APHIS’ EIS on Importing Plant Pests: What it reveals about APHIS

APHIS headquarters in Riverdale, MD

APHIS has published a final Environmental Impact Statement (FEIS) as one of the final steps in modifying its regulations governing conditions for issuing permits for importation, interstate movement, and intrastate movement of plant pests – including biocontrol agents.  Access it here.

The original proposal to modify the regulatory system was published in March 2017.

I find the rationale for modifying the regulations to be compelling: the current regulations:

  • date from 2001;
  • do not adequately reflect changes in APHIS’ mandate enacted by the Plant Protection Act; and
  • do not focus agency efforts on the permit applications that pose the highest risk.

The FEIS presents two alteratives: the “preferred alternative” and the “comprehensive risk mitigation program.” APHIS settles for the less protective actions that expose natural resources, especially, to risk from non-indigenous species

1) The FEIS reiterates — without discussion or rationale — APHIS’ acceptance of the vague word “acceptable” to describe the level of protection the agency strives to achieve (see pp. 2, 22, 45, 106 of the FEIS).  The FEIS does not attempt to quantify the differences in the levels of protection provided by the two alternatives.

2) APHIS advocates a policy alternative that does not require post-release monitoring of biocontrol agents. The FEIS justifies adoption of this alternative despite putting a welcome emphasis on the importance of just such efforts to determine the actual impacts of biocontrol organisms on both target and non-target species (p. 67). On page 70, the FEIS notes that the paucity of documented examples of adverse effects on non-target species “may be the result of insufficient monitoring after release …” It goes on to note that “very few introductions included a careful evaluation of nontarget impacts  …” The FEIS notes the paucity of funding for this research and – sometimes – the lack of authority to require such monitoring.

In the case of APHIS, I see no legal impediment to the agency requiring biocontrol permit applicants to carry out post-release monitoring.

Indeed, if APHIS chose the “comprehensive risk mitigation program”, the agency would require enhanced post-release monitoring. The goal would be to document “the extent of establishment, spread, and limit to expected hosts” of the introduced biocontrol organism (p. 43). Nevertheless, the FEIS accepts the “preferred alternative”, which does not require such monitoring. The reason given for this choice is that the comprehensive program would require too many resources. I note below that we can overcome this barrier by lobbying for increased appropriations and higher staffing levels.

3) APHIS dismisses risks associated with high levels of uncertainty. In justifying the less rigorous “preferred alternative”, the FEIS refers 20 times to the persistence of uncertainties in analyses of the potential impact of importation, interstate transport, or release of non-indigenous organisms. FEIS also says that given these inevitable uncertainties, APHIS should regulate most organisms “conservatively” – defined in the FEIS as “based on what is known” ( p. 74).  Of course, APHIS long ago rejected the precautionary approach – which is a truly conservative approach.

4) The FEIS accepts APHIS’ current practice of evaluating risks only in the geographic area of approved introduction – despite conceding repeatedly that introduced organisms often spread beyond the original introduction site. It is true that the geographic area evaluated includes all continental states (whether Alaska is included is unclear). However, there is no discussion of the likelihood that organisms introduced to the continental states will be transported to U.S. islands in the Caribbean or Pacific – through either authorized or unauthorized mechanisms.

The FEIS Asserts Principles that APHIS Sometimes Fails to Live Up To

As I note above, the FEIS makes numerous references to the reality that an organism released into the environment might establish and spread to its maximum geographic range based upon host distribution, climate and other range-limiting factors. According to the FEIS, APHIS’ decisions about issuing a permit allowing release of non-native organisms must reflect that likelihood. For example:

“In principle, therefore, release of the biological control organism, at even one site, should be considered equivalent to release over the entire area in which potential hosts occur, and in which the climate is suitable for reproduction and survival.” (P. 67)

However, APHIS’ recent decision to allow introduction of a thrips (Pseudophilothrips ichini) in Florida to control Brazilian pepper (Schinus terebinthifolius) does not reflect this principle.

