Invasive Species Policy: Will New Law Empower Agencies? Or Hinder Strategic Planning, Research, and Engaging the Public through Outreach?

Much-Heralded Major Conservation Legislation — S. 47 – Mandates “On-the-Ground” Actions 

Senate bill S. 47 enjoyed strong support from the conservation community because it expanded protection for several National parks and wilderness areas, mandated easier access to public land for hunters and anglers, and provided permanent status for the most important program that funds purchase of lands and waters for recreation and other purposes – the Land and Water Conservation Fund. It passed the Senate on February 12, 2019 by a vote of 92 for, 8 against. The bill passed the House of Representatives on February 26, 2019 by a vote of 363 for, 62 against. Everyone expects President Trump to sign it into law.

The new language had previously been a stand-alone bill introduced in two previous sessions of Congress. The first version, S. 2240, was introduced in 2016; I blogged about a hearing on that legislation in May 2016, describing my reservations. The bill was not enacted in that Congress. It was reintroduced in 2017, when it was called the “WILD Act” (S. 826).

Title VII of the new legislation now expected to become law governs programs implemented by the Departments of Interior, Agriculture (specifically the Forest Service) and the U.S. Army Corps of Engineers. It also applies to the head of “any federal agency” having duties related to planning or treatment of invasive species “for the purpose of protecting water and wildlife on land and in water.”

Title VII takes the form of an amendment to the Fish and Wildlife Coordination Act (16 U.S.C. 661 et seq.)

As in the original 2016 bill (S. 2240), the new law – at Title VII, §10(c)(2)(C) – agencies are required to adopt strategic plans for their invasive species programs. The priorities in the federal agencies’ invasive species plans will be set by state governors – not the federal agency charged with managing that land unit and its resources.

  • Under§10(a)(4)(C), tribal, regional, State, or local authorities are authorized to weigh in on the determination of which terrestrial or aquatic species fit the definitions of ‘invasive’ and ‘alien’ species.
  • Under §10(c)(3).the Secretaries are required, in developing their strategic plans, to take into consideration the ecological as well as the economic costs of acting or not acting, I welcome this provision.

Like the original 2016 bill (S. 2240), the new law – at Title VII, §10(g) – (i)  – requires land-managing agencies to allocate their invasive species funds according to the following formula: 75% for on-the-ground activity; 15% for combined research and outreach; 10% or less for administrative costs.

  • Fortunately, “on-the-ground” activities have been expanded to include
    • detection and monitoring.
    • “the use of appropriate methods to remove invasive species from a vehicle or vessel capable of conveyance.” 
    • “investigations regarding methods for early detection and rapid response, prevention, control, or management of the invasive species.”
    • It is unclear whether “on-the-ground” activities include the salaries of staff who manage such programs from desks (as distinct from people who work in the field).
  • Unfortunately, the definition of “prevention” is unnecessarily limited by §10(a)(6) (B). This clause authorizes agencies ‘‘to impede the spread of the invasive species … by inspecting, intercepting, or confiscating invasive species threats prior to the establishment of the invasive species onto land or water of an eligible State.” This clause reflects too narrow an understanding of prevention actions. They are not limited to (inefficient) inspection and seizure programs at “borders”. It is much more efficient to apply measures intended to prevent the presence of a pest in the transported good in the place of production. One example is APHIS’ requirements governing nursery stock intended to be shipped interstate so as to prevent the spread of the sudden oak death pathogen.

Following the revised 2017 version of the bill (text here; see my blog here) the law requires the agencies to make “substantive annual net reduction of invasive species populations or infested acreage …”  (The original bill mandated an annual reduction of 5%.) It is unclear whether this mandate applies to all invasive species on the affected acreage, or only those designated by a flawed process (see below) and included in the agency’s strategic plan [Title VII, §10(c)(1)].

Under Subsection (d), the plan is to prioritize the use of methods that are effective (as determined by the Secretary, based on sound scientific data); that minimize environmental impacts; and control and manage invasive species in the least costly manner. I worry that this requirement, combined with the mandate to achieve “annual net reductions” in invasive species numbers, will promote the use of chemical pesticides.

Under Section (f), agencies are to apply all available tools and flexibilities to expedite invasive species control projects and activities. Those projects are to be located in an area that is at high risk for invasive species introduction, establishment, or spread; and determined by the Secretary to require immediate action to address that risk. These actions are to be carried out in accordance with applicable agency procedures, including any applicable land or resource management plan. This language apparently replaces earlier efforts to exclude invasive species control projects from analysis under NEPA. How this mandate interacts with state governors’ setting priorities under §10(c)(2)(C) is unclear.

Remember that under the funding allocations specified in Title VII, §10(g) – (i), “… not more than 10% may be used for administrative costs incurred to carry out those programs, including costs relating to oversight and management of the programs, recordkeeping, and implementation of the strategic plan …”. At the same time, §§10(e), (j), and (l) require economic analyses and reports detailing compliance with requirements and results of projects. In other words, the new law restricts expenditure of funds for “administrative costs” but imposes significant additional administrative duties.

Fortunately, Title VII §10(k)(1) states that “Nothing in this section precludes the Secretary concerned from pursuing or supporting, pursuant to any other provision of law, any activity regarding [invasive species]  control, prevention, or management …, including investigations to improve the control, prevention, or management of the invasive species.

In all iterations, the bills called for the projects to be carried out through collaboration with wide range of partners, including private individuals and entities – apparently including non-governmental organizations such as state or local invasive plant coalitions.

Earlier in Congressional consideration of the new law’s provisions, the National Environmental Coalition on Invasive Species (NECIS) responded by adopting its own description of an effective, comprehensive invasive species program.  Under the title “Tackling the Challenge of Invasive Species,” the coalition makes the following major points:

  • Focus prevention efforts on pathways of introduction. Until they are closed, managing established infestations will be a never-ending burden.
  • Broader and more aggressive efforts to control existing invaders is a solid investment, but should not be at the expense of other aspects of a comprehensive national response.
  • Close loopholes in the “Injurious Wildlife” sections of the Lacey Act to provide agencies with more agile processes for regulating the importation and transport of harmful invasive species.
  • Enhance funding for invasive species control and management projects; prioritize efforts to reduce invasive species’ spread at landscape scales.
  • Ensure that federal actions do not inadvertently promote the introduction or spread of harmful invasive species; use caution when promoting nonnative species for biofuels, bioenergy, or other
  • purposes.
  • Adopt metrics to gauge the effectiveness of efforts to prevent the introduction and spread of new invasives and to achieve long-term control or removal of existing invaders.
  • Support robust research and outreach programs, which are essential to improving the efficacy of federal, state, and local invasive species prevention and control efforts.

Given the new legislation’s focus on land-managing agencies, I point to the importance the coalition gave to research on the invasion processes utilized by various species and education of land and water users  so as to gain their cooperation. These recommendations are directly counter to the new law’s stringent limitations on research and “outreach”.

I think particularly pertinent are the recommendations on metrics to measure programs’ efficacy. Proper metrics should metrics address outcomes and program effectiveness re:

  • efforts to prevent species introduction and spread
  • activities that target pathways or vectors
  • the effectiveness of treatments in eradicating or reducing the target invasives.

Potential additional metrics include, but are not limited to:

  • Rate of new invasions; possibly categorized by type of invader or geography
  • Acres infested and changes in infestations over time
  • Acres protected, based on projections of future spread avoided by eradication
  • Economic impact of invasive species
  • Number of species intercepted.

The full document is available here .

Posted by Faith Campbell

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

South African report: Rigorous, Honest, and a Model for U.S. and Others

Density of invasive plants in South Africa

map available here

 

Last month, in my blog about the US Geological Survey’s report on invasive species  I announced release of a report by South Africa on its invasive species management programs – available here.  Because this report is unusual in both its rigor and its honesty, I’m returning to it here. I think it is a model for our country and others.

