    Invasive Forest Pests: Lessons Learned from Three Recent
    Infestations May Aid in Managing Future Efforts (21-APR-06,
    GAO-06-353).

    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.
    -------------------------Indexing Terms-------------------------
    REPORTNUM:   GAO-06-353
        ACCNO:   A52158
      TITLE:     Invasive Forest Pests: Lessons Learned from Three Recent
    Infestations May Aid in Managing Future Efforts
         DATE:   04/21/2006
      SUBJECT:   Agricultural pests
    	     Environmental monitoring
    	     Forest conservation
    	     Forest management
    	     Invasive species
    	     Performance appraisal
    	     Performance measures
    	     Pest control
    	     Pests
    	     Strategic planning
    	     Policy evaluation

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    GAO-06-353

         * 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
         * Contents
              * Results in Brief
              * Background
                   * Potential Economic and Environmental Impacts of Invasive
                     Species
                   * Federal and State Responsibilities
                   * The Asian Longhorned Beetle
                   * The Emerald Ash Borer
                   * P. ramorum
              * Eradicating the Asian Longhorned Beetle Appears Likely, While
                Success on the Emerald Ash Borer and P. ramorum Is Less Promising
                   * Program Officials Believed That the Asian Longhorned Beetle
                     Will Be Eradicated
                   * Eradicating the Emerald Ash Borer Does Not Appear Likely
                   * Eradicating P. ramorum-the Pathogen That Causes Sudden Oak
                     Death-Does Not Appear Likely
              * Efforts to Eradicate These Pests Have Been Affected by Several
                Factors
                   * Biological Characteristics of Each Species Greatly Affect
                     the Success of Control Efforts
                        * Asian longhorned beetle
                        * Emerald ash borer
                        * P. ramorum
                   * Delays in Detecting and Identifying the Asian Longhorned
                     Beetle, the Emerald Ash Borer, and P. ramorum Allowed These
                     Pests to Become Established and Spread
                   * Stakeholders Believed That Quarantines Have Helped Slow the
                     Spread of These Pests, but Implementation Is Difficult
                        * Quarantines Have Helped Limit the Artificial Spread of
                          Pests
                        * Quarantine Boundaries May Not Have Been as Inclusive as
                          Needed Due to Limited Information
                        * Enforcing Compliance with Quarantines Is Difficult
                   * Agencies Lack Effective Technologies for Detecting and
                     Eradicating These Forest Pests
                        * Delineating Infested Areas Is Resource Intensive and
                          Not Always Reliable
                        * Methods for Eradicating Pests Are Limited to Destroying
                          Infested Material
                        * Preventative Treatments Are Only Practical in Limited
                          Applications
                   * Insufficient Funding Has Delayed Eradication of the Asian
                     Longhorned Beetle and Threatens Containment of the Emerald
                     Ash Borer and P. ramorum
                        * Federal Funding for These Three Pest Programs
                        * Federal Funding Constraints Raise Concerns about
                          Achieving Program Goals
              * Forest Health Monitoring Does Not Adequately Address Urban
                Forests
                   * USDA Forest Health Monitoring Programs Cover a Variety of
                     Geographic Areas and Forest Conditions
                   * Surveys for Potentially Harmful Forest Pests Do Not
                     Adequately Cover Urban Areas
              * Coordination Problems Caused Concerns among Stakeholders, and
                Communication on the Status of Pest Responses Is Not Adequate
                   * Stakeholders Generally Believed Appropriate Coordinating
                     Mechanisms Exist, but Suggested Improvements That Could Aid
                     Future Management Efforts
                   * The Status, Direction, and Resource Needs of Pest Response
                     Efforts Are Not Clear from Publicly Available Management
                     Plans
              * 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
         * Objectives, Scope, and Methodology
         * Questions from Structured Interview Guide Administered to Stakeholders
           Involved with the Three Pest Response Programs
              * Federal and State Coordination
              * Imposition and Enforcement of Quarantines
              * Education and Outreach
              * Management Tools and Research
              * Funding Responsibility
              * Funding Mechanisms
              * Risk Assessment and Funding Needs
              * Prospects for Success
         * 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
         * 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
         * 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
                   * Efforts to Control and Eradicate P. ramorum
              * Status of the P. ramorum Infestation
              * Funding of Efforts to Control and Eradicate P. ramorum
         * 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
         * Comments from the Department of Agriculture
         * GAO Contact and Staff Acknowledgments

    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

    Contents

    Tables

    Figures

    April 21, 2006Letter

    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.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.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:

    o 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.

    o 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.

    o 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.

    o 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.

    o 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.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.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.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.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)

    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)

    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.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

    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.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

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

    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.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.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.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

    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).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.13

    Figure 7: Approximate Range of North American Ash Tree Species

    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.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

    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.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

    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 1 1/2 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.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

    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:

    o 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.

    o 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.

    o 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)

    Early Detection and Rapid Response Contributed to the Likely Eradication
    of the Citrus Longhorned Beetle (con't)

    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

    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.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.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.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.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.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

    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.

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

    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.

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

    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.

    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.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.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.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:

    o 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.

    o 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.

    o Nonnative Bark Beetle Survey: In 2001, the Forest Service began a pilot
    of the Nonnative Bark Beetle Survey.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.

    o 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.

    o 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.

    o 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.

    o 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.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.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.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.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.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.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.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.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:

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

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

    o 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

    o 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.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.

    o 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.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.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.

    o 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.

    o 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.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:

    o 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.

    o 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.

    o 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
    h  ttp://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, Robin M. Nazzaro Director, Natural Resources and
    Environment

    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.1 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

                 Number of
               stakeholders,
                    by
                affiliation
                  Federal            State
                  agency             agency
    Forest             APHIS  Forest        Agriculture  Forestry       Local University  Nursery Total
    pests                    Service             agency        or  government            industry
    reviewed                                              natural      agency
                                                        resources
    Asian                  1       1                  3         0           2          1        1     9
    longhorned
    beetle
    Emerald                4       2                  3         2           0          1        0    12
    ash borer
    P. ramorum             3       3                  4         2           0          2        2    16
    Total                  8       6                 10         4           2          4        3    37

    Source: GAO.

    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.

    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.)

    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.1 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.2 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.3 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:

    o 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.

    o 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.

    o 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:

    o 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.

    o 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.

    o 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.

    o 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.

    o Illinois: Illinois established an initial quarantine in July 1998 and
    declared the beetle a nuisance in August 1998.4 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.

    o 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.

    o 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.

    o 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.

    o 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.

    o 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.

    o 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

    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
                             Funding source
    Fiscal year             Commodity Credit       Emerging plant pests  Total
                              Corporation funds             appropriations
    1997a                               $0.0                       $0.8   $0.8
    1998a                                0.0                        1.3    1.3
    1999                                 6.9                        0.0    6.9
    2000                                14.1                        2.1   16.2
    2001b                               49.6                        2.1   51.7
    2002                                14.6                       16.9   31.5
    2003                                 7.0                       26.2   33.2
    2004                                12.9                       30.0   42.9
    2005                                14.6                       30.0   44.6
    2006                                 0.0                       20.0   20.0
    Total                             $119.7                     $129.5 $249.2

    Source: APHIS.

    aAPHIS funded fiscal years 1997 and 1998 from its contingency fund.

    bAPHIS funded fiscal year 2001 from its Miscellaneous Pest fund.

    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.

    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.1 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.2 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

    o 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.

    o 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.

    o 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.3 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.4 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.

    o 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.

    o 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.

    o 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:

    o 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)
    firewood5 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.

    o 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.

    o 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.

    o 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.

    o 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.6 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.7 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 2006.8 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.

    o 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.

    o 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

           Dollars in
            millions
          Fiscal year          Funding source
                                   Commodity Credit      Other appropriated Total
                                  Corporation funds                   funds
    2002                                    $0.0                    $0.2  $0.2
    2003                                    14.6                     0.0  14.6
    2004                                    43.4                     1.5  44.9
    2005                                    18.8                     5.0  23.8
    2006                                     0.0                    10.0  10.0
    Total                                  $76.8                   $16.7 $93.5

    Source: APHIS.

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

        Dollars in
         millions
                        Funding source
    Fiscal year        Commodity Credit        State and   Research and  Total
                               Corporation private forestry    development
                            appropriations   appropriations appropriations
    2002                          $0.00            $0.04          $0.00  $0.04
    2003                           2.80             0.95           0.70   4.45
    2004                           0.00             4.59           0.80   5.39
    2005                           0.00             4.49           1.13   5.62
    2006                           0.00             1.90           1.25   3.15
    (anticipated)
    Total                         $2.80           $11.97          $3.88 $18.65

    Source: Forest Service.

    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.

    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.1 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.2 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

    o 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.

    o 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.

    o 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.3 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 Force4 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 Funding,
                   by USDA
                    agency
                     Forest   Animal and Agricultural    Cooperative State  Total
                    Service Plant Health     Research Research, Education,
                              Inspection      Service        and Extension
                                 Service                           Service
    2000           $0.12        $0.00        $0.00                $0.00  $0.12
    2001            4.20         0.00         0.00                 0.00   4.20
    2002            0.97         0.90         0.00                 0.00   1.87
    2003            3.70         2.00         0.62                 0.30   6.62
    2004            3.70        19.50         1.30                 0.30  24.80
    2005            4.40        12.40         1.00                 0.12  17.92
    Total         $17.09        $34.8        $2.92                $0.72 $55.53

    Source: USDA.

    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.1 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.2 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.3

    In general, in the absence of reliable data, APHIS relies, to a great
    extent, on qualitative analysis to assess the threat of invasive pests.4
    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.5 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.6

    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.

    Appendix VII  Comments from the Department of Agriculture

    Appendix VIII  GAO Contact and Staff Acknowledgments

    Robin Nazzaro, (202) 512-3841

    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)

    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.

    Highlights of GAO-06-353 , a 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

    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 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.

    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.
    *** End of document. ***