum when the pathogen 
is well-established in the natural environment or on nursery stock. 
Without a cure, minimizing the artificial spread of P. ramorum is the 
primary management action. Currently, P. ramorum is known to infect 
species in more than 55 plant genera. The complete list of hosts is 
unknown and continues to grow as additional infected species are 
identified. As of October 2005, the P. ramorum National Nursery Survey 
had identified 25 positive detections in nurseries in 2005. Changes in 
the federal order, effective January 2005, have increased nursery 
inspections and by the end of 2005, APHIS found 99 confirmed positive 
detections of P. ramorum associated with nursery plants in 7 states, a 
decline from 2004. Key stakeholders with whom we spoke do not believe 
the pathogen can be eradicated from the natural environment in 
California. However, the infestation in Oregon has been contained to a 
small portion of Curry County, and many of the stakeholders with whom 
we spoke are optimistic about controlling and eventually eradicating 
its spread in Oregon and the nursery environment. 

Funding of Efforts to Control and Eradicate P. ramorum: 

Several federal and state agencies contribute funding and resources to 
the P. ramorum program. APHIS provides funding in the form of annual 
cooperative agreements to regulated states for management activities, 
such as inspecting, sampling, and testing nursery plants. The Forest 
Service has provided infrastructure support and funding to the 
California Oak Mortality Task Force[Footnote 54] for public outreach 
since 2000. The agency has also provided funds to Oregon for 
eradication activities in Curry County. Additional contributions to P. 
ramorum management by other USDA agencies, such as the Agricultural 
Research Service and the Cooperative State Research, Education, and 
Extension Service, include providing training and educational materials 
to diagnose infected plants in the landscape environment, improving 
diagnostics, and developing fungicides. Table 5 outlines the funds 
spent by various USDA agencies to control P. ramorum between fiscal 
years 2000 and 2005. 

Table 5: Summary of USDA funding for P. ramorum, Fiscal Years 2000 
Through 2005: 

Dollars in millions. 

Fiscal year: 2000; 
Funding, by USDA agency: Forest Service: $0.12; 
Funding, by USDA agency: Animal and Plant Health Inspection Service: 
$0.00; 
Funding, by USDA agency: Agricultural Research Service: $0.00; 
Funding, by USDA agency: Cooperative State Research, Education, and 
Extension Service: $0.00; 
Funding, by USDA agency: Total: $0.12. 

Fiscal year: 2001; 
Funding, by USDA agency: Forest Service: 4.20; 
Funding, by USDA agency: Animal and Plant Health Inspection Service: 
0.00; 
Funding, by USDA agency: Agricultural Research Service: 0.00; 
Funding, by USDA agency: Cooperative State Research, Education, and 
Extension Service: 0.00; 
Funding, by USDA agency: Total: 4.20. 

Fiscal year: 2002; 
Funding, by USDA agency: Forest Service: 0.97; 
Funding, by USDA agency: Animal and Plant Health Inspection Service: 
0.90; 
Funding, by USDA agency: Agricultural Research Service: 0.00; 
Funding, by USDA agency: Cooperative State Research, Education, and 
Extension Service: 0.00; 
Funding, by USDA agency: Total: 1.87. 

Fiscal year: 2003; 
Funding, by USDA agency: Forest Service: 3.70; 
Funding, by USDA agency: Animal and Plant Health Inspection Service: 
2.00; 
Funding, by USDA agency: Agricultural Research Service: 0.62; 
Funding, by USDA agency: Cooperative State Research, Education, and 
Extension Service: 0.30; 
Funding, by USDA agency: Total: 6.62. 

Fiscal year: 2004; 
Funding, by USDA agency: Forest Service: 3.70; 
Funding, by USDA agency: Animal and Plant Health Inspection Service: 
19.50; 
Funding, by USDA agency: Agricultural Research Service: 1.30; 
Funding, by USDA agency: Cooperative State Research, Education, and 
Extension Service: 0.30; 
Funding, by USDA agency: Total: 24.80. 

