pittsfield, ma 01201 usa

Transmitted Via Electronic Mail and Overnight Courier

May 16,2013

Ms. Karen Pelto Case Manager Bureau of Waste Site Cleanup Massachusetts Department of Environmental Protection One Winter Street, 8th Floor Boston, Massachusetts 02108

Re: GE-Pittsfield/Housatonic River Site Hill 78 On-Plant Consolidation Area (GECD210) Work Plan for Bio-Control of Cypress Spurge

Dear Ms. Pelto:

GE 159 Plastics Avenue Pittsfield, MA 01201 USA

Enclosed for the General Electric Company (GE) is a work plan entitled Bio-Control of Cypress Spurge at On-Plant Consolidation Area (Work Plan) in accordance with your October 4, 2012 letter requesting additional details regarding the introduction of Aphthona beetles at the Hill 78 and Building 71 On-Plant Consolidation Areas.

As indicated in the Work Plan, GE anticipates introducing the beetles (weather permitting) on or about July 15, 2013 and will coordinate the release with MassDEP personnel.

Please call me if you have any comments or questions.

Sincerely,

Richard W. Gates ·(r ~ /Remediation Project Manager

Enclosure

cc: Dean Tagliaferro, EPA Richard Fisher, EPA John Kilborn, EPA (w/o enclosure) Holly Inglis, EPA Rose Howell, EPA (CD) Robert Leitch, USACE (w/o enclosure) Michael Gorski, MDEP (CD) Eva Tor, MDEP (CD) John Ziegler, MDEP (2 copies+ CD) Linda Palmieri, Weston (2 copies+ CD) Nancy E. Harper, MA AG (w/o enclosure)

Corp,)fOte EnVIfonmental Programs

Corydon L. Thurston, Executive Director, PEDA Todd Chadwell, Stantec Robin MacEwan, Stantec Mayor Daniel Bianchi, City of Pittsfield Andrew T. Silfer, GE (w/o enclosure) Roderic McLaren, GE (w/o enclosure) James Nuss, ARCADIS James Bieke, Sidley Austin Public Information Repositories GE Internal Repository

General Electric Company Pittsfield, Massachusetts

Bio-Control of Cypress Spurge at On-Plant Consolidation Areas

2013 Work Plan

May 2013

Bio-Control of Cypress Spurge at On-Plant Consolidation Areas 2013 Work Plan

Prepared for:

General Electric Company

Pittsfield, Massachusetts

Prepared by:

ARCADIS of New York, Inc.

6723 Towpath Road

P O Box 66

Syracuse

New York 13214-0066

Tel 315 446 9120

Fax 315 449 0017

Our Ref.:

B0030125.0000

Date:

May 16, 2013

G:\GE\GE_Pittsfield_CD_Hill_78_Remainder\Reports and Presentations\BioControlWP\0921311324WP.doc 1

Table of Contents

1. Introduction 1

2. Program Objectives and Overview 3

2.1 Background 3

2.2 Objective 3

2.3 Aphthona Beetle Life Cycle 4

3. Permitting 5

4. Bio-Control Program 6

4.1 Introduction 6

4.2 Locations 6

4.3 Site Preparation 6

4.4 Release Date 7

5. Monitoring and Management 8

5.1 Introduction 8

5.2 Monitoring and Documentation 8

5.2.1 Spring Monitoring 8

5.2.2 Summer Monitoring 9

5.3 Reporting 10

5.4 Long-Term Management 11

6. Conclusions 12

7. References 13

Figures

1 Flea Beetle Release Locations

2 Vegetation Monitoring Detail

Attachment

Attachment A Weedbuster Permit


Bio-Control of Cypress Spurge

2013 Work Plan

1. Introduction

On June 8, 2012, the General Electric Company (GE) submitted to the U.S. Environmental Protection Agency (EPA) a summary report on its May 2012 inspection of the Hill 78 and Building 71 On-Plant Consolidation Areas (OPCAs), located at the GE facility in Pittsfield,

MA. That summary report identified the presence of Cypress spurge (Euphorbia cyparissias) (Spurge), an invasive species, growing within the Building 71 OPCA and also crossing over and growing onto portions of the Hill 78 OPCA within the natural resource

restoration/enhancement (NRR/E) area. GE’s June 8, 2012 report proposed spraying those areas with an herbicide. However, EPA did not approve that proposal (as noted in a June 14, 2012 e-mail to GE) and stated that GE should investigate alternative methods for

controlling the Spurge at the OPCAs.

