Euphytica (2006) 148: 165Ð183 DOI: 10.1007/s10681-006-5950-8 C Springer 2006

A pest risk assessment for Copitarsia spp., associated with importation of commodities into the United States

Robert C. Venette1,3,∗ & Juli R. Gould2 1Department of Entomology and Midwest Ecological Risk Assessment Center,University of Minnesota, 1980 Folwell Avenue, 219 Hodson Hall, St. Paul, MN 55108, USA; 2Survey Detection and Eradication Laboratory, USDA-APHIS, Building 1398, OTIS Air National Guard Base, Cape Cod, MA 02542-5008, USA; 3Current address: USDA Forest Service, 1561 Lindig Street, St. Paul, MN 55108, USA (∗author for correspondance: e-mails: [email protected]; [email protected])

Key words: Copitarsia, exotic species, international trade, pathway analysis, phytosanitary security, risk assessment

Summary Eggs and larvae of Copitarsia spp. (: ) are frequently intercepted on fresh commodities arriving in the United States from Mexico, Central America, and South America. Copitarsia spp. are not known to occur in the US and, thus, are considered actionable pests by the US Department of Agriculture, and Plant Health Inspection Service (USDA, APHIS). Whenever the is detected in imported goods, shipments must be disinfested, destroyed, or returned to the country of origin. Inspections and interdictions might be unnecessary if Copitarsia spp. were unlikely to establish in the US or if consequences of Copitarsia establishment were trivial. Consequently, we prepared a qualitative pest risk assessment to characterize the degree of risk posed by the genus to US agricultural and natural ecosystems. Published literature was consulted to describe the biology and ecology of the genus. Trade statistics and interception records were summarized to identify pathways of introduction. With this information, experts assigned risk ratings to each of eleven elements identified by USDA, APHIS that pertained to the likelihood or consequence of exotic-pest establishment. The likelihood of Copitarsia spp. becoming established in the US was considered high, but confidence in this assessment was low. Similarly, consequences of Copitarsia establishment were rated high, but confidence in this assessment was moderate. Overall, the assessment revealed that Copitarsia pose a high degree of risk to the US and phytosanitary measures to exclude the pest seem warranted. However, additional research is needed to address critical data gaps and refine assessments of risk for individual species within the genus.

Introduction and ecosystem processes (Kiritani, 1999; Mack et al., 2000). For example, in a recent review, Reitz and The potential impact of exotic on natural Trumble (2002) found that 78% of the cases of compet- and agricultural ecosystems is now widely recognized. itive displacement of established arthropods involved More than 2000 species of non-indigenous arthropods the introduction of an exotic species. Safeguarding the occur in the US (OTA, 1993). Of these species, approx- US from the establishment of non-indigenous pests is imately 1000 are pests of crops and roughly 120 are now considered a vital component of ensuring an inex- serious pests of forests (Pimentel et al., 2000). Non- pensive food supply and preserving natural resources indigenous pests typically cause US$ 500 million in (National Plant Board, 1999). control costs and US$ 16 billion in losses and dam- The US Department of Agriculture, Animal and age per year (Pimentel et al., 2000). Alien species are Plant Health Inspection Service (USDA, APHIS) plays also considered a general threat to species diversity a pivotal role in the exclusion of exotic pests from the 166

US, particularly pests of plants and that are paper does provide a case study for qualitative risk transported through commerce and travel (Mack et al., assessments that are intended to characterize risk suf- 2002). However, the task of excluding exotic pests is ficiently to inform a decision-making process (Mack especially daunting when one considers the number of et al., 2002). Qualitative approaches to pest risk as- species that USDA, APHIS is attempting to keep out of sessment are particularly useful when biological infor- the country. APHIS has reported n = 609,303 intercep- mation about a pest is itself qualitative. The principles tions of n = 4,222 taxa of insects from 1985 to 2001 upon which this risk assessment is built apply not only (USDA, Port Information Network [PIN] database), to non-indigenous arthropods but also to exotic verte- and insects only represent 60Ð65% of all interceptions brates, pathogens, and plants. (Mack et al., 2002). Not all of these taxa are likely to pose the same degree of economic or environmental risk. In this context, risk is defined as the probability Description of the genus of an exotic pest becoming established weighted by the consequences of pest establishment (Mack et al., 2002; Orr et al., 1993). By understanding the risks associated with particular species, APHIS can more efficiently Copitarsia spp. occur within the subfamily Cu- utilize limited resources to exclude pests that pose the culliinae (Lepidoptera: Noctuidae). Systematics and greatest threat to the US (National Plant Board, 1999). nomenclature within this genus are particularly Risk assessment can provide a valuable tool to evaluate problematic (Poole, 1989). Over time, the genus has which pests are most threatening. included from six to eleven species, depending on Noctuid in the genus Copitarsia are fre- which taxonomic authority is consulted (Castillo & quently intercepted at US border ports on produce Angulo, 1991; Hampson, 1906; K¬ohler, 1959; Poole, and cut flowers from Mexico, Central America, and 1989). Currently-described species include: C. anguloi South America (Hunter & Elliott, 1995; Hunter & Sim- Castillo and Angulo, C. basilinea K¬ohler, C. clavata mons, 1995). During an inspection, APHIS officers typ- (K¬ohler), C. editae Angulo and Jana-Saenz, C. humilis ically encounter the genus as eggs or larvae. Copitarsia (Blanchard), C. incommoda (Walker) (=C. consueta spp. are considered quarantine pests because members Walker), C. naenoides (Butler), C. paraturbata Castillo of the genus are not known to occur in the US and and Angulo, C. patagonica Hampson, C. purilinea are of potential economic significance (FAO, 2002). (Mabille), and C. decolora (Guen«ee) (=C. turbata If Copitarsia spp. are found in a shipment, the com- (Herrich-Sch¬affer)). Of these only C. humilis, C. in- modity must be treated, destroyed, or returned to the commoda, C. naenoides, and C. decolora have been country of origin (USDA APHIS, 1999). Inspection reported as pests in the literature. Recently, the validity and interdiction would be unnecessary if Copitarsia of the eleven names has come into question; moreover, spp. were unlikely to become established in the US or because Copitarsia spp. have not been examined with cause significant economic or ecological damage. Al- modern phylogenetic techniques, these names may rep- though risks associated with Copitarsia spp. have been resent geographic variants of one or two species (R. addressed in documents related to international trade Simmons, personal communication). (Cave & Redmond, 1997a,b; USDA, APHIS, 1997), Our assessment focuses on the genus as a whole, the risks posed by the genus have not been assessed in rather than an individual species. Since taxonomy depth. within the genus Copitarsia is poor, pest reports or The objectives of this study were to: (a) analyze biological studies cannot be assigned reliably to any trade and interception records to identify pathways for one species. Adult Copitarsia spp. have few external introduction of Copitarsia spp.; (b) describe pertinent characteristics to distinguish them from other noctuid aspects of the ecology of Copitarsia spp. to evaluate moths and can only be identified with confidence by the likelihood of the genus becoming established in genitalia dissections. Simmons and Pogue (2004) pro- the US and causing adverse economic or environmen- vide morphological descriptions for representatives of tal impacts; and, (c) identify critical data gaps about the genus. At times, members of Copitarsia have been Copitarsia spp. that could substantially impact the risk confused with the genera Agrotis, Euxoa, Polia, and assessment. This study was not intended to evaluate the Orthosia, presenting the possibility that undescribed relative risks associated with each pathway by which species of Copitarsia are currently misnamed within Copitarsia spp could arrive in the United States. This these genera (Gould et al., 2000). Copitarsia larvae 167 can be distinguished from other genera based on exter- intercepted by USDA, APHIS on commodities shipped nal characteristics. For example, Copitarsia larvae have from several countries known to have Copitarsia spp. dark bars at the base of the two medial setae, white dor- and from Belize, Brazil, Dominican Republic, El Sal- sal setae, misaligned head setae (dorsal ventrally), and vador, Haiti, Honduras, Jamaica, Nicaragua, Panama, two dark triangles on posterior abdominal segments St. Lucia and Trinidad and Tobago (Table 1; USDA, (Riley, 1998). Because rearing studies are limited, iden- PIN). The true origin of these commodities is not tification of species from larval specimens is not yet known. However, such information suggests that the possible (R Simmons, personal communication). range of Copitarsia extends from central Mexico to southern South America and may include several Caribbean nations. Populations of the genus have not Bionomics been reported in the United States. Copitarsia spp. begin life as eggs, deposited singly Copitarsia spp. can be found along the western edge of (Lopez-Avila, 1996a) or in egg masses (Velasquez, South and Central America from the southern tip of Ar- 1988), depending on species. A single female may pro- gentina through central Mexico (Figure 1). Copitarsia duce between 570 and 1640 eggs, depending on the spp. have been reported in the literature from all coun- quality of the environment and host (Arce de Hamity tries south of the United States except Belize, Brazil, & Neder de Roman, 1992; Larrain S., 1996; Rojas & El Salvador, French Guiana, Honduras, Nicaragua, Cibrian-Tovar, 1994; Velasquez, 1988). Larvae com- Panama, Paraguay, Suriname, Uruguay, and the islands plete five to six instars during development (Arce de of the Caribbean. Nevertheless, the genus has been Hamity & Neder de Roman, 1993;Lopez-Avila, 1996a)

