I encourage readers of this blog to peruse the attached file, written by Margareta Lelea, a post-graduate researcher at UC Davis, with Frank Zalom, Jim Greishop and Jennifer Sedell. This study, funded by a Cooperative Agreement between the USDA (United States Department of Agriculture) and UC Davis, is a comparison of the emergency responses on the part of the USDA and CDFA (California Department of Agriculture) to the light brown apple moth (LBAM) and European grapevine moth (EGVM).
The experience of the LBAM emergency response was negative for many people on the Central coast of California. Seemingly dead set on the eradication of LBAM no matter what the cost, the USDA and the CDFA brooked very little community input as they attempted to put into place a program of aerial pheromone application accompanied by a quarantine regime composed of intrusive field inspections, disruption of farm business operations and costly field closures.
In contrast, the regulatory experience of EGVM emergency response was more positive for many (including me), and was a program which found its success in the working relationships between local regulatory officials, locally based USDA officials and agents (many of whom were already here for the LBAM program), UC Cooperative Extension and a diversity of other groups including growers and pest managers.
As one can draw from reading this report, that these two programs should have really different outcomes currently should then not be surprising.
The hugely unpopular LBAM emergency response program has had its budget virtually eliminated through the representative political process and has garnered a real distrust of the USDA and CDFA by the affected communities, which to some extent continues to this day.
LBAM continues to flourish on the Central Coast, although it still doesn’t cause a lot damage besides not being anything that can’t be managed easily with environmentally sensible methods. Nevertheless, LBAM still affects trade in a big way, the current situation being a threatened closure of our Canadian and Mexican export markets for berries or broccoli should LBAM arrive there in any shipment of either of these commodities.
In contrast, EGVM has been eradicated following its brief appearance in Santa Cruz County in 2011 and its numbers have been dramatically lowered in other infested areas such as Napa, Sonoma and the Central Valley.
The attached paper does a first class job in outlining and comparing LBAM and EGVM emergency responses and shows us what we and the regulatory agencies can learn from these two experiences to guide us in the future.
Some key takeaways from the paper:
1- Agencies lose credibility and trust from communities when they undertake actions against the will of the people. This the USDA and CDFA did in spades on the LBAM emergency response, pushing ahead while initially ignoring many community concerns about their activities and creating a perception of an abuse of science and government power.
2- Agencies gain credibility and trust through a willingness to engage and effect change, which includes responding to the needs of the communities and the environment and adapting new information from science as appropriate. This was clearly the case with EGVM, as USDA and CDFA agents (many of whom were also involved in LBAM programs) worked together with local regulators, UC Cooperative Extension and growers to arrive at a workable, successful solution to the issue.
3- Aerial spray programs must be enacted only with the support of affected communities.
I guess what I think about after reading through this report is how did the LBAM emergency response go so awry? Most of the USDA and CDFA people involved in the response are very competent, decent people who truly want to serve the public and the agricultural industry in the best possible way.
Have these agencies become bureaucracies, who, to quote the philosopher Ludwig von Mises, “are no longer eager to deal with each case to the best of their abilities; they are no longer anxious to find the most appropriate solution for every problem” and whose “main concern is to comply with the rules and regulations, no matter whether they are reasonable or contrary to what was intended."? I would today answer in the negative, because even if the USDA and CDFA started out behaving as the bureaucracies described by von Mises, they both seem to have learned from their experience and turned the corner pretty promptly. Indeed, that both seemed to undergo pretty well a paradigm shift in their approach on the EGVM emergency response just a few years later after the difficult start on LBAM is a testament to their ability to learn and evolve to best serve the publics who have entrusted them to keep invasive pests out of California.
Kudos to a really thought provoking and illuminating report by Dr. Lelea and her colleagues about two signal invasive pest responses. A must read for entomologists, regulators and pest managers on the Central Coast.
This is an announcement for a light brown apple moth (LBAM) training meeting to be held this coming May 9 at 40 Zils Road in Watsonville. The purpose of the meeting is for growers and others to obtain LBAM identification certification in order to be able to implement on-farm Integrated Pest Management practices to meet San Benito, Monterey and Santa Cruz County quarantine area compliance agreement requirements for export.