As a result, GE conducted such an investigation; and in summary reports to the Natural

Resource Trustees (Trustees) on GE’s June 12 and August 14, 2012 NRR/E inspections of the Hill 78 OPCA, dated August 27 and September 18, 2012, respectively, GE proposed to initiate a biological control program, consisting of the introduction of flea beetle (Aphthona

sp.) populations at the Building 71 OPCA in early July 2013 in an effort to control the Spurge. The reports noted that, based on a review of studies and field trials conducted at other sites, the introduction of the beetles could effectively reduce the density of Spurge at

both OPCAs.

On October 4, 2012, the Trustees, through the Massachusetts Department of

Environmental Protection (MassDEP) as Lead Administrative Trustee, provided conditional approval of GE’s proposal to implement a biological control program for Spurge involving the introduction of beetle populations to the OPCA areas. However, the Trustees requested

submission of additional details regarding the proposed control program prior to finalizing their approval. Specifically, the Trustees requested GE to submit a work plan prior to the planned date of implementation, detailing certain information regarding the bio-control for

review and approval. That information consisted of the following: (1) number of beetles to be released and locations shown on a plan; (2) methods for monitoring and quantifying Spurge population decline (e.g., time interval photography from set locations); (3) criteria for

additional beetle releases and plans for long-term management; (4) how mowing will be integrated with the biological control program; and (5) literature references used in preparing the plan.

In accordance with that request, the following sections of this Bio-Control Work Plan provide additional details regarding the proposed biological control program:

Section 2.0 – Program Objectives and Overview, provides an overview of the bio-control program and the literature used to develop the referenced program.



2013 Work Plan

Section 3.0 – Permitting, describes the permitting requirements associated with acquiring and subsequently releasing of the beetles.

Section 4.0 – Bio-Control Program, provides a summary of the proposed implementation of the bio-control, including the quantity of beetles to be released, release

locations, and release dates.

Section 5.0 – Monitoring and Management, provides an overview of the monitoring and

long-term management activities anticipated.

Section 6.0 – Conclusions, provides a summary of the bio-control program.

Section 7.0 – References, lists the sources of information cited throughout this work plan.



2013 Work Plan

2. Program Objectives and Overview

2.1 Background

Cypress spurge is an exotic species of vegetation native to Europe and Asia that was

introduced into North America during the Nineteenth Century as an ornamental plant (Driesche et al., 2002). Prolific seed production and an extensive root system often enable Spurge to outcompete native plant species (CWMA, 2013). The plant develops deep tap

roots, which can exceed 20 feet and enable it to store reserves during periods of drought and lateral roots or rhizomes that allow the plant to spread and overtake adjacent vegetation quickly (Driesche et al., 2002). In summary, Spurge is adaptable to various

conditions and can often outcompete and completely displace native grassland species.

Control of Spurge is difficult due to the plant’s characteristics (i.e., adaptability to various

conditions and ability to outcompete native grassland species). Conventional control methods such as weeding (i.e., pulling individual plants out of the ground) are frequently ineffective and extremely costly. Herbicide applications can be used in certain situations

where plants have not become well established. However, in areas where Spurge has already outcompeted native grass lands, herbicide applications are often not effective at complete eradication. Accordingly, reapplication of the herbicide is generally required on

regular maintenance intervals. In addition, herbicide treatment also affects native grassland species and re-seeding efforts are required to re-establish these communities.

Currently, Spurge is widespread throughout the Northeast and is currently listed as an invasive species by the United States Department of Agriculture and the Massachusetts Department of Agricultural Resources (see USDA, 2013). Pursuant to Attachment I of GE’s

Statement of Work for Removal Actions Outside the River (SOW), which is part of the Consent Decree (CD) for the GE-Pittsfield/Housatonic River Site, GE is required to inspect NRR/E areas for the presence of invasive species and to take action to reduce such

species if they cover greater than 5% of a given NRR/E area.

Aphthona beetles have proven to be a very effective bio-control against Cypress spurge

(Driesche et al., 2002). These beetles were first approved for use as a bio-control in 1985 and since then have been used extensively in western states to control leafy spurge.

