United States 

Department of 

Agriculture Field Release of the 

Parasitoid Spathius 

galinae for the Biological 

Control of the Emerald 

Ash Borer (Agrilus 

planipennis) in the 

Continental United 

States

Environmental Assessment,

November 2014

Marketing and 

Regulatory 

Programs

Animal and 

Plant Health 

Inspection 

Service
Field Release of the Parasitoid 

Spathius galinae for the for the 

Biological Control of the 

Emerald Ash Borer (Agrilus 

planipennis) in the Continental 

United States

Environmental Assessment,

November 2014

Agency Contact: 

Shirley Wager-Page, Ph.D.

Pest Permitting

Plant Protection and Quarantine

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road, Unit 133

Riverdale, MD 20737–1236
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Table of Contents

I. Purpose and Need for the Proposed Action................................. 1

II. Alternatives ................................................................................. 2

III. Affected Environment................................................................. 8

IV. Environmental Consequences................................................. 10

V. Other Issues ............................................................................. 20

VI. Agencies, Organizations, and Individuals Consulted............... 22

VII. References ............................................................................. 23
I. Purpose and Need for the Proposed 

Action

The U.S. Department of Agriculture (USDA), Animal and Plant Health 

Inspection Service (APHIS), Plant Protection and Quarantine (PPQ), Pest 

Permitting Branch is proposing to issue permits for release of the insect 

parasitoid1 species Spathius galinae (S. galinae) Belokobylskij & Strazanac

(Hymenoptera: Braconidae). This organism would be used by the permit

applicant for biological control of the nonindigenous emerald ash borer 

(EAB) (Agrilus planipennis) in the continental United States. 

This environmental assessment2 (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 the parasitoid wasp, S. galinae, to 

control EAB within the continental United States. This EA considers a “no 

action” alternative and the potential effects of the proposed action.

The applicant’s purpose for releasing S. galinae is to reduce infestations of 

EAB in the continental United States. The EAB is an invasive wood-boring

beetle from Asia threatening North America’s ash trees (Fraxinus spp.). It 

was introduced into the Detroit, Michigan area, probably sometime in the 

1990s, and was identified as the cause of ash mortality in the area in 2002 

(Haack et al., 2002). EAB larvae feed on ash phloem, cutting off the 

movement of resources within the tree and killing the tree in 4-5 years

(Smith, 2006; Knight, 2013). Unlike other Agrilus species that are attracted 

to and attack mainly stressed trees, EAB is able to attack and kill

presumably healthy trees in both natural and urban settings. Today, EAB 

infestations have been detected in 22 states; Colorado, Connecticut,

Georgia, Illinois, Indiana, Iowa, Kansas, Kentucky, Maryland, 

Massachusetts, Michigan, Minnesota, Missouri, New Hampshire, New 

York, North Carolina, Ohio, Pennsylvania, Tennessee, Virginia, West 

Virginia, and Wisconsin. EAB appears well suited for climatic conditions 

in North America and destroys entire stands of ash trees. EAB will 

continue to disperse along continuous corridors of ash now present in 

natural and urban environments due to the widespread use of ash as a 

landscape tree.

1 In this case, small, stingless wasps that during their development, live in the body or egg of a single 

host individual, eventually killing that individual.

2 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. 

1

 
All of the existing EAB management options (discussed below) are 

expensive, temporary, ineffective, and/or include non-target impacts. For 

these reasons, there is a need to identify and release an effective, hostspecific biological control organism against EAB in the continental United 

States. 

II. Alternatives

This section will explain the two alternatives available to APHIS–PPQ: no 

action (no issuance of permits) and issuance of permits for environmental 

release of S. galinae in the continental United States. Although APHIS’ 

alternatives are limited to a decision of whether to issue permits for release 

of S. galinae, other methods are described that are currently used to control 

EAB in the United States. Use of these control methods is not an APHIS 

decision, and their use is likely to continue whether or not APHIS-PPQ 

issued permits for environmental release of S. galinae. 

APHIS–PPQ considered a third alternative but will not analyze it further. 

Under this third alternative, APHIS–PPQ would issue permits for the field 

release of S. galinae. The permits, however, would contain special 

provisions or requirements concerning release procedures or mitigating 

measures, such as limited releases of S. galinae in the United States. There 

are no issues raised indicating that special provisions or requirements are 

necessary.

A. No Action 

Under the no action alternative, APHIS–PPQ would not issue permits for 

the field release of S. galinae for the control of EAB — the release of this 

biological control agent would not occur, and current methods to control 

EAB in the United States will continue. Use of these methods is likely to 

continue even if APHIS–PPQ issues permits for release of S. galinae.

Presently, control of EAB in the United States is limited to physical, 

chemical, and biological control methods.

1. Physical Control

In a forest environment, rapid detection of EAB presence and destruction 

of affected tree materials is the best method to reduce the chance of other 

ash trees being attacked in the area. Dead and dying ash trees should be cut 

down and chipped, burned, or buried on the site.

2
2. Chemical Control

There are several insecticides that may be applied to ash trees; systemic 

insecticides and protective cover sprays. Systemic insecticides are applied 

and translocated throughout the tree. Systemic insecticides including 

imidacloprid, emamectin benzoate, and Bidrin® may be applied as soil 

injections or drenches, or may be injected directly into the tree using 

specialized equipment (Herms et al., 2009). The systemic insecticide 

dinotefuran can be applied to the bark; it is absorbed through the bark and 

distributed throughout the tree (Herms et al., 2009). Protective cover sprays 

using permethrin, bifenthrin, cyfluthrin, or carbaryl, are applied to the bark 

and foliage to target adult beetles or EAB larvae as they chew through the 

bark (Herms et al., 2009). 

