![](media/image1.wmf){width="0.7958333333333333in"
height="0.5465277777777777in"}![](media/image2.jpeg){width="0.45902777777777776in"
height="0.5083333333333333in"}

**Field Release of *Neomusotima conspurcatalis* (Warren) (Lepidoptera:
Crambidae), an Insect for Biological Control of Old World Climbing Fern
(*Lygodium microphyllum*), in the Continental United States**

**Environmental Assessment, June 1, 2007**

Number range CHAPTER**Field Release of *Neomusotima conspurcatalis*
(Warren) (Lepidoptera: Crambidae), an Insect for Biological Control of
Old World Climbing Fern (*Lygodium microphyllum*), in the Continental
United States**

**Environmental Assessment,**

**June 1, 2007**

**Agency Contact:**

Dr. Robert Flanders

Plant Protection and Quarantine

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road, Unit 133

Riverdale, MD 20737

The U.S. Department of Agriculture (USDA) prohibits discrimination

in all its programs and activities on the basis of race, color, national

origin, sex, religion, age, disability, political beliefs, sexual
orientation,

and marital or family status. (Not all prohibited bases apply to all

programs.) Persons with disabilities who require alternative means

for communication of program information (Braille, large print,

audiotape, etc.) should contact USDA's TARGET Center at

\(202\) 720--2600 (voice and TDD).

To file a complaint of discrimination, write USDA, Director, Office of

Civil Rights, Room 326--W, Whitten Building, 1400 Independence

Avenue, SW, Washington, DC 20250--9410 or call (202) 720--5964

(voice and TDD). USDA is an equal opportunity provider and employer.

**Table of Contents**

I. Purpose and Need for the Proposed Action 4

II\. Alternatives 5

III\. Affected Environment 7

IV\. Environmental Consequences 10

V. Other Issues 16

VI\. Agencies, Organizations, and Individuals Consulted 17

VII\. References 18

Appendix 1 21

Number range CHAPTER**I. Purpose and Need for the Proposed Action**

The U.S. Department of Agriculture (USDA), Animal and Plant Health
Inspection Service (APHIS), is proposing to issue a permit to a USDA,
Agricultural Research Service (ARS) researcher for release of a
nonindigenous defoliating moth, *Neomusotima* *conspurcatalis* (Warren)
(Lepidoptera: Crambidae)*.* The agent would be used by the applicant for
the biological control of Old World climbing fern, *Lygodium
microphyllum* (Cav.) R. Br. (Lygodiaceae) in Florida. Before a permit is
issued for release of *N. conspurcatalis*, APHIS must analyze the
potential impacts of the release of this agent into the continental
United States.

This environmental assessment[^1] (EA) has been prepared, consistent
with USDA, APHIS\' National Environmental Policy Act (NEPA) implementing
procedures (Title 7 of the Code of Federal Regulations (CFR), part 372).
It examines the potential effects on the quality of the human
environment that may be associated with the release of *N.
conspurcatalis* to control infestations of *L. microphyllum* within the
continental United States. This EA considers the potential effects of
the proposed action and its alternatives, including no action.

The applicant's purpose for releasing *N. conspurcatalis* is to reduce
the severity of infestations of *L. microphyllum* in Florida. *L.
microphyllum* is a climbing fern that belongs to the plant family
Lygodiaceae[^2]. It has a large native range, extending through much of
the Old World tropics, spanning almost half of the world's circumference
from 18E in Senegal to 150W in Tahiti between the latitudes of 29S in
Australia and 27N in northeastern India (Pemberton, 1998). It has been
introduced into Jamaica, Guyana, and southern and central Florida. *L.
microphyllum* is now well established in central and southern peninsular
Florida, where it grows in a number of wetland and mesic (having a
moderate supply of moisture) habitats including hammocks, cypress
swamps, flatwoods, bayheads, and disturbed sites. The potential
distribution in Florida of this climbing fern includes all mesic
habitats in southern Florida from Lake Okeechobee south. The weed occurs
in central Florida north of Orlando and has become increasingly serious
north of Lake Okeechobee. There is a need to release a host-specific
biological control agent to reduce infestations of *L. microphyllum*
because herbicidal and mechanical controls are expensive, are temporary
solutions, and are damaging to non-target plants.

**II. Alternatives**

This section will explain the two alternatives available to APHIS; no
action and to issue a permit for release of *N. conspurcatalis*.
Although APHIS' alternatives are limited to a decision on whether to
issue a permit for release of *N. conspurcatalis*, other methods
available for control of *L. microphyllum* are also described. These
control methods are not decisions to be made by APHIS and may continue
whether or not a permit is issued for environmental release of *N.
conspurcatalis*. These are methods presently being used to control *L.
microphyllum* by public and private concerns.

A third alternative was considered, but will not be discussed further.
Under this third alternative, APHIS would have issued a permit for the
field release of *N. conspurcatalis* but the permit would contain
special provisions or requirements concerning release procedures or
mitigating measures. No issues have been raised that would indicate that
special provisions or requirements are necessary.

**A. No Action**

Under the no action alternative, APHIS would not issue a permit for the
field release of *N. conspurcatalis* for the control of *L.
microphyllum*. The release of this biological control agent would not
take place. The following methods are presently being used to control
*L. microphyllum*. These control methods will continue under the "No
Action" alternative and may continue even if a permit is issued for
release of *N. conspurcatalis*.

**1. Chemical Control**

Ferriter (2001) summarizes current control methods and reports that
various herbicides have given excellent control of *L. microphyllum*
vines but that regrowth and nontarget damage usually occur. The
herbicides glyphosate (Rodeo®), triclopyr (Pathfinder ®, Garlon®), 2,4-D
(Weedar®, Vanish®), fosamine (Krenite®), and imazapyr (Arsenal ®) are
used for control of *L. microphyllum*. These may be applied to foliage
aerially, such as when tree islands are covered with the vine, or may be
applied as "poodle-cuts" where the vines are cut 4-5 feet up from the
ground and herbicide is applied to the rooted portion of the plant.

**2. Mechanical Control**

Mechanical control includes cutting vines, physical removal
(hand-pulling), or burning. Heavy equipment to remove vines can be used
but has limited value.