Figure 1. Distribution of Copitarsia spp. in the Americas. Circles and municipalities are depicted in gray. Hatch marks designate reported origins of commodities infested with Copitarsia spp. 168

Table 1. Country of origin of com- Liberman Cruz, 1986), although Hichins and Men- modities in which Copitarsia spp. doza (1976) report only one generation per year were intercepted by USDA, APHIS for C. humilis on alfalfa (Medicago sativa L.) in Origin Interceptions Chile. Larvae of Copitarsia spp. are polyphagous. Thirty Colombia 4054 nine crop plants are listed as hosts in the published Mexico 2166 literature (Table 2), and the genus has been found at Ecuador 524 US ports of entry on several additional plant species Guatemala 241 not reported in the literature (Table 3). Collectively, Chile 195 these plants represent more than 19 families. Most Costa Rica 91 of the crops listed as hosts of Coptarsia spp. are Peru 74 also commonly grown in the US. Within its cur- Venezuela 30 rent range, Copitarsia spp. cause damage by reduc- Dominican Republic 11 ing yields or marketability of crops (Arce de Hamity Unknown 9 & Neder de Roman, 1992; Artigas & Angulo, 1973; Arestegui, 1976; Cortes et al., 1972; Lamborot et al., Honduras 8 1999; Larrain, 1984, 1996; Liberman Cruz, 1986; Jamaica 5 Lopez-Avila, 1996a; Machuca et al., 1990; Monge The Netherlands 5 et al., 1984; Quiroga et al., 1989; Sanchez & Aldana, Bolivia 4 1985; Sanchez & Maita-Franco, 1987; Velasquez, Panama 4 1988; Vimos et al., 1998). Information on the extent El Salvador 3 of damage is scarce, but Copitarsia spp. have been Argentina 2 reported to reduce marketability of artichoke heads by Brazil 2 24% (Larrain, 1984) to 54% (Machuca et al., 1990). Belize 1 Copitarsia spp. may reduce quinoa yields by 80Ð90% Haiti 1 if no pesticides are applied (Liberman Cruz, 1986). Japan 1 A large number of natural enemies attack Nicaragua 1 Copitarsia spp. Members of the genus are susceptible to microbial pathogens such as , St. Lucia 1 Bacillus thuringiensis Beauveria bassiana, and Entomophthora sphaeros- Trinidad and Tobago 1 perma (Aruta et al., 1974; Lopez-Avila, 1996a). Larvae of the genus are parasitized by at least 13 taxa of tachinid parasitoids, such as Archytas scutella- and reach a length of ≈2Ð4 cm (Arce de Hamity & tus, Incamyia chilensis, Prosopochaeta setosa, and Neder de Roman, 1993). Later-instars are typically Winthemia spp. (Alcala, 1978; Cortes, 1976; Lamborot green but can also be black or gray (Arce de Hamity & et al., 1995; Leyva & Sanchez, 1993; Sanchez & Neder de Roman, 1993; Lopez-Avila, 1996a). Develop- Maita-Franco, 1987). Eggs and larvae are attacked ment time from egg to adult depends on many factors by another 11 parasitoid taxa in Aphelinidae (e.g., including temperature, humidity, and host. Reported Encarsia portreri), Braconidae (e.g., Apanteles spp.), larval development times vary from approximately Ichneumonidae (e.g., Netelia gerlingi, Thymebatis spp) 43 days at 24.5 ◦C on lettuce (Lactuca sativa L.) to and Trichogrammatidae (e.g., Trichogramma minu- 82.5 days at 20.4 ◦C on artificial diet (Arce de Hamity tum) (Lamborot et al., 1995; Leyva & Sanchez, 1993; & Neder de Roman, 1992; Lopez-Avila, 1996a; Ve- Loo & Aguilera, 1983; Lopez-Avila, 1996a; Machuca lasquez Z., 1988). Larvae generally feed externally on et al., 1989; Porter, 1980; Sanchez & Maita-Franco, leaves, stems, and fruits of host plants but will occa- 1987). Collectively, natural enemies may suppress sionally bore into thicker non-woody tissues (J.R.G., populations of Copitarsia spp., as outbreaks of the personal observation). Pupation occurs in the soil. pest have been associated with changes in agricultural Diapause has not been reported for any members of practices, particularly the use of pesticides (Artigas the genus. In general, Copitarsia spp. appear to have & Angulo, 1973; Cortes, 1976; Cortes et al., 1972; two to four generations per year (Arce de Hamity Liberman Cruz, 1986; Machuca et al., 1989; Monge & Neder de Roman, 1992; Artigas & Angulo, 1973; et al., 1984). 169

Table 2. Commercial horticultural or agronomic crops which are suitable host plants for Copitarsia spp. insects

Spanish (English) Family/Scientific name common name Reference(s)