The report provides the basics. That is, it analyzes pathways of introduction and spread; number, distribution and impact of individual species; species richness and abundance of alien species in defined areas; and the effectiveness of interventions. Of the 775 invasive species identified to date, 556, or about 72%, are listed under some national regulatory program. Terrestrial and freshwater plants number 574 species; terrestrial invertebrates number 107 species. A different set of 107 species, or about 14%, are considered by experts to be having major or severe impacts on biodiversity and/or human wellbeing. The highest numbers of alien species are in the savanna, grassland, Indian Ocean coastal belt, and fynbos biomes. South Africans are particularly focused on the reductions in surface water resulting from plant invasions. Much of the control effort is under the egis of the decades-old “Working for Water” program.

Also, the report has features that are all-too-rare in work of its kind. First is the authors’ focus on rigor – of data sources and interpretation of those data using standardized criteria. Second – and even more important – is their call for analyzing the efficacy of the components of invasive species program. They insist on the need to measure outcomes (that is, results), not just inputs (resources committed) and outputs (“acres treated”, etc.). Inputs are far easier to measure and are, unfortunately, the mainstay of how most U.S. efforts are tracked – if they are tracked at all.

As they note, measure of inputs and outputs are not useful because they provide no guidance on the purpose of the action or treatment or of its effectiveness in achieving that purpose.

(For earlier CISP advocacy of measuring outcomes, visit the National Environmental Coalition on Invasive Species and read the bullet points under “Recommendations for a Comprehensive National Response”.)

The report has been praised by international conservationists, including Piero Genovesi – chair of the IUCN’s Invasive Species Specialist Group. British ecologist Helen Roy says that, to her knowledge, it is “the first comprehensive synthesis of the state of invasive species by any country.”

 

How well are programs working?

The authors’ focus on rigor includes being scrupulously honest in their assessments of current program components. They note deficiencies and disappointments, even when the conclusions might be politically inconvenient. To be fair, all countries struggle to achieve success in managing bioinvasions. And South Africa is, in many ways, a developing country with a myriad of economic and social challenges.

So it is probably not surprising that, for most factors analyzed, the authors say data are insufficient to determine the program’s impact. Where data are adequate, they often show that programs fall short. For example, they conclude that control measures have been effective in reducing populations of established invasive species, usually plants, in some localized areas but not in others. While the situation would arguably have been worse had there been no control, current control efforts have not been effective in preventing the ongoing spread of IAS when viewed at a national scale. Only one of South Africa’s 72 international ports of entry has consistent inspection of incoming air passengers and cargo – and even those inspections are not carried out outside of regular working hours (e.g., nights and weekends).

The authors are even critical of the “Working for Water” program – which is the basis for most control efforts in South Africa and enjoys wide political support. WfW has two goals: providing employment and development opportunities to disadvantaged individuals in rural areas, and managing invasive alien plants. Despite substantial funding, the WfW program has supported control teams that have reached only 2% – 5% of the estimated extent of the most important invasive plants. Furthermore, programs structured to provide employment have not ensured use of the most efficient control strategies.

 

What’s needed in South Africa — and around the world

The authors conclude that South Africa needs new processes to monitor and report on bioinvasions in order to achieve evidence-based policy and management decisions. They call for (1) more research to determine and assess invasive species impacts; (2) better monitoring of the effectiveness of current control measures; and (3) the development of methods to look at the impact of bioinvasions and their management on society as a whole.

The authors say it is important for South Africa to improve its management of invasive species because their impacts are already large and are likely to increase significantly. They note that improving management efficiency will require difficult choices and trade-offs. They recommend a focus on priority pathways, species, and areas. They also stress return on investment.

 

I don’t know how this report has been received in South Africa. I hope government officials, media observers, landowners, political parties, and other stakeholders appreciate the honesty and expertise involved. I hope they take the analyses and recommendations seriously and act on them.

(Preparation of the report was was overseen by a team of editors and contributing authors employed by the South African National Biological Diversity Institute (SANBI) and the DST-NRF Centre of Excellence for Invasion Biology at (C.I.B). Drafts were widely circulated to contributing authors and other stakeholders for comments. An independent review editor will be appointed to assess the review process and recommend any ways to strengthen the process for future reports.)

 

Meanwhile, how do we Americans apply the same rigor to analyzing our own efforts?

 

Posted by Faith Campbell

 

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

 

 

APHIS’ Strategic Plan – Focus on Deregulation & Trade Facilitation

APHIS’ headquarters building

USDA APHIS released its Strategic Plan for fiscal years 2019-2023 just after Thanksgiving. The report is 21 pages long. There is no evidence that any stakeholders were asked for input or review.

The Plan has a disappointing – but not surprising – emphasis on deregulation and “customer service”. A second – and more surprising weakness is the lack of attention to plant pests – even those of agriculture, much less natural resources. The emphasis is clearly on animal pests and diseases – including zoonotics.

APHIS’ mission is “To safeguard the health, welfare and value of American agricultural and natural resources.” To accomplish this mission, APHIS has set three goals:

  • Deliver efficient, effective, and responsive programs.
  • Safeguard American agriculture.
  • Facilitate safe U.S. agricultural exports.

Most references to protecting natural resources relate to finding more environmentally sensitive approaches for the program under which APHIS reduces human-wildlife conflicts (e.g., birds being struck by airplanes).

In the Plan, APHIS Administer Kevin Shea writes in his opening message that achieving APHIS’ difficult mission of protecting the health and value of America’s agriculture and natural resources cannot be accomplished by APHIS alone. Instead, the agency must work collaboratively with other government agencies and industry, and consult regularly with partners and stakeholders regarding programs’ effectiveness. Administer Shea also highlights the importance of “delivering our programs and services efficiently, effectively, with integrity, …” The agency promises to modernize information technology, data management, methods of communication with collaborators, exporters and importers, etc., in order to give good return on expenditure of taxpayer resources. APHIS also pledges to make decisions based on science. There are seven references to basing decisions on scientific data.

Fair enough. Such emphases were to be expected from Trump Administration and prefigured by USDA Secretary Sonny Perdue during his nomination hearing, e.g., facilitating exports, supporting better information technology.

However, the Plan refers to “customer service” or “customer experience” 34 times. An additional seven references are made to reducing regulatory burdens. The Plan also speaks of the need to “protect the health, welfare, and value of American agriculture and natural resources. … at a reasonable cost. … Easing regulatory burdens makes it easier to create jobs and promote economic growth.” (Emphasis added.)

Perhaps the recent proposal to deregulate the emerald ash borer is driven in part by the emphasis on minimizing costs to regulated industries and seeking alternative approaches? (Although the deregulation has been under discussion for several years, predating the Trump Administration.)

from APHIS PPQ website

The imbalance in attention to animal versus plant pests and disease is striking. Each of the 14 goals is supported by a number of specific tactics. There are a total of 100 “tactics” under the two goals most directly relevant to preventing or managing pest introductions. These goals are: “Protecting America’s agriculture” and “Promoting U.S. agricultural exports.” Of the 100 tactics, only ten are clearly related to plant pests; 19 are pretty clearly activities that apply to both plant and animal pests and diseases; and five are unclear as to whether they include plant pests as well as animal diseases. Thus, only a third of the tactics apply!

[In making this calculation, I did not include 43 tactics listed under the first goal (“Deliver efficient, effective, and responsive programs”) or three objectives under the goal of “Protecting American agriculture” that apply explicitly to wildlife management, regulating genetically engineered organisms, or ensuring humane treatment of animals.]

Specific examples of such lack of balance include the six examples illustrating the declaration (on p. 4) that “Pest and disease events are more frequent, more complex, and less predictable.” Five of the examples are animal diseases, the sixth is the insect-vectored human disease caused by the Zika virus.

In discussing its efforts to balance its safeguarding efforts against increasing requests for market access by international trading partners, APHIS mentions some activities pertinent to plant as well as animal pest management, e.g., examining disease and pest risks and inserting mitigation strategies into international agreements and interstate movement protocols. However, the only specific action it mentions is helping countries to build capacity to implement the Global Health Security Agenda.

The only reference to forest pests is under one of the 24 tactics associated with Goal 2. Safeguard American agriculture, Objective 2.1: Prevent damaging plant and animal pests and diseases from entering and spreading in the United States to promote plant and animal health. This tactic calls for strengthening the North American perimeter against pest threats from outside the region to prevent introduction of agricultural, forest, and other invasive pests.

