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Review of the 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: A Letter Report (2009)

Chapter: 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

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Suggested Citation:"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." National Research Council. 2009. Review of the 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: A Letter Report. Washington, DC: The National Academies Press. doi: 10.17226/12762.
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Page 17

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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 

Next: APPENDIX B Biographical Sketches of Committee Members »
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The U.S. Department of Agriculture's Animal and Plant Health Inspection Service (APHIS) has classified the Light Brown Apple Moth (LBAM)--originally from Australia and confirmed in California in 2007--as an "actionable quarantine significant pest" and has applied its authority to implement a program of quarantine restrictions and eradication, which has been met with some public resistance.

Some have petitioned for the LBAM to be reclassified as a "non-actionable pest" based on the argument that the moth is not a significant pest economically and can be controlled by means other than eradication. APHIS asked the Research Council to evaluate the scientific justification of the draft response APHIS wrote to answer the petitions.

This report from the National Research Council concludes that APHIS is within its broad regulatory authority to classify the LBAM as an "actionable" pest. However, APHIS would benefit greatly from referencing more robust science to support its position, as its draft response did not adequately explain the moth's most likely future geographic distribution in the United States or the level of economic harm it could cause.

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