2. Plant Health Protection and Disease Control

2.1 Plant Health Introduction
Last updated: February 08, 2010

Protecting the health of our nation's crops is becoming an increasingly important and difficult task. The passage of trade agreements has increased the flow of fruits, vegetables, and propagative plant materials across our borders making the United States more susceptible to plant pests and diseases. The possible introduction of foreign plant pests and diseases, coupled with current efforts to control pests and diseases already inhabiting the United States, and the phase out of methyl bromide use, make the need for 1) federal-state collaboration and cooperation in program delivery and 2) basic and applied research more important than ever.  Research should be aimed at preventing the introduction of pathogens, controlling plant pest and diseases and developing new methods for reducing and eliminating potential plant health hazards during the production process.

The consumption of and demand for fresh fruit and vegetables and propagative plant materials continues to grow and the agricultural industry must strengthen its efforts to integrate plant health and management programs. Facilitating the transfer of information and technology from the laboratory to the producer/consumer will ensure an adequate and safe supply of food, feed and fuel products.

2.2 Domestic Plant Issues
Last updated: February 08, 2010

The agricultural industry is faced with a wide range of plant pests and diseases that threaten to damage crops and cause farmers to suffer severe economic losses.  Programs have been established at the federal and state level to combat plant health concerns.  NASDA recognizes the importance of controlling  devastating pests and diseases and believes that the federal government should provide adequate funding to carry out existing programs and to perform research on ways to control and eradicate serious pests and diseases.  Cooperative agreements with states and growers should be encouraged as a way of developing appropriate management strategies.  Criteria under consideration by USDA to calculate state and federal participation in cooperative funding for pest and disease eradication and control must be flexible and take into consideration that each problem is unique and may not readily fit a formal criterion.  To control and eradicate pests and diseases, early response is critical.

NASDA supports maintaining or increasing the funding for the following serious plant pest and disease programs:

• Asian Longhorned Beetle
• Avocado Lace Bug
• Boll Weevil Eradication Program
• Emerald Ash Borer
• Citrus Canker Cooperative Eradication Agreements
• Cogongrass
• Federal Scab Initiative
• Fruit Flies of Economic Importance
• Glassy Winged Sharpshooter and Pierce’s Disease
• Golden Nematode Quarantine Efforts
• Grasshopper/Mormon Cricket Program
• Gypsy Moth “Slow the Spread” Strategy
• Honeybee Pests and Diseases
• Imported Fire Ant Program
• National Program Proposal on Late Blight
• Pest Detection and Management
• Pink Hibiscus Mealybug
• Plum Pox Cooperative Eradication Agreements
• Potato Diseases including Potato Virus Yn Complex
• Sudden Oak Death
• Tropical Soda Apple
• Vine Mealybug
• Wood Insect Research Laboratory and Termiticide Efficacy Data

Plant Quarantine
Last updated: February 08, 2010

The pest prevention mission of public agricultural agencies in the United States is to protect agriculture, the environment, and its citizens from the economic and environmental harm that injurious plant pests can cause.  Satisfying this mission while, at the same time, providing for equitable and orderly domestic and international trade, is a major challenge.  The ideal pest prevention system is one that is mutually agreed to and uniformly applied.  The system must efficiently and effectively identify pest harm and assess and manage pest risk.

Mutual agreement among pest prevention officials and agencies cannot be achieved unless the functions, activities, and tasks involved in pest harm identification and pest risk assessment and management are understood.  Uniformity cannot be achieved if there are no mutually agreed upon guidelines that serve as a standard against which various systems and actions can be measured and readjusted as needed.

