Detailed Information on the
Emergency Pest and Disease Management Programs Assessment

Program Code 10003004
Program Title Emergency Pest and Disease Management Programs
Department Name Department of Agriculture
Agency/Bureau Name Department of Agriculture
Program Type(s) Regulatory-based Program
Assessment Year 2005
Assessment Rating Moderately Effective
Assessment Section Scores
Section Score
Program Purpose & Design 100%
Strategic Planning 100%
Program Management 100%
Program Results/Accountability 67%
Program Funding Level
(in millions)
FY2007 $312
FY2008 $360
FY2009 $277

Ongoing Program Improvement Plans

Year Began Improvement Plan Status Comments

Adding a new long-term performance measure to quantify the value of damages prevented or mitigated by the Emergency Pest and Disease Management Programs.

Action taken, but not completed APHIS is in the process of implementing this measure. They anticipate collecting baseline data soon.

Develop at least one measure to show levels of cooperator funding as a percentage of the overall program.

Action taken, but not completed APHIS is in the process of developing the methodology behind this measure. APHIS anticipates the measure to be implemented in FY 2010.

Continuing to review and implement methods and strategies for containing and/or eradicating emerging plant pests.

Action taken, but not completed APHIS has conducted enhanced management and strategic planning regarding the Emerald Ash Borer (EAB) program. APHIS is conducting the follow-up actions that resulted for this process. Management and strategic planning has been initiated for the Potato Cyst Nemotode, the Asian Longhorned Beetle, the Glassy-Winged Sharpshooter Programs.

Completed Program Improvement Plans

Year Began Improvement Plan Status Comments

Develop annual measures for other diseases, such as citrus canker, Emerald Ash Borer and Pierce's Disease.

Completed APHIS has developed annual measures for citrus canker, emerald ash borer, and Pierce??s disease.

Program Performance Measures

Term Type  
Annual Output

Measure: Trees to be treated for ALB.

Explanation:Treating trees protects them from infestation by ALB, thereby reducing the available host material for the beetles and preventing the pest from spreading.

Year Target Actual
2004 Baseline 58,021
2005 81,600 63,006
2006 71,365 50,698
2007 65,221 65,927
2008 60,000
2009 60,000
2010 60,000
Annual Efficiency

Measure: Percent reduction in average Asian Longhorned Beetle treatment cost per tree in New York State (NYS). (Cumulative savings from FY 2003)

Explanation:The measure captures the amount saved in treating infected trees in NYS.

Year Target Actual
2004 Baseline 20%
2005 46% 56%
2006 56% 59%
2007 57% 57%
2008 57%
2009 57%
2010 57%
Annual Outcome

Measure: Square miles regulated for ALB.

Explanation:This measure tracks the area under quarantine for ALB.

Year Target Actual
2003 Baseline 167
2004 183 183
2005 153 157
2006 157 157
2007 157 166
2008 165
2009 165
2010 165
Long-term Outcome

Measure: EPP pests/diseases not contained within the quarantine area.

Explanation:The measure captures plant pests such as: Citrus Canker, Sudden Oak Death, Emerald Ash Borer, Asian Longhorned Beetle, and Glassy-winged Sharpshooter.

Year Target Actual
2003 Baseline 5
2004 4 3
2005 2 2
2006 2 4
2007 3 1
2008 1
2009 1
2010 1
2011 1
2012 1
Annual Outcome

Measure: States and territories whose annual tests of all swine herd for Pseudorabies are negative.

Explanation:For the long-term measure to be successful, a statistically valid number of swine herds must be tested with negative results. If the herds test negative, maintenance of stage V (free) status continues, and commercial production herds in the State are at a lower risk for the reintroduction of the disease.

Year Target Actual
2003 Baseline 42,3
2004 48,3 48,3
2005 49,3 50,3
2006 50,3 50,3
2007 50,3 50,3
2008 50,3
2009 50,3
2010 50,3
Long-term Outcome

Measure: Number of States and territories in Stage V status free of pseudorabies disease in commercial production swine.

Explanation:The national pseudorabies program enables APHIS to obtain an accurate picture of the scope of the disease in the U.S. swine populations. The program provides the means to demonstrate disease freedom or very low risk of disease in commercial production swine for trading purposes.

Year Target Actual
2004 48,3 48,3
2005 50,3 50,3
2006 50,3 50,3
2007 50,3 50,3
2008 50,3
2009 50,3
2010 50,3
2011 50,3
2012 50,3

Questions/Answers (Detailed Assessment)

Section 1 - Program Purpose & Design
Number Question Answer Score

Is the program purpose clear?

Explanation: The Animal and Plant Health Inspection Service (APHIS) is authorized and required to safeguard U.S. agriculture and natural resources from pests and diseases. APHIS safeguards plant and animal health, and facilitates safe agricultural trade. To achieve these goals, the Agency responds to emergencies with quick detection, containment, and eradication. APHIS' Pest and Disease Management Programs minimize agricultural risks by controlling and/or eradicating agricultural pests and diseases, and wildlife damage. This PART includes a number of emergency management programs (such as citrus canker) that are designed to mitigate significant, imminent threats to agriculture, while reducing our reliance on emergency funds. Conversely, other management programs (such as Johne's disease) warrant ongoing, routine activities that yield gradual progress toward program goals.

Evidence: The Act of March 2, 1931, (46 Stat. 1468) that addresses Animal Damage Control; the Animal Health Protection Act of 2002 (7 USC sec. 8301); the Animal Industry Act of 1881 (21 USC sec. 114); the Plant Protection Act of 2000 (7 USC sec. 147); and, the Public Health Security and Bioterrorism Response Act of 2002 (PL 107-188 sec. 211-231). This legislation enables us to cooperate with States to protect American agriculture by eradicating harmful pests and diseases or - where eradication is not feasible - by minimizing their economic impact. Within the scope of this authority, APHIS has defined Emergency programs as those programs that have either recently received emergency funding or have recently received rapidly growing appropriated dollars for pest or disease management purposes.

YES 20%

Does the program address a specific and existing problem, interest, or need?

