United States Department of Agriculture Importation of Orchids
Marketing and Regulatory (Cymbidium and Programs
Animal and Plant Health Phalaenopsis spp.) in Inspection Service Approved Growing Media From the Republic of Korea
Final Environmental Assessment, July 2017
Importation of Orchids (Cymbidium and Phalaenopsis spp.) in Approved Growing Media From the Republic of Korea
Final Environmental Assessment July 2017
Agency Contact: Rosemarie Rodriguez-Yanes Phytosanitary Issues Management Plant Protection and Quarantine Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 140 Riverdale, MD 20737–1237
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Table of Contents
I. Introduction ...... 1 A. Background ...... 1 B. Purpose and Need ...... 2
II. Alternatives ...... 2 A. No Action ...... 2 B. Preferred Alternative ...... 3
III. Affected Environment ...... 6 A. Host Range of Quarantine Pests ...... 7 B. Climate and Host Interactions ...... 10 C. Threatened and Endangered Species ...... 11
IV. Environmental Impacts...... 12 A. No Action ...... 12 B. Preferred Alternative ...... 12 C. Risk Managment ...... 16 D. Endangered Species Act ...... 24 E. Other Considerations ...... 24
V. Listing of Agencies Consulted ...... 25
VI. References ...... 26
I. Introduction
A. Background
Currently in the United States, orchids are sold in pots primarily for the interior design market. It is not uncommon for these plants to be mass-produced and sold at wholesale to general merchandise retailers and specialty outlets where they are purchased by consumers. Cymbidium and Phalaenopsis spp. and other orchids are imported into the United States from the Republic of Korea as bare-rooted plants (7 Code of Federal Regulations (CFR) § 319.37–8(d)), and subject to inspection at U.S. Department of Agriculture’s (USDA) plant inspection stations at certain U.S. ports of entry. In accordance with section 319.37–8(a) of the regulations, USDA’s Animal and Plant Health Inspection Service (APHIS) requires, with certain exceptions, that plants offered for importation into the United States be free of sand, soil, earth, and other growing media. Many U.S. potted orchid growers begin with imported plants; they purchase the bare-rooted imports, pot and grow them for sale.
China serves as the primary market for South Korean exports of live orchids accounting for approximately 94 to 97 percent of its annual exports. The U.S. imports of live orchids from South Korea have fluctuated annually from 97,425 kilograms (km) in 2009 to less than 40,000 km in 2012. The importation of live orchids from South Korea accounts for less than 2 percent of annual U.S. imports. The United States imports between 4.5 and 6 million km of live orchids, valued at nearly $59 million to $70 million annually. Approximately 86 percent of these live orchids imported into the United States are sourced from Taiwan each year. The United States also imports live orchids from Thailand (approximately 4 percent), the Netherlands (approximately 2.4 percent), Canada (approximately 2.4 percent), and Costa Rica (less than 2 percent) each year.
The Republic of Korea has requested to export to the United States Cymbidium and Phalaenopsis spp. orchids potted in APHIS-approved growing media. This will improve the viability of imported plants because, currently, there is high mortality of bare-rooted plants (Su et al., 2001). In Korea, most bare root plants are dry packed in sleeves and cardboard boxes, transported by road to local markets, and airlifted to export destinations with varying levels of post-harvest handling losses.
This environmental assessment (EA) was prepared to comply with the National Environmental Policy Act of 1969 (NEPA) 42 United States Code (U.S.C.) 4321, et seq., as prescribed in implementing regulations
1 adopted by the Council on Environmental Quality (40 CFR §§1500– 1508), by USDA (7 CFR part 1b), by APHIS (7 CFR part 372), and to satisfy Executive Order (EO) 12114, “Environmental Effects Abroad of Major Federal Actions.”
B. Purpose and Need
USDA–APHIS, Plant Protection and Quarantine (PPQ) is proposing to amend the regulations for the importation of plants and plant products (7 CFR part 319). PPQ has been petitioned to add orchids of the genera Cymbidium and Phalaenopsis (known as boat and moth orchids, respectively) from the Republic of Korea to the list of plants that may be imported in approved growing media, subject to specified growing, inspection, and certification requirements.
Currently, orchid species of Cymbidium (a terrestrial orchid) are imported as bare root plants and Phalaenopsis species (spp.) as other epiphytic orchids are imported from the Republic of Korea into the United States as bare-rooted plants or when growing on tree fern slabs, coconut husk or coconut fiber, new clay pots, or new wooden baskets, under the provisions of 7 CFR § 319.37–8(d). The Republic of Korea has requested that PPQ consider amending the regulations to allow Cymbidium and Phalaenopsis spp. orchids to be imported into the United States in an approved growing media under the provisions of 7 CFR § 319.37–8(e).
II. Alternatives
This EA analyzes potential environmental consequences of the implementation of a proposal to amend the regulations governing the importation of plants and plant products into the United States (7 CFR part 319). Two possible alternatives are considered in this EA: maintaining the current regulation for the importation of orchids of the genera Cymbidium and Phalaenopsis into the United States (no action alternative), and the implementation of regulations under the proposed rule (preferred alternative).
A. No Action
The no action alternative would leave 7 CFR part 319 unchanged. Section 319.37–8(a) of the regulations requires, with certain exceptions, that plants offered for importation into the United States be free of sand, soil, earth, and other growing medium. This requirement is intended to help prevent the introduction of plant pests that might be present in unapproved growing media; the exceptions to this requirement take into account factors that mitigate that risk. Those
2 exceptions, which are found in paragraphs (b) through (e) of 7 CFR § 319.37–8, consider either the origin of the plants and growing media; or the nature of the growing media and/or the use of a combination of growing conditions, approved media, inspections, and other requirements.
Currently, as epiphytic plants, Cymbidium and Phalaenopsis orchid spp. are imported from the Republic of Korea into the United States as bare-rooted plants or when growing on tree fern slabs, coconut husk or coconut fiber, new clay pots, or new wooden baskets. All forms are enterable subject to inspection findings at designated ports of entry to the United States, that is, ports associated with facilities where propagative material can be examined (plant inspection stations). All orchid consignments must be accompanied by a USDA permit, a phytosanitary certificate issued by the plant protection service of the exporting country, and a Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) document. Together, these documents certify that the orchids have been inspected, found free of quarantine pests, and authorized for international export.