2.2 Objective

The objective of implementing bio-control at the GE Pittsfield site is to reduce the density of

Spurge at the Building 71 OPCA and thereby reduce the expansion of the species into NRR/E portions of the Hill 78 OPCA. Control of Spurge populations at the Building 71 OPCA should decrease the potential for this invasive to spread in significant numbers into

NRR/E portion of Hill 78. Aphthona beetles will be released in areas with dense Spurge coverage to feed upon the roots and leaves throughout the various live stages of the beetle. The feeding activities should stress the host plants and result in mortality and/or reduction in



2013 Work Plan

reproductive capabilities to reduce the density of Spurge on the site. It is anticipated that the process will start slowly as the beetle population increases in response to available host

material and the areas of effective control will continue to expand until the beetle population reaches equilibrium with the host plant.

Bio-control can be defined as a reduction in the abundance or competitive advantage of a weed or insect pest through the use of natural enemies (Bourchier et al., 2006). Exotic species are a prime candidate for this type of control because their establishment in non-

native environments is often associated with a lack of competition by natural enemies. In summary, the concept is to simply find a natural enemy of the plant, generally in the plant’s native environment that is responsible for controlling the proliferation of the species.

Accordingly, bio-controls often do not totally eradicate the target species, but keep their numbers at levels that do not pose a significant threat to the native species.

2.3 Aphthona Beetle Life Cycle

Aphthona beetles spend the winter months as larvae in soil adjacent to Spurge roots. As

temperatures increase, the larvae begin to feed on Spurge roots. Beetles in this larval stage provide the most significant damage to Spurge during April and May (prior to morphing into adults). In late May to mid-June, the larvae morph into adults and emerge

from the soil to feed on Spurge leaves. Once adult beetles emerge, they continue to feed on Spurge but have a less significant impact on controlling the plant as compared to the larval stage (Bourchier et al., 2006).

Adults generally live for a period of approximately 45-65 days in which they mature and reproduce. Females lay between 50-500 eggs in soil near the base of Spurge plants. Eggs

hatch into larvae in 15-19 days and initiate feeding on spurge roots. Generally, larvae will spend the majority of the summer and early fall feeding within the top 3 inches of soil. During this period, the larvae will morph through three larval states. As temperatures cool

throughout the fall, larvae will move to deeper soils and prepare for winter where they will remain dormant until spring, when the cycle will repeat.



2013 Work Plan

3. Permitting

The interstate transportation and release of Aphthona beetles requires a permit from the U.S. Department of Agriculture Animal and Plant Health Inspection Service (APHIS). Weedbusters Biocontrol, LLC (Weedbusters), a licensed supplier of Aphthona beetles, was

retained by ARCADIS on GE’s behalf as a source of beetles for release in summer 2013. Weedbusters has a permit from APHIS that approves the transport and release of beetles in Massachusetts. A copy of the permit issued to Weedbusters by APHIS is provided in

Attachment A.

No additional permitting was required by the Commonwealth of Massachusetts to transport

and release the beetles.



2013 Work Plan

4. Bio-Control Program

4.1 Introduction

The control of Spurge with beetles can take several years. Numerous factors can affect

the establishment and effectiveness of this bio-control including release locations, site preparation, and time of release. Given their importance in the successful establishment of viable beetle populations, additional details regarding these factors have been provided

below.

4.2 Locations

Beetle populations will be introduced at the Building 71 OPCA at five locations. Approximate locations are shown on Figure 1. In general, introduction locations should be

on south-facing slopes that are not facing the wind. Initial release locations referenced on Figure 1 have been selected based on access to sun and the prevailing wind direction. In addition, loamy soils are preferable to clay and silt soils because the beetle larvae require

an abundance of small, lateral roots within a few inches of the soil surface (Bourchier et al, 2006). Soil conditions at both the Hill 78 and Building 71 OPCAs should be favorable to larvae development. Due to the limited mobility of the beetles, introduction locations should

contain a high density of Spurge plants to increase access to food/habitat. As such, precise release locations will be selected based on field observations at the time of introduction.

In total, GE plans to release 1000 beetles at each of the five separate locations at the Building 71 OPCA. The center of the release locations will be marked with a metal post or other semi-permanent marker.

