The light brown apple moth (Epiphyas postvittana, often abbreviated to LBAM) is a leafroller moth belonging to the lepidopteran family Tortricidae. The moth was confirmed to be present in mainland United States in 2007, principally along the West Coast. The State of California and the US Department of Agriculture quickly imposed agricultural quarantine measures and decided to use aerial spraying to try to eradicate the moth. This led to substantial public controversy and claims of adverse health effects. Aerial spraying was discontinued in 2008. Trapping, monitoring, and inspection efforts were reduced or eliminated in 2012 due to budget problems.
Light brown apple moth The insect is regarded as an herbivorous generalist, and the larvae consume numerous plant crops in Australia and New Zealand. The species is native to Australia and is found in New Zealand, Ireland, the United Kingdom, and Hawaii.
The moth has been classified as a noxious insect in the United States and Canada, but not in Europe. This resulted in restrictions on importing and exporting produce from infested areas between the US, Mexico, and Canada under the North American Free Trade Agreement.
History The first light brown apple moth to be confirmed in California by DNA analysis was found in February 2007. James Carey, a professor of entomology at the University of California-Davis, believes, based on his previous experience with the gypsy moth program and its geographic spread at the time of identification, that the light brown apple moth had likely been in California for many years before that.
In early 2007, the state decided to eradicate the moth. This decision may have been prompted in part by quarantine measures imposed by Canada and Mexico on California's produce. At the time, some experts thought that eradication was feasible, and others did not. The potential losses related to lost and damaged crops, if the moth spread unchecked throughout the state, was estimated to be above US $600 million ($ million after adjusting for inflation).
The California Department of Food and Agriculture issued a State Interior Quarantine order restricting intrastate shipment of plant material from counties where LBAM had been found. The US Animal and Plant Health Inspection Service later issued a Federal Domestic Quarantine order on May 2, 2007, with restrictions on interstate shipment of plant material. CDFA officials, together with the United States Department of Agriculture and the United States Environmental Protection Agency, initiated what they described as an emergency eradication program, including domestic and international quarantines and inspection programs. Although a pesticide cannot be legally used if it has not been registered by EPA's Office of Pesticide Programs in accordance with the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the EPA has the ability to approve emergency exemptions (under Section 18 of FIFRA) for unregistered uses of pesticides for limited time periods, if the EPA determines that emergency conditions exist and the request meets EPA safety requirements. The EPA granted the quarantine exemption request from the USDA.(E,E)-9,11-Tetradecadien-1-yl Acetate; Receipt of Application for Emergency Exemption, and Solicitation of Public Comment
The amount of active ingredient applied was less than one ounce per acre (about one-eighth of a drop per square meter). The Monterey County Weekly, in October 2007, reported that according to CDFA spokesman Jay Van Rein, the first two aerial applications over the Monterey Peninsula cost $3.7 million, with $3.1 million of that used to buy the spray products. The November 2007 application was described as costing $2.7 million.State to spray Santa Cruz County in bid to eradicate apple moth
In 2012, during a budget crunch, the state cut funding for the pest control program, including for agricultural inspections.
Eradication measures
In late 2007, the California moth eradication program controversially included aerial spraying of a product containing sex pheromones that attract LBAM males over sixty square miles near the Pacific coast between Monterey and Santa Cruz.CDFA Light Brown Apple Moth Project The US Environmental Protection Agency authorized the aerial spraying of the pheromone spray every 30 days until 2010. The ingredients of LBAM-F were published on the CDFA website in 2007.Light Brown Apple Moth Eradication Program Update: MONTEREY COUNTY SUPERIOR COURT LIFTS TEMPORARY RESTRAINING ORDER, GOVERNOR ORDERS ERADICATION PROGRAM TO RESUME AND INGREDIENTS TO BE MADE PUBLIC In June 2008, the State of California announced that it was abandoning plans for aerial spraying over population centers.
In December 2015, a California appeals court ruled against the LBAM pesticide program on the grounds that it violated state environmental laws by not sufficiently considering less harmful alternatives.
Adverse health claims After the spraying in Monterey and Santa Cruz counties in the fall of 2007, 453 complaints of adverse health effects in humans were reported. An analysis of all of these reports was published by the state Office of Environmental Health Hazard Assessment (OEHHA) in April 2008. Most of these were self-reports posted on websites; 44 (10%) were reports from healthcare providers. More than half of the reports were from residents of Monterey County. Less than 25% of the reports included the date and place, and almost none of the complaints posted on websites contained all of the information needed to evaluate the complaint. The report said "Our most significant conclusion is that we were unable to link the reported symptoms with exposure to the pheromone formulation".