As stated in 7 CFR § 319.37–8(e), the following groups of plants established in approved growing media are currently allowed entry to the United States:
• Alstroemeria, Ananas, Anthurium; • artificially dwarfed (penjing) plants from the People’s Republic of China of the following plant species: Buxus sinica, Ehretia microphylla, Podocarpus macrophyllus, Sageretia thea, and Serissa foetida; • Bromeliad plants of the genera Aechmea, Cryptanthus, Guzmania, Hohenbergia, Neoregelia, Tillandsia, and Vriesea from Belgium, Denmark, and the Netherlands; • Begonia, Gloxinia (=Sinningia), Nidularium, Peperomia; • Cymbidium and Phalaenopsis spp. from Taiwan; • Polypodiophyta (=Filicales), Rhipsalidopsis spp. from the Netherlands and Denmark, Rhododendron from Europe, Saintpaulia, and Schlumbergera spp. from the Netherlands and Denmark.
Under the no action alternative, Cymbidium and Phalaenopsis spp. orchids from the Republic of Korea would not be added to the list of taxa allowed entry into the United States established in approved growing media and would continue to enter the United States under current requirements (7 CFR § 319.37–8(d)).
3 B. Preferred Alternative
The proposed rule (preferred alternative) would change 7 CFR part 319 and thus allow importation of orchids of the genera Cymbidium and Phalaenopsis from the Republic of Korea rooted in approved growing media. The orchids would be required to be produced, handled, and imported in accordance with the requirements of 7 CFR § 319.37–8(e) and accompanied, at the time of importation, by a phytosanitary certificate issued by the National Quarantine Service of the Republic of Korea (NPQS) declaring that the requirements have been met.
The proposed action includes propagation, rearing, shipping, and importation of Cymbidium and Phalaenopsis spp. in approved growing media into the United States from the Republic of Korea. Below are detailed requirements that must be met, as stipulated in 7 CFR § 319.37–8(e):
(e) Cymbidium and Phalaenopsis spp. orchids may be imported from the Republic of Korea established in an approved growing media if the article meets the conditions of this paragraph and is accompanied by a phytosanitary certificate issued by NPQS that declares that the article meets the conditions of this paragraph:
(1) Approved growing media includes baked expanded clay pellets, organic and inorganic fibers, peat, sphagnum moss, vermiculite, and other media (see 7 CFR § 319.37–8(e)(1) for a complete list), and must not have been previously used.
(2) Articles imported under this paragraph must be grown in compliance with a written agreement for enforcement of this section signed by NPQS and PPQ, must be developed from mother stock that was inspected and found free from evidence of disease and pests by a PPQ or NPQS inspector no more than 60 days prior to the time the article is established in the greenhouse (except for articles developed from seeds germinated in the greenhouse), and must be:
(i) Grown in compliance with a written agreement between the grower and NPQS, in which the grower agrees to comply with the provisions of this section and to allow inspectors and representatives of NPQS access to the growing facility as necessary to monitor compliance with the provisions of this section;
(ii) Grown solely in a greenhouse in which sanitary procedures adequate to exclude plant pests and diseases are always employed, including cleaning and disinfection of floors, benches, and tools, and the application of measures to protect against any injurious plant 4 diseases, injurious insect pests, and other plant pests. The greenhouse must be free from sand and soil and must have screening with openings of not more than 0.6 millimeters (mm) on all vents and openings except entryways. All entryways must be equipped with automatic closing doors;
(iii) Rooted and grown in an active state of foliar growth for at least 4 consecutive months immediately prior to importation into the United States, in a greenhouse unit that is used solely for articles grown in compliance with this paragraph;
(iv) Grown from seeds germinated in the greenhouse unit; or descended from a mother plant that was grown for at least 9 months in the Republic of Korea prior to importation of the descendent plants into the United States, provided that if the mother plant was imported into the Republic of Korea from another country, it must be:
(A) Grown for at least 12 months in the Republic of Korea prior to importation of the descendent plants into the United States, or
(B) Treated, at the time of importation into the Republic of Korea, with a treatment prescribed for pests of that plant by NPQS and then grown for at least 9 months in the Republic of Korea prior to importation of the descendent plants into the United States;
(v) Watered only with rainwater that has been boiled or pasteurized, with clean well water, or with potable (municipal) water;
(vi) Rooted and grown in approved growing media listed in 7 CFR § 319.37–8(e)(1) on benches supported by legs and raised at least 46 centimeters (cm) above the floor;
(vii) Stored and packaged only in areas free of sand, soil, earth, and plant pests;
(viii) Inspected in the greenhouse and found free from evidence of plant pests and diseases by a PPQ inspector or an inspector of NPQS, no more than 30 days prior to the date of export to the United States.
The packaging commonly used in the orchid industry is cardboard boxes; however, other alternatives, such as plastic, are possible. These cardboard boxes are similar to other APHIS-approved packaging that excludes pests during the packing process and prevents hitchhikers from entering the packaged plants. The term “hitchhikers” is commonly used within PPQ to mean biological contaminants, including insects that generally are not specific to orchids. PPQ- approved packing material includes paper, rockwool, sawdust, and
5 other media specified in 7 CFR § 319.37–9. The pots containing the plants are most likely those that are commonly used in the orchid industry such as plastic, clay, or other composite materials.
Preshipment treatment measures (i.e., fumigation) are not included as a condition of entry of Cymbidium and Phalaenopsis spp. orchids from the Republic of Korea because the pest risk assessment (APHIS, 2012a) did not identify any quarantine pests which required these treatments in order to ensure quarantine security beyond the mitigations listed in 7 CFR § 319.37–8(e).
III. Affected Environment
The area available for both the current importation of bare-rooted Cymbidium and Phalaenopsis spp. orchids and the proposed importation of Cymbidium and Phalaenopsis spp. orchids from the Republic of Korea in APHIS-approved growing media is the continental United States. However, no orchid plants will be shipped directly to a location prior to passing through a PPQ plant inspection station where plants can be inspected at the port of entry. Once consignments are cleared through a plant inspection station, orchids could be distributed to any location in the United States, including its possessions and trust territories.
After receiving the Republic of Korea’s request to allow importation of Cymbidium and Phalaenopsis spp. orchids established in approved growing media into the United States, APHIS conducted a pest risk assessment (APHIS, 2012a) to examine the potential plant pest risk associated with unmitigated importations of orchids in growing media. The risk assessment prepared by APHIS examined the plant pest risk associated with the importation of Cymbidium and Phalaenopsis spp. orchids established in APHIS-approved growing media from the Republic of Korea into the continental United States, and characterized risk in terms such as high, medium, or low, based upon supporting evidence regarding climate-host interactions, host range, dispersal potential, economic impact, and environmental impact. In addition, the methods used to initiate, conduct, and report the risk assessment are consistent with guidelines provided by the North American Plant Protection Organization and the International Plant Protection Convention administered by the Food and Agriculture Organization of the United Nations.
