Importation of Orchids 

(Oncidium spp.) in 

Approved Growing 

Media From Taiwan

Draft Environmental 

Assessment, December 2013

United States

Department of 

Agriculture

Marketing and 

Regulatory

Programs

Animal and 

Plant Health 

Inspection 

Service
Importation of Orchids 

(Oncidium spp.) in Approved 

Growing Media From Taiwan

Draft Environmental Assessment

December 2013

Agency Contact:

Heather Coady

Plants for Planting Import Policy

Regulations, Permits and Manuals

Plant Protection and Quarantine

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road, Unit 133

Riverdale, MD 20737–1237

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Table of Contents

I. Introduction .............................................................................. 1

A. Background ........................................................................ 1

B. Purpose and Need.............................................................. 2

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

A. No Action ............................................................................. 2

B. Preferred Alternative ........................................................... 4

III. Affected Environment............................................................... 6

A. Host Range of Quarantine Pests ....................................... 8

B. Climate and Host Interactions........................................... 15

C. Threatened and Endangered Species .............................. 17

IV. Environmental Impacts........................................................... 22

A. No Action ......................................................................... 22

B. Preferred Alternative........................................................ 22

C. Risk Managment.............................................................. 26

D. Endangered Species Act ................................................. 34

E. Other Considerations....................................................... 35

V. Listing of Agencies Consulted................................................ 36

VI. References............................................................................. 37
1

I. Introduction

 

A. Background

 

Currently in the United States, orchids are sold in pots primarily for 

the interior design market. It is not uncommon for these plants to be 

mass-produced and sold at wholesale to general merchandise retailers 

and specialty outlets where they are purchased by consumers. 

Oncidium species and other orchids are imported into the United States 

from Taiwan as bare-rooted plants (7 Code of Federal Regulations 

(CFR) § 319.37–8(d)), and subject to inspection at U.S. Department of

Agriculture’s (USDA) plant inspection stations at certain U.S. ports of 

entry. In accordance with section 319.37–8(a) of the regulations, 

USDA’s Animal and Plant Health Inspection Service (APHIS)

requires, with certain exceptions, that plants offered for importation 

into the United States be free of sand, soil, earth, and other growing 

media. Many U.S. potted orchid growers begin with imported plants; 

they purchase the bare-rooted imports, grow them, and pot them for 

sale. 

The United States imports between 4.5 and 6 million kilograms (kg) of 

live orchids, valued at nearly $59 million to $70 million annually. 

Approximately 86 percent of these live orchids imported into the 

United States are sourced from Taiwan each year. The United States 

also imports live orchids from Thailand (approximately 4 percent), the 

Netherlands (approximately 2.4 percent), Canada (approximately 2.4 

percent), Costa Rica (less than 2 percent), South Korea (less than 1.5 

percent), and China (less than 1 percent) each year.

In Taiwan, most flowers are dry packed in sleeves and cardboard 

boxes, transported by road to local markets, and airlifted to export 

destinations with varying levels of post-harvest handling losses. 

Unfortunately, there is high mortality of bare-rooted plants (Su et al., 

2001). In an effort to improve the viability of orchid imports, Taiwan

has requested to export to the United States orchids potted in 

sphagnum moss or other APHIS-approved growing media. 

This environmental assessment (EA) was prepared to comply with the 

National Environmental Policy Act of 1969 (NEPA) 42 United States 

Code (U.S.C.) 4321, et seq., as prescribed in implementing regulations 

adopted by the Council on Environmental Quality (40 CFR §§1500–

1508), USDA (7 CFR part 1b), APHIS (7 CFR part 372), and to 

satisfy Executive Order (EO) 12114, “Environmental Effects Abroad 

of Major Federal Actions.”
2

B. Purpose and Need 

USDA–APHIS, Plant Protection and Quarantine (PPQ) is proposing to 

amend the regulations for the importation of plants and plant products 

(7 CFR part 319). PPQ has been petitioned to add orchids of the genus

Oncidium from Taiwan to the list of plants that may be imported in 

approved growing media, subject to specified growing, inspection, and 

certification requirements.

Currently, bare-rooted orchid plants from Taiwan, including Oncidium

species (spp.) are generally enterable with appropriate documentation. 

Oncidium cut flowers are also enterable. Epiphytic plants (including 

orchid plants) are imported from Taiwan into the United States as 

bare-rooted plants growing on tree fern slabs, in coconut husk or 

coconut fiber, and grown in new clay pots or new wooden baskets. 

Phalaenopsis spp. orchids in growing media from Taiwan are 

approved in 7 CFR 319.37-8(e) requiring a phytosanitary certificate, 

CITES documentation, and inspection at a plant inspection station at 

the U.S. port of entry by PPQ inspectors. Taiwan has requested that 

PPQ consider amending the regulations to allow Oncidium spp. 

orchids to be imported into the United States in approved growing 

media under the same provisions of 7 CFR § 319.37–8(e). This will 

improve the viability of imported plants because, currently, there is 

high mortality of bare-rooted plants (Su et al., 2001). 

II. Alternatives 

 

This EA analyzes potential environmental consequences of the 

implementation of a proposal to amend the regulations governing the 

importation of plants and plant products into the United States (7 CFR 

part 319). Two possible alternatives are considered in this EA: 

maintaining the current regulation for the importation of orchids of the 

genus Oncidium into the United States (no action alternative), and the 

implementation of regulations under the proposed rule (preferred 

alternative).

A. No Action

The no action alternative would leave 7 CFR part 319 unchanged. 

Section 319.37–8(a) of the regulations requires, with certain 

exceptions, that plants offered for importation into the United States be 

free of sand, soil, earth, and other growing media. This requirement is 

intended to help prevent the introduction of plant pests that might be 

present in unapproved growing media; the exceptions to this 

requirement take into account factors that mitigate that risk. Those 
3

exceptions, which are found in paragraphs (b) through (e) of 7 CFR § 

319.37–8, consider either the origin of the plants and growing media 

or the nature of the growing media and/or the use of a combination of 

growing conditions, approved media, inspections, and other 

requirements.

Currently, Oncidium and other orchids are imported from Taiwan as 

bare-rooted plants established on tree fern slabs, in coconut husk or 

coconut fiber, and grown in new clay pots or new wooden baskets (7 

CFR § 319.37–8(d)). Oncidium cut flowers are also enterable. All 

forms are enterable subject to inspection findings at designated ports 

of entry to the United States, that is, ports associated with facilities 

where propagative material can be examined (plant inspection 

stations). All orchid consignments must be accompanied by a USDA 

permit and a phytosanitary certificate issued by the plant protection 

service of the exporting country. This document certifies that the 

orchids have been inspected and found free of quarantine pests.

As stated in 7 CFR § 319.37–8(e), the following groups of plants

established in approved growing media are currently allowed entry to 

the United States: 

 Alstroemeria, Ananas, Anthurium; 

 artificially dwarfed (penjing) plants from the People’s Republic 

of China of the following plant species: Buxus sinica, Ehretia 

microphylla, Podocarpus macrophyllus, Sageretia thea, and 

Serissa foetida; 

 Bromeliad plants of the genera Aechmea, Cryptanthus, 

Guzmania, Hohenbergia, Neoregelia, Tillandsia, and Vriesea 

from Belgium, Denmark, and the Netherlands; 

 Begonia, Gloxinia (=Sinningia), Nidularium, Peperomia; 

 Dracaena from Costa Rica

 Phalaenopsis spp. from Taiwan

 Polypodiophyta (=Filicales);

 Rhipsalidopsis spp. from the Netherlands and Denmark,

 Rhododendron from Europe;

 Saintpaulia;

 Schlumbergera spp. from the Netherlands and Denmark.

Under the no action alternative, Oncidium spp. orchids from Taiwan

would not be added to the list of taxa allowed entry into the 

United States established in approved growing media and would 

continue to enter the United States under current requirements (7 CFR 

§ 319.37–8(d)).
4

B. Preferred Alternative

The proposed rule (preferred alternative) would change 7 CFR part 

319 and thus allow importation of orchids of the genus Oncidium from 

Taiwan rooted in approved growing media. Orchid plants would be 

shipped to a location only after passing through a PPQ plant inspection 

station located at the port of entry in the United States. Once 

consignments are cleared through a plant inspection station, orchids 

could be distributed to any location in the United States, including its 

possessions and trust territories. 

The orchids would be required to be produced, handled, and imported 

in accordance with the requirements of 7 CFR § 319.37–8(e) and 

accompanied, at the time of importation, by a phytosanitary certificate 

issued by the Kaohsiung Branch of BAPHIQ (Bureau of Animal and 

Plant Health Inspection and Quarantine, Council of Agriculture of 

Taiwan), declaring that the requirements have been met.

The preferred alternative includes propagation, rearing, shipping, and 

importation of Oncidium plants in approved growing media into the 

United States from Taiwan. Below are detailed requirements that must 

be met, as stipulated in 7 CFR § 319.37–8(e):

(e) Oncidium orchids may be imported from Taiwan established in 

an approved growing media if the article meets the conditions of this 

paragraph and is accompanied by a phytosanitary certificate issued by

BAPHIQ that declares that the article meets the conditions of this 

paragraph:

(1) Approved growing media includes baked expanded clay pellets, 

organic and inorganic fibers, peat, sphagnum moss, vermiculite, and 

other media (see 7 CFR § 319.37–8(e)(1) for a complete list), and must 

not have been previously used.