Why are Plant Pests slighted?

Perhaps plant-related efforts were left out because they are less “sexy”? Or because they are more distantly linked to human health? The Plan does state that “The tactics in this plan represent only a portion of APHIS activities and by no means embody all the important work APHIS does to fulfill its mission.”

Who knows what was left out?

How will adoption of this strategy affect future efforts to address tree-killing insects and pathogens – both those already present in the country and those yet to be introduced?

Might PPQ Fill in the Gaps?

In 2014 APHIS Plant Protection and Quarantine issued its own strategic plan. This supplementary plan made frequent mentions of safeguarding natural resources. Indeed, the third of the plan’s seven goals stated:                              

Goal 3: Protect forests, urban landscapes, rangelands and other natural resources, as well as private working lands from harmful pests and diseases

Several “tactics” under each goal also directly applied to protecting natural resources. I list them below:

1) Prevent the entry and spread of ag pests and diseases.

  • Coordinate with Canada to implement an effective multi-national system that reduces the threat of tree pests arriving from Asia and other parts of the world (e.g. AGM).

3: Protect forests, urban landscapes, rangelands and other natural resources, as well as private working lands from harmful pests and diseases

  • Maintain EAB regulatory framework to focus on the leading edge of infestations while minimizing impacts on regulated businesses in quarantined areas.
  • Evaluate the effectiveness of biocontrol releases in states and combining both regulatory & outreach activities to address the risks of moving logs, firewood, and nursery stock.
  • Examine detection technologies and partnering with states to determine and apply the most effective strategies to survey & eradicate the Asian longhorned beetle
  • Partnering with federal and state agencies to enact measures such as a public outreach campaign to mitigate the movement of forest pests through firewood.
  1. Ensure the safe trade of ag products, creating export opportunities for U.S. producers
  • play a leadership role in revising ISPM#15
  1. Protect the health of U.S. agricultural resources, including addressing zoonotic disease issues and incidences, by implementing surveillance, preparedness and response, and control programs
  • Strengthen partnerships with Tribal Nations to develop a robust surveillance and early detection system for detecting and reporting invasive species.
  • Work with all stakeholders to coordinate all-hazards agriculture and natural resources response support.
  • Develop science-based programs in collaboration with industry and academia to jointly identify practices that will mitigate pest damage. E.G., SANC program http://sanc.nationalplantboard.org/ [a Systems Approach to Nursery Certification] implemented jointly with the National Plant Board and nursery industry

Dare we hope that PPQ adopts an updated strategic plan that fills in some of the gaps in the overall APHIS plan?

 

Posted by Faith Campbell

 

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

 

Report Lists Non-Native Species in the U.S.

Ailanthus altissima

Several scientists at the United States Geological Service (USGS) have published a report and accompanying datasets that attempts to provide a publicly accessible and comprehensive list of non-native species established in United States.

Led by Annie Simpson and Meghan C. Eyler, a team of six scientists worked six years (2013–2018). They reviewed 1,166 authoritative sources to develop a list of 11,344 unique names – most of them binomials (genus and species), a few genera, plus some viruses.

This was a Herculean effort that produced very valuable products. We are all in their dept!

Simpson and Eyler point out that knowing which species are non-native to a region is a first step to managing invasive species. Lists compiled in the past were developed to serve a variety of purposes, including watch lists for preventing invasions, inventory and monitoring lists for research and modeling, regulatory lists for species control, and non-regulatory lists for raising awareness. As a result, they are not comprehensive.

Among the sources these authors consulted in preparing the list were peer-reviewed journal articles, books, brochures, circulars, databases, environmental assessments, technical reports, graduate theses, and websites.

Data – by Region

The report also notes which non-native species were established in each of three regions: the “lower 48” states, Alaska, and Hawai`i. Not surprisingly, more than half the non-native taxa are established in the vast area (nearly 7.9 million km2) comprising the “lower 48” states – 6,675 taxa. Almost half of the total number of non-native taxa have established in the tiny geographic region (only 28,311 km2) of Hawai`i – 5,848 taxa.  One-tenth as many non-native taxa – 598 – are reported as established in Alaska (1.7 million km2).

This report includes taxa that are not native to any part of the specific region, but established (naturalized) somewhere in the region. An “established” species must have at least one population that is  successfully reproducing or breeding in natural systems. The list includes domesticated animals and plants introduced for crops or horticulture when the taxon has escaped cultivation or captivity and become established in the wild. Species listed range from feral hogs (Sus scrofa) to plum pox virus and citrus canker to ohia rust (Puccinia psidii).

Of the total 11,344 taxa, 157 are established in all three regions. These included 125 vascular plants (especially grasses and asters); 13 arthropods, 11 mammals; 6 birds; 3 mollusks; 1 bryozoan. One of the ubiquitous plant species is tree of heaven (Ailanthus altissima). I find it entirely appropriate that the cover photo shows this tree – the photo was taken 8 miles from my home in Fairfax County, Virginia.

Nearly three-quarters (71.4%) of the non-native species in Alaska are plant species. More than half (59.7%) of the non-native species in the “lower 48” region are also plants. Nearly all the remainder of the non-native species in both regions are some kind of animal. Fungi constitute only 1.8% of the non-native species in the “lower 48” region; all the rest of the groups (Bacteria, Chromista, Protozoa, Virus) constitute less than 1% of the non-native species recorded in either region.

By contrast, in Hawai`i, animals make up 69.7% of the listed non-native species; most are invertebrates. Plants constitute 29.8% of the Hawaiian list.

Gaps, by Taxon

The authors recognize that invertebrates and microbes are under-represented because species are still being discovered; non-charismatic and difficult-to-identify species tend to be overlooked; and the species composition of any nation in this era of globalization is constantly subject to change.

I have noted some gaps among the pathogens: the absence of some of the Phytophthora that have been detected infecting shrubs and herbaceous plants in California,  e.g., Phytophthora cambivora, siskiyouensis, tentaculata;  and the “rapid ohia death” pathogens, Ceratocystis huliohia and C. lukuohia. Dr. Simpson is aware of these gaps and is soliciting sources to help add these organisms – especially the various Phytophthora species – to the next version of the list.

Simpson and Eyler note that the relative geographic distribution of the list at its current state seems to reinforce three well established premises: that tropical island systems are particularly vulnerable; that higher latitudes host fewer but are not invulnerable; and that species diversity in general decreases with increasing latitude.

 Comparisons to Other Databases

After standardizing the names in the list by comparing them to the Integrated Taxonomic Information System (ITIS), Simpson and Eyler also reviewed the USGS BISON database, which has more than 381 million occurrence records for native and non-native species in the U.S. and Canada, covering 427,123 different taxa. (The BISON database contains significantly more species occurrences for the U.S. than the largest invasive species database, EDDMapS, which contained 4.4 million species occurrences as of June 2018.) Simpson and Eyler had to evaluate which of these taxa met their definition of non-native, since most species occurrence records in the USGS BISON are not labeled as non-native in the original records.

Comparing the BISON and non-native lists, Simpson and Eyler found that the BISON list contained a larger number of occurrence records for non-native taxa: a total of 13,450,515.However, the BISON list does not provide complete coverage of non-native species: it includes records for 77% of list of non-native species Simpson and Eyler found in Alaska, 75% of the “lower 48” sublist, but only 37% of the Hawaiian sublist.

Simpson and Eyler state their intention to continue updating the list of non-native species, they welcome contributions to it from area experts, and they urge integration of new occurrence data into invasive species database such as EDDMapS.

Indicators of Non-Native Species Richness

Figure 3 in the report (above) maps the number of non-native taxa in BISON at the county level. Figure 4 displays the proportion of non-native to native species in BISON. Higher percentages are generally evident in coastal areas and other regional hotspots. For example, the proportion in Hawaiian counties is greater than 33%. Additional data are needed to perform a more in-depth analysis of non-native species richness and abundance.