In the pest risk assessment (APHIS, 2012a), only the quarantine pests that can reasonably be expected to follow the pathway (i.e., be included in commercial shipments of Cymbidium and Phalaenopsis spp. plants) were further analyzed. A quarantine pest is defined as “a pest of potential economic importance to the area endangered thereby 6 and not yet present there, or present but not widely distributed and being officially controlled” (FAO, 2002). The biological hazard of organisms identified only to the order, family, or generic levels is not assessed because of the uncertainty about the lack of species identifications; however, if pests identified only to higher taxa are intercepted at the port of entry in the future, then reevaluations of their risk may occur. The pests that were determined to have potential to be included in commercial shipments of Cymbidium and Phalaenopsis spp. (both bare rooted or in growing media) are listed in table 1.
Table 1. Quarantine Pests that May Follow the Pathway on Cymbidium and Phalaenopsis spp. from the Republic of Korea into the United States. (APHIS, 2012). Type Pest Arthropods Dichromothrips smithi Pseudococcus dendrobiorum Spodoptera litura Thrips palmi Mollusks Deroceras varians Fungi Colletotrichum boninense
A. Host Range of Quarantine Pests
The thrips Dichromothrips smithi feeds on flowers in the orchid family (Orchidaceae) including:
• Arundina graminifolia, • Ascocentrum spp., • Cattleya spp., • Cymbidium spp., • Dendrobium spp., • Habernaria spp., • Phalaenopsis spp., • Sacharum officinarum, • Spathoglottis spp., and • Vanda spp. (White, 2007; Li-zhong, 2000); • Arachmis sp. • Aranthera sp., • Mokara sp., • Phalaenopsis sp., • Rhinchostylis sp., • Vandas sp. ( PestID, 2011). 7
There are no confirmed records of this species affecting other plant families.
The mealybug Pseudococcus dendrobiorum was reported to affect only plants that belong to the family Orchidaceae. Orchid hosts reported include: • Ascoglossum calopterum, • Cymbidium sp., • Dendrobium sp., • D. bigibbum, • D. canaliculatum, • D. discolor, • D. johnsonae, • D. phalaenopsis, • D. phalaenopsis compactum, • Phalaenopsis sanderiana, • P. schilleriana, • Pholidota orbiculata, and • Promatocalpum spicatum (Ben-Dov et al., 2001; Hodges and Buss, 2009).
There are no records of this species affecting other plant families.
The host range of the oriental leafworm moth, Spodoptera litura, includes over 40 plant families. Plant species attacked by S. litura in the tropics include: • Oncidium sp. (TARI, 2009), • Dendrobium sp. (Orchidaceae) (Kumari and Lyla, 2001; Weaver, 2003), • Colocasia esculenta (Araceae), • Brassica sp. (Brassicaceae), • Ipomea batatas (Convolvulaceae), • Cucumis sp. (Cucurbitaceae), • Ricinus sp. (Euphobiaceae), • Arachis sp., • Glycine sp., • Leucaena leucocephala, • Medicago sativa, • Phaseolus sp., • Vigna sp. (Fabaceae), • Linum sp. (Linaceae), • Corchorus sp., • Gossypium sp. (Malvaceae), • Zea mays,
8 • Oryza sp. (Poaceae), • Capsicum sp., • Nicotiana tabaccum, • Solanum melongena, • Solanum tuberosum (Solanaceae), and • Camelia sp. (Theaceae) (CABI, 2011; EPPO, 1997b).
The thrip Thrips palmi feeds on many hosts and attacks plants in several families. Among primary hosts are species of:
• Actinidia chinensis, A. deliciosa (Acitnidiaceae); • Amaranthus spinosus, A. tricolor, A. viridis (Amaranthaceae); • Mangifera indica (Anacardiaceae); • Ageratum conyzoides, Ageratum spp., Chrysanthemun sp., Helianthus annuus, Lactuca sativa (Asteraceae), Cucumis melo, C. sativus, Cucurbita moschata, C, pepo (Cucurbitaceae); • Allium cepa (Liliaceae), Arachis hypogaea, Glycine max, Phaseolus vulgaris, Vigna ungiculat (Fabaceae), Persea americana (Lauraceae); • Gossypium sp. Abelmoschus esculentus (Malvaceae); • Oryza sativa (Poaceae), Sesamum indicum (Pedaliaceae); • Citrus spp., C. medica and C. sinensis (Rutaceae); • Capsicum spp, Capsicum annuum; • Nicotiana tabacum; and • Solanum lycopersicum, S. melongena, S. tuberosum (Solanaceae) (White, 2007)
The fungus Colletotrichum boninense has been reported as an endophyte and phytopathogen on a number of hosts in many genera and families; hosts include monocotyledonous, dicotyledonous, herbaceous and woody plants (Hyde et al., 2009). Hosts reported in the literature include:
• Bambusa sp. (McKay et al., 2009); • Capsicum annuum (Tozze Júnior et al., 2009); • Cattleya sp. (Moriwaki et al., 2003); • Clivia miniata (Moriwaki et al., 2003); • Crinum asiaticum var. sinicum (Moriwaki et al., 2003); • Coelogyne sp. (McKay et al., 2009); • Cucumis melo (Moriwaki et al., 2003); • Cymbidium sp. (Moriwaki et al., 2003); • Dendrobium kingianum (Moriwaki et al., 2003); • Dracaena sanderiana (Farr and Rossman, 2011); • Dracaena sp. (Farr and Rossman, 2011);
9 • Eucalyptus grandis (Lubbe et al., 2006); • Eucalyptus sp.(Lubbe et al., 2004; Shenoy et al., 2007); • Euonymus japonicus (Lee et al., 2005); • Hippeastrum sp. (Farr and Rossman, 2011); • Leucospermum sp. (Crous et al., 2004; Lubbe et al., 2004; Shenoy et al., 2007); • Manguifera indica (McKay et al., 2009); • Pachira sp. (Farr and Rossman, 2011); • Passiflora sp. (Farr and Rossman, 2011, Tarnowsky and Ploetz, 2010); • Passiflora edulis (Moriwaki et al., 2003); • Persea americana (Silva-Rojas and Ávila-Quesada, 2011); • Protea cynaroides (Crous et al., 2004; Lubbe et al., 2004); • Prunus mume (McKay et al., 2009; Moriwaki et al., 2003).