Actinidiaceae Actinidia chinensis Kiwi (Kiwi) (Larrain, S., 1996) Anacardiaceae Pistacia spp. Pistacho (Pistacio) (Larrain, S., 1996) Apiaceae Coriandrum sativum Cilantro (Coriander) (Riley, 1998) Daucus carota subsp. sativus Zanahoria (Carrot) (Neder de Roman & Arce de Hamity, 1991; Arce de Hamity & Neder de Roman, 1992) Asteraceae Calendula spp. Maravilla (Calendula) (Larrain, S., 1996) Cynara scolymus Alcachofa (Artichoke) (Larrain, S., 1984; Machuca, L. et al., 1988, 1989, 1990, Castillo & Angulo, 1991; Larrain, S. & Araya, C., 1994; Larrain, S., 1996) Helianthus annuus Girasol (Sunflower) (Angulo Weigert, 1975b) Lactuca spp. lechuga (lettuce) (Neder de Roman & Arce de Hamity, 1991; Arce de Hamity & Neder de Roman, 1992) Basellaceae Ullucus tuberosus Melloco, Olluco, Ulluma, (Vimos, N. et al., 1998) Chuguas (Ulluco) Brassicaceae Brassica napus Raps (Rapeseed) (Artigas & Angulo, 1973; Castillo & Angulo, 1991; Larrain; S., 1996) Brassica oleracea Repollo (Cabbage) (Carrillo, S., 1971; Aruta et al., 1974; Monge, V. et al., 1984; Grez, 1992; Rojas et al., 1993; Larrain S., 1996; Castrejon G. et al., 1998) Brassica oleracea botrytis coliflor (cauliflower) (Rojas et al., 1993; Castrejon G. et al., 1998) Brassica oleraceae broccoli (broccoli) (Rojas et al., 1993; Castrejon G. et al., 1998) Buxaceae Simmondsia californica jojoba (jojoba) (Quiroga et al., 1989; Castillo & Angulo, 1991; Larrain S., 1996) Caryophyllaceae Dianthus caryophyllus clavel (carnation) (Castillo & Angulo, 1991) Chenopodiaceae Beta vulgaris remolacha, betabel (beet) (Angulo & Weigert, 1975; Castillo & Angulo, 1991; Neder de Roman & Arce de Hamity, 1991; Arce de Hamity & Neder de Roman, 1992; Rojas et al., 1993; Larrain S., 1996) Beta vulgaris ssp. cicla acelga (chard) (Rojas et al., 1993, Lamborot et al., 1995) Chenopodium quinoa quinoa, quinua (quinoa) (Angulo & Weigert, 1975; Liberman Cruz, 1986; Castillo & Angulo, 1991; Lamborot et al., 1999) Spinacia oleracea espinaca (spinach) (Castillo & Angulo, 1991; Rojas et al., 1993) Fabaceae Vicia faba habas (broad or lima bean) (Gomez T., 1972; Neder de Roman & Arce de Hamity, 1991; Arce de Hamity & Neder de Roman, 1992; Lamborot et al., 1995) Cicer arietinum garbanzo (chick pea) (Larrain S., 1996) Medicago saliva alfalfa (alfalfa) (Hichins O. & Rabinovich, 1974; Angulo & Weigert, 1975; Cortes, 1976; Hichins O. & Mendoza M., 1976; Porter, 1980; Castillo & Angulo, 1991; Arce de Hamity & Neder de Roman, 1992; 1993, Rojas et al., 1993; Apablaza & Stevenson, 1995; Larrain S., 1996) Pisum spp. arverjas, chicaro (peas) (Rojas et al., 1993; Lamborot et al., 1995) Trifolium pratense tr«ebol (clover) (Castillo & Angulo, 1991) Iridaceae Gladiolus spp. galdiolo (gladiolus) (Riley, 1998)

(Continued on next page) 170

Table 2. (Continued)

Spanish (English) Family/scientific name common name Reference(s)

Lamiaceae Lolium multiflorium Ballica (Ryegrass) (Angulo & Weigert, 1975; Castillo & Angulo, 1991) Rosmarinus officinalis Romerito (Rosemary) (Rojas et al., 1993) Liliaceae Allium cepa Cebolla (Onion) (Quiroz, E., 1977; Castillo & Angulo, 1991; Lamborot, et al., 1995; Larrain, S., 1996; Lopez-Avila, 1996b; Castrejon, G. et al., 1998) Allium sativum Ajo (Garlic) (Larrain, S., 1996; Lopez-Avila, 1996b) Asparagus officinalis Esp«arragos (Asparagus) (Castillo & Angulo, 1991; Larrain, S., 1996) Linum usitatissimum Lino (Flax) (Wille, T., 1943; Angulo & Weigert, 1975; Castillo & Angulo, 1991) Poaceae Triticum aestivum Trigo (Wheat) (Larrain S., 1996) Zea mays Ma«õz (Corn or Maize) (Castillo & Angulo, 1991; Olivares & Angulo, 1995; Larrain, S., 1996) Polygonaceae Polygonum segetum Malezas (Field Smartweed) (Zenner de Polenia, 1990; Castillo & Angulo, 1991) Rosaceae Fragaria chiloensis Frutilla (Strawberry) (Castillo & Angulo, 1991; Larrain, S., 1996) Malus sp. Manzana (Apple) (Larrain S., 1996) Rubus idaeus Frambuesa (Raspberry) (Castillo & Angulo, 1991; Larrain, S., 1996) Solanaceae Capsicum sp. Pimiento Verde (Bell Pepper) (Riley, 1998) Lycopersicon esculentum Tomate (Tomato) (Lamborot, et al., 1995; Larrain, S., 1996) Nicotiana tabacum Tobacco (Tobacco) (Angulo & Weigert, 1975; Castillo & Angulo, 1991; Larrain S., 1996) Physalis pubescens Tomatillo (Husk Tomato) (Riley, 1998) Solanum melongena Berenjena (Eggplant) (Lamborot, et al., 1995) Solanum tuberosum Papa (Potato) (Munro, 1968; Angulo & Weigert, 1975; Arestegui P., 1976; Loo P. & Aguilera P., 1983; Sanchez V. & Maita-Franco, 1987; Zenner de Polenia, 1990; Castillo & Angulo, 1991; Arce de Hamity & Neder de Roman, 1992; Leyva O. & Sanchez V., 1993; Rojas et al., 1993; Olivares & Angulo, 1995; Larrain, S., 1996; Lopez-Avila, 1996a) Vitaceae Vitis spp., Vitis vinifera uva, vid (Grape) (Castillo & Angulo, 1991; Larrain, S., 1996)

Materials and methods combined for analysis. Since interception reports are not based on random sampling nor are sampling proce- Pathways of introduction dures identical from port to port, traditional parametric statistics (e.g., t-tests and ANOVA)are not appropriate. The Port Information Network database, maintained by Therefore, data were not analyzed statistically. USDA, APHIS, Plant Protection and Quarantine (PPQ) was queried for interceptions of all Copitarsia spp. be- Risk assessment tween January 1985 and April 2000. Four taxa were identified: Copitarsia sp., C. consueta, C. incommoda, The pest risk assessment for Copitarsia spp. followed and C. turbata. The port of entry, interception date, re- the general framework developed by Orr et al. (1993), ported host, method of conveyance (i.e., mail, cargo, which has been further discussed and analyzed by etc.), and country of origin were noted from each in- Mack et al. (2002). Standard, operational guidelines terception record. Information for the four taxa was developed by APHIS for commodity risk assessments 171