The environmental assessment (EA) that analyzed this proposed release reported that the thrips would both encounter a suitable climate in Hawai`i (pp. 11 and 19) and feed on two native Hawaiian species – Rhus sandwicensis and Dodonaea viscosa. The EA described the feeding damage on these non-target species as negligible and noted that P. ichini sustained only one generation on these non-target species (p. 27).  Furthermore, the EA noted (p. 29) that the action being reviewed did not include release of P. ichini in Hawai`i. However, the EA did not discuss the frequency with which insects established on the Continent are transported – without authorization – to the Islands.  In my view, if introduced to Hawai`i – by authorized or non-authorized transport – the thrips is likely to thrive because several good hosts are widespread.  By feeding on these good hosts, the thrips could enjoy a “food subsidy” that would allow it to put constant pressure on the vulnerable Hawaiian species. [You can obtain a copy of my comments on the draft EA by contacting me via the “contact us” button, or by visiting the Federal Register site at the link given above.]

Rhus sandwichensis; photo by Forest & Kim Starr

The FEIS fails to address an important risk

Amynthes agrestis one of the invasive earthworms established in the U.S.
photo by National Park Service

The FEIS doesn’t recognize – or even mention – the impact of non-native earthworms on native ecosystems and native plants! The only discussion of risks associated with earthworms is on p. 26, where the sole concern is the risk that soil-dwelling worms could vector crop and livestock diseases present in the soil in the country of origin.

Yet the FEIS notes that APHIS’ mandate – and the purpose of the permit system – is to protect not only American agriculture but also our natural resources. I have blogged about the severe impact earthworms have on native flora here. Why did the authors of the EIS ignore the large and growing scientific literature on this issue?

Good Points in the FEIS

1) The FEIS notes the concern that biocontrol agents will attack non-target species, with results that “may not be easily reversed.” (pp. 66, 74) The FEIS cites several examples, including Cactoblastis cactorum on North American prickly pear (Opuntia) cacti – see my blogs here and the potential impact of Rhinocyllus conicus on native thistles. The FEIS notes that these particular biocontrol agents would not be approved for release under current policies. However, the FEIS also reports that a biocontrol agent released on thistles in Virginia in 1997 – that is, under criteria currently in use – had spread across the continent to California and Nevada within two years! While the FEIS reports the spread as by natural means, I wonder if some enterprising farmers might have taken infected plants/inoculum without authority.

2) The FEIS notes several indirect concerns arising from the environmental release of biocontrol organisms, including contamination, adaptation, interference, competition, and hybridization. When biocontrol organisms establish but don’t reduce populations of the target weed, they can provide a “food subsidy” to some organisms, thus disrupting the ecological balance. The example given is two gall flies (Urophora affinis and U. quadrifasciata), which failed to control knapweed and led to population explosions of deer mice – with repercussions for competition among small mammals, possibly reduced recruitment of native plant populations, and increased incidence of a serious disease of humans, Sin Nombre hantavirus.  (Recall my similar concern re: a thrips if it reaches Hawai`i, above.)

3) The FEIS cites scientific publications demonstrating the low rate of success of biological control in controlling invasive plants or arthropods.  One such discussion – on p. 53 – notes that an estimated 65% of introduced arthropods successfully establish for the purposes of weed control, 25 – 34% of those introduced to control arthropods. These figures are repeated on p. 59. However, on pp. 67-68, even lower success rates are presented, based on worldwide estimates. This is not a good record, given the risks involved. Furthermore, given my focus on non-native insects, I am concerned by the statement in the FEIS that the scientific study of potential risks of biocontrol targetting arthropods control is not thorough. (pp. 68-69)  

The Center for Invasive Species Prevention hopes that other stakeholders will work with us to persuade APHIS to work toward adoption of the more protective approach described in the “comprehensive  risk mitigation program”. A key factor will be lobbying the Administration and Congress to increase appropriations and personnel ceilings so that APHIS has the resources necessary to carry out the more protective program.

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.

Collapse of Biodiversity – Causes and What We Can Do

frogs in California killed by chytrid fungus
photo by Rick Kyper, US Fish and Wildlife Service

I expect you have heard about the report issued on May 6 by the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services. The executive summary is available here

Based on thousands of scientific studies, the report concludes that the biosphere, upon which humanity as a whole depends, is being altered to an unparalleled degree across all spatial scales. The trends of decline are accelerating. As many as 1 million species (75% of which are insects) are threatened with extinction, many within decades.