4.3 Site Preparation

Prior to release, each of the five release locations will be selected and demarcated as described above. Each location will be inspected to assess the amount and density of spurge. The initial conditions will be documented for comparison to future inspection

results. Reducing the density of the Spurge canopy (i.e., exposing the ground surface) has been found to promote the establishment of beetle populations (Bourchier et al., 2006). Exposed ground surface allows adults easier access to egg laying habitat (upper portions of

the soil adjacent to Spurge roots). For release locations with a thick canopy of Spurge, manual implements may be used to open up the Spurge canopy.



2013 Work Plan

4.4 Release Date

Beetle populations should be released into new environments before they have laid all of their eggs (Merritt et al., 2002). If beetles are released too late in the season, they may not lay enough eggs to produce a viable population for the next season. In the northeast this

timeframe generally occurs during the month of July. Release dates should also coincide with dry weather conditions.

Accordingly, GE proposes a release date of approximately July 15, 2013. The specific release date is subject to change based on the shipment date of the beetles and weather conditions (e.g., releases should generally not be performed during wet and/or rainy

conditions).



2013 Work Plan

5. Monitoring and Management

5.1 Introduction

The release of the beetles should provide long-term management of Spurge at the OPCAs.

Monitoring of release locations will provide information on the extent and effectiveness of the beetle populations at controlling Spurge populations at the release sites. Accordingly, GE proposes to perform monitoring at each of the five release locations. Additional details

regarding monitoring activities and the long-term management of Spurge are provided below.

5.2 Monitoring and Documentation

Monitoring the health and density of Spurge in the release locations will be used to assess

the effectiveness of beetle populations at controlling Spurge populations. GE proposes monitoring the five release locations twice a year following the beetle release. The monitoring events will be conducted in the spring and summer to evaluate the beetles

overwintering population status and the beetles effectiveness at Spurge control, respectively. Visible evidence of beetle presence in the spring and reduced densities of Spurge in the summer will indicate effective bio-control. Activities to be conducted during

these monitoring events are described in the following sections.

5.2.1 Spring Monitoring

The spring monitoring event will be performed during adult emergence from the soil, which can vary based on weather conditions, but typically occurs in mid- to late June. The spring

monitoring event will be a qualitative assessment of beetle presence based on the presence of larvae and adults in the soil and on the stems of Spurge in each release location. Monitoring of adult beetle activity is generally more straightforward than that of the larval

stage (Merritt et al., 2002). Adult beetles can generally be observed by “sweeping” the monitoring location with a canvas net. If populations are present, the adults will be collected in the net. In addition to collecting adults with a net, adults feeding on Spurge plant parts

can also be observed. Light feeding generally results in the “holing” of Spurge leaves while heavier feeding levels results in ragged/shredded leaves.

An assessment of larval presence will be performed by inspecting Spurge plants and manually extracting a few plants from the soil and examining their roots and surrounding soils for beetle presence. Shallow holes may also be dug to further evaluate beetle

presence. Photographs will be taken of observed adults and larvae to document their presence.

GE will coordinate with EPA and MassDEP in performing these inspections.



2013 Work Plan

5.2.2 Summer Monitoring

The summer inspection will be performed in August, when the effects of the beetles on the Spurge will be most evident. The summer inspection will be a qualitative assessment to determine the impact of newly established beetle populations on the condition and density

of Spurge at each release location using the Release Stake Scale methodology (Bourchier et al., 2006). This method consists of assessing the condition of Spurge along four perpendicular transects established from the release point. A detail of the transect layout in

relation to the release location is provided on Figure 2. Assessments will be performed at 1, 3, 5, and 10 meter intervals along each transect. Observations at each assessment point along the transects will be recorded based on the following number system:

1. No evidence of spurge thinning.

2. Some thinning to vegetative stems and some flowering stems.

3. Thinning to stems only.

4. Dead Spurge with very few vegetative stems.

Other indicators of plant damage, such as those presented below, will be recorded when observed:

Stunted Spurge plants;

Reduced or delayed emergence and/or flowering of the plants;

Decreasing in spurge coverage;

The presence of dead spurge cane from last year; and

The presence of larvae in the root masses of stressed Spurge plants.

It should be noted that expansion of the impact zone is not likely to be uniform in all directions. Therefore, during each summer monitoring event, the transects will be extended

to the maximum extent of observed Spurge impacts where observed impacts extend beyond 10 meters from the center stake. This will allow for the long-term assessment of the expansion of the impact zone. The monitoring results will be visually presented in

monitoring reports in a method that allows overlaying each year’s monitoring results to track progress.