Table 3. The top 90% of “host” plants reported for interceptions of In preparation for the assessment, we assem- Copitarsia spp. at the border by USDA, APHIS bled an extensive bibliography on the bionomic char- Host Common name Number intercepted acteristics of Copitarsia spp. Information sources included published literature, web pages, Internet Limonium sp. Sea Lavender 1998 databases, APHIS databases, CD-ROM databases, Alstroemeria sp. Lily of the Incas 1822 internal APHIS reports, and APHIS port manuals. In- Brassica sp. Cole crops 638 formation in Spanish was translated to English by trans- Dianthus sp. Pinks 432 lation software (SYSTRAN Professional, SYSTRAN Coriandrum sp. Coriander/cilantro 332 Software, Inc., La Jolla, CA) and manually checked for Chrysanthemum sp. Chrysanthemum 223 accuracy. Pisum sp. Pea 171 In an attempt to predict the potential distribution Asparagus sp. Asparagus 166 of Coptarsia spp. in the US, we used a geographic information system (ArcView 3.2, ESRI, Redlands, Gladiolus sp. Gladiola 143 California, USA) to determine which biomes (i.e., habi- Chenopodium sp. Quinoa 136 tat types) may support populations of the genus in its Gypsophila sp. Baby’s breath 117 native range. Wepresumed those biomes would provide Aster sp. Aster 113 climatically suitable habitat for Copitarsia if they oc- Lactuca sp. Lettuce 92 curred in the US. We first generated a map of the known Unidentified plant 80 worldwide geographic distribution of the genus (based Physalis sp. Husk tomato 78 on reports from the literature; Figure 1). This map was Rosa sp. Rose 57 then placed over a map of the worldwide distribution of Rosmarinus sp. Rosemary 47 biomes, as defined by the World Wildlife Fund (Olson Capsicum sp. Pepper 46 et al., 2001). A list was made of the biomes that oc- Rubus sp. Blackberry 40 curred within each respective country or municipality Helianthus sp. Sunflower 39 where Copitarsia spp. were reported. We recognized that Copitarsia spp. may not exist in all biomes within a country. In most cases, distribution records provided little guidance (i.e., the presence of (USDA, 1997, 2000) were used to produce a quali- Copitarsia was simply reported for an entire country or tative assessment of pest risk. Although USDA con- state). Using all biomes within a country as a basis for tinues to refine these guidelines, at the moment, they prediction is likely to overestimate the potential distri- remain a standard approach to evaluate pest risk. The bution of the genus. As a result, we attempted to select current paper is not meant to reinvent the process but the minimum number of biomes that could account for simply to use the current guidelines and introduce the the global distribution of Copitarsia. If only one biome concepts of uncertainty and variability. The guidelines were reported for a state (for example) from which Co- address the consequences and likelihood of pest intro- pitarsia was also reported, this biome must be suitable duction (i.e., successful invasion). Five risk elements for members of the genus. All countries or munici- (i.e., climate/host interaction, host range, dispersal po- palities that contained Copitarsia and just one biome tential, economic damage, and environmental damage) were identified, and a list of these biomes was prepared address the consequences of pest establishment. Six (i.e., the “short list”). We then cross-referenced the risk elements (i.e., quantity of potential hosts imported short list with biomes reported in each remaining coun- annually, likelihood of surviving post-harvest treat- try/municipality (i.e., locations with multiple biomes). ment, likelihood of surviving shipment to US, like- Countries/municipalities with at least one biome on lihood of not being detected at port of entry, likeli- the short list were assumed to be accounted for and no hood of arriving in a suitable habitat, and likelihood additional biomes were selected from these areas. We of finding a host) address the probability of success- then examined those locations with biomes which did ful pest invasion. Each risk element is given a ranking not appear on the short list. From these locations only, of high (3 points), medium (2 points) or low (1 point) we added the biome to the short list that occurred in based upon established criteria (USDA, 2000). The sum the greatest number of countries/municipalities. In the of all risk ratings characterizes the overall degree of event that two or more biomes occurred with equal fre- risk. quency, the biome that was reported most frequently 172 from the entire geographic distribution of Copitarsia Hidalgo, Texas. Notably, Nogales, Arizona and San was added to the short list. The process of adding ad- Diego, California, which receive a significant volume ditional biomes to the short list continued until at least of agricultural commodities from Mexico, reported few one biome was noted from each location with Copi- interceptions of Copitarsia (Table 4). Among all in- tarsia. The short list of biomes was evaluated for their terception records, Copitarsia were most commonly occurrence in the US. reported from permit cargo (92.8%), baggage (3.2%), A document that summarized results from the anal- general cargo (2.7 %), and ship stores (1.1%). Mail, ysis of Copitarsia interceptions, the climate matching ship quarters, ship holds, and miscellaneous path- exercise, and queries of information sources was dis- ways collectively accounted for less than 1% of all tributed to an expert panel of 15 scientists for review. interceptions. This document constitutes the first 47 pages of the re- Copitarsia-infested goods/commodities were re- port by Gould et al. (2000). Panel members were chosen ported from 23 countries (Table 1). Nearly twice for their expertise in Lepidoptera biology or pest risk as many reports were based on commodities from assessment. Five panel members were employed by Colombia as compared to Mexico. Colombia, Mex- academic institutions and ten members were employed ico, Ecuador, Guatemala, Chile, and Costa Rica ac- by regulatory agencies. After reviewing copies of the counted for more than 95% of all interception records document, each panelist was mailed a survey for his (Table 1). Reported interceptions of Copitarsia spp. or her evaluation of the eleven elements that contribute from the Netherlands and Japan may not reflect the to pest risk. Risk ratings were based on the informa- true origin(s) of these commodities. The proportion of tion provided and the assessor’s previous experience. insects arriving from each country remained relatively Because the risk assessment is based on the genus as a constant throughout the year (data not shown). Approx- whole, we asked reviewers to assume that if one species imately 150 genera of plants were indicated in reports of Copitarsia satisfied the criterion, the entire genus of Copitarsia interceptions. Genera accounting for the satisfied the criterion. All panelists responded to our top 90% of interceptions are reported in Table 2. The request but did not necessarily answer all questions. majority (∼60%) of reported interceptions were from In addition, for each element, we asked for an in- ornamentals and cut flowers. dication of the level of confidence in the assessment, again high, medium, or low. Confidence levels were Risk assessment assigned based upon the following criteria: high, data were adequate AND analyses were appropriate to draw Element #1 Ð climate/host a conclusion; medium, data were available, but insuf- This risk element attempts to describe the geographic ficient OR analyses were questionable; or low, no data area that might be impacted by a pest. For this element, were available OR analyses were incorrect. Assigning a non-indigenous organism in a new habitat is expected a high risk rating with a low degree of confidence, for to behave as it would in its native range if acceptable example, was acceptable as was a low risk rating with host plants are available and climate is conducive to a high degree of confidence. survival and reproduction (USDA, 1997, 2000). APHIS guidelines assign risk ratings based on the number of US plant hardiness zones (Cathey, 1990) that a species Results and discussion is expected to occupy. A high rating is assigned if the pest has the potential to become established in four or Pathways of introduction more hardiness zones; medium, if the pest is expected to establish in two or three plant hardiness zones; or From 1985 to April 2000, n = 7434 interceptions of low, if the pest is expected to establish in a single plant Copitarsia spp. were reported from 38 ports of entry hardiness zone. One hardiness zone is <19% of the area into the US. Only three records were found where spec- of the contiguous US; 2Ð3 zones represent 19Ð39% of imens were identified to the species level. Interceptions the area of the contiguous US, and four or more zones were most commonly reported from Miami (Table 4). are >39% of the area of the contiguous US (R. Venette, Reports from Miami, Florida, were seven times greater unpublished data). than the second most commonly reporting port, Laredo, A simple climate matching exercise suggests that Texas. Interceptions of Copitarsia from ports along Copitarsia spp. may survive in biomes characterized the US/Mexico border were greatest from Laredo and as montane grasslands; temperate coniferous forests; 173

Table 4. Interceptions of Copitarsia spp. reported from US ports of entry by USDA, APHIS and percentage of interceptions at each port associated with different pathways

% Observed in

Copitarsia General Permit Port interceptions Baggage cargo cargo Misc. Stores Quarters