3. Biological Control 

Three parasitoids were discovered parasitizing EAB in China and were 

approved as biological control agents of EAB in the United States (Liu et 

al., 2003; 2007). These EAB biocontrol agents are: (1) Oobius agrili, a 

solitary egg parasitoid that has two generations per year (Zhang et al.,

2005; Bauer and Liu, 2007), (2) Tetrastichus planipennisi, a larval 

endoparasitoid that may complete four generations per year and produces 

an average of 57 progeny per EAB larva (Liu et al., 2003; 2007; Yang et 

al., 2006; Ulyshen et al., 2010), and (3) Spathius agrili, a larval 

ectoparasitoid that has two generations per year and produces an average of 

five progeny per EAB larva (Yang et al., 2010; Gould et al., 2011). 

B. Issue Permits for Environmental Release of 

S. galinae (Preferred Alternative)

Under this alternative, APHIS–PPQ would issue permits upon request and 

after evaluation of each application for the field release of S. galinae for the 

control of EAB in the continental United States. These permits would 

contain no special provisions or requirements concerning release 

procedures or mitigating measures.

1. Spathius galinae Taxonomic Information

Spathius galinae is an ectoparasitoid attacking 2nd to 4th instar EAB larvae. 

Oviposition (egg laying) by S. galinae on the EAB larva paralyzes it and 

stops its development beyond the larval stage.

a. Taxonomy: Spathius galinae (Hymenoptera: Braconidae). No 

synonymy or common names.

3
b. Location of voucher specimens. Specimens of S. galinae were 

deposited in the Zoological Institute of the Russian Academy of Sciences, 

St. Petersburg, Russia. Specimens also were deposited in the National 

Museum of Natural History, Smithsonian Institution, Washington, DC, the 

American Museum of Natural History, New York (Belokobylskij et al., 

2012), and at the USDA-Agricultural Research Service (ARS) Beneficial 

Insects Introduction Research Unit.

c. Natural geographic range, other areas of introduction, and expected 

attainable range in North America (also habitat preference and 

climatic requirements of S. galinae). Spathius galinae has been collected 

from Vladivostok and Khaborovsk, Russia and from Daejeon and 

Yangsuri, South Korea (Belokobylskij et al., 2012; Gould and Duan, 2013). 

The insects used to initiate colonies in the United States were all collected 

from EAB populations infesting Fraxinus pennsylvanica trees in the 

Vladivostok area (Duan et al., 2012a). In contrast, the previously 

introduced agent S. agrili was collected primarily from Tianjin, China, and 

it is rare and difficult to collect in Changchun, China. Tianjin, 

approximately 1,000 kilometers south of Vladivostok, is the source of the 

S. agrili population released in the United States. The climatic conditions 

that are most conducive to population growth of S. galinae or S. agrili are 

not explicitly known; therefore, climate matching analyses were conducted 

to determine how similar Vladivostok and Tianjin are with the regions of 

the United States that are infested with EAB. 

The climate matching feature of the climate analysis software CLIMEX 

(Hearne Scientific Software Pty Ltd, Melbourne, Australia) was used. The 

software calculated a Climate Match Index (CMI) that is a measure of the 

degree of similarity between a home location and away locations. The 

index had values between 0, complete dissimilarity, and 1, exact climate 

match. Adult Spathius are only present in the summer, so the adult model 

for matching was restricted to June 4 through September 30 and was based 

on minimum temperature, maximum temperature, total precipitation, 

precipitation pattern, and relative humidity. Because larvae live under 

bark, the larval model for matching was based on minimum temperature, 

maximum temperature, total precipitation, and precipitation pattern for an 

entire year.

Climate matching analyses comparing Vladivostok and Tianjin to the rest 

of Asia indicate that S. agrili and S. galinae come from climatically unique

regions of Asia. Species adapted to one of these conditions are more likely 

to establish and survive well in parts of North America that match these 

climatic conditions than will other species. The climate of Tianjin (the 

source area for S. agrili) is best matched with the climate in the center of 

the United States (larval model – green area in Fig. 1) and the southeastern 

4
United States (adult model – green area in Fig. 2). The areas where 

scientists have released and studied establishment of S. agrili to date are in 

the more northern parts of the United States (Michigan, Ohio, Illinois). At 

these sites, S. agrili does establish, and percentage parasitism after the first 

winter is sometimes high, but after the first year the insects are found in 

very low numbers or not at all. Climate incompatibility and possible 

asynchrony between parasitoid and host could certainly contribute to the 

observed lack of persistence of S. agrili in the northern United States. The 

climate matching analysis indicates that S. galinae may be better adapted

than S. agrili for establishment in the northern United States (green areas in 

Figs. 3 and 4).

Figure 1: Climate match between Tianjin, China (source of S. agrili) and 

North America based on minimum temperature, maximum temperature, 

total precipitation, and precipitation pattern for the entire year (larval 

model).

5
Figure 2: Climate match between Tianjin, China (source of S. 

agrili) and North America based on minimum temperature, 

maximum temperature, total precipitation, and precipitation pattern, 

and relative humidity from June 4 – September 30 (adult model).