(2) Articles imported under this paragraph must be grown in 

compliance with a written agreement for enforcement of this section 

signed by BAPHIQ and PPQ, must be developed from mother stock 

that was inspected and found free from evidence of disease and pests 

by a PPQ or BAPHIQ inspector no more than 60 days prior to the time 

the article is established in the greenhouse (except for articles 

developed from seeds germinated in the greenhouse), and must be:

(i) Grown in compliance with a written agreement between the 

grower and BAPHIQ, in which the grower agrees to comply with the 

provisions of this section and to allow inspectors and representatives 

of BAPHIQ access to the growing facility as necessary to monitor 

compliance with the provisions of this section;
5

(ii) Grown solely in a greenhouse in which sanitary procedures 

adequate to exclude plant pests and diseases are always employed, 

including cleaning and disinfection of floors, benches, and tools, and 

the application of measures to protect against any injurious plant 

diseases, injurious insect pests, and other plant pests. The greenhouse 

must be free from sand and soil and must have screening with 

openings of not more than 0.6 millimeters (mm) on all vents and 

openings except entryways. All entryways must be equipped with 

automatic closing doors; 

(iii) Rooted and grown in an active state of foliar growth for at least 

4 consecutive months immediately prior to importation into the 

United States, in a greenhouse unit that is used solely for articles 

grown in compliance with this paragraph;

(iv) Grown from seeds germinated in the greenhouse unit; or 

descended from a mother plant that was grown for at least 9 months in 

Taiwan prior to importation of the descendent plants into the United 

States, provided that if the mother plant was imported into Taiwan

from another country, it must be:

(A) Grown for at least 12 months in Taiwan prior to importation of 

the descendent plants into the United States, or

(B) Treated, at the time of importation into Taiwan, with a 

treatment prescribed for pests of that plant by BAPHIQ and then 

grown for at least 9 months in Taiwan prior to importation of the 

descendent plants into the United States;

(v) Watered only with rainwater that has been boiled or pasteurized, 

with clean well water, or with potable (municipal) water;

(vi) Rooted and grown in approved growing media listed in 7 

CFR § 319.37–8(e)(1) on benches supported by legs and raised at least 

46 centimeters (cm) above the floor;

(vii) Stored and packaged only in areas free of sand, soil, earth, and 

plant pests;

(viii) Inspected in the greenhouse and found free from evidence of 

plant pests and diseases by a PPQ inspector or an inspector of 

BAPHIQ, no more than 30 days prior to the date of export to the 

United States.

The packaging commonly used in the orchid industry is cardboard 

boxes; however, other alternatives, such as plastic, are possible. These 
6

cardboard boxes are similar to other APHIS-approved packaging that 

excludes pests during the packing process and prevents hitchhikers 

from entering the packaged plants. The term “hitchhikers” is 

commonly used within PPQ to mean biological contaminants, 

including insects that generally are not specific to orchids. PPQapproved packing material includes paper, rockwool, sawdust, and 

other media specified in 7 CFR § 319.37–9. The pots containing the 

plants are most likely those that are commonly used in the orchid 

industry such as plastic, clay, or other composite materials. 

Preshipment treatment measures (i.e., fumigation) are not included as a 

condition of entry of Oncidium orchids from Taiwan because the pest 

risk assessment (PRA) (APHIS, 2012a) did not identify any quarantine 

pests which required these treatments in order to ensure quarantine 

security beyond the mitigations listed in 7 CFR § 319.37–8(e).

III. Affected Environment

The affected environment for both the current importation of barerooted Oncidium orchids (no action alternative) and the proposed 

importation of Oncidium orchids from Taiwan in APHIS-approved 

growing media (preferred alternative) is the United States, including 

Hawaii, Puerto Rico, and the U.S. Virgin Islands. 

Oncidium is a large and diverse New World genus, comprising nearly 

400 species. These orchids may grow naturally anywhere from sea 

level in the tropics to the high elevations of the Andes (American 

Orchid Society, 2013). Oncidium species occur both in lowlands and 

in the tropics, hence they have varying cultural requirements, from 

cool-house to warm-house, depending on the species; they usually

require considerable sun and air (Bailey and Bailey, 1976). In their 

natural habitats, Oncidium orchids are epiphytes (Hydro-orchids.com, 

2013). Epiphytes, or epiphytic plants, grow on rocks or other plants 

(such as trees) and use their specialized roots to take water and 

nutrients from the air, rain, and debris that may accumulate around the 

plant.

Oncidium are bee-pollinated; their ecology includes pollination by

carpenter bees (Xylocopa), bumble bees (Bombus), and digger bees 

(Centris). Pollination by digger bees is most commonly observed 

(Dressler, 1981). Carpenter bees, bumble bees, and digger bees are 

found throughout North and South America, although digger bees are 

considered primarily a tropical group. Carpenter bees and bumble 

bees are generalists, pollinating many different flower types, including 

those found on some important agricultural crops such as legumes and 

cucurbits (Daly et al., 1971). 
7

Upon receiving Taiwan’s request to allow importation of Oncidium

orchids established in approved growing media into the United States, 

APHIS conducted a pest risk assessment (PRA) (APHIS, 2012a) to 

examine the potential plant pest risk associated with unmitigated 

importations of orchids in growing media. The risk assessment 

prepared by APHIS examined the plant pest risk associated with the 

importation of Oncidium orchids established in APHIS-approved 

growing media from Taiwan into the United States. 

The PRA characterizes risks as high, medium, or low, based upon 

supporting evidence regarding climate-host interactions, host range, 

dispersal potential, economic impact, and environmental impact of 

plant pests. The methods used to initiate, conduct, and report the risk 

assessment are consistent with guidelines provided by the North 

American Plant Protection Organization and the International Plant 

Protection Convention administered by the Food and Agriculture 

Organization of the United Nations.

The PRA (APHIS, 2012a) analyzes the quarantine pests reasonably 

expected to follow the pathway (i.e., be included in commercial 

shipments of Oncidium plants) were analyzed. A quarantine pest is 

defined as “a pest of potential economic importance to the area 

endangered thereby and not yet present there, or present but not widely 

distributed and being officially controlled” (FAO, 2002). The 

biological hazard of an organism is only assessed if the organism can 

be identified to the species; however, if in the future, pests identified 

only to higher taxa are intercepted at the port of entry, then 

reevaluations of their risk may occur. 

The pests that were determined to have potential to be included in 

commercial shipments of Oncidium (both bare rooted or in growing 

media) are listed in Table 1.

Table 1. Quarantine Pests that May Follow the Pathway on Oncidium

spp. from Taiwan into the United States. (APHIS, 2012a).

Type Taxonomy Pest

Acari Arachnida: Tetranychidae Tetranychus kanzawai Kishida

Insecta Lepidoptera: Arctiidae Amsacta lactinea Cramer

Lepidoptera: Noctuidae Spodoptera litura (Fabricius)

Thysanoptera: Thripidae Scirtothrips dorsalis Hood

Thrips palmi Karny

Mollusca Stylomatophora: Achatinidae Lissachatina fulica (Bowdich)

Stylomatophora: 

Agriliomacidae

Deroceras laeve (Muller)

Stylomatophora: 

Helicarionidae

Deroceras martensi Simroth

Petalochlamys vesta (Pfeiffer)
8

Stylomatophora: 

Philomycidae

Meghimatium bilineatus (Benson)

Meghimatium pictum Stoliczka

Stylomatophora: 

Veronicellidae

Laevicaulis alte (Férussac)

Bacteria Gammaproteobacteria: 

Enterobacteriaceae

Pectobacterium cypripedii (Hori) 

Brenner et al.

Fungi Ascomycetes: Pleosporales Bipolaris zizaniae (Y. Nisik.) 

Shoemaker

A. Host Range of Quarantine Pests

The quarantine pests associated with the importation of Oncidium

from Taiwan and identified in the PRA pose a potential risk to a 

variety of other plants. This section lists quarantine pests and the 

respective potential host plants found in the United States. 

The host range of the moth, Amsacta lactinea, is very wide. It feeds 

on virtually all cultivated and wild vegetation. Some of its affected 

hosts include:

 Oncidium sp. (Orchidaceae) 

 Arachis sp.

 Leucaena leucocephala

 Phaseolus sp.,

 Glycine sp.

 Camelia sinensis

 Gossypium sp.

 Ligustrum sinennsis

 Oriza sp.

 Phragmites australis

 Helianthus annuus

 Ocimun basilicum, and 

 Sapium sebiferum

(APHIS, 2012a)

A number of additional host plants belong to the families

 Asteraceae

 Euphorbiaceae

 Fabaceae

 Lamiaceae

 Malvaceae

 Oleaceae
9

 Orchidaceae

 Poaceae

 Rosaceae, and;

 Theaceae.

(APHIS, 2012a)

The host range of the oriental leafworm , Spodoptera litura, includes 

over 40 plant families. Plant species attacked by S. litura in the tropics 

include:

 Oncidium sp.,

 Dendrobium sp. (Orchidaceae), 

 Colocasia esculenta (Araceae), 

 Brassica sp. (Brassicaceae), 

 Ipomea batatas (Convolvulaceae), 

 Cucumis sp. (Cucurbitaceae), 

 Ricinus sp. (Euphobiaceae), 

 Arachis sp., 

 Glycine sp., 

 Leucaena leucocephala, 

 Medicago sativa, 

 Phaseolus sp., 

 Vigna sp. (Fabaceae), 

 Linum sp. (Linaceae), 

 Corchorus sp., 

 Gossypium sp. (Malvaceae), 

 Zea mays, 

 Oryza sp. (Poaceae), 

 Capsicum sp., 

 Nicotiana tabaccum, 

 Solanum melongena, 

 Solanum tuberosum (Solanaceae), and 

 Camelia sp. (Theaceae) 

((CABI 2011b); (EPPO 1997c)b).

