Light Brown Apple Moth Summary

Name

The LBA moth's official name is Epiphyas postvittana.

Strains

The LBA moth is impossible to distinguish from native moths without DNA analysis. "The larvae are virtually indistinguishable from other native leaf-rollers, including the apple pandemis, garden tortrix, oblique banded and orange tortrix." (Nursery owner Jeff Rosendale 09/05/2007)

History

The LBA moth is apparently native only to Australia.

It was introduced to New Zealand and Hawaii more than 100 years ago. It is also found in Ireland, Tanzania, and the United Kingdom.

The first find of an LBA Moth on the mainland US was in Berkeley, California confirmed on March 12, 2007 by DNA analysis.

UC Davis entomologists believe the LBA moth has been in California for "a very long time prior" to finding it here. HOPE is persuaded it has probably been here for years, if not decades because the moth only flies a few dozen yards in a lifetime yet it is spread densely across Santa Cruz County and is found as far away as Los Angeles and Napa.

It has since been found in Alameda, Contra Costa, Marin, Monterey, Santa Clara, Santa Cruz, San Francisco and San Mateo counties (as of May 2007 it was not known in Napa). About 87 percent of all (8,000) LBAM captures come from "southern Santa Cruz and northern Monterey Counties."

About 1 percent of the detections of the moth came from "mostly single trap captures in Los Angeles, Marin, Napa, San Mateo, Santa Clara, and Solano Counties."

On May 2, 2007 USDA decreed a quarantine restricting exports of a wide range of plant materials from Hawaii to the U.S. Mainland.

On July 24, 2007 US-EPA granted a Quarantine Emergency Exemption allowing the spraying to occur every 30 days until January 2010.

On Sept 9, 2007 CDFA began aerial spraying of the Monterey Peninsula with Checkmate OLR-F.

* CDFA plans to re-spray Monterey Peninsula with Checkmate on Oct 9^th

Mapped Locations

LBAM has been found in 12 California counties from Los Angeles to Napa, primarily close to the coast and most occurrences are near the San Francisco Bay area.

Santa Cruz County is the center of the highest density of the moth population, with more than 82% of the moths found there. Monterey County has only about 6% of those found.

Only 2 LBA moths were found in Monterey and none have been found in Pacific Grove (though one was trapped near David Ave.), Pebble Beach or Carmel.

Spread

LBAM spreads almost exclusively through human transport of plant materials.

The moth only travels at most 100 yards in a lifetime, more typically only 20-30 yards from its birthplace. It reportedly flies no higher than 10 feet above the ground.

USDA admits the LBA moth is "not spreading." (USDA’s Larry Hawkins radio interview on Tomorrow Matters, Sept 10, 2007)

Affected Species Breadth

USDA claims LBAM harms 250 - 2000 plant species.

USDA claims "Major domestic hosts of concern are stone fruit (peaches, plums, nectarines and apricots), apples, pears, grapes, cherries and citrus."

Harm Types

There is no documented damage from LBAM in California even though millions of dollars in crops have been sold from the areas for which it is now found and for which it should have caused harm.

LBAM is not considered a "significant pest" by Hawaii's Department of Agriculture. "In fact, LBAM may actually be considered a biocontrol agent for serious invasive weeds, such as gorse and blackberry in Hawaii."

CDFAs’ John Connell claims the moth would cause major damage to our native Monterey pine forest "and redwoods".

But Monterey pine tree farms in New Zealand which have been there for 150 years have not had a large problem with LBA moths even though the moth invaded the country 100 years ago. New Zealand has more than a thousand square miles of Monterey pine tree farms which are the county's largest dollar export.

USDA claims "The pest destroys, stunts or deforms young seedlings; spoils the appearance of ornamental plants; and injures deciduous fruit-tree crops, citrus and grapes."

However, USDA and CDFA have NOT provided evidence about what kind, and the extent of, harm which allegedly occurs in each species. It seems that the moth affects each plant species differently, some exceedingly little.

Critics point out that "spoiling the appearance of ornamental plants" is only superficial or cosmetic.

USDA and CDFA have shown zero evidence of significant harm to Monterey pines and other non-fruit trees anywhere. There is no evidence of harm to Monterey pines or redwoods in California.

Symptoms

(larvae webs?)

Susceptibility vs. Resistance

There is very little evidence of actual harm to those hundreds of plant species in California.

Mortality vs. Symptoms

In California there is no evidence of dead individuals for each of those hundreds of plant species.

Quarantine

On May 2, 2007 USDA Decreed a quarantine restricting exports of a wide range of plant materials from Hawaii to the U.S. Mainland.

The quarantine order requires nearly all plant material to be inspected visually and certified as free of LBAM prior to shipping by state or federal agricultural inspectors. This includes nursery stock, cut flowers, flower lei, fruits, vegetables, greenery, greenwaste and hay.

USDA also decreed an "Eradication Directive" that requires that all efforts be made to exterminate, cause local extinction to, the LBA moth.

Cures, Treatments

LBA moths have been successfully attracted, trapped and killed with "Johnson" (sticky) Traps with an attractant pheromone.

LBA moths have been successfully attracted, trapped and killed using "black lights."

Pesticides

Two pheromones pesticides are used in the aerial spraying: Checkmate OLR-F and LBAM-F.

* US-EPA makes it clear that even though they are not intended to kill, both chemical pheromones are classified and intended to be used as pesticides.

* Neither USDA or CDFA has ever conducted a successful eradication program using pheromones.

* Neither USDA or CDFA has ever conducted a successful eradication of a lepidopterous insect that feeds on so many species.

Testing for Harm to Animals and Plants

No Toxicological testing on animals or plants has been conducted on the Checkmate (LBAM-F) chemical spray. US-EPA also gave the chemical an emergency waiver from testing for harm to biota, even though USDA's Environmental Assessment said close chemical relatives to the spray can be deadly to "aquatic invertebrates" (e.g. abalone, crabs, shrimp, and krill) in parts per billion (drops in a swimming pool). OLR-F has had only minimal biota testing and remains an "unregistered" pesticide as of July 2007.

CDFA & USDA have conducted aerial chemical sprays of a pheromone Checkmate OLR-F over Monterey Peninsula cities where only a handful of the LBA moths have been found. CDFA plans to use LBAM-F for the planned aerial spraying of Monterey Peninsula scheduled for Oct 9^th, 2007.

Chemicals related to the Spray can kill aquatic invertebrates (e.g. abalone, crabs, vernal pool fairy shrimp and krill) in tiny amounts; in parts per billion (USDA EA July 2007).

Efficacy Testing

Even though required by FIFRA (the U.S. Federal Pesticide Testing and Registration law), no efficacy testing has been conducted on the chemical spray Checkmate (LBAM-F). US-EPA gave the chemical LBAM-F an emergency waiver. Efficacy testing on the Checkmate OLR-F (that was sprayed on the Monterey Peninsula in Sept 2007) is that it is at best only 80 percent effective on the LBA moth. According to one expert this poor result means that using it is a waste of time and money.

________

For More Information – Choose sources other than USDA or CDFA. On this issue both agencies have shown a systematic pattern of serious intentional deception and withholding vital information contradicting their positions and conclusions, particularly whether there is an emergency. All of their claims should be verified from another source.

Refusal to Answer Questions -- After Sec. Kawamura promised to answer all questions, we hand delivered a set of our questions to Sec Kawamura and the USDA at the Monterey Conference Center City Council Meeting. USDA AND CDFA have both failed to answer virtually every question asked by HOPE. We spent more than 8 hours researching those questions.

USDA further refused to take call-in questions and comments on a Sept 10, KRXA radio talk show.