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David I. Theodoropoulos, Las Sombras Biological Preserve, Box 337, La Honda, CA 94020-0337 USA
(408) 236-3728
dt@dtheo.org

Comments submitted to the NISC on 9 February 2008.

The following are my brief comments on the 2008 2012 National Invasive Species Management Plan.

http://www.invasivespeciesinfo.gov/council/mpdraft07.pdf

Also attached is a copy of a portion of my previous comments with many important points and unanswered questions - indeed, questions that have yet to be addressed by the NISC. [See: Comments on the NISC Draft management Plan, Prediction: Is it Possible, Unanswered Questions] The NISC has not addressed any of the serious problems I pointed out years ago. The NISC seems to be intent on ignoring all scientific and practical problems with its plan, and creating an expensive, pork barrel boondoggle for the American public. Remember the Mirex program? The Aedes aegyptii program in the 1960s? Hundreds of millions spent with zero beneficial result, and great harm done to the environment. The NISC's plans will repeat these mistakes many times over.

I again challenge the NISC to address any of the substantive questions I pose in my attached comments ("Prediction: Is it possible?"), and I challenge the NISC to stop the deliberate exclusion of skeptical voices from the process, and to invite any of the skeptical scientific voices, myself included, to come to the table and participate.

The NISC has persistent problems with failure to craft operational definitions: What is non-native? What is harm? What is an "invasion"?

Every species on the planet can be considered harmful by some criterion - how will economic harm and economic benefit be evaluated and balanced? More importantly, how will ecological harm be defined? If, as seems to be the usual practice, the mere presence of any species that is considered "non-native" is considered by some to be harm, how will you deal with the examples that follow?

The zebra mussel cleared polluted water in the Great Lakes, and increased native aquatic macrophytes and native fishes, increasing the catch of native yellow perch fivefold. What economic analysis has been done of the benefits of the removal of pollution, clearing of water, and increased fish catch? How does the dollar value of these benefits compare with the dollar values of harms such as intake pipe fouling? What procedures does the NISC have for conducting such evaluation?

The seeds of "invasive alien" plants are the preferred food for the endangered giant kangaroo rat (Dipodomys ingens) - what procedures does the NISC have in place to evaluate such benefits of "invaders" and balance them against putative "harm" from invaders?

"Invasive" eucalyptus in California are the preferred habitat for at-risk native monarch butterfly overwintering congregations - how will the NISC evaluate such phenomena? Ecological harm or ecological benefit? How will positive ecological impacts be compared with "negative" impacts? Does mere change equal harm? What justifies such a position? Many other examples like these have been detailed in my book "Invasion Biology: Critique of a Pseudoscience" - until such time as the NISC can effectively answer the substantive questions detailed there and in my attached comments, it must not institute policies which are based on a non-scientific and anecdotal foundation.

What will be included in the definition of non-native? Will northward range expansions of native species (more and more likely, and even ecologically necessary, in response to climate change) be considered invasions? Will a native species be considered an invader if it appears several states away? In the next state? Next county? Will the endangered Mexican grey wolf be considered an invader if it moves northward? The jaguar, as it expands its range northward? The jaguar was present all the way into the boreal forests fringing the icecap during the last glaciation, showing that there are no ecological limits other than man to prevent its reinhabitation of its former range. While I would personally welcome the range expansion of these predators, wolves and jaguars would certainly have adverse economic impacts on ranchers - will the NISC then be in the business of exterminating endangered species? If not, what are the criteria involved in making such a decision? If not, why will economic harm be ignored in these cases? The horse was present here in North America until a mere 6000 years ago - is it to be considered native, or a non-native invader? Even the lion (Panthera leo, the same species as that currently found in Africa and Asia) inhabited the ice-free desert of northern Alaska during the last glaciation, and as such must be considered a native North American species.

If your definitions and procedures do not effectively answer these very simple examples, then it is time for you to turn out the lights and go home.

Page 11 - "Implementation Task P.1.1: Develop screening processes to evaluate invasiveness of plants which are intended for planting and are moving in trade."

My response to this may be found in the attached document "Prediction: Is it possible?" The NISC has not addressed even one of the numerous, substantive questions I posed in this paper, although it has had years to do so. It is extremely negligent for the NISC to fail to address these points. Again, it is grossly irresponsible to inhibit the strategically important free flow of biological resources without serious, verifiable reason. NO system of prescreening or risk assessment is needed or appropriate, except for those species that have been identified as causing proven harm elsewhere. The only reason to create a system of prescreening introductions that have not proven harmful elsewhere is to create bureaucratic sinecures.

Page 15, Early Detection and Rapid Response (EDRR).
Will the NISC see all newly-discovered populations of species existing in areas where previously unknown to be new "invasions" to be hit with a rapid response and extermination?

If so, what criteria and procedures has the NISC created to determine:

1) Whether a newly-discovered population is an outlying, disjunct preexisting population of a native species which had not been recorded before, a new, anthropogenic population of said species, or a natural range extension by the species in response to global climate change.

2) Whether a newly-discovered population of a species not previously present in the US (or state or smaller political unit) is of conservation value (a species at-risk elsewhere, such as the Mexican wolf, or the naturalized populations of endangered Echium species such as exist in California).

3) Whether a newly-discovered population of a species not previously present in the US (or state or smaller political unit) is in fact harmful, and will not be one of the many new species that will integrate without harm or have beneficial ecological effects such as those mentioned above.

In the absence of scientifically-valid criteria and procedures to address the above points, it will be grossly irresponsible for the NISC to engage in any sort of "rapid response" to contain or exterminate such species. It is extremely negligent for the NISC to fail to address these points.

EDRR Point f - "How will the effort be funded?", is important. Considering the state of the economy, size of the national debt, and amount of our basic infrastructure that is in serious need of repair, is it really wise to spend public funds on such pork? It is grossly irresponsible to spend money on any "invader" that is not a clear and present, proven danger. Money should not be spent on eradicating any species that does not have proven economic or ecological harm that substantially outweighs the economic and ecological benefits it may provide.

Increased inspection of imports for known pests would be a more effective use of public funds.

The NISC has made it abundantly clear that it intends to continue to ignore all public input that is not consistent with its "party line", and intends to create massive, expensive interventions into society, inhibiting scientific research, free trade, and biological preservation efforts. Widespread toxic and destructive extermination projects will be mandated, based on assessments of invasiveness and harm that are entirely without operational definitions or objective, empirical measurement of harm, and which have no testable scientific foundations.

I was not aware of the current public comment period until a few days ago. As one of the NISC's scientific critics, I believe that the NISC has the responsibility to insure that critcal, skeptical voices be heard. Therefore I am requesting that in the future, the NISC notify me of all public comment periods in a timely manner so that I will have adequate time to submit my comments.

David Theodoropoulos


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