The thrips Scirtothrips dorsalis is mainly a foliage feeder; it does not 

feed on flower pollen (Edwards, 2010). The host range of S. dorsalis

includes over 40 plant families. Plant species attached by this thrips 

include: 

 Odontonema strictum (Acanthaceae); 

 Actinidia deliciosa (Actinidiaceae);

 Ilex crenata , I. integra (Aquifoliaceae); 

 Alternanthera sessilis, 

 Amaranthus spp., A. blitum, (Amaranthaceae); 

 Anacardium occidentale, 
10

 Mangifera indica (Anacardiaceae); 

 Calotropis gigantea (Apocinaceae); 

 Schefflera arboricola (Araliaceae); 

 Chrysanthemum x morifolium, 

 Dahlia pinnata, 

 Imorphotheca aurantiaca, 

 Helianthus annuus, 

 Sonchus asper (Asteraceae); 

 Viburnum awabuki, V. suspensum (Caprifoliaceae); 

 Euonymus japonicus (Celastraceae); 

 Beta vulgaris (Chenopodiaceae); 

 onocarpus erectus, 

 Laguncularia racemosa (Combretaceae); 

 Ipomoea batatas (Convolvulaceae); 

 Citrullus lanatus, 

 Cucumis melo, C. sativus, 

 Cucurbita pepo (Cucurbitaceae); 

 Diospyros kaki (Ebenaceae); 

 Pieris japonica, 

 Rhododendron sp. (Ericaceae); 

 Hevea brasiliensis, 

 Hevea sp.;

 Ricinus communis (Euphorbiaceae); 

 Acacia arabica, A. brownie;

 Acacia spp. A. auriculiformis,

 Arachis hypogaea; 

 Brownea spp.; 

 Dolichos lablab; 

 Glycine max; 

 Melanoxylum sp.; 

 Melilotus indica, 

 Mimosa pudica, 

 Phaseolus vulgaris, 

 Saraca minor, 

 Saraca spp., 

 Tamarindus indica, 

 Vigna radiata (Fabaceae); 

 Castanea crenata,

 Quercus glauca, 

 Q. virginiana, 

 Saraca indica (Fagaceae); 

 Ginkgo biloba (Ginkgoaceae); 

 Distylium racemosum (Hamamelidaceae); 

 Hydrangea spp. (Hydrangeaceae); 
11

 Laurus nobilis (Lauracea), 

 Lamium barbatum (Lamiaceae); 

 Allium cepa, A. sativum, 

 Asparagus officinalis (Liliaceae); 

 Cuphea hyssopifolia (Lythraceae); 

 Gossypium herbaceu, G.hirsutum (Malvaceae); 

 Ficus carica, F. elastic,

 Morus sp. (Moraceae); 

 Musa sp. (Musaceae); 

 Syzygium malaccense, S. samarangense (Myrtaceae); 

 Nelumbo lutea, N. nucifera (Nelumbonaceae); 

 Jasminum multiflorum, 

 Ligustrum japonicum, 

 Osmanthus heterophyllus (Oleaceae); 

 Passiflora edulis (Passifloraceae); 

 Eurya japonica (Pentaphylacaceae); 

 Sauropus androgynus (Phyllanthaceae); 

 Pittosporum tobira (Pittosporaceae); 

 Plumbago auriculata (Plumbaginaceae); 

 Zea mays (Poaceae); 

 Coccoloba uvifera (Polygonaceae); 

 Podocarpus macrophyllus (Podocarpaceae); 

 Fagopyrum esculentum (Polygonaceae); 

 Portulaca oleracea (Portulacaceae); 

 Punica granatum (Punicaceae); 

 Zizyphus mauritiana (Rhamnaceae); 

 Fragaria x ananassa, F. chiloensis, 

 Photinia glabra, 

 Prunus sp., P. mume, P. persica, P. salicina,

 Pyracantha angustifolia, 

 Pyrus spp., 

 Rhaphiolepis indica, R. umbellata

 Rosa spp., 

 Rubus spp. (Rosaceae); 

 Gardenia jasminoides (Rubiaceae)

 Citrus aurantiifolia, C. maxima, C. sinensis, C. unshiu, 

 Murraya paniculata, 

 Zanthoxylum piperitum (Rutaceae); 

 Populus deltoids (Salicaceae); 

 Acer sp., 

 Dimocarpus longan, 

 Litchi chinensis, 

 Nephelium lappaceum (Sapindaceae); 

 Capsicum annuum, C. frutescens, 
12

 Lycopersicon esculentum, 

 Nicotiana tabacum, 

 Solanum melongena (Solanaceae), 

 Theobroma cacao (Sterculiaceae); 

 Camellia japonica, C. sasanqua, C. sinensis (Theaceae)

 Ampelopsis brevipedunculata;

 Cayratia japonic; and

 Vitis pteroclada, V. vinifera (Vitaceae) 

(CABI, 2011; (EPPO 1997); (Edwards et al. 2010)).

The thrips Thrips palmi feeds on many hosts and attacks plants in several 

families. Among primary hosts are species of:

 Actinidia chinensis spp. (A. deliciosa);

 Amaranthus spinosus spp. (A. tricolor, A. viridis);

 Mangifera indica; 

 Ageratum spp. (A. conyzoides);

 Chrysanthemun spp.;

 Helianthus annuus;

 Lactuca sativa ;

 Cucumis spp. (C. melo, C. sativus);

 Cucurbita spp. (C. moschata, C. pepo);

 Allium cepa;

 Arachis hypogaea,;

 Glycine max; 

 Phaseolus vulgaris; 

 Vigna ungiculat; 

 Persea americana; 

 Gossypium spp;

 Abelmoschus esculentus; 

 Oryza sativa; 

 Sesamum indicum; 

 Citrus spp. (C. medica, C. Sinensis);

 Capsicum annuum;

 Nicotiana tabacum;

 Solanum spp. (S. lycopersicum, S. melongena, and S. tuberosum)

(CABI, 2011)

The fungus Bipolaris zizaniae infects water bamboo (Zizania latifolia 

(Family: Poaceae)) and petals of Oncidium orchids (Family:

Orchidaceae)) (Hsieh et al., 2000). This fungus appears to infect 

Oncidium petals only when they are located near infected Z. latifolia

(Hsieh et al., 2000); this suggests that Oncidium is not a primary host 

for this fungus.
13

The terrestrial snails, Deroceras laeve, Laevicaulis alte, Meghimatium 

bilineatum, M. pictum, Parmarion martensi, and Petalochlamys vesta, 

are herbivorous. They feed on plant material (leaves, stems, soft bark, 

and fruits) and algae. The host range of these species covers several 

families, including: 

 Amryllidaceae,

 Araceae, 

 Asteraceae, 

 Euphorbiaceae, 

 Fabaceae, 

 Lauraceae,

 Malvaceae, 

 Oleaceae, 

 Orchidaceae, 

 Passifloraceae, and 

 Zingiberaceae 

((Hollingsworth et al. 2007)).

The terrestrial snail, Lissachatina fulica, has a broad range of host 

plants, and includes more than 200 plant species in about 40 families 

(Raut and Barke, 2002). Young snails are most predaceous on living 

vegetation, while very small and older individuals prefer detritus and 

decaying vegetation (The Global Invasive Species Database, 2006). 

Major hosts include:

 Amaranthus sp.,(Amaranthaceae);

 Alocasia sp., 

 Colocasia sculenta, 

 Xanthosoma brasiliensis (Araceae); 

 Brassica oleracea (Brassicaceae); 

 Citrillus lanatus, 

 Cucumis melo, C. sativus, 

 Cucurbita maxima, C. pepo, Luffa sp.,(Cucurbitaceae);

 Arachis hypogea, 

 Glycine max, 

 Pisum sativum (Fabaceae);

 Allium cepa (Liliaceae); 

 Gossypium sp (Malvaceae); 

 Musa paradisiaca (Musaseae); 

 Coffea arabica, C. canephora, (Rubiaceae);

 Citrus sinensis, C. reticulata (Rutaceae);

 Solanum melongena, 

 Lycopersicum sculentum, 

 Capsicum annun (Solanaceae);

 Theobroma cacao (Sterculiaceae);
14

 Camellia sinensis (Theaceae)

((Raut and Barke 2002)).

The bacterium Pectobacterium cypripedii affects plant species within 

the Orchidaceae family, including Cypipedium sp. and Phalaenopsis

amabilis. In addition, the pest will occasionally infect Carica papaya

(Caricaceae). 

The mite, Tetranychus kanzawai, can feed on more than 160 plant 

species in at least 60 families (Migeon and Dorkeld, 2006), including:

 Cordyline fruticosa, C. terminalis, Dracaena fragrans, 

Polianthes tuberosa (Agavaceae)

 Eucharis grandiflora (Amaryllidaceae)

 Annona squamosal (Annonaceae)

 Nerium indicum (Apocynaceae)

 Alocasia macrorhiza, A. odora, Colocasia esculenta (Araceae)

 Aralia elata, A. nudicaulis, Polyscias guilfoylei (Araliaceae)

 Areca catechu (Arecaceae (Palmae))

 Achillea filipendulina, Ageratum sp., Ambrosia ambrosioides,

Arctium lappa, Chrysanthemum sp., Dahlia sp., Helianthus 

annuus, Senecio cruentus, Sonchus oleraceus (Asteraceae)

 Impatiens balsamina, Impatiens sp.( Balsaminaceae)

 Bambuseae, Polyanthus sp. (Bambusaceae)

 Corylus heterophylla (Betulaceae)

 Ehretia macrophylla (Boraginaceae)

 Brassica juncea (Brassicaceae (Cruciferae)

 Platycodon grandiflorum (Campanulaceae)

 Humulus japonicas, Humulus lupulus (Cannabaceae)

 Sambucus sp.(Caprifoliaceae)

 Carica papaya (Caricaceae)

 Gypsophila paniculata, Dianthus caryophyllus

(Caryophyllaceae)

 Chenopodium sp. (Chenopodiaceae)

 Clethra alnifolia (Clethraceae)

 Terminalia catappa (Combretaceae)

 Commelina communis (Commelinaceae)

 Calystegia pellita, Ipomoea aquatic, I. batatas, Ipomoea sp. 

