2.2 Domestic Plant Pest and Disease Issues

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.