Comment from Leellen Solter

I write to urge USDA APHIS PPQ to go forward with “Movement of Plant Pests, Biological Control Organisms, and Associated Articles” Alternative 2, “Revise requirements for movement of plants pests consistent with the scope of the Plant Protection Act”. As an insect pathologist, I am concerned about two issues, 1. the importation of microbials for classical biological control, and 2. the potential for inadvertently importing exotic pathogens with hosts intended for use as biological control agents or other beneficial use. Rules are needed for import and release of biological control agents that are risk-based, with the steps to be followed made clear and straight-forward for timely decision-making. Rules for hand-carrying biologicals should also be clear and should acknowledge that the safest route for delivery from point of origin to the U.S. laboratory is in the hands of expert researchers who have obtained permits for their import and use. Pathogens and other organisms collected for biological control programs (usually at the expense of the U.S. government agencies directly or via federal grants to other institutions) are sensitive and could easily be damaged or destroyed in the hands of non-experts. The USDA NIFA program has provided a response to this notice. I support their recommendations to create a workable, communicative, facilitative and risk-based regulatory process based on scientific data. My personal experience with importation and release of host-specific pathogens of gypsy moth was not a matter of roadblocks, but of the lack of a clear process to follow… confusing and time consuming for all involved in the application and decision-making process. Regarding importation of diseased arthropod biological control agents, many pathogens are chronic and may not become apparent while the articles are in quarantine, but ultimately can destroy expensive colonies, compromising biological control projects and potentially posing a risk to native congeners