Figure 3: Climate match between Vladivostok, Russia (source of 

S. galinae) and North America based on minimum temperature, 

maximum temperature, total precipitation, and precipitation pattern 

for the entire year (larval model).

6
Figure 4: Climate match between Vladivostok, Russia (source of 

S. galinae) and North America based on minimum temperature, 

maximum temperature, total precipitation, and precipitation pattern, 

and relative humidity from June 4 – September 30 (adult model).

d. Source of the culture/agent in nature (name of collector, name of 

identifier). Spathius galinae was collected by USDA-ARS and USDAAPHIS scientists in collaboration with personnel from the Russian Far East 

Research Institute, and the insects were described as a new species by 

Belokobylskij et al. (2012). 

e. Life history (including dispersal capability and damage inflicted on 

EAB). Spathius galinae females search the trunk of ash trees infested with 

EAB, ovipositing on the larvae through the bark. The EAB is paralyzed 

and the parasitoid eggs are deposited on the outside of the larva. From 

6−15 larvae feed externally on the EAB larva and spin cocoons inside the 

EAB gallery (Duan et al., 2012a), eventually chewing through the bark and 

emerging as adults. In the laboratory, a female lays an average of 31 eggs 

during her lifetime, which averages 6.8 weeks. Spathius galinae can 

complete a generation in 3–4 weeks under normal rearing conditions (25–

27o

C, and 16 hours of light:8 hours of dark photoperiod) and diapause is 

not obligatory (it does not enter diapause under long day/warm temperature 

conditions), both of which indicate that this insect completes at least two 

generations per year. Sample percentage parasitism on green ash at two 

sites near Vladivostok, Russia averaged approximately 63 percent (Duan et 

al., 2012a); while at a site near Khabarovsk, EAB were attacked by T. 

planipennisi and S. galinae was not present. Because S. galinae has at least 

two generations per year, total attack by parasitoids within a single EAB 

7
generation is likely higher. Although data are not available on the dispersal 

capability of S. galinae, they fly strongly and are long lived (10–12 weeks), 

indicating that dispersal capabilities may be high. 

f. History of past use of S. galinae. Spathius galinae has never been used 

as a biological control agent.

g. Pathogens, parasites, hyperparasitoids of S. galinae and how to 

eliminate them from a culture of the agent. No pathogens, parasitoids, 

or hyperparasitoids have been observed attacking S. galinae, either in 

Russia or Korea or in specimens imported to the United States. Only 

healthy S. galinae are used to establish colonies. If any diseased organisms 

are discovered, they will be sent to insect pathologists for identification,

and hyperparasitoids will be eliminated from the colony. Insects that are 

subsequently reared in the United States will be maintained in pure culture 

and monitored for disease. 

h. Standard Operating Procedures stating how agent will be handled in 

quarantine. Both the ARS Beneficial Insects Introduction Research Unit 

and PPQ have well developed quarantine standard operating procedures for 

handling exotic insects including S. galinae. All imported (exotic) insects 

will be first examined and screened in a well-confined sample processing 

room; any contaminants will be excluded during the process. Spathius 

galinae will be reared on EAB larvae feeding in small ash logs according to 

methods described in Duan et al. (2011; 2013b). Spathius galinae females 

readily parasitize EAB larvae in these logs. Colonies will be maintained in 

bioclimatic chambers set at 25oC, 65 percent relative humidity, and a day 

length of 16 hours of light and 8 hours of dark. Under these conditions, S. 

galinae does not enter diapause and colonies can be maintained 

indefinitely. All material is sterilized before being removed from 

quarantine.

III. Affected Environment

A. North American Agrilus species

The “Nomina insecta Nearctica; a checklist of the insects of North 

America” (Poole, 1997) lists 164 species of Agrilus in North America. 

Most are not considered pests; however, Solomon (1995) considers 24 

Agrilus species to cause injury to trees and shrubs under certain 

circumstances. Most species of Agrilus are unable to colonize healthy trees; 

in fact, EAB is not typically a pest of Fraxinus in its native range. Agrilus 

species typically attack trees that are stressed by factors such as drought, 

damage from other insects, or poor silvicultural practices. In some cases 

their actions may be considered beneficial since they remove sick or 

8
damaged trees from the forest. Species such as Agrilus anxius Gory (bronze 

birch borer) and Agrilus bilineatus (Weber) (two-lined chestnut borer) are 

often considered major pest species in forest and landscape situations, but 

they are typically acting as secondary pests on already stressed trees or 

trees not native to the United States. Agrilus hyperici (Creutzer) has been 

released as a biological control agent of the weedy St. John’s wort, 

Hypericum perforatum L., in the western United States and is considered to 

be contributing to weed suppression in Idaho (Campbell and McCaffery,

1991). However, St. John’s wort is a perennial herb, not a tree, and grows 

in meadows, not in forests.

B. Ash Resources of North America

The known hosts of EAB in the United States are ash trees (Fraxinus spp.). 

Twenty-two species of ash grow in the United States, of which sixteen are 

native (USDA, NRCS, 2006). Ash species native to North American forests 

and known to be susceptible to EAB include: white ash (F. americana), 

green ash (F. pennsylvanica), and black ash (F. nigra), which are major 

components of the forest; and blue ash (F. quadrangulata) and pumpkin 

ash (F. profunda), which are less common species. There is increasing 

evidence that EAB will attack all Fraxinus spp., although susceptibility 

varies by ash species and variety (Liu et al., 2003; Wei et al., 2004; 2007; 

Rebek et al., 2008; Duan et al., 2012a). 