Of the 74 people who said they sought medical assistance, most reported asthma exacerbations or non-specific respiratory symptoms such as cough, shortness of breath, runny nose, or wheezing. The symptoms reported, such as irritated eyes, wheezing, or headaches, were similar to those experienced by 15–25% of adults in California each week. The rate of reported symptoms was 0.12% of people per application (less than one-hundredth the normal rate). Since the reported symptoms are very common, it was impossible to determine whether any individual's symptoms were related to the spray.
Critics such as Assemblymember John Laird were disappointed by the report.
Efficacy debate and proposed solutions
Critics state that no published efficacy reports on the pheromone formulations used aerially against LBAM exist, raising questions about the validity of the eradication effort. Additionally, University of California scientists and other independent experts recommend containment measures in urban areas, reserving full-scale airplane spraying for crop areas in the Central Valley. Oakland city council member Jane Brunner questioned the location of the sprayings in interviews and in her resolution against the efforts.
The group 'Helping Our Peninsula's Environment' proposes controlling the moth with the targeted use of pheromone-baited sticky traps. These are the same traps used for population size measuring purposes. The traps have caught and killed almost all the 27,000 LBAM moths found so far in California. This method would employ four additional traps for every LBAM caught and consumes far less resources in traps and staff than applying 160,000 twist ties per square mile (250 per acre).
Other critics of the aerial spray plan, such as The California Nevada Regional Conservation Committee of the Sierra Club, propose that twist ties be impregnated with the pheromone and hung on trees and other structures across the area. They say they prefer least-toxic, environmentally sensitive control methods to spraying.
The California Department of Food and Agriculture has determined that more than nine million twist ties would be required to cover the infested area. Because the twist ties need to be placed at optimal distances from each other, one trained employee can correctly place 30 to 40 twist ties in a single day.Light Brown Apple Moth Twist ties become ineffective after about three months and then need to be removed, disposed of, and replaced four times a year. As a result, using twist ties as the primary measure to control the moth has been ruled out. In early February 2008, the California Department of Food and Agriculture and the U.S. Department of Agriculture (USDA) announced that treatment using pheromone-infused twist ties was scheduled for LBAM eradication in some lightly infested areas. A USDA official has stated that they are still considering whether to treat San Francisco and the East Bay Area through ground or aerial application.
In March 2008, Fairfax, California City Councilmember Larry Bragman wrote an article stating that since no biological basis for the spraying appears to exist, the more likely issue appears to be the costly trade quarantines invoked by Mexico and Canada under the North American Free Trade Agreement (NAFTA). But he also cited an excerpt from the Mexican quarantine demand: "The present phytosanitary conditions may be modified or harmonized whenever we have more technical and scientific information regarding E. postvittana (LBAM) as well as we receive more information about the evolution status of this pest in the United States."
Bragman, like others, notes that the moth is not a quarantine pest in Europe, and pointed to the recent research papers by Harder and Carey that he believes constitute technical and scientific information which should be conveyed to trade representatives.
Several county public health officials posted public letters expressing their concerns or disagreements with the spray program. Health Officer of the Public Health Division of the County of Santa Cruz, Poki Stewart Namkung, stated in a letter on March 18, 2008, to Santa Cruz Assemblymember Laird, that "We do not believe that any spraying should commence before completion of an EIR that includes a comprehensive human health assessment."
Alameda County Public Health Director, Athony Iton, along with Alameda County Supervisor Keith Carson, stated in a letter on February 26, 2008, to the CDFA, that "We are confident that there are a variety of other methods to address the LBAM that are much safer for people and the environment and do not pose a major health risk to the residents of Alameda County and California."
On April 9, 2008, California Congressmember Sam Farr (D-Carmel) further inquired at an agriculture hearing in Washington D.C. about how and when the light brown apple moth was blacklisted and whether it should be declassified from that status. News stories about the inquiry quoted Farr as saying: "If we don’t even know why the moth is listed as a dangerous pest, it’s impossible to determine how far we must go to control it or whether the current emergency eradication tactics are justified."Can't we just de-list the moth, already?
In December 2013, James Carey and Daniel Harder published an article criticizing the way expert panels are structured, because they permit scientists involved in a decision-making process to have private discussions and do not generally release information about internal disagreements to the public.
Legal challenges, public outcry and investigations