The current array of international, federal, and state plant pest and disease regulatory requirements varies considerably, giving rise to occasional disputes and charges of unfair trade practices.  In addition to these inconsistencies, a number of other trends create a need to increase the consistency and effectiveness of pest prevention programs.  These trends include increased responsibility of the states, rather than the federal government, to be wholly involved in the management of plant inspection and quarantine programs for both domestic and international trade; heightened awareness and concern about the adverse environmental impacts of plant pests and the resulting increased use of pesticides; the importance of pest prevention programs in facilitating commodity exports as specified in both the North American Free Trade Agreement (NAFTA) and the General Agreement on Trade and Tariffs (GATT); and the frequency of breaches in existing quarantines.

Given these trends, uniformity among states becomes even more important from a federal and international standpoint.  States should evaluate their current pest prevention programs for conformity with the National Plant Board guidelines and consider modifying their programs in order to achieve uniformity with them.  The USDA should make provision for approval of state quarantine and plant health program regulations as "official control" programs.  Pests covered should include quarantine and regulated non‑quarantine pests as defined in the International Plant Protection Convention. 

In addition, the USDA should optimize federal domestic program delivery via state plant pest prevention organizations.  This can be accomplished using various agreements including 1) partnership agreements as detailed in NASDA's "Key Principles of A Cooperative Relationship" Policy Statement, 2) memoranda of understanding, and 3) contractual agreements. 

Taxonomic Resource List
Last updated: February 08, 2010

Accurate and timely diagnosis is critical to making effective regulatory decisions when pests, weeds, and diseases of possible regulatory significance are found associated with commodities in foreign and interstate commerce.  The existing diagnosis experts are few in number and located among various federal, state, and county governmental agencies, universities, museums, and private industry.  Retiring diagnostic experts are not being replaced in many organizations and universities are training fewer and fewer biosystematists.

Emergency Eradication
Last updated: February 08, 2010

Federal-state cooperative programs that control invasive pest species, plant and animal, benefit all states by controlling the spread of such pests and, thereby, limiting the damage to agricultural crops nationwide.  States which are found to harbor an invasive pest species have recently been required by the Office of Management and Budget (OMB) to contribute a minimum of 15% of the costs associated with controlling such pests in order to receive emergency federal assistance through USDA’s Animal & Plant Health Inspection Service (APHIS). NASDA recommends that the cost-share requirements for funding federal-state plant pest control containment and eradication efforts be eliminated.  Emergency eradication and official control funding should be negotiated on a case by case basis with the state and should take into account the damage resulting from pest activity in the affected state, the economic impact upon the state’s regulated businesses, the financial and competitive disadvantages that are inherent when a state discovers an invasive pest species within its borders and the potential economic impact on the rest of the country.

NASDA wishes to remind OMB that the Plant Protection Act authorizes the Secretary of Agriculture to cooperate with state and local governments, but does not authorize or obligate states to perform plant pest or disease emergency (eradication) project activities.  The USDA alone is responsible for the eradication of federally regulated plant pests and diseases.  The federal government should accept responsibility for full funding of its programs, declare its intent to cooperate with the affected state(s), implement cooperative agreements to fund state eradication and control program costs, and exercise leadership.

APHIS Emergency Programs
Last updated: February 08, 2010

APHIS has published a proposed rule that would codify a standardized cost-sharing formula for animal disease and plant pest and disease emergency eradication programs that are conducted cooperatively with states. Unfortunately, expanding world trade and the threat of bio-terrorism have increased the risk of destructive pests and diseases being introduced into the United States. The USDA is the federal agency statutorily charged with preventing the introduction, spread and establishment of plant pests and diseases, noxious weeds and pests and diseases of livestock in the United States. States are not federally mandated to partner with USDA in this endeavor yet have historically done so with great success.  Developing a plan on how the USDA should respond to emergencies is not without merit. In fact, NASDA's Animal Health Safeguarding Review and the Safeguarding American Plant Resources Review conducted by the National Plant Board contain recommendations that would facilitate the kind of out year planning envisioned in the proposed rule.

Emergency programs relating to animal and plant health by their very nature, however, do not accommodate a "one size fits all" approach.  While some suggest a cost-share formula would yield savings to the Federal Government in future years, it will actually result in quite the opposite for states, who are already bearing significant costs associated with plant and animal pest and diseases that are not detected at the border.

