status of a pest species newly discovered in California that is of economic importance elsewhere in its range. First reported in 2006, the moth has been found in 17 California counties; APHIS classified LBAM as a high-risk pest of quarantine significance and in fall 2007 initiated an eradication program in cooperation with the California Department of Food and Agriculture. The two petitions were filed in accordance with Chapter 18 of the USDA Emergency Programs Manual (Floyd et al., 2002), which details criteria for termination of an emergency eradication program.


In response to its statement of task, the committee found that APHIS did not “fully consider and address the specific arguments” and did not “conduct a thorough and balanced analysis” supporting the conclusions in its Response. Full consideration would have included a more detailed economic analysis and a more complete response to the argument against eradication. Overall, the committee found that the APHIS Response would greatly benefit from the use of more robust science to support its position. In responding to the petitions, APHIS would be well served by articulating the justification for its actions to the public clearly, and the Response should be revised accordingly. In addition, the LBAM regulations should be published for comment in the Federal Register.

Sincerely,

May Berenbaum,

Chair

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



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