2013 Work Plan

In addition to the vegetation monitoring process, summer monitoring will include a photo-monitoring component. Pre-release photographs of the five release points will be collected

just prior to the release date. Pre-release photographs of each of the five monitoring plots will be reviewed and a percent Spurge coverage value will be assigned (e.g., 0% through 100% coverage).

Following the beetle release, photographs will be taken from the release point stake in the four directions of the vegetation monitoring transects. These photographs will provide

documentation of the vegetation monitoring results and provide an additional visual assessment tool for monitoring the extent of impact. Annual post-release photos for the first four years (i.e., 2014, 2015, 2016, and 2017) will be collected during the summer

(July/August) at each plot. If/when Spurge mortality extends beyond the plot boundaries, the photo view will be correspondingly expanded during subsequent photo monitoring events. Photos of the entire site will also be collected to provide an overall depiction of

spurge status. Monitoring location photographs will also be reviewed and percent Spurge coverage values assigned for all photographs collected.

Overall photographs of the Hill 78 and Building 71 OPCA areas will be taken from permanent locations to document the cumulative effects of the five release points on Spurge density across the entire site. Photographs will be provided in each year’s

monitoring report. Based on the release date of July 15, 2013, the first scheduled adult monitoring inspection is proposed for July 2014 with follow-up inspections in 2015, 2016, and 2017. As proposed for the spring monitoring, GE will coordinate with EPA and

MassDEP in performing these inspections.

5.3 Reporting

Monitoring the effects of the beetle release on the Spurge population will be conducted for four years (2014-2018). The results of the annual monitoring activities will be included in

the regular inspection reports provided to EPA on the OPCA inspections and to the Trustees on the Hill 78 NRR/E inspections. For years in which NRR/E inspection reports are not submitted to the Trustees, GE will provide an annual inspection summary letter to

the Trustees describing the results of the Spurge monitoring performed during that year.

At the conclusion of the four-year monitoring period identified above, GE will evaluate the

success of the bio-control program. This evaluation will be based on the successful establishment of beetle populations and the ability of established populations to control Spurge. The evaluation will also assess the ability of established populations to colonize

adjacent areas. The results of the evaluation indicate that viable populations of beetles have not been established at each of the five release locations, additional beetle populations may be released. Viable populations of beetles will be measured by the

decrease in density of Spurge and the presence of both adults and larvae at the release locations.



2013 Work Plan

GE will provide to EPA and the Trustees a summary of the results collected over the four-year period in a summary letter in December 2017. The summary report will also include

any proposed activities that GE anticipates performing in the future to promote the development of sustainable flea beetle populations.

5.4 Long-Term Management

Successful management of Spurge populations can often be accomplished through the

implementation of several solutions. This is generally referred to as Integrated Pest Management (IPM) practices and includes other Spurge management activities such as mowing, grazing, burning, and the application of herbicides (Merritt et al., 2002). GE

proposes the use of mowing at designated timeframes to assist with the decrease in the Spurge population. Additional details regarding the long-term management of Spurge are provided below.

Management of the areas adjacent to the release sites can assist in reducing the Spurge populations. Mowing Spurge prior to seed development can reduce the reproductive rate of

the plant. Due to the potential to impact beetle populations, mowing will not be performed within 100 feet of the release point to provide adequate plants for the expansion of the beetle population and to eliminate the potential for direct mortality to beetle adults and

larvae from mowing. Mowing activities performed in early spring (i.e., late April through early May) can decrease the ability of Spurge to flower and produce seed. Based on the above information, GE proposes to cut the vegetation on the Building 71 OPCA in early

May (weather permitting), as well as the regularly scheduled mowing in September, as required by GE’s Revised OPCA Post-Removal Site Control Plan (Appendix H to the approved Final Completion Report for the OPCAs). Due to the limited amount of Spurge

currently observed on the Hill 78 OPCA, mowing in May is not recommended. In accordance with the Revised OPCA Post-Removal Site Control Plan, the Hill 78 OPCA will be mowed once per year in September.