2.3 Foreign Plant Issues
Last updated: February 08, 2010

Homeland Security and Agriculture
Last updated: February 08, 2010

Pest Exclusion
Last updated: February 08, 2010

The introduction of foreign pests has cost the nation millions of dollars in control and eradication efforts and lost production.  Foreign pest invasions should be recognized as a national problem, not just the problem of the state in which the pest originally entered the United States.  Regardless of the entry point of the disease, it still poses a threat to the entire agriculture industry.  Initiatives should be focused on pest exclusion activities including tighter security.  In order to be successful, traditional APHIS pest management programs must be fully funded to meet this objective, and maintain current quarantines for federally regulated pests.

User Fees
Last updated: February 08, 2010

APHIS should seek authority to use the Agricultural Quarantine Inspection  user fees collected from the traveling public and the shipping industry for better surveillance and protection of the plant industry in the United States.  Further, APHIS should seek to expand or increase the user fees charged to conduct a comprehensive pest prevention program. 

Plant Pest Survey
Last updated: February 08, 2010

Given the passage of the North American Free Trade Agreement (NAFTA) and the General Agreement on Tariffs and Trade (GATT), several states have taken initiatives to develop  agreements which support the export of agricultural crops and commodities.  A primary concern of importing countries in the negotiation of these agreements is the risk of introducing exotic or threatening pests.  U.S. exporters face a host of phytosanitary barriers around the world resulting in millions of dollars of lost trade opportunities.

To help resolve this concern, a list of known pests associated with a crop or commodity is required by the importing country.  In some cases, the crop or commodity is prohibited from export if the target pest is known to occur in the exporting state.  In other situations, the importer allows entry, providing that the state can declare that a particular pest does not occur in the country of origin or growing site.  Statewide pest survey programs that are supported by USDA-APHIS-PPQ through the Cooperative Agricultural Pest Survey (CAPS) can help address these phytosanitary concerns.  The CAPS Program utilizes a National Agricultural Pest Information System (NAPIS) database for efficient pest management.

Proper funding for the CAPS Program should continue so that pest data can be collected and the exporting of agricultural crops and commodities can be enhanced.  States should also consider conducting survey programs to complement the federal program. 

Offshore Pest Program
Last updated: February 08, 2010

In response to introductions and interceptions of the Asian gypsy moth in the early 1990s in the U.S., an offshore program in Russian Far Eastern Port Areas was initiated to exclude this and two other exotic major pests of forest and urban trees and shrubs.  This program, which was initiated in 1993, has tracked the population density and distribution of three pests of Lymantria species, including the Asian gypsy moth (L. dispar), the nun moth (L. monacha), and the rosy gypsy moth (L. mathura) and implemented measures to minimize the risk of their introduction into the United States since the initiation of this monitoring program.

This cooperative project between the United States Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS), the USDA Forest Service, the Federal Forest Service of Russia, and the State Plant Quarantine Service of Russia is largely supported with funds provided by APHIS and the Forest Service.  During FY 2001, APHIS and the Forest Service will jointly provide about $150,000.  Most of these funds are provided by APHIS.  Populations of the Asian and rosy gypsy moths typically begin to peak in the Russian Far East during the late spring and early summer.  This translates into a higher risk of artificial movements of these pests on ships and cargo. 

NASDA urges the U.S. Department of Interior and USDA to fund this program for as long as these pests pose a significant risk of introduction into North America.  NASDA also urges USDA-APHIS and the USDA  Forest Service to evaluate the risks arising from the movement of ships and cargo from other areas infested by these pests, such as Japan, Korea, and China.  NASDA encourages the expansion of this program to cover other known pest threats and threats which may be identified through the timely completion of pest risk analyses in the future.

