Comment from Richard McDonald

Document ID: APHIS-2012-0060-0010
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: September 03 2012, at 12:00 AM Eastern Daylight Time
Date Posted: September 4 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: August 3 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: September 4 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 810ffc09
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I fully support the release of Scymnus coniferarum Crotch, (SCW) against hemlock woolly adelgid, Adeges tsugae, (HWA) a strain of which is native to the Pacific Northwest. Once we realized the HWA was native to the Pacific Northwest, we were able to discover this potentially valuable predator of the 'summer' generation. Dr. Michael Montgomery of the USFS has remarked repeatedly that the eastern US is lacking a good generalist adelgid predator. SCW is found in 19 western states, from southern Arizona to Idaho, and west to South Dakota, indicating the potential for adelgid predation in a wide range of habitats. SCW may be a wash; or it might fill a niche we believe has not yet been occupied in our hemlock woolly adelgid predator guild. We have seen 8 straight years of buildup by the native cogenitor winter HWA predator Laricobius niginrus in our area of NW NC, but we have no corresponding buildup at the present of summer predators to hit the 2nd generation of HWA. We are lacking a good summer predator after all this time. SCW may be it. The discovery of this beetle shows teamwork and learning occurring on a regional level between private, state and federal entities. Mark Dalusky of Georgia was instrumental in seeing this beetle's potential in its native habitat. I was lucky and honored to work with Prof. Scott Salom of Virginia Tech, Brad Onken of the US Forest Service - Forest Health Protection, and especially Dr. Michael Montgomery of the US Forest Service Research Station, on Chinese Scymnus species initially; that is what lead to our understanding of the native predators to the point that we can offer this beetle in service of the forest. Robert Tichenor was a gem & APHIS is lucky to have him. If Scymnus coniferarum does turn out to be a good adelgid predator, there are also pest adelgid problems in the Fraser fir industry and other conifer industries that could possibly benefit from improved predation by this and other native and exotic adelgid predators.

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