08/24/2019
All fellow Beekeepers, USDA is considering release of a biological control to eradicate Japanese Knotweed, along with Giant and Bohemian Knotweed. Japanese Knotweed is a nectar plant in bloom NOW and is one of the few nectar sources our bees have at this time of year.
You already received the comment letter written by the Pollinator Stewardship Council. They have asked the Individual Beekeepers send their support to USDA by following the instructions below.
If you agree with, and want to support the Pollinator Stewardship Council in their efforts to protect forage for our Honey bees and also Native Pollinators, please follow the following steps:
1. Go to: https://www.regulations.gov/
2. Search on "Knotweed"
3. Choose and click on the one that says: Environmental Assessments; Availability, etc.: Release of Aphalara Itadori for the Biological Control of Japanese, Giant, and Bohemian Knotweeds
Notice by APHIS on 08/02/2019 ID: APHIS-2019-0002-0239
4. Click on "Comment Now!"
5. Copy and past the below comments into the comment block or write your
own comments in.
6. Fill out the name blocks and agree, and submit comments.
This is the letter you can use:
I join with the Empire State Honey Producers Association and the Pollinator Stewardship Council expressing concern of the proposed method of removal of Japanese, Giant, and Bohemian Knotweeds from the landscape. The proposed action of USDA-APHIS to release a foreign exotic agent for the biological control of an exotic plant is narrowly focused, presents no plan for comparable replacement of a nectar source for honey bees or for water control on vacant urban lots and therefore mosquito control, or for restoration of native plant diversity to prevent soil erosion.
Value to Pollinators
“When blooming (July to September), the plant puts on an attractive floral display befitting the common name ‘fleece flower’.”1 “Japanese knotweed is highly regarded for its attractive flowers and has been planted by beekeepers for its nectar.”2 “Knotweed is “ alive with pollinators and are particularly attractive to honey bees. Many beekeepers manage to harvest a monofloral honey from the vast stands found locally. And if you don’t harvest, it makes a great late-summer boost to a colony’s winter pantry.”3 “The honey is dark and flavorful, and many people compare it to a mild form of buckwheat honey.”4
“Bee lovers have found another use for Japanese knotweed. The hollow stems are often cut into lengths and bundled for use as native bee habitat. The stem diameters vary just enough to provide suitable housing for a wide range of tunnel-nesting bees, including mason bees and leafcutters.”5
Range of Invasive Plant
Like many invasives, knotweed is beneficial in some areas, and damaging to the ecosystem in others. Knotweed is found throughout most of the United States, “especially in urban and suburban landscapes, roadsides, gullies, and waste areas.” 6 “It is often associated with moist but well-drained sites with nutrient-rich soil, and it tolerates semi-shaded environments. It has also been planted in sandy sea-shore areas where it stabilizes soil and withstands salt and low nutrients.”7 “It has been planted along highways to control soil erosion and has been used for revegetation of strip-mine spoil and to stabilize land affected by volcanoes.”8
When we compare the range of the Knotweed with the range of disease-carrying mosquitoes, the plan to remove Knotweed is problematic. It is a plant found on vacant lots in urban areas and which absorbs standing water; breeding sites for mosquitoes. Vacant lots would benefit from the implementation of a native plant re-introduction plan that will absorb standing water, mitigating the risk of mosquito breeding sites, and the spread of disease. Removal of knotweed with no plan for replacement with native plants or mitigation of standing water will support mosquito habitat, thus impacting human health concerns from disease carrying mosquitoes.
Management
To manage invasive species of plants Physical or Mechanical Control, Chemical Control, Cultural Management, and/or Biological Controls are the methods in place now. As Japanese knotweed exhibits great tolerance to most herbicides9 it is critical to have a variety of “tools in the toolbox,” to control this non-native plant. Mechanical controls appear to have the best success, whether from weekly mowing, or digging up the plant. However, if another plant is not put in place, then knotweeds’ resilience to survive will lead to its return.
Proposed Release of Non-Native Pest
USDA-APHIS has presented a rationale for this additional knotweed control tool, but they need to complete the plan for the release of a non-native pest into the US ecosystem. We are concerned as to your statement, “These permits would contain no special provision or requirements concerning release procedures or mitigating measures.” 10
The Proposed Action needs to:
Provide release procedures and mitigating measures relevant to the introduction of this non-native pest;
Examine how to control the psyllid if it does attack native plants; Develop a replacement planting plan for native plants, especially for those that bloom in the fall and provide forage for honey bees, and native pollinators;
Introduce a genetic marker to track the released A. itadori;
Detail the post-release monitoring plan for A. itadori.
Management of knotweed, and other invasive plants is a “long term venture.” Knotweed is an invaluable honey bee forage vital to sustaining these crop pollinators through the winter so they are available for the next growing season.
Sincerely,
Take action and submit your comments at http://pollinatorstewardship.org/index.php/current-action-to-take-for-pollinators/