Ash trees are present as ornamentals, street trees, or timber trees in all of 

the lower 48 states except Idaho. It is estimated that there are more than 7.5 

billion ash trees in the United States, and unless climate inhibits population 

growth in the most southern states, all of those trees are at risk of being 

destroyed by EAB. Each Fraxinus species is adapted to slightly different 

habitats within forest ecosystems. Several species are tolerant of poorlydrained sites and wet soils, protecting environmentally-sensitive riparian 

areas; pure stands of black ash grow in bogs and swamps in northern areas 

where they provide browse, thermal cover, and protection for wildlife such 

as deer and moose. In agricultural and shelterbelt areas, ash provides vital 

shelter for livestock; for example, about 25 percent of all trees in North 

Dakota are Fraxinus spp. Bark of young ash trees is a favored food of 

mammals including beaver, rabbit, and porcupines; older trees provide 

habitat for cavity-nesting birds such as wood ducks, woodpeckers, 

chickadees, and nuthatches; seeds are consumed by ducks, song and game 

birds, small mammals, and insects.

Ash timber is valued for applications requiring strong, hardwood, but with 

less rigidity than maple. In the eastern United States, a net volume of 114 

billion board feet of ash sawtimber is harvested, comprising 7.5 percent of 

the volume of all hardwood species (FR, 2003). In 2001, ash accounted for 

over 149 million board feet of timber products produced in the United 

9
States. White ash is the primary commercial hardwood used in production 

of tool handles, baseball bats, furniture, flooring, containers, railroad cars 

and ties, canoe paddles, snowshoes, boats, doors, and cabinets; green ash is 

used for both solid wood applications such as crating, boxes, handles, and 

for fiber in the manufacture of high grade paper; black ash is typically used 

for interior furniture, cabinets (FR, 2003), and Northeastern Native 

Americans require ash for the art of basketry.

Beyond manufacturing, ash trees play an important role in the urban 

landscape due to their historical resistance to pests and tolerance of adverse 

growing conditions, such as soil compaction and drought. Many of the ash 

trees that now serve as street, shade, and landscape trees were planted to 

replace elm trees destroyed by Dutch elm disease; ash trees now comprise 

5−20 percent of all street trees throughout North America. In the United 

States, urban areas cover about 3.5 percent of the total land area, contain 

more than 75 percent of the population, and support about 3.8 billion trees. 

The City of Chicago has approximately 603,000 ash trees that provide 14.4

percent of leaf area (FR, 2003). Trees are considered vital to the health of 

cities because they sequester gaseous air pollutants and particulate matter, 

help people conserve energy through the shade they provide, assist in the 

dispersal of storm water, provide shelter belts for urban fauna, and 

contribute aesthetic pleasure to the lives of city-dwellers and tourists. Ash 

is a vital component of the urban forest.

IV. Environmental Consequences

A. No Action Alternative

1. Impact of EAB 

EAB is an invasive wood-boring beetle that is spreading rapidly and poses 

a serious threat to ash trees in the United States if not controlled. Despite 

state and federal quarantines designed to contain EAB, there is a lack of 

effective methods to detect and control EAB. Besides natural dispersal, the 

spread of EAB has been accelerated through human-assisted movement of 

infested ash firewood, timber, solid-wood packing materials, and nursery 

stock. As EAB spreads throughout North America, regulatory agencies, 

land managers, and the public are seeking sustainable management tools to 

reduce EAB population densities and to slow its spread (Cappaert et al., 

2005; GAO, 2006; Poland and McCullough, 2006). Since its discovery, 

EAB has killed tens of millions of ash trees and has cost municipalities, 

property owners, nursery operators and forest products industries tens of 

millions of dollars. 

10
Trees in the genus Fraxinus are important components of many forested 

ecosystems throughout North America and are planted extensively as urban 

and shelterbelt trees. USDA Forest Service Forest Inventory and Analysis 

estimates that establishment of EAB throughout the United States could 

result in loss of approximately 2.6 percent of trees in timberlands or 7.5 

billion trees (USDA FS, 2006). White, blue, and Oregon ash grow on 

fertile uplands and river terraces; green, black, Carolina, and pumpkin ash 

are wetland species; and velvet and single-leaf ash grow in semi-deserts 

and canyons. If EAB populations are not managed, ash resources 

throughout North America will be devastated (MacFarlane and Meyer,

2005). The loss of ash over large geographical areas will adversely affect 

water, soil, and air, resources. Ash is an important riparian tree and is often 

found along river banks. Removing ash from stream banks will affect bank 

soil retention and stream processes. 

2. Impact from the Use of Other EAB Control Methods

The continued use of physical, chemical, and biological control at current 

levels would result if the “no action” alternative is chosen, and may 

continue even if permits are issued for environmental release of S. galinae.

a. Physical Control

Although physical control may slow the spread of EAB to other ash trees in 

an area, this method is not effective at controlling the EAB population. It 

is likely that ash trees in the area will eventually become infested. 

b. Chemical Control

Insecticide treatment of ash trees for EAB control is inconsistent in 

effectiveness, especially on larger trees. Results have been mixed in 

insecticide efficacy studies; in some sites, insecticides are effective but fail 

in other sites (Herms et al., 2009). In addition, insecticide treatment does 

not guarantee that the tree will be protected from EAB attack. Trees with 

greater than 50 percent canopy loss are unlikely to recover even if treated 

with insecticides (Herms et al., 2009). Foliar and bark treatments can result 

in pesticide drift that affects non-target organisms in the treatment area, and 

trunk injections can cause damage to the injected tree. Insecticide 

treatments can be costly, especially on large trees and must be repeated 

annually to be effective, although emamectin benzoate is effective for two 

years or longer (Herms et al., 2009). 