UPDATE! New Report in the Works

In June 2021, USGS announced that it was updating its Comprehensive List of Non-Native Species Established in 3 Major Regions of the U.S. so that the document more closely aligns with the parameters of the Global Register of Introduced and Invasive Species. The new USGS dataset is to be called the US Register of Introduced and Invasive Species. The list in the current draft includes 15,364 records. About 500 of these records are in Alaska, 6,000 in Hawai`i, and 8,700 in the conterminous 48 States.

One of the lead authors, Annie Simpson, contacted invasive species experts seeking feedback and suggested additions – based on authoritative resources such as peer reviewed journal articles, pest alerts, databases, books, and technical bulletins. She sought input by 25 July, 2021.

The published version of this dataset will be made freely available on USGS’ ScienceBase (https://www.sciencebase.gov), and all reviewers will be acknowledged in the dataset’s abstract.

SOURCE

Simpson, A., and Eyler, M.C., 2018, First comprehensive list of non-native species established in three major regions of the United States: U.S. Geological Survey Open-File Report 2018-1156, 15 p.

The report and accompanying data tables are available here.

South African report

In an unrelated but similar development, South Africa has issued a report on its invasive species — 2017 The Status of Biological Invasions and Their Management in South Africa. The report analyzes pathways of introduction and spread; number, distribution and impact of individual species; species richness and abundance of alien species in defined areas; and the effectiveness of interventions. The report notes that 775 invasive species have been identified to date, of which 556 are listed under some national regulatory program. Terrestrial and freshwater plants number 574 species; terrestrial invertebrates number 107 species. (This total does not include the polyphagous shot hole borer, which was detected too recently.) 107 species are considered by experts to be having either major or severe impacts on biodiversity and/or human wellbeing. Alien species richness is highest in the savanna, grassland, Indian Ocean coastal belt and fynbos biomes, lower in the more arid Karoo and desert biomes. South Africans are particularly focused on the reductions in surface water resulting from plant invasions. The decades-old “Working for Water” program has two goals: providing employment and development opportunities to disadvantaged individuals in rural areas, and managing invasive alien plants.

The Status of Biological Invasions and Their Management in South Africa is available here.

Posted by Faith Campbell

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

In Absence of Federal Action, States take Initiative

As the federal government continues to dawdle in responding to invasive species challenges, some states are ramping up their efforts in significant ways.

 

California: New Legislation Creates a Program – but Only for One Year

The California state legislature has created a new invasive species program that focuses on those bioinvaders that threaten native ecosystems and the urban environment. It thus addresses some of the criticisms that I have previously levelled at the California Department of Food and Agriculture (CDFA) [see my  earlier blogs here and here]

The new program has been established for one year; it will have to be renewed by the legislature next year.

The program results from adoption of legislation that combines what were initially two bills:

  • Assemblyman Timothy Grayson introduced AB 2470. This bill provided a legal foundation for the California Invasive Species Council and its Invasive Species Advisory Committee. It also provided funding for early detection and control projects targetting high-priority species, including weed management areas; and for supportive research and diagnostics work by the University of California.
  • Assemblywomen Lorena Gonzalez-Fletcher introduced AB 2054 focused specifically on the invasive shot hole borers [see descriptions of the polyphagous and Kuroshio shot hole borer here https://www.dontmovefirewood.org/ ]. The “Protect California Trees with Shot Hole Borer Beetle Prevention” (1) established a framework for a coordinated statewide effort; (2) instructed the Invasive Species Council of California and the California Invasive Species Advisory Committee to coordinate with state and local agencies and stakeholder groups to develop a plan to suppress the disease spread by this beetle.

The final legislation provided the full $5 million for addressing the shot hole borer but cut funding for the other components of the combined programs to just $2 million (so, a total of $7 million).

State officials have begun developing a shot hole borer management plan; they are expected to get input from a subcommittee by the Invasive Species Advisory Committee. The Advisory Committee held a meeting in mid-July to begin carrying out its coordinating functions.

Congratulations and thanks go to John Kabashima, who retired from his position as extension horticultural advisor with the University of California’s Division of Agriculture and Natural Resources. John has devoted two years to building the alliances needed to make this happen.

 

 

Minnesota: New Funding for Research

In 2014, the Minnesota legislature created the Minnesota Invasive Terrestrial Plants and Pests Center at the University of Minnesota. The Center applies science-based solutions to protect the state’s terrestrial ecosystems and agricultural resources. It utilizes an allocation from the Environment and Natural Resources Trust Fund to support a competitive research grant program. The current funding level is $3.5 million. Recently funded projects include evaluating the role of fungi in protecting ash trees from emerald ash borer and disease, genetic control of invasive insects, and use of goats in invasive plant control

The Center’s draft list of priority insects, plant pathogens, and invasive plants includes numerous forest pests. Among the 40 insect species listed, 19 are forest pests. Those in the top ten include mountain pine beetle, emerald ash borer, European and Asian gypsy moths, two elm beetles, and Asian longhorned beetle. Nineteen of 39 plant pathogens are tree-killers. Among the top ten are Dutch elm disease, oak wilt, Japanese oak wilt, Annosum root rot, sudden oak death, thousand cankers disease, and white pine blister rust.

In both cases, the lists include species that are already present and those not yet in the state (or even on the continent).

 

Western Governors’ Association: Initiative on Biosecurity

Incoming chairman, Hawaiian Gov. David Ige, has announced a Biosecurity and Invasive Species Initiative. The Initiative will focus on the impacts that invasive species have on ecosystems, forests, rangelands, watersheds, and infrastructure in the West, and examine the role that biosecurity plays in addressing these risks. Governor Ige hosted a webinar on 12 July [not yet posted on the WGA website] on which he was joined by such experts as Chuck Bargeron,  Center for Invasive Species & Ecosystem Health, University of Georgia; Pam Fuller, Program Leader, Nonindigenous Aquatic Species Database, USGS; Stinger Guala, Director of Biodiversity Information Serving Our Nation (BISON), USGS; Jamie Reaser, Executive Director, National Invasive Species Council; and Lori Scott, Interim President & CEO, and Chief Information Officer, NatureServe. The Association is sponsoring regional workshops on various components of the invasive species response on the following dates

  • Lake Tahoe, NV Sept 17-18 – prevention, control, management of established species
  • Cheyenne, WY Oct 11 -12 – restoration
  • Helena, MT Nov 14 – early detection and rapid response
  • Hawai`i Dec 9 & 10 – biosecurity and agriculture

 

Posted by Faith Campbell

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

 

 

 

The 2018 Farm Bill – It’s Complicated!

As you might remember, the Center for Invasive Species Prevention and the Vermont Woodland Owners Association last year proposed several amendments to the Farm Bill that we hoped would strengthen the U.S. Department of Agriculture’s programs on non-native insects, plant pathogens, and invasive plants. These proposed amendments are here and here.

Two of our amendments sought to strengthen funding for long-term strategies to counterpests and restore pest-depleted tree species to the forest. We intended these proposals to be implemented together.  They were put forward as two proposals only because they fell into different sections, called “titles”, of the Farm Bill.

Our first proposal would create a grant program managed by the National Institute of Food and Agriculture (NIFA) to fund research focused on biocontrol and genetic manipulation of the pests; enhancement of host-resistance mechanisms for tree species; and development of other strategies for restoration. U.S. government agencies, state cooperative institutions, academic institutions with a college of agriculture or wildlife and fisheries, and non-profit organizations would all be eligible for funding.

Our second proposal would provide long-term funding to a similar array of organizations to support research into and deployment of strategies for restoring pest-resistant genotypes of native tree species to the forest. We suggested funds be drawn from the McIntyre-Stennis program. Successful grant applicants would be required to integrate several components into a cohesive forest restoration strategy:

  • Collection and conservation of native tree genetic material;
  • Production of sufficient numbers of  propagules of pest-resistant native trees to support landscape scale restoration;
  • Site preparation in native trees’ former habitat;
  • Planting of native tree seedlings; and
  • Post-planting maintenance of the trees.