Fiscal year: 2005; 
Funding, by USDA agency: Forest Service: 4.40; 
Funding, by USDA agency: Animal and Plant Health Inspection Service: 
12.40; 
Funding, by USDA agency: Agricultural Research Service: 1.00; 
Funding, by USDA agency: Cooperative State Research, Education, and 
Extension Service: 0.12; 
Funding, by USDA agency: Total: 17.92. 

Fiscal year: Total; 
Funding, by USDA agency: Forest Service: $17.09; 
Funding, by USDA agency: Animal and Plant Health Inspection Service: 
$34.8; 
Funding, by USDA agency: Agricultural Research Service: $2.92; 
Funding, by USDA agency: Cooperative State Research, Education, and 
Extension Service: $0.72; 
Funding, by USDA agency: Total: $55.53. 

Source: USDA. 

[End of table] 

[End of section] 

Appendix VI: Risk Analysis as a Tool to Address Invasive Forest Pests: 

The PPQ organization within APHIS is the primary federal agency 
responsible for protection of the nation's public and private forests 
from invasive forest pests, while providing for movement of agriculture 
and other commodities across the United States and its borders. In 
1999, President Clinton signed Executive Order 13112 on invasive 
species. The order established the National Invasive Species Council, 
in part, to coordinate the federal government's efforts to manage risks 
associated with invasive pests. The order also called for a scientific 
process to evaluate risks associated with the introduction and spread 
of invasive pests and to develop a risk-based process for control and 
management of invasive pests. Furthermore, under the World Trade 
Organization's Agreement on the Application of Sanitary and 
Phytosanitary Measures (SPS), the United States must be able to justify 
protection measures against invasive pests on the basis of scientific 
principles and a risk assessment and protection measures must not be 
applied in a manner that would constitute a disguised restriction on 
international trade. Consequently, risk analysis is important as it 
constitutes key evidence for member countries demonstrating that the 
measures they have adopted are to ensure human, animal, or plant 
protection, rather than to create arbitrary barriers to trade. To this 
end, APHIS develops and employs risk analysis as an essential tool in 
meeting its responsibilities for detection, control, as well as 
development of appropriate programs aimed at management of invasive 
pests. 

Although PPQ is the primary agency that assesses the risks that 
invasive plant pests pose to the United States' economy and 
environment, a large number of offices within USDA and APHIS are 
engaged in activities related to risk analysis. The Center for Plant 
Health Science and Technology (CPHST), in particular the Plant 
Epidemiology and Risk Analysis Laboratory group in the CPHST division 
of PPQ, is the scientific support organization that assesses the risks 
that invasive plant pests pose to the United States' economy. Risk 
Analysis Systems, a component of the Policy and Program Development 
(PPD) office within APHIS is devoted to basic investigations associated 
with risk analysis, data collection, quantitative methods, and other 
analytical support activities required for APHIS programs. The office 
of Policy Analysis and Development, also in PPD, provides economic 
analysis for rulemaking and cost-benefit analysis required for a USDA 
"major proposed regulation," the primary purpose of which is to 
regulate issues of human health, human safety, or the: 

environment.[Footnote 55] Finally, the Office of Risk Assessment and 
Cost-Benefit Analysis, under the office of USDA's Chief Economist, is 
to ensure that regulatory analyses include a risk assessment and cost- 
benefit analysis that are performed consistently and use reasonably 
obtained and sound scientific, economic, technical, and other data. 

In this appendix, we briefly give an overview of APHIS's responsibility 
for conducting risk analysis for detection, control, and regulation of 
invasive forest pests. We also define the essential component of risk 
analysis--risk assessment and risk management. Finally, we discuss what 
risk assessment was done by APHIS for the three pests investigated in 
this report. 