Humans dominate Earth: natural ecosystems have declined by 47% on average. Especially hard-hit are inland waters and freshwater ecosystems: only 13% of the wetland present in 1700 remained by 2000. Losses have continued rapidly since then.

The report lists the most important direct drivers of biodiversity decline – in descending order – as habitat loss due to changes in land and sea use; direct exploitation of organisms; climate change; pollution; and invasive species. The relative importance of each driver varies across regions.

If you have been paying attention, these conclusions are not “news”.

However, the report serves two valuable purposes. First, it provides a global overview, a compilation of all the data and trends. Second, the report ties the direct drivers to underlying causes which are in turn underpinned by societal values and behaviors. Specifically mentioned are production and consumption patterns, human population dynamics and trends, trade, technological innovations, and governance (decision making at all levels, from local to global).

The report goes to great lengths to demonstrate that biological diversity and associated ecosystem services are vital for human existence and good quality of life – especially for supporting humanity’s ability to choose alternative approaches in the face of an uncertain future. The report concludes that while more food, energy and materials than ever before are now being supplied to people, future supplies are undermined by the impact of this production and consumption on Nature’s ability to provide.   

The report also emphasizes that both the benefits and burdens associated with the use of biodiversity and ecosystem services are distributed and experienced inequitably among social groups, countries and regions. Furthermore, benefits provided to some people often come at the expense of other people, particularly the most vulnerable.  However, there are also synergies – e.g., sustainable agricultural practices enhance soil quality, thereby improving productivity and other ecosystem functions and services such as carbon sequestration and water quality regulation.

The report contains vast amounts of data on the recent explosion of human numbers and – especially – consumption – of agricultural production, fish harvests, forest products, bioenergy production … and on the associated declines in “regulating” and “non-material contributions” ecosystem services. In consequence, the report concludes, these recent gains in material contributions are often not sustainable.

While invasive species rank fifth as a causal agent of biodiversity decline globally, alien species have increased by 40% since 1980, associated with increased trade and human population dynamics and trends. The authors report that nearly 20% of Earth’s surface is at risk of bioinvasion. The rate of invasive species introduction seems higher than ever and shows no signs of slowing.

The report notes that the extinction threat is especially severe in areas of high endemism. Invasive species play a more important role as an extinction agent in many such areas, especially islands. However, some bioinvaders also have devastating effects on mainlands; the report cites the threat of the pathogen Batrachochytrium dendrobatidis to nearly 400 amphibian species worldwide.

The report also mentions that the combination of species extinctions and transport of species to new ecosystems is resulting in biological communities – both managed and unmanaged — becoming more similar to each other — biotic homogenization.

The report notes that human-induced changes are creating conditions for fast biological evolution of species in all taxonomic groups. The authors recommend adopting conservation strategies designed to influence evolutionary trajectories so as to protect vulnerable species and reduce the impact of unwanted species (e.g., weeds, pests or pathogens).

The report says conservation efforts have yielded positive outcomes – but they have not been sufficient to stem the direct and indirect drivers of environmental deterioration. Since 1970, nations have adopted six treaties aimed at protection of nature and the environmental, but few of the strategic objectives and goals adopted by the treaties’ parties are being realized. One objective that is on track to partial achievement is the Aichi Biological Diversity Target that calls for identification and prioritization of invasive species. 

That might well be true – but I would not consider global efforts to manage invasive species to be a success story in any way. I have blogged often about studies showing that introductions continue unabated … and management of established bioinvaders only rarely results in measurable improvements.   [For example, see here and here.]

The report gives considerable attention to problems caused by some people’s simultaneous lack of access to material goods and bearing heavier burden from pollution and other negative results of biodiversity collapse. Extraction of living biomass (e.g. crops, fisheries) to meet the global demand is highest in developing countries whereas material consumption per capita is highest in developed countries. The report says that conservation of biodiversity must be closely linked to sustainable approaches to more equal economic development. The authors say both conservation and economic goals can be achieved – but this will require transformative changes across economic, social, political and technological factors.