Explanation: These represent individual infestations which APHIS works to eradicates. Some are individually identifiied line items, and some are categorized under the line item "Emerging Plant Pests." APHIS' Pest and Disease Management Programs are designed to limit the potentially significant damage caused by pests and diseases established in the United States, eradicate established or domestic pests and disease, and manage wildlife damage. For example, Citrus canker has existed in Florida since 1996 and continues to be a threat to nationwide citrus production. How quickly this devastating disease can spread was seen in 2004 when hurricanes spread citrus canker across significant portions of the state. The Asian Longhorned Beetle (ALB) was first detected in New York State in FY 1997, but was detected most recently in 1 square mile in New Jersey in August 2004, proving it is still a threat. Left untreated, this infestation will expand beyond 100 square miles within 2 years.

Evidence: ALB can cause $670 billion in replacement value to the urban environment, and would cause irreversible loss to native tree species if left untreated. Chronic Wasting Disease impacts the $9.4 billion farmed and wild cervid industry. The Chronic Wasting Disease program works cooperatively with States to provide disease surveillance in wild cervids. Identifying this disease in the wild reduces the potential for CWD spread to captive cervid herds, thereby protecting the farmed cervid industry and its related economic value. If Citrus Canker becomes widespread in Florida, the combined yield and market loss could reach $500 million per year. Also, APHIS would need to establish a State-wide quarantine. The Agency also helps producers manage animal damage and disease, and miscellaneous plant pests. Examples include avian influenza, bovine tuberculosis, grasshoppers, Johne's disease, plum pox virus, scrapie, and wildlife rabies.

YES 20%

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: APHIS - in partnership with other Federal, State, and local entities - has designed unique programs to minimize agricultural risks by effectively managing agricultural pests and diseases and wildlife damage on an interstate level. The Agency exists as part of a larger community and works to develop productive and cooperative relationships within that community. The Agency creates strategic alliances with stakeholders to accomplish program goals. Industry cooperation is cultivated through effective partnership agreements and open communication with stakeholders. APHIS uses cooperation and partnership strategies to encourage informed compliance with regulations and statutes, but recognizes the need to address non-compliance vigorously when cooperative efforts falter. In larger programs involving several States, APHIS coordinates contributions from each State and facilitates the flow of information.

Evidence: APHIS is authorized and required to safeguard U.S. agriculture and natural resources by legislation. These statutes delegates to APHIS sole responsibility for regulation and control of importation and interstate movement of plants and animals, and only this responsibility. Under its authority, APHIS coordinates program-wide activities across all affected States. For instance, the Agency coordinates and leads state programs affected by the Emerald Ash Borer. This includes Indiana, Michigan, and Ohio. APHIS is also the lead agency charged with policies and actions to eradicate the plum pox virus. The Agency works with the state of Pennsylvania and local entities to prevent the virus from spreading beyond the current infected area. Since APHIS has the authority, capability, and expertise to carry out wildlife management activities, the Agency assists the Federal Aviation Administration in preventing wildlife strikes with aircrafts.

YES 20%

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: The Agency continually assesses each program to ensure implementation maximizes effectiveness, efficiency, and maximization of benefits. The Agency uses technical expertise in many areas to achieve the highest degree of effectiveness. In addition, APHIS' program designs are internationally accepted. For example, other countries have adopted the Agency's strategy of the Citrus Canker Program. The Agency continually reviews program designs to achieve the highest level of effectiveness and efficiency. APHIS often uses cooperative agreements to help accomplish program goals efficiently and effectively. In a vast majority of cases, we prefer to use cooperative agreements rather than grants because the agreements enable us to delegate certain activities while still maintaining ultimate control of these activities. We delegate activities to entities that have a local infrastructure, and local expertise and contacts. State regulations sometimes make it easier and quicker to accomplish certain tasks.

Evidence: Several APHIS program designs are internationally accepted. For instance, the Agency's bovine Tuberculosis (TB) program served as a model to the Bovine Tuberculosis Eradication Program of Mexico. Also, a joint U.S.-Mexico Tuberculosis Committee was formed to support initiatives aimed at disease eradication in both countries. The APHIS review team frequently evaluates Mexico's TB activities and provides recommendations upon review. In addition, the Agency provides training and technical support to the Mexican program. Since Mexico borders the United States and is a major exporter of livestock, these activities also safeguard U.S. livestock. Moreover, APHIS officials have presented upon request the Agency's strategy to several international conferences, such as Avian Disease Control presented in 2004 at the International Conference on the Control of Infectious Animal Diseases by Vaccination. APHIS also delegates programmatic tasks to the States in order to maximize effectiveness. For example, our citrus canker program requires approximately 1,000 temporary workers at any given time. State hiring practices in Florida enable the program to hire these workers more rapidly than would be possible under Federal regulations. As a result, infected tress can be discovered and destroyed earlier, and disease spread can be minimized increasing the program's effectiveness.

YES 20%

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: APHIS assesses each individual threat to U.S. agriculture to determine and target the primary beneficiaries. The Agency directs resources to program areas based on these scientifically-based risk assessments. APHIS communicates regularly with State and industry cooperators to ensure funding reaches intended beneficiaries. APHIS funds over $7 million in State and Tribal cooperative agreements to provide disease surveillance in wild cervids in areas where Chronic Wasting Disease is present. Identifying this disease in the wild reduces the potential for CWD spread to captive cervid herds, thereby protecting the farmed cervid industry and its related economic value. APHIS also regularly works with States and the cattle industry to ensure that all concerns regarding bovine tuberculosis are addressed.

Evidence: APHIS' Emerald Ash Borer Program recently completed a strategic planning review to ensure resources are targeted to the highest priority components of the program. The ALB Eradication Program is supported by APHIS methods development projects, as well as by research and technology development conducted by the U.S. Forest Service, the Agricultural Research Service, and university scientists in the United States and in China. USDA scientists work with Chinese officials to develop better control methods and treatment techniques, while researchers explore enhanced detection and trapping tools. APHIS also received praise from the Airlines Pilots Association for preventing wildlife strikes on aircraft. APHIS has worked with 10 States through cooperative agreements to control low pathogenic avian influenza.