Pest Risk Assessment Is an Essential Element of Risk Analysis: 

Pest risk assessment is the essential first component of risk analysis; 
risk management and communication are the other components. In general, 
pest risk assessment involves estimating the likelihood of the 
introduction, establishment, and spread of invasive pests. Risk 
assessment also involves estimation of economic and environmental 
consequences associated with the spread and establishment of invasive 
pests. Risk management, however, involves identification and selection 
of appropriate risk management options; risk communication involves 
documentation and conveyance of this information to interested parties. 

In general, the protocol and terminology used by APHIS in conducting 
its risk assessments are developed pursuant to the international 
standards as established by the SPS and the International Plant 
Protection Convention (IPPC). Although SPS establishes the baseline 
requirement for the use of risk assessments, IPPC is the key 
organization for providing the detailed guidelines to be followed by 
member countries when conducting these assessments. IPPC guidelines are 
published by the Secretariat under a number of International Standards 
for Phytosanitary Measures (ISPM)--such as ISPM No. 11, which provides 
detailed guidance for risk analysis for quarantine pests.[Footnote 56] 
Under this standard, the process for risk assessment for quarantine 
pests involves a number of specific steps that could include, (1) 
identification of the pest or pathway risk for introduction of the 
pest, (2) estimation of the likelihood of pest entry, (3) estimation of 
the likelihood for establishment and spread, (4) estimation of economic 
and environmental consequences, and (5) integrating this and other 
information about risks into an overall conclusion about risk that will 
be useful to decision makers. 

Resources and data permitting, pest risk assessments can be conducted 
quantitatively where various likelihoods are quantified and integrated. 
Individual risk factors are combined, resulting in an overall 
conclusion about the pest risk. That is, the threat of establishment of 
the invasive pest and the economic and environmental impacts of the 
pest invasion. However, when data for quantitative evaluation are 
lacking, risk assessments are based on a more subjective assignment of 
the risk values and on qualitative scales, such as high, medium, or low 
risks. Such qualitative presentations usually omit the details that are 
included in the more rigorous quantitative risk assessments.[Footnote 
57] 

In general, in the absence of reliable data, APHIS relies, to a great 
extent, on qualitative analysis to assess the threat of invasive 
pests.[Footnote 58] For example, APHIS used a qualitative assessment to 
assess the risk for entry, establishment, and consequence of 
establishment of the Asian longhorned beetle associated with solid wood 
packing material imported from China. Three risk factors--entry, 
establishment, and consequences--were all rated "high." APHIS then 
combined these individual risk factors to arrive at one overall high- 
risk rating for the pest. 

Risk Assessment Is a Tool for Risk Management: 

The ultimate value of risk assessment is the extent to which it is used 
by risk managers to target activities, allocate resources, justify 
regulations, and improve the quality of their management decisions. In 
particular, risk assessment can be used to prioritize pest threats, 
targeting limited resources commensurate with the risk of pest threats, 
and to mitigation and control programs that most effectively address 
the most significant threats and produce the most impact for the 
resources invested. APHIS conducts risk assessments to be used for 
import and export and for emergency and regulatory programs. It also 
could integrate risk-based information in several aspects of its 
invasive pest management decision making. 

APHIS conducts risk assessments to assess the potential threat of 
introducing new and of exotic plant pests into the United States when 
permits are requested for importation of plants or plant 
products.[Footnote 59] Such risk assessment begins by determining the 
likelihood of a harmful pest becoming established in the United States 
and the magnitude of potential adverse consequences. When this risk is 
deemed unacceptable, the assessment could lead to identifying risk 
mitigation options and eventually to decisions to authorize, prohibit, 
or allow importation under specific conditions, depending on the risk 
and potential adverse effects of the pest. Furthermore, for invasive 
pests that have previously entered the United States, risk assessments 
can be conducted to estimate the likelihood and potential damage of 
further spread across the country and to support decision makers' 
allocation of resources to different control and eradication measures. 

Risk assessment can also become a component of economic analysis 
required for rulemaking to regulate invasive pests. The Policy Analysis 
and Development office provides economic impact and cost-benefit 
analysis. When available, risk assessment can be used as an additional 
input for conducting regulatory impact analysis and is a component of 
information forwarded to decision makers, along with economic analysis. 