Furthermore, priorities for competitive grants issued by this second fund would be based on the level of risk to forests in the state where the activity would take place, as determined by the following criteria:

  • Level of risk posed to forests of that state by non-native pests, as measured by such factors as the number of such pests present there;
  • Proportion of the state’s forest composed of species vulnerable to non-native pests present in the United States; and
  • Pests’ rate of spread via natural or human-assisted means.

 

Several coalitions presented these two proposals – in various forms – to the House and Senate Agriculture committees earlier this year.

 

ACTION IN THE HOUSE OF REPRESENTATIVES

The Stefanik Amendment

In the House, Representative Elise Stefanik (R-NY21) inserted a modified version of CISP’s proposed amendments into the Farm Bill (H.R. 2) . Ms. Stefanik’s speech on the House floor introducing her amendment, and support of that amendment by Rep. Glenn Thompson of Pennsylvania and Agriculture Committee Chairman K. Michael Conaway (R-TX) can be heard here; scroll to time 25.16

The Stefanik amendment includes some of the key provisions advocated by CISP but it also differs in significant ways. That is, it relies on an existing grant-making program, the Competitive Forestry, Natural Resources, and Environmental Grants program. This program funds proposals pursuing numerous purposes, including pest management and genetic tree improvement. Rep. Stefanik’s amendment adds a new purpose, restoring forest tree species native to American forests that have suffered severe levels of mortality caused by non-native pests. It is unclear whether this approach will significantly increase resources available for breeding trees resistant to non-native pests.

Another difference is that institutions receiving funds would have to demonstrate that their activity is part of a broader strategy that includes at least one of the following components:

1) Collection and conservation of genetic material;

2) Production of sufficient numbers of propagules to support the tree’s restoration to the landscape;

3) Site preparation of former native tree habitat;

4) Planting; and

5) Post planting maintenance

The original CISP proposal required any funded program to incorporate all of these components.

The Stefanik amendment would award grants based on the same three criteria proposed by CISP.

While we are disappointed that research underlying tree restoration has merely been added to an already-long list of purposes under the Competitive Forestry, Natural Resources, and Environmental Grants program, this approach might be the best we can hope for. There had been considerable opposition to our proposal because it would have changed the formula under which McIntire-Stennis funds are apportioned to the states. Adopted in 1962, the existing formula is based on each state’s

1) area of non-Federal commercial forest land;

2) volume of timber cut annually;

3) total expenditures for forestry research from non-Federal sources;

4) base amount distributed equally among the States.

 

The Faso Amendment

The House also accepted an amendment sponsored by Rep. John Faso (R-NY19) that would require APHIS and the US Forest Service to collaborate on surveillance to detect newly introduced tree-killing pests. The agencies would also report to Congress by 2021 on which pests are being detected on imports of wood packaging and living plants (APHIS’ so-called “plants for planting”) and the geographic origins of those pests. Rep. Faso’s speech introducing the amendment and supportive statements by Reps. Thompson and Conaway can be heard here; scroll to time 32 (immediately after the Stefanik amendment).

 

The Welch Bill

Meanwhile, as I blogged earlier, Rep. Peter Welch (D-VT) has introduced a separate bill (H.R. 5519) that contains modified versions of several CISP proposals.

Rep. Welch’s bill would do two things: strengthen APHIS’ access to “emergency” funds to respond to invasive pests, and create a competitive grant program to support research on biological control of plant pests or noxious weeds, enhancing host pest-resistance mechanisms, and other strategies for restoring tree species. These studies must be part of comprehensive forest restoration research. Eligible institutions would include federal and state agencies, academic institutions, and nonprofit organizations. Funding  would come from a USDA corporation, the Commodity Credit Corporation so they would not be subject to annual appropriations.

The House has taken no action on Rep. Welch’s bill.

 

THE CURRENT STATUS OF THE FARM BILL – AND CISP’s BOTTOM LINE

On 17 May,  the House of Representatives failed to pass the Farm Bill. No Democrats voted for the bill. About 30 Republicans also voted against the bill – not because they objected to its contents, but because they wanted to force a vote on an immigration bill. House leaders now promise a new vote on the Farm Bill on June 22nd.

Is this good news? As I said, it is complicated! The House bill contains several provisions to which there is significant opposition. The most controversial is a requirement that recipients of food stamps prove that they are working. Other provisions – which have not received much attention in the media, would:

  • Allow the U.S. Forest Service and the Interior Department’s Bureau of Land Management to decide for themselves whether an activity might “jeopardize” an endangered species (eliminating the need to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service) (Section 8303);
  • Allow the U.S. Forest Service and Bureau of Land Management to avoid preparing an environmental assessment under the National Environmental Policy Act (NEPA) for a long list of actions which currently must be assessed. That is, they could claim a “categorical exclusion” when taking a wide variety of “critical” actions aimed at addressing several goals. These include countering insect and disease infestations, reducing hazardous fuel loads, protecting municipal water sources, improving or enhancing critical habitat, increasing water yield, expediting salvage of dead trees following a catastrophic event, or achieving goals to maintain early successional forest. These “categorical exclusions” would apply to projects on up to 6,000 acres. (Sections 8311 – 8320); and
  • Require the EPA Administrator to register a pesticide if the Administrator determines that the pesticide, when used in accordance with widespread and commonly recognized practices, is not likely to jeopardize the survival of a species listed under the Endangered Species Act or to alter critical habitat. Unlike under current law, the Administrator would not be required to consult with the U.S. Fish and Wildlife Service or National Marine Fisheries Service when making such determinations (Section 9111).

The Endangered Species Act, adopted almost unanimously in 1973, requires such “consultations” because experience had shown that agencies proposing projects tended to underestimate the damage that they might cause to imperiled species.  NEPA is one of the foundational statutes of U.S. environment protection; it was adopted in 1970. Finally, the EPA Administrator is supposed to decide whether to allow pesticide use based on science, per a much weaker but still important environmental protection statute, the Federal Insecticide, Fungicide, and Rodenticide Act (originally adopted in 1910; significantly amended in 1972).

Is getting an imperfect and partial program that might stimulate breeding of tree species resistant to invasive pests worth accepting this level of damage to fundamental environmental programs?

I don’t think so.

We don’t yet know what the Senate will do. We hope the Senate bill will support strong conservation programs – including strengthening APHIS and research into and application of long-term strategies such as resistance breeding – while not undermining the foundations of our Nation’s conservation and environmental programs.

Meanwhile, the House should rewrite the Farm Bill to remove the objectionable provisions.

 

Posted by Faith Campbell

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

 

National Park Service Experts Urge Improvements to Invasive Species Efforts

 

cats – reported to be the most widespread invasive animal in National parks

In two recent evaluations and resulting reports, National Park Service experts admit the agency has fallen short on managing the invasive species threat and suggest ways to improve. One report – that on invasive animals (see below) identifies the principal problem to be lack of support for invasive species programs from NPS leadership.

They’re not alone: I have previously criticized the NPS here and here

 

Invasive Animals

The bolder of the two reports addresses invasive animals – “Invasive Animals in U.S. National Parks – By a Science Panel” https://irma.nps.gov/DataStore/DownloadFile/594922 commissioned by the NPS Chief of Biological Resources Division. The report was released in December 2017.

The report is blunt – which I welcome.

 

Key Message

The NPS’ mission of preserving America’s natural and cultural resources unimpaired for future generations is “under a deep and immediate threat as a consequence of invasive animal species, yet the National Park Service does not have a comprehensive understanding of the costs and impacts of invasive animals or a coordinated strategy for their management.”  The result: “The consequence is a general record of failure to control invasive species across the system.”

The report says there are opportunities for the NPS to take a lead in addressing the threat – including to help counter invasive species denialism. It suggests ways to provide the needed capacity and to change the agency culture that hampers efforts to realize this ambition.

 

Current Picture

More than half of all National Park units reporting to the report’s authors (245 out of 326 parks) reported the presence of invasive animals – ranging from freshwater mussels to feral cats. In the process of compiling the report, the authors received reports of 1,409 invasive animal populations – comprising 331 species — probably an underestimate. Only a small percentage can be considered under some form of management. The most widely reported species:

Domestic cat                69 parks

Common starling         66 parks

Common pigeon          47 parks

House sparrow             40 parks

Red imported fire ant   40 parks

Feral hog                      39 parks

Rainbow trout              36 parks (often introduced deliberately)

 

The report mentions several tree-killing insects or pathogens among the damaging animal invaders in National parks: emerald ash borer, hemlock woolly adelgid, and rapid ohia death (a pathogen). (Background on all three is here.)