(Convolvulaceae)

 Benincasa hispida, Citrullus lanatus, Cucumis melo, C. 

sativus, Cucumis sp., Cucurbita sp., Diplocyclos palmatus, 

Lagenaria siceraria, Luffa acutangula, Trichosanthes 

cucumeroides (Cucurbitaceae)

 Cyathea sp. (Cyatheaceae)

 Dioscorea alata, D. oppposita (Dioscoreaceae)
15

 Diospyros kaki (Ebenaceae)

 Acalypha sp., Codiaeum variegatum, Euphorbia pulcherrima, 

Jatropha sp., Mallotus japonicas, Manihot esculenta, M. 

glaziovii, M. maritima, Melanolepis multiglandulosa

(Euphorbiaceae)

 Amphicarpaea bracteata, Arachis hypogaea, Canavalia sp., 

Erythrina variegate, Glycine max, G. soja, Glycine sp., Lablab 

purpureus, Lathyrus odoratus, Mimosa invisa, Phaseolus 

lunatus, P. vulgaris, Phaseolus sp., Pisum sativum, 

Psophocarpus tetragonolobus, Pueraria lobata, P. montana, P. 

thunbergiana, Robinia pseudoacacia, Trifolium pretense, T. 

repens, Trifolium sp., Vicia faba, Vigna angularis, V. catiang, 

V. unguiculata (Fabaceae)

 Gentiana scabra (Gentianaceae)

 Gladiolus sp. (Iridaceae)

 Perilla frutescens, Perilla sp. (Lamiaceae (Labiatae))

 Akebia quinata (Lardizabalaceae)

 Polygonatum falcatum (Liliaceae)

 Althaea rosea, Gossypium sp., Hibiscus syriacus (Malvaceae)

 Maranta sp. (Marantaceae)

 Melia sp., Sandoricum indicum (Meliaceae)

 Artocarpus integrifolia, Ficus religiosa, Morus alba, Morus 

australis, Morus bombycis (Moraceae)

 Musa sp.( Musaceae)

 Averrhoa carambola (Oxalidaceae)

 Passiflora edulis (Passifloraceae)

 Sesamum indicum (Pedaliaceae)

 Saccharum officinarum, Sorghum vulgare (=bicolor), Zea 

mays, (Poaceae)

 Polygonum multiflorum (Polygonaceae)

 Primula sieboldii, Trientalis sp. (Primulaceae)

 Punica granatum (Punicaceae)

 Thalictrum minus (Ranunculaceae)

 Ziziphus mauritiana (Rhamnaceae)

 Eriobotrya japonica, Fragaria chiloensis (=x ananassa), 

Kerria japonica, Malus domestica, Prunus armeniaca, P. 

avium, P. campanulata, P. mume, P. persica, Pyrus communis, 

P. japonica, P. pyrifolia, P. serotina, Rosa hybrid, Rubus 

crataegifolius, R. thunbergii (Rosaceae)

 Galium spurium, Gardenia jasminoides (Rubiaceae)

 Citrus grandis, C. limon, Murraya paniculata, Orixa japonica, 

Poncirus trifoliate, Zanthoxylum piperitum (Rutaceae)

 Populus sp., Salix glandulosa (Salicaceae)

 Cardiospermum halicacabum (Sapindaceae)

 Hydrangea hortensia (Saxifragaceae)
16

 Capsicum annuum, Capsicum frutescens, Lycium chinense, 

Solanum melongena, S. nigrum, S. torvum (Solanaceae)

 Strelitzia reginae (Strelitziaceae)

 Camellia sinensis (Theaceae)

 Celtis sinensis (Ulmaceae)

 Boehmeria nivea, Urtica thunbergiana (Urticaceae)

 Clerodendrum trichotomum, Tectona grandis, Verbena 

hortensis, V. phlogiflora (Verbenaceae)

 Viola mandshurica (Violaceae)

 Cayratia japonica, Vitis vinifera (Vitaceae)

 Zingiber officinale (Zingiberaceae)

(APHIS, 2012a)

B. Climate-Host Interaction

Climate limits the potential distribution and survival of pest species. 

The climactic limitations of the quarantine pests of concern are as 

follows:

Scirtothrips dorsalis is a thrips that is distributed over several tropical 

and subtropical countries (CABI, 2011, EPPO, 1997a) that correspond 

to Plant Hardiness Zones 7 – 11 (USDA, 2005). This includes 

portions of the following States and territories: Hawaii, Puerto Rico, 

Washington, Oregon, California, Nevada Utah, Arizona, New Mexico, 

Oklahoma, Texas, Arkansas, Mississippi, Louisiana, Alabama, 

Florida, Georgia, South Carolina, North Carolina, Virginia, Maryland, 

Delaware, New Jersey, Connecticut, New York, and Massachusetts. 

Amsacta lactinea, or red tiger moth, is found in parts of the world that 

correspond to Plant Hardiness Zones 9–11 in the continental United 

States ((Magarey et al. 2008)). These Plant Hardiness Zones are

currently found within portions of California, Oregon, Nevada, Arizona, 

Texas, Louisiana, Florida, Hawaii, and Puerto Rico (USDA, 2012c). 

The leafworm, S. litura, is widely distributed over several subtropical 

and tropical countries ((EPPO 1997c)b) corresponding to Plant 

Hardiness Zones 7–11 ((Magarey et al. 2008)). This includes portions 

of the following States and territories: Hawaii, Puerto Rico, 

Washington, Oregon, California, Nevada Utah, Arizona, New Mexico, 

Oklahoma, Texas, Arkansas, Mississippi, Louisiana, Alabama, 

Florida, Georgia, South Carolina, North Carolina, Virginia, Maryland, 

Delaware, New Jersey, Connecticut, New York, and Massachusetts

(USDA, 2012c). 

The spider mite T. kanzawai was reported in the United States in the 
17

States of California and New York (Migeon and Dorkeld, 2006). 

However, it is estimated that the pest could establish permanent 

outside populations in Plant Hardiness Zones 9 – 11, which include 

portions of California, Oregon, Nevada, Arizona, Texas, Louisiana, 

Florida, Hawaii, and Puerto Rico (USDA, 2012c). One or more of its 

potential hosts occur in these zones (Magarey et al., 2008). 

Thrips palmi (T. palmi) is a thrips that is subtropical to tropical in 

distribution. Populations in temperate climates are able to overwinter in 

greenhouses or other artificial situations because it cannot survive 

subzero temperatures for more than a few days ((Lewis 1997); (Capinera 

2010)). Based on this distribution, it is estimated that T. palmi could 

establish in the United States in U.S. Plant Hardiness Zones 9–11. These 

Plant Hardiness Zones are currently found within portions of California,

Oregon, Nevada, Arizona, Texas, Louisiana, Florida, Hawaii, and Puerto 

Rico. One or more of its potential hosts occur in these zones ((USDA 

1990)2012c; (Magarey et al. 2008)). 

Among the snails D. laeve, L. alte, M. bilineatum, M. picturm, P. 

martensi, and P. vesta, most have been reported from countries in East 

Asia (Hollingsworth et al., 2007; Noseworthy and Choi, 2007; Wu and 

Tsai, 2003). These correspond to Plant Hardiness Zones 9 – 11, which 

are currently found within portions of California, Oregon, Nevada, 

Arizona, Texas, Louisiana, Florida, Hawaii, and Puerto Rico (USDA, 

2012c). 

The snail Lissachatina fulica can inhabit ranges far outside of tropical 

areas, where most members of the Family Achatinidae are found. The 

snail is able to enter dormancy to survive temperatures as low as 2°C

or 35.6°F (USDA, 2005; Raut and Barke, 2002). Overall, this species 

is likely to survive in Plant Hardiness Zones 10 – 11, which includes 

portions of California, Arizona, Hawaii, southern Florida, and Puerto 

Rico (USDA, 2012c). However, based on the worldwide distribution 

of L. fulica, it is most likely associated with tropical and subtropical 

broadleaf forests, which do not occur in the United States. 

Pectobacterium cypripedii was reported in California, Florida, Idaho, 

New Mexico, and New York. These States feature Plant Hardiness 

Zones 3 – 11, which are found throughout large portions of the United 

States (USDA, 2012c). Based on this distribution, the bacterium could 

establish outdoors on host species found in Puerto Rico and Hawaii. 

The fungus B. zizaniae infects Zizania latifolia (Hsieh et al., 2000), so 

it can be expected to survive where Z. latifolia grows naturally in the 

environment. Zizania latifolia is present in areas that correspond to 

U.S. Plant Hardiness Zones 9 – 11 (USDA, 2008; USDA, 2012c). 

These Plant Hardiness Zones are currently found within portions of 
18

California, Oregon, Nevada, Arizona, Texas, Louisiana, Florida, Hawaii, 

and Puerto Rico. 

C. Threatened and Endangered Species

The following table lists threatened and/or endangered plant species 

that may be impacted by the establishment of actionable pests 

identified by the PRA. These pests may follow the pathway of 

Oncidium from Taiwan into the United States.

Table 2. Quarantine pests that may follow the pathway on Oncidium 

spp. plants from Taiwan into the United States and the 

associated Threatened and/or Endangered plant species that 

may be affected by their establishment (APHIS, 2012a).

Actionable 

Pest 

Listed Plant Species Distribution of Listed 

Species

A. lactinea Achyranthes mutica HI

Achyranthes splendens var. rotundata HI

Crotalaria avonensis FL

Cyperus trachysanthos HI

Euphorbia haeleeleana HI

Helianthus schweinitzii NC, SC

Euphorbia telephioides FL

Vigna o-wahuensis HI

Helianthus paradoxus NM, TX

S. litura Trifolium amoenum CA

T. stoloniferum AR, IN, KY, MO, OH, 

WV

T. trichocalyx CA

Solanum drymophilum Puerto Rico

Solanum incompletum HI

Solanum sandwicense HI

Allium munzii CA

Amaranthus brownii HI

Amaranthus pumilus DE, MA, MD, NC, NJ, 

NY, RI, SC, VA

Helianthus paradoxus NM, TX

Helianthus schweinitzii NC, SC

Lilium occidentale CA, OR

Lilium pardalinum ssp. pitkinense CA

Manihot walkerae TX

Alopecurus aequalis var. sonomensis CA

Aristida chaseae Puerto Rico

Aristida portoricensis Puerto Rico

Calamagrostis hillebrandii HI

Cenchrus agrimonioides HI

Eragrostis fosbergii HI

Festuca molokaiensis HI

Ischaemum byrone HI

Neostapfia colusana CA

Neostapfia colusana CA

Orcuttia inaequalis CA

Orcuttia pilosa CA
19

Orcuttia tenuis CA

Orcuttia viscida CA

Panicum fauriei var. carteri HI

Panicum niihauense HI

Poa atropurpurea CA

Poa mannii HI

Poa napensis CA

Poa sandvicensis HI

Poa siphonoglossa HI

Swallenia alexandrae CA

Tuctoria greenei CA

Tuctoria mucronata CA

Vigna o-wahuensis HI

Zizania texana TX

Sesbania tomentosa HI

Prunus geniculate FL

T. palmi Allium munzii CA

Cucurbita okeechobeensis spp. 