Finally, risk assessment can be a valuable tool used by decision makers 
in budget development, resource allocation, and prioritization programs 
and strategies to control the threat of invasive pests. 

APHIS Has Conducted Risk Assessments for P. ramorum and the Asian 
Longhorned Beetle: 

The risk assessments for the pests we reviewed were focused on showing 
that the pest problem is potentially significant and warrants a 
management response. We did not see analysis of the costs and benefits 
of taking specific management actions within specific time frames. 

The risk analysis for the pathogen P. ramorum was conducted and 
published in May 2005 by APHIS's Plant Epidemiology and Risk Analysis 
Laboratory. The analysis was aimed at assessing the risk associated 
with the importation and domestic spread of the pathogen. Such risk 
assessment would make possible the promulgation of regulations and 
present mitigation measures to prevent the movement and spread of the 
pest to noninfested areas of the United States. The assessment was 
conducted pursuant to relevant international standards published by 
IPPC and APHIS guidelines for pest risk assessments.[Footnote 60] 

In this risk analysis, a qualitative scale was used to rate all 
individual risk factors for P. ramorum. This led to an overall pest 
risk potential for this pest--to spread, infect, and cause potential 
economic and environmental consequences--of a "high" rating. In 
particular, as there are many areas in the United States with potential 
hosts and climates favorable to the pest, the rating for the Host- 
Climate Interaction Factor was judged to be "high." Similarly, given 
that many host plants are susceptible to infection by this pest, and 
that a number of other factors, both natural and human-assisted, can 
aid the dispersal of the pest to areas with suitable hosts and climate 
conditions, the risk rating for Host Range and Dispersal Potential 
factors were judged to be "high." As a result of a "high-" risk rating 
in these and other risk elements, the overall risk potential for the 
pest was assessed as "high." 

APHIS has not published similar detailed risk assessment studies for 
the emerald ash borer or the Asian longhorned beetle. However, in 1998, 
APHIS published a risk assessment report for the Asian longhorned 
beetle, as a part of a study examining the risks associated with solid 
wood packing material imported from China into the United States. 
According to this study, because of widespread detection of the pest in 
the United States, favorable climate, and a wide variety of hardwood 
tree hosts, both the risk of entry through this pathway and 
establishment of the Asian longhorned beetle in the United States were 
rated as "high." Furthermore, because many studies had suggested that 
the beetle could severely affect the forest resources and forest- 
related industries in the United States, the risk for potential 
consequences was also rated "high," leading to a "high" overall risk 
potential for infection from the Asian longhorned beetle in the United 
States. 

Finally, APHIS has not conducted an economic risk assessment for the 
emerald ash borer. The Forest Service generated some preliminary 
estimates of the damages that the ash borer could cause across the 
country, including the impacts on the ash timber industry and ash trees 
in residential areas. APHIS cited these estimates in support of its 
decision to impose quarantine regulations. The Forest Service is in the 
process of revising its analysis of the potential impact of ash 
mortality in urban areas; it expects to complete this analysis in early 
2006. 

[End of section] 

Appendix VII: Comments from the Department of Agriculture: 

USDA: 
United States Department of Agriculture: 
Office of the Secretary: 
Washington, D.C. 20250: 

March 29, 2006: 


Ms. Robin Nazzaro: 
Director: 
Natural Resources and Environment: 
United States Government Accountability Office: 
441 G Street, NW: 
Washington, D.C. 20548-0001: 

Dear Ms. Nazzaro: 

Thank you for the opportunity to review the draft Government 
Accountability Office (GAO) report GAO-06-353, entitled "AGRICULTURE 
INVASIVE SPECIES: Lessons Learned from Three Recent Infestations May 
Aid in Managing Future Efforts." We find the report to be comprehensive 
and well-written. 

Although we do not have major concerns regarding the three 
recommendations in the report, we do not completely agree with them. 
Accordingly, we offer following comments. 