Insecticide treatments are useful to protect certain high value trees but are 

not practical for controlling EAB over a large area or forest situation. 

Besides being costly, there are label restrictions on the amount of 

insecticide that can be applied per acre per year. 

11
c. Biological Control 

All three parasitoid species that have been previously released against EAB

(Oobius agrili, Tetrastichus planipennisi, and Spathius agrili) have been 

recovered following release in the United States; however, only T. 

planipennisi and O. agrili have been recovered consistently more than one 

year after release. At two sites in Michigan, parasitism by O. agrili 

increased from 3-4 percent in the year of release to 20–28 percent two 

years later. Tetrastichis planipennisi, a stronger flier than O. agrili, has 

effectively spread and established. At six intensively studied sites in 

Michigan, 92 percent of the trees at the release site contained at least one 

brood of T. planipennisi four years after release, and parasitism levels 

increased steadily to an average of over 20 percent (Duan et al., 2013a). 

Parasitism by T. planipennisi at the six control sites (at least 1 kilometer

away) also increased yearly to an average level of 13 percent. The story 

was not the same for S. agrili. At a release site near Hawley, Michigan, 18

percent of the EAB were parasitized by S. agrili after one year; however, a 

sample of 40 entire trees the following year revealed not a single parasitoid. 

At another site, parasitism one year after release was 45 percent, two 

broods were discovered the following year and two broods were recovered 

in 2011, but parasitism by S. agrili has been very low. At the six 

intensively sampled study sites, S. agrili was recovered in yellow pan traps, 

but only two EAB larvae parasitized by this species have been recovered 

after 2–5 years of sampling. One possible explanation is that S. agrili was 

collected from Tianjin, China, which is near the southern limit of the EAB 

distribution in China, and the climate there is a better match for the central 

rather than the northern United States. There may be a problem with 

synchrony between the emergence of adult S. agrili and availability of the 

mature EAB larvae that they attack.

Although O. agrili and T. planipennisi are establishing and dispersing, both 

have limitations that affect their ability to successfully control EAB 

populations. Oobius agrili is a very small insect, dispersing much more 

slowly than T. planipennisi. It is also solitary, with only one adult emerging 

from an EAB egg, although it is important because it prevents damage to 

the phloem caused by EAB larvae. Tetrastichus planipennisi is a gregarious 

larval parasitoid, producing an average of 57 adults per EAB larva (Liu et 

al., 2003; 2007; Yang et al., 2006; Ulyshen et al., 2010); however, it is a 

relatively small insect with a short ovipositor (egg-laying organ) and 

cannot parasitize EAB larvae under the thick bark of larger trees (Abell et 

al., 2012). Tetrastichus planipennisi cannot oviposit in bark thicker than 

3.2 millimeters (mm), which means it is limited to attacking EAB in the top 

of mature trees or in smaller trees (stems <11.2 centimeters (cm) diameter). 

It is anticipated that T. planipennisi will be most effective in stands of 

small, early successional ash rather than in mature forests. 

12
B. Biological control alternative (preferred alternative)

1. Environmental and Economic Impacts of the Proposed 

Release of S. galinae

a. Known impact on vertebrates including humans: Spathius galinae is 

an obligate parasitoid of wood boring larvae, specifically EAB. As such, it 

will rarely come into contact with humans or other vertebrates, and if it 

does, it is incapable of stinging or biting. Braconid wasps have no known 

adverse impacts on humans or other vertebrates.

b. Direct impact of S. galinae (e.g., intended effects on EAB, direct 

effects on non-targets). Percentage parasitism by S. galinae in Russia can 

reach 63 percent in stands of green ash (Fraxinus pennsylvanica) (Duan et 

al., 2012a). Because S. galinae has at least two generations per year 

compared with just one (univoltine) or half (semivoltine) for EAB, 

generational percentage parasitism will be greater than that measured 

during a single collection. Spathius galinae clearly has the potential to 

cause considerable mortality to EAB populations. In Asia, it is probable 

that EAB is not typically a pest because of the interaction between host 

plant resistance and natural enemies. While it is clear that American ash 

species are not resistant to EAB per se, they can withstand some attack as 

evidenced by callusing of EAB galleries, and woodpeckers can remove a 

considerable percentage of overwintering larvae. In Michigan, 32 to 42

percent of EAB larvae were removed by woodpeckers (Duan et al., 2010;

2013a) and a 2012 study at sites in Ulster County in New York found that 

woodpeckers removed between 40 and 65 percent of mature EAB larvae 

(Gould and Vandenberg, unpublished). Duan et al. (2010) also found that 

tree defenses in lightly infested young green ash killed 10 to 12 percent of 

EAB larvae. Spathius galinae will not have to cause 100 percent mortality 

of EAB to beneficially affect the health of ash stands, because ash can

successfully withstand some attack.