One key transformation is changing people’s conception of a good life to downplay consumption and waste. Other attitudinal changes include emphasizing social norms promoting sustainability and personal responsibility for the environmental impacts of one’s consumption. Economic measures and goals need to address inequalities and integrate impacts currently considered to be “economic externalities”. The report also calls for inclusive forms of decision-making and promoting education about the importance of biodiversity and ecosystem services.

Economic instruments that promote damaging, unsustainable exploitation of biological resources (or their damage by pollution) include subsidies, financial transfers, subsidized credit, tax abatements, and commodity and industrial goods prices that hide environmental and social costs. These need to be changed.

Finally, limiting global warming to well below 2oC would have multiple co-benefits for protecting biodiversity and ecosystem services. Care must be exercised to ensure that large-scale land-based climate mitigation measures, e.g., allocating conservation lands to bioenergy crops, planting of monocultures, hydroelectric dams) do not themselves cause serious damage to biodiversity or other ecosystem services.

The threats to biodiversity and ecosystem services are most urgent in South America, Africa and parts of Asia. North America and Europe are expected to have low conversion to crops and continued reforestation.

Table SPM.1 lays out a long set of approaches to achieve sustainability and possible actions and pathways for achieving them. The list is not exhaustive, but rather illustrative, using examples from the report.

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.

Progress in Combatting Invasives – with Caveats

Missouri Makes Progress in Eradicating Feral Hogs – Despite Sabotage

Feral hogs have expanded their range in the U.S. from 17 to 38 states over the past 30 years. Their populations grow rapidly because feral hogs can breed any time of the year and produce two litters of one to seven piglets every 12 to 15 months. [See MDC Press Release, January 25, 2019]

hog “sounder” in a trap in Missouri
Missouri Department of Conservation

Missouri’s program is increasingly successful: the numbers of hogs removed has risen from 5,358 in 2016, to 6,561 in 2017, to 9.365 in 2018. [See MDC Press Release, January 25, 2019] I have previously praised Missouri’s scientifically-based program to eradicate feral hogs – here and here (Missouri has extensive material on feral hogs posted here)  

According to the Missouri Department of Conservation’s feral hog elimination team leader, Mark McLain, said “This strategic approach is important because if we leave even a few feral hogs behind in an area, they can reproduce quickly and put us back where we started.”

According to McLain, hunting is not an effective method for eliminating feral hog populations. “For over 20 years, unregulated hunting of feral hogs was allowed in Missouri, during which time our feral hog population expanded from a few counties to over 30 counties,” he said.

In 2017, MDC, the Corps of Engineers, and the LAD Foundation established regulations against feral hog hunting on lands owned and managed by these three organizations. Other agencies have passed regulations similar to MDC’s to eliminate hog hunting on land they own.

However, illegal releases of feral hogs continue. The February 2019 press release (referenced below) describes several examples of the problems such releases cause. McLain said that those who release feral hogs face hefty fines. Hunting, especially with dogs, pushes the hogs onto neighboring property, which causes problems for neighbors. The hogs travel back and forth between the properties, escaping and causing more damage. Trapping with no hunting interference is the best method to eliminate them.

MDC advises landowners to seek help from the Department and USDA APHIS. These agencies providetechnical advice and training; conduct on-site visits; and loan equipment.

Are feral hog programs in other states using the same methods? Are they as successful?

SOURCES

Missouri Department of Conservation. More than 9,300 Feral Hogs Eliminated from Missouri in 2018. Press Release. January 25, 2019.

Missouri Department of Conservation. Interference with feral hog trapping sites costs trappers time, taxpayers money. Press Release. February 21, 2019.

Florida Looks to Biocontrol to Makes Progress Against Some of its Worst Invasive Plants

Brazilian peppertree tangle
John Randall, The Nature Conservancy
www.bugwood.org

Until recently, melaleuca (Melaleuca quinquenervia) was considered the worst invasive tree or shrub in Florida. It threatened to convert the everglades “sea of grass” into a thicket of exotic trees which could not support native wildlife. Thanks to the biocontrol agent Oxyops vitiosa, melaleuca is considered to be under maintenance control on public conservation land in the state. Still, melaleuca control demands about $2 million per year because of the huge area previously (and still) affected by the tree.

