United States

Department

of Agriculture

Forest Service

Animal and Plant

Health Inspection

Service

Record of Decision

Gypsy Moth Management in the

United States: a cooperative approach
Record of Decision

Gypsy Moth Management in the

United States: a cooperative approach

Contents

Purpose.................................................................................................... 1

Statutory Authorities ............................................................................... 1

The Decision ........................................................................................... 1

Alternatives............................................................................................. 1

Environmentally Preferable Alternative ................................................. 3

Rationale for the Decision ...................................................................... 3

USDA Goal...................................................................................... 3

Issues................................................................................................ 3

Human Health ........................................................................... 4

Nontarget Organisms................................................................. 4

Forest Condition ........................................................................ 4

Management Flexibility ................................................................... 4

Mitigating Measures and Standard Operating Procedures...................... 5

Monitoring .............................................................................................. 5

Public Involvement ................................................................................. 5

Implementation........................................................................................ 6

Responsible Officials .............................................................................. 6
Purpose

This document records the selection and rationale

for selection of an alternative from the six alternatives

analyzed in the final environmental impact statement,

“Gypsy Moth Management in the United States: a

cooperative approach.”

The gypsy moth (Lymantria dispar [L.]) is a

nonnative insect that alters ecosystems, destroys the

beauty of woodlands, and disrupts people’s lives and

livelihoods by feeding on the foliage of trees, shrubs,

and other plants. The European strain of the gypsy

moth, brought to the United States from Europe and

accidentally released in eastern Massachusetts in the

late 1860’s, is now established in all or portions of 16

northeastern and midwestern States and the District of

Columbia. It continues to spread into uninfested

areas. The Asian strain of the gypsy moth was

introduced into Oregon and Washington by ships from

eastern Russian ports in 1991 and into North Carolina

by shipping containers from Germany in 1993. These

introductions have been eradicated. The possibility of

future introductions is a concern, however, especially

given the recent increase in international trade and

travel.

The U.S. Department of Agriculture (USDA)

has carried out its gypsy moth management

responsibilities through the Forest Service and the

Animal and Plant Health Inspection Service (APHIS)

under the programmatic direction of decisions based

on an environmental impact statement prepared in

1985. Changes in gypsy moth status and

management techniques that have occurred since

1985 indicate that a new programmatic policy built

upon an updated environmental impact statement on

the gypsy moth was needed.

Statutory Authorities

The Forest Service and APHIS conduct pest

management activities under broad discretionary

authority given by Federal laws including the Federal

Plant Pest Act of 1957, as amended (7 U.S.C.

sections 150aa-150jj); the Department of Agriculture

Organic Act of 1944, as amended (7 U.S.C. section

147a); and the Cooperative Forest Assistance Act of

1978 (16 U.S.C. section 2101 [note]), as amended by

the Forest Stewardship Act of 1990 (16 U.S.C.

section 2101 [note]). Activities conducted under

these statutory authorities are listed on pages 1-8 and

1-9 of the final environmental impact statement.

USDA gypsy moth policy is presented on page 1-3 of

the final environmental impact statement.

The Decision

We have selected alternative 6, which includes

all three of the gypsy moth management strategies

analyzed—suppression, eradication, and slow the

spread. Implementation of this alternative will

require that site-specific environmental analyses be

conducted to address local issues before Federal or

cooperative suppression, eradication, or slow-thespread treatments are conducted. These site-specific

environmental analyses will be tiered to this

programmatic environmental impact statement.

Alternative 6 will guide the national gypsy moth

management program.

Alternatives

Combinations of the three gypsy moth

management strategies, or their absence, comprised

ten alternatives. The suppression strategy applies to

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the generally infested area (the area of the United

States where the European strain of the gypsy moth is

established). Suppression prevents or minimizes

heavy defoliation of trees by reducing outbreak

populations of the gypsy moth.

The slow-the-spread strategy applies to the

transition area (a band 50 to 100 miles wide where

the gypsy moth is spreading naturally and by shortrange artificial spread from the generally infested

area). The objective of this strategy is to slow the

spread of the European strain of the gypsy moth from

the generally infested area and to delay the impacts

and costs associated with gypsy moth outbreaks. The

operational and economic feasibility of this strategy

are being evaluated in a large-scale pilot test initiated

in 1992.

The eradication strategy applies to areas where

the gypsy moth is not established but where isolated

infestations can occur. The objective of eradicating

isolated infestations of the European strain of the

gypsy moth is to prevent it from becoming established

in uninfested areas. The objective of eradicating

infestations of the gypsy moth that exhibit

characteristics of the Asian strain is to prevent it from

becoming established anywhere in the United States.