The beginning and ending sections of the report seem appropriate, but 
intervening sections give an unfavorable impression of the job done by 
the agencies. Various agencies worked hard against these invasive 
species with some success. For example, the Asian long-horned beetle 
(ALB) is nearly eradicated from Chicago, and Sudden Oak Death (SOD) 
does not seem to be present in the forests of the eastern United 
States. On the other hand, the emerald ash borer (EAB) now seems well 
established in the United States. ALB and EAB were not on any list of 
potential or existing invasive species, and we could not have predicted 
they would enter the United States. Phythophora ramorum, the organism 
responsible for the plant disease known as sudden oak death (SOD), is a 
new pest previously unknown to science. Given these considerations, we 
believe that the coalition of Federal and State agencies and private 
collaborators did a reasonable job in combating these pests. We 
recognize that improvements can be made, but we disagree with the 
generally critical tone of the report. It is our view that decisions 
were made in a short time frame, in the heat of the crisis, and most of 
them were the correct decisions. 

Recommendation 1, to increase urban monitoring, focuses only on Federal 
government agencies. The effort to combat invasive species necessarily 
requires a partnership among personnel in Federal, State, university, 
tribal, business and non-governmental organizations. GAO did not 
examine the roles of these partners, their responsibilities, or the 
outcomes of their efforts. We suggest including all affected 
organizations in recommended actions. 

Recommendation 2, keeping management plans updated, is a sound business 
practice which we support. We believe a reasonable job was done in this 
regard, given the workload and the fact that there was the need to 
allocate resources to get the job done on-the-ground-which left little 
time to update management plans. 

Recommendation 3, put more rigor into how science panels are formed, 
seems reasonable. It implies, however, that people who had important 
information to share were not heard. We believe there were ample 
opportunities for all interested parties to be heard either directly or 
through representatives. The use of a Federal Advisory Committee Act-
chartered committee would hamper our flexibility in dealing with these 
invasive species issues, and we do not support implementing this 
recommendation at the Department of Agriculture. 

Thank you for providing us the opportunity to review the report and 
provide our comments. We look forward to seeing the final report. 

Sincerely, 

Signed by:  

Mike Johanns: 
Secretary: 

[End of section] 

Appendix VIII: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Robin Nazzaro, (202) 512-3841: 

Staff Acknowledgments: 

In addition to the individual named above, Trish McClure, Assistant 
Director; Ross Campbell; John Delicath; Dewi Djunaidy; Les Mahagan; 
Mehrzad Nadji; Jena Sinkfield; and Amy Webbink made major contributions 
to this report. Important contributions were also made by Laura Gatz; 
Gerry Laudermilk; Charlotte Moore; Judy Pagano; and Jay Scott. 

(360583): 

FOOTNOTES 

[1] When obtaining advice from a committee or similar group comprising, 
in part, nonfederal officials, it is possible that the committee may 
meet the Federal Advisory Committee Act's (FACA) definition of a 
federal advisory committee and be subject to FACA's requirements. For 
example, the act requires that advisory committees be fairly balanced 
in terms of points of view and the functions to be performed by the 
committee, and the act generally requires that committee meetings be 
open to the public. 

[2] The corporation has the authority to borrow up to $30 billion. The 
borrowed funds are repaid through periodic congressional 
appropriations. 

[3] GAO, Invasive Species: Cooperation and Coordination Are Important 
for Effective Management of Invasive Weeds, GAO-05-185 (Washington, 
D.C.: Feb. 25, 2005); and Invasive Species: Clearer Focus and Greater 
Commitment Needed to Effectively Manage the Problem, GAO-03-1 
(Washington, D.C.: Oct. 22, 2002). 

[4] Pub. L. No. 107-296, 116 Stat. 2135 (2002). 

[5] The report will be available on GAO's Web site, identified as GAO- 
06-644. 

[6] David J. Nowak, Judith E. Pasek, Ronaldo A. Sequeira, Daniel E. 
Crane, and Victor C. Mastro. "Potential Effect of Anoplophora 
glabripennis (Coleoptera: Cerambycidae) on Urban Trees in the United 
States." Journal of Economic Entomology, vol. 94, no. 1 (2001). 