okeechobeensis

FL

Solanum drymophilum Puerto Rico

Solanum incompletum HI

Solanum sandwicense HI

Vigna o-wahuensis HI

Helianthus paradoxus NM, TX

Helianthus schweinitzii SC, NC

Amaranthus brownie HI

Amaranthus pumilus DE, NC, NJ, NY, SC, 

VA

Cranichis ricartii Puerto Rico

Isotria medeoloides CT, DE, GA, IL, MA, 

ME, MI, MO, NC, NH, 

NJ, NY, OH, PA, RI, SC, 

TN, VA, WV

Lepanthes eltoroensis Puerto Rico

Piperia yadonii CA

Platanthera holochila HI

Platanthera leucophaea IA, IL, IN, ME, MI, MO, 

OH, OK, VA, WI

Platanthera praeclara IA, KS, MN, MO, ND, 

NE, OK, SD

Spiranthes delitescens AZ

Spiranthes diluvialis CO, ID, MT, NE, NV, 

UT, WA, WY

Spiranthes parksii TX

Vigna o-wahuensis HI

S. dorsalis Allium munzii CA

Amaranthus pumilus DE, MA, MD, NC, NJ, 

NY, RI, SC, VA

Cucurbita okeechobeensis ssp. 

Okeechobeensis 

FL

Amaranthus brownii HI

Rhododendron chapmanii FL

Helianthus paradoxus NM, TX

Helianthus schweinitzii SC, NC

Vigna o-wahuensis HI
20

Solanum drymophilum Puerto Rico

Solanum incompletum HI

Solanum sandwicense HI

Gardenia brighamii HI

Gardenia mannii HI

Ilex cookii Puerto Rico

Ilex sintenisii Puerto Rico

Quercus hinckleyi TX

Pittosporum halophilum HI

Pittosporum hawaiiense HI

Pittosporum napaliense HI

Portulaca sclerocarpa HI

Ziziphus celata FL

Prunus geniculate FL

Zanthoxylum dipetalum var. tomentosum HI

Zanthoxylum hawaiiense HI

Zanthoxylum oahuense HI

Zanthoxylum thomasianum HI

T. kanzawai Zizania texana TX

D. laeve Cucurbita okeechobeensis ssp. 

Okeechobeensis 

FL

Solanum drymophilum HI

Solanum incompletum HI

Solanum sandwicense HI

L. fulica Cucurbita okeechobeensis ssp. 

okeechobeensis

FL

Amaranthus pumilus DE, MA, MD, NC, NJ, 

NY, RI, SC, VA

Amaranthus brownii HI

Solanum drymophilum PR

Solanum incompletum HI

Solanum sandwicense HI

Vigna o-wahuensis HI

Opuntia treleasei CA

Scirpus ancistrochaetus MD, MA, NH, NY, PA, 

VT, VA, WV

Cereus eriophorus var. fragrans FL

Manihot walkerae TX

Allium munzii CA

Clitoria fragrans FL

Hibiscus arnottianus ssp. immaculatus HI

Hibiscus brackenridgei HI

Hibiscus clayi HI

Hibiscus dasycalyx TX

Hibiscus waimeae ssp. hannerae HI

Gardenia brighamii HI

Gardenia mannii HI

Portulaca sclerocarpa HI

Eryngium aristulatum var. parishii CA

Eryngium constancei CA

Eryngium cuneifolium FL
21

Asplenium fragile var. insulare HI

Asplenium scolopendrium var. 

americanum

AL, MI, NY, TN

Pteris lidgatei HI

L. alte Listed plants of the Families Asteraceae, Euphorbiaceae, Fabaceae, 

Lauraceae, Malvaceae, Oleaceae, and Orchidaceae 

Genus and species- level data unspecified

M. bilineata

M. pictum

P. martensi

P. vesta

P. cypripedii Cranichis ricartii Puerto Rico, HI

Lepanthes eltoroensis Puerto Rico, HI

Platanthera holochila Puerto Rico, HI

B. zizaniae Zizania texana TX

Potential negative effects to listed members of the Family Orchidaceae 

may result from the introduction and establishment of pest species

associated with the preferred alternative, or habitat encroachment, 

should imported Oncidium plants establish. Currently, members of 

Family Orchidacea are listed as threatened or endangered, including: 

Small Whorled begonia (Isotria medeoloides), Ute ladies’-tresses

(Spiranthes diluvialis), Canelo Hills ladies’-tresses (Spiranthes 

delitescens), Navasota ladies’-tresses (Spiranthes parksii), Yadon’s 

piperia (Piperia yadonii), white fringeless orchid (Platanthera 

integrilabia), Eastern prairie fringed orchid (Platanthera leucophaea), 

Platanthera holochila, and Western prairie fringed orchid (Platanthera 

praeclara). 

The listed species Isotria medeoloides occurs in many places within 

the continental United States. However, none features the habitat 

requirements of Oncidium. Major threats to the recovery of I. 

medeoloides do not include herbivory, predation, or habitat 

encroachment by invasive species (FWS, 1992). However, slugs are 

considered serious pests of the orchid in New England (FWS, 1992), 

which features Plant Hardiness Zones that may accommodate D. laeve. 

The listed species, Spiranthes diluvialis, which was originally known 

only to Colorado, Utah, and Nevada is now reported to also occur in 

Wyoming, Montana, Nebraska, Idaho, and Washington where the 

temperatures are likely to support Oncidium. However, S. diluvialis

grows in moist soils and wet meadow habitats (NatureServe, 2002)

which is unlikely habitat for Oncidium. Similarly, Spiranthes 

delitescens, or Canelo Hills ladies’-tresses, occurs in marshy wetland 

in Arizona (NatureServe, 2002). Currently, predation has not been 

identified as a threat to recovery efforts (USFWS, 1995). 

Spiranthes parksii occurs in open, lightly wooded, seasonally moist 

soils along open wooded margins of stream banks of the Brazos and 

Navasota Rivers in Texas (NatureServe, 2002). The soil moisture and 

average low temperatures of the region would not meet the habitat 
22

requirements of Oncidium. Currently, predation has not been 

identified as a threat to recovery efforts (USFWS, 1984).

Piperia yadonii, or Yadon’s piperia, is endemic to the pine forest and 

maritime chaparral communities of Monterrey County in California. 

This habitat would not support outdoor growth of Oncidium plants. 

The distribution of P. yadonii overlaps with the climate-host 

distribution of each quarantine pest identified in the PRA. 

Orchidaceae are identified as possible host plants for A. lactinae, B. 

zizaniae, L. fulica (Gregoric et al., 2013), P. cypripedii, S. litura, and

T. palmi. Herbivory has been identified as a potential threat to the 

recovery of the listed species, although this is generally associated 

with grazing by mule deer (USFWS, 2009).

Platanthera holochila is found on the islands of Hawaii, in montane 

wet forests or bogs. This habitat is not suitable for outdoor growth of 

Oncidium plants. Predation by slugs has been identified as a potential 

threat to this species (USFWS, 1999b). 

Platanthera leucophaea occurs in cooler climates, such as Iowa, 

Illinois, Indiana, Maine, Missouri, New York, Ohio, Pennsylvania, 

Oklahoma, Virginia, and Wisconsin, which are not conducive to 

Oncidium (NatureServe, 2002). However, this distribution overlaps 

with the climate-host range of S. litura, S. dorsalis, and D. laeve, three 

of the quarantine pests identified in the PRA. Members of the Family

Orchidaceae are identified as host plants for S. litura and D. varians, a 

similar species to D. laeve. Predation, however, has not been 

identified as a threat to the recovery of P. leucophaea (USFWS, 

1999a).

The taxonomically related P. praeclara also occurs in areas with 

average nighttime temperatures that are likely too low for Oncidium

orchids to establish, such as Iowa, Kansas, Minnesota, Missouri, 

Nebraska, North Dakota, South Dakota, and Oklahoma (NatureServe, 

2002). These states overlap the climate-host range of P. cypripedii, 

whose plant host range includes members of Family Orchidaceae. 

Predation, however, has not been identified as a threat to recovery

efforts (USFWS, 1996). 

IV. Environmental Impacts 

 

A. No Action

There have been no reports of invasiveness of Oncidium orchids in the 

United States since bare-rooted importations have been allowed to 
23

enter the country. The importation of orchids into the United States 

has occurred for decades, and they are shipped to all known habitats. 

The PLANTS database (http://plants.usda.gov) and other weed 

reporting services do not include reports of imported Oncidium

orchids as invasive or having weed potential.

A screening performed by PPQ for the weed potential of Oncidium

from Taiwan showed that these plants did not meet the criteria of a 

weed pest (APHIS, 2012a). The screening took into account that the 

Oncidium plants that are already present in the United States are not 

reported as weeds.

B. Preferred Alternative

Within the United States, nonindigenous species have had major 

impacts including degradation of wildlife habitat, decreased biological 

diversity, altered natural ecosystems, and negative effects on fishing 

and water sports (OTA, 1993). There is concern that, because Taiwan

is climatically similar to portions of Florida, Hawaii, and Puerto Rico,

the preferred alternative may allow for the introduction and subsequent 

establishment of nonindigenous species in these areas. 

Many plants that are classified as weeds have a suite of characteristics 

associated with colonization capabilities, some of which characterize 

orchids in general, including abundant seed production and distance 

dispersal. Most orchids occur in frequently disturbed habitats, 

including pastures, roadsides, citrus groves, and coffee and tea farms 

(Ackerman, 2007). Reports of orchids as weeds include Oeceoclades

maculata, which has recently naturalized in central and southern 

Florida (Pemberton et al., 2008). It is not known whether it escaped 

from cultivation or arrived in Florida via windblown seeds from the 

Greater Antilles or the nearby Bahaman Archipelago (FNA, 2003).

