APPENDIX A
Review of U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) Response to Petitions to Reclassify the Light Brown Apple Moth as a Non-Actionable Pest

STATEMENT OF TASK

To evaluate the ability of policy and regulatory decisions to be supported by sound, scientific evidence and effectively communicated in a transparent fashion, an NRC committee will examine the scientific bases of two competing opinions about the classification of the Light Brown Apple Moth (LBAM) as an actionable pest, based on petitions from various parties in California to reclassify the pest, and on federal documents that justify and defend the rationale for the current pest classification. The committee will focus on the comprehensiveness and credibility of the federal justification in light of arguments to the contrary. The committee will prepare a letter report evaluating whether the justification:

  • fully considers and addresses the specific arguments for reclassification raised in the petitions and their accompanying documentation; and

  • clearly articulates a thorough and balanced analysis that justifies and adequately supports its conclusions in response to the petition.



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APPENDIX A Review of U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) Response to Petitions to Reclassify the Light Brown Apple Moth as a Non-Actionable Pest STATEMENT OF TASK To evaluate the ability of policy and regulatory decisions to be supported by sound, scientific evidence and effectively communicated in a transparent fashion, an NRC committee will examine the scientific bases of two competing opinions about the classification of the Light Brown Apple Moth (LBAM) as an actionable pest, based on petitions from various parties in California to reclassify the pest, and on federal documents that justify and defend the rationale for the current pest classification. The committee will focus on the comprehensiveness and credibility of the federal justification in light of arguments to the contrary. The committee will prepare a letter report evaluating whether the justification:  fully considers and addresses the specific arguments for reclassification raised in the petitions and their accompanying documentation; and  clearly articulates a thorough and balanced analysis that justifies and adequately supports its conclusions in response to the petition. 17