[7] The term "genera," the plural form of genus, refers to a category 
of biological classification ranking between the family and the 
species, comprising related species. 

[8] One stakeholder, a member of academia, did not believe eradication 
is possible under the current management program. 

[9] The various trees that serve as hosts for the Asian longhorned 
beetle include the following: very good hosts are maple, boxelder, 
horsechestnut, buckeye, willow, and elm trees; good hosts are birch and 
London plane trees; and occasional hosts are mimosa, hackberry, ash, 
poplar, and mountain ash trees. 

[10] David J. Nowak, Judith E. Pasek, Ronaldo A. Sequeira, Daniel E. 
Crane, and Victor C. Mastro. "Potential Effect of Anoplophora 
glabripennis (Coleoptera: Cerambycidae) on Urban Trees in the United 
States." Journal of Economic Entomology, vol. 94, no. 1 (2001). 

[11] The Forest Service Web address for this information is http:// 
www.fs.fed.us/ne/syracuse/Data/Nation/data_list_alb.htm. 

[12] USDA estimates that there are approximately 8 billion ash trees in 
U.S. forests. 

[13] USDA is in the process of refining this estimate. 

[14] Fifteen of the 16 stakeholders did not believe eradication was 
possible; 1 stakeholder was uncertain. 

[15] In July 2001, APHIS designated P. ramorum as a domestic control 
program rather than an eradication program after determining that the 
infestation in California was too widespread to eradicate. A domestic 
program is one in which the agency expects to engage in suppression for 
an indefinite period of time. 

[16] Epicormic shoots are sprouts that emerge from dormant buds along 
the trunk or branch of a tree. They can form in response to stress 
inflicted upon the tree. 

[17] The Plant Protection Act generally prohibits states from 
regulating the interstate movement of any article, means of conveyance, 
plant, biological control organism, plant pest, noxious weed, or plant 
product in order to control a plant pest or noxious weed, eradicate a 
plant pest or noxious weed, or prevent the introduction or 
dissemination of a biological control organism, plant pest, or noxious 
weed, if the Secretary has issued a regulation or order to prevent the 
dissemination of the biological control organism, plant pest, or 
noxious weed within the United States. However, a state may impose 
prohibitions or restrictions if (1) they are consistent with and do not 
exceed APHIS regulations or orders or (2) the state (or political 
subdivision of a state) demonstrates to APHIS that there is a special 
need for additional prohibitions or restrictions based on sound 
scientific data or a thorough risk assessment. 

[18] The California State Board of Forestry declared known areas of 
infestation to be "zones of infestation" in April 2001, thereby 
effectively regulating all timber harvesting plans in those zones. 

[19] Four of the 9 Asian longhorned beetle stakeholders, all 12 of the 
emerald ash borer stakeholders, and 13 of the 16 P. ramorum 
stakeholders we interviewed noted the lack of control technologies. 

[20] By "eradication," we mean the actual killing of pests that are 
infesting trees and plants. We recognize that there are other important 
components of a management program, including surveys, quarantines, 
preventive treatments, and public outreach, that may help reduce their 
spread. 

[21] "Biological control" is the use of an animal, insect, or disease 
to reduce the population of an invasive species. Ideally, the 
controlling animal, insect, or disease affects only the targeted 
species. 

[22] See Consolidated Appropriations Act, 2004, Pub. L. No. 108-199, 
§761 (2004). This prohibition has also been included in subsequent 
appropriations legislation. 

[23] OMB Statement of Administrative Policy on S. 1427 (Nov. 5, 2003). 

[24] For more on the issue of CCC funding, see Congressional Research 
Service, Funding Plant and Animal Health Emergencies: Transfers from 
the Commodity Credit Corporation (July 30, 2004). 

[25] The Nonnative Bark Beetle Survey also addresses nun moths. 

