Article posted on August 22, 2019

Take Action by Aug. 26: Submit Public Comments to USDA on Aphalara Itadori


Pollinator Stewardship Council, Inc, joins with Empire State Honey Producers Association to submit beekeepers’ concerns about the USDA proposed plan of the Release of Aphalara Itadori for the Biological Control of Japanese, Giant, and Bohemian Knotweeds. (The USDA Risk Assessment for the Field Release of the Knotweed Psyllid can be found here.)

Pollinators, including honey bees, are a vital part of U.S. agriculture, and yet honey bee health faces a variety of challenges. Late fall forage opportunities for honey bees are vital in their collection of food supplies to survive the winter. Removing Japanese, Giant, and Bohemian Knotweeds from the landscape with no plan for replacing this lost nectar source will further contribute to the health stressors of honey bees.

The proposed action of USDA-APHIS to release a foreign exotic agent for the biological control of an exotic plant is narrowly focused, presents no plan for comparable replacement of a nectar source for honey bees or for water control on vacant urban lots and therefore mosquito control, or for restoration of native plant diversity to prevent soil erosion.

“When blooming (July to September), the plant puts on an attractive floral display befitting the common name ‘fleece flower’.”1 “Japanese knotweed is highly regarded for its attractive flowers and has been planted by beekeepers for its nectar.”2 “Knotweed is “ alive with pollinators and are particularly attractive to honey bees. Many beekeepers manage to harvest a monofloral honey from the vast stands found locally. And if you don’t harvest, it makes a great late-summer boost to a colony’s winter pantry.”3 “The honey is dark and flavorful, and many people compare it to a mild form of buckwheat honey.”4

“Bee lovers have found another use for Japanese knotweed. The hollow stems are often cut into lengths and bundled for use as native bee habitat. The stem diameters vary just enough to provide suitable housing for a wide range of tunnel-nesting bees, including mason bees and leafcutters.”5 Harvesting knotweed stalks, removing them from the ecosystem would hold two benefits: 1) provide a cash “crop” for local economies in the sale of nesting material for stem dwelling native pollinators; 2) remove the end of season “knotweed litter” from the ecosystem aiding the growth of native plants.

“Well-liked by bees, the blossoms provide bee forage when little else is available. The amber honey has a pleasing flavor.”6 “As is often the case with invasive weeds, apiarists consider F. japonica to be of value to bees and invertebrates, with an increase of 45 kg in hive weight in 5 days being reported from a knotweed stand (Andros, 2000).”7

As part of the invasive weed control plan, native plants need re-introduced into the area to prohibit other opportunistic, monofloral species from taking seed.

Proposed Release of Non-Native Pest

USDA-APHIS has presented a rationale for this additional knotweed control tool, but they need to complete the plan for the release of a non-native pest into the US ecosystem. We are concerned as to your statement, “These permits would contain no special provision or requirements concerning release procedures or mitigating measures.” 23

The Proposed Action needs to:

  • Provide release procedures and mitigating measures relevant to the introduction of this non-native pest;
  • Examine how to control the psyllid if it does attack native plants;
  • Develop a replacement planting plan for native plants, especially for those that bloom in the fall and provide forage for honey bees, and native pollinators;
  • Introduce a genetic marker to track the released A. itadori;
  • Detail the post-release monitoring plan for A. itadori.

Management of knotweed, and other invasive plants is a “long term venture.” It is easy to destroy the ecosystem; it is difficult and expensive to restore it. Beekeepers need this valuable nectar source for their honey bee livestock. Knotweed is an invaluable honey bee forage vital to sustaining these crop pollinators through the winter so they are available for the next growing season.

Please take action today!

(see PDF of letter for footnote citations)

Deadline to submit your comments is August 26, 2019.

HOW TO SUBMIT YOUR COMMENTS:

You can read our letter at this link. You can save the PDF of the letter to your desktop, then attach it to the docket.

You can copy and paste the text below into the text box at Regulations.gov, or upload a PDF letter in support of the Empire State Honey Producers Association and the Pollinator Stewardship Council comments.

The Pollinator Stewardship Council, Inc, and Empire State Honey Producers Association ask you to submit beekeepers’ concerns about the USDA proposed plan of the Release of Aphalara Itadori for the Biological Control of Japanese, Giant, and Bohemian Knotweeds.

Please submit your comments or feel free to copy and paste our letter below and submit it by August 26, 2019. You can also simply upload the PDF of our letter to the docket. Let them know you want bee forage for honey bees and native pollinators.

Step 1

Highlight and Copy the Text of the draft letter below (there is a “5000 character with spaces” limitation in the text box. A sample letter below is available for you to copy the text)

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I join with the Empire State Honey Producers Association and the Pollinator Stewardship Council expressing concern of the proposed method of removal of Japanese, Giant, and Bohemian Knotweeds from the landscape. The proposed action of USDA-APHIS to release a foreign exotic agent for the biological control of an exotic plant is narrowly focused, presents no plan for comparable replacement of a nectar source for honey bees or for water control on vacant urban lots and therefore mosquito control, or for restoration of native plant diversity to prevent soil erosion.