Miami Florida 4,617 2.0 1.9 95.4 0.1 Ð 0.2 Laredo Texas 656 18.4 2.0 79.5 Ð Ð Ð Hidalgo Texas 589 4.6 1.7 93.1 0.6 Ð Ð San Juan Puerto Rico 252 5.4 0.6 93.4 Ð 0.6 Ð Dallas Texas 247 9.0 Ð 90.3 Ð 0.7 Ð Chile 2J 191 1.5 Ð 98.5 Ð Ð Ð Brownsville Texas 172 16.9 9.4 78.7 1.1 Ð Ð Houston Texas 171 9.2 5.9 71.1 Ð 13.8 Ð JFK Airport New York 118 Ð 56.0 44.0 Ð Ð Ð Des Plaines Illinois 62 10.5 89.5 Ð Ð Ð Ð Los Angeles California 46 11.1 6.7 82.2 Ð Ð Ð Fort Lauderdale Florida 45 Ð 2.9 91.2 Ð 5.9 Ð New Orleans Louisiana 43 Ð Ð 26.2 Ð 73.8 Ð Chicago Illinois 38 15.2 Ð 81.8 Ð Ð 3.0 El Paso Texas 34 44.8 Ð 55.2 Ð Ð Ð San Antonio Texas 34 3.2 3.2 90.3 Ð 3.2 Ð Atlanta Georgia 19 16.7 22.2 61.1 Ð Ð Ð Tampa Florida 18 Ð Ð 92.3 Ð 7.7 Ð Roma Texas 14 10.0 Ð 90.0 Ð Ð Ð Elizabeth New Jersey 13 30.8 15.4 53.8 Ð Ð Ð Pharr Texas 9 Ð Ð 100.0 Ð Ð Ð Jacksonville Forida 8 Ð Ð Ð Ð 87.5 12.5 Port Arthur Texas 8 Ð Ð Ð 14.3 85.7 Ð Progreso Texas 5 20.0 Ð 80.0 Ð Ð Ð Nogales Arizona 4 25.0 Ð 50.0 25.0 Ð Ð Savannah Georgia 4 Ð Ð 25.0 Ð 75.0 Ð Others (12 ports) 17 11.8 11.8 52.9 Ð 23.5 Ð Total 7,434 5.8 5.0 85.2 0.2 2.1 0.1 temperate grasslands, savannas, and shrub lands; desert zones and rated the element high; however, there was and xeric shrub lands; tropical and subtropical dry no consensus among panel members (Figure 3A). The broadleaf forests; and tropical and subtropical moist majority of respondents also felt that data were insuf- broadleaf forests. Montane grasslands and tropical and ficient or analyses were questionable and, as a result, subtropical dry broadleaf forests do not occur in the only had a moderate degree of confidence in their as- US. Because of its broad host range, the potential dis- sessment of this element. Again, no consensus was ap- tribution of Copitarsia is unlikely to be constrained parent (Figure 3B). We believe that further research is by host availability. As a result, Copitarsia spp. may necessary on the response of Copitarsia populations to have the potential to become established in 70% of the temperature and soil moisture to better predict the range contiguous US (Figure 2). of Copitarsia spp. in the United States. Such biologi- The majority of survey respondents felt it was likely cal data would increase confidence in the ranking for for this genus to survive in four or more plant hardiness this element. Two of three previous commodity risk 174

Figure 2. Possible distribution (gray)ofCopitarsia spp. in the US based on simple climate matching. assessments that addressed Copitarsia consueta also Respondents generally had high confidence in their as- gave this element a high rating (Table 5). sessment of this element.

Element #2 Ð host range Element #3 Ð dispersal potential This risk element accounts for the diversity of domes- This risk element pertains to the rate at which a new tic plants that could be affected by a pest. The element pest will achieve its maximum range in the US. Asses- is rated high if a pest attacks multiple plant species sors consider pest movement and reproductive poten- within multiple plant families; medium, if it attacks tial when evaluating this element. A high rating is as- multiple species within a singe plant family; and low, signed if a pest has the potential to move >10 km/year if it attacks a single species or multiple species within a and reproduce rapidly (e.g., many generations per year, single genus. In addition to the 39 species of host plants many offspring per generation, or a high innate ca- reported in the literature, Copitarsia spp. have been in- pacity for population increase). A medium rating is tercepted on more than 100 other plant genera arriving assigned, if a pest has only one of these characteris- in the US. Reports do not indicate whether Copitarsia tics. A low rating is assigned if none of these attributes spp. were actively feeding on these additional genera applies. or were simply hitchhiking. Nevertheless, most of the Several Copitarsia species are highly fecund. crops reported as hosts of Copitarsia are grown in the Copitarsia consueta and C. turbata produce approx- US (Texas Agricultural Statistics Service, 1999). imately 1500 eggs per female (Arce de Hamity & All respondents felt that Copitarsia spp. could Neder de Roman, 1992; Larrain, 1996; Rojas & attack multiple species within multiple plant fami- Cibrian-Tovar, 1994; Velasquez, 1988). These two lies and assigned a high risk rating in this category species also have three to four generations per year (Figure 3A), which is consistent with previous risk as- (Arce de Hamity & Neder de Roman, 1992; Artigas sessments (Table 5). The majority of respondents also & Angulo, 1973; Liberman Cruz, 1986). No informa- felt that adequate data were available and analyses tion has been published about the dispersal characteris- were appropriate to draw a conclusion (Figure 3B). tics of Copitarsia spp. However, other noctuid species 175

High A 1.0 A. Risk Elements-Consequences A Medium A A 0.8 Low

0.6 A A AB A 0.4

0.2 B B A B B BB B B B 0.0

1.0 B. Confidence 0.8 A 0.6 A A A AAA A 0.4 A A AB A AA A 0.2 A A B 0.0 Climate/ Host Dispersal Economic Environmental Overall Host Range Potential Impact Impact Consequences

A 1.0 C. Risk Elements-Likelihood A 0.8 A A A 0.6 A AA A 0.4 AB A Proportion of Panelists A 0.2 A B A A B A BB B 0.0

1.0 D. Confidence A A 0.8 A A 0.6 A AA 0.4 AB AB AA AA AA 0.2 B B B B B B 0.0 Quantity Survive Survive Not Moved to Find Overall of Hosts Post-harvest Shipment Detected Suitable Host Likelihood of Imported Treatment Habitat Plant Establishment

Figure 3. Proportion of an expert panel (n = 15) assigning a high, medium, or low rating to characterize: (A) risk elements describing the consequences of Copitarsia establishment; (B) the panel’s level of confidence in those ratings; (C) risk elements describing the likelihood of Copitarsia establishment; and (D) the panel’s level of confidence in those ratings. For each cluster of three bars, bars with the same letter are not significantly different (P > 0.05) as determined by overlap of 95% confidence intervals. disperse as adults over immense distances (Hendricks Element #4 Ð economic impact et al., 1973; Rose et al., 1985; Showers et al., 1989; Assessors consider three types of economic impacts Westbrook et al., 1995). when evaluating this risk element. Economic impacts The majority of respondents gave this risk element can occur if a pest lowers yield of the host, lowers a medium/high rating (Figure 3A), but there was lit- value of the host, or causes the loss of markets (USDA, tle agreement about the sufficiency of data to reach a 1997, 2000). A high rating is given to this risk element conclusion (Figure 3B). Additional research on the dis- if a pest could cause all three impacts; medium, if two persal potential of members of the genus would refine impacts could occur; and low, if only one impact could evaluation of this element. Two of three previous risk occur. assessments also classified this risk element as high In its native range, Copitarsia spp. have low- (Table 5). ered yields, lowered the value of the commodity, 176

Table 5. Previous qualitative assessments of the likelihood and medium/high, but again no consensus was apparent consequences of Copitarsia establishment in the US based on 11 (Figure 3B). risk elements

