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2002.



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Report to Executive Agency Officials:



October 2002:



INVASIVE SPECIES:



Clearer Focus and Greater Commitment Needed to Effectively Manage the 

Problem:



GAO-03-1:



Letter:



Results in Brief:



Background:



More Comprehensive Analysis of the Economic Impacts of Invasive Species 

Would Better Inform Decision Makers:



The National Management Plan Lacks a Clear Long-Term Outcome, and Its 

Implementation Has Been Slow:



The Current Regulations Concerning Ballast Water Management Are Not 

Keeping Invasive Species Out of the Great Lakes:



There Is a Growing Interest in Coordination between the United States 

and Canada, but a Comprehensive Approach Has Yet to Be Developed:



Conclusions:



Recommendations for Executive Action:



Agency Comments and Our Evaluation:



Appendixes:



Appendix I: Scope and Methodology:



Appendix II: Survey of Charter Members of the Invasive Species

Advisory Committee:



Appendix III: Comments from the Department of the Interior:



Appendix IV: Comments from the Department of State:



Appendix V: Comments from the National Invasive Species Council

through the Department of the Interior:



Appendix VI: Comments from the Environmental Protection Agency:



Figures:



Figure 1: Profile of the Mute Swan:



Figure 2: Key Federal Departments and Their Responsibilities for 

Invasive Species:



Figure 3: National Invasive Species Council and Management Plan:



Figure 4: Profile of the European Green Crab:



Figure 5: Profile of the Asian Long-Horned Beetle:



Figure 6: Profile of Buffelgrass:



Figure 7: Rates of Compliance with Ballast Water Exchange Requirement 

for Ships Entering the Great Lakes, 1992-2001:



Figure 8: Discovery of Nonnative Aquatic Species Introduced into the 

Great Lakes and Major Legislation and Regulatory Decisions, 1985-2002:



Figure 9: Profile of the Zebra Mussel:



Figure 10: Profile of West Nile Virus:



Abbreviations:



APHIS: Animal and Plant Health Inspection Service:



CDC: Centers for Disease Control:



EPA: Environmental Protection Agency:



FICMNEW: Federal Interagency Committee for the Management of Noxious 

and Exotic Weeds:



GAO: General Accounting Office:



IMO: International Maritime Organization:



NANPCA: Nonindigenous Aquatic Nuisance Species Prevention and Control 

Act:



NISA: National Invasive Species Act:



OMB: Office of Management and Budget:



OTA: Office of Technology Assessment:



USDA: United States Department of Agriculture:



USGS: U.S. Geological Survey:



Letter October 22, 2002:



The Honorable Ann M. Veneman

Secretary of Agriculture:



The Honorable Gale A. Norton

Secretary of the Interior:



The Honorable Donald L. Evans

Secretary of Commerce:



Invasive species--harmful, nonnative plants, animals, and 

microorganisms--are found throughout the United States, causing 

damage to crops, rangelands, waterways, and other ecosystems that is 

estimated in the billions of dollars annually. Some have termed 

invasive species “biological pollutants.” Unlike some chemical 

pollutants that can degrade over time, biological pollutants have the 

potential to persist, multiply, and spread.[Footnote 1] In addition to 

their economic costs, invasive species can have a devastating effect on 

natural areas, where they have strangled native plants, taken over 

wetland habitats, crowded out native species, and deprived waterfowl 

and other species of food sources. Conservation biologists rank 

invasive species as the second most serious threat to endangered 

species after habitat destruction. Overall, scientists, academicians, 

and industry leaders are recognizing invasive species as one of the 

most serious environmental threats of the twenty-first century. We have 

issued two prior reports on this subject: one on funding to address 

invasive species and the other on the government’s approach for quickly 

responding to invasions by new species.[Footnote 2]



In February 1999, in response to the challenges faced by state and 

federal agencies to minimize the spread of invasive species, President 

Clinton issued Executive Order 13112. The order directs federal 

agencies to take actions that will prevent the introduction of invasive 

species; provide for their control; and minimize their impact on the 

economy, the environment, and human health. The order established the 

National Invasive Species Council, which now comprises the heads of 10 

federal departments and agencies, to provide national leadership and 

coordination in federal invasive species activities and to issue a 

national invasive species management plan.[Footnote 3] The order also 

directed the Secretary of the Interior to establish an advisory 

committee to provide information and advice to the council.



The problem of invasive species is an international one. Organisms are 

brought, intentionally or unintentionally, from one country to another. 

They may also spread on their own across international borders. Because 

of the international aspects of the issue, as well as the seriousness 

of the problem for both Canada and the United States, we undertook a 

review of federal invasive species management in cooperation with the 

Office of the Auditor General of Canada. One issue of particular 

importance to both countries is preventing aquatic invasive species 

from entering the Great Lakes in the ballast water of ships.[Footnote 

4] We and the Auditor General are issuing simultaneous but separate 

reports. The Office of the Auditor General’s Report of the Commissioner 

of the Environment and Sustainable Development to the House of Commons 

contains a chapter on Canada’s invasive species management efforts.



The objectives of our review were to (1) assess the usefulness of 

analyses that have estimated the economic impact of invasive species in 

the United States to federal decision makers responsible for preventing 

and controlling their spread; (2) assess the National Invasive Species 

Management Plan, including the extent to which the plan has been 

implemented; (3) provide the views of experts on the adequacy of 

U.S. and Canadian federal government efforts to prevent the 

introduction of invasive species into the Great Lakes via the ballast 

water of ships; and (4) describe how the United States and Canada are 

coordinating invasive species management efforts.



Among the efforts we undertook to analyze these issues was a survey 

of all 32 members of the Invasive Species Advisory Committee. About 

74 percent of the committee members responded to our survey and 

68 percent completed it. We also observed meetings of the committee. 

See appendix I for further details on our scope and methodology.



Results in Brief:



The scope of existing studies on the economic impact of invasive 

species in the United States range from narrow to comprehensive, and 

most are of limited use for guiding decision makers formulating federal 

policies on prevention and control. Narrowly focused estimates include 

analyses of past damages that are limited to a certain commercial 

activities such as agricultural crop production and simple accountings 

of the money spent to combat a particular invasive species. These 

estimates typically do not examine economic damage done to natural 

ecosystems, the expected costs and benefits of alternative control 

measures, or the impact of possible invasions by other species in the 

future. On the other hand, more comprehensive--and rare--analyses are 

those that examine the past and prospective economic impact of invasive 

species on commercial activities and natural ecosystems and the 

potential costs of preventing or controlling them. In general, the more 

comprehensive the approach used to assess the economic impacts of 

invasive species, the greater its potential usefulness to 

decision makers for identifying potential invasive species, 

prioritizing their economic threat, and allocating resources to 

minimize overall damages. Recent initiatives by federal agencies to 

integrate information on the likelihood of invasion, the likelihood of 

economic damage to commercial activities and natural ecosystems, and 

the likely effectiveness of control methods should help support more 

informed decisions about managing invasive species. However, according 

to agency officials, efforts to produce more comprehensive and complex 

studies that address the range of factors are hampered by a lack of 

necessary data and of targeted resources.



The National Invasive Species Council’s 2001 management plan, 

Meeting the Invasive Species Challenge, lacks a clear long-term outcome 

and quantifiable measures of performance. While the actions called for 

in the plan are likely to contribute to controlling invasive species, 

it is unclear how implementing them will move the United States toward 

a specific outcome, such as a lower number of new invasive species or 

reduced spread of established species by a certain amount. Federal 

officials recognize that there are deficiencies in the plan and are 

working toward improvements. At present, the only available performance 

measure that can be used to assess overall progress is the percentage 

of planned actions that have been completed by the due dates set in the 

plan. By this measure, implementation has been slow. As of September 

2002, the departments and agencies composing the council had completed 

less than 20 percent of the actions that the plan had called for by 

that date, although they have begun work on others. A large majority of 

the members of the Invasive Species Advisory Committee who responded to 

our survey believe that the pace of implementation is inadequate. There 

are numerous reasons for the slow progress, including delays in 

establishing teams that will be responsible for guiding implementation 

of the planned actions, the low priority given to implementation by the 

council, and the lack of funding and staff responsible for doing the 

work. Some stakeholders expressed the view that the low priority and 

associated lack of progress may be due to the fact that the Congress 

did not create the council or direct it to implement the plan. However, 

even if the actions in the plan were more fully implemented their 

effect would be uncertain because they typically do not call for 

quantifiable improvements in invasive species management or control.



According to experts and agency officials we consulted, current efforts 

by the United States and Canada are not adequate to prevent the 

introduction of invasive species into the Great Lakes via the ballast 

water of ships. Beginning in 1993, U.S. federal regulations required 

ships that enter the Great Lakes from more than 200 nautical miles off 

the U.S. coast to exchange their ballast water in the open ocean (that 

is, in waters deeper than 2,000 meters and farther than 200 

nautical miles from the U.S. coast), retain the ballast water on board, 

or use an alternative, environmentally sound, method of ballast water 

management. The purpose of the exchange is to flush the ballast tanks 

of living organisms or kill them with salt water. Canada has had 

voluntary guidelines calling for a similar ballast water exchange since 

1989. The U.S. Coast Guard inspects all ships entering the Great Lakes 

and, according to the agency, 88 percent of the ships entering with 

ballast water from 1994 through 2001 had exchanged it in compliance 

with U.S. regulations. The Coast Guard has not approved alternative 

treatment methods; therefore, those that did not exchange their ballast 

were prohibited from emptying their tanks while in the Great Lakes. 

Nevertheless, aquatic invasive species are still entering the 

Great Lakes and establishing themselves in the ecosystem. According to 

the experts we consulted, at least two factors contribute to the 

failure of the existing regulations to prevent introductions. First, 

about 70 percent of the ships that enter the Great Lakes are classified 

by the Coast Guard as having no ballast on board and are, therefore, 

exempt from open-ocean exchange requirements. However, these ships may 

in fact have thousands of gallons of residual ballast water and 

sediment containing potentially invasive organisms in their drained 

tanks that may be mixed with water later taken from, and then 

discharged into, the Great Lakes. Second, for those ships that have 

ballast, open-ocean exchange does not effectively remove or kill all 

organisms in the ballast tanks. Although the United States and Canada 

believe they should do more to protect the Great Lakes from ballast 

water discharges, their plans for doing so depend on the development of 

standards and technologies that will take a decade or more. In the 

meantime, the continued introduction of invasive species could have 

major economic and ecological consequences.



The United States and Canada participate in a wide variety of bilateral 

and multilateral efforts to share information, conduct research, and 

coordinate their efforts to reduce the threat of invasive species. 

However, the two countries have not developed a comprehensive strategy 

for joint prevention and management efforts. The long history of 

coordination between the United States and Canada has focused on such 

areas as agricultural research and shared boundary waters. There are 

numerous bilateral and multilateral organizations of which the United 

States and Canada are a part that recognize invasive species as an 

important issue and provide a forum for increased planning and 

coordination between the two countries. In general, however, efforts to 

date have addressed specific pathways, species, or geographic areas in 

a reactive way, rather than as part of a coordinated approach. The 

National Invasive Species Council has recognized the need for the 

United States to work with Canada (and Mexico) in a more comprehensive 

manner and has taken initial steps to develop a North American 

strategy, as called for by the national management plan. It is too 

early to tell, however, what form such a strategy will take.



We are making several recommendations to the National Invasive Species 

Council as a whole, and to the member departments and agencies 

individually, aimed at improving the nation’s management of invasive 

species. The council and member agencies generally agreed with these 

recommendations.



Background:



Invasive Species Threaten the Economy and the Environment:



As we have reported in the past, the impact of invasive species in the 

United States is widespread, and their consequences for the economy 

and the environment are profound.[Footnote 5] They affect people’s 

livelihoods and pose a significant risk to industries such as 

agriculture, ranching, and fisheries. The cost to control invasive 

species and the cost of damages they inflict, or could inflict, on 

property or natural resources are estimated to total billions of 

dollars annually. For example, according to the U.S. Department of 

Agriculture (USDA), the Formosan termite causes at least $1 billion 

annually in damages and control costs in 11 states (in 2001 dollars). 

USDA also estimates that, if not managed, fruit flies could cause more 

than $1.8 billion in damage each year (in 2001 dollars).



According to the National Invasive Species Council, hundreds, and 

perhaps thousands, of nonnative species have established populations in 

the United States. Invasive species continue to be introduced in new 

locations, with recent examples including the northern snakehead fish 

in Maryland and the emerald ash borer in Michigan. Many scientists 

believe that invasive species are a significant threat to biodiversity 

and are major or contributing causes of population declines for almost 

half the endangered species in the United States. Invasive species can 

alter entire ecosystems by disrupting food chains, preying on critical 

native species such as pollinators, increasing the frequency of fires, 

or--as in the case of some plants--simply overshadowing and smothering 

native plants. Invasive species may arrive unintentionally as 

contaminants of bulk commodities such as food, in packing materials and 

shipping containers, or in ships’ ballast water. Others may be 

introduced intentionally; kudzu, for example--a rapidly growing 

invasive vine that thrives in the southeastern United States--was 

intentionally introduced from Japan as an ornamental plant and was used 

by USDA in the 1930s to control soil erosion. Other invasive species 

are imported as crops, livestock, aquaculture species, or pets, and 

later escape or are released into the environment. (See fig. 1 for 

details on the mute swan, intentionally introduced to adorn parks and 

private bird collections.):



Figure 1: Profile of the Mute Swan:



[See PDF for image]



[End of figure]



Not all nonnative species, however, cause harm. Many nonnative species, 

such as cattle, wheat, soybeans, many fruits, and ornamental plants 

(such as tulips and chrysanthemums), have been largely beneficial and 

their propagation controllable. Various terms have been applied to 

invasive species, including “alien,” “exotic,” “nonindigenous,” and 

“nonnative.” In this report, we use the definition provided by 

Executive Order 13112, which states that an invasive species is an 

alien species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health. An alien species is one 

that is not native to a particular ecosystem. (We used this definition, 

as well as other factors, in selecting species to profile in 

this report.):



The Federal Government Conducts a Variety of Invasive Species 

Activities:



More than 20 federal agencies in 10 departments--including USDA, 

Commerce, Defense, and the Interior--have responsibility for some 

aspect of invasive species management. (See fig. 2.) States also have a 

significant management role, but the extent of their involvement varies 

considerably. USDA has the largest federal role because of its 

responsibility to (1) conduct port-of-entry inspections and quarantine 

goods coming into the country, (2) manage more than 190 million acres 

of national forests and grasslands, (3) conduct research, and 

(4) provide technical assistance to the private sector and in large 

agricultural pest control projects. We reported that in fiscal 

year 2000, seven of the departments obligated more than $624 million 

for activities related to invasive species management.[Footnote 6] 

According to the council, appropriations to those departments for such 

activities increased in fiscal year 2001 to approximately 

$1.05 billion, of which USDA received almost $975 million.