YES 20%
Section 1 - Program Purpose & Design Score 100%
Section 2 - Strategic Planning
Number Question Answer Score

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: APHIS' emergency pest and disease management programs have long term measures to support the program goals of eradicating and/or controlling serious agricultural pests and diseases. Since the overall goal of the program is the eradication of specific pests and diseases, APHIS has included one long term measure showing the number of pests and diseases (addressed by Emerging Plant Pests program (EPP) that have not been contained in a quarantine area. APHIS is working on a new measure that will demonstrate the value of damage prevented or mitigated by APHIS programs. The EPP and pseudorabies programs that are reflected in the measures represent a significant portion of the emergency programs, and include several important infestations, such as the Asian Longhorned Beetle (ALB), the Emerald Ash Borer (EAB), Sudden Oak Death (SOD) and citrus canker. Pseudorabies is included since it serves as a current success story that is being used as a model for other programs.

Evidence: The long-term measure for the EPP program is the number of pests/diseases not controlled within the quarantine area. This measure tracks the programs' success in preventing five serious pests (ALB, EAB, SOD, glassy-winged sharpshooter, and citrus canker) from spreading to new areas. Preventing pest spread protects resources surrounding the infested areas and allows the program to concentrate on eradication activities within a limited area. The Pseudorabies program's long-term performance measure is the number of States and territories that have reached Stage V status free for Pseudorabies disease in commercial production swine. This measure allows the program to evaluate its success in eradicating this specific disease.

YES 11%

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: The long-term target is to have no more than one pest/disease not contained within the quarantine area. The pseudorabies program's goal is for all 50 States and three territories to achieve Stage V Free Status by FY 2006. This is a significant improvement over FY 2003, when only 42 States and 3 territories had reached Stage V Status. Even though the measure showing the number of pests that escape from quarantine does not change from FY 2007 to FY 2009, it can still be considered to be ambitious, since this measure also includes unexpected emergency pests and diseases with which they also have to deal. In addition, one of the diseases, citrus canker spread in Florida due to the unexpected number of hurricanes affecting that State in 2004.

Evidence: The EPP measure tracks the program's success in preventing five serious pests (ALB, EAB, SOD, glassy-winged sharpshooter, and citrus canker) from spreading beyond their quarantine areas. Three of these were not contained in FY 2004: Citrus Canker, Sudden Oak Death (SOD) and Emerald Ash Borer (EAB). Containing these pests within their quarantined areas is an ambitious task considering the ease with which all three can be spread through the movement of regulated articles (such as nursery stock for SOD or firewood for EAB), natural spread, and, for citrus canker, hurricanes which frequent the quarantine area. Containing at least two of the three by FY 2006 will require intense quarantine enforcement and survey activity for all three and enhanced tree removal for EAB and citrus canker. The pseudorabies program goal is ambitious because the program expects to continue making progress toward eradication while maintaining surveillance activities to ensure that disease-free areas remain free, while just two years ago 8 States detected infected herds. The program cleaned them up quickly and is back on track to eradicate the disease.

YES 11%

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: The emergency programs have specific annual performance measures that demonstrate progress toward their long-term goals. The Asian Longhorned Beetle, a major eradication program has targets that show a reduction in the number of acres under quarantine and an increase in the number of trees treated to protect them from the disease, which directly affects the long term measure related to emerging plant pests. The number of States and territories that annually test all swine herds and achieve negative results supports the long term goal of eradicating pseudorabies by ensuring States maintain their negative status.

Evidence: One of the EPP program's annual measures is the number of trees treated in New York State. Treating trees protects them from infestation by ALB, thereby reducing the available host material for the beetles and preventing the pest from spreading. An example of one of four pseudorabies measures is the target in FY 2004 which was to have 48 States and three territories that annually test all swine herds negative for pseudorabies. The target was met. The target for this measure in 2006 is 50 states and three territories.

YES 11%

Does the program have baselines and ambitious targets for its annual measures?

Explanation: APHIS has baselines and ambitious targets for its annual measures that allow for continued improvement. Each program assesses its work load and establishes the maximum amount that can be accomplished with the available funding. If performance targets are achieved, the program reassesses future targets, and when applicable, increases that target.

Evidence: The ALB program's targets for the number of trees to be treated are 81,600 for FY 2005 and 84,000 for FY 2006 (up from 58,201 trees treated in FY 2004). These targets are ambitious because the program is maintaining as fast a pace as possible while its resources are decreasing. The pseudorabies program's annual measure of the number of states that achieve negative results for all swine herds for pseudorabies will increase from 48 to 50 in FY 2006. In FY 2004, eight animals tested positive. This information allowed the program to take necessary actions to avoid any impact to the industry. This demonstrates the relationship between effective surveillance and effective eradication efforts; the program must increase both activities at once while its resources remain the same.

YES 11%

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: APHIS uses cooperative agreements and Memoranda of Understanding (MOU) to hold program partners accountable for the achievement of annual and long-term goals. State and university partners are committed because in most cases they have the same stakeholder base as APHIS. Furthermore, cooperators, whose resources are directly affected by the program, cost share on many of programs activities, which commits them to the program goals, since they have a financial stake in program success. Many cooperative agreements incorporate performance measures that indicate progress toward achieving program goals.

Evidence: Cooperative agreements and MOU's have specific work and spending plans that tie to APHIS goals. Many cooperative agreements incorporate performance measures that track progress toward the agency goals. This evidence can be found in cooperative agreement 03-97290007-CA dealing with brucellosis (which sets testing data targets for states) and 04-8251-0434-CA requiring surveillance of Sudden Oak Death. The National Pseudorabies Eradication Program Standards were developed, and are updated annually by APHIS, through the cooperation and recommendations from swine health practitioners, industry representatives, and state animal health officials at the annual meeting of the U.S. Animal Health Association. The pseudorabies program collects testing data to measure its performance through information required in cooperative agreements with the states. The Chronic Wasting Disease program worked with the Department of Interior, U. S. Geologic Survey, National Park Service, U. S. Fish and Wildlife, as well as private partners to develop a national plan for addressing the disease, and the task force meets regularly to evaluate the program's progress towards its long-term goals.

YES 11%

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: Independent evaluations of sufficient scope and quality are conducted as needed to support program improvements and evaluate program effectiveness and relevance to APHIS' interest in safeguarding American agriculture from pest and disease outbreaks. Many of the management and control programs are reviewed annually by review boards made up of industry stakeholders or science advisory panels. Science advisory panels, which sometimes have representatives from APHIS' Center for Plant Health Science and Technology, are entirely independent of the programs and conduct comprehensive reviews of how specific pest eradication programs operate. Science panels review program design and available technology for survey and eradication, as well as how programs are using technology. Stakeholder review boards evaluate programs annually. Other evaluations are conducted as needed. For example, the EAB science panel has reviewed the program six times within three years. Additionally, several Emerging Plant Pest (EPP) programs are undergoing program reviews in the summer of FY 2005. These review boards are formed for the specific purpose of the review and will not have any conflicts of interest with the program managers.