 

This new report acknowledges management efforts. They reviewed 80 NPS projects in the pipeline from 2000 through 2023. Most projects target a limited number of species: feral hogs, cats, and horses/burros; fire ants; hemlock woolly adelgid; and emerald ash borer.

EAB-killed ash tree in Shenandoah NP  (F.T. Campbell)

Eradication has reportedly been attempted for 21 invasive animal populations; 17 of those populations remained under some control efforts (e.g., monitoring to detect any re-invasion) in 2016. Nine of the eradicated populations were in the Pacific West region – especially Channel Islands National Park. Another eight were in the Southeast. Three other regions — Intermountain, Northeast, and National Capital regions — each reported one invasive animal population eradicated and under control. Another 150 invasive animal populations were reportedly “controlled”.

 

What’s the Problem?

The report’s authors note numerous (and well-known) difficulties in managing invasive animals. These include difficulty detecting invaders at early stages of invasion; paucity of effective management tools; and social constraints such as perceived benefits associated with some (e.g., trout and other sport fishes) and ethical and humane objections to killing vertebrates.

However, the report identifies the principal problem to be lack of support for invasive species programs from NPS leadership. Constraints that hamper park managers’ efforts within the agency include Service-wide coordination, lack of capacity, park culture, “social license” (i.e., public approval), and cross-boundary coordination.

The authors suggest that to correct these deficiencies, the Service should formally acknowledge that invasive animals represent a crisis on par with each of the three major crises that drove Service-wide change in the past:

1) over-abundance of ungulates due to predator control (leading to the “Leopold Report” in the 1960s);

2) Yellowstone fire crisis (which led to new wildfire awareness in the country); and

3) recognition of the importance of climate change (which resulted in the report “Leopold Revisited: Resource Stewardship in the National Parks”).

To achieve true success in such a major undertaking, all levels of NPS management must be engaged. Further NPS’ current culture and capacity must be changed. The report suggests providing incentives for (1) efforts to address long-term threats (not just “urgent” ones) and (2) putting time and effort into coordinating with potential partners, including other park units, agencies at all levels of government, non-governmental organizations, private landowners, and economic entities.

An additional step to realizing a comprehensive invasive animal program would be to integrate invasive animal threats and management into long-range planning goals for natural and cultural landscapes and day-to-day operations of parks and relevant technical programs (e.g., Biological Resources Division, Water Resources Division, and Inventory and Monitoring Division).

The report notes the need for increased funding. Such funding would need a flexible timeline (unlike existing Service-wide funding for more general purposes), allowing parks to be responsive to time-sensitive management issues. It would also have to be available consistently over the long term – since eradication can take a long time. Several approaches are proposed, including incorporating some invasive species control programs (e.g., weeds, wood borers) into infrastructure maintenance budgets; adopting invasive species as fundraising challenges for “Friends of Park” and the National Park Foundation; and adopting invasive species as a priority threat.

The authors would like NPS to become a leader on the invasive species issue – specifically by testing emerging best management practices and by better educating visitors on the ecological values of parks and the serious threat that invasive species pose to the their biodiversity. The authors suggest that the NPS also take the lead in countering invasive species denialism.

While officially-approved deliberate introductions of non-native species are probably unlikely to continue, the report expects that the numbers of invasive animals and species in national parks will increase due to continuing spread of invaders from neighboring areas. Therefore, NPS’ current piecemeal approach needs to be replaced with a much stronger, strategic approach in which parks engage in collaboration with conservation partners on adjacent lands or waters and across the greater landscape.

 

Invasive Plants

The NPS launched a coordinated effort targetting invasive plants years ago — in 2000. The most obvious component of which was the Exotic Plant Management Teams (EPMTs). The broader program was officially named the Invasive Plant Program (IPP) only in 2014. The IPP provides leadership to individual parks, regions, and the park system on invasive plant management, restoration, and landscape level protection. The IPP released its strategic plan in December 2016. (Ok! More than a year ago. I am tardy.)

Despite the large size of the program – 15 EMPTs across the country – and the clear and recognized threat that invasive plants pose to NPS values, I got the impression that the program struggles to gain  support from the Service. In that way, the situation is similar to the challenges to efforts on animal invasives described above.

   removing Miconia to protect Haleakala National Park

The Strategic Plan identifies goals and actions to optimize the program’s effectiveness, while increasing program and park capacity and leveraging human and fiscal resources with state, federal, and private entities.

The plan articulates a mission, a vision, five broad goals, and actions for the next 10 years. It’s intended to guide annual planning and major projects, as well as to identify and help prioritize funding needs and initiatives.

The overall vision is for the Invasive Plant Program to guide park service efforts to enhance landscape level stewardship of resources by applying “technically sound, holistic, collaborative, adaptive, and innovative approaches.” The hope is that other NPS units will increasingly rely on the IPP’s expertise in implementing their programs and building partnerships.

The strategic plan lays out five broad goals, each supplemented by a list of detailed activities. Priority actions have been identified for the first 5 years (2017-2021) with the expectation that actions will be re-prioritized during annual reviews. These five goals are:

  1. Develop program standards

Clarify and standardize administrative and operational roles and tasks. Improve data management and train colleagues in those standards. Incorporate science-informed procedures to support park management of invasive plants.

Interestingly, the Plan calls for IPP staff to quantify the invasive plant threat and effort needed to manage it and then to communicate the gap between effort needed and resources available to decision makers.

2. Promote the Invasive Plant Program by highlighting the services it provides and the significance of the invasive plant issue both internally and with stakeholders. Assure that IPP efforts parallel those in the Department of Interior Action Plan for invasive species.

  1. Build capacity of individual parks and the Service to prevent the arrival of invasive plants and manage infestations that are already present

Enhance resource and information sharing and field-based training. Find ways to encourage parks to continue managing the invaders after the EMPT completes the initial eradication. Also find ways to increase the EPMT Program’s efficiency. Possibly develop an NPS pesticide applicators’ certification course (the Bureau of Land Management and Department of Defense already have one).

Increase partnerships to deal with actions that are outside parks’ control. Specifically, participate in regional and state invasive plant councils, and collaborate with a full range of external partners to identify successful techniques, conduct control and restoration campaigns, improve and implement efficient plant management across park boundaries, and recruit and manage youth and volunteers.

  1. Promote holistic and integrated invasive plant management

Work with other NPS programs and parks (across all divisions) to establish resource stewardship and landscape preservation / restoration goals. Integrate integrated pest management strategies in management actions. Continue close collaboration with Climate Change Response Program (if it still exists!). Identify research needs and get the research done.

  1. Collaborate on invasive plant management

Foster and encourage internal and external collaboration and coordination to leverage available resources, expertise, and knowledge.

Identify parks, NPS programs, partner agencies, organizations, and related initiatives with similar objectives to increase efficiency and effectiveness. Coordinate with NPS monitoring programs (although the invasive animal study authors thought the monitoring program is not structured to serve invasive species needs). Partner with BLM and US Fish and Wildlife Service and non-federal partners to cooperatively manage invasive plants on the landscape. Coordinate compliance with National Environmental Policy Act (NEPA) and National Historic Preservation Act.

 

Each IPP unit is expected to develop an annual work plan that aligns with an annual financial plan. Priorities will be reviewed annually. Each IPP unit will also submit an annual accomplishment report. IPP might develop a tracking system to be applied to each assigned action.

Plus the IPP strategic plan will be reviewed annually and actions will be re-prioritized as needed. The annual status reports will be made available to stakeholders and partners on the Web.

 

Posted by Faith Campbell

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

 

Spring! the good & the ugly

Virginia bluebells

 

It’s spring in the Mid-Atlantic!