Figure 2: Key Federal Departments and Their Responsibilities for 

Invasive Species:



[See PDF for image]



[End of figure]



In February 1999, invasive species prevention and control efforts 

received heightened attention with the issuance of Executive 

Order 13112. The executive order established the National Invasive 

Species Council, which is now made up of the secretaries and 

administrators of 10 federal departments and agencies.[Footnote 7] The 

executive order required the Secretary of the Interior to establish an 

advisory committee to provide information and advice to the council. 

Accordingly, in November 1999, the secretary established the Invasive 

Species Advisory Committee, composed of 32 nonfederal members 

representing a range of interests relevant to invasive species, 

including academia, environmental organizations, industry, trade 

associations, Native American tribes, and state government.



The executive order also required that the council develop a national 

invasive species management plan using a public process and revise it 

biennially. Among other things, the executive order called for the plan 

to (1) recommend performance-oriented goals and objectives and specific 

measures of success, (2) recommend measures to minimize the risk of new 

introductions of invasive species, and (3) review existing and 

prospective approaches and authorities for preventing the introduction 

and spread of invasive species. The council and its staff worked with 

members of the advisory committee and other interested parties to 

produce draft management plans for public comment. In January 2001, the 

council issued the final plan, which identifies nine categories of 

planned actions to aid in the prevention, control, and management of 

invasive species in an effort to minimize their economic, 

environmental, and human health impacts. (See fig. 3.) The council’s 

plan calls for member departments to implement a total of 86 discrete 

actions, each with an associated due date or start date. Examples of 

the actions include establishing and coordinating long-and short-term 

capacities for basic and applied research on invasive species and 

gathering and disseminating information on the council’s Web site.



Figure 3: National Invasive Species Council and Management Plan:



[See PDF for image]



[End of figure]



The United States and Canada Face Many Difficult Issues Related to 

Managing Invasive Species:



The United States and Canada have a mutual interest in limiting the 

introduction or spread of invasive species across their borders. The 

two countries share more than 5,500 miles of terrestrial and aquatic 

border that provide potential pathways for invasive species. Each 

country is the other’s largest trading partner, sending and receiving a 

variety of goods, such as crops, livestock, wood, and horticultural 

products, that can harbor invasive species. Therefore, species that 

enter one of the two countries have opportunities to spread into 

the other.



The Great Lakes--a shared U.S. and Canadian resource--have been subject 

to invasion by nonnative species since the settlement of the region. At 

least 160 nonnative aquatic organisms have become established in the 

lakes since the 1800s, most of which have come from Europe, Asia, and 

the Atlantic coast. More than one-third of the organisms have been 

introduced in the past 30 years, a trend coinciding with the opening of 

the St. Lawrence Seaway in 1959 and other changes in ship operations. 

Ballast water in ships is considered a major pathway for the transfer 

of invasive aquatic organisms to the Great Lakes. Ballast is essential 

to the safe operation of ships because it enables them to maintain 

their stability and control how high or low they ride in the water. 

Ships take on or discharge ballast water over the course of a voyage to 

counteract the loading or unloading of cargo, and in response to sea 

conditions. The ballast that ships pump aboard in ports and harbors may 

be fresh, brackish, or salt water. These waters may contain various 

organisms that could then be carried to other ports around the world 

where they might be discharged and survive.



Canada adopted voluntary ballast water management guidelines in 1989 

in response to the 1988 discovery of nonnative zebra mussels in 

Lake St. Clair. The Canadian guidelines were superceded by new 

guidelines in 2000 and encourage ships’ masters entering the 

Great Lakes and other waters under Canadian jurisdiction to employ 

management practices--such as exchanging ballast water in the open 

ocean--to minimize the probability of future introductions of harmful 

aquatic organisms. They also direct ships’ masters to provide ballast 
water 

details to Canadian authorities.[Footnote 8] The United States followed 
the 

Canadian lead and passed the Nonindigenous Aquatic Nuisance Prevention 
and 

Control Act of 1990.[Footnote 9] This legislation directed the 
Secretary of 

Transportation to issue voluntary ballast water guidelines and 

regulations for the Great Lakes. Joint United States and Canadian 

voluntary guidelines, which closely tracked the 1989 Canadian 

guidelines, went into effect in March 1991. The U.S. Coast Guard issued 

the first set of mandatory ballast water regulations for the 

Great Lakes in April 1993.[Footnote 10] The National Invasive Species 

Act of 1996 amended the 1990 act and required the Secretary of 

Transportation to issue voluntary ballast water guidelines for the rest 

of the United States.



More Comprehensive Analysis of the Economic Impacts of Invasive Species 

Would Better Inform Decision Makers:



The scope of existing analyses of the economic impact of invasive 

species in the United States range from narrow to comprehensive. 

Narrowly focused analyses include estimates of past damages that are 

limited to commercial activities such as agricultural crop production 

and simple accountings of the money spent to combat a particular 

invasive species. These estimates typically do not include the economic 

impact of these species on natural ecosystems, the expected costs and 

benefits of alternative measures for preventing their entry or 

controlling their spread, or the impacts of possible invasions by other 

species in the future. On the other hand, more comprehensive--and rare-

-analyses are those that examine the past and prospective economic 

impact of invasive species to both commercial activities and natural 

ecosystems and the potential costs of preventing or controlling them. 

Few analyses have been done that examine the likelihood that new 

species will invade new locations and that estimate their costs. 

Although the estimates we reviewed may have served the purpose for 

which they were intended, the narrow scope of many of them may limit 

their usefulness to decision makers formulating federal policies on 

prevention and control. In general, the more comprehensive the approach 

used to assess the economic impacts of invasive species, the more 

likely its usefulness to decision makers for identifying potential 

invasive species, prioritizing their economic threats, and allocating 

resources to minimize overall damages. Federal agencies recognize the 

value of this type of analysis and have recently taken steps to use it 

more often. According to officials from several agencies, however, 

efforts to improve economic impact analyses are hampered by a lack of 

data on invasive species and a lack of economists assigned to assessing 

their economic impacts on commercial activities and natural ecosystems.



The Narrow Scope of Many Analyses May Limit Their Usefulness to 

Decision Makers:



The narrow scope of many analyses of the economic impacts of invasive 

species may limit their usefulness to decision makers developing 

policies and allocating resources to address the problem.[Footnote 11] 

First, many of the analyses we reviewed do not address the economic 

impact of invasive species on natural area ecosystems. Instead, they 

reflect the impacts of invasive species on commercial activities such 

as agricultural and timber production and fisheries. This reflects the 

fact that most of the management and control of invasive species in the 

United States has focused on those species that damage agricultural 

crops and livestock. For example, the Federal Interagency Committee for 

the Management of Noxious and Exotic Weeds (FICMNEW) studied the 

economic impact of weeds on the U.S. economy and found the estimated 

value of losses from invasive weed species to be about $15 billion per 

year.[Footnote 12], [Footnote 13] However, the committee reported that 

the economic impact on most nonagricultural sites was not available. 

Focusing solely on the impact of invasive species on commercially 

valuable activities ignores the potential impact of invasive species on 

ecosystems as a whole, possibly understating the impact of these 
species.

[Footnote 14] Consistent with that point, according to the 
Environmental 

Protection Agency, the true cost of invasive species is underestimated 
if 

estimates of damages do not include lost ecosystem services, such as 
water 

purification and aesthetic values.[Footnote 15]



Second, many of the existing analyses do not fully account for the 

expected costs and benefits that are associated with different control 

methods for invasive species. Two frequently cited summations of the 

aggregate impacts of invasive species in the United States were based 

on estimates of this type. The first, by the U.S. Office of Technology 

Assessment (OTA), estimated that by 1991 at least 4,500 nonnative 

species had become established in the United States, of which about 600 

had caused severe harm. The OTA was able to obtain data showing that 

the economic impact of 79 of these species totaled about $118 billion 

between 1906 and 1991 and impact included damage to agricultural crops, 

industrial activities, and human health.[Footnote 16] The second effort 

was by researchers at Cornell University who estimated in 1999 that 

approximately 50,000 nonnative plant and animal species are known to 

have entered the United States--although not all have established 

harmful populations--and that the overall cost of the harmful species 

is about $137 billion annually.[Footnote 17] However, the estimates 

that these aggregate studies relied on typically did not include an 

analysis of whether control measures are desirable given their costs or 

what the most cost-effective methods for preventing or controlling 

particular invasive species would be. (Many of the estimates included 

in these aggregate studies also lack information on the impact of 

invasive species on natural area ecosystems.):



It is not unusual for analyses to lack information for the assessment 

of the cost-effectiveness of prevention and control measures. The most 

complete data on invasive species damages, and prevention and control 

costs and effectiveness are available for known pests that the USDA has 

identified as serious threats to agriculture on the basis of past 

invasions. These include diseases and pests such as the virus that 

causes foot-and-mouth disease, citrus canker, and the Mediterranean 

fruit fly. Yet, even for these pests, relatively little is known about 

the likely success of alternative methods for preventing their entry or 

controlling their spread. For example, an official in charge of risk 

analysis for USDA’s Animal and Plant Health Inspection Service (APHIS) 

told us that there is a general lack of information on the likely 

success of different measures--short of outright bans on the 

importation of some products--that could be used to prevent the 

importation of invasive species into the country. He said that even for 

a pest such as the one that causes foot-and-mouth disease, for which 

the potential costs of an outbreak have been studied, data are not 

available on the cost-effectiveness of many prevention methods. 

Prevention methods could range from a ban of all products that might 

carry the disease from all countries known to harbor it to less 

stringent restrictions that allow more trade but that might provide 

less protection. For invasive species that have previously entered the 

United States and caused damages, there is also little information 

available on the likelihood that they will do so again at particular 

times and by particular pathways. Even less information of this nature 

is available for non-agricultural pests. More comprehensive analyses 

that include such information may help decision makers allocate limited 

resources among different prevention and control efforts.



A third way in which the narrow scope of many estimates may limit their 

usefulness is that they focus on the impact of species that are known 

to cause problems but do not provide decision makers with information 

on the likelihood that new species will invade and cause damage. The 

typical estimate includes data on the damages already caused by species 

or the money spent to control them. The OTA and Cornell estimates 

mentioned above are largely based on these types of estimates. Other 

examples include USDA’s report that it cost about $26 million between 

1996 and 2000 to remove trees infested with Asian long-horned beetle in 

New York and:



Illinois[Footnote 18] and the estimate by North Dakota State University 

researchers in 1996 that three species of knapweed cause about 

$48 million per year in damage to Montana’s economy.[Footnote 19] Data 

such as these can be used to estimate the continued effects of a 

species in the same location or the potential effects in a new 

location. For example, researchers used data on the effects that the 

European green crab had had on East Coast fisheries to estimate that 

this invasive species could damage native oyster, clam and crab 

fisheries on the West Coast by as much as $54 million per 

year.[Footnote 20] (See fig. 4 for more information on the European 

green crab.):



However, experts in biological invasions caution that it is difficult 

to extrapolate from a past invasion event to introductions of new 

species that have not occurred. According to an official with the 

Department of the Interior, decision makers need guidance on which 

potential invasive species pose the greatest threat to the United 

States and how to best design policies for combating them. Some 

researchers suggest that the best way of protecting ourselves from 

invasive species is to try to predict new arrivals of potentially 

invasive species, study the basic biology of probable new arrivals, and 

work on biological controls for them as part of a program for early 

detection and rapid response.[Footnote 21] One environmental scientist 

has suggested that one of the best ways to predict the introduction of 

and damage from species new to the United States is to study recent 

introductions of species into other countries that have ecosystems 

similar to those in this country.[Footnote 22] While USDA and others 

have done some studies of this type, particularly for agricultural 

pests, the preponderance of economic analysis has focused on species 

that have already invaded the United States rather than on new species 

that could invade in the future.



Figure 4: Profile of the European Green Crab:



[See PDF for image]



[End of figure]



More Comprehensive Analyses Are Potentially More Useful to 

Decision Makers:



While most of the analyses that we reviewed have limitations in their 

scope that lessen their usefulness to decision makers, some used a more 

comprehensive approach. Some analyses accounted more fully for the 

expected costs and benefits to producers and consumers of different 

control measures. For example, to further improve analysis of the 

expected costs and benefits of control measures, the Risk Assessment 

and Management Committee under the Aquatic Nuisance Species Task Force 

expanded the scope of existing federal risk assessment processes and 

methodologies to include the socioeconomic impacts of invasive 

species.[Footnote 23] In a case study covering, in part, the effects of 

importing the Asian black carp, U.S. Geological Survey (USGS) 

researchers balanced the potential for economic gains from 

intentionally introducing this species--it eats snails that may harbor 

parasites in fishponds and zebra mussels in the wild--against the 

potential for economic and environmental damage if it became 

established in the wild.[Footnote 24] Risks were estimated by expert 

judgment. Based upon the outcome of the assessment, the Aquatic 

Nuisance Species Task Force decided that establishment of this species 

would create an unacceptable level of potential harm. The U.S. Fish and 

Wildlife Service has proposed amending its regulations to add the Asian 

black carp to a list of injurious fish, crustacean, and mollusk species 

that are not allowed to be imported into the United States.[Footnote 

25]



Researchers also recently discussed how the benefits from integrating 

risk assessment and benefit cost analysis into the regulatory process 

can provide decision makers with more information than is available 

when only a single dimension of information is considered. These two 

dimensions of information give decision makers an opportunity to 

evaluate the tradeoffs that they face when they choose among 
alternative 

regulatory measures.[Footnote 26] The researchers addressed the 
question of 

the tradeoff between banning the imports of commodities that may harbor 

invasive species and enjoying the benefits of those commodities. As an 

example, they analyzed a partial ban on imports of Mexican avocados and 

found that, based on the assessment of invasion risk alone, the ban 

seemed to have greater benefits than costs.[Footnote 27] However, when 

they incorporated into their analysis the costs to U.S. consumers that 

the ban would impose in terms of reduced availability of low-cost 

avocados, they found that less stringent regulations would likely be 

more desirable than the ban.



As another example, the same researchers demonstrated the benefit of 

integrating benefit cost analysis and risk assessment simultaneously 

into the evaluation of risk management options for the invasive fungus 

that causes Karnal bunt disease in wheat. In this case, they 

illustrated how analyses that estimate invasion risks and costs and 

benefits for control programs for this species but do not adjust 

benefit estimates of the control program components for risk may not 

help decision makers choose control policies with the greatest overall 

benefit. USDA had estimated that the Karnal bunt fungus could cause 

more than $500 million per year in damages to the U.S. wheat industry 

by reducing the amount of wheat suitable for export and had adopted a 

program to control the spread of the fungus.[Footnote 28] However, 

researchers found that the USDA’s estimate was incomplete, in part 

because it focused on reducing the probability of an outbreak of the 

disease by adopting multiple quarantine options but did not examine 

whether each option was an economically efficient quarantine policy. 