The detection, in early 2002, of live Mediterranean fruit fly larvae in Spanish Clementine citrus fruit delivered throughout the U.S. poses a serious threat to all fruit and vegetable areas. This unfortunate phytosanitary certification program failure makes it abundantly clear that proper safeguards were not adequately developed to protect our valuable agricultural resources from exotic plant pest introductions. The Spanish Clementine/medfly phytosanitary failure indicates there may be other agricultural protocols that are not adequate to protect our valuable food and fiber resources.  USDA should take immediate steps to review the safeguards that are needed to assure all fruits and vegetables from any foreign country, as well as the current situation including citrus fruit from Spain are pest and disease free upon entry. The reviews should include treatment efficacy, pest surveilance, mitigation at origin, inspection at port of export, and inspection upon arrival. The expertise of NASDA as well as the expertise of the USDA-ARS, National Plant Board, and university system should be involved in the review which should be ongoing as new programs are proposed.

Imported Wood Regulation
Last updated: February 08, 2010

Current pest risk analyses have addressed surface or shallow wood pests.  However, there is concern over a potential deficiency in the current imported wood regulations with regard to railroad ties, temperate hardwood logs, wood chips, bark chips, humus, and similar materials.  Experience with the currently regulated commodities to date indicates that the current regulations do not completely address the potential risks associated with these materials.  Specifically, evidence that  pathogenic fungi and live insects have been imported on railroad ties, that fumigation does not always control deep wood insects or fungi, and recent experiences with Asian longhorned beetle and citrus longhorned beetle demonstrate that insects that bore deep into wood still pose a serious threat.  It was determined by the Oregon Department of Agriculture that live fungi, including pathogenic species, have been found in imported fumigated wood and inside fumigated bark.

NASDA urges USDA-APHIS-PPQ to conduct additional pest risk analyses and revise the wood regulations to mitigate pathways for introduction of potential deep wood pests and diseases through imported wood products.

Quarantine 37
Last updated: February 08, 2010

Any proposed changes to CFR 319.37 commonly known as “Quarantine 37" must be based on a comprehensive biological assessment of the pest and disease introduction risk associated with the commodity and country of origin. The current request to allow additional plant species to enter the U.S. is of concern and must be subjected to a full assessment including evaluation from areas of the U.S. that are considered to be most at risk from exotic plant introductions. As Quarantine 37 has been, and remains, an important part of our first line of defense against exotic plant pests of concern to the U.S. nursery industry as well as other segments of agriculture, it must maintain its current high degree of biological integrity.

2.4 Controlling Pests
Last updated: February 08, 2010

Biological Pest Control
Last updated: February 08, 2010

Classical biological control is a pest control strategy that involves the importation of new natural enemies to control introduced pests.  Classical biological control has been successfully implemented in the U.S. over the last 100 years.  The use of this strategy of pest management is experiencing renewed attention because it is extremely cost effective and environmentally sound.  Both the agricultural and urban populations in the U.S. have much to gain from the continued use of such efforts.  Once an effective natural enemy is established, control is self-sustaining, requiring no additional revenues.  Because the biocontrol agent is specific to the pest organism, its introduction has no adverse effect on the environment.

Currently, there is no coordinated effort between the federal government and the state departments of agriculture to support and promote classical biological control at regional and national levels.  NASDA believes that a coordinated approach is essential so as to encourage continued importation of new natural enemies into the United States.  NASDA urges Congress to appropriate funds to adequately support the research and development of biological control agents and establish this effort as a priority within USDA-APHIS to combat established invasive species.

Land grant institutions and the USDA have played a critical role in current and past biological control projects.  However, funding has been shifting to basic research in the field of biotechnology.  Although the products of this new technology hold much promise, classic biological control is a proven pest management strategy benefiting a broad range of concerns that must be financially supported by government agencies as well as the agricultural community.  Private enterprise cannot promote the development of classic biological control because the profit motive for controlling individual organisms vanishes when a pest problem is permanently solved.