2013 Work Plan

6. Conclusions

Control of Spurge through the use of Aphthona beetles as a bio-control is anticipated to be a more effective control measure than conventional controls such as herbicides. Though the use of beetles is not anticipated to result in the immediate eradication of Spurge

populations, over time this bio-control should prove a more sustainable control method than conventional practices. GE anticipates that once beetle populations have been established at the five release locations, these populations should expand to adjacent areas and

eventually maintain Spurge populations at or below the 5% coverage.



2013 Work Plan

7. References

Bourchier, R., R. Hansen, R. Lym, A. Norton, D. Olson, C.B. Randall, M. Schwarzlander, and L. Skinner. Biology and Biological Control of Leafy Spurge. 2006. United States Department of Agriculture Forest Service. Forest Health Technology Enterprise Team.

Morgantown, West Virginia. FHTET-2005-07. 2 – 87 pp.

Colorado Weed Management Association (CWMA). 2013.

http://www.cwma.org/CypressSpurge.html

Driesche, F.V., B., Blossey, M. Hoodle, S. Lyon, and R. Reardon. 2002. Biological Control

of Invasive Plants in the Eastern United States. United States Department of Agriculture Forest Service. Forest Health Technology Enterprise Team. Morgantown, West Virginia. FHTET-2002-04. 413 pp.

Merrit, S., D. Hirsch, and D. Nelson. 2002. Biological Control of Leafy Spurge Area-Wide IPM Program. United States Department of Agriculture Forest Service. TEAM Leafy

Spurge (2002). http://www.team.ars.usda.gove/biocontrolmanual.html

United States Department of Agriculture (USDA). 2013. Introduced, Invasive, and Noxious Plants. http://plants.usda.gov/java/noxious?rptType=State&statefips=25

Figures

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FIGURE

GENERAL ELECTRIC COMPANYPITTSFIELD, MASSACHUSETTS

FLEA BEETLE BIO-CONTROL WORK PLAN

1

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PROPOSED RELEASE LOCA 110N

BASEMAP INFORMA 110N BASED ON FIELD SURVEY INFORM A 110N OBTAINED FROM SK DESIGN GROUP, INC. ON OCTOBER 6, 2006, DECEMBER 11, 2006, JANUARY 30, 2008, APRIL 15, 2009, MAY 15, 2009 AND AUGUST 24, 2010. ADDITIONAL BASEMAP INFORMATION BASED ON "EXISTING SITE PLAN" PREPARED BY ARCADIS BBL, DATED APRIL 2007.

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EUEVA liONS SHOWN ARE REFERENCED TO NA 110NAL GEODETIC VERTICAL DATUM (NGVD 1929).

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VEGETATION MONITORING DETAIL

GENERAL ELECTRIC COMPANYPITTSFIELD, MASSACHUSETTS

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2

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Attachment A

Weedbuster Permit

United States Department of Agriculture

Animal and Plant Health Inspection Service

4700 River Road

Riverdale, MD 20737

Permit to Move Live Plant Pests, Noxious Weeds, and SoilInterstate Movement

Regulated by 7 CFR 360

This permit was generated electronically via the ePermits system

PERMITTEE NAME: Kandace Rich PERMIT NUMBER: P526P-12-02031ORGANIZATION: Weedbusters Biocontrol LLC APPLICATION NUMBER: P526-120304-026ADDRESS: 5607 Hillview Way

Missoula, MT 59803FACILITY NUMBER: N/A

MAILING ADDRESS: 5607 Hillview WayMissoula, MT 59803

HAND CARRY: Yes

DATE ISSUED: 05/10/2012PHONE: (406) 251-4261 FAX: EXPIRES: 05/10/2015DESTINATION: MA RELEASE: MA

Under the conditions specified, this permit authorizes the following:

Article Category: Biocontrol Organisms - Invertebrate Herbivores of Weeds

Regulated Article Life Stage(s) Intended Use ShipmentOrigins

Originally Collected CultureDesignation

Aphthona flava Adult Release -Biocontrol

MT Originally Collected from ForeignLocations

Aphthona lacertosa Adult Release -Biocontrol


Aphthona nigriscutis Adult Release -Biocontrol


Ceutorhynchus litura Adult Release -Biocontrol


Cyphocleonus achatesAdult Release -Biocontrol


Larinus minutus Adult Release -Biocontrol


Larinus obtusus Adult Release -Biocontrol


Mecinus janthinus Adult Release -Biocontrol


Obereaerythrocephala

Adult Release -Biocontrol


Permit Number P526P-12-02031

THIS PERMIT HAS BEEN APPROVED ELECTRONICALLY BY THE FOLLOWINGPPQ HEADQUARTER OFFICIAL VIA EPERMITS.

