USDA, Animal and Plant Heath Inspection Service, Plant Protection and Quarantine

Biological Control Permitting Overview

Robyn Rose, Ph.D. National Policy Manager

Animal and Plant Health Inspection Service (APHIS)

• Plant Protection and Quarantine (PPQ) – Safeguards agriculture and natural resources from

risks associated with the entry, establishment, or spread of pests and noxious weeds.

• Plant Pest

– The term ‘‘plant pest’’ means any living stage of a pest that can directly or indirectly injure, cause damage to, or cause disease in any plant or plant product.

• Any enemy, antagonist, or competitor used to control a plant pest or noxious weed.

• Common examples include:

• parasites and predators of plant pests; • pathogens of plant pests; • herbivores used against noxious weeds; • microorganisms which kill plant pathogens or prevent infection of the host

plants.

Biological Control

Initiation

Assemble release petition

prioritize & select targets

Host specificity testing

“Foreign exploration”

Distribution, monitoring and evaluation

Technology transfer

Environmental compliance

Initial field releases and establishment

Pre-release R&D: most of the costs much of the time

Implementation: putting agents in the

field monitoring methods incl. non-target impacts

mass-rearing technology Release site criteria and protocols

Develop and facilitate partnerships

Endangered Species Act National Environmental Policy

Act & Tribal Outreach

Research in U.S. quarantine, foreign partners (CABI), country of origin Confirm ID and strain/colony purity

non-target/environmental impacts

geographical range monitoring plan

10-20 years

Collect, colonize, screen

develop agent release protocols establishment

Implementation Timeline

• How Long? – Difficult to Answer – Recovery: 2-3 years or more – Establish: 5-10 years or more – Maintain Field Insectaries: 3-5 years – Regional Distribution: 3-5 years – Self-Sustaining Population

Factors to Determine PPQ Interest and Need

• PPQ priorities • State interest • Pest impact • Exotic/Introduced pest • Impending risk of invasion • Pests impacting Threatened/Endangered Species • Lack of effective/feasible alternatives • Multi-state established pest • Emergency response needs

Project Prioritization Factors

• Importance of pest (e.g. emergency, impacts) • Amount of resources needed (time and money) • Opportunities (e.g. timing, agents, partnerships) • Likelihood of success (e.g. measurable, agent

establishment and impact)

Foreign Exploration

APHIS requires researchers to have PPQ 526 permits for the: • Importation • Interstate movement • Movement between containment facilities • Continued permits for containment facilities • Releases into the environment

Permits for Biological Control Organisms

• Required for • all biological control organisms • EPA registered biopesticides

• Containment facility

• must be inspected

• Some, “commercial” biological control organisms, that are native or widely established, have few permit restrictions after importation.

Permits for Importation

• Required when:

• researchers move non-native organisms between states for release • release or research occurs outside a containment facility • native organisms are moved into states where they are not established

Interstate Movement Permits

• Ecological risk analyses • Host specificity testing • Environmental compliance

Environmental Release Permits

• Review the petition • Consult with NAPPO (North American Plant Protection Organization) • Endangered Species Act (ESA)

• Biological Assessment (BA) • U.S. Fish and Wildlife Service (FWS)

• National Environmental Policy Act (NEPA) documents. • Environmental Assessment (EA) • Environmental Impact Statement (EIS) • Categorical Exclusion (CatEx)

• Tribal consultation

Environmental Compliance for New Release Permits

BA/BE Preparation in Accordance with ESA

• 3 parts • Species accounts for all listed endangered,

threatened, proposed, and candidate species that might be affected by the proposed action

• Current status of the listed species and critical habitat designation

• Effects assessment

• Determinerniation • No effect • May affect, but is not likely to adversely affect • May affect, and is likely to adversely affect.

• Go to the threatened and endangered species system

http://ecos.fws.gov/tess_public/

EA Preparation in Accordance with NEPA • Four parts to an EA

1. Purpose and need for the proposed action 2. Alternatives including the proposed action 3. Affected environment and environmental consequences 4. List of preparers

• EA must address whole continental US • Cumulative effects • 4-Point Memo

o Public communication o Public controversy o EIS for permitting regulations

• Notice of Availability published in Federal Register to allow PUBLIC comment. • Response to comments

Final EA and Finding of No Significant Impact (FONSI)

Funding

• PPQ Biological Control Line Item • Farm Bill Section 10007

Acknowledgements

Ron Weeks, APHIS PPQ Science and Technology Keith Colpetzer, APHIS PPQ Field Operations Bob Pfannanstiel, APHIS PPQ Permitting Tracy Willard, APHIS PPD, Environmental and Risk Analysis Kai Caraher, APHIS PPQ Environmental Compliance

Thank You!

Questions?