More than 19 families of plants are listed as hosts for Deroceras slugs. This mollusk can affect numerous plant species, including:
• Rapahnus sativus, • Brassica oleraceae, • Wasabia japonica, • Cucumis sp., • Cucurbita sp., • Allium sp., • Capsicum sp., • Solanum sp., • Lactuca sp., • Zingiber sp., • Fragaria sp. (NIHHS, n.d.), and • Panax sp. (Kim and Ohh, 1990).
B. Climate-Host Interaction
Studies suggest that D. smithi is a tropical/sub-tropical pest, unlikely to establish in most of the conterminous United States. These areas correspond to three Plant Hardiness Zones (9–11) in the United States (Magarey et al., 2008). Pseudococcus dendrobiorum is distributed over several subtropical and tropical countries, including India, Indonesia, Malaysia, Philippines, Sri Lanka, Thailand, South Korea (Asia); and Australia, Guam, Hawaiian Islands, and Papua New Guinea (Oceania) (Ben-Dov et al., 2001). These areas correspond to three Plant Hardiness Zones (9–11) in the United States (Magarey et al., 2008). The leafworm, S. litura, is widely distributed over several subtropical and tropical countries (EPPO, 1997b)
10 corresponding to Plant Hardiness Zones 7–11 (USDA, 1990; Magarey et al., 2008).
Thrips palmi (T. palmi) is subtropical to tropical in distribution. Populations in temperate climates are able to overwinter in greenhouses or other artificial situations because it cannot survive subzero temperatures for more than a few days (Lewis, 1997; Capinera, 2010). Based on this distribution, it is estimated that T. palmi could establish in the United States in U.S. Plant Hardiness Zones 9–11. One or more of its potential hosts occur in these zones (USDA, 1990; Magarey et al., 2008). The initial detections of C. boninense indicate an ability to survive in the climatic environments similar to those in the Eastern United States. Based on this distribution, it is estimated that C. boninense could establish in the United States in U.S. Plant Hardiness Zones 9–11. One or more of its potential hosts occur in these zones (USDA, 1990). It is likely that the mollusk D. varians is not very sensitive to cold unless it freezes; however, it is sensitive to drought. At temperatures just above freezing, it is already active and can, therefore, be seen all year round (CABI, 2011). This pest can establish in at least three Plant Hardiness Zones in the United States.
C. Threatened and Endangered Species
Given the lack of information available on D. smithi, it is very difficult to estimate with any certainty the impact it would have on listed species of orchids if introduced into the natural environment. Native orchid species are found throughout the United States, including several threatened and endangered species. In general, direct feeding by thrips, especially flower thrips, rarely leads to plant death, although it may lead to a reduction in the amount of quality of fruit produced by the plant. Most thrips considered to be serious pests cause damage by vectoring viruses or diseases; however, it is unknown if D. smithi is a vector of any plant viruses or diseases.
None of the genera within the host range of P. dendrobiorum include threatened and endangered species in the United States (50 CFR § 17.12, 2005). Hosts that could be affected by S. litura include endangered species in the genus Trifolium (50 CFR § 17.12, 2005).
Spodoptera litura is similar in biology and host range to army worms already present in the United States. It is, therefore, unlikely to increase the risk of these threatened or endangered species in the United States. Outbreaks in crops in the pest risk analysis area, however, would likely trigger increased chemical control programs similar to those now in effect for other caterpillars. This pest has the potential to attack plants listed as threatened or endangered in the United States (e.g., Allium munzii, Cucurbita okeechobeensis spp. 11 okeechobeensis, Helianthus paradoxus and H. schweinitzii). Its introduction would undoubtedly initiate control programs in areas of the United States to which it was newly introduced because it is a major pest of numerous economic crops (e.g., beans, peppers, and tomatoes). Similar programs have been considered in other countries, such as Japan (Hirose et al., 1993). Outbreaks in crops in the pest risk assessment area would likely trigger increased chemical control programs similar to those now in effect for other caterpillars. The mollusk D. varians may impact some protected species of the genera within its host range, specifically Cucurbita okeechobeensis. No listed species within the continental United States were identified as potential hosts for P. dendrobiorum.
IV. Environmental Impacts
A. No Action
There are no reports of invasiveness of Cymbidium and Phalaenopsis spp. orchids in the United States since bare-rooted importations have been allowed to enter the country. The importation of orchids into the United States has occurred for decades, and they are shipped to all known habitats. The PLANTS database (http://plants.usda.gov) and other weed reporting services do not include reports of imported boat or moth orchids as invasive or having weed potential.
Many plants that are classified as weeds have a suite of characteristics associated with colonization capabilities, some of which characterize orchids in general, including abundant seed production and distance dispersal. Most orchids do occur in frequently disturbed habitats, including pastures, roadsides, citrus groves, and coffee and tea farms (Ackerman, 2007). Reports of orchids as weeds include Oeceoclades maculata, which has recently naturalized in central and southern Florida (Pemberton et al, 2008). It is not known whether it escaped from cultivation or arrived in Florida via windblown seeds from the Greater Antilles or the nearby Bahaman Archipelago (FNA, 2003). Monadenia bracteata is a species in Australia that flowers more abundantly after fire (Bates, 1996). The introduced Epipactis helliborine is an orchid with few growth requirements and high environmental adaptability that grows as a weed across much of the Eastern United States (McCartney, 2010).
B. Preferred Alternative
Within the United States, nonindigenous species have had major impacts including degradation of wildlife habitat, decreased biological diversity, altered natural ecosystems, and negative effects on fishing
12 and water sports (OTA, 1993). There is concern that because the Republic of Korea is climatically similar to Florida and California, nonindigenous species imported with orchids from the Republic of Korea are more likely to become established in these areas. Many of these areas have already been heavily impacted by nonindigenous species, despite State and Federal efforts to prevent them. USDA APHIS currently allows the importation of bare root Phalaenopsis plants from Taiwan; however, no reports of escaped or naturalized orchids have been linked to the importation of orchids established in growing media.