When the researchers examined these options individually, they were 

able to identify the most efficient options, that is, those imposing 

the least cost on producers. According to these researchers, by not 

adopting only the most efficient options, the costs of the agency’s 

program for controlling the spread of the fungus exceeded the program’s 

benefit. The researchers suggest that failure to look at the expected 

marginal benefits and costs of various quarantine options may have led 

to the adoption of an unnecessarily costly quarantine policy.



Another way in which some estimates have been more comprehensive is by 

including an examination of the impact of invasive species on more than 

just commercial commodities. For example, in estimating the effect of 

gypsy moth caterpillars on forest trees, researchers estimated that 

benefits from programs that would slow their spread would be between 

$1 billion and $4.8 billion in present value, depending on their rate 

of spread and the control programs adopted, in increased timber 

production, recreational opportunities, residential and scenic land 

values, water quality and other amenities, over 25 years.[Footnote 29] 

In another example, researchers used an economic model based on 

property values to estimate damages to lakefront properties in New 

Hampshire from milfoil, an invasive aquatic weed that causes serious 

economic, recreational, and ecological damage. Their estimates showed 

that between 1990 and 1995, property values on milfoil-infested lakes 

were about 16 percent lower than similar properties on uninfested 

lakes.[Footnote 30] According to an official with the Department of 

Commerce, the state of New Hampshire adopted a program to control this 

invasive weed on the basis of this study.



Finally, some analysts are taking more comprehensive approaches 

by analyzing the likelihood that species will be introduced, become 

established, and cause harm in particular geographic areas or via 

particular pathways. For example, a researcher has built upon earlier 

USDA work on pest risk assessment to evaluate the likelihood of 

establishment of Eurasian poplar leaf rust.[Footnote 31] The researcher 

combined information on the incidence of the disease and the location 

of susceptible plant hosts in the United States with data on past 

invasions of this species in similar ecosystems abroad, to assess the 

likely danger to geographic areas in the United States.



In another example, USDA examined the likelihood that the Eurasian 

pine shoot beetle would enter and spread via various pathways and which 

pathways would impose the greatest risk of harm.[Footnote 32] This 

beetle emerged as a new and potentially serious pest of timber in the 

upper midwestern United States in 1992. Potential losses from the 

beetle were large, and the state of Michigan proposed 25 mitigation 

measures that would have included large expenditures on pesticide 

sprays. USDA’s analysis, which included a risk assessment of the likely 

pathways by which the beetle might spread, showed that 99.8 percent of 

the risk of spread occurred by one pathway in a 2-week period during 

the timber’s processing. Using this information, the timber industry 

took appropriate control measures during this 2-week period to 

effectively manage the risk at low cost and without the need 

for regulation.



Recent Actions May Prompt More Comprehensive Analyses:



Recent federal actions may help to prompt further improvements in the 

economic impact analysis available to decision makers. Among other 

things, Executive Order 13112 calls on federal agencies to prevent the 

introduction of invasive species, and to detect, respond rapidly to, 

and control them in a cost-effective and environmentally sound manner. 

The executive order also directs agencies to determine that the 

benefits of any actions they take that are likely to cause or promote 

the introduction or spread of invasive species clearly outweigh the 

potential harm caused by the species and to take measures to minimize 

the risk of harm in conjunction with these actions. Implementing the 

order will thus require agencies to undertake more comprehensive 

studies of risks, costs, and benefits.



In addition, the federal Aquatic Nuisance Species Task Force has 

developed a process to evaluate the risk of introducing nonnative 

organisms into a new environment and, if needed, determine the correct:



management steps to mitigate that risk.[Footnote 33] The task force has 

also developed guidelines to provide direction to assist states in the 

development of their own management plans for aquatic nuisance 

species.[Footnote 34] The guidance, formally adopted by the task force 

in 2000, emphasizes a need for feasible, cost-effective, comprehensive 

plans that can be developed quickly, and can be used to focus on the 

most pressing species problems that can be effectively managed. As an 

example of how these efforts have been used, the U.S. Fish and Wildlife 

Service, USDA’s Animal and Plant Health Inspection Service, and the 

National Oceanic and Atmospheric Administration, in conjunction with 

state authorities, have prevented the spread of the aquatic weed 

caulerpa in U.S. coastal waters.[Footnote 35]



USDA has also taken recent steps to refine its risk assessment 

practices. Over the years, in making decisions about allowing the 

importation of certain agricultural commodities from countries known to 

harbor potentially serious plant pests, USDA occasionally used analysis 

that led to partial rather than outright bans of those commodities in 

recognition of both risks of invasion and the benefits that consumers 

would obtain from access to that commodity.[Footnote 36] An impetus for 

doing more of this type of analysis was international trade agreements 
that 

call for the United States and others to use the least restrictive 
measures 

to protect against invasive pests. In other words, the trade agreements 

prohibit countries from imposing outright bans of certain agricultural 

commodities if biological and economic data show that partial bans 

would be just as effective. Partly in response to these agreements, 

USDA’s Animal and Plant Health Inspection Service issued for the first 

time in August 2001 guidelines for the agency to use when assessing the 

risks posed by diseases and pests.[Footnote 37] These guidelines state 

that risk assessments should consider the probable biological and 

economic consequences of the entry and establishment of invasive 

species, as well as the likelihood that those species will enter. 

However, according to the chief of APHIS Risk Assessment Systems, 

agency assessments done in the past frequently focused on the 

likelihood that species will enter and become established and, because 

of a lack of credible data, were less focused on their biological and 

economic consequences.



Moreover, USDA recently established a task team to improve the ways in 

which risk assessment is incorporated into the department’s analyses of 

the economic impacts of invasive species. Agency officials said that 

this effort would better enable federal decision makers to adhere to 

Executive Order 13112’s emphasis on a risk-based approach to dealing 

with invasive species. In addition, the officials said that the 

information generated by the task team would also help the National 

Invasive Species Council implement the national management plan, which 

calls for a risk-based approach to preventing potential invasive 

species from becoming established.[Footnote 38]



Officials from the National Invasive Species Council staff and 

departments within the council agreed that improved economic analysis 

would help the federal government develop an overall budget for 

invasive species programs. However, they cautioned that the capacity of 

the federal government to do this work is limited. Specifically, there 

are limits to the data available on the biology of invasive species and 

the impacts they have--particularly on natural ecosystems--and the 

effectiveness of control methods. The officials also stated that there 

are not enough resources devoted to analyzing the impacts of 

invasive species.



The National Management Plan Lacks a Clear Long-Term Outcome, and Its 

Implementation Has Been Slow:



While the National Invasive Species Council’s 2001 management plan, 

Meeting the Invasive Species Challenge, calls for actions that are 

likely to help control invasive species, it lacks a clear long-term 

outcome and quantifiable performance criteria against which to evaluate 

the overall success of the plan. Federal officials recognize that there 

are deficiencies in the plan and are working toward improving it. At 

present, however, the only available performance measure that can be 

used to assess overall progress is the percentage of planned actions 

that have been completed by the due dates set in the plan. By this 

measure, implementation has been slow. Specifically, the council 

departments have completed less than 20 percent of the planned actions 

that were called for by September 2002, although they have begun work 

on others. A large majority of the members of the invasive species 

advisory committee who responded to our survey believe that the pace of 

implementation is inadequate. In addition, some of the actions that 

agencies have reported to the council are not clearly linked to 

coordinated implementation of the management plan. Our survey and other 

evidence indicate numerous reasons for the slow progress, including 

delays in establishing implementation teams that will be responsible 

for carrying out the planned actions, the low priority given to 

implementation by the council, and the lack of funding and shortage of 

staff responsible for doing the work. Another factor contributing to 

slow progress was the need to transition to a new administration. 

However, while the national management plan calls for many actions that 

would likely contribute to preventing and controlling invasive species, 

even if the actions in the plan were more fully implemented their 

effect would be uncertain because they typically do not call for 

quantifiable improvements in invasive species management or control.



National Invasive Species Management Plan Does Not Clearly Define a 

Long-Term Outcome or Contain Performance Measures:



The national management plan does not clearly define a long-term 

outcome or measures of success as are called for by sound management 

principles. The executive order states that the management plan shall 

“detail and recommend performance-oriented goals and objectives and 

specific measures of success for federal agency efforts concerning 

invasive species.” Consistent with that requirement, the council and 

its advisory committee adopted as one of their guiding principles that 

efforts to manage invasive species are most effective when they have 

goals and objectives that are clearly defined and prioritized. Both the 

executive order and this guiding principle are also consistent with the 

Government Performance and Results Act of 1993, which emphasizes 

setting measurable goals and holding agencies accountable by evaluating 

performance against those goals.[Footnote 39]



However, the council did not articulate in the plan a long-term outcome 

or condition toward which the federal government should strive. For 

example, the plan does not contain overall performance-oriented goals 

and objectives, such as reducing the introduction of new species by a 

certain percentage or halting the spread of established species on 

public lands. Instead, the plan contains an extensive list of actions 

that, while likely to contribute to preventing and controlling invasive 

species, are not clearly part of a comprehensive strategy.



Similarly, many of the actions in the plan call for the federal 

departments to take certain steps rather than achieve specific results 

and do not have measurable outcomes. For example, the plan calls for 

the council, starting in January 2001, to work with relevant 

organizations to “expand opportunities to share information, 

technologies, and technical capacity on the control and management of 

invasive species with other countries.” Another action item calls for 

the council to have outlined by June 2001 a plan for a campaign to 

encourage U.S. travelers to voluntarily reduce the risk of spreading 

invasive species overseas. Other actions call for the council to 

support international conferences and seminars. We believe that these 

types of actions are more process-oriented than outcome-oriented. Taken 

individually, the actions may be useful, but it will be difficult to 

judge whether or not they are successful and have contributed to an 

overall goal.



Respondents to our survey also raised concerns about the lack of 

measurability in the plan. While the majority of respondents (17 of 23) 

said that the plan is focused on the most important issues, 9 

criticized it for a lack of specificity or a clear mechanism for 

measuring effectiveness or holding departments accountable for 

implementing it. Of these, several commented that it is unclear how we 

will know when actions are implemented and completed. Others noted that 

there are no consequences for the council, staff, or agencies if they 

miss deadlines. Other stakeholders made similar comments to us. For 

example, one person who was involved in the development of the 

management plan told us that it represents a “fundamentally misguided 

approach” and that it contains no coherent goal or measures of success. 

He said that the plan should have measures of success such as a 

reduction in the rate of introduction or spread of species. Another 

stakeholder said that the plan is unclear with regard to what actions 

would be enough to help solve the problem and echoed concerns about the 

difficulty measuring success. Eight respondents to our survey, however, 

made more positive comments about the degree of specificity in the 

plan, stating that the plan was clear, measurable, and achievable and 

that it had very specific actions with deadlines for agencies 

to implement.



The council acknowledged in the plan itself that many of the details 

of the actions called for would require further development in the 

implementation phase. The Department of the Interior’s Deputy Assistant 

Secretary for Performance and Management told us that the plan was 

developed with little input from people trained in performance 

management processes. In addition, the Executive Director of the 

council staff told us that, in her opinion, given the scope of this 

first-time effort, it would have been unrealistic and difficult to also 

agree on specific measurable goals. She also said that in many areas, 

the federal government does not have the data on invasive species 

conditions needed to set long-term goals and develop better performance 

measures. She said that many of the actions called for in the 

management plan are designed to help develop needed data. In their 

comments on our draft report, EPA and the Department of the Interior 

also noted that it would be difficult to apply performance measures to 

invasive species management activities.



The executive order calls for the council to revise the plan by January 

2003. However, the Executive Director of the council told us that the 

council and the advisory committee had agreed not to begin revising the 

management plan until after the council prepares a progress report on 

the plan. That report is also due to the Office of Management and 

Budget (OMB) in January 2003.



The council is in the process of working with OMB on implementing one 

of the planned actions that should help to establish a desired outcome 

and relevant performance measures. The plan called for a crosscut 

budget proposal for federal agency expenditures concerning invasive 

species beginning in fiscal year 2003. The council and OMB are hoping 

to have a proposal ready for the fiscal year 2004 budget cycle. 

According to the Department of the Interior official responsible for 

this project on behalf of the council, the proposal will represent the 

beginnings of a strategic plan for the federal government’s invasive 

species activities. It will be performance-oriented with common long-

term goals, intermediate goals, and definitions for the relevant 

departments. OMB will identify performance measures with help from a 

task team of federal stakeholders and will initially focus on early 

detection and rapid response, control, and prevention. According to the 

council, the proposal for fiscal year 2004 will not represent the 

totality of invasive species expenditures or efforts but will primarily 

focus on the activities of the Departments of the Interior, 

Agriculture, and Commerce.



National Invasive Species Council Departments Have Completed a 

Small Percentage of Actions in the Management Plan:



While the council has not reported on implementation of the plan, we 

estimate that, as of September 2002, council departments had completed 

less than 20 percent of the actions that the plan had called for by 

that date. The departments have started work on other planned actions, 

including some that have a deadline after September 2002 and that the 

council believes are a high priority. When asked to assess 

implementation of the plan, 18 of the 21 advisory committee members who 

responded to that question said that the council was making inadequate 

or very inadequate progress. Survey comments and other evidence 

indicate various reasons for the lack of progress. Delays in 

implementing the plan will hamper agency efforts to prevent and control 

invasive species as intended by the executive order.



Lack of Departmental Reporting Hinders Measurement of Progress:



It has been difficult to quantitatively measure the council’s progress 

in implementing the management plan because only 6 of the 10 member 

departments had submitted reports summarizing the steps they had taken 

to implement the plan. The plan calls for departments to submit such 

reports annually beginning in October 2001. Council staff aggregated 

the reports that were submitted into one summary of activities. These 

annual reports would be used to carry out yet another requirement of 

the executive order and management plan that calls for the council to 

revise the plan by January 2003.



Several survey respondents commented that it was difficult for them to 

evaluate the council’s progress in implementing the plan because 

information from the council had been inadequate. For example, some 

respondents wrote that the level of interaction between them and the 

council was not sufficient, and that feedback to the advisory committee 

from the council on implementation progress has been poor.



The management plan also calls for the council to establish a 

“transparent oversight mechanism” that engages public involvement. The 

purpose of the oversight mechanism would be for use by federal agencies 

in complying with the executive order and reporting on its 

implementation, which includes the management plan. The plan called for 

the mechanism to be in place by April 2001, but according to the 

council staff, work has not yet begun.