Brassica Brassica Pisum Element #5 Ð environmental impact from from Central from APHIS lists five potential impacts for consideration: a b c Element Mexico America Mexico direct environmental impacts, direct impacts on en- Climate/host High High Medium dangered or threatened species, indirect impacts on Host range High High High endangered or threatened species, initiation of disrup- tive control programs (pesticides), and release of non- Dispersal potential High High Medium indigenous biological control agents (USDA, 1997, Economic impact High High Medium 2000). A high rating is warranted if two or more of Environmental impact Medium Medium High the criteria apply; medium, if one criterion applies; or Overall consequences High High High low, if none of the criteria apply. of establishment If established in the US, Copitarsia spp. would Quantity imported annually Medium Medium Low have the potential to damage the environment di- Likelihood survive High High Medium rectly, through feeding on native plants, or indirectly post-harvest treatment by stimulating pest control. Nearly 700 plants native Likelihood survive shipment High High High to the US belong to genera known to be attacked Likelihood not detected High Medium Low by Copitarsia larvae (USDA NRCS, 1999). The U.S. Likelihood moved to High High Medium Fish and Wildlife Service lists seven of these native suitable habitat species as threatened or endangered (USDA NRCS, Likelihood find suitable host High High Medium 1999). Munz’s onion (Allium munzii), showy Indian Overall likelihood of High High Medium clover (Trifolium amoenum), and Monterey clover (T. establishment trichocalyx) are endangered and occur in Califor- Overall degree of risk via this High High Medium nia. Running buffalo clover (T. stoloniferum) is also pathway endangered and occurs in Arkansas, Illinois, Indiana, Note: Additional details about each risk element and associated Kansas, Kentucky, Missouri, Ohio, and West Virginia. criteria for high, medium, or low ratings are provided in the text. Eggert’s sunflower (Helianthus eggertii) and the Pecos a(Cave & Redmond, 1997b). b(Cave & Redmond, 1997a). sunflower (H. paradoxus) are threatened. Eggerts sun- c(USDA APHIS, 1997). flower occurs in Alabama, Kentucky and Tennessee, whereas the Pecos sunflower occurs in New Mex- ico and Texas. Unfortunately, reports of Copitarsia spp. feeding on non-crop plants generally list the host and affected export markets (see ‘Bionomics’ section as a “weed”, except for field smartweed (Polygonum above). For many of the commodities attacked, Copi- segetum), without providing taxonomic identification tarsia directly damages the part of the plant that is (Castillo & Angulo, 1991; Zenner de Polenia, 1990). harvested and consumed. Hunter and Elliott (1995) Indirect environmental damage could be caused consider the potential economic impact of Copitarsia if pesticides applied to control Copitarsia leave the spp. to be significant in Texas. In addition, the US ex- treated field, either as drift or in contaminated wa- ports at least seven crops (asparagus, berries, broccoli, ter, and affect other species in the ecosystem. APHIS cabbage, cauliflower, and lettuce), valued at US$ 457 also considers the potential release of natural enemies million in 1999 (USDA Economic Research Service, through a biological control program to constitute a 1999), that could harbor Copitarsia eggs or larvae. The risk to native organisms (USDA, 1997, 2000). Many presence of Copitarsia spp. could affect access to local natural enemies have been reported attacking Copitar- markets through domestic quarantine; Copitarsia spp. sia in its native range and would be potential agents are not noted as quarantine pests by plant protection for a biological control program. These natural ene- organizations outside the US (EPPO, 2000). mies include: pathogens, predators and parasitoids (see The majority of respondents felt that all three ‘Bionomics’ above). Any pest with the potential to impacts were likely in the US (Figure 3A), as did reduce yields or reduce the marketability of a crop two of three previous risk assessments (Table 5). The is likely to stimulate biological or chemical control overall confidence in this assessment was considered efforts. 177