Spring prompts many memories for me. I first committed to environmental causes 48 (!) years ago when I discovered the glories of spring in the woods owned by the Institute for Advanced Studies in Princeton, NJ.  I would rise at 5 AM or earlier to greet the sunrise in the woods. There were wonderful birds, deer, even weasels … and carpets of spring ephemerals. The floodplain was covered by spring beauties, violets of every hue, trout lilies, occasional toothwarts … for reasons no one has never been able to explain, very few bluebells (other floodplains I have visited in the Mid-Atlantic — e.g., Brandywine & Bull Run —  have lots of bluebells). Within weeks, there were mayapples and some trilliums and even some pink ladyslippers.

trout lilies & spring beauty

(My studies at Princeton had nothing to do with nature or conservation … )

Yesterday I visited a floodplain near my home in Northern Virginia (Accotink Creek downstream from the dam; Fairfax County). I found those same wildflowers – but they are struggling to find space under a tsunami of invasive herbaceous plants – especially European buttercup and Leucojum. (Garlic mustard is much less common – I think volunteers might be pulling it.)

European buttercups

 

Leucojum  

The shrub layer is dominated by multiflora rose, honeysuckles (shrub & vine), and privet .

Makes me sad … makes me mad! Let’s redouble our efforts.

What is invading your favorite bottomland hardwood forest? Send me your comments!

Faith

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.

APHIS Nursery Stock Regulations (Q-37) – Modernization Finally Completed!

citrus longhorned beetle – entered country several times in imported bonzai plants

After about 20 years, APHIS has finalized important changes to the regulations which govern imports of living plants (what they call “plants for planting”; the regulation is sometimes called “the Quarantine 37” rule).  The new regulation takes effect on April, 18, 2018.

I congratulate APHIS on this important achievement!

[Twenty years is a long time – so changes happen. When APHIS released its Advance Notice of Proposed Rulemaking (ANPR) in December 2004 and its proposed rule in April 2013, I was employed by The Nature Conservancy and submitted comments for that organization. I will refer to those earlier comments in this blog. However, I now represent the Center for Invasive Species Prevention, so my comments here on the final regulations reflect the position of CISP, not the Conservancy.]

APHIS’ 2004 ANPR came after years of preparation. Then, more than eight years passed until the formal proposal was published on April 25, 2013. Comments were accepted from the public until January 30, 2014. During this nine-month period, 17 entities commented, including producers’ organizations, state departments of agriculture, a foreign phytosanitary agency (The Netherlands), private citizens, and The Nature Conservancy. [You can view the ANPR and proposal, comments on these documents, and APHIS’ response here — although you need to click on “Restructuring of Regulations on the Importation of Plants for Planting” and then “Open Docket Folder” to pursue the older documents.]

In the beginning, APHIS had a few goals it hoped to achieve: to allow the agency to respond more quickly to new pest threats, to apply practices that are more effective at detecting pests than visual inspection at points of import, and to shift much of the burden of preventing pest introductions from the importer and APHIS to the exporter.

Progress has been made toward some of these goals outside this rule-making. APHIS instituted a process to temporarily prohibit importation of plants deemed to pose an identifiable risk until a pest risk assessment has been completed (the NAPPRA process). APHIS has further enhanced its ability to act quickly when a pest risk is perceived by relying increasingly on “Federal Orders”.

At the same time, APHIS participated actively in efforts by international phytosanitary professionals to adopt new “standards.” These define a new approach to ensure that plants in international trade are (nearly) pest-free. Both the North American Plant Protection Organization’s regional standard (RSPM#24)  and the International Plant Protection Organization’s global standard (ISPM#36)  envision a system under which countries would no longer rely primarily on inspections at ports-of-entry. Instead, they would negotiate with the supplier or exporting country to develop programs to certify that growers’ pest management programs are effective. Both standards detailed: 1)  how the place of production might manage pest risk and ensure traceability of plants; 2) how the importing and exporting countries might collaborate to administer the program; 3) how audits (including site visits) would ensure the program’s efficacy; and 4) what actions  various parties might take in cases of noncompliance.

It was hoped that these international standards would lead to widespread adoption of “integrated pest management programs” composed of similar requirements – similar to the impact of ISPM#15 for wood packaging.  However, living plants are more complex pest vectors than the wooden boards of crates and pallets, so each country was expected to negotiate its own specific programs – something not  encouraged for wood packaging.

APHIS’ decades-long effort to amend its regulations is warranted because of the high risk of non-native insects and – especially – pathogens being introduced via international trade in living plants. U.S. examples include white pine blister rust, chestnut blight, dogwood anthracnose, and sudden oak death (all described briefly here )

dogwood anthracnose

According to Liebhold et al. 2012 (full reference at end of blog), 12% of incoming plant shipments in 2009 were infested by a quarantine pest. This is an approach rate that is 100 times greater than the 0.1% rate documented for wood packaging (Haack et al. 2014). I have discussed the living plant introductory pathway and efforts up to 2014 to get it under control in my report, Fading Forests III.

 

Shortcomings of the Final Q 37 Rule

So – how well does this final rule  meet APHIS’ objectives?

First, will it shift much of the burden of preventing new pest introductions from the importer and APHIS to the exporter, while ensuring the system’s efficacy? In my view, on behalf of CISP, it falls short.

The new rule sets up a process under which APHIS might require that some types of imported plants be produced and shipped under specified conditions intended to reduce pest risk. However, non-American entities have little incentive to protect America’s natural and agricultural resources and from invasive species. So any new process needs severe penalties for violators.

We have seen how widespread and persistent compliance failures are for wood packaging under ISPM#15. http://nivemnic.us/wood-packaging-again-11-years-after-ispm15-problems-persist/ For this reason, I (on behalf of the Conservancy) had suggested that APHIS formally adopt a specific goal of “no new introductions”. I recognized that this goal was unachievable per se, but suggested that it should stand as a challenge and be the basis for adopting stringent restrictions on plant imports. I suggested  limiting plant imports to those either a) produced under integrated pest management measures systems (verified by third-party certification) or b) plants brought into facilities operating under post-entry quarantine conditions — and following other best management practices that had been developed and supervised by independent, scientifically-based bodies.

In my current view, APHIS’ regulation falls far short of either this goal of shifting burdens or setting a truly stringent requirement. In fact, APHIS has explicitly backed away from its own original goals and procedures.

The new regulation does authorize APHIS to choose to set up import programs under which the exporting country agrees to produce plants for the U.S. market under a system of integrated pest risk management measures (IPRMM) approved by APHIS. In accordance with the international standards, the programs established under this new power will address how the place of production will manage pest risk and ensure traceability of plants; how APHIS and the exporting country will administer the program; how plant brokers will ensure plants remain pest-free while in their custody; how audits will be performed to ensure program efficacy; and what actions various parties will take in cases of noncompliance.

How efficacious this new approach will be in preventing new introductions will depend on how aggressive APHIS is in both choosing the plant taxa and places of-origin to be managed under such IPRMM programs and in negotiating the specific terms of the program with the exporting country.

It is discouraging that APHIS has ratcheted down how frequently it expects to rely on the IPRMM approach. In the explanatory material accompanying the final regulation, APHIS clarifies that did not intend that IPRMM would be used for all imports of living plants. The IPRMM framework is described as only one of several means to achieve the goal of preventing introduction of quarantine pests. APHIS will choose the “least restrictive measures” needed to prevent introduction of quarantine pests. To clarify its position, APHIS changed the introductory text to indicate that IPRMM will be applied when such measures are necessary to mitigate risk – that is, “when the pest risk associated with the importation of a type of plants for planting can only be addressed through use of integrated measures.” [Emphases added]

The final rule is also discouraging in some of its specifics.

  • Whereas the draft regulation specified steps that places of production must take to ensure traceability of the plants they produce, in the final regulation the traceability elements specified in each IPRMM agreement will depend on the nature of the quarantine pests to be managed. Again, APHIS seeks to ensure that its requirements are not unnecessarily restrictive.
  • Although the international standard had specified severe penalties when a grower or broker violated the terms of the IPRMM agreement, APHIS proposed to base the regulatory responses to program failures on existing bilateral agreements with the exporting country. Despite the Conservancy’s plea that APHIS follow ISPM#36 in adopting more specific and severe penalties, APHIS has not done so. The one bright spot is that APHIS may verify the efficacy of any remedial measures imposed by the phytosanitary agency of the exporting country to correct problems at the non-compliant place of production. [Emphasis added]
  • APHIS is relaxing the detailed requirements for state post-entry quarantine agreements – despite the Conservancy’s concern that such agreements’ provisions could be influenced by political pressure and other nonscientific factors.