The Council Has Completed Less Than 20 Percent of Planned Actions:



Our review of the council’s summary of department actions, which 

focused on the 65 planned actions with due dates through September 2002 

(an additional 21 planned actions have due dates after September 2002, 

for a total of 86), revealed that less than 20 percent of the actions 

due by September 2002 were complete.[Footnote 40] Several actions 

completed on time related to the development of the council’s Web site, 

which is found at www.invasivespecies.gov. Another completed action 

concerned a series of regional workshops on invasive species for 

policymakers that the council, led by the Department of State, cohosted 

with countries such as Brazil, Costa Rica, Denmark, Thailand, and 

Zambia. Also in accord with the plan, the National Oceanic and 

Atmospheric Administration, the Coast Guard, the Department of the 

Interior, and EPA have sponsored research related to ballast 

water management.



Departments and the council staff have also started work on over 

60 percent of the other planned actions, including some that have a due 

date beyond September 2002. For example, departmental representatives 

and the council staff are working with the President’s Council on 

Environmental Quality on guidance to federal agencies on how to 

consider the issue of invasive species as they prepare analyses 

required by the National Environmental Policy Act. However, the 

guidance is not expected to be ready until early 2003, past its 

August 2001 target date. USDA has begun work on additional regulations 

to further reduce the risk of species introductions via solid wood 

packing materials, but the department did not meet the management 

plan’s January 2002 deadline. (See fig. 5 for information on the Asian 

long-horned beetle, an invasive species that entered the United States 

in solid wood packing material.) Council departments have begun work on 

a national public awareness campaign--cataloging existing public 

awareness programs and conducting a survey of public attitudes toward 

invasive species--and are seeking budget approval for starting the 

campaign in fiscal year 2004. They missed the June 2002 completion date 

called for in the plan. Among those actions that the council is working 

on that are not due until after September 2002 is a risk-based 

comprehensive screening system for evaluating first-time intentionally 

introduced nonnative species, which is due by December 2003. According 

to council staff, the complexities of implementing a screening system 

dictate that the departments work on this now. According to council 

staff, work is also underway on a coordinated rapid response program 

due by July 2003.



Figure 5: Profile of the Asian Long-Horned Beetle:



[See PDF for image]



[End of figure]



There are also actions in the plan that the council has not started to 

work on. For example, the council has not acted on the item in the plan 

that called for draft legislation by January 2002 to authorize tax 

incentives and otherwise encourage participation of private landowners 

in restoration programs. Nor has the council moved to ensure that a 

clearly defined process and procedures be in place by July 2001 to help 

resolve jurisdictional and other disputes regarding invasive species 

issues. Two respondents to our survey commented on the lack of council 

progress toward a resolution process, citing the need for it in cases 

such as one where federal agencies are taking contradictory actions 

with respect to an invasive rangeland grass (see fig. 6 for more on 

buffelgrass). In its comments on our draft report, EPA emphasized the 

significance of this deficiency and noted that there are other 

situations where a resolution process is needed, such as fish stocking 

to enhance recreational fisheries and using genetically modified 

organisms in aquaculture and agriculture.



Figure 6: Profile of Buffelgrass:



[See PDF for image]



[End of figure]



The majority of the advisory committee members responding to our survey 

noted the lack of progress made by the council agencies. Eighteen of 

the 21 members who responded to a question about implementation said 

that that the council was making inadequate or very inadequate 

progress. One noted that the only clear achievement to date is the 

council’s Web site.



Some of the Agencies’ Actions Are Not Clearly Linked to Coordinated 

Implementation of the Management Plan:



In our view, while it is apparent that the agencies are taking various 

actions to address invasive species issues, the actions the agencies 

have reported to the council often do not represent coordinated 

progress toward implementation of the plan or management of the 

problem. The executive order and the management plan both emphasized 

the need for coordination among agencies. As evidence of that emphasis, 

a majority of the actions in the management plan are to be carried out 

by multiple agencies. However, the actions that the agencies reported 

to the council often did not appear to be directly linked to each other 

or be directly responsive to the specific actions called for by the 

management plan. In our survey, several advisory committee members also 

commented that coordination has been inadequate.



For example, the management plan called for the council to implement by 

January 2002 a process for identifying high-priority invasive species 

that are likely to be introduced unintentionally and for which 

effective mitigation tools are necessary. One agency noted to the 

council that it had contracted with professional societies to provide a 

list of the most harmful insect, weed, and disease plant pests that are 

not yet present in the country or present but not widely distributed. 

It also noted that it has a risk assessment procedure for identifying 

pests that may be introduced with commodities such as agricultural 

products. A second agency noted that it had held a workshop to identify 

potentially invasive species that might enter the nation’s waters from 

Eastern Europe. A third agency indicated that it is providing training 

for firefighters to reduce the spread of weeds from one fire site to 

another. While these activities are related to the planned action, they 

do not indicate that the agencies are working together through the 

council to implement a process for identifying high priority species as 

called for by the plan.



The Executive Director of the council acknowledged that some of the 

actions reported by agencies did not seem to directly link to the 

management plan, although such information was useful for overall 

coordination purposes. She said that in the future implementation teams 

would help the agencies focus on those actions that are directly linked 

to the management plan. The Executive Director and one of the Assistant 

Directors of the council told us that they believe that increased 

coordination has been an important accomplishment and that agency 

officials are now routinely talking with each other about invasive 

species management issues. In comments on our draft report, the 

Department of the Interior also noted that coordination and 

communication among the agencies has increased.



Slow Progress on Management Plan Is Due to a Combination of Factors:



Our survey and other evidence indicate that the slow progress in 

implementing the management plan has been caused by a combination of 

factors, including delays in forming teams responsible for developing 

specific implementation plans, the lack of priority given to the plan 

by the council as a whole and by the departments individually, and 

insufficient funding specifically targeted to support the plan. 

Progress was also slowed by the need to transition from the previous 

administration to the current administration.



Delays Forming Implementation Teams:



In October 2000, before issuing the management plan, the advisory 

committee and council staff agreed that implementation teams made up of 

federal and nonfederal stakeholders were needed to put the management 

plan into action. The advisory committee members and council staff 

agreed that the teams should be under the auspices of the advisory 

committee and be closely aligned to the major sections of the 

management plan. Specifically, the teams would be responsible for 

“delivery” of the planned actions. For example, a prevention team would 

be responsible for guiding implementation of the actions relevant to 

prevention. However, for various reasons, most implementation teams 

were not formed until June 2002. Specifically:



* The Executive Director of the council told us that she did not 

believe it would have been appropriate to form the implementation teams 

until after the management plan was issued in January 2001.



* The change in administration then delayed action on implementing the 

plan by about 6 months because it took time for cabinet secretaries--

the members of the council--and other political appointees to be 

nominated and confirmed; departments were ready to move forward with 

forming the implementation teams in the fall of 2001.



* By that time, the first term of all of the advisory committee members 

was approaching its end in November 2001 and because the advisory 

committee members were to be an integral part of the implementation 

teams, the Executive Director told us it did not make sense to form the 

teams until the next advisory committee was convened.



* Appointment of the second set of advisory committee members was 

delayed until April 2002 for a number of reasons, including the 

temporary loss of e-mail and regular mail delivery at the Department of 

the Interior.[Footnote 41]



* The second advisory committee held its first meeting in May 2002, and 

committee members and council staff decided that the implementation 

teams should not meet until after the advisory committee members had a 

chance to review the teams’ responsibilities and membership and discuss 

them at greater length at their next scheduled meeting in June 2002.



* In June 2002, nine implementation teams were created that largely 

mirror sections of the management plan (all but two of the teams will 

comprise federal and nonfederal members).



The Executive Director of the council told us the decision to create 

implementation teams of federal and nonfederal members under the 

auspices of the advisory committee was in part in recognition of the 

importance of getting consensus from key stakeholders early in the 

implementation process. She told us that she recognizes that there are 

potential problems with the teams comprising a disparate group of 

federal and nonfederal stakeholders. Specifically, logistical problems 

in getting the teams together and disputes within the teams could delay 

the federal departments in taking action to implement the plan. She 

said that the council would have to monitor the teams closely to 

determine whether or not they are effective.



The delay in establishing the implementation teams has hindered the 

agencies in achieving an important objective of both the executive 

order and the management plan--coordinated action. Several respondents 

to our survey commented that they had not seen adequate increases in 

the amount of coordination, and some pointed to the delays in forming 

the teams as a cause. One respondent thought that federal departments 

and agencies were continuing to pursue their own mandates and programs 

with only a cursory regard for the framework and coordination that the 

council attempts to provide. The Executive Director of the council told 

us that she expected coordination to improve as the implementation 

teams become established.



In our view, the relationship of the advisory committee to the 

implementation teams has slowed progress on the plan and could continue 

to do so. While we understand why the council decided to form the 

implementation teams under the auspices of the advisory committee--to 

foster consensus among key stakeholders early in the implementation 

process--we believe that this decision may slow federal action. 

Specifically, it may be difficult for teams of federal and nonfederal 

stakeholders to put forth the concerted effort needed to implement the 

management plan. We are also concerned that it will be difficult to 

hold the departments accountable for carrying out the plan if they are 

relying upon the actions of teams with federal and nonfederal members.



Lack of Priority from the Council and Its Member Departments:



About one-half of the respondents to our survey criticized the council 

and the departments for not giving the plan a higher priority. For 

example, several noted that it did not appear that the council had 

positioned itself to take a leadership role in implementing the plan or 

that the plan was not a high priority on the agendas of the leaders of 

the council’s member departments. In addition, numerous survey 

respondents said that the individual departments needed to give the 

plan higher priority by providing better support in staff 

and resources.



Our review of agencies’ performance plans (prepared pursuant to the 

Government Performance and Results Act) also indicates that 

implementing the management plan is not a high priority for individual 

agencies. We reviewed the performance plans of the three cochair 

departments on the council (the departments of Agriculture, Commerce, 

and the Interior), as well as those of the Department of 

Transportation, the Environmental Protection Agency, and agencies 

within the Department of the Interior (National Park Service, Bureau of 

Land Management, Fish and Wildlife Service, and Geological Survey). 

While most of the agencies’ performance plans describe activities 

intended to control or manage invasive species--and are therefore 

consistent with the national management plan--none of the plans 

specifically identified as a measure of performance implementing 

actions called for by the council’s plan. As one official from the 

Environmental Protection Agency told us, activities that are not in the 

agency’s performance plan do not receive a high priority. Nevertheless, 

the Department of the Interior official responsible for pulling 

together the crosscut budget for invasive species programs told us that 

he believes that process--because of its emphasis on performance 

measures--will help departments link the management plan to their 

performance plans.



With regard to the notion that the council was not giving the plan a 

high priority, three of the 23 advisory committee members who responded 

to our survey commented on the absence of specific legislative 

authority establishing the council. One stated “the council needs to be 

approved legislatively so that they are their own entity with better 

options to act.” Another said “Congress or the President needs to make 

this a priority through legislation or funding. . . . Agencies need to 

be told this is a priority and given funding to accomplish their 

goals.” Because executive orders such as the one that established the 

council do not provide any additional authority to agencies, the 

Executive Director of the council noted that legislative authority for 

the council, depending on how it was structured, could be useful in 

implementing the management plan. Officials from USDA, the Department 

of Defense, and EPA who are departmental liaisons to the council also 

told us that legislative authority, if properly written, would make it 

easier for council departments to implement the management plan. The 

Congress has recently considered legislation that would give the 

council certain responsibilities; namely to provide input into 

decisions about allocating funds to local governments and other 

organizations for controlling invasive plants. However, the Executive 

Director of the council told us that such a requirement would be 

unworkable if the legislation did not also formally establish the 

council and a future administration decided to discontinue the 

executive order that created the council.



The management plan calls for the council to conduct an evaluation by 

January 2002 of the current legal authorities relevant to invasive 

species. The council has not completed the evaluation. According to the 

plan, the evaluation is to include an analysis of whether and how 

existing authorities may be better utilized and could be used to 

develop recommendations for changes in legal authority. However, it 

does not state that the analysis should address whether the council 

itself is hampered in its mission by not having specific legislative 

authority that would allow it to direct its members to implement the 

national management plan.



Insufficient Funding and Staff:



In the management plan, the council stated that many of the actions 

could be completed or at least initiated with current resources but 

that without significant additional resources for existing and new 

programs it would not be possible to accomplish the goals of the plan 

within the specified timeframes. The council also noted in its comments 

on the draft report that it believes the timeframes in the plan are 

optimistic given current resources. Two of the actions in the plan 

called for federal agencies to request additional funding for separate 

management functions through the annual appropriations process 

beginning in fiscal year 2003. According to a summary prepared by the 

council, the President’s budget request for invasive species activities 

in fiscal year 2003 was at least 23 percent more than was requested in 

fiscal year 2002 (although slightly less than Congress appropriated in 

fiscal year 2002).[Footnote 42] The council went on to say in the plan 

that estimates of the additional support required would depend on the 

details of implementation schedules developed by federal agencies and 

stakeholders. As we described above, however, the council and the 

advisory committee have only recently created the teams that will be 

responsible for working out the detailed plans for implementation. 

Therefore, it is unclear what additional resources are needed and 

whether the requested appropriations will be adequate to implement 

the plan.



In response to several of the questions in our survey, advisory 

committee members cited the lack of funding as a key reason for 

poor implementation of the council’s management plan. (We did not 

independently assess the adequacy of funding.) Of the 18 who said that 

the council was inadequately implementing the plan, 9 said that funding 

was insufficient. A typical comment was that the council members need 

to make a better case to get Congress to support funding for an 

invasive species line item. Over 70 percent of the respondents to 

another question said that they knew of instances where federal 

agencies do not have the resources to carry out actions in the national 

management plan. While several respondents gave details on specific 

examples of where they believe federal agencies have underfunded 

invasive species programs, four others said that none of the agencies 

have the resources to implement the management plan in its entirety.



In addition, 19 of the 21 respondents to one question said that the 

council had inadequate staff resources to serve the needs of the 

council. (The council has had a staff of five to seven people in the 

last 2 years.) One respondent said that the “level of funding now is 

token only and serves to support the most minimal staffing one can 

imagine for a national effort of this scale. It’s embarrassing.” Many 

of the respondents said that the council’s staff are working hard and 

doing the best that they can. However, respondents also commented that 

the staff is overwhelmed, faced with substantial obstacles, and is not 

sufficient to support both the council and advisory committee. Several 

respondents emphasized that the council staff should be larger to more 

effectively push for implementation of the management plan.



Transition to New Administration:



Finally, the Executive Director of the council staff told us that, in 

her opinion, progress on the management plan was slowed by the 

transition to a new administration. High-level political appointments 

are often vacant for months during the transition from one 

administration to another. A senior official from the Department of the 

Interior pointed out in July 2002 that many key managers relevant to 

the crosscutting budget proposal had been in office only a few months 

because of the time required to nominate and approve 

political appointees.