Monadenia bracteata is a species in Australia that flowers more 

abundantly after fire (Bates, 1996). The introduced Epipactis 

helliborine is an orchid with few growth requirements and high 

environmental adaptability that grows as a weed across much of the 

Eastern United States (McCartney, 2010). However, characteristics of 

weedy orchid species, such as limited growth requirements and high 

environmental adaptability, do not represent the basic biology of 

Oncidium.

The greenhouse conditions that favor Oncidium feature temperatures 

between 55 degrees Fahrenheit and 100 degrees Fahrenheit. Plants 

prefer moderate humidity, between 30 and 60 percent (American 

Orchid Society, 2013). Oncidium typically require a two to ten-day

“wet-to-dry cycle”, meaning before the roots are exposed to water, 

they must have remained completely dry for a period of two to ten
24

days. For this reason, Oncidium species are most successful when 

grown in a coarse, porous medium (American Orchid Society, 2013). 

In addition, Oncidium plants require 20 to 60 percent shade, depending 

on the species. These environmental conditions are limited to portions 

of Florida, Hawaii, and Puerto Rico. This constrains the potential of 

this genus to become invasive (Mooney and Hobbs, 2000; Cox, 1999; 

Zimdahl, 1999; Devine, 1998; Radosevich et al., 1997) and creates

environmental and spatial barriers to plant introduction into native 

ecosystems. 

 

Several arthropod pests (S. litura, T. palmi, A. lactinea, S. dorsalis, 

and T. kanzawai), mollusks (D. varians, L. alte, M. bilineatum, M. 

pictum, P. martensi, L. fulica, and P. vesta,), a bacteria (P. cypripedii), 

and a fungus (B. zizaniae) were identified as quarantine pests likely to 

be imported with unmitigated shipments of Oncidium orchids. To help 

protect against accidental importation, phytosanitary measures are 

required to minimize risk. 

Thrips palmi is subtropical to tropical in distribution, and cannot 

survive subzero temperatures for more than a few days. U.S. 

populations are restricted to American Samoa, southern Florida, 

Guam, Hawaii, and Puerto Rico (APHIS, 2012a). Thrips palmi is a 

serious pest of cucurbits and eggplant. The species is a vector of 

tomato spotted wilt tospovirus (CABI, 2001), which is difficult to 

control chemically, requiring repeated applications of insecticides to 

achieve acceptable levels of control (Sakimura et al., 1986). Its 

introduction would undoubtedly initiate control programs in areas of 

the United States because it is a major pest of numerous economic 

crops (e.g., beans, peppers, and tomatoes). Outbreaks in crops within 

the affected environment area would likely trigger increased chemical 

control programs similar to those now in effect for other caterpillars. 

Heavy infestations of thrips could cause dieback or death of host 

plants; however, outbreaks in other horticultural crops and orchids are 

not likely to occur due to its restricted host range. 

Spodoptera litura (S. litura), is distributed over a number of U.S. trade 

cooperators that feature subtropical and tropical climates. The 

leafworm causes major damage to tobacco, cotton, chilis, cabbage, and 

other crops, and has a host range of at least 120 species (CPC, 2002). 

Most damage by S. litura is caused by larval foliar feeding, but larvae 

may also injure cotton bolls, and corn stalks and ears. This insect has 

high dispersal capability and potential for a high level of economic 

impact if it were to become established in the United States. 

Spodoptera litura is similar in biology and host range to army worms 

already present in the United States. Outbreaks in crops would likely

1. Insects
25

trigger increased chemical control programs similar to those now in 

effect for other caterpillars. 

The host range of A. lactinea is very wide. It feeds on virtually all 

cultivated and wild vegetation, and is distributed over several 

subtropical and tropical countries. Amsacta lactinea may reproduce 

several times each year. This pest has a high reproductive potential, 

but because it is not a strong flier, its potential for dispersal is 

relatively low. 

The dispersal potential of S. dorsalis is informed by its ability to 

reproduce large numbers of offspring over a relatively short period of 

time, and is capable of flying long distances. It has a very large host 

range, including several crop species, and has been reported as a 

serious pest of numerous commodities in several countries. The 

majority of these commodities occur in the United States, and include 

onions, tomatoes, tamarind, cashews, castor beans, cotton, citrus, 

peanuts, peppers, chilies, mangos, litchis, strawberries, tea, soybeans, 

capsicum, and grapevines ((USDA-APHIS-PPQ-CPHST 2005)).

Tetranychus kanzawai feeds on more than 160 plant species, and has 

caused serious damage to cherries in China and strawberries in Taiwan 

(USDA, 2012a). The range of host species of this pest includes 

economically-significant crops to the United States. Its establishment 

in Puerto Rico and Hawaii could result in the loss of foreign markets 

for various agricultural commodities. This spider mite has a high 

reproductive potential and is able to disperse long distances in 

contaminated plant material. The female of T. kanzawai can mature 

and deposit up to 3,000 eggs during its life; several generations per 

year are possible. 

 

The terrestrial snails, D. laeve, L. alte, M. bilineatum, M. pictum, P.

martensi, L. fulica, and P. vesta, cannot travel long distances, unaided.

The most active individuals tracked in a study moved 500 meters in six 

months ((Tomiyama and Nakane 1993)), and natural spread is 

estimated to be a few hundred meters per year ((Lambert and Tillier 

1993)). Most can be transported for long distances on conveyances 

(transport vehicles) and non-host plant material (e.g., soil, gravel, and 

baggage) (CABI, 2011). Lissachatina fulica could be introduced on: 

bulbs, tubers, corms, rhizomes, leaves, roots, stems (above ground), 

shoots, trunks, branches. All of them could carry eggs, and juveniles 

that could be visible to the naked eye (CABI, 2011). The natural 

spread of these terrestrial snails appears to be limited, but their high 

reproductive potential and ability to be transported long distances 

increases the potential risks associated with these mollusks.

2. Snails
26

Snail feeding reduces plant quality and productive leaf area, and some 

snails clip off succulent plant parts ((Godan 1983); (Flinth 1999)). The 

introduction of the mollusk Bradybeana similaris into Louisiana and 

other states necessitated control treatments for this pest ((Aguirre and 

Poss 2000)). Parmarion cf. martensi could become an important 

vector of Angiosiorus cantonensis in Hawaii ((Hollingsworth et al. 

2007)). PPQ found no reports about agricultural losses caused by 

Petalochlamys vesta, but this species could be as destructive as 

Pomacea canaliculata because of the wide variety of plants it is able 

to feed upon and the huge population sizes ((Lee and Wu 2006)). The 

snails may alter the food chain in native ecosystems by providing an 

alternative food source for predators. This can have unfortunate 

consequences if the predator species is also invasive (APHIS, 2012a).

In Miami-Dade County, Florida, APHIS established a quarantine to 

control the spread of L. fulica . An eradication program began in late 

2012, and treatments are ongoing. In India, L. fulica, caused severe 

damage to vegetable crops and rice paddies during 1946-47 when it 

appeared in epidemic proportions (Pallewatta et al., 2002; (The Global 

Invasive Species Database 2006)). Lissachatina fulica may also 

increase the spread of certain plant diseases via its feces, such as black 

pod disease caused by Phytophthora palmivora ((Mead 1961); 

Muniappan et al., 1986, in (CABI 2011a)). Lissachatina fulica

consumes large volumes of native plants, modifies habitats, and outcompetes native snails (USDA, 2013). The snail may also alter the 

food chain within ecosystems by providing an alternative food source 

for predators ((Mead 1961)). 

Movement of P. cypripedii (bacterial brown rot) from plant to plant is 

sometimes facilitated by rain or water splash. In trade, it is likely to be 

moved by infected plants and compost. The host species for this 

bacterium are primarily limited to orchids, but also include the tropical 

papaya fruit tree.

The fungus B. zizaniae produces spores on infected tissue that are 

dispersed by rain or water splash and wind. The spores are very 

prolific and easily dispersed, surviving for an extended period of time 

in debris and soil. However, Oncidium is a secondary host of the 

fungus; its primary host is water bamboo, and only infects Oncidium

petals when in contact with infected water bamboo plants. 

C. Risk Management

Although the affected environment and the environmental 

consequences under both the no action alternative and the preferred 

alternative are the same, the risk management to prevent the 

introduction of pests differs between the two alternatives. The 

3. Bacteria

4. Fungus
27

following section discusses the phytosanitary measures imposed under 

the current importation scheme of bare-rooted Oncidium orchids (no 

action alternative) and the proposed phytosanitary measures for the 

import of these plants in growing media (preferred alternative).

The phytosanitary measures of the no action alternative would leave 

7 CFR part 319 unchanged. Currently, Oncidium and other orchids are 

imported as bare-rooted plants, growing on tree fern slabs, or in 

coconut husk or fiber (7 CFR § 319.37–8(d). All forms are enterable 

subject to inspection findings at designated ports of entry, that is, ports 

associated with facilities where propagative material can be examined 

(plant inspection stations). All orchid consignments must be 

accompanied by a USDA permit and a phytosanitary certificate issued

by NPQS. This document certifies that the orchids have been 

inspected and found free of quarantine pests before shipment to the 

United States. No special growing conditions are required for these 

plants. Oncidium plants imported bare-rooted generally do not have 

buds or flowers, and roots are not hidden from view within growing 

media; as such, visual inspection of these plants at the port of entry is 

effective. 

Inspections of bare-rooted orchid consignments are conducted by PPQ 

personnel at a plant inspection station at the first port of entry in the 

United States. These stations are staffed with PPQ pest identification 

specialists, as well as PPQ officers, who carefully examine orchid 

consignments. Inspection and examination may be limited to a 

verification of the contents and a review of the documentation, or may

consist of a standard inspection, including an inspection of at least 

2 percent of the plants in the shipment. If quarantine pests are 

discovered on bare-rooted orchid consignments, appropriate 

phytosanitary measures are conducted (e.g., treatment, destruction, or 

return of consignments to exporting country).