To evaluate the effects of S. galinae on non-target insect species, no-choice 

and choice host specificity tests were conducted in the United States to 

determine the physiological host range of S. galinae and possible direct 

effects on non-target species. Between 2011 and 2013, 15 North American 

species of wood-boring insects were exposed to S. galinae by scientists at 

the ARS Beneficial Insects Introduction Research Unit and PPQ to assess 

the parasitoid’s host range. Spathius galinae finds hosts to parasitize by 

using cues associated with sounds or vibrations produced by feeding borer 

larvae. Studies have shown that they do not attack prepupae or molting 

larvae that are not feeding (Duan et al., 2013c). All test larvae, therefore, 

had to be feeding inside their natural hosts during testing. To accomplish 

this, bark flaps were created in 4-8 cm diameter logs and a 3 cm long 

groove was drilled underneath each flap. The test larvae were placed in 

13
these grooves, and the flaps were reassembled and secured with rubber 

bands. The logs were placed into plastic jars that contained five one-week 

old S. galinae females and one male. The parasitoids were fed honey 

streaked on the fabric covering the lid of the jars. Every time a test was 

initiated with one or more non-target hosts, the same number of EAB 

larvae was tested in ash as a positive control to demonstrate that the wasps 

used in the tests were physiologically ready to attack suitable hosts. After 

two weeks, the larvae were checked to determine if they were parasitized. 

All parasitized larvae were held for at least 4 weeks to determine if S. 

galinae could develop to the adult stage. For the choice tests, gravid 

females of S. galinae were presented simultaneously to both an ash log 

containing five target host larvae (EAB) and an ash or non-ash log 

containing five non-target host larvae in a test arena (ventilated-clear 

polystyrene crisper boxes,each 17.6 × 12.6 × 10 cm, Tri-State Plastics, 

Latonia, KY). After a period of 2-weeks of exposure, the logs were 

incubated in normal rearing conditions for two weeks and scored for 

parasitism by S. galinae as previously described for the no-choice test. 

The larvae of fifteen wood-boring insects were tested to assess the host 

specificity of S. galinae (Table 1). Emphasis was placed on species closely 

related to the target pest or those feeding on ash. Thirteen species were 

wood-boring beetles; one clearwing moth (Lepidoptera: Sesiidae) and one 

sawfly (Hymenoptera: Cephidae) were also tested. Of the beetles, five 

were in the genus Agrilus, and were thus closely related to the EAB, and 

another was in the same family (Buprestidae). Three of the tested insects, 

the longhorned beetle Neoclytus acuminatus; the clearwinged moth 

Podosesia spp.; and the eastern ash bark beetle, Hylesinus fraxini attack ash 

as their main host and would be susceptible to parasitism if S. galinae 

accepts any boring insects infesting ash. 

Spathius galinae only attacked one species other than the EAB, and that 

was the gold spotted oak borer, Agrilus auroguttatus in red oak. The rate 

of parasitism was, however, considerably less (41 percent) on the nontarget host than on the EAB (71 percent) under test conditions that strongly 

favored parasitism. Spathius galinae did not attack any of the other three 

species infesting red oak, nor did they attack any of the other Agrilus or any 

of the three non-Agrilus species infesting ash. 

14
Table 1. Host specificity testing of S. galinae against sixteen species of wood-boring insects. EAB larvae were used in each trial as a 

positive control (from Gould and Duan, 2013).

Test Species Order/Family

Choice 

or no 

choice

Host 

Plant

No. of 

Replicates

# 

viable 

hosts

Parasitism 

Rate

S. galinae

Progeny Per 

Host (+ SE)

Agrilus anxius Coleoptera: Buprestidae none Birch 5 18 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 5 12 67% 8.0 + 1.4

Agrilus anxius Coleoptera: Buprestidae choice Birch 5 11 0%

Agrilus planipennis Coleoptera: Buprestidae choice Ash 5 23 91% 6.7 + 0.3

Agrilus masculinus Coleoptera: Buprestidae none Maple 16 42 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 15 52 33% 7.1 + 0.5

Agrilus sulcicollis Coleoptera: Buprestidae none Red Oak 10 38 0%

Agrilus bilineatus Coleoptera: Buprestidae none Red Oak 10 45 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 10 37 62% 5.6 + 0.7

Agrilus auroguttatus Coleoptera: Buprestidae none Red Oak 10 44 41% 5.4 + 1.4

Unknown Cerambycidae Coleoptera: Cerambycidae none Red Oak 10 48 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 10 48 71% 5.8 + 0.7

Chrysobothris spp. Coleoptera: Buprestidae none Maple 4 12 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 4 17 65% 5.4 + 1.3

Anoplophora glabripennis Coleoptera: Cerambycidae none Maple 13 65 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 9 44 57% 5.1 + 0.8

15
Test Species Order/Family

Choice 

or no 

choice

Host 

Plant

No. of 

Replicates

# 

viable 

hosts

Parasitism 

Rate

S. galinae

Progeny Per 

Host (+ SE)

Anoplophora glabripennis Coleoptera: Cerambycidae choice Maple 9 20 0%

Agrilus planipennis Coleoptera: Buprestidae choice Ash 9 32 100% 7.0 + 0.4

Elaphidion mucronatum Coleoptera: Cerambycidae none Maple 10 38 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 10 45 29% 4.2 + 0.9

Neoclytus acuminatus Coleoptera: Cerambycidae none Ash 11 49 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 11 36 83% 3.6 + 0.7

Neoclytus acuminatus Coleoptera: Cerambycidae none Maple 10 41 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 10 38 47% 5.7 + 0.7

Urographus fasciatus Coleoptera: Cerambycidae none Maple 6 25 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 9 32 50% 5.6 + 0.9