Characteristics of weedy orchid species, such as limited growth requirements and high environmental adaptability, do not represent the basic biology of Cymbidium and Phalaenopsis spp., therefore, neither moth nor boat orchids are expected to become invasive. Invasive orchids share the following characteristics: quick development, self- pollination (autogamy), asexual reproduction through seeds (apomixis), wide ecological amplitudes, and broad natural distribution (Adamowski, 1999). Orchid species in the genera Cymbidium and Phalaenopsis do not share any of these characteristics. In addition, a screening performed by PPQ for the weed potential of both genera from Korea showed that these plants did not meet the criteria of a weed pest (APHIS, 2012a).
The climate that favors Phalaenopsis is replicated in greenhouses and indoor environments (not less than 65 °F, and either a humid atmosphere or unfailing moisture at the roots (Bailey and Bailey, 1976) within most of the continental United States, which creates environmental and spatial barriers to plant introduction into native ecosystems. Moth orchids are native to Asia, the Malay Archipelago, and Oceania (Bailey and Bailey, 1976). Although plants may be discarded, there is no evidence that these discards have the capacity to over-season out-of-doors outside of tropical and semi-tropical areas.
Moth orchids are epiphytes or rock-dwelling herbs (Bailey and Bailey, 1976). The physical environments that favor root growth are found in osmundia fiber and sphagnum moss (Bailey and Bailey, 1976) in pots (Griesbach, 2000). Moth orchids have light-intensity requirements (Konow and Wang, 2001; Wang, 1995) in addition to nutrition (Wang, 1998; Duan and Yazawa, 1995; Wang and Gregg, 1994) and mycorrhizal requirements (Clements, 1988). This means that a favorable combination of many factors is needed for moth orchids to grow. This contrasts with the habits of plants that tend to become problematic as invasive species (Mooney and Hobbs, 2000; Cox, 1999; Zimdahl, 1999; Devine, 1998; Radosevich et al., 1997). For these reasons, it is unlikely that Phalaenopsis species will become invasive in the future. 13
A climate that favors Cymbidium orchids mimics the temperate mountain regions of mid-Asia (native habitat for the genus) and Australia, with nighttime temperatures of 45 to 55 °F. The cycle of cool nights and warm days during the spring months in these regions is necessary for flower spike bud formation. Within the continental United States, these conditions can only be found at sea level in the coastal regions of California. Boat orchids prefer filtered light, but will tolerate extreme heat (above 100 °F) and cold (below 29 °F) for short periods (CSA, 2008). Cymbidiums, or boat orchids, must be rooted in a growing media which is free-draining and acidic. Currently, Cymbidium and terrestrial orchids are planted in the US as outdoor bedding plants in environments that are favorable to sustain growth and reproduction (Cymbidium Society of America, 2008).
Potential negative effects to listed members of the Orchidaceae are not expected because the host ranges for the quarantine pests do not overlap or are not within the same genus (congeneric) as Phalaenopsis. The listed species Isotria medeoloides occurs in many places within the continental United States, and is primarily threatened by loss of habitat (FWS, 1992). Similarly, the listed species Platanthera leucophaea occurs in colder climates, such as Iowa, Illinois, Indiana, Missouri, New York, Ohio, Pennsylvania, Oklahoma, Virginia, and Wisconsin (NatureServe, 2002). The taxonomically related P. praeclara also occurs in areas likely to be too cold for moth orchids, such as Iowa, Kansas, Minnesota, Missouri, Nebraska, North Dakota, and Oklahoma (NatureServe, 2002).
The listed species, Spiranthes diluvialis, which was originally known only to Colorado, Utah, and Nevada is now reported to also occur in Wyoming, Montana, Nebraska, Idaho, and Washington where the temperatures are likely to support Cymbidium and Phalaenopsis, though S. diluvialis grows in lower-elevation wet meadow habitats (NatureServe, 2002). In contrast, the listed species Spiranthes delitescens occurs in Arizona (NatureServe, 2002), where the climate is likely to be too dry for moth or boat orchids to survive out-of-doors (Bailey and Bailey, 1976). Spiranthes parksii is reported as variable and robust, exhibiting hybrid vigor because it is believed to be either a polyploid member of the S. cernua complex or it is a nonpersisting hybrid of S. lacera var. gracilis and S. cernua (NatureServe, 2002). It occurs in open, grassy woodland sites in Texas that are likely to be exposed to heavy cattle grazing (NatureServe, 2002). The soil types that support grassy woodlands are unlikely to be able to provide the physical and nutritional requirements of moth or boat orchids which are either epiphytes, semi-terrestrial, or less commonly, rock-dwelling herbs (Bailey and Bailey, 1976).
14
Several arthropod pests (D. smithi, P. dendrobiorum, S. litura, T. palmi), a mollusk (D. varians), and a fungus (C. boninense) were identified as quarantine pests likely to be imported with unmitigated shipments of Cymbidium and Phalaenopsis spp. orchids, possibly requiring phytosanitary measures to minimize risk. Outbreaks of D. varians within the continental United States would likely trigger increased control programs similar to those now used for other snails. Outbreaks of P. dendrobiorum in crops (citrus) within the continental United States would likely trigger the use of chemical control programs similar to those now in effect for other mealybugs.
1. Insects The thirp D. smithi has been reported in several countries including Asia, Australia, and one interception at a port in the Netherlands on a shipment from Thailand. There is no record of this species being intercepted at U.S. ports of entry, although specimens in the genus Dichromothrips that were not identified to the species level have been intercepted over 250 times since 1985 (APHIS, 2012a). D. smithi feeds exclusively on flowers in the orchid family. Damage caused by flower thrips can sometimes make flowers unmarketable, but there is already a variety of thrips known to attack and infest orchid flowers in the United States. P. dendrobiorum is distributed over several subtropical and tropical countries, and is reported to affect only plants that belong to the family Orchidaceae. Thirps palmi is subtropical to tropical in distribution, and cannot survive subzero temperatures for more than a few days. This thrips is known to occur in Asia; Africa; North, Central, and South America; and parts of the tropical Pacific. U.S. populations are restricted to American Samoa, southern Florida, Guam, Hawaii, and Puerto Rico (APHIS, 2012a).
Like many mealybugs, heavy infestations of thrips could cause dieback or death of host plants; however, outbreaks in other horticultural crops in addition orchids are not likely to occur due to its restricted host range.
Spodoptera litura (S. litura), a moth, is distributed over a number of U.S. trade cooperators that feature subtropical and tropical climates. The moth causes major damage to tobacco, cotton, chilies, cabbage, and other crops, and has a host range of at least 120 species (CPC, 2002). Most damage by S. litura is caused by larval foliar feeding, but larvae may also injure cotton bolls, and corn stalks and ears. This insect has high dispersal capability and potential for a high level of economic impact if it were to become established in the United States.
