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4. U.S. Department of Agriculture, Animal and Plant Health Inspection Serv- 

 ice, Plant Protection and Quarantine maintains that their authority to conduct 

 inspections do not extend beyond their inspection for specific plant pests des- 

 ignated under USDA's 15 Federal quarantines, many of which are to keep Ha- 

 waii's pests from leaving the islands. The department also maintains that Fed- 

 eral magistrates would not issue warrants for pests that are confirmed by detec- 

 tor dogs because of Hawaii's broad definition of a pest under State law and 

 rules. 



What we have then is a State that would like equal protection from alien species, 

 a U.S. Postal Service that will allow for inspections through search warrant proce- 

 dures, a U.S. Fish and Wildlife Service that can invoke State laws only after a viola- 

 tion occurs, and a U.S. Department of Agriculture, which has inspection authority, 

 but only for a select number of plant pests that for the most part are of little con- 

 cern to Hawaii. Since USDA-APHIS-PPQ currently inspects outgoing mail, specific 

 language must be developed in this Act to give this agency the authority to also in- 

 spect incoming domestic mail for plant and animal pests as designated under Ha- 

 waii law. 



Our efforts to implement the Alien Species Prevention and Enforcement Act have 

 been very frustrating to say the least. Each year, new pests are discovered in our 

 islands causing problems to our growers and citizens. We continually capture or con- 

 fiscate prohibited animals, many of which have been turned loose or have escaped. 

 Last fiscal year (July 1, 1992 to June 30, 1993) alone, we captured, confiscatecf, or 

 investigated 42 lizards, 18 snakes, 22 turtles, 13 mammals, 25 oirds, 119 amphib- 

 ians, and over 5,000 arthropods that were illegal to possess in Hawaii. Many of 

 these animals probably entered the State under the "protection" of the first class 

 mail pathway. 



The second issue deals with USDA-APHIS-PPQ's Risk Assessment Pohcy and pol- 

 icy on "quarantine action pests." We understand that USDA-APHIS-PPQ policy re- 

 quires Federal inspectors to take action only on "quarantine pests" that enter Ha- 

 waii froni foreign areas. All other pests are referred to state inspectors, if available. 

 Perhaps it is time to review this pohcy in light of Hawaii's unique situation, it may 

 be that other States may also have unique situations as Hawaii. 



Unlike most other States, Hawaii's (1) heavy reliance on imports; (2) mild climate; 

 (3) diverse vegetation; and (4) lack of natural enemies result in a larger influx of 

 pests into the State from foreign areas, and a higher probability of those pests be- 

 coming established and causing damages. Furthermore, USDA-APHIS-PPO's recent 

 adoption of a "risk assessment policy on plants grown in media" that is based on 

 the economic importance of the crop places many of Hawaii's important crops in 

 jeopardy because of the minor crop status in the U.S. of Hawaii's economically im- 

 portant crops. 



Hawaii's limited island resources place a high demand on imports from abroad. 

 The ratio of total imports to Hawaii's gross State product is now 60 percent as com- 

 pared to 10 percent for the total contmental U.S. economy. This heavy reliance on 

 imports means a ^eater potential of pests being transported to Hawaii fi^om both 

 foreign and domestic areas. 



Establishment is relatively easy once the pest arrives. Our subtropical climate, 

 further moderated by the Pacific, provides year-round development for pest popu- 

 lations. Approximately 75 crops are commercially grown in Hawaii. Thousands of 

 other plant species — collectea from temperate, subtropical, and tropical areas 

 throughout the world — are used in Hawaii's landscaping, pastures, forests, and con- 

 servation areas. Insects from abroad would have no difficulty in finding a suitable 

 host in Hawaii. 



Because of our geographical isolation, Hawaii is also relatively devoid of the natu- 

 ral enemies common to continental areas, further making it easier for a pest to be- 

 come established, it is well known that the introduction of insects, previously 

 thought to be innocuous or of minor significance, have had devastating effects on 

 Hawaii's plant life and economy. 



Hawaii can no longer afford to act as a "stepping stone" or "buffer" for pests mov- 

 ing from the Orient, South Pacific, and Tropical America into the continental U.S. 

 USDA-APHIS-PPQ needs to give Federal PPQ inspectors broader authority to take 

 quarantine action on all pests entering Hawaii from foreign areas. Decisions on 

 what is a quarantine action pest in Hawai — should not be based on a risk assess- 

 ment that has evolved from knowledge of continental crops and economics — but 

 rather from one that is based on sound knowledge of local environmental and eco- 

 nomic factors. For Hawaii and other tropical/subtropical areas, all organisms that 

 feed on plants, or compete with other plants, should be treated as a potential quar- 

 antine action pest. 



