August 28, 2023

Regulated Domestic Pest Program

Evaluation Committee Recommendations 

for the Biological Control Program

Introduction

In spring of 2019 (FY 2020), representatives from the United States Department of Agriculture 

(USDA), Animal and Plant Health Inspection Service (APHIS), Plant Protection and Quarantine 

(PPQ) and the National Plant Board (NPB) selected the PPQ Biological Control (BC) domestic 

program for review by the Regulated Domestic Pest Program Evaluation Committee (RDPPEC).

Based on the information the RDPPEC received from the CFWG, the RDPPEC determined it 

was not possible to complete a comprehensive review of the program. Lack of a strategic plan, a 

clearly defined process for selecting and evaluating biocontrol projects, and no relevant

evaluative program metrics hindered the review process. In January 2021, interim 

recommendations were provided to the PPQ Deputy Administrator and recommended that the 

CFWG: 

• Review, revise, and finalize the Biological Control Program strategic plan; 

• Develop a consistent and transparent process for identifying, selecting, and supporting 

new biocontrol projects that align with strategic goals and objectives; 

• Establish relevant metrics to evaluate program performance; and 

• Develop a CFWG charter using the PPQ template. 

In February 2023, the RDPPEC followed up with the CFWG to determine whether they 

completed the RDPPEC’s recommendations. Based on the information provided by the 

CFWG, the RDPPEC determined there was adequate information available to perform a full 

program review of the BC program. The recommendations, included herein, are presented for 

consideration by the joint leadership of PPQ and NPB.

Program Background

The PPQ Biological Control program currently operates under the regulatory authority of the 

Plant Protection Act (PPA) of 2000, which states: “biological control is often a desirable, lowrisk means of ridding crops and other plants of plant pests and noxious weeds, and its use should 

be facilitated by the Department of Agriculture, other federal agencies, and states whenever 

feasible.”

Regarding biological control organisms, the PPA also states: “Congress finds that the 

unregulated movement of plant pests, noxious weeds, plants, certain biological control 

organisms, plant products, and articles capable of harboring plant pests or noxious weeds could 

present an unacceptable risk of introducing or spreading plant pests or noxious weeds.”

Starting in 1971, three different USDA agencies were involved in biological control programs
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including:

1. Agricultural Research Service (ARS), covered basic and applied research and foreign 

exploration;

2. Animal and Plant Health Inspection Service (APHIS) was committed primarily to action 

programs, such as mass-rearing and release; and

3. Forest Service (FS) was involved with the use of biological control for endemic and 

exotic forest pests.

PPQ’s Biological Control program has four goals: 

• Goal 1. Administer clear and transparent project selection and evaluation processes in 

order to support the most appropriate and successful biological control projects.

• Goal 2. Develop and deliver timely and informative program and pest specific reports, 

milestone achievements, and key project impact assessments.

• Goal 3. Support existing PPQ biological control expertise, capabilities, and infrastructure 

while leveraging outside agency expertise and support. 

• Goal 4. Leverage multiple funding sources and opportunities among partners and vested 

stakeholders to achieve program goals more rapidly and efficiently.

There is no Technical Working group for the Biological Control program. Though there is a

Technical Advisory Group for Biological Control Agents of Weeds (TAG) which acts

independently of the Biological Control Program. TAG members review petitions for 

biological control of weeds and provide an exchange of views, information, and advice to 

researchers.

The Biological Control Program touches many aspects of everyday life as agents have been 

released to support, agriculture, natural resources, targeted pests, has supported foreign and 

domestic trade, human and/or animal health. APHIS would have to rely on other agencies or 

organizations to develop and support biological control technologies to suppress emerging 

plant pests and to support biological control options in established domestic plant pest 

programs.

Results of Review of the Biological Control Program

The RDPPEC reviewed program documents provided by the BC CFWG and the group’s 

responses to questions raised by the RDPPEC. The following is not an all-inclusive list items 

pertaining to the review, but are the significant facts and findings of the review, on which the 

recommendations are based:

• The CFWG had completed all of the actions that had previously been recommended by 

the RDPPEC, as interim recommendations. The CFWG developed program guidance 

documents, a written strategic plan, a charter following the PPQ template, and identified 

their process for selection and evaluation of target BC agents and host pests.

• The CFWG cooperated with the RDPPEC in providing documentation and additional 

information for the RDPPEC to perform its program review.

• The CFWG Charter is robust and includes roles and responsibilities for each member and 

also identifies how the CFWG will operate regular business for the BC program. It 
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should be noted that the charter did not identify or list evaluative metrics to measure the 

successes of the program. 