The Current Regulations Concerning Ballast Water Management Are Not 

Keeping Invasive Species Out of the Great Lakes:



According to experts and agency officials we consulted, current efforts 

by the United States and Canada are not adequate to prevent the 

introduction of nonnative aquatic organisms into the Great Lakes via 

ballast water of ships, and they need to be improved. Compliance with 

regulations is high but nonnative aquatic organisms are still entering 

and establishing themselves in the Great Lakes ecosystem. U.S. and 

Canadian agency officials believe that they should do more to protect 

the Great Lakes from ballast water discharges. However, several time-

intensive steps must be taken before the world’s commercial fleet is 

equipped with effective treatment technologies. In the meantime, the 

continued introduction of nonnative aquatic organisms could have a 

major economic and ecological impact on the Great Lakes.



Compliance with U.S. Regulations Is High, but Nonnative Aquatic 

Organisms Are Still Entering the Great Lakes:



Since 1993, U.S. regulations have governed how vessels entering the 

Great Lakes from outside the Exclusive Economic Zone, a zone extending 

200 nautical miles from the shore, must manage their ballast 

water.[Footnote 43] To be allowed to discharge ballast water into the 

Great Lakes, ships must exchange their ballast water before entering 

the zone and in water deeper than 2,000 meters.[Footnote 44] Exchanging 

ballast water before arriving in the Great Lakes is intended to serve 

two purposes: to flush aquatic organisms taken on in foreign ports from 

the ballast tanks and to kill with salt water any remaining organisms 

that happen to require fresh or brackish water. If a ship bound for the 

Great Lakes has not exchanged its ballast water in the open ocean it 

may hold the ballast in its tanks for the duration of the voyage 

through the lakes. Under some circumstances--such as bad weather making 

an open-ocean exchange unsafe--the Coast Guard may approve a ship 

master’s request to do the exchange in an alternative exchange zone in 

the Gulf of St. Lawrence.



The U.S. Coast Guard, the Saint Lawrence Seaway Development 

Corporation, and the Canadian St. Lawrence Seaway Management 

Corporation inspect ships as they enter and travel through the St. 

Lawrence Seaway. The Coast Guard also inspects ships at U.S. ports 

throughout the Great Lakes. Data from the Coast Guard show that 

the percentage of ships entering the Great Lakes after exchanging their 

ballast water has steadily increased since the regulations took effect 

in 1993 and averaged over 93 percent from 1998 through 2001. (See 

fig. 7.) Representatives of the Coast Guard and the seaway corporations 

told us that the high exchange rate indicates that the current 

regulations for the Great Lakes are being effectively 
enforced.[Footnote 45] 

Experts have concluded, however, that numerous nonnative aquatic 
organisms have 

entered the Great Lakes via ballast water and established populations 
since the 

regulations were promulgated. (See fig. 8.) Two such species are the 
fish-hook 

water flea (Cercopagis pengoi), discovered in 1998, and an amphipod (a 

small crustacean) known as Echigogammarus ischnus, discovered 

in 1995.[Footnote 46]



Figure 7: Rates of Compliance with Ballast Water Exchange Requirement 

for Ships Entering the Great Lakes, 1992-2001:



[See PDF for image]



[End of figure]



Figure 8: Discovery of Nonnative Aquatic Species Introduced into the 

Great Lakes and Major Legislation and Regulatory Decisions, 1985-2002:



[See PDF for image]



[End of figure]



Experts have cited several reasons for the continued introductions of 

nonnative aquatic organisms into the Great Lakes despite the ballast 

water regulations. First, the Coast Guard has not applied the ballast 

water exchange regulations to ships with little or no pumpable ballast 

water in their tanks; approximately 70 percent of ships entering the 

Great Lakes during 1999 through 2001 were in this category. These 

ships, however, may still have thousands of gallons of residual ballast 

and sediment in their tanks. This could harbor potentially invasive 

organisms from previous ports of call and could be discharged to the 

Great Lakes during subsequent ballast discharges.



Second, there are also concerns that exchanging a particular percentage 

of ballast water does not remove an equivalent percentage of organisms 

from the tank. The Environmental Protection Agency and the Aquatic 

Nuisance Species Task Force reported that ballast water exchange with 

open-ocean water flushed 25 to 90 percent and 39 to 99.9 percent, 

respectively, of the organisms studied. Researchers explain this range 

by pointing out that organisms in sediment at the bottom of the tanks 

may not be flushed out by an exchange.



Third, there is some uncertainty regarding what percentage of the water 

in the tanks is actually flushed out during a typical ballast water 

exchange. When determining whether tanks have been flushed and refilled 

in the open ocean, the Coast Guard tests the new ballast water to see 

if it has a salt concentration of at least 30 parts per 

thousand.[Footnote 47] However, given uncertainties about the salinity 

of a ship’s original ballast water and evaporative losses that occur 

during transit, it is not clear from a basic salinity test 

what percentage of the original ballast water--and the potentially 

invasive aquatic organisms it may contain--has been removed.



Fourth, there is growing concern that freshwater organisms may be able 

to survive the saline environment created by mid-ocean exchange. 

Certain organisms have a stage in their life cycle during which they 

are “resting eggs” or “cysts” and may be tolerant of salt water. Once 

discharged into the Great Lakes freshwater system, these organisms can 

regain viability. There are also examples of species--including 

alewives and the sea lamprey--that normally spend part of their lives 

in salt water and part in freshwater, but have been able to thrive 

despite being “locked” into the freshwater of the Great Lakes.



In an effort to reduce the further introduction of nonnative species, 

the Saint Lawrence Seaway Development Corporation and its Canadian 

counterpart, the St. Lawrence Seaway Management Corporation, amended 

their joint regulations in February 2002 to require all commercial 

ships entering the Seaway system to comply with Great Lakes shipping 

industry codes for ballast water management.[Footnote 48] These codes 

contain “best management practices” that are intended to reduce the 

number of organisms in ballast tanks. Such practices include not taking 

on ballast at night--when marine organisms are more likely to be near 

the surface--and regularly cleaning tanks.



Regulatory Decisions, Technological Developments, and Ship 

Modifications Needed to Significantly Reduce Ballast Water Invasions 

Will Take Many Years:



According to experts we consulted, it will take many years to solve the 

problem of nonnative aquatic organisms arriving in ballast water. The 

Coast Guard is now working to develop new regulations that would 

include a performance standard for ballast water--that is, a 

measurement of how “clean” ballast water should be before discharge 

within U.S. waters. In May 2001, the Coast Guard requested comments on 

how to establish a ballast water treatment standard and offered for 

consideration four conceptual approaches. The agency received numerous 

comments showing a wide range of opinion. As a result, it issued an 

advanced notice of proposed rulemaking and another request for comments 

in March 2002 on the development of a ballast water treatment goal and 

an interim ballast water treatment standard. The Coast Guard is 

expecting to have a final rule ready for interdepartmental review by 

the fall of 2004 that will contain ballast water treatment goals and a 

standard that would apply not only to ships entering the Great Lakes 

but also to all ships entering U.S. ports from outside the Exclusive 

Economic Zone.



Once the Coast Guard sets a new performance standard for how clean 

ballast water should be, firms and other entities will have a goal to 

use as the basis for developing and measuring treatment technologies. 

Government, industry, academia, and other nongovernment interests are 

investigating several technologies, including filtration, 

hydrocyclonic separation, and chemical and physical biocides such as 

ozone, chlorination, ultraviolet radiation, heat treatment, and vacuum. 

Each technology has its strengths and weaknesses. One major hurdle 

facing any technological solution is how to treat large volumes of 

water being pumped at very high flow rates. Container vessels and 

cruise ships, which carry a smaller volume of ballast water, may 

require different technologies than larger container vessels. As a 

result, it is likely that no single technology will address the problem 

adequately. To facilitate technology development, the Coast Guard and 

the Department of Transportation’s Maritime Administration are 

developing programs to provide incentives for ship owners to actively 

participate in projects designed to test treatment technologies.



To help with technology development, the National Invasive Species Act 

created a ballast water demonstration program that funds select 

proposals to develop and demonstrate new ballast water technologies. 

Under this program, the National Oceanic and Atmospheric Administration 

and the U.S. Fish and Wildlife Service have funded 20 ballast water 

technology demonstration projects at a total cost of $3.5 million since 

1998. Other programs also support research, such as the National Sea 

Grant College Program, which has funded nine projects totaling 

$1.5 million. In addition, the National Oceanic and Atmospheric 

Administration, through the National Sea Grant College Program, and the 

U.S. Fish and Wildlife Service announced on June 6, 2002, that they 

expect to make $2.1 million available in fiscal year 2002 to support 

projects to improve ballast water treatment and management. In 

conjunction with this program, the Department of Transportation’s 

Maritime Administration expects to make available several ships of its 

Ready Reserve Force Fleet to act as test platforms for ballast water 

technology demonstration projects. In fiscal years 2001 and 2002, 

Congress appropriated $550,000 to the Coast Guard for research and 

development related to ballast water management. In addition, EPA and 

the Coast Guard expect to contribute $210,000 to fund a 3-year study on 

the transfer of aquatic organisms in ballast water. Nonfederal 

researchers in industry and academia are also studying the content of 

ballast water and prospective treatment technologies. For example, a 

Canadian shipping company funded the installation of a treatment system 

on one of its ocean-going ships and allowed the Michigan Department of 

Environmental Quality to perform testing on the system.



Once effective technologies are developed, another hurdle will be 

installing the technologies on the world fleet.[Footnote 49] New ships 

can be designed to incorporate a treatment system. Existing ships, on 

the other hand, were not designed to carry ballast water technologies 

and may have to go through an expensive retrofitting process. With each 

passing year without an effective technology, every new ship put into 

service is one more that may need to be retrofitted in the future.



Public and private interests in the Great Lakes have expressed 

dissatisfaction with the progress in developing a solution to the 

problem of nonnative aquatic organism transfers through ballast water. 

An industry representative told us that she and other stakeholders were 

frustrated with the Coast Guard’s decision to make a second request for 

public comment on a treatment standard; she said they were anticipating 

that the agency would publish a proposal rather than another request 

for information. More broadly, in a July 6, 2001, letter to the 

U.S. Secretary of State and the Canadian Minster of Foreign Affairs, 

the International Joint Commission and the Great Lakes Fishery 

Commission stated their belief that the two governments were not 

adequately protecting the Great Lakes from further introductions of 

aquatic invasive species.[Footnote 50] They also noted that there is a 

growing sense of frustration within all levels of government, the 

public, academia, industry, and environmental groups throughout the 

Great Lakes basin and a consensus that the ballast water issue must be 

addressed now. The two commissions suggested that the re-authorization 

of the National Invasive Species Act is a clear opportunity to provide 

funding towards implementing research aimed at developing binational 

ballast water standards.[Footnote 51] The International Joint 
Commission 

recommended in its 2002 11th Biennial Report that the U.S. and Canadian 

governments fund research recommended by expert regional, national, 
binational 

panels, task forces, and committees.[Footnote 52]



In an effort to prevent the introduction of nonnative aquatic organisms 

into their waters, several Great Lake states have considered adopting 

ballast water legislation that would be more stringent than current 

federal regulations. For example, the legislatures in Illinois, 

Minnesota, and New York are currently considering ballast water 

legislation that would, among other things, require ships to 

“sterilize” their ballast water--a standard that would exceed even 

those for drinking water. The Michigan legislature also debated a 

proposal that would have required ships to sterilize ballast water 

before discharge. The stringency of that proposed legislation was a 

result of one Michigan legislator’s frustration with the federal 

government’s slow progress in implementing an effective national plan 

to protect the Great Lakes from invasions through ballast water. The 

bill that passed into law in Michigan, however, has requirements 

similar to those in the federal program.[Footnote 53]



Citing inadequacies in the United States’ regulatory program, an 

environmental organization petitioned EPA in 1999 on behalf of 

15 nongovernmental, state, and tribal organizations to address ballast 

water discharges under the Clean Water Act. The petition asked the 

agency to eliminate the exemption that currently excludes ballast water 

discharges from regulation under its National Pollutant Discharge 

Elimination System program.[Footnote 54] Eighteen members of Congress 

followed the petition with a letter also requesting that the agency 

examine whether the Clean Water Act could be used to provide effective 

regulation of nonnative aquatic organisms in ballast water. In its 

September 10, 2001, draft response to the petition and the 

congressional letter, the agency concluded that the exemption should 

not be lifted because regulation of ballast water discharges under the 

Clean Water Act would be more problematic than the process already in 

place under the National Invasive Species Act. The agency asserted that 

issuing uniform discharge requirements would require significant 

federal and state agency resources and would not necessarily provide 

protection greater than the National Invasive Species Act. The agency 

also stated that the using the Clean Water Act would likely subject 

ship operators to multiple and potentially different state and federal 

regulatory regimes.



On the international level, the United States is also an active member 

of the International Maritime Organization (IMO), a specialized United 

Nations agency that is also addressing ballast water 

management.[Footnote 55] In 1997, the organization adopted “Guidelines 

for the Control and Management of Ships’ Ballast Water to Minimize the 

Transfer of Harmful Aquatic Organisms and Pathogens.” The IMO requests 

that all maritime nations adopt and use these voluntary guidelines that 

call for, among other things, open-ocean ballast water exchange. Member 

nations are also working toward an international convention to address 

ballast water management. According to a State Department official who 

is a member of the U.S. delegation to the IMO, the organization is 

developing a new convention for possible adoption in the fall of 2003. 

The State Department official told us that the convention would 

probably include ballast water exchange as an interim method and would 

likely include provisions for modifying the performance standard over 

time to correspond with and spur improvements in technology. Even if a 

convention were available for signature in the fall of 2003, it would 

take some years for it to enter into force and for effective treatment 

technologies to be installed on the world fleet. Recognizing the time 

needed to develop and install new technologies, the Coast Guard has 

suggested to the Marine Environment Protection Committee that the date 

by which ships must meet a new performance standard be 10 years after 

the organization adopts a convention (in this case, 2013).



The Continued Introduction of Nonnative Aquatic Organisms Via Ballast 

Water Could Have Major Economic and Ecological Effects on the 

Great Lakes:



Although no estimates have been made, using the past as a guide, 

the continued introduction of nonnative aquatic organisms into the 

Great Lakes could have significant economic and ecological impacts on 

the Great Lakes basin.[Footnote 56] In a May 2001 report, the 

International Joint Commission noted that the past and ongoing economic 

impacts of invasive species introductions to the Great Lakes region 

represent hundreds of millions of dollars annually.[Footnote 57] As a 

result, experts dread the introduction of the “next zebra mussel.” The 

zebra mussel was introduced to the Great Lakes in 1988 and is 

continuing to wreak havoc on the ecosystem and surrounding economies. 