Treatments available for use in suppression are

application of the insecticides Bacillus thuringiensis

var. kurstaki, diflubenzuron, and the gypsy moth

nucleopolyhedrosis virus (Gypchek). Treatments

available for use in eradication and slow the spread

include these three insecticides, as well as the use of

the noninsecticidal treatments of mass trapping,

mating disruption, and sterile insect release.

All of the alternatives except one—discontinuing

all gypsy-moth-related activities in the USDA gypsy

moth management program—included Forest Service

and APHIS support for integrated pest management

and delivery of technical assistance to cooperators.

Four of the alternatives were considered but not

carried forward for analysis in the environmental

impact statement: slow the spread only; suppression

and slow the spread; discontinuing the gypsy moth

program; and eradicating the gypsy moth from the

United States. These alternatives were impractical or

failed to meet the USDA goal of reducing the adverse

effects of the gypsy moth nationwide. A detailed

discussion of the alternatives considered but not

carried forward is presented on pages 2-13 and 2-14

of the final environmental impact statement.

Six of the alternatives were considered in detail.

Alternative 1. No suppression,

no eradication, no slow the spread. The Forest

Service and APHIS could not conduct suppression,

eradication, or slow the spread of the gypsy moth.

Alternative 2. Suppression. The Forest

Service could conduct suppression and cooperate with

other Federal agencies and States to conduct

suppression.

Alternative 3. Eradication. The Forest Service

and APHIS could conduct eradication and could

cooperate with other Federal agencies and States to

conduct eradication of isolated infestations of the

gypsy moth.

Alternative 4. Suppression and eradication.

The Forest Service could conduct suppression and

could cooperate with other Federal agencies and

States to conduct suppression. The Forest Service

and APHIS could conduct eradication and could

cooperate with other Federal agencies and States to

conduct eradication of isolated infestations of the

gypsy moth.

Alternative 5. Eradication and slow the

spread. The Forest Service and APHIS could

conduct eradication and slow the spread of the gypsy

moth, and could cooperate with other Federal

agencies and States to conduct eradication and slow

the spread.

Alternative 6. Suppression, eradication, and

slow the spread. The Forest Service could conduct

suppression and could cooperate with other Federal

agencies and States to conduct suppression. The

Forest Service and APHIS could conduct eradication

and slow the spread of the gypsy moth, and could

cooperate with other Federal agencies and States to

conduct eradication and slow the spread.

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Environmentally

Preferable Alternative

Alternative 1 poses the least potential for adverse

effects due to treatments because no treatments would

be conducted; however, there would be adverse

effects caused by the gypsy moth. Alternative 6 poses

the least potential for adverse effects due to the gypsy

moth because treatments could be conducted

throughout the United States; however, there would

be adverse effects due to treatments. Discussion of

adverse effects due to the gypsy moth and due to

gypsy moth treatments is presented on pages 4-71

through 4-95 of the final environmental impact

statement.

Within the framework of a cooperative approach

to managing the gypsy moth in the United States,

alternative 6 is environmentally preferable. Actions

taken against the gypsy moth by other agencies,

organizations, or individuals without cooperation of

the Forest Service or APHIS are not within the scope

of the environmental impact statement or this Record

of Decision.

Rationale for the

Decision

Alternatives were compared on the basis of these

criteria: (1) how they respond to the goal of the

USDA gypsy moth management program as

determined by expected future conditions for each

alternative in the year 2010, (2) how they respond to

issues raised during scoping, and (3) the amount of

flexibility they provide for managing ecosystems.

We selected alternative 6 (suppression,

eradication, and slow the spread) because analysis

showed that it fully meets the USDA goal of reducing

the adverse effects of the gypsy moth on the nation’s

forests and trees, it addresses the major issues

associated with the gypsy moth and their treatment,

and it provides the greatest amount of flexibility (the

greatest number of options) in managing ecosystems

affected by the gypsy moth. A description of how the

alternatives address the selection criteria follows.

USDA Goal

Alternative 6 best meets the USDA goal to

reduce the adverse effects of the gypsy moth on the

nation’s forests and trees by allowing Federal action

and cooperation in gypsy moth treatments anywhere

in the United States where the gypsy moth may occur.

Alternatives 2, 3, 4, and 5 only partially meet the

USDA goal in that they do not cover the entire

United States. The gypsy moth would be best

managed under alternative 6. Defoliation would

affect fewer acres than under the other alternatives.

Environmental effects due to the gypsy moth

therefore would be less under alternative 6 than

under the other alternatives.

Alternatives 5 and 6 both minimize expansion of

the generally infested area and would result in the

smallest transition area, limit the spread of the gypsy

moth from the generally infested area, and prevent or

delay adverse effects due to the gypsy moth.