Evidence: The EAB program has been reviewed six times by its science advisory panel which ecommended the use of new survey tools and strategies and identified high priority areas to implement to meet program goals. The program has implemented changes recommended by the panel such as moving employees and resources to these high-priority areas to improve its effectiveness.. Program reviews scheduled this year for the Asian Longhorned Beetle (ALB) and EAB will evaluate all program aspects, including technical, management and financial.

YES 11%

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: The program budget is aligned with the program goals. The planning and budgeting process specifically identifies program results with changes in funding, policy, or legislative mandates. The program budgets for all costs allocated to and paid for by the agency, and resource needs are presented in a complete and transparent manner in the program's budget.

Evidence: Transparency in resource needs is attained by the inclusion of Budget Object Class codes in Decision Memos when emergency funds are requested. Furthermore, in the Explanatory Notes submitted to Congress as the official budget request we specifically link funding requests to performance targets. For example, with a funding increase requested for the EPP program in FY 2006, the program plans to reduce the number of square miles infested with ALB from 215 to 185, demonstrating the link between the budget request and performance.

YES 11%

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: As noted in questions 2.1 through 2.4, the Pest and Disease Management program has specific long-term and annual performance goals. The program regularly reviews its progress toward meeting the goals in conjunction with its strategic plans to address any deficiencies. If a program is not meeting its targets, program officials review all aspects of the program, including its strategy and operational management.

Evidence: Several individual programs have revised their strategic plans to address planning deficiencies. For example, the EAB program conducted a strategic planning review because of a significant number of EAB detections outside the quarantined area. Based on these detections, the program set a new goal of preventing the pest from spreading beyond areas defined as "gateways" and developed new performance measures. Based on its new strategic plan, the program is also enhancing its focus on quarantine enforcement, allocating funds to the highest-priority sites, and moving offices and employees to accomplish high-risk activities.

YES 11%

Are all regulations issued by the program/agency necessary to meet the stated goals of the program, and do all regulations clearly indicate how the rules contribute to achievement of the goals?

Explanation: Regulations are necessarily issued by the program to meet the program goals. All regulations clearly indicate how the rules contribute to the achievement of the goals. USDA regulations have a preamble stating the goal of the program to justify the need for the regulation.

Evidence: All regulations appear in the Federal Register and are reviewed by APHIS regularly. For example, the EAB program's quarantine regulations prohibiting the movement of host materials out of infested areas are critical to meeting the program's goal of preventing the spread of EAB. The regulations clearly explain the relationship between the movement of host material and spread of the pest and detail how the quarantine contributes to the goal of the program.

YES 11%
Section 2 - Strategic Planning Score 100%
Section 3 - Program Management
Number Question Answer Score

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: APHIS collects periodic performance information to determine where to direct funding and resources. Performance data is collected through an automated process or through a web-based system. After the data is entered, a quality control process allows States to review the data to confirm its accuracy. In addition, APHIS often meets with cooperators to evaluate the management and effectiveness of program activities.

Evidence: APHIS uses performance information to align resources with needs and manage work load efficiently. For example, the Scrapie program identified a need to adjust sample collection at meat processing plants through an analysis of performance data. The program collects samples for testing from 40 slaughter facilities. Of the 308 federally inspected plants that slaughtered sheep in 2004, only 56 slaughter one or more sheep per week. We focus on the largest facilities to ensure cost effectiveness of the sampling effort. We may expand this effort to additional plants through MOUs or reimbursable agreements with FSIS. This will enable us to collect more samples from a larger geographic area, as well as achieve our target for sample collection while realizing greater efficiencies by using existing resources. In the citrus canker program, APHIS collects significant amounts of vital information from the Florida Department of Agriculture and Consumer Services (FDACS). FDACS provides us information on the number of trees cut, the size of the quarantine area, and the success of residential and grove surveys. Grasshopper data is provided to Federal, State, and private land managers for use in directing control actions. Additionally, the ALB and EAB programs use survey data collected for performance measures on a daily basis to direct program activities. We use some of this information as performance indicators in justifying our budgets.

YES 9%

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: Program partners are held accountable for program funding and accomplishments. Regular reports are required from the Regional and Area Offices showing progress toward program goals. Staff managers are evaluated based on their progress toward program standards. Cooperators submit a work and financial plan that must be approved by the program before they can receive any funds. In addition, APHIS randomly audits cooperative agreements to look for any program performance weaknesses. The Agency issues findings to the program to facilitate corrective action. We maintain a database of OIG and GAO findings that ensure that previous problems have been corrected.

Evidence: Program managers are responsible for assessing and directing program policies and regulations to assure alignment with program goals and objectives. The successes or failures of program performance are a direct reflection of program management at all levels and are reflected in employee performance evaluations. Contracts that do not produce desired results are not renewed, unless significant process improvements are made or there were extenuating circumstances (such as unprecedented hurricane activity) which directly impacted the contractors' ability to produce the desired results. For example, when the Asplundh Company has not met our expectations regarding the work of tree climbers for our ALB program, we have reduced our payments to them. In other cases with the ALB and EAB programs, we have chosen not to renew certain contracts when a contractor has not performed to APHIS' satisfaction.

YES 9%

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: APHIS' budget office monitors the spending of program funds. Reports from States provide information on the use of federal funds provided through cooperative agreements. The reports required under cooperative agreements detail the performance and expense rates

Evidence: APHIS Budget staff meets monthly with program management to review spending and projections to assure funds are obligated in a timely manner and for the intended purpose. Program regional offices monitor and report on expenditures, while the program budget staff monitors the reports and provides financial recommendations to the program.

YES 9%

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: APHIS' Pest and Disease Management (PDM) programs contain effective management procedures and measures to ensure the most efficient use of funds. Additionally, the programs maximize cost-effectiveness by developing less expensive - and sometimes automated - methods that enable additional performance with no additional funding. Each program regularly monitors performance to evaluate efficiency and effectiveness, and makes changes accordingly. The programs continually assess activities to determine whether alternatives that are more efficient could be used while still maintaining effectiveness. APHIS regularly analyzes its IT infrastructure and the community it serves to ensure that it has the organization and management to efficiently develop products and support increased needs for systems, services, and support.