**Number range CHAPTERB. Issue the Permit for Environmental Release of
*N. conspurcatalis***

Under this alternative, APHIS would issue a permit for the field release
of *N. conspurcatalis* for the control of *L. microphyllum*. This permit
would contain no special provisions or requirements concerning release
procedures or mitigating measures.

**1. Biological control agent information**

The moth *N.* *conspurcatalis* (Lepidoptera: Crambidae) was first
observed to defoliate *L. microphyllum* vines in Hong Kong by Robert
Pemberton (Pemberton and Goolsby, 2005). During field surveys it was
found to occur widely from Southeast Asia to Australia (Goolsby et al.,
2003)**.** Specifically, it occurs in northeastern India in Assam and
Sikkim; in Indonesia on the islands of Java, Sulawesi, Sumatra; in East
Timor; and in north Queensland and the Northern Territory of Australia.
In China it is known from Hong Kong, Guandong, and Hainan Provinces.

*Neomusotima* *conspurcatalis* is a brown moth with two distinctive
white boomerang shaped marks near the margin of the top surface of the
forewing. The eggs are very flat, pale yellow and usually laid in
clusters on the leaflets. The larvae are yellow to green with dark brown
heads and prothoracic shields. Older larvae may have black spots on the
under surface. Young larvae feed together in groups, often under
webbing, on the undersides of the leaves which they skeletonize (scrape
leaf surface). Older larvae are more spaced and eat whole leaflets.
Pupae are dark brown.

The lifecycle of *N. conspurcatalis* is as follows: moths mate after
emergence, and females lay eggs in small clusters on both sides of the
leaflets and the leaf stem of *L. microphyllum*. The eggs are initially
very flat and almost transparent but as they mature they swell and the
developing larva is visible inside. The first three larval instars feed
by scraping the surface of the leaf. The fourth- and fifth-instar larvae
usually eat the entire leaf, but there can still be some leaf scraping.
Most of the leaf consumption is by the fourth and fifth instars. Larvae
will drop from the leaf or stem on a silken thread when threatened. The
fifth-instar spins a very loose web of silk on the leaf or stem and
pupates beneath it. There is no cocoon protecting the pupa, and there
has been no diapause[^3] observed. The life cycle takes approximately
23-24 days at 27 º C. Eggs hatch in 7 days, larvae pupate in 10-11 days,
and pupae develop to adults in 5-7 days. Females lay a few eggs during
the first night after emergence as adults, but most eggs are laid on the
second night. Realized fecundity (eggs laid) varied greatly in the
laboratory with a range in one test of 0 to 219 eggs. The median for 15
females was 101 eggs.

Dispersal of *N. conspurcatalis* has not been formally studied in the
field or the laboratory. However, in northern Australia, the moth is
often the first herbivore (plant feeder) to recolonize stands of *L.
microphyllum* following flooding or bushfires. This suggests that it
readily disperses within its environment. In the laboratory, *N.
conspurcatalis* adults are able to fly. The wide geographic range of the
moth, coupled with the fact that *L. microphyllum* is not very abundant
and is relatively scattered in its native range of northern Australian
and Southeast Asia, suggest that *N. conspurcatalis* may have reasonable
dispersal abilities. The greater abundance of *L. microphyllum* in
Florida (compared to its home range), the frequent on-shore winds, and
the lack of hills or mountains that could block movement may promote the
dispersal of *N. conspurcatalis* after introduction. Ability to disperse
can increase the potential for the agent to establish and spread in the
environment.

*N. conspurcatalis* causes damage to *L. microphyllum* by defoliation.
Only the larval stage causes damage to *L. microphyllum*. Plant
defoliation is expected to slow the growth of *L. microphyllum* even if
it does not kill the vines, and would permit light penetration to
underlying plants, thus encouraging recovery of afflicted habitats. In
laboratory studies, defoliated potted *L. microphyllum* plants regrow
slowly.

**III. Affected Environment**

**A. Areas affected by *L. microphyllum***

*L. microphyllum* climbs over plants, including tall trees, forming
massive walls of vegetation. It forms thick mats on the ground that
displace native plants. Fires can be carried quickly to the tops of
trees by burning fern and then spread by the floating, burning pieces.
Because it reproduces by millions of spores spread by wind and other
physical carriers, new infestations can arise great distances from
existing populations. Young *L. microphyllum* plants are often found on
moist portions (moss collars) of tree buttresses.

In 1973, *L. microphyllum* was limited to small portions of Martin and
Palm Beach Counties along the eastern coast and to some sites in the
inland Highlands County in Florida. By 1993, it had expanded greatly in
Martin and Palm Beach Counties and was also found in Glades County for
an estimated infestation of 11,213 hectares (Pemberton and Ferriter,
1998). In 1997, an estimated 15,892 hectares were infested in 15
counties from coast to coast along the southern half of the Florida
peninsula (Pemberton and Ferriter, 1998). By January 2002, the
infestation was estimated at more than 40,470 hectares and is still
expanding (Pemberton, 2003). The weed is a severe problem in many parks
and preserves in south Florida including Loxahatchee National Wildlife
Refuge, the Panther Refuge, Audubon Corkscrew Sanctuary, J. Dickinson
Park, Fakahatchee Strand Preserve State Park, and Everglades National
Park. First detected in Everglades National Park in 2001, the weed was
found to occupy an estimated 900 hectares of coastal marsh spread over
40 miles (Pemberton, 2003). Among the most invaded communities are
Everglades tree islands. A recent model predicts that *L. microphyllum*
has the potential to occupy most of the cypress swamps and Everglades
tree islands in the southern third of Florida by 2009 (Volin et al*.,*
2004).

In the continental United States, *L. microphyllum* also has the
potential to invade the Gulf Coast of Mexico and southern Texas with its
wind borne spores (Pemberton et al., 2002). A single spore carried by
the wind is capable of starting a new infestation (Lott et al., 2003).