Alternatives 3, 4, 5, and 6 all would prevent the

establishment of isolated infestations of the European

gypsy moth that ultimately would increase the size of

the generally infested area. These alternatives also

would prevent the Asian gypsy moth from becoming

established in the United States.

Under alternative 1 the Forest Service and

APHIS would be limited to providing technical

assistance and would not conduct or cooperate in

gypsy moth treatments.

A description of how the alternatives prevent or

minimize damage to resources, eliminate isolated

infestations, and reduce the rate of spread is

presented on pages 2-19 through 2-22 of the final

environmental impact statement.

Issues

The major issues raised during scoping that

influenced our decision are summarized in the

question: How do the gypsy moth and gypsy moth

treatments affect human health, nontarget organisms,

and forest condition?

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Human Health

Human health concerns fall within two

categories: (1) concerns about the effects caused by

the presence of large numbers of caterpillars

(including skin rashes, hazardous walkways, and

emotional discomfort from the presence of vast

numbers of insects), and (2) concerns about the

effects of possible exposure to gypsy moth treatments.

A detailed examination of the human health risks is

presented in appendix F, Human Health Risk

Assessment, of the final environmental impact

statement.

Officials responsible for gypsy moth treatments

would be provided the most latitude to address sitespecific health concerns under alternative 6. They

would have a choice of whether to treat, and a choice

of treatments.

Nontarget Organisms

The gypsy moth is the target of treatments. All

other plant or animal species are considered nontarget

organisms and are potentially affected directly or

indirectly by some gypsy moth treatments. Nontarget

organisms may also be affected by defoliation caused

by the gypsy moth.

Alternative 1 results in no effects from gypsy

moth treatments and the most effects from gypsy

moth outbreaks. Alternatives 2 through 6 cause

effects associated with gypsy moth treatments and

reduce effects caused by gypsy moths. Alternative 6

provides the greatest potential for nontarget

organisms or their habitats to be affected by

treatments, and the least potential for nontarget

organisms to be affected by the gypsy moth.

Managers at the local level must weigh the benefits

against the potential adverse effects to determine

whether suppression or slow the spread should be

conducted, which treatment or treatments would be

most appropriate for any of the management

strategies, and how to mitigate adverse effects of

treatments.

Forest Condition

Changes in tree species diversity, age class

distribution, and overall health and vigor of forests

and trees are affected by defoliation. Alternatives 1

and 3 do not prevent the gypsy moth from changing

forest condition. Alternatives 2, 4, 5, and 6 reduce or

delay the effects on forest condition caused by the

gypsy moth, to varying degrees. Alternative 6

provides the greatest protection to forests because it

allows action anywhere the gypsy moth may occur

and the use of various treatments. Forest condition is

not directly affected by gypsy moth treatments.

How the alternatives respond to issues is

described on pages 2-22 through 2-29 of the final

environmental impact statement.

Cumulative effects that result from implementing

the alternatives can be caused by:

• Repeated gypsy moth outbreaks and

defoliation of the same area;

• Repeated treatment of the same area in the

same season;

• More than one treatment in the same area; and

• Retreatment of the same area the following

season, or a season soon after.

Cumulative effects are discussed on pages 4-85,

and 4-89 through 4-91 of the final environmental

impact statement, and have been considered in our

decision.

Management Flexibility

The alternatives differ in providing a range of

options that the Forest Service and APHIS could

exercise in managing ecosystems or in helping others

in managing ecosystems. Alternative 1 does not

provide managers with the option to treat to prevent

or reduce the adverse effects to ecosystems caused by

the gypsy moth. Alternatives 2 through 5 provide

more options than alternative 1. Under all

alternatives the gypsy moth could cause changes that

may not be desirable in some ecosystems.

Alternative 6 provides the greatest flexibility and

the most options in managing or assisting others in

managing ecosystems affected by the gypsy moth.

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Record of Decision
The Forest Service and APHIS would decide where

to treat and how to treat gypsy moths, and how to

mitigate treatment effects. These decisions will

require site-specific environmental analyses.

Mitigating Measures and

Standard Operating

Procedures

Means to avoid or minimize environmental harm

from implementation of alternative 6 have been

considered and adopted. Mitigating measures

designed to reduce adverse environmental effects that

could result from conducting gypsy moth treatments

are discussed under Standard Operating Procedures

and Mitigating Measures in chapter 2 of the

environmental impact statement. That section

discusses measures to minimize adverse effects on

nontarget organisms, water quality, human health and

safety, people’s perceptions and behaviors, economic

factors, and recreation. For example, use of no-spray

buffer zones to minimize or eliminate insecticide drift

into sensitive areas may be applicable to protect

nontarget organisms, bodies of water, or organic

farming operations. Site-specific analyses will

determine the need for further mitigating measures.