2. Mollusks The mollusk, Deroceras varians, has been reported in Japan and South Korea. Slugs from the genus Deroceras can affect numerous families, including Acanthaceae, Amarrillidaceae, Apiaceae, Araceae,
15 Araliaceae, Asteraceae, Brassicaceae, Commelinacerae, Cucurbitaceae, Fabaceae, Hippocastanaceae, Iridaceae, Lamiaceae, Orchidaceae, Rosaceae, Papaveraceae, Solanaceae, Vitaceae, and Zingiberaceae (APHIS, 2012a). D. reticulatum is extremely polyphagous and has been reported to attack a very broad range of crops if soil and climatic conditions are favorable (APHIS, 2012a). Human-assisted movement is the most effective means of long- distance dispersal for this slug. Plant parts that could carry eggs and juveniles of the mollusk are bulbs, tubers, corms, rhizomes, leaves, roots, stems (above-ground), shoots, trunks, and branches. Plant parts not known to carry the pest in trade or transport are growing media accompanying plants, flowers, inflorescences, cones, calyces, seedlings, micropropagated plants, true seeds, and wood (APHIS, 2012a). D. varians may alter the food chain in native ecosystems by providing an alternative food source for predators. This can have unfortunate consequences if the predator species is also invasive (APHIS, 2012a).
3. Fungus Initial detections of C. boninense in the Japanese Prefectures of Ibaraki, Kagawa, and Kagoshima and in the Kwanak Mountains, near Seoul, Korea indicate an ability to survive in climatic environments similar to those in the Eastern United States. From January 2009 until April 15, 2010, there were 12 interceptions of the fungus from foreign ports occurred on Ascocentrum, Cymbidium, Dracaena, Pachira, Paphiopedium, and Phalaenopsis species, indicating that plants are a pathway for long-distance dispersal (APHIS, 2012a). The fungus produces a high number of spores, but the methods of dispersal (wind and water-splash) facilitate limited, short-distance dispersal.
C. Risk Management
Although the affected environment and the environmental consequences under both the no action alternative and the proposed action alternative are the same, the risk management to prevent the introduction of pests differs between the two alternatives. The following section discusses the phytosanitary measures imposed under the current importation scheme of bare-rooted Cymbidium and Phalaenopsis spp. orchids (no action alternative) and the proposed phytosanitary measures for the import of these plants in growing media (preferred alternative).
1. No Action The phytosanitary measures of the no action alternative would leave 7 CFR part 319 unchanged. Currently, Cymbidium and Phalaenopsis spp., and other orchids, are imported as bare-rooted plants, growing on tree fern slabs, or in coconut husk or fiber (7 CFR § 319.37–8(d). All forms are enterable subject to inspection findings at designated ports of entry, that is, ports associated with facilities where propagative 16 material can be examined (plant inspection stations). All orchid consignments must be accompanied by a USDA permit and a phytosanitary certificate issued by NPQS. This document certifies that the orchids have been inspected and found free of quarantine pests before shipment to the United States. No special growing conditions are required for these plants. Cymbidium and Phalaenopsis spp. plants imported bare rooted generally do not have buds or flowers, and roots are not hidden from view within growing media; as such, visual inspection of these plants at the port of entry is effective.
Inspections of bare-rooted orchid consignments are conducted by PPQ personnel at a plant inspection station at the first port of entry in the United States. These stations are staffed with PPQ pest identification specialists, as well as PPQ officers, who carefully examine orchid consignments. Inspection and examination may be limited to a verification of the contents and a review of the documentation, or may consist of a standard inspection, including an inspection of at least 2 percent of the plants in the shipment. If quarantine pests are discovered on bare-rooted orchid consignments, appropriate phytosanitary measures are conducted (e.g., treatment, destruction, or return of consignments to exporting country).
2. Preferred This section describes the phytosanitary measures required if Alternative Cymbidium and Phalaenopsis spp. plants in approved growing media are imported into the continental United States from the Republic of Korea. Amendment of 7 CFR part 319, according to the proposed rule, would allow importation of Cymbidium and Phalaenopsis spp. moth orchids from the Republic of Korea rooted in approved growing media, provided the orchids were produced, handled, and imported in accordance with the requirements of 7 CFR § 319.37–8(e), and are accompanied at the time of importation by a phytosanitary certificate issued by NPQS declaring that those requirements have been met.
Systems Approach
To effectively prevent the introduction of plant pests associated with plants grown in approved media, a series of important safeguards, (phytosanitary measures) must be in place. The risk management program used for plants in media is the systems approach—a defined set of phytosanitary procedures, at least two of which have an independent effect in mitigating pest risk associated with the movement of commodities. This approach relies on a series of phytosanitary measures that, individually and cumulatively, reduce the pest risk posed by pests that may be associated with plants. All phases associated with plants established in growing media—before planting, during the growing period, postharvest, during transport, and importation—are considered. 17
The APHIS regulation on plants in media requires multiple phytosanitary measures designed to reduce the pest risk. The overall systems approach operates like as a fail-safe system in that tiered safeguards are built into the process. That is, if one mitigating measure fails, other safeguards exist to ensure that the risk is progressively reduced and managed. The systems approach is designed to apply all the measures to obtain the maximum risk reduction and to apply additional safeguards, as required. The steps or measures may overlap or be redundant to ensure an adequate reduction in pest risk, and that the reduction of risk is maintained during the entire process. These measures would be applied to the importation of Cymbidium and Phalaenopsis spp. orchids from the Republic of Korea in approved growing media.