• While the BC strategic plan provides a written description of how the BC Program

operates and performs its evaluation, selection, and research work, the plan does not 

address future needs of the program or strategies to address influencing situations such as 

climate change over the next five to ten years and how that would impact host selection 

or environment suitability for releases. The Strategic Plan is broad in scope and 

generalized to how the program operates currently. There is a section in the Plan with 

listed Goals, Actions, and Deliverables, but it is the RDPPEC’s opinion that these are not 

evaluative metrics that would inform if the program was succeeding or meeting the 

mission of the program. Rather, the RDPPEC notes that it is a list of the work currently 

being performed and how the CFWG is maintaining the information of the work, but it is 

not presented in a way that will evaluate programmatic success. 

• The funding source that the BC program is tied to is allocated for one only year, making 

it difficult for the program to be flexible in funding projects for new and emergent pests. 

Once funds are dedicated to existing projects, and since BC projects take an extended 

amount of time to complete, there are not a lot of options to include new projects, such as 

new and emerging pests that would benefit from BC agents. 

• Canvassing for species of concern appears to not include external entities who may be 

interested in providing rearing support or facilities for species that have been vetted by 

the BC program. Additionally, canvassing was last performed five years ago at the time 

this review was performed. There have been a large number of staffing changes with 

SPHD’s, SPRO’s, and program staff at USDA-APHIS-PPQ and the RDPPEC supports 

the CFWG’s desire to recanvass to determine which target pests should be pursued.

• The CFWG performs annual reviews of each biological control target agent and host pest 

to evaluate continued work at the progress level at time of review, however, some 

projects might not need an annual review, and some might need more than an annual 

review. 

• In documentation provided, it was revealed that stakeholders were not aware of project 

status or updates on biological control agent availability through the Plant Protection Act 

Section 7721 program. Additionally, regular updates through the stakeholder registry 

have not been utilized.

• There was a budgetary item of concern where in Fiscal Years 2022 and 2021, there were 

unspent funds from the allocation in the approximate amounts of $224,000 and $97,000, 

respectively. The CFWG indicated that these may be from unfunded salary increases, 

however, since these are one-year funds, these are a lot of funds that could be utilized 

within the program.

• Additional quality control work is needed to further quantify the effectiveness of BC 

releases and population establishment in the targeted environments after agents have been 

released into the impacted areas. The CFWG stated that there is not enough follow-up at 

the state level to have a full picture of the success of releases in the environment. 
August 28, 2023

Recommendations

The RDPPEC believes, based on the information provided by the CFWG, that the BC Program 

provides a beneficial, unique service in researching the feasibility, applicability, and rearing of 

appropriate biological control agents for targeted pests of concern. The RDPPEC recognized 

areas within the BC Program which could benefit from increased focus and development by the 

CFWG, and support by PPQ Management. The following recommendations, in the Committee's 

view, would ensure that the BC Program continues to provide valued research and development 

of biological control agents to meet the plant protection mission of both PPQ and NPB. 

The RDPPEC recommends that the CFWG: 

Communication 

• Further develop BC Strategic Plan to include specific and measurable performance 

indicators or metrics, that can be used to evaluate whether the activities of the program 

are 1) supporting the mission and 2) addressing program gaps and challenges in the short 

and long term. 

• Develop a collection of stories that describe BC successes. Increase communication of 

BC Program updates and successes utilizing tools such as the Stakeholder Registry 

system or other communication strategies to advance the mission of the BC program. 

• Develop, maintain, and make available a resource that identifies the status of BC agent 

selection work and availability. The resource should identify what level of completion the 

agent is in and whether they can be made available through PPA 7721. It is recommended 

that the resource be posted on the NPB intranet for SPRO availability to assist with PPA 

7721 suggestions and on the BC Program webpage on USDA’s website, for partner 

institutions.

Process 

• Identify and develop a process for newly introduced and emergent pests to be integrated 

into the BC program, given the existing funding structure.

• Establish a written protocol or contingency plan to ensure all allocated funds are spent 

(equipment purchases, one-time expenses, etc...) by the end of the fiscal year.

• When performing canvassing, begin soliciting interest from private industries and 

stakeholders in the biological control industries. It is possible that these external partners 

may be interested in taking over rearing from APHIS, which would provide relief on 

APHIS resources and potentially more capacity for rearing. 

• When canvassing, evaluate and modify the survey criteria and questions to clearly define 

agents and target pests for priority ranking from SPRO’s, SPHD’s, and other entities 

being canvassed. 

Implementation 

• Develop tools to assess biological control agent effectiveness and establishment. This 

may require increased funding to support quality control work in the field.
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• Develop tools to assess and determine appropriate timelines, for the specific pest, 

understanding that not all pests require annual review.

• Appropriately engage with ARS to ensure PPQ’s biological control needs are clearly 

articulated during their planning processes. 

• Develop a detailed knowledge management document which defines existing and 

potential cooperators. The list should include the contact person, their contacting 

information and affiliated institution or organization and will serve as an index of experts 

and ongoing partnerships.