**B. Plants related to *L. microphyllum* and their distribution**

**1. Taxonomically related plants**

*Lygodium* species and other plants related to *L. microphyllum* are the
most likely non-target plant species that could potentially be attacked
by *N. conspurcatalis.* The genus *Lygodium* occurs in tropical areas
with 30-40 species worldwide (Wikström et al., 2002). There is only one
native *Lygodium* species in North America, *L. palmatum*. This species
is state-listed as threatened in Maryland, state-listed as endangered in
Indiana, Michigan, New York, and Vermont, a plant of special concern in
Connecticut and Massachusetts, and a rare plant in Pennsylvania, but is
not federally-listed. There is also an invasive Asian species in the
United States, *L. japonicum*, which Florida considers a noxious weed.

Additional species of *Lygodium* are native to the Caribbean area and
Central and South America. These species could be threatened by natural
dispersal from large *N. conspurcatalis* populations in southern Florida
or by dispersal through trade or transportation. These species include
*L. cubense* Kunth, *L. oligostachyum* (Willd.) Desv., *L. venustum*
Sw., and *L. volubile* Sw.

Pemberton (1998) discussed *Lygodium* and its relationship to other
ferns. The genus *Lygodium* has been placed in the family Schizaeaceae
(Wunderlin and Hansen, 2000), along with two Florida native genera,
*Actinostachys* and *Anemia*. In this EA, the genus *Lygodium* is
included in the family Lygodiaceae, the genus *Anemia* in the family
Anemiaceae, and the genus *Actinostachys* in the family Schizaeaceae,
following the classification scheme of Wagner and Smith (1993).

There are six species of pineland ferns in the genus *Anemia* in North
America and Puerto Rico: *Anemia adiantifolia* (L.) Swarz, *Anemia
hirsuta* (L.) Sw., *Anemia hirta* (L.) Sw., *Anemia mexicana* Klotzsch,
*Anemia portoricensis* Maxon, and *Anemia wrightii* Baker. There is one
North American species within the genus *Actinostachys, A. pennula*
(Swartz) Hooker (also considered by some authors to be *Schizaea
pennula* Swartz). There are four other species of *Schizaea* in North
America: *S. fluminensis* Miers ex Sturm, *S. poeppigiana* Sturm, *S.
pusilla* Pursh, and *S. robusta* Baker.

**2. Distribution**

*Lygodium palmatum* is a temperate species ranging along the Appalachian
Mountains throughout the eastern United States. It is generally local
and rare except for the Cumberland Plateau of Kentucky and Tennessee
where it is locally abundant in poorly drained, acidic soils, especially
after disturbance. It occurs in woods, thickets, and bog margins in
humus-rich, acid soils (Naumann, 1993). The southernmost limits appear
to be northeastern Alabama (Cherokee County) and near Charleston, South
Carolina (probably from ornamental plantings). Its presence in Florida
has never been confirmed and is doubtful (Nelson, 2000).

*Lygodium japonicum* occurs in Asia and Queensland, Australia (Ferriter
2001). In the United States it is naturalized in the warmer regions of
all coastal states from Texas to Virginia including the southern part of
Arkansas. It occurs in wet woods, marshes, roadside ditches, riverbanks,
and other wet, disturbed sites (Naumann, 1993).

Pemberton (1998) has reported the following *Lygodium* distributions:

*L. cubense* occurs in Cuba, *L. heterodoxum* occurs in southeastern
Mexico and Central America, *L. oligostachyum* occurs in Cuba and
Hispaniola, *L. venustum* occurs in southwestern Brazil though South
America, Central America, Cuba, Grenada, Hispaniola, Jamaica, Mexico,
and Trinidad, and *L. volubile* occurs in northern Argentina to northern
South America, Cuba, Guatemala, Jamaica, and Trinidad.

*Actinostachys* (*Schizaea*) *pennula* is reported only from Dade and
Palm Beach Counties at the tip of the Florida peninsula and from
Pinellas County near Tampa in damp forests and open baylands (Naumann,
1993).

*Schizaea pusilla* is reported from Delaware, New Jersey, and New York
in the United States and from New Brunswick, New Caledonia, and
Newfoundland in Canada, occurring in bogs, wet, sandy depressions, and
crevices of ledges along shores (Naumann, 1993). *S. fluminensis* and
*S. poeppigiana* are reported from Puerto Rico. *S. robusta* is reported
from Hawaii.

*Anemia wrightii* is reported in the U.S. only from Dade County,
Florida, on the tip of the peninsula. *A. adiantifolia* is reported from
the four southernmost counties on the Florida peninsula plus the
contiguous Palm Beach and Martin Counties and from three contiguous
central counties along the coast: Citrus, Hernando, and Levy. It occurs
in open to lightly shaded, rocky slopes and in hammocks and pine woods,
often on limestone (Naumann, 1993). *A. mexicana* is reported only from
Texas in lightly shaded limestone outcrops of the Edwards Plateau
(Naumann, 1993). *A. hirsuta, A. hirta*, and *A. portoricensis* are
reported from Puerto Rico.

**IV. Environmental Consequences**

**A. No Action**

**1. Impact of spread of *L. microphyllum***

*Lygodium microphyllum* grows in wetland and mesic habitats including
hammocks, cypress swamps, flatwoods, bayheads, and disturbed sites.

Once established, *Lygodium* climbs and blankets other vegetation,
ultimately causing mortality to mature canopy and subcanopy trees in the
case of *L. microphyllum* (Roberts, 1996; 1997). Sometimes, *Lygodium*
covers other vegetation so completely, it is not possible to see other
plants beneath it (Pemberton and Ferriter, 1998). Near the ground
surface, a thick mat of old and new fronds also forms that kills native
plants by light deprivation, including herbs and tree seedlings that
would ordinarily maintain the forest canopy if allowed to mature. Rare
plant species such as the tropical curlygrass fern (*Actinostachys*
*pennula*) are severely imperiled by the spread of *L. microphyllum*
into their last remaining habitats, such as the northern Everglades tree
islands. Effects of *Lygodium* on native wildlife appear to be
significant, but are in need of investigation" (Ferriter, 2001).