Everyone planning to attend the meeting must RSVP for this meeting by contacting Sofia Hernandez of the California Strawberry Commission at firstname.lastname@example.org, (831)724-1301 or Hillary Thomas, email@example.com, (831)254-1184.
The link for the meeting announcement and agenda is:
Strawberry and caneberry growers should be reminded that the CDFA-USDA regulatory program for light brown apple moth is still regnant in Santa Cruz and north Monterey counties this year and we should all be taking steps to reduce numbers of this pest in the production fields. I communicated with Rick McKay, head of the USDA-APHIS regulatory effort for this area, and he assured me the program will be active again in 2013 in the same way it was active last year, at least until September 30.
Pheromone based twist ties are a good way to reduce LBAM numbers in fields, especially in raspberries and blackberries since the ties are attached to the trellis with very little effort and time. The twist ties are still available through the Santa Cruz County Agricultural Commissioner at 763-8080. There are still quite a few left, and a quick call to the distributor Pacific Biocontrol Corporation reassured me that these ties, which were received in 2010, are still viable since they are being stored in a cooler and are in their original packaging. These twist ties cost nothing and give growers a good measure of protection against LBAM infestation and the accompanying regulation.
Growers and industry people may find the following website useful for understanding population fluctuations of light brown apple moth (LBAM). The site, maintained by my UCCE colleagues Neal Murray and Steve Tjosvold, is a compilation of trap data at points across Santa Cruz and north Monterey County, and gives a really good sense of where LBAM populations are:
Particularly striking is the surge in numbers of adults trapped over the past few weeks. Important information to know.
- Posted By: Mark Bolda
- Written by: Mark Bolda
I had a fruitful meeting with PPQ Supervisor Rick McKay, Inspector Leah Gayagas and currently serving Santa Cruz County Agricultural Commissioner Mary Lou Nicoletti on May 19. This meeting was concerning the current inspection and field closure procedures for light brown apple moth in strawberry and caneberry growers in the quarantine zone which covers all of Santa Cruz county and most of the berry production areas of North Monterey counties.
At the time of the meeting, three raspberry fields and one strawberry fields had been closed because of positive finds, so this matter is of considerable urgency to the berry growing community.
Inspections are to take place for each grower every thirty days, either at the cooler for those sending fruit there, or at the field for those growers who are sending fruit out of the quarantine zone venues such as farmer's markets and fruit stands. In addition to this, it is worth reminding growers who are growing fruit for export out of the USA that county phytosanitary inspections are also being done on every load, and they will forward suspect leafrollers to the USDA PPQ program.
Inspections are being done as before, that is to say that 2% of a designated load are evaluated for leafroller presence. If a leafroller is found in the load- and this means any leafroller species - a hold is put on the load and also on the field from where the load came. If no leafrollers are found, the field is clear for another thirty days. A suspect leafroller gets shipped up to the identification laboratory in Sacramento immediately via FedEx and a positive or negative determination should be available within one or two days of the find. If determined to be positive, the hold on the fruit and field continues, if negative then the hold on the fruit and field is lifted. As noted before however, if the larva is very small or is in the pupal stage, the determination will take longer, maybe up to a week and a half.
Field closure is done after an inspection of the field from where the infested load originated. Size of the closure is not arbitrary, it depends on where the larvae are. If they are in a corner of the field only, then only that corner will be closed. If they are spread evenly through the field, then the whole field will unfortunately be closed. Growers should be aware of the trend of finding more leafrollers along the edges of fields in wooded and riparian areas.
One key point out of this meeting for berry growers and their consultants is that once a hold is put on a field, it must be inspected for light brown apple moth larvae before being released. The date of inspection is negotiable, and it might not necessarily be in one's best interest to have a field inspected immediately, since if there are no larvae found, then the hold on the field is lifted and no regulated spray and subsequent field inspection necessary. So, it would seem a good thing for growers experiencing a load hold and subsequent field hold to get that field cleaned up right away. Arrangements can generally be made for inspectors to come out a few days after a hold is put in place, which would give the grower time to spray a fast acting material like a spinosyn and run a crew through and pick out leaf rolls. By doing all of this effectively, the grower avoids the burden of dealing with the regulated spray (and it's disappointingly short list of allowed chemicals) and follow up inspections. By moving quickly, the grower can avoid all that.
The attachment below is the USDA inspection protocol for fruit inspected at a cooler.