Now Florida is about to release biocontrol agents to attack Brazilian pepper (Schinus terebinthifolius). In Florida, Brazilian peppertree is found from Monroe County in the south to St. Johns, Levy, and Nassau counties in the north plus Franklin County in the Panhandle. An estimated 283,000 hectares of south and central Florida are invaded. The South Florida Water Management District alone is spending approximately $1.7 million per year (as of 2011) to control it.

Brazilian peppertree invades disturbed sites such as canal banks and fallow farmlands. Of greater concern to me are the many natural communities invaded – Brazilian peppertree infests more natural areas in Florida than any other invasive plant species. Invaded ecosystems include pinelands, hardwood hammocks, and critically important mangrove forests. The coastal mangroves are valued because of their high productivity, wildlife habitat, and shoreline protection and stabilization.

Brazilian peppertree infestation in the Everglades
Tony Pernas, USDI National Park Service
www.bugwood.org

Dense stands of Brazilian peppertree shade out and may kill food plants used by white-tailed deer – key prey for the endangered Florida panther. Other mammals and birds might be poisoned by toxic resins in the bark, leaves and fruits — although some birds feed extensively on the fruits – and thereby contribute to spread of the invasive plant.

Existing options for management of Brazilian peppertree, including chemical, mechanical, and physical control measures, have been used with some success against this weed. However, applying these strategies repeatedly to prevent regrowth is costly and labor intensive. Furthermore, such practices can be detrimental to native vegetation. For example, mangroves are particularly sensitive to both herbicides and the soil disturbances associated with mechanical control

After more than 20 years of searching, Florida hopes it has identified useful biocontrol agents. USDA APHIS is seeking public comment on the proposed release of two insect species, Calophya latiforceps  (a leaf galling psyllid) and Pseudophilothrips ichini (a thrips) as biological control agents targetting Brazilian pepper.

Much as I sympathize – Brazilian peppertree is a highly damaging invasive plant and there are no other effective control measures – I have questions. First, the psyllid is sedentary; dispersal would be by wind. Would this limit its efficacy?

More troubling is host specificity. The Environmental Assessment (available here) reveals that the thrips can reproduce in low numbers on several non-target plant species, including the Hawaiian sumac Rhus sandwicensis. True, the proposal is to release the biocontrol agents on the continent, not on Hawai`i. But insects have often been transported inadvertently to Hawai`i – and the islands’ plant species have often proved highly vulnerable to attack by non-native species (I confess that the most recent examples are pathogens, e.g., ‘ōhi‘a rust and rapid ‘ōhi‘a death.)

APHIS is accepting comments on the Environmental Assessment until March 29. Please consider providing your views. Again, the document is available here.

RESULTS

In June 2019, APHIS announced that it would issue permits for release of the two biocontrol agents on the continent – starting in Florida – without any restrictions. APHIS dismissed my concerns about the potential threat to native Hawaiian plants — Rhus sandwicensis and Dodonaea viscosa. See the agency’s responses in Appendix 7.

As regards the potential threat to the two Hawaiian species from the thrips Pseudophilothrips ichini APHIS chose to ignore my two greatest concerns:

1) that insects are introduced accidentally to Hawai`i frequently – so the threat from this thrips must be considered.

2)  if introduced to Hawai`i, P. ichini would have ample resources to maintain high population levels and so could put constant pressure on Rhus sandwicensis and Dodonaea viscosa even ‘though neither plant itself supports more than one generation of the thrips.

In response to my query as to who in Texas would be consulted re: possible release of the biocontrol agents in that state, APHIS replied the chief state plant regulatory official (head of plant pest issues in the state Department of Agriculture) and the APHIS representative in the state. No conservation authorities are designated. Nor would APHIS prepare a new environmental assessment – although the current one cites data almost exclusively for Florida.

One good response: in response to my concerns that the psyllid Calophya latiforceps is too sedentary to spread through the hundreds of thousands of acres invaded by Brazilian pepper, APHIS clarifies that a mass rearing and release program is under development.

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.

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

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