Pemberton and Ferriter (1998) predicted the fern would spread northward
in Florida along the coasts within the boundaries of USDA hardiness Zone
9A. The confirmation by Pemberton (2003) of *L. microphyllum* in Orange
County, Florida (Zone 9A) supports this prediction. Volin et al. (2004)
predict that *L. microphyllum* will spread to most of south Florida by
2014. This model predicts that the climbing fern has the potential to
occupy most of the cypress swamps and Everglades tree islands in the
southern third of Florida by 2014. These communities represent about 30%
of the Greater Everglades Ecosystem. The model predicts that about 30%
of the land area in the southern part of Florida could be infested.
Goolsby (2004) used the climate-matching program CLIMEX to predict the
potential distribution of *L. microphyllum* in North and South America.
The CLIMEX model was fitted from climate data from the known
distribution of the fern in the Old World. The CLIMEX model was based on
intensive surveys for the plant near its ecoclimatic limits in China and
Australia. The model predicts that climate is suitable for further
expansion of *L. microphyllum* northwards into central Florida and
southward into large parts of the Caribbean, Central and South America.
Current occurrence in central Florida and USDA hardiness zone
information also suggests that the climbing fern has the potential to
invade the Gulf Coast of Mexico and southern Texas with its wind borne
spores (Pemberton et al., 2002; Pemberton, 2003). *Lygodium
microphyllum's* gametophytes have been recently found to be self
fertile, which means that a single spore carried by the wind is capable
of starting a new infestation (Lott et al., 2003).

**2. Impact from use of other control methods**

[Chemical control]{.underline}

The continued use of chemical herbicides and mechanical controls at
current levels would be a result if the "no action" alternative is
chosen. In addition to being expensive to agencies that manage *L.
microphyllum*, control tactics based entirely on the use of herbicides
can lead to negative environmental side effects including undesirable
chemical residues both in the ecosystem (soil, water) as well as adverse
effects on non-target organisms. Herbicides and cutting of vines only
provide temporary weed suppression, and in addition to being expensive,
they can cause a great deal of non-target damage, and spread spores to
new locations. Ferriter (2001) summarizes current control efforts and
reports that various herbicides have given excellent control of the
vines but that regrowth and non-target damage usually occurs. Herbicides
disussed included glyphosate (Rodeo®), triclopyr (Pathfinder ®,
Garlon®), 2,4-D (Weedar®, Vanish®), fosamine (Krenite®), and imazapyr
(Arsenal ®)

[Mechanical control]{.underline}

Cutting vines will result in death of the vines above the cut location,
but will not kill the lower portion of the plant. Regrowth will occur
after physical removal (hand-pulling) or burning. Use of heavy equipment
has limited value because site access is often limited, and equipment
can disturb soils and non-target vegetation and transport spores to new
locations. Flooding does not kill established vines but seems to

prevent germination of spores on flooded soils.

These environmental consequences may occur even with the implementation
of the biological control alternative, depending on the efficacy of *N.
conspurcatalis* to reduce *L. microphyllum* in Florida.

**B. Issue the permit for environmental release**

**1. Impact of *N. conspurcatalis* on non-target plants**

The target weed *L. microphyllum* is the only known host of *N.
conspurcatalis* in its native range. Research demonstrated that *N.
conspurcatalis* was found to be specific to the genus *Lygodium.* In
choice and no choice host specificity tests conducted in Australia and
Florida (Pemberton and Goolsby, 2005) the moth was able to complete
development only on the target weed, *L. microphyllum*, another invasive
weed -- the Japanese climbing fern (*L. japonicum*), and the native
North American climbing fern (*L. palmatum*). None of the four native
*Lygodium* species that occur in the Caribbean supported development of
the moth. No development occurred on any of the other test plants which
included 46 species of ferns belonging to 25 genera and 18 families (see
Appendix 1 for a list of plants tested).

The native climbing fern *L. palmatum* supported development of *N.
conspurcatalis.* However, the moth is a tropical-subtropical species
currently limited to Florida, whereas *L. palmatum* is a temperate
species occurring north of Florida. This indicates that it is unlikely
that the moth will be unable to live where this native fern occurs. The
CLIMEX model predicts that the northeast coast of Florida will be the
most northerly area where *L. microphyllum* can live in the United
States (Goolsby, 2004). *Lygodium* *japonicum*, which supported full
development of the moth, ranges farther north into Virginia, which is in
Plant Hardiness Zone 7 (USDA, ARS, 1990). Lethal lower limit temperature
studies of *N. conspurcatalis* found no survival at -7^o^C. (Pemberton
and Goolsby, 2005). This indicates that the moth should be restricted to
Plant Hardiness Zones 10, 9b, and perhaps 9a (USDA, ARS, 1990).
Hardiness Zone 8a is the warmest zone that the native *L. palmatum* is
known to occur, which is too cold for *N. conspurcatalis.* There has
been no indication of a winter diapause in the field; the moth is active
throughout the year in its native region. Stress tests of moths exposed
to simulated winter temperature minimums corresponding to Charleston,
South Carolina, the southern limits of *L. palmatum* distribution, were
conducted. Results demonstrated the moth's inability to survive in this
8b zone (Goolsby and Pemberton, 2004). All but a few *L. palmatum*
populations occur in Appalachia, the Midwest (Indiana and Michigan) and
New England, that are too cold for establishment of *N. conspurcatalis*.

*N. conspurcatalis* is specific to only three species in the genus
*Lygodium*: the target *L. microphyllum,* *L. japonicum, and L.
palmatum.* No other fern including the nearest non-*Lygodium* ferns,
*Actinostachys* and *Anemia* species, supported development of *N.
conspurcatalis.* The lack of larval development on the four species of
Caribbean *Lygodium* indicates that *N. conspurcatalis* poses no danger
to those plants even if the moth is able to migrate to those areas. On
the contrary, the moth might be a potential control agent, if the
climbing fern invades the Caribbean islands which are climatically
suitable for the weed.

