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Congressman Farr wants hearing on LBAM reclassification

by Dick Andre
Congressman Sam Farr (D-Carmel) has submitted a petition to the USDA for reclassifying the Light Brown Apple Moth to a minor pest status. He has also stated that he hopes his Agricultural Appropriations Committee will hold hearings with the USDA answering questions about making errors and correcting them. A copy of the petition is available on request.
CASS (California Alliance to Stop the Spray)
Oct. 22, 2008

Press release

Contact: Dick André, Phone 831-818-5685

Farr wants hearing on LBAM classification

Congressman Sam Farr (D-Carmel) at a Town Hall Meeting in
Salinas Wed. night, affirmed his hope that his Agricultural Appropriations Committee will have a hearing with the US Department of Agriculture (USDA) Light Brown Apple Moth (LBAM) reclassification.

Farr has already submitted a 97 page petition to the US Department of Agriculture arguing to lower the classification of the LBAM from Class A (voracious pest) to Class C (minor pest).

“I am very excited about putting the USDA on the spot,” Farr had commented earlier. “I hope that we (the Appropriations Committee) can have a hearing on it.”

The USDA gets all of its money from the appropriations committee, so USDA “has to be responsive to our questions.” In his letter submitting the petition, Farr wrote, “I urge the Department to make a determination of the merits of the petition on the basis of sound science and proceed accordingly as soon as feasible.”

The petition challenges the quality of the science used by USDA in listing the moth class A and establishing trade quarantines. “The Plant Protection Act (PL 106-224:2000) . . . requires that decisions affecting trade be based on sound science.” the petition states.

In California, no damage from the moth has been found. Wherever the moth exists in the world, damage is not an issue, the petition reports. “The totality of published scientific literature suggests LBAM is at worst an episodically minor pest . . ..”

Along with three others, Roy Upton, LBAM Liaison for Citizens for Health, prepared the petition, which cites 182 sources, six from USDA and California Department of Food and Agriculture (CDFA) publications or statements.

Supporting letters with the petition are from Professors James R. Carey and Frank G. Zalom, internationally recognized University of California, Davis, entomologists, and Doctor Derrell Chambers and Doctor Hilary Lorraine, retired US agriculture officials.

“The current classification of LBAM is based on out-of-date information, incomplete understanding of LBAM biology, and does not reflect the true potential agricultural impact of LBAM on agriculture within the context of modern practices,” wrote Chambers and Lorraine.

The petition details all of the points made by Chambers and Lorraine.

Regarding classification and the associated quarantine on California produce, the petition says USDA relied on pre-1998 scientific and agricultural literature, ignoring one New Zealand scientist who changed a previous unsupported opinion that LBAM was a problem by reporting that LBAM “. . . is neither constant or endemic, nor characterized by sporadic plague-like outbursts.”

The petition also points out that some pests are classified A but without a quarantine. The USDA’s own figures show that most costs associated with LBAM in Australia and New Zealand are caused by requirements to meet the US zero-tolerance for LBAM, not for controlling LBAM.

Can the Mexico and New Zealand quarantines be lifted? Both governments have indicated that a change in US policy will be the main impetus needed for them to “harmonize” their policies. The discoverer of the first LBAM found in California in 2006, retired entomologist Jerry Powell, said, “. . . it doesn’t seem to me there’s much point to quarantining things . . ..”

Regarding LBAM biology, the petition recounts numerous errors, including the fact that USDA originally thought LBAM could not survive in coastal California, its only known home in the US.

The most frightening error was the projection of LBAM offspring provided by CDFA in 2007. It assumed that every egg laid by an LBAM would survive to maturity, increasing the California population to a range of 6.7 million to 7.8 trillion in a year.

In fact, the LBAM population has remained relatively stable. A main reason is predators. USDA and CDFA assumed no native predators would control LBAM. The petition lists 65 US LBAM predators, including six Trichogramma wasp species, a type of wasp that CDFA proposed importing.
Regarding modern agricultural practices, if LBAM were a threat, the petition offers this: “The success of New Zealand agriculture and horticulture professionals in controlling LBAM and other leafrollers using IPM (integrated pest management) techniques and few or no chemical applications is a model of best IPM practices that can readily be adopted in California.”

-end-





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