DATE

Ingrid Asmundsson 05/10/2012

WARNING: Any alteration, forgery or unauthorized use of this Federal Form is subject to civil penalties of up to $250,000 (7 U.S.C.s 7734(b)) or punishable by a fine of not more than

$10,000, or imprisonment of not more than 5 years, or both (18 U.S.C.s 1001)

Page 1 of 3

Animal andPlant HealthInspection Service

PlantProtection &Quarantine

PERMIT CONDITIONS

This permit is issued to Kandace Rich, Weedbusters Biocontrol LLC, 5607 Hillview Way, Missoula, Montana and authorizesthe interstate movement of the listed species from Montana to Massachusetts for environmental release on the respective plantspecies.

1. This permit is issued only for the named permit holder at the address(s) identified on this permit. This permit cannot betransferred or assigned nor does it fulfill or modify the requirements of any other federal or state regulatory authority(such as the U.S. Environmental Protection Agency, the U.S. Fish and Wildlife Service, the U.S. Food and DrugAdministration, the Centers for Disease Control and Prevention, or your State's Department of Agriculture). 04/08

2. The permit holder verifies United States residency by initialing and accepting these permit conditions. If you are not aUnited States resident, it is unlawful for you to initial or accept these permit conditions because a USDA 526 Plant PestPermit can only be issued to United States residents. 04/08

3. The permit holder is solely responsible for ensuring compliance with all statutory requirements and specifically listedpermit conditions. Failure to comply with the terms and conditions of this permit is cause for the following: (a)cancellation of this permit, (b) cancellation of other permits issued to the permit holder, (c) seizure and/or destruction ofregulated organisms, (d) denial of future permit applications by this permit holder, (e) liability for civil penalties, and (f)criminal prosecution under provisions in the Plant Protection Act. 04/08

4. Any alteration, forgery or unauthorized use of this permit and/or associated Federal Forms are subject to civil andcriminal penalties including fines and imprisonment. 04/08

5. Plant feeding biocontrol organisms and natural enemies of plant pests are regulated by USDA under the authority of thePlant Protection Act of 2000. This permit authorizes the interstate movement of organisms listed on the PPQ Form 526(henceforth referred to as approved organisms) to the designated state for release into the environment.

6. Approved organisms are to be shipped in sturdy escape-proof containers.

7. If organisms that are not authorized in this permit are received, the permit holder must take all prudent measures tocontain the organism(s) and notify the PPQ permit unit by contacting a compliance officer within one business day bycalling 866-524-5421 or by e-mail to [email protected]. The permit holder must immediately notify thepermit unit of the destruction of regulated organisms received under this permit, as above. Similarly, the permit holdermust immediately notify the permit unit if facilities are destroyed or decommissioned for any reason. 04/08

8. Without prior notice and during reasonable hours, authorized PPQ and/or State regulatory officials shall be allowed toinspect the records and the conditions associated with the regulated organisms authorized under this permit. 04/08

9. No propagative host plant parts are to be included in the shipments of approved organisms unless these organismsnormally live within a propagative plant part.

10. Issuance of this permit constitutes neither a certification nor an endorsement by USDA/APHIS of the quality, efficacy orany other potential product claim related to the commercial value or effectiveness of products derived from issuing thispermit.

11. Permittee moving field collected organisms must take all precautions to prevent shipping of unidentified species anddiseased or parasitized individuals to prevent the movement of contaminant organisms.

12. The identity of all organisms in each shipment must be clearly stated on each shipment container and the shipper mustassure purity of the shipment. Shipment may be checked by USDA/APHIS/PPQ and/or State inspectors to assureidentity and purity of the contained organisms.

13. Shipments must not be contaminated with other species of biological control organisms. Contamination of any shipmentwith non-permitted organisms is a violation of this permit.

14. The permit holder must keep records of all shipments received and sent under this permit for a period of three (3) yearsafter the shipping date. All records retained under this permit must be made available to the USDA upon request.Failure to keep, or make available, records required under this permit is cause for this permit to be cancelled and finesassessed. Failure to keep, or make available, records required under this permit is cause for future permits to be denied.07/09



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pittsfield, ma 01201 usa

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