This section describes the phytosanitary measures required if 

Oncidium plants in approved growing media are imported into the 

continental United States from Taiwan. Amendment of 7 CFR part 

319, according to the proposed rule, would allow importation of 

Oncidium orchids from Taiwan rooted in approved growing media, 

provided the orchids were produced, handled, and imported in 

accordance with the requirements of 7 CFR § 319.37–8(e), and are 

accompanied at the time of importation by a phytosanitary certificate 

issued by BAPHIQ declaring that those requirements have been met.

Systems Approach

To effectively prevent the introduction of plant pests associated with 

plants grown in approved media, a series of important safeguards, 

1. No Action 

2. Preferred 

Alternative
28

(phytosanitary measures) must be in place. The risk management 

program used for plants in media is the systems approach—a defined 

set of phytosanitary procedures, at least two of which have an 

independent effect in mitigating pest risk associated with the 

movement of commodities. This approach relies on a series of 

phytosanitary measures that, individually and cumulatively, reduce the 

pest risk posed by pests that may be associated with plants. All phases 

associated with plants established in growing media—before planting, 

during the growing period, postharvest, during transport, and 

importation—are considered. 

The APHIS regulation on plants in media requires multiple 

phytosanitary measures designed to reduce the pest risk. The overall 

systems approach operates like as a fail-safe system in that tiered 

safeguards are built into the process. That is, if one mitigating 

measure fails, other safeguards exist to ensure that the risk is 

progressively reduced and managed. The systems approach is 

designed to apply all the measures to obtain the maximum risk 

reduction and to apply additional safeguards, as required. The steps or 

measures may overlap or be redundant to ensure an adequate reduction 

in pest risk, and that the reduction of risk is maintained during the 

entire process. These measures would be applied to the importation of 

Oncidium orchids from Taiwan in approved growing media.

a. Approved Plant Sources

The orchids imported into the United States will be greenhouse- or 

laboratory-propagated plants, or may be propagated in the laboratory

from aseptic tissue culture. Wild or collected specimens and

nondomesticated plants are not approved for importation into the 

United States. The plants must come from pest-free mother stock, as 

determined by a PPQ or an BAPHIQ inspector, no more than 60 days 

prior to the time the plants are established in the greenhouse.

b. Approved Growing Media

Plants offered for importation into the United States must be free of 

sand, soil, earth, and other unapproved growing media. This 

requirement helps prevent the introduction of plant pests that might be 

present in and around the roots, and also eliminates many soil- and 

root-associated saprophytic organisms. Exceptions to the growing 

media requirement reflect additional factors that mitigate plant pest 

risk. Those exceptions consider either the origin of the plants and the 

growing media (7 CFR § 319.37–8(b)), the nature of the growing 

media (§§ 319.37–8(c), (d)), or the use of a combination of growing 

conditions, approved media, inspections, and other requirements 

(§ 319.37–8(e)). Soil-less and new, unused growing media eliminate 
29

an initial source for pests, including S. litura, T. palmi, A. lactinea, S. 

dorsalis, and T. kanzawai, D. varians, L. alte, M. bilineatum, M. 

pictum, P. martensi, L. fulica, and P. vesta, P. cypripedii, and B. 

zizaniae. Studies on APHIS-approved growing media found that 

pathogens are not present (Santacroce, 1991). 

c. Agreements 

The orchids must be grown in accordance with written enforcement 

agreements between APHIS, BAPHIQ, and Taiwanese growers. This 

will include the preparation of an operational work plan that outlines 

specific detection and eradication protocols to detect and eliminate 

problem pests before the orchids are exported to the United States. 

The work plan also outlines how the program will be monitored and 

supervised to ensure compliance. Taiwanese orchid growers who plan 

to export Oncidium orchids in growing media must be registered with 

BAPHIQ; any grower not in compliance with the work plan 

requirements will be eliminated from the program.

d. Exclusionary Greenhouse 

The orchids for shipment must be grown in a pest exclusionary

greenhouse using the following phytosanitary measures: “Grown 

solely in a greenhouse in which sanitary procedures are adequate to 

exclude plant pests and diseases are always employed, including 

cleaning and disinfection of floors, benches, and tools, and the 

application of measures to protect against any injurious plant diseases, 

and injurious insect pests, and other plant pests” (7 CFR § 319.37–

8(e)(2)(ii)). These measures may include trapping, surveying, and 

scouting to determine if pests are present, and pesticide applications or 

other control measures to eliminate pests that are discovered.

e. Raised Benches

The height of the benches on which the orchids are grown must be at 

least 46 centimeters above the floor. Raised benches reduce the 

chance of water being splashed onto benches from the floors that 

might be contaminated with nematodes, pathogens, and weed seeds. 

Also, because snails and slugs have the capability to climb up sidings 

and posts, higher benches make it more difficult for snails and slugs to 

climb and decrease the chances that such pests will invade the plants 

and media. The benches must be supported by legs that have copper 

plates wrapped around each leg, or an equivalent means of preventing 

snail infestation.
30

f. Floors 

Greenhouse floors must be completely void of soil. They must be 

composed of permanent material that can be cleaned and sanitized to 

destroy pathogens and nematodes, and to prevent establishment of 

weeds. 

g. Automatic Doors 

Automatic closing doors are required to exclude flying insects from 

entering the growing area. They are also used, to a limited extent, to 

keep windborne pests from being blown into the growing area and 

provide a physical barrier that reduces the exposure of the plants to 

splashing by rain and irrigation water (Agrios, 1997).

h. Screens 

Greenhouses have vents or openings principally for the exchange of 

outside air and for temperature control. The addition of screens to 

these openings lowers the risk of certain pests entering the greenhouse. 

Screens must have openings no larger than 0.6 mm. Screens with 

0.6 mm openings do not exclude all pests; however, they will act as a 

deterrent or barrier to many pests, including S. litura, D. varians, and 

C. boninense.

i. Sanitation 

Sanitary procedures must be used to maintain the greenhouse 

relatively free of pests. A suitable disinfectant should be employed to 

sanitize the greenhouse interior prior to plantings to reduce pathogens, 

nematodes, and other pests. These procedures should also include 

keeping tools, hoses, benches, floors, work areas, and floor benches 

clean and properly sanitized. The grower should maintain a record of 

the number of times disinfection takes place.

j. Detention Periods 

Plant materials are commonly detained to allow time for certain pests 

to develop and become visible and detectable. Mother stock orchids 

must be grown in Taiwan for at least 9 months prior to export of 

descendant orchids to the United States. Mother plants imported into 

Taiwan from another country must be grown at least 12 months in 

Taiwan prior to the export of descendant orchids to the United States. 

The growing period can be reduced to 9 months, as above, provided 

there is a prescribed treatment of the mother stock upon importation of 

that plant into Taiwan. Descendant plants in media must be rooted and 

grown in an active state of foliar growth for at least 4 consecutive 
31

months prior to export. Detention periods are necessary to allow 

ample time for the expression of disease, symptoms, and other signs of 

pests.

k. Clean Water Sources

The water source for plant watering must be either rainwater that has 

been boiled or pasteurized, clean well water, or potable water. Water 

is considered one of the principal means for the dispersal of plant 

pests, including pathogens and snails; water from clean sources must 

be used to ensure that phytosanitary measures are effective.

l. Phytosanitary Certificate 

A phytosanitary certificate must be issued by BAPHIQ. This 

document must accompany the plants during importation and certify

that the required growing conditions were met. 

m. Inspection 

Inspections are an integral phytosanitary measure to reduce pest risk. 

In growing areas in Taiwan, inspection of Oncidium orchids in 

growing media is primarily the responsibility of BAPHIQ. Whenever 

pests of quarantine significance are found during inspection, 

appropriate action must be taken promptly, as outlined in the 

operational work plan. 

Mother stock must be inspected by a PPQ or a BAPHIQ inspector and 

found free of evidence of diseases and insect pests. The rationale is to 

inspect the mother stock in advance of any movement to ensure a pestfree source of plant material used for descendant plants. Inspection 

must take place no more than 60 days prior to the time the article is 

established in the greenhouse. Inspection of mother stock is a primary

measure to prevent the introduction of pests such as snails, insects, and 

pathogens into greenhouse crops.

For descendant plants, an inspection must be performed no more than 

30 days prior to the date of export, and must be done on the premises 

or site where the orchids are grown to prevent contaminants and 

hitchhikers from entering the shipment. Because the roots cannot be 

visually examined while in growing media, a small number of plants 

will be randomly inspected and removed from the media to examine 

the roots and the inside of the media ball.

PPQ inspectors will visit Taiwan periodically to ensure the program is 

working adequately, including review of treatment and control records 

generated by registered Taiwanese growers. 
32

At the port of entry in the United States, inspection of orchid 

consignments will be conducted by PPQ at plant inspection stations. 

These stations are staffed with PPQ pest identification specialists, as 

well as PPQ officers, who will carefully examine orchid consignments. 

Generally, initial consignments from a newly approved importation 

program (e.g., orchids in APHIS-approved growing media) are 

subjected to rigorous inspections that include the removal of plants 

from pots to examine roots and growing media. Once the program 

becomes established, the inspection and examination may be limited to 

a verification of the contents and a review of the documentation or the 

inspection may consist of a standard inspection of at least 2 percent of 

the plants in the consignment, including roots and growing media. 

Standard inspection techniques are highly likely to detect larger 

mature and juvenile forms of the snails D. laeve, L. alte, M. 

bilineatum, M. pictum, P. martensi, L. fulica, and P. vesta present on 

plants. Mollusks can also be detected by the slime trails, excrement, 

chewed leaves, and lesions they leave behind on plants. This would 

allow snails to be detected either before they enter the greenhouse or 

during required inspections. Small eggs in soil are difficult to detect; 

however, the use of clean, approved growing media not previously

used will reduce the likelihood of their presence. In addition, plants 

produced in APHIS-approved growing media under pest-exclusionary

conditions are expected to be free of snail eggs. 

Spider mites, such as T. kanazawa, can be detected by careful 

examination of the plant leaves. They are typically found on the 

underside of the leaf, where they feed. As a result, the upper surface 

of the leaf develops characteristic whitish or yellowish stippling. As 

mites move around, they spin webbing on leaves and stems. 

