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WHEREAS, in Hawaii, the family Myrtaceae is represented by 49 species in nine <br />genera, including eight native species. The dominant tree of native Hawaiian forests is ' ohi' a <br />(Metrosideros polymorpha Gaud.) and it is related to the strawberry guava and numerous <br />introduced timber trees, including Eucalyptus species, are distant relatives; and <br />WHEREAS, Tectococcus will not kill the strawberry guava, but it will reduce the health <br />of the tree and its capacity for fruit production by creating unsightly galls on the leaves that <br />house the female Tectococcus, protecting the female from assault from predators and <br />insecticides; and <br />WHEREAS, despite the quarantine and research, the IPIF cannot guarantee that <br />Tectococcus is host specific to the strawberry guava outside of quarantine conditions, and only <br />"expects" Tectococcus to: 1) be host specific, 2) to spread gradually as an infestation on the <br />target plant reaching damaging levels within a few years at each release site, 3) reduce vitality, <br />growth rate, and reduce fruit and seed production of the strawberry guava over a number of <br />years, and 4) that the infestation of Tectococcus will protect the Hawaiian forests by suppressing <br />the strawberry guava and thereby allowing the native forest to regenerate; and <br />WHEREAS, each female Tectococcus remains enclosed in a gall throughout her life, <br />producing up to several hundred eggs in a matrix of wax filaments, which helps the eggs and <br />crawlers to float on the wind, and each female is parthenogenic (reproducing asexually), which <br />increases the likelihood of producing crawlers that spread the infestation; and <br />WHEREAS, a mass infestation of gall -bearing strawberry guava trees with lowered <br />vitality in our forests, orchards, yards, hedges, and along our roads will be unsightly. The <br />lowered viability of the strawberry guava trees may encourage other opportunistic insects and <br />disease to attack the strawberry guava and may spread those opportunistic insects and disease <br />throughout the native forest, to other horticulturally significant trees, and to the orchards of <br />commercial guava growers and residents' personal fruit trees; and <br />WHEREAS, the U.S. Forest Service, Pacific Southwest Research Station, in its <br />brochure, "Repelling Invaders" states that "Despite their potential usefulness, biocontrol agents <br />are potentially hazardous", and further that "biocontrol agents introduced to control invasive <br />blackberry also attacked the Hawaiian raspberry"; and <br />WHEREAS, the draft Environmental Assessment indicates that many commercial crops <br />(tomatoes and other vegetables, most fruits, coffee, protea and orchids) grown on Hawaii Island <br />that are constantly attacked by other species of scale have not been tested to determine whether <br />Tectococcus will preferentially choose to eat those plants over the strawberry guava; and <br />WHEREAS, the draft Environmental Assessment does not indicate whether Tectococcus <br />can or may hybridize with other scale species and create a "super -scale" capable of eating many <br />of our agricultural crops; and <br />WHEREAS, despite improved research, the beliefs and expectations of the IPIF cannot <br />be guaranteed, and the IPIF states in its publication, Biological control of weeds in Hawai `i: <br />Page 2 of 4 <br />