Treatments that use insecticides approved by the U.S.

Environmental Protection Agency will be conducted

in compliance with instructions on the labels.

The Fish and Wildlife Service was consulted

during preparation of the environmental impact

statement. In compliance with the Endangered

Species Act of 1973 (16 U.S.C. sections 1531-1536,

1538-1540) the Forest Service and APHIS will

consult with the Fish and Wildlife Service or—where

appropriate—the National Marine Fisheries Service,

on gypsy moth treatments that would be conducted by

the Forest Service, APHIS, or in cooperation with

other Federal agencies or States.

The Fish and Wildlife Service concurs that

project-specific consultation on a case-by-case basis

will ensure that maximum attention is given to

threatened and endangered species for each treatment

proposal (Nickerson, Paul R. Letter to John Hazel.

1995 August 1. 1 leaf. Located at: U.S. Department

of Agriculture, Forest Service, Radnor, PA).

Appropriate field offices of the Fish and Wildlife

Service Ecological Services will be contacted as part

of the environmental analysis process for site-specific

projects.

Monitoring

Surveys are conducted to monitor gypsy moth

populations and to determine the extent of

infestations. Selected treatment projects are

monitored to see that they are carried out as

prescribed and to determine whether effects on the

environment are those expected. Gypsy moth

infestations are monitored in treatment areas to

determine whether projects were effective.

Public Involvement

A public involvement effort informed the public

about the environmental impact statement and

elicited their suggestions, ideas, and concerns related

to gypsy moth management. Public outreach was

conducted throughout the duration of the

environmental impact statement process and was

highlighted by formal public comment periods in

which written comments were sought.

During the first opportunity for public comment

the public’s concerns and ideas about gypsy moth

management were identified. An extensive effort

used direct mail, news releases, presentations,

publications, handouts, correspondence, and phone

calls to reach the public that is interested in or

affected by the gypsy moth. More than 3,500 written

comments about gypsy moth management were

received. The comments were used by the preparers

of the environmental impact statement to determine

the issues that were analyzed, to refine the

alternatives, and to expand the range of alternatives.

During the second opportunity for public input

the public’s comments on the draft environmental

impact statement were obtained. More than 13,000

copies of the summary or the four-volume draft

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Record of Decision
document were mailed to interested people and

organizations. Outreach through newspapers and

radio stations reached more than 22 million people.

Publications, presentations, handouts,

correspondence, magazines, newsletters, and phone

calls were used, along with postings on the Internet.

More than 650 written comments on the draft

environmental impact statement were received. Use

of the comments resulted in improvements to the final

environmental impact statement and indicated no

need for significant changes.

A third opportunity for public comment on the

environmental impact statement was provided

between the time the Notice of Availability of the

final environmental impact statement was published

in the Federal Register on December 1, 1995, and

the date of this decision. No comments that resulted

in a need to change the final environmental impact

statement were received during this period.

To conduct public involvement on a national

scale and to ensure that the environmental impact

statement served all areas of the United States, the

preparers of the environmental impact statement were

assisted by public affairs and forest pest managers

throughout the Forest Service and APHIS. A

detailed accounting of the public affairs and public

involvement activities appears in appendix C of the

environmental impact statement.

Implementation

A minimum of thirty days has passed since the

Environmental Protection Agency published a notice

in the Federal Register on December 1, 1995,

announcing the availability of the final environmental

impact statement. Alternative 6 may be implemented

immediately. Before gypsy moth treatments can be

implemented, analysis of the site-specific

environmental effects must be carried out, in

accordance with the National Environmental Policy

Act.

This decision is not subject to administrative

appeal because it neither implements a National

Forest land and resource management plan (36 CFR

215.1) nor approves, amends, or revises a National

Forest land and resource management plan or

regional guide (36 CFR 217.1).

Questions concerning this decision or other

topics related to the environmental impact statement

should be directed to:

John W. Hazel

USDA Forest Service

5 Radnor Corporate Center, Suite 200

Radnor, PA 19087-4585

(610) 975-4150

or

Charles Bare

USDA Animal and Plant Health Inspection

Service

4700 River Road, Unit 134

Riverdale, MD 20737-1236

(301) 734-8247

Responsible Officials

Joan M. Comanor, Deputy Chief Date

State and Private Forestry

USDA Forest Service

14th and Independence, S.W.

P.O. Box 96090

Washington, DC 20090-6090

Donald F. Husnik, Deputy Administrator Date

Plant Protection and Quarantine

USDA Animal and Plant Health Inspection Service

Administration Building, Room 312-E

Washington, DC 20250-3401

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Record of Decision