Zebra mussel control measures alone are estimated to have cost 

municipalities and industries $69 million from 1989 through 1995. (See 

fig. 9 for more on the zebra mussel.):



Figure 9: Profile of the Zebra Mussel:



[See PDF for image]



[End of figure]



Such fears appear to be well founded because scientists predict that 

additional invasions will occur if effective safeguards are not placed 

on the discharge of ballast water from ocean-going ships. We have 

discussed two species and listed others that have been introduced since 

ballast water regulations were implemented. (See fig. 10.) In addition, 

scientists have identified 17 species from the Ponto-Caspian region 

(Caspian, Black, and Azov Seas) of Eastern Europe alone that have a 

high invasion potential, are likely to survive an incomplete ballast-

water exchange, and are considered probable future immigrants to the 

Great Lakes.



The continued introduction of nonnative aquatic organisms could further 

damage a U.S. and Canadian Great Lakes sport and commercial fishing 

industry that is valued at almost $4.5 billion annually and supports 

approximately 81,000 jobs. Aggressive fish that have invaded the lakes 

in the past (such as the sea lamprey, the Eurasian ruffe, and the round 

goby) have harmed native fish by directly preying either on them or on 

their food supply. Two of the potential species from the Ponto-Caspian 

region, the amphipods Corophium curvispinum and Corophium sowinskyi, 

could significantly alter biological communities along shorelines and 

food chains in North American river systems. Invasive species can also 

carry parasites and pathogens that could affect existing fish 

populations. For instance, fish pathologists fear that continued 

introductions of species such as the Eurasian ruffe may facilitate the 

introduction of new and potentially harmful parasites and pathogens, 

such as viral hemorrhagic septicemia, a serious disease of rainbow 

trout in Europe that could affect North American fish populations.



Ballast water is also known to carry human pathogens, although the 

risks they pose to human health has not been determined. One study 

performed during the 1997 and 1998 shipping seasons sampled ballast 

water in ships passing through the St. Lawrence Seaway en route to 

ports in the Great Lakes.[Footnote 58] Human pathogens, such as fecal 

coliform, fecal streptococci, Clostridium perfringens, Escherichia 

coli, and Vibrio cholerae, as well as multiple species of 

Cryptosporidium, Salmonella, and Giardia, were detected in the samples. 

According to the Coast Guard, these organisms are also found in bodies 

of water that are influenced by human development.



There Is a Growing Interest in Coordination between the United States 

and Canada, but a Comprehensive Approach Has Yet to Be Developed:



The United States and Canada participate in a variety of bilateral and 

multilateral efforts to share information, conduct research, and 

coordinate efforts to reduce the threat of invasive species. The two 

countries’ long history of coordination has focused on particular 

segments of the issue such as shared boundary waters and agricultural 

research, and stakeholders have called for a more comprehensive 

strategy for joint prevention and management efforts. The National 

Invasive Species Council recognized the need for the United States to 

work with Canada (and Mexico) in a more comprehensive manner and has 

taken initial steps to develop a North American strategy as called for 

by the national management plan. It is too early to tell, however, what 

form a North American strategy will take or how existing organizations 

will be integrated.



Coordination Between the Two Governments Has Focused on Specific Issues 

or Geographic Regions:



Historically, coordination between the United States and Canada has 

focused on specific pathways, species, or geographic areas rather than 

on a comprehensive coordinated approach. Primary examples of this 

coordination concern shared boundary waters and agriculture.



Shared Boundary Waters:



One mechanism for coordination is the International Joint Commission, 

which was established by the Boundary Waters Treaty of 1909. The treaty 

established the commission to advise the U.S. and Canadian governments 

concerning issues along the boundary and approve certain projects in 

boundary and transboundary waters that affect water levels and flows 

across the boundary. The commission has focused much of its attention 

on the Great Lakes. The purpose of the 1978 Great Lakes Water Quality 

Agreement between the United States and Canada is to “restore and 

maintain the chemical, physical, and biological integrity of the waters 

of the Great Lakes Basin Ecosystem.” The International Joint 

Commission’s role with respect to the agreement includes evaluating and 

assessing the two countries’ programs and providing a report at least 

every 2 years that presents its findings, advice, and recommendations. 

Recent reports have contained recommendations to the governments on how 
to 

reduce the flow of invasive species through ballast water.[Footnote 59]



Protection of the Great Lakes fisheries against the nonnative sea 

lamprey was a motivating factor behind the creation of the Great Lakes 

Fishery Commission in 1955 in the Convention on Great Lakes Fisheries 

between the U.S. and Canada. The fishery commission, which is jointly 

funded by the two countries, has been largely successful in 

controlling, although not eradicating, the sea lamprey. Another primary 

objective of the fishery commission is to formulate a research program 

or programs to determine the need for measures to make possible the 

maximum sustained productivity of fish of common concern. One of the 

commission’s goals is to ensure that no nonnative fishes will be 

unintentionally introduced into the Great Lakes. The commission has 

stated that it will intensify its work with partners to address those 

vectors for invasive species, such as ship ballast water, that pose the 

greatest threat to the lakes.



Another mechanism that has promoted coordination between the United 

States and Canada is the establishment of regional panels to address 

aquatic invasive species. The Nonindigenous Aquatic Nuisance Prevention 

and Control Act of 1990 authorized the establishment of the Great Lakes 

Panel on Aquatic Nuisance Species, which comprises U.S. and Canadian 

public-and private-sector representatives.[Footnote 60] Its activities 

include identifying Great Lakes priorities for aquatic nuisance 

species, coordinating information and education efforts, making 

recommendations to the federal government, and advising the public 

about control efforts. Two other U.S. panels recently established under 

the National Invasive Species Act of 1996 in the West and the Northeast 

also include Canadian members.



As noted earlier, the United States and Canada are also working 

together on managing ballast water coming into the Great Lakes through 

the St. Lawrence Seaway. Cooperative efforts by the two countries were 

most recently demonstrated by the joint decision of the United States’ 

Saint Lawrence Seaway Development Corporation and Canada’s 

St. Lawrence Seaway Management Corporation to require all ships 

entering the seaway to follow established best management practices.



Agricultural Research and Pest Control:



There has also been a long history of coordination between the U.S. and 

Canada in the area of agricultural research and pest control. As we 

reported in July 2002, for over 30 years the two countries and Mexico 

have held regular meetings on animal health issues to make North 

America’s import requirements consistent and, more recently, to 

coordinate preventive actions and emergency response activities in the 

event of an outbreak of the nonnative foot-and-mouth disease.[Footnote 

61] In 2000, the three countries held joint exercises to test their 

foot-and-mouth disease communication and response plans and to assess 

their response systems. As a result of this exercise, the three 

governments signed a memorandum of understanding to formally establish 

the North American Animal Health Committee. According to USDA, the 

United States and Canada have also worked very closely in the past 

several years on jointly assessing the threat from two other foreign 

animal diseases--bovine spongiform encephalopathy (also known as “mad 

cow disease”) and chronic wasting disease. Another emerging animal and 

public health issue that the United States and Canada have worked 

together on is the West Nile virus, which is transported by migratory 

birds and by insects such as mosquitoes. (See fig. 10 for more details 

on the virus.):



Figure 10: Profile of West Nile Virus:



[See PDF for image]



[End of figure]



To further strengthen communication and collaboration on invasive 

species and trade-related matters, USDA’s Animal and Plant Health 

Inspection Service established an office in Ottawa, Canada, in 2000. 

The office oversees a preclearance program throughout Canada that 

conducts inspections, treatments and/or other mitigation measures in 

Canada to identify and/or mitigate the risk of exotic pest 

introductions via agricultural commodities before the commodities are 

cleared through the U.S. Customs Service.



Another vehicle for coordination in the agriculture sector is the 

North American Plant Protection Organization, created as a regional 

plant protection organization under the International Plant Protection 

Convention of 1951. The convention called for the governments to 

establish regional plant protection organizations responsible for 

coordinating activities under the convention, such as the development 

and promotion of the use of international phytosanitary 

certificates.[Footnote 62] For example, through the plant protection 

organization, the United States, Canada, and Mexico worked together to 

develop a standard for treating solid wood packing materials. According 

to USDA, the United States and Canada are also working together to 

develop an international standard for evaluating the environmental 

impact of invasive species. This standard, which the USDA expects to be 

adopted by the International Plant Protection Convention in 2003, would 

provide a common framework for assessing the invasive potential of 

pests and thereby ensure a more rigorous but common approach to dealing 

with them.



Stakeholders Have Called for Increased Coordination between the United 

States and Canada:



While there are numerous examples of coordination between the United 

States and Canada on invasive species control, some stakeholders in 

this issue believe that not enough is being done. For example, in June 

1999, the Great Lakes Panel on Aquatic Nuisance Species wrote that 

there was a lack of inter-jurisdictional consistency in laws, 

regulations, and policies directed at aquatic nuisance species 

prevention and control efforts, and that improvements were needed to 

ensure a more efficient and effective regional prevention and 

control program.



As noted previously, the International Joint Commission stated its 

belief that the two governments were not adequately protecting the 

Great Lakes from further introduction of aquatic invasive species and 

it made several recommendations regarding a binational approach to 

better management. In addition, according to EPA, there are numerous 

locations where there is a need for continuing regional cooperation to 

address aquatic invasive species in binational waterways, including the 

St. Croix River of New Brunswick and Maine; Lake Champlain of Quebec, 

Vermont, and New York; the Red River of North Dakota, Minnesota, and 

Manitoba; the Souris River of Saskatchewan, Manitoba, and North Dakota; 

and the Georgia Basin-Puget Sound of British Columbia and Washington. 

For example, in the Red River watershed of North Dakota, a proposed 

water diversion could introduce nonnative species into new locations. 

An official from EPA’s Office of International Affairs told us that, in 

his opinion, having an overarching policy with respect to aquatic 

invasive species along the border would help better address these 

situations more quickly or avoid them completely.



The National Invasive Species Council’s Assistant Director for 

International Policy, Science, and Cooperation told us that she 

believes that the United States could expand two existing interagency 

organizations--the Federal Interagency Committee for the Management of 

Noxious and Exotic Weeds and the Aquatic Nuisance Species Task Force--

to include Canadian representation, or that Canada should be encouraged 

to develop similar organizations.[Footnote 63] She said this would make 

it much easier to establish dialogue between officials with similar 

responsibilities. The council’s Assistant Director also said she 

thought that the National Oceanic and Atmospheric Administration’s Sea 

Grant Program could be more effectively used to support educational 

programs developed and implemented in the United States and Canada. She 

noted that because tourists frequently cross the border to and from 

Canada it is important to address this pathway with a common education 

strategy. In this same vein, while we reported in August 2002 that the 

United States, Canada, and Mexico have worked to coordinate animal 

health measures, we also noted that there are differences in the 

countries’ policies and practices with regard to foot-and-mouth disease 

that could contribute to the risk that travelers may bring foreign 

animal disease across our mutual borders.



The National Invasive Species Council Has Taken Initial Steps Toward 

Developing a North American Strategy, but its Form Is Not Yet Known:



The National Invasive Species Council recognized the need for the 

United States to work with Canada (and Mexico) in a more comprehensive 

manner. The management plan called for the council to outline an 

approach to a North American invasive species strategy by 

December 2001. The strategy was to be built upon existing tripartite 

agreements and regional organizations. The plan also called for the 

council to initiate discussions with Canada and Mexico for further 

development and adoption of the strategy. The council has taken initial 

steps but has not completed this planned action.



The council established the North America Strategy task team in 

January 2002. It comprises federal and nonfederal stakeholders, and is 

cochaired by the Department of State, the Environmental Protection 

Agency, and the Fish and Wildlife Service. In March 2002, the 

Department of State sent a cable to United States embassy staff in 

Canada and Mexico requesting that they notify officials in those two 

countries of the federal government’s desire to develop a North 

American strategy. According to one U.S. official involved in this 

project, Canadian representatives have responded positively to 

the idea.



In the time since it sent the memorandum, however, the team has done 

little to develop the strategy. The council staff and the advisory 

committee placed the team into a holding pattern in May 2002 when they 

decided that all of the implementation teams needed to be reviewed by 

the advisory committee. According to one of the cochairs of the team, 

among other things that the team will need to do is identify the 

objectives of the U.S. participation in the various North American 

organizations and determine what actions are being taken.



Two other multilateral organizations provide opportunities for a more 

comprehensive approach to an invasive species strategy across 

North American borders but do not have significant resources dedicated 

to the issue. The North American Commission on Environmental 

Cooperation, which is governed by a council composed of the 

Administrator of the United States Environmental Protection Agency, 

the Minister of the Environment in Canada, and the Secretary of the 

Environment and Natural Resources in Mexico, provides an opportunity 

for the United States and Canada to research and develop strategic 

plans for common ecosystems such as northern forests, grasslands, and 

aquatic ecosystems.[Footnote 64] One objective in its 2001 draft 
Strategy

for the Conservation of Biodiversity in North America, is to promote 
the 

development of concerted efforts to combat invasive species in North 

America. In March 2001, participants at a workshop sponsored by the 

commission recommended five priority areas for cooperation in North 

America on invasive species. Because of limited resources, however, the 

commission has decided to proceed with just one of those areas--

identifying invasive species and invasion pathways that are a concern 

of two or more countries (within North America)--and determine 

priorities for bi-or tri-lateral cooperation.



The Trilateral Committee for Wildlife and Ecosystem Conservation and 

Management is composed of the wildlife agencies from the United States, 

Canada, and Mexico, and also has the ability to look at approaches for 

managing invasive species more broadly.[Footnote 65] The committee has 

not analyzed invasive species in depth, although the issue was on its 

meeting agenda in April 2002 in order to set it as a topic for 

discussion at a later meeting. According to a State Department official 

who attended the meeting, the committee decided to add invasive species 

to the portfolio of the “working table” on biodiversity information.



Conclusions:



While the available data are often inadequate to thoroughly describe 

the costs and risks associated with invasive species, it is apparent 

that their impacts on our environment and, thus, our economy are 

significant. At the same time, because of limitations in both the 

quantity and quality of economic impact analysis, it may not be readily 

apparent to decision makers in the federal government how they should 

most effectively allocate limited resources to prevent and manage 

invasive species. It is encouraging that the National Invasive Species 

Council and OMB are working on a crosscut budget that the federal 

government can use to plan resource allocations to and among 

departments. Such decisions would be better informed by information and 

data on the risk that nonnative species will enter the country, become 

established, spread, and cause harm. The ballast water management 

situation is a prime example. The federal government faces decisions 

about dedicating resources to fund ballast water technology research or 

standard setting, and ultimately about imposing more protective 

regulations. Decision makers could weigh the costs of those activities 

against the potential costs of the next zebra mussel or sea lamprey to 

arrive in U.S. waters, if such data were readily available.