**2. Uncertainties Regarding the Environmental Release of *N.
conspurcatalis***

Once a biological control agent such as *N. conspurcatalis* is released
into the environment and becomes established, there is a slight
possibility that it could move from the target plant (*L. microphyllum*)
to attack nontarget plants, such as native *L. palmatum*. Host shifts by
introduced weed biological control agents to unrelated plants are rare
(Pemberton, 2000). Native species that are closely related to the target
species are the most likely to be attacked (Louda et al., 2003). If
other plant species were to be attacked by *N. conspurcatalis*, the
resulting effects could be environmental impacts that may not be easily
reversed. Biological control agents such as *N. conspurcatalis*
generally spread without intervention by man. In principle, therefore,
release of this biological control agent at even one site must be
considered equivalent to release over the entire area in which potential
hosts occur and in which the climate is suitable for reproduction and
survival. Post- release evaluations of *N. conspurcatalis* populations
and their effects on *L. microphyllum* and other non-target species will
be conducted by ARS researchers.

In addition, these agents may not be successful in reducing *L.
microphyllum* populations in the continental United States. Worldwide,
biological weed control programs have had an overall success rate of 33
percent; success rates have been considerably higher for programs in
individual countries (Culliney, 2005). Actual impacts on *L.
microphyllum* by *N. conspurcatalis* will not be known until after
release occurs and post-release monitoring has been conducted.

**3. Cumulative Impacts**

"Cumulative impacts are defined as the impact on the environment which
results from the incremental impact of the action when added to other
past, present and reasonably foreseeable future actions regardless of
what agencies or person undertakes such other actions" (40 CFR 1508.7).

[Management of *L. microphyllum* in Florida]{.underline}

Since 1998, Florida's Department of Environmental Protection, Bureau of
Invasive Plant Management, Upland Invasive Plant Management Program, has
controlled more than 14,000 acres of *Lygodium japonicum* and *Lygodium
microphyllum* at a cost of approximately \$8.2 million (DEP, BIPM,
2006). This acreage does not include work done by federal and local
governments. The Lygodium Strike Team is comprised of experienced weed
control specialists under contract with the Bureau. They are prepared to
provide either foliar applications or "poodle-cuts" (cut vines 4-5 feet
up from the ground and apply herbicide to the rooted portion of the
plant). The Florida Department of Environmental Protection is planning
increased effort for aerial spraying of herbicides to attempt to reduce
*L. microphyllum* infestations in Loxahatchee National Wildlife Refuge.
State level chemical control efforts have been made on conservation
lands within the Everglades region managed by the SFWMD. Florida State
parks and refuges in southern Florida have used both aerial and ground
based herbicide applications in attempts to control the weed. Everglades
National Park has been treating *L. microphyllum* infestations within
the park with aerial applications of herbicides for about 5 years and
these efforts continue. Various levels of government including State of
Florida and Counties are assisting the control of *L. microphyllum* on
private lands.

The only biological control agent for *L. microphyllum* to be released
to date (*Austromusotima camptozonale*) has not definitively established
in Florida. The moth was first released during February 2005 and
releases involving about 15,000 individuals per year have been made in
2005, 2006 and 2007 in Martin and Palm Beach Counties. At some release
sites the moths bred for several generations after being released, but
no evidence of persistence of the moths was acquired after the hot rainy
summer periods. The second approved biological control agent, a gall
mite named *Floracarus perrepae*, was permitted for release in December,
2006. Field releases to attempt to colonize the mite will begin during
the spring or early summer 2007 (R. Pemberton, pers. comm.).

Release of *N. conspurcatalis* will have no negative cumulative impacts
in the continental United States because of its host specificity to *L.
microphyllum*. Effective biological control of *L. microphyllum* will
have beneficial effects to current Everglades restoration activities and
*L. microphyllum* management activities, and may result in a long-term,
non-damaging method to control *L. microphyllum* in south Florida, and
prevent its spread into other areas potentially at risk from invasion.

**4. Endangered Species Act**

Section 7 of the Endangered Species Act (ESA) and ESA's implementing
regulations require Federal agencies to ensure that their actions are
not likely to jeopardize the continued existence of federally listed
threatened endangered species or result in the destruction or adverse
modification of critical habitat.

There are 23 federally listed ferns and fern allies in the United
States. Most of these species occur in Hawaii and Puerto Rico, but some
occur in Alaska, Alabama, Georgia, Florida, South Carolina, Louisiana,
Mississippi, Michigan, NewYork, and Tennessee. None of these species are
related to *Lygodium* ferns.

*N. conspurcatalis* is able to develop on only three *Lygodium* species
as host plants and it will not attack any federally listed threatened or
endangered plant species. The moth is a tropical-subtropical species
known only to attack *L. microphyllum* in its native Australia and
Southeast Asia home range. In host specificity testing, *N.
conspurcatalis* was able to complete its life cycle only on three
*Lygodium* species; the target weed (*L. microphyllum*), *L*.
*japonicum*, and the native *L. palmatum*.

North America: *N. conspurcatalis* occurs only in subtropical and
tropical Australia and Asia. Studies examining the moth's ability to
survive at lower temperatures indicate that it will be unable to survive
in USDA cold hardiness zone 8b (Pemberton and Goolsby, 2005). The six
federally listed North American ferns and fern allies (*Thelypteris
pilosa* var. *alabamensis*, *Polystichum aleuticum, Asplenium
scolopendrium* var. *americanum, Isoetes melanospora, I. louisianensis,
and I. tegetiformans*) live in colder zones than those where the moth
can survive. In addition, the host specificity is limited to the genus
*Lygodium*, which is unrelated to any federally listed threatened or
endangered plant in the continental United States.

Puerto Rico and the Virgin Islands: The climate in this area is suitable
for the moth but there is no likely pathway from Florida to Puerto Rico
and the Virgin Islands. This biological control agent will not be
released in Puerto Rico or the Virgin Islands. No ferns or fern allies
are federally listed in the Virgin Islands but eight are listed in
Puerto Rico (*Adiantum vivesii, Cyathea dryopteroides, Elaphoglossum
serpens, Polystichum calderonense, Tectaria estremerana,* *Thelypteris
inabonensis, T. verecunda,* and *T. yaucoensis*). However, none of these
plants are related to *L. microphyllum*.