Value to Pollinators

“When blooming (July to September), the plant puts on an attractive floral display befitting the common name ‘fleece flower’.”1 “Japanese knotweed is highly regarded for its attractive flowers and has been planted by beekeepers for its nectar.”2 “Knotweed is “ alive with pollinators and are particularly attractive to honey bees. Many beekeepers manage to harvest a monofloral honey from the vast stands found locally. And if you don’t harvest, it makes a great late-summer boost to a colony’s winter pantry.”3 “The honey is dark and flavorful, and many people compare it to a mild form of buckwheat honey.”4

“Bee lovers have found another use for Japanese knotweed. The hollow stems are often cut into lengths and bundled for use as native bee habitat. The stem diameters vary just enough to provide suitable housing for a wide range of tunnel-nesting bees, including mason bees and leafcutters.”5

Range of Invasive Plant

Like many invasives, knotweed is beneficial in some areas, and damaging to the ecosystem in others. Knotweed is found throughout most of the United States, “especially in urban and suburban landscapes, roadsides, gullies, and waste areas.” 6 “It is often associated with moist but well-drained sites with nutrient-rich soil, and it tolerates semi-shaded environments. It has also been planted in sandy sea-shore areas where it stabilizes soil and withstands salt and low nutrients.”7 “It has been planted along highways to control soil erosion and has been used for revegetation of strip-mine spoil and to stabilize land affected by volcanoes.”8

When we compare the range of the Knotweed with the range of disease-carrying mosquitoes, the plan to remove Knotweed is problematic. It is a plant found on vacant lots in urban areas and which absorbs standing water; breeding sites for mosquitoes. Vacant lots would benefit from the implementation of a native plant re-introduction plan that will absorb standing water, mitigating the risk of mosquito breeding sites, and the spread of disease. Removal of knotweed with no plan for replacement with native plants or mitigation of standing water will support mosquito habitat, thus impacting human health concerns from disease carrying mosquitoes.

Management

To manage invasive species of plants Physical or Mechanical Control, Chemical Control, Cultural Management, and/or Biological Controls are the methods in place now. As Japanese knotweed exhibits great tolerance to most herbicides9 it is critical to have a variety of “tools in the toolbox,” to control this non-native plant. Mechanical controls appear to have the best success, whether from weekly mowing, or digging up the plant. However, if another plant is not put in place, then knotweeds’ resilience to survive will lead to its return.

Proposed Release of Non-Native Pest

USDA-APHIS has presented a rationale for this additional knotweed control tool, but they need to complete the plan for the release of a non-native pest into the US ecosystem. We are concerned as to your statement, “These permits would contain no special provision or requirements concerning release procedures or mitigating measures.” 10

The Proposed Action needs to:

  • Provide release procedures and mitigating measures relevant to the introduction of this non-native pest;
  • Examine how to control the psyllid if it does attack native plants;
  • Develop a replacement planting plan for native plants, especially for those that bloom in the fall and provide forage for honey bees, and native pollinators;
  • Introduce a genetic marker to track the released A. itadori;
  • Detail the post-release monitoring plan for A. itadori.

Management of knotweed, and other invasive plants is a “long term venture.” Knotweed is an invaluable honey bee forage vital to sustaining these crop pollinators through the winter so they are available for the next growing season.

Sincerely,

[YOUR NAME HERE]

Notes

  • 1, 2, 3, 4 Ohio Perennial and Biennial Weed Guide, The Ohio State University, College of Food, Agricultural and Environmental Sciences, 2019, https://www.oardc.ohio-state.edu/weedguide/single_weed.php?id=60
  •  Knotty but Nice for Bees
  • 6 U.S. Fish and Wildlife Services, Frequently Asked Questions About Invasive Species, https://www.fws.gov/invasives/faq.html
  • 7, 8, 9 Ohio Perennial and Biennial Weed Guide, The Ohio State University, College of Food, Agricultural and Environmental Sciences, 2019, https://www.oardc.ohio-state.edu/weedguide/single_weed.php?id=60
  • 10 Field Release of the Knotweed Psyllid Aphalara itadori (Hemiptera: Psyllidae) for Classical Biological Control of Japanese, Giant, and Bohemian Knotweeds, Fallopia japonica, F. sachalinensis, and F. x bohemica (Polygonaceae), in the Contiguous United States, Environmental Assessment, April 2018, https://www.regulations.gov/document?D=APHIS-2019-0002-0002

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Step 2

Select this link at Regulations.gov, where comments can be submitted to the docket.

Click on the Comment Now button on the Regulations.gov website, and paste the text (which is less than 5000 characters) into the text box. Feel free to edit the sample comments and type your own, just remember you are limited to 5000 characters including spaces.

You can also simply type in the comment area on the docket, “I join with the Empire State Honey Producers Association and the Pollinator Stewardship Council in support of their comments and suggestions concerning this proposal about Knotweed.” Then, add the PDF of our letter.

The docket will advise you if you were successful in sending your comment. If you provided your email address, you will receive an email confirmation from USDA/Regulations.gov

Thank you for Taking Action for Pollinators!