Regional plant protection centers are critical research facilities which provide biological control agents for the surrounding states in the region.  Strong regional support is important as heavy biological control needs demand the facilitation of interstate and international shipping of commodities while reducing the trend of strict pesticide use.  NASDA supports classic biological control in dealing with established invasive species and other agricultural plant pests.

Irradiation
Last updated: February 08, 2010

Irradiation is the process of using ionizing energy derived from electronic beams, x-rays and other energy sources to treat possible sources of contamination.  Ionizing energy has a number of applications in food processing and pest control.  The increased energy state, which evolves from the irradiation process, attacks and destroys microorganisms, parasites, insects and bacteria.  It can be used to treat plant or animal products including fruits, vegetables and meats.  It is also an important tool for preventing the introduction, through importation, of plant pests.  Irradiation, a process considered safe by national and world health organizations and accepted by  many countries, is a technological development that can be applied to agricultural products in a safe manner. 

NASDA believes that the USDA should encourage the use of irradiation for pest control.  This is an important technology that  can be applied to agricultural products to ensure a safe and healthy food supply.

ICM and IPM
Last updated: February 08, 2010

The American consumer has the safest, most abundant, and secure source of food in the world.  America's farmers and ranchers have continually used the most up to date technology available to feed the American public.  However, today's farmers and ranchers are being criticized for abusing our natural resources while still being asked to provide more and cheaper food.  Producers and scientists across the country are searching for new and safer ways to meet the consumer needs that are also economic and environmentally friendly.  Two practices currently expanding in use are Integrated Crop Management (ICM) and Integrated Pest Management (IPM).

Integrated crop management (ICM) is the practice of monitoring and treating pests, diseases and soil conditions on a field by field basis with the goal of reducing cost and production inputs. Integrated pest management (IPM) is a component of the ICM system of management.  IPM  is a sustainable approach to managing pests by combining biological, cultural, physical and chemical tools in a way that minimizes economic, health and environmental risks.

Major advances have been made in the use of agricultural chemicals and in the development of management practices using chemicals in combination with non-chemical production tools.  Developing a system of setting goals and measuring progress would result in real and positive changes in America's agriculture toward the underlying objectives of reducing environmental impact and increasing public confidence in the safety of foods.

IPM should be implemented nationally to reduce the reliance on chemical pesticides and increase the use of non-chemical tools over the long term.  It will probably take at least $40 million to $50 million to implement a national system that defines appropriate federal and state roles, for many of the highest priority invasive plant pests that threaten our agriculture and environment.

IPM will reduce the reliance on chemicals, but chemical use will continue with varying degree due to such factors as  non-uniform pest problems, regional differences in climate, pest resistance problems, and reductions in pesticide use already achieved by IPM programs currently in use.

The following IPM principles are important to the implementation of such strategies in each state:

• Assessment of pest problems associated with the planting, growing, harvesting, storing and processing of raw agricultural commodities, ingredients and processed foods for human and animal consumption.
• Determination of management plans that emphasize non-chemical tactics to deal with pest problems.
• Establishment of thresholds for each pest problem to define when corrective action must be implemented.
• Implementation of monitoring procedures for each pest.
• Implementation of corrective action when a threshold is reached for any pest problem.
• Implementation of a documentation system to catalogue and monitor information and to document management procedures.
• Establishment of evaluation and verification procedures to assure the IPM program is meeting stated risk reduction measures.

Any national IPM strategy should consider the following principles and goals:

• Adoption of IPM practices through a combination of education and cost-sharing programs with USDA's Water Quality Initiative and other conservation programs.
• Development of training and educational programs to teach extension agents, growers, consultants and processors specifics of IPM principles and regional crop guidelines.
• Establishment of economic incentives for growers to implement IPM practices.
• Issuance of an annual report for each region summarizing levels of adoption of IPM principles for each crop and area.
• Establishment of regional research priorities on the basis of annual results and recommendations from each region.
• Establishment of regional centers structured to meet regional IPM needs.