Hawaii: Ten federally listed ferns and allies occur in Hawaii
(*Asplenium fragile* var. *insulare, Diellia falcata, D. pallida, D.
erecta, D. unisora*, *Diplazium molokaiense, Adenophorus periens,
Marsilea vilosa, Pteris ligatei,* and *Ctenitis squamigera*). None of
these species are related to *L. microphyllum.* The climate of Hawaii is
suitable for *N. conspurcatalis* but natural or purposeful spread from
Florida to Hawaii would be unlikely. *L.* *microphyllum* does not occur
in Hawaii and there are no native *Lygodium* species in Hawaii. *L.
japonicum*, which is a potential host of the moth, occurs sparingly as a
naturalized plant on Hawaii so might be able to support modest
populations of the moth. There would be no effect on federally listed
threatened or endangered plants because of the specificity of the moth
to *Lygodium*.

APHIS has determined that *N. conspurcatalis* will have no effect on any
threatened or endangered plant species because of the very limited host
range of the moth, the taxonomic separation between the target weed and
listed ferns and fern allies, the inability of the moth to live in the
climatic zones where North American listed ferns and fern allies occur,
and the geographic distance of Florida from Puerto Rico and Hawaii,
where other federally listed ferns and fern allies occur.

**V. Other Issues**

Number range CHAPTERConsistent with Executive Order (EO) 12898, "Federal
Actions to Address Environmental Justice in Minority Populations and
Low-income Populations," APHIS considered the potential for
disproportionately high and adverse human health or environmental
effects on any minority populations and low-income populations. There
are no adverse environmental or human health effects from the field
release of *N. conspurcatalis* and will not have disproportionate
adverse effects to any minority or low-income populations.

Consistent with EO 13045, "Protection of Children From Environmental
Health Risks and Safety Risks," APHIS considered the potential for
disproportionately high and adverse environmental health and safety
risks to children. No circumstances that would trigger the need for
special environmental reviews is involved in implementing the preferred
alternative. Therefore, it is expected that no disproportionate effects
on children are anticipated as a consequence of the field release of *N.
conspurcatalis*.

Number range CHAPTER**VI.** Number range CHAPTER**Agencies,
Organizations, and Individuals Consulted**

The Technical Advisory Group for the Biological Control Agents of Weeds
(TAG) recommended the release of *Neomusotima conspurcatalis* on March
21, 2006. TAG members that reviewed the release petition (Pemberton and
Goolsby, 2005) included representatives from the U.S. Fish and Wildlife
Service, Bureau of Indian Affairs, Cooperative State Research,
Education, and Extension Service, National Park Service, Environmental
Protection Agency, Bureau of Land Management, U.S. Forest Service, the
U.S. Army Corps of Engineers, Bureau of Reclamation, Florida Natural
Areas Inventory, California Department of Food and Agriculture, Oregon
Department of Agriculture, Agriculture and Agri-Food Canada,
Environmental Health Canada, Health Canada.

This EA was prepared and reviewed by APHIS and ARS. The addresses of
participating APHIS units, cooperators, and consultants (as applicable)
follow.

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Policy and Program Development

Environmental Services

4700 River Road, Unit 149

Riverdale, MD 20737

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Permits, Registrations, Imports, and Manuals

4700 River Road, Unit 133

Riverdale, MD 20737

U.S. Department of Agriculture

Agricultural Research Service

Invasive Plant Research Laboratory

3225 College Ave.

Ft. Lauderdale, FL 33312

**VII. References**

Culliney, T.W. 2005. Benefits of classical biological control for
managing invasive plants. Critical Reviews in Plant Sciences.
24(2):131--150.

DEP, BIPM−see Department of Environmental Protection, Bureau of Invasive
Plant Management

Department of Environmental Protection, Bureau of Invasive Plant
Management. 2006. Lygodium Strike Team
<http://www.dep.state.fl.us/lands/invaspec/3rdlevpgs/Lygodiumstrike.htm>
*last accessed* March 27, 2007.

Ferriter, A., (Ed.). 2001. *Lygodium* management plan for Florida.
Florida Exotic Pest Plant Council\'s *Lygodium* Task Force. West Palm
Beach, Florida. 51 pp. (copies can be obtained from LeRoy Rogers, South
Florida Water Management District, 3301 Gun Club Road, West Palm beach,
FL 33416.)

Goolsby, J.A. and R.W. Pemberton. 2005. Proposed field release of the
Australian *Floracarus perrepae* Knihinicki & Boczek (Acariformes:
Eriophyidae), a leaf roll galler of the Old World climbing fern,
*Lygodium microphyllum* (Cav.) R. Br. (Pteridophyta: Lygodiaceae) in
Florida. On file at the U.S. Department of Agriculture, Agricultural
Research Service Biological Control Documentation Center, National
Agricultural Library, Beltsville, Maryland, USA. Release petition
submitted to the Technical Advisory Group for Biological Control Agents
of Weeds.

Goolsby, J.A. 2004. Potential distribution of the invasive Old World
climbing fern, *Lygodium microphyllum*, in North and South America.
Natural Areas Journal. 24: 351--353.

Goolsby, J.A., T. Wright, and R.W. Pemberton. 2003. Exploratory surveys
in Australia and Asia for natural enemies of Old World climbing fern,
*Lygodium microphyllum*: Lygodiaceae. Biological Control. 28: 33--46.

Lott, M.S., J.C. Volin, R.W. Pemberton, and D.F. Austin. 2003. The
reproductive biology of *Lygodium microphyllum* and *L. japonicum*
(Schizaeceae): implications for invasive potential. American Journal of
Botany. 90: 1144--1152.

Louda, S.M., R.W. Pemberton, M.T. Johnson, and P.A. Follett. 2003.
Nontarget effects−The Achilles' heel of biological control?
Retrospective analyses to reduce risk associated with biological control
introductions. Annual Review of Entomology. 48: 365--396.

Naumann, C.E., 1993. Lygodiaceae C. Presl. Climbing ferns, *In*: Flora
of North America Editorial Committee, Flora of North America North of
Mexico, Volume 2, Pteridophytes and Gymnosperms. Oxford Univ. Press,
N.Y., pp. 114--116.

Nelson, G., 2000. The Ferns of Florida, A Reference and Field Guide,
Pineapple Press, Sarasota, Florida.

Pemberton, R.W. 1998. The potential of biological control to manage Old
World climbing fern (*Lygodium microphyllum*), an invasive weed in
Florida. American Fern Journal. 88: 176--182.