[26] The focus of the 2002 pilot, the P. ramorum National Nursery 
Survey, was on nurseries that had received known host plant material 
from Europe, California, or Oregon within the past few years; nurseries 
located in areas where native vegetation included host plants; and 
nurseries that carried listed host plant material. 

[27] In 2004, the forest survey did find two infected coast live oaks 
in Golden Gate Park. 

[28] U.S. Department of Agriculture, Forest Service, The Early Warning 
System for Forest Health Threats in the United States. 

[29] Pub. L. No. 108-148, § 601(c)(2003). 

[30] The project had a third component that sought to combine the 
protocols and methods of the first two components into a technology 
transfer effort for the benefit of local communities. According to the 
national program manager, the Forest Service is no longer funding that 
component. 

[31] We administered a structured interview to 37 stakeholders--9 
involved with the Asian longhorned beetle, 12 with the emerald ash 
borer, and 16 with P. ramorum. The government officials included 
federal, state, and local officials directly engaged in one of the pest 
management efforts; nongovernmental officials included academic 
scientists with expertise in one of the pests and representatives from 
the nursery industry affected by one of the pests and by quarantine 
regulations. 

[32] Stakeholders who believed that improvements could be made included 
some who did not believe appropriate mechanisms had been created and 
some who did. All 16 P. ramorum stakeholders, 7 of 12 emerald ash borer 
stakeholders, and 6 of 9 Asian longhorned beetle stakeholders believed 
improvements could be made to federal coordinating mechanisms. 

[33] Cooperative extension agents are part of the Cooperative State 
Research, Education, and Extension Service. 

[34] National Invasive Species Council, General Guidelines for the 
Establishment and Evaluation of Invasive Species Early Detection and 
Rapid Response Systems, Version 1 (2003). 

[35] Pub. L. No. 108-488, 118 Stat. 3964 (2004). 

[36] APHIS has drafted protocols outlining the response to positive P. 
ramorum finds in the forest and wildland environments. Under the draft 
protocols, it would be at the states' discretion whether or not to 
undertake eradication efforts. 

[37] Pub. L. No. 92-463, 86 Stat. 770 (1972) (classified at 5 U.S.C. 
app. 2). Under FACA, an "advisory committee" is defined as any 
committee, board, commission, council, conference, panel, task force, 
or similar group, or any subcommittee or other subgroup thereof, which 
is established by statute or reorganization plan, or established or 
utilized by the President or by one or more agencies, in the interest 
of obtaining advice or recommendations for the President or one of more 
federal agencies. The term "advisory committee" does not include (1) 
any committee composed wholly of full-time federal employees or (2) any 
committee created by the National Academy of Sciences or the National 
Academy of Public Administration. Federal advisory committees play an 
important role in the development of public policy and government 
regulations by providing advice to policymakers on a wide array of 
issues. 

[38] Results from nonprobability samples cannot be used to make 
inferences about a population because, in a nonprobability sample, some 
elements of the population being studied have no chance or an unknown 
chance of being selected as part of the sample. 

[39] The Asian longhorned beetle is also known by its scientific name, 
Anoplophora glabripennis. 

[40] The various trees that serve as hosts for the Asian longhorned 
beetle include the following: maple, boxelder, horsechestnut, buckeye, 
willow, elm, birch, London plane, hackberry, ash, mimosa, poplar, and 
mountain ash. 

[41] David J. Nowak, Judith E. Pasek, Ronaldo A. Sequeira, Daniel E. 
Crane, and Victor C. Mastro. "Potential Effect of Anoplophora 
glabripennis (Coleoptera: Cerambycidae) on Urban Trees in the United 
States." Journal of Economic Entomology, vol. 94, no. 1 (2001). 

[42] The date of the declaration is the final date following a public 
hearing as required by state law. 

[43] The emerald ash borer is also known by the scientific name Agrilus 
planipennis Fairmaire. 

[44] The Forest Service is in the process of refining this estimate. 