2.5 Karnal Bunt
Last updated: February 08, 2010

Karnal bunt is the disease of wheat, durum wheat, and triticale that is caused by Tilletia indica. Plant pathologists generally consider Tilletia indica to be a weak pathogen that causes a disease of minor  production importance.  Measurable yield loss is uncommon.  The most severe adverse economic impacts are associated with the current domestic and the more than 50 foreign quarantines which have disrupted the traditional marketing of wheat produced in the  United States.  The presence of Tilletia indica-like teliospores jeopardizes wheat shipments  in the marketplace.

There is a consensus, among the majority of the plant regulatory officials of the United States and plant pathologists, who work with smut diseases, that Tilletia indica can be effectively managed and controlled with normal crop management practices.  Since Karnal bunt is a pathogen of minor significance, the USDA should emphasize and promote the successful management of Karnal bunt in the United States in discussions with our trading partners. 

The USDA should call for deregulation of Karnal bunt as a quarantine pest by our trading partners and individual states immediately.  Any revisions to domestic restrictions should include provisions for the shipment of seed from a potentially infected area if that seed is tested free of teliospores and treated with a fungicide. NASDA encourages USDA to immediately work with the National Plant Board to revise the federal domestic quarantine regulating grain to allow its movement while minimizing the spread of the disease.  To this end, NASDA encourages USDA and the National Plant Board to analyze and review the pest risk posed by allowing movement based upon tests for bunted kernels versus teliospores.  USDA also should revise the federal foreign quarantine to be consistent with the revised federal domestic quarantine.

Recognizing that, in the meantime, quarantine requirements will be established by importing countries, the USDA should continue efforts to prevent additional quarantine restrictions and to negotiate with trading partners for reasonable phytosanitary requirements.  The national survey should continue to validate the pest-free status of all United States production areas, serve as the basis for further regulation on an annual basis and be the validation for Federal Phytosanitary Certificates.

Consistent with the Principles of Plant Quarantine, USDA should work with the scientific community to identify, prioritize, and facilitate the accomplishment of research objectives.  Further, NASDA encourages the international scientific community to develop a scientific position statement  on Karnal bunt and other smut diseases for the global community.

2.6 Regulation of Nursery Stock
Last updated: February 08, 2010

NASDA supports the needs of the nursery stock industry to move products freely between states, but believes that nursery stock must adhere to a long established reciprocity agreement of inspection/certification by the state of origin which is re-enforced by state and/or federal quarantine regulations.

While standardized procedures for the inspection/certification process may be appropriate, non-infested states must be protected from potential introductions for several reasons.  First, introductions of pests could put valuable forest and agricultural resources and urban/suburban forested areas that contribute substantially to the economic/social welfare of the state at risk.  Second, considerable resources have been invested by non-infested states to eradicate localized infestations and to establish surveys to detect, delimit infestations and monitor control treatments.  Third, environmental degradation and public chaos resulting from infestations and pesticide treatments could result.  Fourth, additional resources would be required to inspect high risk nursery stock imported to non-infested states at dealer locations that should be credibly inspected and certified at the grower location. Finally, trade agreements and markets for nursery, Christmas tree, and other regulated industries intending to export their crops or commodities could be hampered.

2.7 Seed Health
Last updated: February 08, 2010

State Seed Programs
Last updated: February 08, 2010

All 50 states have seed laws which require individuals and seed firms to truthfully label all seed for sowing purposes which is offered for sale.  Over the past years, a number of states have either reduced funding for their seed programs or eliminated them altogether.  Biotechnology and other advances in seed technology will likely be marketed to the consumer through the genetic structure of seed, thus placing additional demands on seed regulatory programs.  The situation has become very critical in the Northeast, where some states have reduced seed programs or eliminated their seed regulatory laboratories altogether.

