Protect Molokaʻi and the Rest of Hawaiʻi from Invasive Pests
Next Tuesday, the Board of Agriculture and Biosecurity (“BAB”) will be considering two items that have raised significant concerns from the Molokaʻi community and biosecurity stakeholders throughout the islands.
First, BAB will consider a petition from the superintendent of the Kalaupapa settlement on Molokaʻi, asking for an exception to the ban on the importation of coconut rhinoceros beetle (CRB) host material passed late last year. Notably, while the request comes from Kalaupapa superintendent, it would allow for the importation of “treated” gravel anywhere on Molokaʻi. Topside residents who organized and advocated successfully for the importation ban were not consulted by the petitioner, and the recent discovery of CRB for the first time on Molokaʻi over the last several weeks makes clear that this is NOT the time to loosen CRB protections, or distract from current rapid response efforts to detect and eradicate any potential infestations.
Second, legislators have been raising concerns - validated by the Attorney General - that Department of Agriculture and Biosecurity (“DAB”) inspectors are not complying with the law, by allowing goods “lightly infested” with unspecified invasive species to enter the state without treatment or eradication, when those species are already known to occur in some parts of the islands. In response, BAB will consider a rule proposal to designate what invasive species will be considered a “pest” subject to regulatory action, including during importation into the islands and interisland transportation. The problem? The list of designated “pests” is based on a list from 2008 - omitting species, like the two-lined spittlebug, hala scale, and queensland longhorn beetle - that have since been recognized as posing major threats to our islands’ biosecurity. Clearly, this rule proposal must be much more thoroughly developed before it advances to a formal public hearing, and its outdated list of designated pest species are “locked in” for the foreseeable future.
Please take a moment to testify - sample testimony and testimony instructions below!
Sample Testimony
To: DAB.BOARD.TESTIMONY@HAWAII.GOV
Subject: Testimony on Agenda Items C-2 and C-3.
Aloha Chair Hurd and Members of the Board of Agriculture and Biosecurity,
My name is [your name] and I am a resident of [your island/moku/ahupuaʻa]. I respectfully urge you to REJECT the staff recommendations in items C-2 and C-3, concerning 1) the petition for an exception to the Molokaʻi coconut rhinoceros beetle (“CRB”) rules you adopted last year, and 2) a rulemaking proposal to designate certain invasive species as “pests” subject to “regulatory action” by the Department of Agriculture and Biosecurity (“DAB”).
First,with regards to C-2, I stand with Molokaʻi residents who successfully advocated for last year’s historic CRB emergency rule for Molokaʻi, in urging you to reject the petition for an exception to this rule.
Notably, while submitted by the Kalaupapa superintendent, the petition would allow for “treated” gravel to be imported to any part of the island. However, despite the wide-ranging implications and increased risk of CRB introductions, the petitioner still has not met meaningfully with the larger Molokaʻi community. Instead, it has substituted community consultation with a survey it appears to have developed on its own, and circulated among only a few dozen individuals, nearly all from Kalaupapa. Minimally, much more community conversation and dialogue is needed before you even consider this controversial ask.
Beyond the need to actually consult with the larger community, including and particularly the advocates for last year’s importation ban, this petition should also be rejected as particularly untimely. With multiple recent detections of CRB on Molokaʻi for the first time ever, now is not the time to relax protections against the further introduction of CRB to the island, nor is it the time to distract from or disrupt the active rapid response efforts being undertaken by the Molokaʻi community to detect and eradicate any potential CRB infestations as soon as possible.
Second, with regards to C-3, I have grave concerns about moving forward with a list of designated pests, based only on certain species of concern identified over 18 years ago. The 2008 list of invasive species proposed for “pest” designation and regulatory action - such as importation bans and intrastate movement prohibitions - ignores a number of invasive species that have arisen as serious threats since that time, as well as the extensive work that has been done to identify additional species of concern (such as the queensland longhorn beetle, the two-lined spittlebug, or the hala scale) over the last 5 years. Please do not “lock in” official pest designations to only those invasive species that were deemed a threat nearly two decades ago, and urge DAB staff to “go back to the drawing board” to consult with experts and community members who have been at the forefront of our current fight against invasive species.
Mahalo nui for your consideration of this matter.
Testimony Instructions
Written Testimony: E-mail your testimony (sample testimony above) to DAB.BOARD.TESTIMONY@HAWAII.GOV.
Verbal Testimony: On Tuesday, April 28, starting at 9 a.m., go to the Plant Quarantine Branch headquarters at 1849 Auiki Street, Honolulu, Hawaiʻi 96819 or log into the meeting Zoom link at https://us02web.zoom.us/j/86320553662 and “raise your hand” when calls for public testimony are announced (more testimony options and instructions can also be found on the meeting agenda here).