 

Two Improvements

I am pleased that APHIS has retained requirements applied to plant brokers, despite one commenter’s objections. Brokers handling international shipments of plants grown under an IPRMM program must both handle the plants themselves in ways that prevent infestation during shipment and maintain the integrity of documentation certifying the origin of the plants. A weakness, in my current view, is that APHIS will allow brokers to mix consignments of plants from more than one producer operating under the IPRMM program.  APHIS does warn that if non-compliant (infested) plants are detected at import, all the producers whose plants were in the shipment would be subject to destruction, treatment, or re-export.

A major improvement under the new regulation is that APHIS will now operate under streamlined procedures when it wishes to amend the requirements for importing particular plants (whether a taxon, a “type”, or a country of origin). Until now, APHIS has been able to make such changes only through the cumbersome rulemaking process, Instead, APHIS will now issue a public notice, accept public comments, and then specify the new requirements through amendment of the “Plants for Planting Manual” [  https://www.aphis.usda.gov/import_export/plants/Manuals/ports/downloads/plants_for_planting.pdf ] APHIS estimates that such changes can be finalized four months faster under the new procedure.

 

A Final Caveat

Finally, APHIS needs to be able to measure what effect the new procedures have on preventing pest introductions.  Such measurement depends on a statistically sound monitoring scheme. APHIS has stated in some documents that the current Agriculture Quarantine Inspection Monitoring (AQIM) system doesn’t serve this purpose. APHIS needs to develop a valid monitoring program.

 

References

 

Haack RA, Britton KO, Brockerhoff  EG, Cavey JF, Garrett LJ, et al. (2014) Effectiveness of the International Phytosanitary Standard ISPM No. 15 on Reducing Wood Borer Infestation Rates in Wood Packaging Material Entering the United States. PLoS ONE 9(5): e96611. doi:10.1371/journal.pone.0096611

Liebhold, A.M., E.G. Brockerhoff, L.J. Garrett, J.L. Parke, and K.O. Britton. 2012. Live Plant Imports: the Major Pathway for Forest Insect and Pathogen Invasions of the US. www.frontiersinecology.org

 

Posted by Faith Campbell

 

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New study evaluates “candidate pool” from which invasive species might come

Campanula latifolia – one of the species detected as an “emerging” invasive species in the database relied upon by the authors of the study

The authors of a new study note that officials managing invasive species programs rely largely on knowledge of a species’ previous invasion history to predict its level of threat in the geographic area under their responsibility. This approach does not work with the many introduced species that have no history of a previous detected invasion. Hanno Seebens and 49 coauthors – including tree-pest experts Eckehard G. Brockerhoff, Marc Kenis, Andrew M. Liebhold, and Alain Roques — have sought to figure out how great a handicap that lack of data is. See “Global rise in emerging alien species results from increased accessibility of new source.” The study is available for $10 here. Figures, tables, and references are available without charge.

The study used a database of 45,984 first records of establishment of 16,019 species belonging to the following major taxonomic groups: vascular plants, mammals, birds, fishes, insects, crustaceans, mollusks, and other invertebrates.

Last year, many of the same scientists, relying on the same database, found that the rate of new introductions of alien species has risen rapidly since about 1800 – and shows no sign of slowing down. The adoption of national and international biosecurity measures during the 20th century have slowed introductions – but they are not sufficiently effective, especially regarding those plants and animals that are introduced primarily accidentally as stowaways on transport vectors or contaminants of commodities (e.g., algae, insects, crustaceans, mollusks and other invertebrates). The 2017 study found a strong correlation between these “accidental” alien species’ spread and the market value of goods imported into the region of interest. For that study, go here.  I blogged about the findings on 1 March 2017 – here.

In the new 2018 article, the scientists found that even after many centuries of invasions the rate of emerging alien species is still high. Across all taxonomic groups, one out of four detections during 2000 – 2005 was of a species that had not been previously recorded anywhere as alien. Detections of “new” or “emerging” aliens is occurring at an even higher rate for some taxonomic groups. But new detections of insects fit the average – every fourth detection during 2000 – 2005 was of a species not previously recorded outside its native range.

The authors conclude that the continuing high proportion of “emerging” alien species is best explained by the interplay of 1) the incorporation into the pool of potential alien species of species native to regions formerly not accessible to traders; 2) increases in introduction rates due to higher import volumes; and 3) probably rising establishment rates as a consequence of land degradation that facilitates establishment in recipient regions. This process compensates for the decrease of new invaders from historically important source regions – from which potentially invasive species have presumably already taken advantage of pathways and been recorded as introduced somewhere.

emerald ash borer Agrilus planipennis – one of the species in the database of “emerging” invasive species

 

The number of insect species in the database candidate species pool is 20,611 species – an admittedly small fraction of all insects (for example, there are more than 350,000 beetle species worldwide). Twenty-four percent of these insect species have already been established somewhere outside their native ranges. However, the authors note that data gaps – which are larger for some taxonomic groups and geographic regions – mean that the number of actual “first” introductions is probably larger than records indicate, and consequently the estimated size of the candidate species pools may also be higher. Indeed, the paper does not attempt to estimate the actual size of the invasive species “pool” for insects.

The authors analyzed the importance of eight factors – temperature, relative humidity, import values, three land-use categories, number of botanical gardens, and human population size – in explaining the continued high number of “emerging” invaders detected in recent years. While these factors were explanatory for some taxonomic groups, they had a very low predictive value for insects.

For vascular plants, every third record of an introduction in 2000 – 2005 was of an “emerging” alien  species. Interestingly, the number of botanical gardens in a country was a significant predictor for emerging alien vascular plants. However, as the authors of the article point out, reliance on this factor ignores the probable importance of other contributors such as the number of species planted in the receiving country; similarities between source and receiving environments; and introductions by acclimatization societies, European explorers or settlers, and plant hunters.

Acer ginnala –one of the species detected as an “emerging” invasive species in the database; photo by J. Weisenhorn, University of Minnesota extension

In any case, lots of previously undetected alien species are detected each year. In this database, 58% of the species had a single record; 86% of all species have no more than two first records in countries on the same continent. The large number of species with only one or two records led the authors to conclude that most species will not spread widely. I question that conclusion because species often require some time to spread to new locations – either local or distant. The authors do admit that they are unable to determine which species have a high potential for spread.

ash trees at the St. Louis arch – before arrival of emerald ash borer

 

The continued high rate of introduction of new species leads the authors to estimate that between 1% and 16% of all species on Earth – depending on the taxonomic group – qualify as potential invasive alien species. The authors did not attempt to estimate the true candidate pool or percentage of invasive species for insects. For vascular plants, the authors estimated the candidate pool at 47,000 species (out of a total of 368,000 species on Earth), or 13%.

Like its predecessor, this study’s importance arises from its broad perspective – covering the entire globe and a wide range of taxonomic groups. Its major conclusion that invasions will continue on a large scale serves as a warning to all stakeholders. These include officials charged with protecting agriculture and the broader economy, or the natural environment; conservationists; and those engaged in the economic activities that promote invasion.

However, the authors found that the data did not support more specific advice. First, as noted above, they were unable to determine which of the “emerging” invasive species in all taxonomic groups have a high potential to spread.

For those of us focused on invasive species that threaten native plants, data gaps limit the predictive value of the study the most. The database is too scant even to estimate the invasive species “pool” of potential insect pests. Plant pathogens are not included in the analysis.

 

 

Posted by Faith Campbell and Phyllis Windle

 

We welcome comments that supplement or correct factual information, suggest new approaches, or promote thoughtful consideration. We post comments that disagree with us — but not those we judge to be not civil or inflammatory.