Isorhipis obliqua Coleoptera: Eucnemidae none Maple 6 15 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 6 10 30% 8.0 + 1.0

Hylesinus fraxini Coleoptera: Curculionidae none Ash 10 52 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 10 42 98% 4.5 + 0.5

Podosesia spp. Lepidoptera: Sesiidae none Ash 6 24 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 6 22 36% 6.3 + 1.1

Janus abbreviatus Hymenoptera: Cephidae none Willow 10 37 0%

Agrilus planipennis Coleoptera: Buprestidae none Ash 15 55 78% 5.7 + 0.8

16
2. Effects on the Physical Environment and Indirect Effects of 

the Release of S. galinae

a. Effects on physical environment (e.g. water, soil and air resources): 

Trees in the genus Fraxinus are important components of many forested 

ecosystems throughout North America and are planted extensively as 

urban and shelterbelt trees. USDA Forest Service Forest Inventory and 

Analysis estimates that establishment of EAB throughout the United 

States could result in loss of approximately 2.6 percent of trees in U.S. 

timberlands or 7.5 billion trees (USDA, FS, 2006). White, blue, and 

Oregon ash grow on fertile uplands and river terraces; green, black, 

Carolina, and pumpkin ash are wetland species; and velvet and single-leaf 

ash grow in semi-deserts and canyons. If EAB populations are not 

managed, ash resources throughout North America could be devastated 

(MacFarlane and Meyer, 2005). The loss of ash over large geographical 

areas will adversely affect water, soil, and air, resources. Ash is an 

important riparian tree and is often found along river banks. Removing 

ash from stream banks will affect bank soil retention and stream processes. 

The successful deployment of EAB biocontrol agents such as S. galinae

will have a positive impact on the physical environment by moderating 

EAB population increase, thus limiting tree damage. Conservation of ash 

trees in North American timberlands and urban forests will result in less 

flooding and soil erosion and moderate changes in air quality.

b. Indirect effects (e.g. potential impacts on organisms that depend on 

EAB or non-target species including potential competition with 

resident biological control agents). Successful management of EAB 

using biological control agents, including S. galinae, will result in 

positive, indirect effects on U.S. municipalities, land owners, wood 

industries, Native American basketry, air quality, forest biodiversity, 

wildlife, riparian areas, wildlife, and organisms dependent on Fraxinus 

spp. (e.g., the cerambycid: red-headed ash borer, Neoclytus acuminatus;

the sphingid: great ash sphinx, Sphinx chersis). Organisms most directly 

affected by EAB-associated ash demise will be those directly dependent 

on ash trees, such as ash-specialist plant-feeding arthropods (Gandhi and 

Herms, 2010), including several Lepidoptera (butterflies, moths, and 

skippers) species identified at high risk of endangerment (Wagner, 2007).

Fraxinus pennsylvanica provides food and nesting for songbirds and food 

and shelter for mammals (USDA, NRCS, 2003). Fraxinus nigra seeds are 

consumed by game birds, songbirds and small mammals and used as 

browse by white-tailed deer and moose (Wright et al., 1990). Beavers also 

use ash as a food resource (Henry and Bookhout, 1970). 

The indirect effects on a few biological control projects that utilize Agrilus

species to control weeds must be considered. Agrilus hyperici was 

released against Klamath weed (St. John’s wort) in the western United 

17
States and has shown mixed results. In northern Idaho it is beneficial in 

assisting two Klamath weed beetles, Chrysolina sp., in controlling the 

target weed (Campbell and McCaffery, 1991), but in California it has been 

displaced by Chrysolina quadrigemina (McCaffrey et al., 1995). Agrilus 

hyperici is a root feeder acting on a rangeland weed and it is not likely to 

come in contact with populations of S. galinae. Another exotic buprestid, 

Sphenoptera jugoslavica, also a root feeder, was released against spotted, 

diffuse, and squarrose knapweeds. Spathius galinae attacks larvae in 

branches and trunks in forest ecosystems. It is unlikely that S. galinae will 

be attracted to rangeland habitats or to attack larvae in the roots of 

herbaceous plants. Spathius galinae is not known to search for hosts 

underground and is not likely to attack A. hyperici or S. jugoslavica.

3. Uncertainties Regarding the Environmental Release of S. 

galinae.

Once a biological control agent such as S. galinae is released into the 

environment and becomes established, there is a slight possibility that it

could move from the target insect (EAB) to attack nontarget insects, such 

as native Agrilus species. Based on host specificity testing conducted, S. 

galinae only attacked one species other than the EAB, and that was the 

gold spotted oak borer, Agrilus auroguttatus, in red oak. The rate of 

parasitism was considerably less (41 percent) on the non-target host than 

on EAB (71 percent) under test conditions that strongly favored 

parasitism. Native species that are closely related to the target species are 

the most likely to be attacked (Louda et al., 2003). If other insect species 

were to be attacked by S. galinae, the resulting effects could be 

environmental impacts that may not be easily reversed. Biological control 

agents such as S. galinae generally spread without intervention by man. In 

principle, therefore, release of these parasitoids at even one site should 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 S. galinae populations and their 

effects on EAB and other non-target species will be conducted by the 

permittee.