Evidence: In FY 2003, APHIS completed 5 streamlined studies (APHIS vs. competing businesses) under OMB Circular A-76. APHIS won, meaning that the rate charged by vendors exceeded our costs, and that APHIS operations are more efficient. APHIS' Pest and Disease Management programs look for greater sensitivity and specificity of diagnostic tests and strategies while decreasing program costs. For example, the Johne's program is validating strategies such as pooled fecal culturing or environmental sampling to determine the infection status of herds. This method reduces the cost of enrolling herds, simplifies sample collection, and saves time. More sensitive tests lead to rapid identification of infected animals and allows for quick disease containment. These programs develop strategies to improve efficiencies and methods. For ALB, APHIS revised the method of tree injection to reduce the cost of treating a tree by 50%, which allowed the program to treat more trees in the same amount of time, reducing the rate of the spread of ALB. In FY 2003, the Grasshopper Program began using the Reduced Area and Agent Treatment Strategy (RAATS) to conduct suppression treatments to achieve efficiencies, and in FY 200 treated 719,212 acres, but protected 1,190,487 acres with the RAATS. APHIS invests in information technology (IT) with goals of improving efficiency. Animal health programs such as Johne's and bovine Tuberculosis use the Generic Disease Database (GDB) to collect data, generate reports, and direct resources.

YES 9%

Does the program collaborate and coordinate effectively with related programs?

Explanation: APHIS' Pest and Disease Management programs work with other Federal agencies, State Departments of Agriculture, Native American tribal communities, and State colleges and universities, and local and private programs. The effectiveness of these relationships is reflected in our performance measures. One of our main collaborators in the plant health arena is the National Plant Board, with whom we determine how best to safeguard agriculture and natural resources from the risks associated with the entry, establishment, or spread of plant pests and diseases. Budget limitations and expanding mission demands require widespread collaboration among stakeholders to build affordable cross-functional networks to accomplish mutual goals. National and worldwide demands require integration and cooperation among external partners and other Federal Agencies, as well as within APHIS. We are committed to network and share strategies at all levels.

Evidence: The Pest and Disease Management programs work with multiple partners to research, manage, and disseminate animal and plant health information. In June 2002, for example, a task force of APHIS' Chronic Wasting Disease (CWD) program and other Federal and State wildlife management agencies completed the Plan for Assisting States, Federal Agencies, and Tribes in Managing CWD in Wild and Captive Cervids and presented it to Congress. APHIS' Wildlife Services Operations (WSO) coordinates oral rabies vaccination (ORV) projects targeting raccoon rabies in 15 eastern States in response to increasing rabies levels. WSO also continued cooperating in ORV projects targeting rabies in coyotes and gray foxes in Texas. The Centers for Disease Control (CDC), Rabies Section, plays a pivotal role in this surveillance by training WSO field biologists and technicians in sample collection and submission, laboratory diagnosis of surveillance samples, serological analysis, and rabies expertise. WSO continues to work with Cornell University and State agencies in ORV along the Quebec, Canada border. Part of this effort includes cooperation with a project in the Lake Champlain Valley in New York State (NYS) led by the NYS Health Department. APHIS maintains a strong partnership with the Florida Department of Agriculture on the citrus canker program. When APHIS detects an infected tree, State officials immediately begin surveys within the infection zone. APHIS also maintains a strong partnership with the California Department of Food and Agriculture (CDFA) on fruit fly and sharpshooter programs. This partnership is vital in arranging with local entities to conduct survey and regulatory activities.

YES 9%

Does the program use strong financial management practices?

Explanation: The programs use strong financial management practices. Each program receives an annual allocation and is held accountable for keeping its spending within this amount. During the year, program officials meet regularly with APHIS Budget to review projections and discuss financial issues of concern. Procurement is based on established procedures, controls, and competitive practices. APHIS reviews spending on a monthly basis, and our financial management system (the USDA Foundation Financial Information System, or FFIS) meets statutory requirements as well as those established by the Joint Financial Management Improvement Program. Financial information from FFIS is downloaded nightly into our reporting system for tracking and analysis, and system assurance routines are run to ensure that the data is accurate. For example, APHIS analyzes object class 4310 - Interest Paid/Prompt Payment within the financial system to monitor payments not made in a timely fashion relative to the Prompt Payment Act.

Evidence: As of June 2005, the interest paid represents 0.0014% of total expenditures for the current fiscal year. The Office of Inspector General (OIG) has reviewed USDA programs and issued clean audit opinions for FY 2002 and FY 2003 stating that the programs are free of material control weaknesses. APHIS also received a clean audit opinion for FY 2004, but the Agency is correcting one material weakness identified that year, the certification and accreditation of our Veterinary Services User Fee System. This correction will be complete by September 30, 2005. However, this does not affect APHIS' day-to-day operations, nor do the APHIS Pest and Disease Management programs use this system. APHIS' Review and Analysis Branch recently conducted audits of the APHIS Pest and Disease Management programs under the requirements of the Improper Payments Act. In conducting the audits, APHIS officials assessed the programs' vulnerabilities to improper payment, the internal controls in place to prevent them, and (based on these identified vulnerabilities and controls) the programs' level of risk of making improper payments. The auditors concluded that the programs are at low risk for improper payments because of internal checks and balances within the automated financial systems and in-house investigative reviews and audits of APHIS cooperative agreements and employee misconduct.

YES 9%

Has the program taken meaningful steps to address its management deficiencies?

Explanation: APHIS regularly reviews and adjusts its strategic plans to address deficiencies and takes steps to improve its emergency response capacity to minimize the impact of emergencies to ongoing program activities. APHIS also conducts post emergency reviews to identify areas of improvement for managing other emergency programs. To provide a systematic approach, APHIS has created the Office of Emergency Management and Homeland Security whose mission is to ensure that APHIS has in place the infrastructure and contingency plans needed to address future emergencies. The new office will also formalize the process by which APHIS employees will be assigned to lend their expertise and service to future emergency programs.