Early instar larvae of the red tiger moth, A. lactinea, cause damage to 

host plant leaves. Their presence can be detected by pellets of larval 

excrement, or whitish leaves, a result of early-instar larval feeding; 

heavy damage indicates the presence of late-instar larvae, which can 

be readily detected on the plants. Eggs may also be detected on the 

underside of the leaves, grouped in rows of 6-22, which make them 

easier to detect.

Because thrips are small, S. dorsalis can hide in plant parts and can be 

difficult to detect by visual inspection alone. However, plant material 

can be carefully examined for signs of infestation, such as scars, 

deformities, and discoloration. T. palmi, another thrips species, attacks 

the stem, particularly at or near the growing tip, and are also found 

amongst the petals and developing ovaries in flowers and on the 

surface of fruit. They leave numerous scars and deformities. 
33

The adult stage of the moth S. litura is 15–20 mm long with a 

wingspan of 30–38 mm, and is easily detected upon inspection. 

Newly hatched larvae can be detected by the “scratch” marks left on 

the leaf surface. Larvae are defoliators, which feed extensively on 

plants and produce visible leaf damage. Older larvae are night feeders 

and can be found in the soil around the base of the plants during the 

day. 

The fungus B. zizaniae is detected by spots on petals of Oncidium

orchids, which are easily identified by visual inspection. It is assumed 

that the fungus does not display dormancy, and that infected plants 

readily express symptoms. 

The bacterium P. cypripedii causes brown rot on orchids. Upon close 

inspection of the leaves, its presence easily detected by small, watersoaked lesions. The lesions will grow in size, into large brown, 

greasy-looking, slightly sunken areas. 

In order to protect against the introduction and spread of invasive plant 

pests and diseases, APHIS has established a risk-based sampling 

protocol for inspecting Oncidium from Taiwan at its plant inspection 

stations, prior to entry into the United States. In accordance with 

procedures directed by APHIS Agricultural Quarantine Inspection 

Monitoring (AQIM) protocol, if the frequency of interceptions of a 

quarantine pest surpasses the level specified in the risk-based sampling 

protocol, PPQ will require more specific mitigation against the pest(s) 

of concern. 

APHIS-inspected, -approved, and -registered greenhouses in Taiwan

will identify specific problem greenhouses or growers. In addition, if 

quarantine pests are discovered on orchid consignments at the port of 

entry, appropriate phytosanitary measures will be conducted (e.g., 

treatment, destruction, or return of consignment to exporting country).

n. Packing and Storing

Plants for export must be packed and stored in areas free of sand, soil, 

and plant pests. This will prevent contamination and the introduction 

of hitchhikers. Oncidium plants shall not be packed in the same 

container as prohibited articles.

Conclusions

APHIS has determined that quarantine pests are effectively removed 

from the pathway, and effectively precluded from establishment in the 

continental United States by the mitigation measures already present in 
34

the applicable regulations. The PRA has determined that importation 

of orchids (Oncidium spp.) from Taiwan, under the conditions required 

by 7 CFR § 319.37–8(e), pose no greater pest risks than the risks 

presented by other epiphytic orchid material currently allowed entry as 

bare-rooted plants. The same pests identified in the PRA that may be 

imported with orchids in growing media may also be imported with 

consignments of bare-rooted orchids currently being imported into the 

United States. The risk assessment concluded that application of 

additional safeguards will reduce the risk posed by the importation of 

Oncidium orchids in approved growing media to a level similar to that 

posed by currently permitted bare-rooted importations (APHIS, 

2012b). 

If quarantine pests accompanying Oncidium shipments were to 

become established in the United States, an eradication program would 

likely be initiated. Although eradication of any nonindigenous pest 

would require the use of pesticides, APHIS would prepare the 

necessary environmental documentation under NEPA and the 

Endangered Species Act (ESA) in advance of any eradication 

activities. 

D. Endangered Species Act

Section 7 of the Endangered Species Act (ESA) and the ESA’s 

implementing regulations require Federal agencies to consult with the 

U.S. Fish and Wildlife Service (FWS) and/or the National Marine 

Fisheries Service to ensure that their actions are not likely to 

jeopardize the continued existence of threatened or endangered species 

or result in the destruction or adverse modification of critical habitat. 

APHIS submitted a biological assessment (BA) to FWS, Arlington, 

Virginia, in compliance with Section 7 of the ESA. APHIS has 

determined that the proposed action may affect, but is not likely to 

adversely affect federally-listed plants and plants proposed for listing 

that are potential hosts of the 14 quarantine pests identified in the PRA 

or the designated or proposed critical habitat of those plant species. 

This includes all of the listed orchids and their critical habitat:

Cranichis ricartii, Lepanthes eltoroensis, Platanthera holochila, 

Spiranthes delitescens, Spiranthes parksii, Piperia yadonii, Isotria 

medeoloides, Spiranthes diluvialis, Platanthera leucophaea, and 

Platanthera praeclara), Allium munzii and critical habitat, Alopecurus 

aequalis var. sonomensis, Amaranthus brownii and critical habitat, 

Amaranthus pumilus, Achyranthes mutica and critical habitat, 

Achyranthes splendens var. rotundata and critical habitat, Aristida 

chaseae, Aristida portoricensis, Asplenium fragile var. insulare and 

critical habitat, Asplenium scolopendrium var. americanum, 

Calamagrostis hillebrandii, Cenchrus agrimonioides and critical 
35

habitat, Cereus eriophorus var. fragrans, Clitoria fragrans, Crotalaria 

avonensis, Cucurbita okeechobeensis ssp. okeechobeensis, Cyperus 

trachysanthos and critical habitat, Eragrostis fosbergii and critical 

habitat, Eryngium aristulatum var. parishii, Eryngium constancei, 

Eryngium cuneifolium, Euphorbia haeleeleana and critical habitat, 

Euphorbia telephioides, Festuca molokaiensis, Gardenia brighamii, 

Gardenia mannii and critical habitat, Helianthus paradoxus and 

critical habitat, Helianthus schweinitzii, Helianthus verticillatus and 

proposed critical habitat, Hibiscus arnottianus ssp. immaculatus and 

critical habitat, Hibiscus brackenridgei and critical habitat, Hibiscus 

clayi and critical habitat, Hibiscus dasycalyx and critical habitat, 

Hibiscus waimeae ssp. hannerae and critical habitat, Ilex cookii, Ilex 

sintenisii, Ischaemum byrone and critical habitat, Lilium occidentale, 

Lilium pardalinum ssp. pitkinense, Manihot walkerae, Neostapfia 

colusana and critical habitat, Opuntia treleasei, Orcuttia californica, 

Orcuttia inaequalis and critical habitat, Orcuttia pilosa and critical 

habitat, Orcuttia tenuis and critical habitat, Orcuttia viscida and 

critical habitat, Panicum fauriei var. carteri and critical habitat, 

Panicum niihauense and critical habitat, Pittosporum halophilum, 

Pittosporum hawaiiense, Pittosporum napaliense, Poa atropurpurea

and critical habitat, Poa mannii and critical habitat, Poa napensis, Poa 

sandvicensis and critical habitat, Poa siphonoglossa and critical 

habitat, Portulaca sclerocarpa and critical habitat, Prunus geniculata, 

Pteris lidgatei, Quercus hinckleyi, Rhododendron chapmanii, Scirpus 

ancistrochaetus, Sesbania tomentosa and critical habitat, Solanum 

drymophilum, Solanum incompletum and critical habitat, Solanum 

sandwicense and critical habitat, Swallenia alexandrae, Tuctoria 

greenei and critical habitat, Tuctoria mucronata and critical habitat,

Vicia menziesii, Vigna o-wahuensis and critical habitat, Viola 

chamissoniana ssp. chamissoniana and critical habitat, Viola helenae

and critical habitat, Viola kauaiensis var. wahiawaensis and critical 

habitat, Viola lanaiensis, Viola oahuensis and critical habitat, 

Zanthoxylum dipetalum var. tomentosum and critical habitat, 

Zanthoxylum hawaiiense and critical habitat, Zanthoxylum oahuense 

and critical habitat, Zanthoxylum thomasianum and critical habitat, 

Ziziphus celata, and Zizania texana and critical habitat. APHIS has 

requested concurrence with these determinations, and is currently 

engaged in consultation with FWS.

E. Other Considerations

Executive Orders

Executive Order (EO) 12898, "Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income 
36

Populations," focuses Federal attention on the environmental and 

human health conditions of minority and low-income communities,

and promotes community access to public information and public 

participation in matters relating to human health or the environment. 

This EO requires Federal agencies to conduct their programs, policies, 

and activities that substantially affect human health or the environment 

in a manner so as not to exclude persons and populations from 

participation in or benefitting from such programs. It also enforces 

existing statutes to prevent minority and low-income communities 

from being subjected to disproportionately high and adverse human 

health or environmental effects. Neither alternative poses 

disproportionately high or adverse human health or environmental 

effects to any specific minority or low-income group.

EO 13045, “Protection of Children from Environmental Health Risks 

and Safety Risks,” acknowledges that children may suffer 

disproportionately from environmental health and safety risks because 

of their developmental stage, greater metabolic activity levels, and 

behavior patterns as compared to adults. The EO, (to the extent 

permitted by law and appropriate, and consistent with the agency’s 

mission) requires each Federal agency to consider environmental 

health risks and safety risks that may disproportionately affect 

children. Neither alternative is expected to have disproportionately

high or adverse human health or environmental effects to children.

V. Listing of Agencies Consulted

Environmental and Risk Analysis Services

Policy and Program Development

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road, Unit 149

Riverdale, MD 20737–1238

Phytosanitary Issues Management

Plant Protection and Quarantine

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road, Unit 140

Riverdale, MD 20737–1228

Regulations, Permits, and Manuals

Plant Protection and Quarantine

Animal and Plant Health Inspection Service

U.S. Department of Agriculture

4700 River Road, Unit 141

Riverdale, MD 20737–1228
37

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