In addition, these agents may not be successful in reducing EAB 

populations in the continental United States. Approximately 12 percent of 

all parasitoid introductions have led to significant sustained control of the 

target pests, but the majority of introductions have failed to provide 

control of the pest (Greathead and Greathead, 1992) either because 

introduction did not lead to establishment or establishment did not lead to 

control (Lane et al., 1999). Actual impacts on EAB populations by S. 

galinae will not be known until after release occurs and post-release 

monitoring has been conducted. For instance, although Oobius agrili and 

18
Tetrastichus planipennisi are establishing and dispersing, both have 

limitations that affect their ability to successfully control EAB populations

that were not known until after their release. Parasitism of EAB by 

Spathius agrili has also been much lower than expected. 

The environmental consequences discussed under the “no action” 

alternative may occur even with the implementation of the biological 

control alternative, depending on the efficacy of S. galinae, in 

combination with the other organisms released for biological control of 

EAB, to reduce EAB populations in the continental United States.

4. 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). 

APHIS has put quarantines in place to prevent the movement of EAB out 

of EAB-infested areas of the United States (7 CFR Subpart 301.53). This 

area may expand as new infestations are discovered. Quarantines are put 

in place to prevent the artificial spread of EAB through movement of 

infested firewood or other infested wood materials. In addition, APHIS, in 

cooperation with the appropriate State Departments of Agriculture, 

conducts survey program to determine new areas of EAB infestation. 

These methods do not control EAB but slow the spread or provide 

infestation information to state departments of agriculture for 

implementation of quarantines. 

Homeowners apply insecticides or hire arborists and tree care 

professionals to make applications to protect high-value ash trees in the 

landscape. Landowners may conduct a salvage harvest should EAB be 

detected in their ash trees. Insecticide applications and tree removals 

provide a temporary local reduction of EAB but do not result in long term 

control.

Because little can be done to control EAB, research is being conducted at 

universities and by Federal agencies to understand the beetle's life cycle 

and find ways to detect new infestations, control EAB adults and larvae, 

and contain the infestation.

Release of S. galinae will have no negative cumulative impacts in the 

continental United States because of its host specificity to EAB, other than 

potential impacts on non-target Agrilus species such as the gold spotted 

oak borer, Agrilus auroguttatus. However, based on host-specificity 

testing conducted, impacts to non-target Agrilus spp. are expected to be 

19
minimal because S. galinae clearly preferred EAB. Effective biological 

control of EAB will have beneficial effects to current EAB management 

activities, and may result in protection of ash resources and reduction in

removals of infested trees.

5. 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 

or endangered species or result in the destruction or adverse modification 

of critical habitat. 

Only one wood boring insect is listed as threatened under the ESA, the 

valley elderberry longhorned beetle (Desmocerus californicus dimorphus) 

and none are listed as endangered. The valley elderberry longhorned 

beetle mines the interior wood of the host plant, which must be at least 2.5 

cm in diameter (Paine et al., 2004), where it would not be accessible to the 

relatively short ovipositor of S. galinae. In addition, the valley elderberry 

longhorned borer is not closely related to EAB, and elderberry is not 

closely related to ash. Therefore, release of S. galinae will have no effect 

on the valley elderberry longhorned beetle or its designated critical 

habitat. Spathius galinae must attack its hosts, even EAB, as they are 

feeding beneath the bark of trees; therefore S. galinae will have no effect 

on any other threatened or endangered insects (or their critical habitat), 

which are all external feeders. 

V. Other Issues

Consistent 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. No environmental or human 

health effects from the proposed action are expected and there will be no 

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 are involved in implementing the preferred 

alternative. Therefore, it is expected that no disproportionate effects on 

children are anticipated as a consequence of implementing the preferred 

20
alternative.

EO 13175, “Consultation and Coordination with Indian Tribal 

Governments”, was issued to ensure that there would be “meaningful 

consultation and collaboration with tribal officials in the development of 

Federal policies that have tribal implications....” Consistent with EO 

13175, in April and May, 2014, APHIS sent letters of notification and 

requests for comment and consultation on this proposed action to tribes in

32 states, reflecting the very wide national distribution of ash (Fraxinus

spp.) in the lower 48 states. APHIS received responses from the Quartz 

Valley Indian Reservation (California), the Sokaogon Chippewa

Community (Wisconsin), and the Houlton Band of Maliseets (Maine). In 

June, 2014, APHIS conducted a phone conversation with the Seneca 

Nation (New York) who expressed support at the end of the call. Contacts 

were made informally with other tribes in New York, followed by calls in 

July and August 1, 2014. On August 1, APHIS officials participated in 

informal consultation, via telephone, with representatives from the Saint 

Regis Mohawk Tribe and the Shinnecock Nation, both in New York. The 

Saint Regis Mohawk Tribe supported the action, while the Shinnecock 

Nation wished to further examine the documents. The Shinnecock Nation 

subsequently indicated they had no further questions. Some of these tribes

have expressed interest in participating in S. galinae releases and 

monitoring activities. APHIS will continue to consult and collaborate 

with Indian tribal officials to ensure that they are well-informed and 

represented in policy and program decisions that may impact their 

agricultural interests, in accordance with EO 13175.

21
VI. Agencies, Organizations, and 

Individuals Consulted

This EA was prepared and reviewed by APHIS. The addresses of 

participating APHIS units, cooperators, and consultants (as applicable) 

follow.

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Plant Protection and Quarantine

Otis Pest Survey, Detection, and Exclusion Laboratory

Building 1398

Otis ANGB, MA 02542-5008

U.S. Department of Agriculture

Animal and Plant Health Inspection Service

Policy and Program Development 

Environmental and Risk Analysis Services

4700 River Road, Unit 149

Riverdale, MD 20737–1238

22
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