Pemberton, R.W. and A. Ferriter. 1998. Old World climbing fern
(*Lygodium microphyllum*); a dangerous weed in Florida. American Fern
Journal. 84: 165--175.

Pemberton, R.W. 2000. Predictable risk to native plants in weed
biological control. Oecologia. 125: 489--494.

Pemberton, R.W., J.A. Goolsby, and T. Wright. 2002. Old World climbing
fern, *In*: R. Van Driesche, B. Blossey, M. Hoddle, S. Lyon, and R.
Reardon (Eds.), Biological Control of Invasive Plants in the Eastern
United States, USDA-FS, FHTET-2002-04, Morgantown, West Virginia, U.S.,
pp. 139--147.

Pemberton, R.W*.* 2003. Northern range extension in Florida of the
invasive fern *Lygodium microphyllum* (Lygodiaceae). Sida. 20:
1759--1761.

Pemberton, R.W. and J.A. Goolsby. 2005. Proposed field release of
*Neomusotima* *conspurcatalis* (Warren) (Lepidoptera: Crambidae), a
defoliator of the Australian Old World climbing fern, *Lygodium
microphyllum* (Cav.) R. Br. (Lygodiaceae) in Florida. (Petition to
release a biological control agent). On file at the U.S. Department of
Agriculture, Agricultural Research Service Biological Control
Documentation Center, National Agricultural Library, Beltsville,
Maryland, USA. (Petition to release a biological control agent).

Solis, M.A., S-H. Yen, and J.A. Goolsby. 2004. Species of *Lygomusotima*
New Genus, and *Neomusotima* Yoshiyasu (Lepidoptera: Crambidae) from
Australia and Southeastern Asia feeding on *Lygodium microphyllum*
(Schizaeaceae). Annals of the Entomological Society of America. 97:
64--76.

U.S. Fish and Wildlife Service. 1999. South Florida multi-species
recovery plan. Atlanta, GA. 2172 pp.

United States Department of Agriculture, Agricultural Research Service.
1990. USDA Plant Hardiness Zone Map. USDA, ARS Misc. Publ. No. 1475.
Washington, DC.

Volin, J.C., M.S. Lott, J.D. Muss, and D. Owen. 2004. Predicting rapid
invasion of the Florida Everglades by Old World climbing fern (*Lygodium
microphyllum*). Diversity and Distributions. 10: 439--446.

Wagner, W.H., Jr., and A.R. Smith. 1993. Pteridophytes. In: Flora of
North America Editorial Committee, Flora of North America North of
Mexico, Volume 1, Introduction. Oxford Univ. Press, N.Y., pp. 247--266.

Wikström, N., P. Kenrick, and J.C. Vogel. 2002. Schizaeaceae: a
phylogenetic approach. Review of Palaeobotany and Palynology. 119:
35--50.

Wunderlin, R.P. and B.F. Hansen. 2000. Flora of Florida, Vol. 1,
Pteridophytes and Gymnosperms. University Press of Florida, Gainesville,
Florida.

**Appendix 1.** Plants tested for host specificity to *N.
conspurcatalis* (Pemberton and Goolsby, 2005). Species in bold are
plants native to Florida.