Moving ahead with a comprehensive management plan to combat invasive 

species is clearly in the national interest. It also poses a daunting 

challenge. Success in this effort will depend in no small part on 

crafting a plan that calls for clearly defined, measurable outcomes and 

has a mechanism in place to hold departments accountable for carrying 

it out. The National Invasive Species Council now has the opportunity 

to improve upon its management plan in a revision due in 2003. 

Successful implementation of the plan depends in part on the members of 

the council making it a priority within their own departments and 

agencies and, recognizing the enormity of the task ahead, developing 

estimates of the resources needed. Statements from various stakeholders 

suggest it is possible that federal agencies could better coordinate 

their efforts to implement the management plan if the Congress 

established the council in legislation. The management plan states that 

the council will conduct an analysis of legislative authorities 

relevant to invasive species. We believe that the evaluation should 

also examine the question of whether the lack of legislative authority 

establishing the council is hampering the council in its efforts to 

implement the national management plan.



Recommendations for Executive Action:



To better manage the threats posed by invasive species in the United 

States, we recommend that the cochairs of the National Invasive Species 

Council--the Secretaries of Agriculture, Commerce, and the Interior--

direct council members to:



* Include within the revision to the National Invasive Species 

Management Plan a goal of incorporating information on the economic 

impacts and relative risks of different invasive species or pathways 

when formulating a crosscuting invasive species management budget for 

the federal government. Such a goal may require a commitment from the 

council to ensure that adequate resources are dedicated within the 

federal government to expand the capacity for conducting appropriate 

economic analysis.



* Ensure that the updated version of the national management plan, due 

in January 2003, contains performance-oriented goals and objectives and 

specific measures of success.



* Give a high priority to completing planned action #1, which calls for 

establishing a transparent oversight mechanism for use by federal 

agencies in complying with Executive Order 13112 and reporting on 

implementation of the management plan.



* Include in its planned evaluation of current legal authorities an 

examination of whether the lack of legislative authority establishing 

the National Invasive Species Council and specifically directing its 

members to implement the national management plan hampers the council’s 

efforts to implement the plan.



To better ensure the implementation of the national management plan, 

we recommend that the members of the National Invasive Species Council 

who are responsible for taking actions called for in the plan recognize 

their responsibilities in either their departmental-or agency-level 

annual performance plans. The annual performance plans and performance 

reports should describe what steps the departments or their agencies 

will take or have taken to implement the actions that are specifically 

called for in the national management plan. For the existing (2001 

version) of the national management plan, the member departments to 

which this applies include the Departments of Agriculture, Commerce, 

Interior, Defense, State, and Transportation, and the Environmental 

Protection Agency.



Agency Comments and Our Evaluation:



We provided copies of our draft report to the Departments of 

Agriculture, Commerce, Defense, Treasury, State, Transportation, and 

the Interior; the Environmental Protection Agency; the U.S. Trade 

Representative; and the National Invasive Species Council. We received 

written comments from the Department of the Interior, the Department of 

State, the Environmental Protection Agency, and the National Invasive 

Species Council. We received oral comments from the Departments of 

Transportation, Agriculture, and the Treasury. The written comments 

from the Department of the Interior, the Department of Agriculture, the 

National Invasive Species Council, and EPA are in appendixes II 

through V.



The Department of the Interior concurred with the recommendations in 

the report and said that it would work with the other cochairs of the 

National Invasive Species Council to implement the recommendations in a 

timely manner consistent with current budget and authority. While 

agreeing with the recommendations, the department expressed the view 

that our draft report did not adequately acknowledge the extensive 

invasive species activities that federal agencies are doing outside of 

what is called for by the national management plan. We agree that 

federal agencies are engaged in other invasive species management 

activities and have described many of them in prior reports. A 

principle objective of this review, however, was to assess the 

implementation of the national management plan, and not all federal 

activities. The department also commented that it believes that the 

Fish and Wildlife Service, the National Oceanic and Atmospheric 

Administration, and the Maritime Administration are demonstrating 

substantial progress in developing technologies to treat ballast water. 

We agree that progress is being made, but continue to believe that much 

important work remains to be done. To illustrate this, we reported the 

Coast Guard’s estimate that it may be at least 10 years before ships 

must meet a new performance standard for ballast water treatment, a 

step critical to real progress. The department suggested several other 

minor changes that we have incorporated where appropriate.



The Department of State commented that it did not fully concur with our 

finding that the slow progress on the national management plan is due 

to lack of priority given to the plan by the Council and departments. 

The department claimed that it places a high priority on accomplishing 

the goals of the management plan, and it itemized numerous activities 

in support of that statement. We do not disagree with the department’s 

claims. However, we did not evaluate the efforts or progress of one 

department versus another; instead, we evaluated implementation of the 

management plan overall. The letter from the Department of State also 

included comments from the International Joint Commission. The 

commission suggested that we include a recommendation that the federal 

government work with Canada to develop an effective approach to 

immediately improve the management of all ballast waters coming into 

the Great Lakes. Our report describes the current and expected 

situation with respect to ballast water in the Great Lakes. We believe 

that the decision to take more immediate action to solve the problem is 

a policy decision best left to the Congress or the administration. The 

commission also suggested that we ask the Congress to consider 

completing reauthorization of the National Invasive Species Act. While 

we recognize the importance of the commission’s suggestion, we did not 

evaluate the current proposal to reauthorize the act. The department 

and the commission also offered minor corrections, which we have made.



The National Invasive Species Council concurred with our 

recommendations but made several clarifying comments. In particular, 

it noted that the management plan’s deadlines were optimistic and 

suggested that we should have evaluated whether the deadlines were 

realistic or attainable. We believe that an assessment of its deadlines 

is an appropriate task for the council when it revises the management 

plan. In addition, the council commented that the report undervalued 

the progress being made toward coordination and cooperation among 

federal agencies and gave examples of such activity. We acknowledge 

that coordination between departments has increased as a result of the 

creation of the council and the management plan, and we have added 

language to support this point. Nevertheless, the report provides 

support for the position that improvement can still be made in this 

area. Finally, the council made other minor comments that we have 

incorporated where appropriate.



The Environmental Protection Agency commented that our recommendations 

were reasonable and believes that their implementation would enhance 

the federal government’s response to dealing with the problem of 

invasive species. The agency also noted that the report is well written 

and helpful in assessing the progress made in coping with invasive 

species. The agency also made several clarifying comments that we have 

incorporated where appropriate. The agency questioned whether we should 

have based our conclusions about the pace of implementation of the 

management plan solely on the results of our survey of the members of 

the first term of the advisory committee, given the small size of the 

population and their possible biases. We did not draw our conclusions 

about the pace of implementation solely, or even primarily, from the 

survey. Our statement that less than 20 percent of the plan has been 

implemented is based on our analysis of information from the National 

Invasive Species Council staff and the council’s member departments. 

EPA also noted that the report’s section on ballast water focused on 

the Great Lakes and pointed out that work is being done and needs to be 

done in other parts of the country. We agree that ballast water is an 

important issue in other parts of the country. However, our objective, 

as part of our coordinated review with the Canadian Office of the 

Auditor General, was to focus on the Great Lakes. Finally, EPA made a 

number of technical clarifications that we have incorporated, where 

appropriate, in the report.



The invasive species coordinator for the Department of Agriculture said 

that our comments on the implementation of the national management plan 

were fair and on target. This official also provided two minor 

clarifying comments that we have incorporated.



The Department of Transportation’s Director for Performance Planning in 

the Office of Budget and Program Performance provided oral comments on 

the draft. He told us that the department disagreed with our draft 

recommendation calling for the members of the National Invasive Species 

Council to incorporate the national management plan into their annual 

performance plans. He said that the department does not believe that it 

is appropriate to include performance goals with respect to invasive 

species in its performance plan because managing invasive species is 

not one of its core missions. In addition, he told us that the agencies 

within the department that have a more direct role with respect to 

invasive species, such as the Coast Guard, Maritime Administration, and 

Federal Highway Administration, are at liberty to include invasive 

species management goals in their annual performance plans. In response 

to this comment, we modified the wording of the recommendation to 

specify that the national management plan should be addressed in the 

most appropriate annual performance plan, whether at the departmental 

level or the agency level. The department also commented that there are 

many mechanisms other than ballast water by which invasive species are 

introduced into the environment. We agree, and noted some of them in 

the report. However, our objective specifically focused on the issue of 

ballast water in the Great Lakes.



A representative with the Office of Planning in the Department of the 

Treasury’s U.S. Customs Service told us that because the current 

national management plan does not call for the Customs Service to 

undertake significant activity on invasive species, it does not believe 

that it is appropriate for it to address the management plan in its 

annual performance plan as called for in our recommendation. We 

acknowledge that the current plan does not have action items directed 

to the Customs Service, and we modified our recommendation to clarify 

its applicability to those member agencies that are specifically 

responsible for action items in the existing (2001) national management 

plan. If future versions of the plan specify action items for other 

agencies, we would encourage them to follow the same practice with 

regard to their department-or agency-level annual performance plans. 

The Customs Service made no technical comments.



We are sending copies of this report to the other members of the 

National Invasive Species Council: the Secretaries of State, Defense, 

Transportation, Health and Human Services, and Treasury, and the 

Administrators of the Environmental Protection Agency and the 

U.S. Agency for International Development. We are also sending copies 

of this report to the Chairmen and Ranking Minority Members of the 

following congressional committees: the Senate Committee on 

Agriculture, Nutrition, and Forestry; the Senate Committee on 

Commerce, Science, and Transportation; the Senate Committee on 

Environment and Public Works; the Senate Committee on Energy and 

Natural Resources; the Senate Committee on Foreign Relations; the 

Senate Committee on Appropriations; the House Committee on Agriculture; 

the House Committee on Resources; the House Committee on Science; the 

House Committee on Transportation and Infrastructure; the House 

Committee on Energy and Commerce; the House Committee on International 

Relations; and the House Committee on:



Appropriations. We will make copies available others upon request. This 

report is also available on our Web site at www.gao.gov. If you have 

any questions concerning this report, I can be reached at (202) 512-

6878. Major contributors to this report include Trish McClure, Ross 

Campbell, Patrick Sigl, Don Cowan, Anne Stevens, and Amy E. Webbink.



David G. Wood

Director, Natural Resources 

 and Environment:



Signed By David G. Wood:



[End of section]



Appendixes:



Appendix I: Scope and Methodology:



To determine the usefulness to decision makers of economic impact 

studies for invasive species in the United States, we reviewed 

economics and other policy literature that analyzes invasive species’ 

effects on the U.S. economy and ecosystems. We also reviewed the 

literature that describes and evaluates U.S. regulatory policies for 

invasive species. We paid particular attention to the literature that 

evaluates how well cost-benefit analyses of invasive species’ effects, 

and of regulatory policies to control them, have been adjusted to 

reflect uncertainties and risks associated with these assessments. To 

further determine the usefulness of the existing studies, we selected 

and interviewed experts, including some authors of studies, and 

government officials involved in both authoring and using the economic 

impact studies. We identified these experts through our literature 

search.



To assess the National Invasive Species Management Plan, including the 

extent to which the United States government has implemented it, we 

first analyzed the content of the plan in relation to the requirements 

spelled out in Executive Order 13112. In particular, we analyzed the 

extent to which it contained “performance-oriented goals and objectives 

and specific measures of success for federal agency efforts concerning 

invasive species.” The plan contains 57 enumerated actions. However, 

several of those actions have distinct subparts. In consultation with 

council staff, we agreed that there are a total of 86 distinct actions 

called for by the plan. To evaluate the extent to which the plan has 

been implemented, we focused primarily on those actions that had a 

start or completion date of September 2002 or earlier. There are 65 

actions in that category. To determine whether actions had been 

completed, were in progress, or had not been started, we relied on the 

National Invasive Species Council’s summary of agency progress, 

materials provided to us by agency officials, and interviews with 

council staff and agency officials. For those actions that had been 

started but not completed, we did not attempt to characterize the 

extent to which they had been completed. In only a few instances did we 

attempt to determine when incomplete actions would be complete.



To assist in our evaluation of the plan and our assessment of its 

implementation, we surveyed the 32 people serving on the Invasive 

Species Advisory Committee for a 2-year term beginning in December 

1999. We had several reasons for surveying this group: (1) they 

participated in developing the national management plan; (2) they 

represented a wide range of interests relevant to the invasive species 

issue; and (3) by virtue of their professions and their involvement 

with the committee, they were likely to have information and opinions 

on how the management plan was being implemented. The Secretary of the 

Interior reappointed 15 of these 32 people for another term on the 

advisory committee beginning in April 2002.



One of the members of the original advisory committee told us that he 

had resigned from the committee partway through his term and did not 

believe that he was informed enough about events surrounding the 

council, the committee, or the management plan to respond to our 

survey. Therefore, for the purposes of calculating a response rate, we 

are using 31 as the size of our survey population. Twenty-one of the 31 

members of the committee completed our survey, while 2 others completed 

a small portion of the survey. Therefore, while the response rate was 

74 percent, the completion rate was 68 percent. Thirteen of the 15 

people reappointed to the committee responded to the survey.



The survey instrument contained questions that asked for either 

numerical or open-ended answers. The survey, including a tally of the 

numerical answers, is in appendix IV. Because we did not take a sample 

of the committee members, the numerical answers are presented as a 

straight percentage of the total number of respondents. There are no 

error rates associated with the results. We did not reprint the open-

ended answers in the report because they are too numerous and lengthy.



To determine the experts’ views on the adequacy of U.S. and Canadian 

efforts to control the introduction of invasive aquatic species into 

the Great Lakes via the ballast water of ships, we selected and 

interviewed experts from various stakeholder interests. We identified 

experts through a literature search and by soliciting the names of 

other expert contacts throughout our review. In the end, we contacted 

experts from U.S. federal agencies, academic institutions, and the 

shipping industry. We also met with staff from two binational agencies-

-the International Joint Commission and the Great Lakes Fishery 

Commission--and with representatives of the Great Lakes Commission. In 

addition, we attended a conference on aquatic nuisance species to 

obtain opinions from a range of stakeholders on ballast water and 

associated shipping vectors.



To describe the current management of ballast water in the Great Lakes, 

we researched U.S. and Canadian legislation, regulations, and 

guidelines. In order to determine the compliance rate and effectiveness 

of the current regulatory regime for the Great Lakes, we obtained 

compliance and other data from the Coast Guard Marine Safety Detachment 

and the Saint Lawrence Seaway Development Corporation in Massena, 

New York. The Saint Lawrence Seaway Development Corporation also showed 

us the U.S. ballast water inspection procedures on a vessel docked in 

Montreal, Canada, and bound for the Great Lakes. We also reviewed 

studies on the introduction of nonnative aquatic organisms traced to 

ballast water, paying particular attention to those that have invaded 

after the ballast water regulations for vessels entering the 

Great Lakes took effect in 1993. We interviewed both United States and 

Canadian scientists on the significance of the continued invasions 

since 1993.