[45] The group included representatives from APHIS, the Forest Service, 
USDA's Agricultural Research Service, the Michigan Department of 
Agriculture, Michigan State University, the National Plant Board, and 
the Oregon Department of Agriculture. (Oregon was represented by an 
expert on similar beetles.) 

[46] As of December 2005, the panel consisted of two APHIS employees, 
one Forest Service employee, two university professors, one state 
employee, three Canadian government employees, and one retired Forest 
Service employee. 

[47] Ash is a hardwood. All hardwoods are regulated as a precaution 
because of the difficulty of distinguishing ash firewood from some 
other species of hardwood, such as oak or maple. 

[48] This is a huge number of trees. However, to put the number in 
perspective, note that the trees include saplings that can be less than 
1 inch in diameter. 

[49] Infested sites slated for eradication are not all equal. To define 
a site, surveyors map a ½ mile radius around a single infested tree. If 
that is the only infested tree found in the area, the eradication zone 
will be about 8/10 of a square mile. If multiple trees in the area are 
infested, the size of the eradication zone becomes larger. For example, 
one eradication zone in Indiana is about 10 square miles in size. The 
number of ash trees that need to be cut in each area may vary greatly, 
thereby affecting the time and expense of the eradication project. 

[50] On January 20, 2006, the department reported the detection of an 
infestation in Hamilton County. The department estimated it had been 
there for 7 years. 

[51] The tanoak, Lithocarpus densiflorus, is not a member of the oak 
genus. 

[52] According to the Oregon Department of Forestry, there is no 
evidence of the pathogen spreading from California to Oregon. 

[53] Under the Plant Protection Act, a state may not regulate pests 
more stringently than USDA, unless the state has requested and the 
Secretary of Agriculture has made a finding of "special need" based on 
sound scientific data or a thorough risk assessment. 

[54] The California Oak Mortality Task Force is a coalition of research 
and educational institutions, public agencies, nonprofit organizations, 
and private interests. Its stated objectives include assisting 
communities affected and threatened by P. ramorum and providing 
information and education to interested parties. 

[55] A "major regulation" is any regulation that the Secretary of 
Agriculture estimates is likely to have an annual economic impact on 
the U.S. economy of $100 million in 1994 dollars. 

[56] IPPC defines a "quarantine pest" as a pest of potential economic 
importance to the area the pest endangers but not yet present there, or 
present but not widely distributed and being officially controlled. 

[57] A more rigorous analysis could, for example, assign ranges and 
probability distributions to introduction, rate of spread, or 
effectiveness of controls being applied to invasive pests and using 
probability models make projections as to what might happen. 

[58] The study, Economic and Policy Implications of Wind-Borne Entry of 
Asian Soybean Rust into the United States, is one example of a more 
rigorous analysis of invasive pests. It was conducted by the Economic 
Research Service in collaboration with other USDA offices. The study 
which was completed in 2004, explicitly introduces probabilities to 
quantify the likelihood of various occurrences and specifies various 
geographic scenarios of rust outbreak extent and yield loss to estimate 
a range of economic impacts on agriculture producers and consumers. 

[59] More specifically, risk assessment associated with trade includes 
commodity risk assessment for plants and plant products proposed for 
import; pathway risk assessment associated with baggage, packing 
materials, and mail; and export risk assessment to support market 
access for the United States exports. 

[60] USDA, APHIS, PPQ, Permits and Risk Assessment Commodity Risk 
Analysis Branch, Guidelines for Pathway-Initiated Pest Risk 
Assessments, Version 5.02 (October 2000). 

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Voice: (202) 512-6000: 

TDD: (202) 512-2537: 

Fax: (202) 512-6061: 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm 

E-mail: fraudnet@gao.gov 

Automated answering system: (800) 424-5454 or (202) 512-7470: 

Public Affairs: 

Jeff Nelligan, managing director, 

NelliganJ@gao.gov 

(202) 512-4800 

U.S. Government Accountability Office, 

441 G Street NW, Room 7149 

Washington, D.C. 20548: