September 14, 2009:
National Academy of Sciences panel reviews USDA report on reclassification 
Classifying Light Brown Apple Moth for Eradication, Quarantine Is Justifiable In Draft Response by APHIS to Petitioners(don't be fooled by the headline, the actual review is very critical of USDA's report and questions the eradication program)
view NAS press release National Academy of Science (NAS) Report Criticizes Light Brown Apple Moth Program: Concludes Science Lackingpress release Citizens for Health
press release Pesticide Watch
National Research Council Report: USDA’s Science on Light Brown Apple Moth Lacking, Risks Posed by Moth Overstated
A report by the National Research Council (NRC) released today found that the U.S. Department of Agriculture (USDA) has overstated the risks posed by the light brown apple moth (LBAM) and that USDA “did not conduct a thorough and balanced analysis” and did not communicate its justification for classifying the moth as a quarantinable pest “in a scientifically rigorous way or with sufficient clarity.”
“Overall,” the report by the NRC, part of the National Academy of Sciences, says, USDA’s analysis “would greatly benefit from the use of more robust science to support its position.”
The NRC report addressed an unpublished USDA response to two petitions filed last year requesting that LBAM be reclassified as a non-quarantinable insect because of the lack of evidence of LBAM damage in California and elsewhere in the world where the moth is naturalized.
“The biological data presented in the [USDA] Response to support the invasive nature of LBAM, its history in California, and its potential geographic distribution in the United States are problematic and in some cases not based on sound, rigorous science. In particular, the prediction of the potential geographic distribution of LBAM in the United States … and all economic analyses based on it, are questionable and in need of reassessment with a more rigorous approach” the NRC report concludes.
Ending LBAM’s status as an “actionable, quarantinable pest” would end eradication treatments by the USDA and California Department of Food and Agriculture (CDFA), including aerial pesticide spraying, that have been met with widespread public resistance. Reclassification of LBAM would also end quarantines that have restricted farmers’ ability to ship produce and subjected crops to frequent inspections and required chemical treatments.
The NRC report noted that USDA did not justify its decision to pursue eradication of LBAM and that “it is debatable whether [USDA] has met” the criteria that are prerequisites for successful eradication: acting before a species becomes widespread (LBAM has been found in 18 California counties so far), and maintaining public support for the program. The report recommends that USDA conduct a study that includes “scientific feasibility and cost–benefit analysis, of LBAM eradication and alternative control approaches.”
"The single most resounding message of this report is the inadequacy of the science underlying USDA and CDFA's LBAM policy," observed James Carey, Professor of Entomology at the University of California, Davis, an expert in invasive species.
The NRC report found that “There is substantial uncertainty about the ability of LBAM to spread geographically, about its host range, and about the severity of damage that it can inflict on host plants” and expressed “substantial concerns regarding the economic component” of USDA’s analysis, “based primarily on the ambiguous foundation of the analysis for the predicted geographic distribution of LBAM and the inconsistent and sometimes incomprehensible analytic techniques used” by USDA.
“The NRC’s report vindicates what we have been saying for two years – that USDA’s decisions about LBAM have been based on selective and outdated science,” said Nan Wishner of Stop the Spray East Bay.
The NRC committee also labels USDA’s conclusion that LBAM populations are increasing: as “misleading,” noting that it is not possible to accurately track populations given “the increasing number of traps and the increasing geographic area of their placement.” The report also states that LBAM trapping efforts prior to the launching of the eradication program in 2007 were “probably insufficient” to determine whether LBAM was already present in the state.
Regarding USDA’s acknowledgment that “the greatest economic threat posed by LBAM is losses associated with trade restrictions on host plants and commodities in both international and interstate trade,” NRC comments, “Trade restrictions have been known to be imposed in ways that ignore basic biology.”
The committee noted USDA’s misrepresentation of scientific literature, for example concluding that LBAM poses a risk to forests when the literature indicates the opposite, and that in many cases USDA claims lack sources or cite questionable references, such as a single unpublished email from an industry representative as the sole basis for estimates of LBAM costs to the nursery industry.
Regarding USDA’s citing of the Plant Protection Act (PPA) as a basis for classifying LBAM as a quarantinable pest, NRC observes that “while the PPA confers broad discretion, it does not obviate the need for rigorous science in arriving at and communicating the basis of decisions regarding pest status classification and actions taken to mitigate the problem.”
The 10-member NRC committee that prepared the report included Dr. Jerry Powell, emeritus professor of entomology at UC Berkeley, who identified LBAM in his Berkeley backyard three years ago, and Dr. Nicholas Mills, UC Berkeley, who is researching biological control of LBAM. Two committee members are current or former USDA employees.
###
http://www.santacruzsentinel.com/localnews/ci_13339087Scientific review finds flaws in USDA apple moth research
Santa Cruz Sentinel, September 14, 2009
WATSONVILLE -- The U.S. Department of Agriculture had the authority to mandate quarantine and eradication programs for the light brown apple moth, but its reasoning for doing so was in part "not based on sound science," according to a independent review by a scientific panel.
The report by the National Academy of Sciences' National Research Council, released Monday, questions the USDA Animal and Plant Health Inspection Service's predictions of the moth's potential spread and the level of economic damage it could cause and recommends the agency use "more robust science" to back up its claims.
The panel reviewed the USDA's response to petitions from private citizens and groups seeking to downgrade the threat status of invasive pest from Australia and end quarantine and eradication programs in favor of strategies to control the moth.
"Overall, the committee found that the federal Animal and Plant Health Inspection Service response would greatly benefit from the use of more robust science to support its position," chair May Berenbaum writes in the introduction to the 31-page report.
In a written statement APHIS administrator Cindy Smith said the agency would use the panel's analysis to strengthen its response to the petitions and that the revised response would be posted for public comment in coming weeks before the agency made a decision on reclassifying the moth.
"The information we provided was perhaps not as well documented as they would have liked, but it was sufficient for that pest to be listed as a quarantined pest," said APHIS spokesman Larry Hawkins.
But UC Arboretum Director Dan Harder, who co-wrote one the two petitions with Soquel herbalist Roy Upton, said the report amounted to a "pretty strong rebuke" of the USDA.
"They have the mandate, but there's a lot of buts," Harder said. "The report constantly reiterates the lack of real science."
Upton said the USDA is required by law to base its decisions on sound science. But he doesn't think the USDA will back down because the emergency eradication program brings in "too much funding."
"I really believe the next step is a lawsuit against USDA," Upton said.
Since the moth was first detected in a Berkeley backyard in 2006, more than 150,000 light brown apple moths have been trapped in the state, two-thirds in Santa Cruz and San Francisco counties. More than 23,000 moths had been found in Santa Cruz County so far this year. Close to 3,500 square miles have been quarantined, requiring inspection of vegetables, fruits, flowers and plants to confirm they are pest-free before shipment outside the area.
In June, state agriculture officials reported damage to blackberries in a field near Watsonville, the first actual crop damage reported in California.
Federal and state agriculture officials launched an aggressive campaign from the start in hopes of eradicating the moth before it became entrenched. But aerial spraying of a pheromone over urban areas of Santa Cruz and Monterey counties sparked outrage and lawsuits.
The current strategy, under environmental review prior to implementation, relies heavily on releasing millions of sterile male moths to reduce moth reproduction.