In contrast to two of three previous risk assess- Pest opportunity ments (Table 5), the majority of respondents assigned a high rating to this element (Figure 3A). However, the Collectively, the remaining five elements describe the panel was equally divided in their level of confidence likelihood of a pest remaining associated with a com- in this assessment (Figure 3B). Evaluation of this el- modity, arriving as a viable individual in a suitable en- ement was complicated by the fact that the need for vironment, and locating a suitable host plant. For each chemical/biological control depends on the value and element, a rating of high is given if the probability of use of a commodity. Furthermore, many crops in the the event is >10%; medium, 0.1Ð10%, and low, <0.1% US are already subject to intense pest control regimens. (USDA, 2000). Each risk element is evaluated indepen- These control programs may effectively lower numbers dently of the preceding elements in this section. of Copitarsia spp. below economic thresholds. As a re- sult, Copitarsia spp. may not stimulate new pest control Element #6b Ð likelihood of surviving post-harvest activities, but the effects of current pest management treatment programs on this genus are not known. For this element, post-harvest treatment refers to any manipulation, handling or treatment of the commod- ity including culling, washing, fumigation with pesti- Element # 6a Ð quantity of commodity imported cides, and cold storage. If no post-harvest treatment The likelihood of introducing a foreign pest gener- occurs, APHIS recommends assigning this element a ally increases as the quantity of imported host plants high rating (USDA, 1997, 2000). We did not find any increases. APHIS estimates the volume of imported indication that commodities were treated prior to export commodities in terms of the number standard shipping specifically to reduce the number of Copitarsia. As part containers (12.2 m × 2.59 m × 2.44 m), a unit of mea- of the processing of certain commodities, obviously- sure readily understood by importers/exporters, that are damaged plants are removed prior to shipment. How- expected to arrive in the US annually (USDA, 1997, ever, the commodity receives no additional treatment to 2000). If >100 shipping containers are imported each destroy any pests that may have been missed. Because year, the element is assessed as high; 10Ð100 contain- no data were available, the panel was divided in their ers, medium; <10 containers, low. APHIS guidelines ranking of this element (Figure 3C) and in their level about the quantity of a commodity imported refer to of confidence in this assessment (Figure 3D). Two of one specific commodity from one country imported three previous risk assessments ranked this element as into the entire US. Our pest based risk assessment con- high (Table 5). cerns a genus that is found on many commodities from many countries of origin, and we included all possible Risk Element #6c Ð likelihood of surviving shipment shipments for assessing the risk element. This element estimates the probability that pests will A query of the APHIS Plant Quarantine database survive the conditions experienced under standard (PQ-280) indicated that from October 1993 to shipping conditions, or under conditions specifically December 1999, six billion metric tons of fruits, veg- designed to provide phytosanitary control (e.g., cold etables, herbs, ornamentals, and cut flowers potentially treatment in refrigerated containers). We know that harboring Copitarsia were imported in 814,278 ship- Copitarsia larvae survive shipment because only live ments into the US from Western Hemisphere countries. larvae are reported in the APHIS PIN database. Be- All respondents felt that a high rating for this element tween January 1985 and April 2000, 7434 intercep- was justified given the total volume of all the com- tions of commodities containing live Copitarsia were modities on which Copitarsia could enter (Figure 3C). reported. Over 90% of these interceptions were in A high rating would be appropriate even for certain, in- cargo, with the remainder of the interceptions from dividual commodities from specific countries entering baggage, mail, stores, quarters, and holds. We do a single port (data not shown). The majority of respon- not know the percentage of all Copitarsia larvae that dents were highly/moderately confident in the assess- survive shipment or whether intercepted larvae were ment (Figure 3D). Certain commodities from specific healthy. The majority of the panel ranked this ele- countries may not meet the standard for a high rating, ment as medium/high, but no obvious consensus was which would explain why previous APHIS risk assess- achieved (Figure 3C). The panel expressed a strong lack ments assigned ratings of low or medium to this risk of confidence in their assessments (Figure 3D). To ade- element (Table 5). quately assess this element, we would need to know the 178 number of larvae associated with a commodity at the infestation that would be necessary in order to detect time a shipment was ready to leave its country of ori- the pest with 95% confidence when 2% of the shipment gin. A detailed study of shipping conditions and their is sampled. effects on the viability of Copitarsia larvae is an im- Samples collected following AQIM guidelines portant area for future study. maintain a 95% probability of detecting pests at an infestation level of 10%, regardless of the size of the Risk element #6d Ð likelihood of avoiding detection shipment (USDA, 1998; Venette et al., 2002). When a All plant and animal products imported into the US constant 2% of the shipment is sampled, pests in small are subject to physical inspection by APHIS PPQ of- shipments are not likely to be detected. For example, ficers at ports of entry. The likelihood of detecting a in shipments with 300 potential sampling units (e.g., pest when it is present in a shipment is a function of boxes of produces), the probability of finding at least how noticeable a pest is (which is related to pest size, one pest is 0.469. The goal of detecting pests with 95% color, and behavior), the size of the shipment, the de- confidence is only achieved when the shipment size gree of infestation, and the amount of sampling effort. is large (i.e. >≈1,500 boxes) and ≥30 boxes are in- When assessors evaluate this risk element, typical sam- spected (Venette et al., 2002). As the shipment size pling procedures are assumed to apply. PPQ officers use (and the number of boxes inspected) declines, the level one of two sampling strategies before releasing cargo. of infestation must be high to be 95% certain that pests The first strategy is recommended under agricultural will be detected (Figure 4). As the infestation level de- quarantine inspection monitoring (AQIM), often called clines, the chances of selecting an infested box also hypergeometric sampling. The term “hypergeometric” decline (Venette et al., 2002). When the 2% rule is refers to a special statistical distribution that describes followed in shipments smaller than 500 boxes, PPQ the probability of detecting 1, 2, or more pests (con- officers are not likely to detect Copitarsia with 95% sidered successes) after inspecting a certain number confidence unless >25% of the commodity is infested of units (boxes, trays, etc.), when the total number of (Figure 4). pests in the shipment is known (or is assumed) and Because most sampling conducted by APHIS-PPQ the total shipment size is relatively small. The sam- follows the 2% rule, the majority of respondents felt pling strategy recommended under AQIM is designed that the probability of Copitarsia spp. not being de- to detect pests (assuming a 10% infestation level) with tected when it was present in commodity shipments was 95% confidence (USDA, 1998). Less than 1% of all high (Figure 3C). The majority of respondents also felt shipments entering the U.S. are currently inspected fol- that adequate data were available and appropriately an- lowing AQIM guidelines. Typically, cargo is inspected alyzed to reach a conclusion (Figure 3D). Previous risk following a 2% guideline (i.e., 2% of the shipment is assessments were divided on this issue with rankings inspected for the presence of pests). Ideally, the 2% for this element ranging from low to high (Table 5). sample should be drawn at random from a shipment, but tailgate inspections (i.e., inspection of units in a Element #6e Ð likelihood of arriving in a suitable shipment that are easily accessible) remain common. climate We conducted an analysis to determine the proba- APHIS recognizes that not all final destinations will bility of releasing cargo for entry into the U.S. when have a climate suitable for pest survival. This risk ele- AQIM guidelines or the 2% rule were followed (Venette ment considers the geographic locations of likely mar- et al., 2002). We assumed that all shipments were 10% kets and the proportion of a commodity that is likely infested. Because the number of samples collected (N) to move to locations that are suitable for pest survival. under the 2% rule is small relative to the shipment size, Without any additional information, we assume that we applied binomial statistics. From binomial statis- Copitarsia-infested products are distributed into dif- tics, it can be shown that the probability of observing 1 ferent biomes in the US in direct proportion to the or more pests, P[X > 0], is P[X > 0] = 1−(1 − p)N .In number of people who live in those areas and would this analysis, p = 0.10. We conducted a further analy- presumably purchase produce for consumption. In risk sis to look at the infestation rate needed to detect >1 element #1, we identified temperate coniferous forests; pest with 95% confidence. If the probability of detec- temperate grasslands, savannas, and shrub lands; desert tion is set at 95% (0.95) and the number of samples is and xeric shrub lands; and tropical and subtropical known (e.g. 2% of the shipment), we can rearrange the moist broadleaf forests as biomes that occur in the equation to solve for p. In this case, p is the level of US and could be suitable for Copitarsia establishment. 179

1.0

0.8

0.6

0.4

0.2 Proportion of Infested Sample Units 0.0 0 200 400 600 800 1000 1200 1400 Shipment Size

Figure 4. Proportion of sample units that must be infested to have 95% confidence of finding at least one pest when sampling 2% of a shipment.