Strong and efficient state seed programs ensure the consumer that the seed they have purchased is truthfully labeled and is routinely being sampled and tested for quality under the state seed laws of their state.  Consumers of seed in states without viable seed programs may suffer financial losses when they unknowingly purchase poor quality seed sold or shipped into their state that would not be offered for sale in another state with a strong seed regulatory program.  Since a large volume of seed is sold through interstate channels, it is in the best interests of all states to have strong and viable seed regulatory programs in order to create a level field for marketing of seed in the United States.

Seed-borne Pathogens
Last updated: February 08, 2010

Seed-borne diseases constitute a demonstrated threat to American agriculture.  Many seeds used by American agriculture are imported from foreign countries.  Although such seed importations are frequently inspected for weeds or insect pests by the USDA, no such inspections are conducted or required for seed-borne pathogens.  A testing and/or certification program for seed-borne pathogens is needed in the United States so as to protect agricultural crops.

Seed Health Initiative
Last updated: February 08, 2010

A seed health initiative proposal would provide for the accreditation of seed laboratories and seed companies to perform seed health laboratory and field testing to provide supporting documentation for issuing phytosanitary certificates.  This concept of a laboratory accreditation system has merit, but several concerns must be met.  First, a chain of custody for samples, including who, when, and how they are drawn, transported, and submitted should be established.  Public laboratories should also receive accreditation with consideration given to cost, loss of public laboratory resources for working on minor crops and approval vs. accreditation.  APHIS should maintain oversight authority over accredited laboratories.  Consideration needs to be given to the types of laboratories that should be accredited, including concerns about conflicts of interest associated with private laboratories belonging to seed companies.

Finally, the availability of test data for plant pest officials’ inclusion in the National Agricultural Pest Information System database should be addressed. 

National Variety Name Registration
Last updated: February 08, 2010

A National Variety Name Registration should be established in the Federal Seed Act for all agricultural and vegetable crops, and it is recommended that adequate funding be provided for variety name registration over current budget allocations or registration fees be implemented to administer the program.  This program should be established because the release of new varieties into commerce has greatly increased with the advent of genetic engineering, the large proliferation of new variety releases are difficult to track and regulate, there is no national variety name registration within the United States, some cultivars may be illegally marketed by different variety names from one company to the next, confusion exists between variety labeling and brand labeling for some crop kinds, and some mixtures of agricultural crops are incorrectly labeled as single varieties.

2.8 Noxious Weeds
Last updated: February 08, 2010

Invasive non-indigenous plant species threaten to destroy America's biological heritage and cause serious economic loss by polluting natural areas and agricultural systems.  Biological pollution seriously impacts agricultural production and natural ecosystems causing economic and ecological losses.  It has been estimated that the annual economic losses caused by these invasions is more than $20 billion.

Invasive, non-indigenous plants are assaulting America's wildlands, recreation areas, forest and pasture lands, replacing native vegetation, reducing the productivity and grazing land for livestock, degrading wildlife habitat, and clogging waterways.  This invasion of harmful, non-indigenous plants is not like other resource management problems.  It changes the very structure and function of critical ecosystems.  In essence, these noxious weeds cause a blight at the ecosystem level and interfere with ecosystem management.  Delays in controlling existing populations and preventing new invasive, non-indigenous plant species will only increase costs over time to America's agricultural industry and natural resource managers.

NASDA believes it is appropriate and vital that the federal government assert primary jurisdiction and assume a more dynamic leadership role in the interdiction and eradication of destructive invasive species.  It is also critical that the federal agencies work in partnership with state and local governments and non-government organizations in developing policies and procedures.  Building greater capacity of state and local governments for effectively dealing with destructive invasives should be a paramount goal of this effort.