Evidence: Based on both internal and external review processes, the programs evaluate their operations on a regular basis and make improvements to increase management efficiency and effectiveness. The grasshopper program uses historical data to predict where outbreaks may occur. This data is useful since grasshoppers do not migrate. Because the Johne's program is voluntary, several APHIS initiatives encourage producer participation. These initiatives include emphasizing the implementation of comprehensive producer education and training programs; defining and prioritizing knowledge gaps that influence producer participation and affect Johne's disease control; enhancing State implementation of the Program, and thus uniformity, through better participant coordination; and strengthening the standardized national database to allow measurement of Program progress and participation. APHIS is currently developing a Program Planning Guide that will provide a systematic approach for managing emergency needs. Additionally, to ensure that an adequate number of employees are available to respond to APHIS emergency programs, all vacancy announcements now note that "it may be necessary for employees to participate in multiple rotations to an emergency program assignment."

YES 9%

Did the program seek and take into account the views of all affected parties (e.g., consumers; large and small businesses; State, local and tribal governments; beneficiaries; and the general public) when developing significant regulations?

Explanation: APHIS' Pest and Disease Management programs regularly consult with State and local officials, and industry about animal and plant health issues and are committed to a rule-making process that provides for full public participation. From the start, the Agency collaborates with affected parties on drafting an initial rule. To implement a new regulation, APHIS solicits the opinions of affected parties on the regulation and evaluates the concerns and suggestions raised by these entities. Suggestions are incorporated into the regulation before finalization. If a suggestion is not incorporated, the Agency provides the public with an explanation.

Evidence: APHIS addresses comments in final rules. For example, we adopted a rule to compensate for the depopulation of Pseudorabies (PRV)-infected swine herds. We received two comments. One commenter asked us to require that premises depopulated of swine because of PRV not be restocked for 30 days after cleaning. We published a technical amendment to modify the regulations to provide that depopulated premises may be restocked with swine 30 days after an approved cleaning and disinfection. In addition, APHIS amended a plum pox rule to provide additional compensation. We received two comments. A grower asked us to adopt our proposal as a final rule, and a private citizen opposed the proposal but did not provide a reason. We did not change our proposal.

YES 9%

Did the program prepare adequate regulatory impact analyses if required by Executive Order 12866, regulatory flexibility analyses if required by the Regulatory Flexibility Act and SBREFA, and cost-benefit analyses if required under the Unfunded Mandates Reform Act; and did those analyses comply with OMB guidelines?

Explanation: The Pest and Disease Management programs work closely with APHIS' Regulatory Analysis and Development (RAD) staff to ensure all analyses required for a particular rule are conducted The process starts with a regulatory work plan that is reviewed by RAD, policy officials in USDA, and at the Office of Management and Budget (OMB). OMB designates particular actions as not significant, significant, or economically significant. If OMB designates the proposed rule as "significant", the rule must be cleared by several USDA offices outside APHIS and then by OMB. If OMB designates a proposed rule as not significant, there is minimal USDA review beyond APHIS, and OMB does not review the rule. Whenever OMB deems a rule significant, APHIS prepares a regulatory impact analysis, regulatory flexibility analysis, and cost benefit analysis that comply with OMB guidelines. Economic analyses always receive peer review outside of the program, for example, from economists of the Policy and Program Development staff, from USDA's Office of Budget and Program Analysis, and Office of the Chief Economist. These analyses receive external peer review, if appropriate. Also, APHIS receives guidance from the Small Business Administration on analyses prepared under the Regulatory Flexibility Act regarding the economic effects of our rules on small entities.

Evidence: Recent examples of proposed regulations include final rules for Tuberculosis in Cattle and Bison, Karnal Bunt, and Low Pathogenic Avian Influenza. OMB deemed the Tuberculosis in Cattle and Bison; State and Zone Designations rule significant, and APHIS submitted analyses under Executive Order 12866 and the Regulatory Flexibility Act. For this action, OMB waived its review under Executive Order 12866. The requirements did comply with OMB guidelines. For the Karnal Bunt; Revision of Regulations for Importing Wheat rule, APHIS prepared an economic analysis, which provided a cost-benefit analysis as required by Executive Order 12866, as well as an analysis of the potential economic effects of this rule on small entities, as required under the Regulatory Flexibility Act. OMB determined the rule to be not significant for the purposes of Executive Order 12866 and, therefore, OMB did not review the rule. The Low Pathogenic Avian Influenza; Payment of Indemnity rule was determined to be significant for the purposes of Executive Order 12866 and underwent OMB review.

YES 9%

Does the program systematically review its current regulations to ensure consistency among all regulations in accomplishing program goals?

Explanation: APHIS' Pest and Disease Management programs continually review regulations to ensure consistency in accomplishing program goals. Ongoing review is a part of management responsibilities, and APHIS reviews all regulations at a minimum 5-year cycle, per APHIS policy and in accordance with Section 610 of the Regulatory Flexibility Act. The review process is managed by APHIS' Regulatory Analysis and Development organization (RAD) which identifies the sections of legislation that are to be reviewed. Individual Pest and Disease Management programs' within the Agency review regulations more frequently because they are central to achieving program goals.

Evidence: During the course of reviewing the regulations and taking comments it was discovered that industry felt that the burden for compliance was significant and costly. As a result, APHIS is currently revising 9 CFR 54 and 79 to reduce this burden and to adopt better methods based on new information and new technology. RAD undertook a review of 7 CFR Part 319 - Subpart Nursery Stock. A public comment period on an advance notice of proposed rulemaking has recently closed. Another RAD project was the review of 7 CFR part 319 - Subpart Fruits and Vegetables. If approved, they will streamline the regulations to allow APHIS to be more responsive to requests to allow importation of new commodities. RAD is also involved in projects to amend 9 CFR parts 50, 77, and 93. These changes are currently being drafted and, when implemented, will enhance our ability to control and eradicate bovine tuberculosis in the U.S. APHIS also reviews and updates the program Uniform Methods and Rules annually to insure clarity and consistency in implementation of the regulations. In addition to these systematic reviews, the emergency projects within the Emerging Plant Pests program evaluate their regulations continually and change them as needed; for example, APHIS frequently amends quarantine boundaries based on survey data because ensuring that host materials from infested areas are regulated is critical to the program's success in meeting its goals. Since the Emerald Ash Borer program's inception in FY 2003, the program has updated its quarantine regulations three times to reflect newly affected areas. The Asian Longhorned Beetle program amended its quarantine regulations most recently in April 2005, removing areas in Illinois from the regulated area because the quarantine restrictions were no longer necessary to prevent the spread of the pest. Within the past three years, APHIS has published rules to classify States based on their bovine tuberculosis status. The Agency measures each state based on tuberculosis (TB)-affected herds. If a state TB status improves, the state will undergo fewer restrictions on interstate movement. If a State TB status declines, the State will undergo restrictions that are more stringent. These restrictions play a vital role in achieving the program's goal.