+--------------+-----------------------------+------------------------+
| **[Plant     | **[Test Plant               | **[Common name of test |
| Family]{.    | Species]{.underline}**      | plants]{.underline}**  |
| underline}** |                             |                        |
+--------------+-----------------------------+------------------------+
| Pteridophyta |                             |                        |
+--------------+-----------------------------+------------------------+
| Lygodiaceae  | *Lygodium microphyllum* FL  | Old World climbing     |
|              |                             | fern                   |
+--------------+-----------------------------+------------------------+
| Lygodiaceae  | *Lygodium japonicum*        | Japanese climbing fern |
|              | (Thunb.) Sw.                |                        |
+--------------+-----------------------------+------------------------+
| Lygodiaceae  | *Lygodium palmatum*         | American climbing fern |
|              | (Bernhardi) Swartz          |                        |
+--------------+-----------------------------+------------------------+
| Lygodiaceae  | *Lygodium oligostachyum*    | none                   |
|              | (Willdenow) Desv.           |                        |
+--------------+-----------------------------+------------------------+
| Lygodiaceae  | *Lygodium venustum* Sw.     | none                   |
+--------------+-----------------------------+------------------------+
| Lygodiaceae  | *Lygodium cubense* Kunth    | Cuban climbing fern    |
+--------------+-----------------------------+------------------------+
| Lygodiaceae  | *Lygodium volubile* Sw.     | none                   |
+--------------+-----------------------------+------------------------+
| Anemiaceae   | ***Anemia adiantifolia*     | pine fern              |
|              | (L.) Swartz**               |                        |
+--------------+-----------------------------+------------------------+
| Anemiaceae   | ***Anemia wrightii* Baker** | Wright's pineland fern |
+--------------+-----------------------------+------------------------+
| Aspleniaceae | ***Asplenium platyneuron*   | ebony spleenwort       |
|              | (L.) Britton, Sterns, &     |                        |
|              | Poggenburg**                |                        |
+--------------+-----------------------------+------------------------+
| Aspleniaceae | ***Asplenium scolopendrium* | Hart's-tongue fern     |
|              | L.**                        |                        |
+--------------+-----------------------------+------------------------+
| Aspleniaceae | ***Asplenium nidus L.***    | bird's-nest fern       |
+--------------+-----------------------------+------------------------+
| Azollaceae   | ***Azolla caroliniana*      | mosquito fern          |
|              | Willdenow**                 |                        |
+--------------+-----------------------------+------------------------+
| Blechnaceae  | ***Blechnum serrulatum*     | swamp water fern       |
|              | Richard**                   |                        |
+--------------+-----------------------------+------------------------+
| Blechnaceae  | ***Woodwardia areolata*     | netted/narrow leaf     |
|              | (L.) T. Moore**             | chain fern             |
+--------------+-----------------------------+------------------------+
| Blechnaceae  | ***Woodwardia virginica     | Virginia chain fern    |
|              | (*L.) Smith**               |                        |
+--------------+-----------------------------+------------------------+
| Cyatheaceae  | *Cyathea cooperi* (F. J.    | Australian tree fern   |
|              | Muell.) Domin               |                        |
+--------------+-----------------------------+------------------------+
| Denn         | ***Pteridium aquilinum*     | bracken fern           |
| staedtiaceae | (L.) Kuhn**                 |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ***Athyrium filix-femina*   | Lady fern              |
| opteridaceae | Roth**                      |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ***Ctenitis sloanei*        | Florida tree fern      |
| opteridaceae | (Poeppig ex Sprengel) C. V. |                        |
|              | Morton**                    |                        |
+--------------+-----------------------------+------------------------+
| Dry          | *Cyrtomium falcatum* (L.f.) | Japanese holly fern    |
| opteridaceae | C. Presl                    |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ***Dryopteris ludoviciana*  | Southern Wood fern     |
| opteridaceae | (Kunze) Small**             |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ***Polystichum              | Christmas fern         |
| opteridaceae | acrostichoides* (Michaux)   |                        |
|              | Schott**                    |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ######### *Rumohra adian    | ######                 |
| opteridaceae | tiformis* (G. Forst) Ching  | ### leather leaf fern  |
+--------------+-----------------------------+------------------------+
| Dry          | ***Tectaria fimbriata*      | least halberd          |
| opteridaceae | (Willdenow) Proctor &       |                        |
|              | Lourteig**                  |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ***Tectaria heracleifolia*  | broad halberd          |
| opteridaceae | (Willdenow) L. Underwood**  |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ***Nephrolepis biserrata*   | giant sword fern       |
| opteridaceae | (Swartz) Schott**           |                        |
+--------------+-----------------------------+------------------------+
| Dry          | *Nephrolepis cordifolia*    | tuberous sword fern    |
| opteridaceae | (L.) C. Presl               |                        |
+--------------+-----------------------------+------------------------+
| Dry          | ***Nephrolepis exaltata*    | wild Boston fern       |
| opteridaceae | (L.) Schott**               |                        |
+--------------+-----------------------------+------------------------+
| Equisetaceae | ***Equisetum hyemale* L.**  | rough horsetail        |
+--------------+-----------------------------+------------------------+
| Marsileaceae | *Marsilea vestita* Hooker & | water clover           |
|              | Greville                    |                        |
+--------------+-----------------------------+------------------------+
| Oph          | ***Ophioglossum petiolatum* | slender adders-tongue  |
| ioglossaceae | Hooker**                    |                        |
+--------------+-----------------------------+------------------------+
| Osmundaceae  | ***Osmunda cinnamomea* L.** | cinnamon fern          |
+--------------+-----------------------------+------------------------+
| Osmundaceae  | ***Osmunda regalis* L.**    | royal fern             |
+--------------+-----------------------------+------------------------+
| P            | ***Phlebodium aureum* (L.)  | goldfoot fern          |
| olypodiaceae | J. Smith**                  |                        |
+--------------+-----------------------------+------------------------+
| P            | *Platycerium bifurcatum*    | staghorn fern          |
| olypodiaceae | (Cav.) C.Chr.               |                        |
+--------------+-----------------------------+------------------------+
| P            | ***Pleopeltis               | resurrection fern      |
| olypodiaceae | polypodioides* (L.) E.G.    |                        |
|              | Andrews & Windham**         |                        |
+--------------+-----------------------------+------------------------+
| Pteridaceae  | ***Adiantum                 | southern maidenhair    |
|              | capillus-veneris* L.**      | fern                   |
+--------------+-----------------------------+------------------------+
| Pteridaceae  | ***Pteris bahamensis* (J.   | Bahama ladder brake    |
|              | Agardh) Fee**               |                        |
+--------------+-----------------------------+------------------------+
| Pteridaceae  | *Pteris vittata*            | Chinese Ladder brake   |
+--------------+-----------------------------+------------------------+
| Salviniaceae | *Salvinia minima* Baker     | water fern             |
+--------------+-----------------------------+------------------------+
| Schizaeaceae | ***Actinostachys pennula*   | ray spiked fern        |
|              | (Swartz) Hooker**           |                        |
+--------------+-----------------------------+------------------------+
| Sel          | *Selaginella pallescens*    | peacock fern           |
| aginellaceae | Spring                      |                        |
+--------------+-----------------------------+------------------------+
| Sel          | *Selaginella uncinata*      | blue spike-moss        |
| aginellaceae | (Desvauxex Poiret) Spring   |                        |
+--------------+-----------------------------+------------------------+
| Thel         | ***Thelypteris kunthii*     | Southern shield fern   |
| ypteridaceae | (Desvaux) C.V. Morton**     |                        |
+--------------+-----------------------------+------------------------+
| ########     |                             |                        |
|              |                             |                        |
| ########     |                             |                        |
|  Gymnosperms |                             |                        |
+--------------+-----------------------------+------------------------+
| Taxodiaceae  | ***Taxodium distichum* (L.) | bald-cypress           |
|              | Richard**                   |                        |
+--------------+-----------------------------+------------------------+
| *            |                             |                        |
| Angiosperms* |                             |                        |
+--------------+-----------------------------+------------------------+
| Poaceae      | *Oryza sativa* L.           | Rice                   |
+--------------+-----------------------------+------------------------+
| Poaceae      | *Saccharum officinarum* L.  | sugarcane              |
+--------------+-----------------------------+------------------------+
| Rutaceae     | *Citrus sinensis (L.)       | orange                 |
|              | Osbeck* Macf.               |                        |
+--------------+-----------------------------+------------------------+

[^1]: ^1^ Regulations implementing the National Environmental Policy Act
    of 1969 (42

    United States Code 4321 *et seq.*) provide that an environmental
    assessment "\[shall include brief discussions of the need for the
    proposal, of alternatives as required by section 102(2)(E), of the
    environmental impacts of the proposed action and alternatives, and a
    listing of agencies and persons consulted." 40 CFR § 1508.9.

[^2]: Other authors consider the plant to belong to the plant family
    Schizaeceae that includes several additional genera, such as
    *Achinostachys* and *Anemia*.

[^3]: ^3^ A period during which growth or development is suspended and
    metabolic rate is reduced; a period of dormancy not immediately
    referable to adverse environmental conditions.