Approximately, 39.2% of the US population lives in Additional research is needed on the ability of these zones (R. Venette, unpublished data). Copitarsia Copitarsia spp. to survive during the transport process also must survive domestic shipment. from harvest to market. Moreover, it may be useful to Respondents were divided in their assessment of consider the ultimate fate of an imported commodity, the fraction of viable larvae that would be transported whether it is consumed (e.g., fresh fruits and vegeta- to a climatically suitable habitat (Figure 3C). Corre- bles) or not (e.g., cut flowers and ornamentals). In this spondingly, respondents were divided in their level of assessment, we did not ask panelists to distinguish the confidence in these decisions (Figure 3D). No research relative risks associated with each commodity or path- has been conducted to formally define the probability of way. Yet, if we had, the fate of the commodity would pests surviving the environmental conditions encoun- only affect responses to Element #6f. As a result, we tered during shipment or the final processing of the conducted a sensitivity analysis on this risk element by commodity. setting the response of each panelist to low (i.e., host material and associated insects most likely to be con- Element #6f Ð likelihood of finding suitable host sumed), then to high (i.e., host material put into the This element considers whether suitable host plants environment), and examined changes in the likelihood would be available to support pest populations and of establishment and the overall degree of risk. whether a pest has the potential to detect and move to those hosts. Copitarsia spp. can feed on >39 crops. Overall assessment of risk An additional ≈700 native plant species in the United States belong in genera fed upon by Copitarsia. Po- Despite some variation in responses to individual risk tential host plants can be found in almost every county elements, the panel agreed, though not unanimously, in the United States (Texas Agricultural Statistics Ser- that Copitarsia spp. posed an overall high degree of vice, 1999). The likelihood of finding a suitable host risk. Summary assessments of risk were determined is also related to the dispersal capability of an individ- based on the sum of original scores provided by each ual. The dispersal potential for larvae or adults is not respondent and criteria developed by USDA (USDA, known. As a result, the panel did not agree on the like- 2000). Likewise summary assessments of confidence lihood of Copitarsia spp. finding a suitable host nor were evaluated by summing individual confidence did they concur about their level of confidence in the scores; this analysis of confidence is not part of USDA assessment (Figure 3C,D). guidelines (USDA, 2000). In total, the panel felt that 180 the consequences of Copitarsia establishment would be and remains, the lack of reliable data. In the absence of high (Figure 3A), but there was no consensus in the con- robust data, APHIS relies on a process that analyzes fidence of this conclusion (Figure 3B). Three previous potential pest introductions based largely on highly risk assessments also concluded that the consequences subjective and uncharacterized expert judgment in the of Copitarsia establishment would be high (Table 5). assessment of risk values” (National Plant Board, 1999, The panel also felt that the likelihood of establishment p. 9). There will always be gaps in the data available was high to moderate (Figure 3C), but confidence in this about potentially invasive organisms, and risk assess- conclusion was only moderate (Figure 3D). Previous ments will need to be based on incomplete data. We risk assessments found that the likelihood of establish- agree with Gray et al. (1998) that the risk assessment ment was high to moderate (Table 5). process must include measures of variability and un- Overall 85% of the panel judged the joint conse- certainty and clearly document information sources. quences and likelihood of Copitarsia establishment to We have attempted to follow these golden rules. In de- be high; 15% judged the risk to be medium; 20% of veloping a risk assessment for the genus Copitarsia, the panel was highly confident with the data and anal- we chose to formally describe the variability and un- ysis, 60% was moderately confident, and 20% had low certainty in risk ratings by quantifying the ratings of a confidence. For individual risk elements, our panel of group of experts. We have also provided statistical and experts rarely concurred about their level of confidence phenomenological models to help inform the risk rat- in their assessments. This lack of confidence reflects a ing process. As a result, this assessment moves beyond general lack of information about the genus; however, a strictly qualitative approach to a hybrid of qualitative we note that far more is known about this genus than and quantitative methods to evaluate risks associated many other exotic pests. Two of three previous risk as- with non-indigenous species. sessments also concluded that Copitarsia posed high If Copitarsia spp. are high-risk pests and members risk (Table 5). of the genus are frequently intercepted at U.S. ports of Our sensitivity analysis showed that the overall de- entry, suggesting potentially high levels of infestation gree of risk when all responses to risk element #6f given typical sampling protocols, why has not the genus were set to low did not differ significantly from the already established in the United States? We consider outcome when all responses for this element were set four responses to this question. First, because this eval- to high. In the former case, the modified scores of 77% uation focuses on an entire genus, it may overestimate of respondents indicated high risk and 23% indicated the risk associated with an individual species. For ex- medium risk. In the latter case, the modified scores ample, if species X were oligotrophic within one plant of 85% of respondents indicated high risk and 15% family (warranting a medium risk rating for risk ele- showed moderate risk. As would be expected, the es- ment #2) and species Y were oligotrophic within a sep- timated overall degree of risk was less sensitive than arate family, the genus would receive a high risk rating the estimated likelihood of establishment to changes for this element. Thus, it is conceivable that individual in scores assigned to element #6f. When this element species of Copitarsia may pose less risk than we and was set to low, the sum of modified scores of 57% other risk assessments have described. Addressing the of respondents indicated a high likelihood of estab- biological and pathway-related research questions out- lishment, 36% indicated medium likelihood, and 7% lined above, and improving taxonomy and systematics indicated low likelihood. When the score was raised within the genus, would allow us to more accurately to high, 86% indicated a high likelihood of establish- characterize risks associated with a particular species. ment and 14% indicated a medium likelihood. These Second, the framework that we used (USDA, 2000) changes were not statistically significant (P > 0.05), incompletely addresses the invasion process. Specifi- but the lack of significance is not surprising given the cally, the framework does not address the fate of a pest small size of the panel. Nevertheless, this analysis sug- population after viable individuals find a host plant in gests that the fate of the commodity does not dictate an area climatically suitable for survival. Allee effects, the degree of risk posed by a pest, at least as measured resident antagonists, and a potential absence of mutual- using a standard protocol (USDA, 2000; Mack et al., ists further lower the probability of invasion and are ex- 2002). ceptionally difficult to characterize a priori (Crawley, A recent review of the APHIS PPQ safeguarding 1989). Third, the scores for risk elements are additive system reports that “...a major obstacle to the evolu- rather than multiplicative, which tends to overestimate tion of the APHIS pest risk analysis process has been, the likelihood of pest invasion (Mack et al., 2002). If 181 four of the five elements describing invasion potential Arestegui, P.A., 1976. Plagas de la papa en Andahuaylas, Apurimac. were high, but one element was incredibly unlikely, the Rev Peru Entomol 19: 97Ð98. overall probability that the pest would establish would Artigas, J.N. & A.O. Angulo, 1973. Copitarsia consueta (Walker), bi- ologia e importancia economica en el cultivo de raps (Lepidoptera, be low, but this probability would be characterized as Noctuidae). Bol Soc Biol Concep 46: 199Ð216. high using this ranking system. In a qualitative pest risk Aruta, M.C., R. Carillo, L. & S.M. Gonzalez, 1974. Determinacion assessment framework for aquatic species, Orr (2003) para Chile de hongos entomopatogenos del genero Entomoph- suggests that the lowest rating assigned in the assess- thora. Agro Sur 2: 62Ð70. ment of the likelihood of pest establishment be used Carrillo, S.J.L., 1971. Pruebas de thuricide (Bacillus thuringiensis) para combatir gusanos de la Colen Chapingo. Mex Agric Tecnic to characterize the overall likelihood of establishment. Mex 3: 58Ð60. Finally, we cannot exclude the possibility that Copi- Castillo, E.E. & A.O. Angulo, 1991. Contribution to the knowledge tarsia has in fact successfully established in the United of the genus Copitarsia Hampson 1906 (Lepidoptera, Glossata, States. Currently, there are no pheromone lures to aid Cucullinae). Guy Zool 55: 227Ð246. in detection programs, nor are there routine, systematic Castrejon, G.J.R., T.L. Cibrian, J. Valdes & M.L. Camino, 1998. Morfologia, distribucion y cuantificacion de los sensulos ante- surveys for this pest. Further, the difficulty of distin- nales en adultes de Copitarsia consueta. Fol Entomol Mex 103: guishing Copitarsia in the field increases the possibil- 63Ð73. ity of confusing this potential new with other Cathey, H.M., 1990. USDA plant hardiness zone map, Miscellaneous endemic/naturalized noctuid pests. Publication No. 1475. U.S. National Arboretum, Agricultural Re- This risk assessment provides a blueprint for fu- search Service, U.S. Department of Agriculture, Washington, DC. http://www.usna.usda.gov/Hardzone/ushzmap.html. ture research that should be used to validate/refute ele- Cave, G.L. & L. Redmond, 1997a. Importation of Brassica spp. ments of the assessment. Risk assessment should be a from Costa Rica, El Salvador, Honduras, and Nicaragua into dynamic process with the risk assessment identifying the United States. US Department of Agriculture, Animal and needed research, and the research results contributing Plant Health Inspection Service, Plant Protection and Quarantine. to a re-evaluation of risk. In fact, the authors are cur- http://www.aphis.usda.gov/ppq/pra/. Cave, G.L. & L. Redmond, 1997b. Importation of Chinese cab- rently pursuing research to validate this risk assessment bage (Brassica pekinensis), kohlrabi (B. oleracea var gongy- for Copitarsia spp. lodes) and pak-choi (B. chinensis) from Mexico into the United States. US Department of Agriculture, Animal and Plant Health Inspection Service, Plant Protection and Quarantine. Acknowledgments http://www.aphis.usda.gov/ppq/pra/. Cortes, R.P., A.P. Aguilera, C.H. Vargas, Q.N. Hichins, L.E. Campos & W.J. Pacheco, 1972. Las “cuncunillas” (Noctuidae) de la alfalfa We would like to thank L. Thompson, R. Simmons, en Lluta y Camarones, Arica-Chile.- un problema bio-ecologico F. Mu˜noz-Quesada for technical assistance. We appre- de control. Rev Peru Entomol 15: 253Ð266. ciate the constructive comments of D. Andow and S. Cortes, R., 1976. Multi-control of cutworms and armyworms (Noc- Naranjo on earlier versions of this manuscript. tuidae) in alfalfa in the desert valleys of Lluta and Camarones, Arica., Proc. Tall Timbers Conf. 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