YES 9%

Are the regulations designed to achieve program goals, to the extent practicable, by maximizing the net benefits of its regulatory activity?

Explanation: APHIS' Pest and Disease Mangement Programs design regulations to achieve the programs' goals of safeguarding U.S. agriculture and facilitating safe agricultural trade. Each regulation must undergo regular independent economic analysis to ensure that its design yields the maximum benefits. APHIS also assesses how each additional regulation adds to the level of regulatory requirements and strives to minimize regulatory compliance burdens. In accordance with the Paperwork Reduction Act, APHIS reports on paperwork burden when publishing proposed rules and requests comments on how to further minimize burdens. APHIS allows alternative compliance methods, by permitting producers to sign compliance agreements that allow them to move products out of quarantine areas, if the risk of spreading of infestation can be mitigated. Compliance agreements state what specific requirements producers must follow.

Evidence: For example, in the interim rule establishing the EAB quarantine regulations for 13 Michigan counties, APHIS described the associated paperwork requirements, including the completion of compliance agreements, certificates, and limited permits to move regulated articles and quantified the estimated burden in terms of time (0.48 hours per response) and number of respondents (225 per year). APHIS also recently amended it bovine tuberculosis regulations regarding State and zone classifications by raising California's status from modified accredited advanced to accredited-free after determining that California met the criteria for designation as an accredited-free State. In assessing the benefits, APHIS noted that with fewer restrictions on interstate movement, such as testing, California's designation as accredited-free eliminated the costs of testing for herd owners in the State. Tuberculosis testing, which includes veterinary fees and handling expenses, costs approximately $7.50 to $15 per test. The average per-head value of cattle in California was $1,030 in 2003, so the cost of testing represented between 0.7 and 1.5 percent of that average value. These cost savings are beneficial to the herd owner while still achieving the program's goal. Of course, the more a particular herd owner is involved in interstate movement, the greater the cost savings.

YES 9%
Section 3 - Program Management Score 100%
Section 4 - Program Results/Accountability
Number Question Answer Score

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: To date, the Pest and Disease Management programs have achieved their long-term goals. For example, the EPP program exceeded its target for the number of pests/diseases addressed by the program that are not contained within the quarantined area. The Pseudorabies program has made considerable progress toward having all 50 States in Stage V status and free of Pseudorabies disease in commercial production swine since 2003.

Evidence: The EPP program estimated that as many as four out of five of the pests addressed by the program would not be contained within their quarantined areas in FY 2004 but the program was able to contain 2, a vast improvement over the baseline year for the measure (FY 2003), when all 5 pests spread to new areas. For ALB, one of the pests addressed by the EPP program, the program has not only contained the infestation but removed over 97 percent of the total infestation between FY 1996 and 2004. As of November 1, 2004, all 50 states and 3 territories have reached Stage V status (free) of the Pseudorabies program , a year ahead of schedule. The program recovered quickly from setbacks experienced in FY 2002 and 2003, when only 42 States and 3 territories were at Stage V, largely as a result of steep drops in hog prices and reluctance on the part of producers to spend money to vaccinate swine. However, the program redoubled its efforts to find and depopulate infected herds, and by FY 2004, 48 States and 3 territories had reached free status. The program is now ahead of its FY 2005 target for 49 States and 3 territories to be at Stage V. Prior to initiating the accelerated pseudorabies eradication program, USDA economists estimated that the disease caused producers $30 million in annual losses.


Does the program (including program partners) achieve its annual performance goals?

Explanation: The Pest and Disease Management programs have met or exceeded their annual targets in areas such as ensuring that States retest swine herds for pseudorabies to maintain negative status and the number of square miles regulated for ALB. However, the number of acres treated for the Asian Longhorned Beetle were significanlty less that the target.

Evidence: The program met its FY 2004 target to ensure that the 48 States and 3 Territories with class free status for pseudorabies continue to achieve negative test results for commercial swine herds to ensure that the disease is not present, up from 42 States and 3 Territories in FY 2003. This measure demonstrates the States' (our partners in this and many other programs) commitment to meeting performance targets, as program partners are responsible for conducting this testing. The ALB program met its annual target of having 183 square miles regulated for the pest. While this is an increase over the number regulated in FY 2003, the new area represents a separate infestation tied to imported products rather than spread of an existing infestation.


Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: APHIS demonstrates cost efficiency through A-76 competition conducted in FY 2003. In winning this competition and demonstrating that APHIS' costs were less than those proposed by potential contractors, the programs' efficiency was validated. The program also works to maximize cost-effectiveness by developing less expensive - and sometimes automated - methods that enable personnel to accomplish more with the same funding level. For example, APHIS began using the reduced area and agent treatment strategy (RAATS) to conduct suppression treatments for grasshoppers in FY 2003 and began using a less labor intensive treatment mechanism to protect trees from ALB in FY 2005. The program has also reduced the costs associated with testing for the scrapie program by modifying the immunohistochemistry (IHC) test to allow two samples to be run on the same slide.

Evidence: In FY 2003, APHIS completed 5 streamlined studies (APHIS vs. competing businesses). One involved ALB tree climbers. All studies were conducted under OMB Circular A-76. APHIS won, meaning the rate charged by vendors exceeded our costs. This indicates APHIS operations are more efficient than vendor services. Other examples for improvements in efficiency in individual programs follow. In using the RAATS strategy, the grasshopper program applies pesticides at low levels to alternate swaths of rangeland, rather than applying pesticides evenly to a tract of land. RAATS is nearly as effective as full-coverage treatment and allows us to protect more than one and a half as many acres. In FY 2003, program officials treated 719,212 acres, but protected 1,190,487 acres with the RAATS technique. The ALB program is reducing the average treatment cost per tree in New York State by 18% between FY 2004 and FY 2005. Additionally, the advancements in IHC testing procedures will reduce testing costs by 50 percent over FY 2004, for a savings of $600,000 to $900,000 in FY 2005 and future years.


Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: APHIS is the lead Agency in eradicating pests and diseases in the United States. The APHIS Pest and Disease Management programs coordinate national agricultural pest and disease programs in the United States and work cooperatively with State and other Federal agencies involved in these efforts, but there are no other comparable programs in the United States. APHIS programs compare favorably with similar programs operated by the Canadian Food Inspection Agency (CFIA) and Mexico. Several pests dealt with under the Emerging Plant Pests program are also present in Canada, including ALB, EAB, and plum pox, and our progress either exceeds or matches Canada's. APHIS and CFIA also cooperate through the Oral Rabies Vaccination Program. APHIS' Bovine Tuberculosis program presented program performance during the United States Animal Health Association Meeting in 2004. At the same time, Mexico's Director of Animal Health gave a status on the campaign against bovine Tuberculosis (TB) in Mexico. This comparison showed that APHIS is testing more and finding less TB infection.

Evidence: CFIA modeled its ALB program on APHIS' eradication program for the pest. Using the same protocols, both programs are making progress in reducing the size of ALB infestations. At the FY 2006 President's Budget level, the program plans to reduce the number of square miles infested with ALB from 215 to 185. APHIS and CFIA are also both dealing with plum pox infestations. APHIS has successfully contained the U.S. plum pox outbreak and is very close to eradicating it, while plum pox is widely dispersed in Canada. APHIS and CFIA are addressing EAB with similar strategies; both are in early stages of eradication (both Canada's EAB and ALB infestations are smaller than the U.S. infestations and will likely be eradicated first.). APHIS and its Canadian cooperators apply the same outbreak strategies in the Oral Rabies Vaccination Program. They coordinate via the wildlife rabies management with the same goal of eliminating raccoon rabies. The Bovine Tuberculosis (TB) programs of Mexico and the United States have similar goals. However, APHIS' TB program has a lesser prevalence rate, 0.0009 percent compared to 0.15 percent in Mexico. Furthermore, APHIS has tested more herds; therefore, the Agency has also accredited free more herds of tuberculosis, 1,086,210 herds compared to 3,759 herds in Mexico.


Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: The Pest and Disease Management programs are closely scrutinized by APHIS stakeholders such as the National Association of State Departments of Agriculture and the National Plant Board. Many of the management and control programs have standing review boards or science advisory panels, some of which are wholly independent of APHIS and some of which are made up of APHIS as well as State and industry representatives. These reviews include program-wide evaluations of the entire scope of each infestation. These evaluations indicate that the programs are effective and achieving results and often result in additional improvements to the programs. Reviews are comprehensive. Science panels review design, available technologies and the program's use of technologies for maximum effectiveness. Review boards ensure that stakeholder needs are considered. Science panels for plant pest programs review survey and eradication data, evaluate program strategies through policy review and field visits and review laboratory/technical operations. Stakeholder review boards compile stakeholder input and provide feedback and annual evaluations and recommendations. The grasshopper program review board includes university scientists, State officials, industry representatives, and individual ranchers.

Evidence: For example, the pseudorabies program is reviewed semi-annually by the National Pseudorabies Control Board, an independent review board made up of representatives from swine producers, State officials, university professors, and the United States Animal Health Association. The board reviews data and information from each of the States. This information is compared to the national pseudorabies plan. Any deficiencies are recorded and forwarded to APHIS for action. The last review was in April, 2005. During the last review the Board found that all States had a successful status review and approval, an annual measure of the program's performance. This is directly related to the program's long term performance measure of how many States in Stage V remained PRV free. The review indicates that the program is effective and achieving results. The USAHA Committee on Pseudorabies meets annually to review the APHIS Pseudorabies Program. During this meeting APHIS and APHIS cooperators provide information and updates about the APHIS program and activities conducted during the year for control and eradication of PRV from the swine herds in the United States. The committee resolutions effect changes that may be needed in the APHIS program to make progress toward our goal of eradicating PRV from swine. Often these resolutions are made in response to recent changes in the industry or the international OIE code. The EAB program's science advisory panel recently issued a report indicating that the program is using the available management tools for EAB effectively and recommended changes in strategy to make the program more effective, such as implementing new survey protocols based on the location and shifting employees to higher-priority locations.

YES 17%

Were programmatic goals (and benefits) achieved at the least incremental societal cost and did the program maximize net benefits?

Explanation: Through regulatory impact analyses of significant rules, APHIS assures that its goals and benefits are achieved with minimum societal cost and maximum benefit. All animal disease management programs work to allow producers to survive financially and eliminate disease from their herds/flocks, while minimizing costs. Plant health program regulations also demonstrate flexibility. APHIS assesses how each additional regulation adds to the current level of regulatory requirements and strives to keep the regulatory compliance burden at a minimum. In accordance with the Paperwork Reduction Act, APHIS quantifies and reports the level of paperwork burden when publishing proposed rules and request comments on how we can further minimize the burden. While APHIS' primary concern in implementing regulations is to protect U.S. plant and animal health, it works with regulated indistries whenever possible to assure flexibility. For example, the scrapie program regulations give indstry and States options for meeting the regulatory goal of eradicating scrapie, by allowing States to propose and pilot different strategies for eliminating the infection from or preventing its spread. Whenever possible, APHIS uses compliance agreements to allow industry to move restricted articles.

Evidence: In the interim rule establishing the EAB quarantine regulations for 13 Michigan counties, the Agency described the paperwork requirements of the regulations, including the completion of compliance agreements, certificates, and limited permits to move regulated articles, and quantified the time the estimated burden (0.48 hours per response) and number of respondents (225 per year). While regulated businesses are experiencing additional costs and documentation requirements, the monetary values at risk if no regulatory action is taken are significant. Costs to replace trees killed by EAB in the first six affected Michigan counties would total $11.7 billion. Prior to the detection of EAB, ash trees were the most popularly planted tree in new residential and business developments because of their tolerance of drought and resistance to gypsy moth. Accordingly, EAB has the potential to destroy street trees across the United States.

Section 4 - Program Results/Accountability Score 67%

Last updated: 09062008.2005SPR