a. Approved Plant Sources
The orchids imported into the United States will be greenhouse- or laboratory-propagated plants, or may be propagated in the laboratory from aseptic tissue culture. Wild or collected specimens and nondomesticated plants are not approved for importation into the United States. The plants must come from pest-free mother stock, as determined by a PPQ or an NPQS inspector, no more than 60 days prior to the time the plants are established in the greenhouse. b. Approved Growing Media
Plants offered for importation into the United States must be free of sand, soil, earth, and other unapproved growing media. This requirement helps prevent the introduction of plant pests that might be present in and around the roots, and also eliminates many soil- and root-associated saprophytic organisms. Exceptions to the growing media requirement reflect additional factors that mitigate plant pest risk. Those exceptions consider either the origin of the plants and the growing media (7 CFR § 319.37–8(b)), the nature of the growing media (§§ 319.37–8(c), (d)), or the use of a combination of growing conditions, approved media, inspections, and other requirements (§ 319.37–8(e)). Soil-less and new, unused growing media eliminate an initial source for pests, including D. smithi, T. palmi, S. litura, P. dendrobiorum, C. boninense, and D. varians. Studies on APHIS- approved growing media found that pathogens are not present (Santacroce, 1991). c. Agreements
The orchids must be grown in accordance with written enforcement agreements between APHIS, NPQS, and Korean growers. This will
18 include the preparation of an operational work plan that outlines specific detection and eradication protocols to detect and eliminate problem pests before the orchids are exported to the United States. The work plan also outlines how the program will be monitored and supervised to ensure compliance. Korean orchid growers who plan to export moth and/or boat orchids in growing media must be registered with NPQS; any grower not in compliance with the work plan requirements will be eliminated from the program. d. Exclusionary Greenhouse
The orchids for shipment must be grown in a pest exclusionary greenhouse using the following phytosanitary measures: “Grown solely in a greenhouse in which sanitary procedures are adequate to exclude plant pests and diseases are always employed, including cleaning and disinfection of floors, benches, and tools, and the application of measures to protect against any injurious plant diseases, and injurious insect pests, and other plant pests” (7 CFR § 319.37– 8(e)(2)(ii)). These measures may include trapping, surveying, and scouting to determine if pests are present, and pesticide applications or other control measures to eliminate pests that are discovered. e. Raised Benches
The height of the benches on which the orchids are grown must be at least 46 cm above the floor. Raised benches reduce the chance of water being splashed onto benches from the floors that might be contaminated with nematodes, pathogens, and weed seeds. Also, because snails and slugs have the capability to climb up sidings and posts, higher benches make it more difficult for snails and slugs to climb and decrease the chances that such pests will invade the plants and media. The benches must be supported by legs that have copper plates wrapped around each leg, or an equivalent means of preventing mollusk infestation. f. Floors
Greenhouse floors must be completely void of soil. They must be composed of permanent material that can be cleaned and sanitized to destroy pathogens and nematodes, and to prevent establishment of weeds. g. Automatic Doors
Automatic closing doors are required to exclude flying insects from entering the growing area. They are also used, to a limited extent, to keep windborne pests from being blown into the growing area and
19 provide a physical barrier that reduces the exposure of the plants to splashing by rain and irrigation water (Agrios, 1997).
h. Screens
Greenhouses have vents or openings principally for the exchange of outside air and for temperature control. The addition of screens to these openings lowers the risk of certain pests entering the greenhouse. Screens must have openings no larger than 0.6 mm. Screens with 0.6 mm openings do not exclude all pests; however, they will act as a deterrent or barrier to many pests, including S. litura, D. varians, and C. boninense.
i. Sanitation
Sanitary procedures must be used to maintain the greenhouse relatively free of pests. A suitable disinfectant should be employed to sanitize the greenhouse interior prior to plantings to reduce pathogens, nematodes, and other pests. These procedures should also include keeping tools, hoses, benches, floors, work areas, and floor benches clean and properly sanitized. The grower should maintain a record of the number of times disinfection takes place.
j. Detention Periods
Plant materials are commonly detained to allow time for certain pests to develop and become visible and detectable. Mother stock orchids must be grown in the Republic of Korea for at least 9 months prior to export of descendant orchids to the United States. Mother plants imported into the Republic of Korea from another country must be grown at least 12 months in the Republic of Korea prior to the export of descendant orchids to the United States. The growing period can be reduced to 9 months, as above, provided there is a prescribed treatment of the mother stock upon importation of that plant into the Republic of Korea. Descendant plants in media must be rooted and grown in an active state of foliar growth for at least 4 consecutive months prior to export. Detention periods are necessary to allow ample time for the expression of disease, symptoms, and other signs of pests.
k. Clean Water Sources
The water source for plant watering must be either rainwater that has been boiled or pasteurized, clean well water, or potable water. Water is considered one of the principal means for the dispersal of plant pests, including pathogens and mollusks; water from clean sources must be used to ensure that phytosanitary measures are effective.
20 l. Phytosanitary Certificate
A phytosanitary certificate must be issued by NPQS. This document must accompany the plants during importation and certify that the required growing conditions were met. m. Inspection
Inspections are an integral phytosanitary measure to reduce pest risk. In growing areas in the Republic of Korea, inspection of Cymbidium and Phalaenopsis spp. orchids in growing media is primarily the responsibility of NPQS. Whenever pests of quarantine significance are found during inspection, appropriate action must be taken promptly, as outlined in the operational work plan.
Mother stock must be inspected by a PPQ or an NPQS inspector and found free of evidence of diseases and insect pests. The rationale is to inspect the mother stock in advance of any movement to ensure a pest- free source of plant material used for descendant plants. Inspection must take place no more than 60 days prior to the time the article is established in the greenhouse. Inspection of mother stock is a primary measure to prevent the introduction of pests such as mollusks, insects, and pathogens into greenhouse crops.
For descendant plants, an inspection must be performed no more than 30 days prior to the date of export, and must be done on the premises or site where the orchids are grown to prevent contaminants and hitchhikers from entering the shipment. Because the roots cannot be visually examined while in growing media, a small number of plants will be randomly inspected and removed from the media to examine the roots and the inside of the media ball.
PPQ inspectors will visit the Republic of Korea periodically to ensure the program is working adequately, including review of treatment and control records generated by registered Korean growers.
At the port of entry in the United States, inspection of orchid consignments will be conducted by PPQ at plant inspection stations. These stations are staffed with PPQ pest identification specialists, as well as PPQ officers, who will carefully examine orchid consignments. Generally, initial consignments from a newly approved importation program (e.g., orchids in APHIS-approved growing media) are subjected to extremely rigorous inspections that include the removal of plants from pots to examine roots and growing media. Once the program becomes established, the inspection and examination may be limited to a verification of the contents and a review of the documentation or the inspection may consist of a standard inspection
21 of at least 2 percent of the plants in the consignment, including roots and growing media. Standard inspection techniques are highly likely to detect larger mature and juvenile forms of the mollusk, D. varians, present on plants. Small eggs in soil are highly likely to escape detection; however, plants produced in APHIS-approved growing media under pest-exclusionary conditions are expected to be free of mollusk eggs.