NASDA also believes that caution is warranted in the development of the Invasive Species Management Plan.  It must clearly differentiate useful and beneficial “alien species” from destructive, invasive “alien species”.  NASDA recommends that the Council and the Advisory Committee avoid developing a “list” in the Plan that would combine the two categories of exotics.  In fact, we see no need to develop such a list at all. The Plan should generally reference invasive or noxious lists developed by local councils or committees which have utilized input from a broad constituency and which have followed public participation policy requirements.  The Plan should layout a framework of federal action that focuses on prevention of accidental or intentional introduction of harmful invasives to the United States and it’s territories.  It should also establish a foundation for a national monitoring and informational network to provide state and local government with early warning about new potentially destructive species.

2.9 Soybean Rust
Last updated: February 08, 2010

Asian soybean rust (Phakopsora pachyrhi) is a plant disease that is currently found in Australia, Africa, Asia, and South America. Soybean rust is an airborne fungal disease that can cause premature defoliation, which results in fewer pods, lighter seeds and poor seed quality. Rust damaged crops can suffer up to an 80 percent yield loss. Soybean rust can be easily confused with other common soybean diseases such as bacterial pustule, bacterial blight or septoria brown spot. Soybean rust and the seed from rust infected plants are not shown to be harmful to humans or animals.

Soybean rust can be transferred many ways but most commonly it is transported by wind/air currents. Airborne spores can be carried for long distances and can infect and reproduce on numerous alternate host plants, including kudzu, which grows in many areas of the southeastern United States. Soybean rust will be impossible to contain and eradicate in the continental United States, because the spores are produced in massive quantities on a variety of infected plants, and then dispersed via air currents. Spores may also be transmitted on infected plant material or on articles such as shoes and clothing.

Asian soybean rust has been detected in at least eight states since its initial discovery in a research plot in Louisiana on November 6, 2004. As predictive modeling indicated, soybean rust spores were introduced via hurricane activity, moving into the United States from the Southern Caribbean.

In the foreseeable future, the only way to control the disease is through timely fungicide applications and management plan development. Currently there are two fungicides registered for foliar application in the United States. Several other fungicides and application programs are being evaluated and an application for Section 18 status has been submitted to the EPA. Researchers continue to work to develop genetically resistant or tolerant varieties to be used as an alternative or in conjunction with fungicide applications. In addition, seed treatment options are being explored for possible effectiveness and efficacy.

Minimize Spread
Last updated: February 08, 2010

NASDA believes communication among government agencies as well as within the farm community is central to monitoring and minimizing the damage from soybean rust. NASDA supports producer education about identification of the disease and about viable options to control the pest, so producers are well informed and equipped to address the problem.

Quarantine and eradication steps are not practical as the disease may infect many plant species (crop and non crop) found in the United States. Therefore, it is imperative that NASDA members, USDA and other federal officials coordinate their actions and quickly inform producers of a rust confirmation. Time is of the essence as under the right conditions, soybean rust may produce spores at an alarming rate, further infecting additional fields. The faster the news of a rust confirmation can be communicated with growers, the earlier the producers can apply fungicides to lessen the consequences of a soybean rust infestation.

Farmers must be assured that communication concerning infected fields with agricultural officials will not result in punitive actions. Rather, it must be emphasized that early detection allows officials to warn growers so that both protective and curative fungicide treatments can begin as soon as possible.

NASDA encourages the USDA to take a leadership role in the development of a soybean rust monitoring plan to determine the seasonal rate of spread. Further, the USDA should take the lead in the development of a soybean rust management plan.

Homeland Security Designation
Last updated: February 08, 2010

NASDA urges the USDA and DHS to swiftly re-evaluate the pathogens currently on the Select Agents List. NASDA strongly urges the evaluation to disregard pathogens that are predicted to naturally spread to the United States, as rust is a prime example of a pathogen with no control mechanism to stop the airborne spread.

This Select Agent designation highlights soybean rust in an unnecessarily negative manner. Soybean rust should be treated as any other normal quarantinable pest that could enter the country at any time. As long as soybean rust is labeled a Select Agent, we raise the risk that trading partners could use rust as reason to block imports of U.S. soybeans.