Standard visual inspection techniques are not likely to detect microscopic crawler stages of the mealybug, P. dendrobiorum, because they live on the roots of orchids. However, early instars on foliage can be detected by the presence of chlorophyll-free, whitish leaves. Late-instar larvae can be readily detected by their contrasting reddish brown color against green leaves; they feed on the entire leaf, leaving only the main veins, which can easily be detected during inspection.
Because thrips are small, D. smithi can hide in plant parts and can be difficult to detect by visual inspection alone. However, plant material can be carefully examined for signs of infestation, such as scars, deformities, and discoloration. The characteristic symptom of D. smithi on orchids is their failure to bloom, due to the damage to the young shoots of flowers. T. palmi, another thrips species, attacks the stem, particularly at or near the growing tip, and are also found amongst the petals and developing ovaries in flowers and on the surface of fruit. They leave numerous scars and deformities.
The adult stage of the moth S. litura is 15–20 mm long with a wingspan of 30–38 mm, and is easily detected upon inspection. Newly hatched larvae can be detected by the “scratch” marks left on the leaf surface. Larvae are defoliators, which feed extensively on plants and produce visible leaf damage. Older larvae are night feeders and can be found in the soil around the base of the plants during the day.
The fungus C. boninense may cause lesions on leaves, stems, and/or fruit, often leading to dieback and reduction of plant or fruit quality. Therefore, plants must be carefully inspected for symptoms of anthracnose disease, characterized by small areas of dead tissue.
In order to protect against the introduction and spread of invasive plant pests and diseases, APHIS has established a risk-based sampling protocol for inspecting Cymbidium and Phalaenopsis spp. from Korea at its plant inspection stations, prior to entry into the United States. In accordance with procedures directed by APHIS Agricultural Quarantine Inspection Monitoring (AQIM) protocol, if the frequency of interceptions of a quarantine pest surpasses the level specified in the
22 risk-based sampling protocol, PPQ will require more specific mitigation against the pest(s) of concern. APHIS-inspected, --approved, and -registered greenhouses in the Republic of Korea will identify specific problem greenhouses or growers. In addition, if quarantine pests are discovered on moth orchid consignments at the port of entry, appropriate phytosanitary measures will be conducted (e.g., treatment, destruction, or return of consignment to exporting country). n. Packing and Storing
Plants for export must be packed and stored in areas free of sand, soil, and plant pests. This will prevent contamination and the introduction of hitchhikers. Cymbidium and Phalaenopsis spp. plants shall not be packed in the same container as prohibited articles.
Conclusions
APHIS has determined that quarantine pests associated with growing media are effectively removed from the pathway, and effectively precluded from establishment in the continental United States by the mitigation measures already present in the applicable regulations. The pest risk assessment has determined that importation of boat and moth orchids (Cymbidium and Phalaenopsis spp.) from the Republic of Korea, under the conditions required by 7 CFR § 319.37–8(e), pose no greater pest risks than the risks presented by other epiphytic orchid material currently allowed entry as bare-rooted plants. The same pests identified in the pest risk assessment that may be imported with orchids in growing media may also be imported with consignments of bare-rooted orchids currently being imported into the United States. The risk assessment concluded that application of additional safeguards will reduce the risk posed by the importation of Cymbidium and Phalaenopsis spp. boat and moth orchids in approved growing media to a level similar to that posed by currently permitted bare- rooted importations (APHIS, 2012b).
If quarantine pests accompanying Cymbidium and Phalaenopsis spp. shipments were to become established in the United States, an eradication program would likely be initiated. Although eradication of any nonindigenous pest would require the use of pesticides, APHIS would prepare the necessary environmental documentation under NEPA and the Endangered Species Act (ESA) in advance of any eradication activities.
23 D. Endangered Species Act
Section 7 of the Endangered Species Act (ESA) and the ESA’s implementing regulations require Federal agencies to consult with the U.S. Fish and Wildlife Service (FWS) and/or the National Marine Fisheries Service to ensure that their actions are not likely to jeopardize the continued existence of threatened or endangered species or result in the destruction or adverse modification of critical habitat.
APHIS submitted a biological assessment (BA) to FWS, Arlington, Virginia, in compliance with Section 7 of the ESA. APHIS has determined that the proposed action may affect, but is not likely to adversely affect federally listed plants in the continental United States, including Yadon’s piperia and its critical habitat, small-whorled pogonia, eastern prairie fringed orchid, western prairie fringed orchid, Canelo Hills ladies’-tresses, Ute ladies’-tresses, Navasota ladies’- tresses, Munz’s onion and its critical habitat, Pecos sunflower and its critical habitat, Schweinitz's sunflower, running buffalo clover, Okeechobee gourd, Monterey clover, and showy Indian clover. APHIS received a concurrence letter on July 11, 2014 confirming these determinations. (APHIS/FWS/AWS/DER/BCH/057839 FWS2014-I-003).
E. Other Considerations
Executive Orders
Executive Order (EO) 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," focuses Federal attention on the environmental and human health conditions of minority and low-income communities, and promotes community access to public information and public participation in matters relating to human health or the environment. This EO requires Federal agencies to conduct their programs, policies, and activities that substantially affect human health or the environment in a manner so as not to exclude persons and populations from participation in or benefitting from such programs. It also enforces existing statutes to prevent minority and low-income communities from being subjected to disproportionately high and adverse human health or environmental effects. Neither alternative poses disproportionately high or adverse human health or environmental effects to any specific minority or low-income group.
EO 13045, “Protection of Children from Environmental Health Risks and Safety Risks,” acknowledges that children may suffer disproportionately from environmental health and safety risks because of their developmental stage, greater metabolic activity levels, and 24 behavior patterns as compared to adults. The EO, (to the extent permitted by law and appropriate, and consistent with the agency’s mission) requires each Federal agency to consider environmental health risks and safety risks that may disproportionately affect children. Neither alternative is expected to have disproportionately high or adverse human health or environmental effects to children.
V. Listing of Agencies Consulted
Environmental and Risk Analysis Services Policy and Program Development Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 149 Riverdale, MD 20737–1238
Phytosanitary Issues Management Plant Protection and Quarantine Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 140 Riverdale, MD 20737–1228
Regulatory Coordination Plant Protection and Quarantine Animal and Plant Health Inspection Service U.S. Department of Agriculture 4700 River Road, Unit 141 Riverdale, MD 20737–1228
U.S. Fish and Wildlife Service Ecological Services Division of Environmental Review Washington, D.C. 20240
25 VI. References
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APHIS—See U.S. Department of Agriculture, Animal and Plant Health Inspection Service
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27
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