For the international perspective on ballast water management, we 

reviewed the history and development of the current International 

Maritime Organization policies and guidelines. We also met with members 

of the U.S. delegation to the organization to determine the status of 

negotiations on a future international agreement related to ballast 

water. These officials represent the United States on the Marine 

Environmental Protection Committee and lead the correspondence group 

that is tasked with developing a performance standard for the future 

International Maritime Organization Convention on ballast water 

management.



To describe coordination between the United States and Canada, we 

interviewed officials from departments in the National Invasive Species 

Council to determine if their departments were involved in any 

significant efforts to coordinate with Canadian officials on invasive 

species management. From these discussions, we learned that 

coordination efforts on a binational (or in some cases trinational) 

level have focused primarily on shared boundary waters and agriculture. 

We obtained further information from the relevant departments on the 

nature of those coordination efforts. To learn more about how 

nonfederal organizations can play a role in coordinating the work of 

the two countries, we interviewed and obtained documents from officials 

representing the International Joint Commission, the Great Lakes 

Fishery Commission, the Great Lakes Commission, and the North American 

Commission on Environmental Cooperation. We also obtained documentation 

that described relevant work being done by the International Plant 

Protection Organization, the North American Plant Protection 

Organization, the North American Animal Health Committee, and the 

Trilateral Committee for Wildlife and Ecosystem Conservation and 

Management. Finally, we relied on previous GAO work on foot-and-mouth 

disease.



In choosing invasive species to profile, we judgmentally selected 

species that (1) illustrate problems in a variety of environments 

(aquatic, terrestrial, managed, and natural areas), (2) are drawn from 

a wide variety of taxonomic groups (vertebrate, invertebrate, virus, 

and plant), (3) include some that are well known by the public and 

others that are not, and (4) provide a selection whose distribution 

collectively covers a large portion of the United States. We collected 

and reviewed data on the species from federal agencies, academic 

institutions, and previous GAO reports. We obtained photographs of 

species from the U.S. Geological Survey and USDA.



We conducted our review from November 2001 through September 2002 in 

accordance with generally accepted government auditing standards.



[End of section]



Appendix II: Survey of Charter Members of the Invasive Species Advisory 

Committee:



[See PDF for image]



[End of figure]



[End of section]



Appendix III: Comments from the Department of the Interior:



United States Department of the Interior:



OFFICE OF THE SECRETARY Washington, D.C. 20240:



OCT 1 5 2002:



Mr. David G. Wood:



Director, Natural Resources and Environment United States General 

Accounting Office 441 G Street, NW:



Washington, DC 20548:



Dear Mr. Wood:



Thank you for the opportunity to respond to the draft report entitled, 

“Invasive Species: Clearer Focus and Greater Commitment Needed to 

Effectively Manage the Problem” (GAO-03-01). The Department concurs 

with the recommendations of this report and will work with the other 

Co-Chairs of the National Invasive Species Council to implement the 

recommendations in a timely manner consistent with current budget and 

authority. Our efforts to develop a budget crosscut on Invasive Species 

for FY 2004 should further support the report’s recommendations.



Our specific response to each of the draft report recommendations is 

provided in the enclosure. If you have further questions, please 

contact A. Gordon Brown, DOI Invasive Species Coordinator, at (202) 

513-7245.



Sincerely,



P. Lynn	Scarlett:



Assistant Secretary for Policy, Management and Budget:



Signed by P. Lynn Scarlett:



Enclosure:



Department of the Interior Comments on GAO Draft Report entitled, 

“Invasive Species: Clearer Focus and Greater Commitment Needed to 

Effectively Manage the Problem” (GAO-03-01):



General Comments:



The recommendations of the report are directed to the National Invasive 

Species Council (Council) co-chairs. Since the Department of the 

Interior is a co-chair of the Council, the Department will work 

cooperatively with the other co-chairs, in the Departments of 

Agriculture and Commerce, to address the report’s recommendations.



The Department supports development of a budget crosscut on invasive 

species for FY 2004 and later requests by the Council departments. We 

believe this will lead to development of a performance-based strategic 

plan for most of the Executive Branch agencies.



Specific Comments:



Fish and Wildlife Service clarified an error of fact on Page 21 - “In 

addition, the Federal Aquatic Nuisance Species Task Force has developed 

a process to evaluate the risk of introducing non-native organisms into 

a new environment and, if needed, determine the correct management 

steps to mitigate that risk. The task force has used this process to 

provide guidance to states for designing their own management plans for 

aquatic nuisance species.”:



The second sentence of this statement is incorrect in that the risk 

assessment process is separate from the State management planning 

process. The second sentence should be modified to read: “The Task 

Force has also developed guidelines to provide direction to assist 

States in the development of their own management plans for aquatic 

nuisance species.”:



Recommendation #1: that the co-chairs of the Invasive Species Council-

the Secretaries of Agriculture, Commerce, and the Interior-include 

within the revision of the National Invasive Species Management Plan, a 

goal of incorporating information on economic impacts and relative 

risks of different invasive species or pathways when formulating a 

budget crosscut.



The Department of the Interior, in consultation with the other co-

chairs, will work to expand the capacity for conducting appropriate 

economic analysis on invasive species and their impacts.



Recommendation #2: that the co-chairs of the Invasive Species Council-

the Secretaries of Agriculture, Commerce, and the Interior-ensure that 

the next edition of the national management plan contains performance-

oriented goals and objectives and specific measures of success.



The Department of the Interior is working to advance activity-based 

costing as a model of performance budgeting and management for its own 

programs. A pilot program of performance-oriented goals and objectives 

with specific measures of success will be implemented in January 2004 

for the National Invasive Species Council. This information will be 

used to build a more:



complete budget crosscut proposal on invasive species for FY 2005, 

including shared goals, strategies and performance measures.



Recommendation #3: that the co-chairs of the Invasive Species Council-

the Secretaries of Agriculture, Commerce, and the Interior-give a high 

priority to completing planned action #1, a Federal oversight mechanism 

for compliance with EO 13112 and management plan implementation.



The Department of the Interior will cooperate with the other co-chairs 

to jointly provide leadership on this issue and solicit consensus views 

on any proposal from the Invasive Species Advisory Committee.



Recommendation #4: that the co-chairs of the Invasive Species Council-

the Secretaries of Agriculture, Commerce, and the Interior-include in 

its planned evaluation of current legal authorities an examination of 

the importance of legislative authority to National Invasive Species 

Council implementation of the national management plan.



The Department of the Interior will work with the other co-chairs to 

assess legislative authority for a national invasive species management 

plan.



Comments supplied by the bureaus:



Fish and Wildlife Service:



Page 33 - “One respondent thought that federal departments and agencies 

were continuing to pursue their own mandates and programs with only a 

cursory regard for the framework and coordination that the council 

attempts to provide. “:



The National Invasive Species Management Plan (ISMP) is a critical 

document helping to focus department and agency invasive species 

activities; however, Federal agencies are also guided by other policies 

and legislation that direct their activities. Many of these activities 

are conducted by the agencies and are not reflected in the actions 

outlined in the ISMP. The GAO report gives a critical review of the 

Federal government’s efforts to implement the ISMP with minimal 

acknowledgment of these extensive activities that balance invasive 

species workloads to meet both existing responsibilities and new 

activities outlined in the ISMP.	In addition, we point out that the 

Council has made great strides in coordinating agency activities and 

increasing communication among agencies and departments about their 

invasive species activities.



Page 34 - “In our view, the relationship of the advisory committee to 

the implementation teams has slowed progress on the plan and could 

continue to do so. While we understand why the council decided to form 

the implementation teams under the auspices of the advisory committee - 

to foster consensus among key stakeholders early in the implementation 

process - we believe that this decision may slow Federal action. 

Specifically, it may be difficult for teams of Federal and non-federal 

stakeholders to put forth the concerted effort needed to implement the 

management plan. “:



While we agree that progress might have been made more quickly without 

input from the Advisory Committee, we support the Council’s decision to 

proceed with a partnering process that incorporates input from the 

stakeholder Advisory Committee.



Page 37 - “The current regulatory approach to ballast water management 

is not keeping invasive species out of the Great Lakes “.



While we agree that ballast water continues to be a major pathway for 

introductions of aquatic invasive species, we believe that the progress 

being made on monitoring and compliance by the Coast Guard to develop 

and implement regulations is timely and reflects the time-consuming 

nature of the regulatory process. We also believe that the efforts by 

the Fish and Wildlife Service, the National Oceanic and Atmospheric 

Administration, and the Maritime Administration are demonstrating 

substantial progress to develop technologies to treat ballast water to 

remove invasive species.



Page 54 - “The National Invasive Species Council’s Assistant Director 

for International Policy, Science, and Cooperation told us that she 

believes that the United States could expand two existing interagency 

organizations - the Federal Interagency Committee for the Management of 

Noxious and Exotic Weeds and the Aquatic Nuisance Species Task Force - 

to include Canadian representation. . . “:



The Aquatic Nuisance Species Task Force (ANS) has Canadian 

representation in an “invited observer” status. In addition, the ANS 

Task Force has actively recruited Canadian representation in the 

efforts of its numerous committees. For example, three of the Regional 

Panels of the Task Force (Northeast, Great Lakes, and Western) have 

Canadian representatives serving on the committees.



National Park Service:



The draft report dwells on the need for more comprehensive data and 

analysis of risks and of economic and ecological costs of invasive 

species. We recognize that others may need this information, but we 

would like to point out that lack of information is not a major 

hindrance to our efforts to control invasive species.



We have a major Inventory and Monitoring Program in the National Park 

Service and some of the funds allocated for weed management are used 

for inventory and monitoring. We know where our weeds are and we know 

why we are controlling them. We do not wait for more information to 

implement an effective program. Our greatest need is for more funds for 

operational work.



Further, quantification of the costs of invasive species will tend to 

favor management of invasive species in situations where the costs can 

be easily given monetary value. Costs to agriculture are easily 

quantified in monetary terms whereas costs to natural areas are 

difficult to quantify. Therefore, generation of this data will tend to 

favor funding of control for invasive species that affect agriculture, 

at the expense of natural areas control efforts. Those who advise 

decision makers must assure that the decision makers are aware of the 

values of resources and natural processes that cannot be easily 

quantified.



The draft report points to a need for better performance management. We 

would welcome increased emphasis on performance management, but we want 

performance managers to understand the difficulty and complexity of 

applying performance measures to land management situations involving 

the interaction of multiple biological communities and diverse 

populations of existing and new organisms. A simple example will 

demonstrate this.



Suppose a land management agency has one million acres of weeds. If 

they treat one percent of the infested acres per year, or 10,000 acres, 

it would seem that they should be able to reduce the number of infested 

acres to zero in one hundred years. This is far from true.



Some weeds spread slowly while other spread very rapidly. For large 

scale planning purposes, weed scientists often assume an average spread 

or rate of increase of 15 percent per year. Therefore, if you begin 

with one million infested acres and treat 10,000 acres, at the end of 

the year you will have an infested area of 1 million minus 10,000 acres 

treated, plus 148,000 newly infested acres (990,000 x 0.15) for a total 

of 1,138,000 acres. This is the situation faced by most Federal land 

managers today. Presently, our objectives are to slow the spread of 

weeds and to try to target the most critical species and acres.



Further, we are never finished with the 10,000 acres treated. They must 

be periodically monitored and may require periodic retreatment. In many 

cases, planting the sites with native species, a costly and difficult 

process, would offset the need for retreatment. The agency will reach a 

point where the monitoring of treated acres and retreatment will 

require 100 percent of its weed management budget.



Finally, we would like to make one technical comment. The draft report 

suggests that we should develop biological controls for potential 

invaders before they arrive in North America so those biological 

controls will be available for rapid responses. This would be extremely 

expensive, especially when you consider that some of the potential 

invaders may never reach our shores or may be intercepted at the ports 

of entry. More importantly, biological controls, even if they are 

available, are not an effective tool for rapid responses. Biological 

controls work very slowly and can reduce but not exterminate 

established populations. They would have little or no impact on 

incipient populations.



We appreciate the opportunity to offer our perspectives on the draft 

report.



[End of section]



Appendix IV: Comments from the Department of State:



United States Department of State Washington, D. C.	20520:



OCT 16 2002:



Dear Ms. Westin:



We appreciate the opportunity to review your draft report, “INVASIVE 

SPECIES: Clearer Focus and Greater Commitment Needed to Effectively 

Manage the Problem,” GAO-03-25, GAO Job Code 360158.



The Department’s comments are enclosed for incorporation as an appendix 

to the GAO final report, along with comments from the International 

Joint Commision (IJC). Please find technical comments attached as well.



If you have any questions, regarding this response, please contact Dana 

Roth, Office of Ecology and Terrestrial Conservation, Bureau of Oceans 

and International Environmental Scientific Affairs on (202) 736-7426.



Christopher B. Burnham:

Assistant Secretary of Resource Management and 

Chief Financial Officer:



Signed by Christopher B. Burnham:



Enclosure:



As stated.



cc: GAO/NRE - Mr. Wood State/OIG - Mr. Berman State/OES - Ms. Stephens:



Ms. Susan S. Westin, Managing Director, International Affairs and 

Trade, U.S. General Accounting Office.



Department of State Comments on GAO Draft Report:



INVASIVE SPECIES: Clearer Focus and Greater Commitment Needed to 

Effectively Manage the Problem, (GAO-03-25, GAO Code 360158):



The Department of State and the International Joint Commission (IJC) 

appreciate the opportunity to comment on the draft report INVASIVE 

SPECIES: Clearer Focus and Greater Commitment Needed to Effectively 

Manage the Problem, and both noted the comprehensiveness of the report. 

IJC’s comments follow those of the Department of State.



The Department of State places a high priority on accomplishing the 

goals of the National Invasive Species Management Plan, and this 

priority is reflected in the attention the Department has devoted to 

the invasive species issue and the progress we have made, as outlined 

below. At least in relation to the Department’s activities, we 

therefore do not fully concur with the finding of the GAO report that 

attributes slow progress on the management plan to lack of priority 

given to the plan by the Council and departments (e.g., p.32).



* Over the last four years, the Department of State has increased 

resources to work on the invasive species issue. Currently, there is an 

American Association for the Advancement of Science Fellow employed 

full-time in OES/ETC who works almost exclusively on this issue.



* The Department coordinates the inter-agency process for the 

Convention on Biological Diversity that addresses invasive alien 

species. The agencies have worked with the Department over many hours 

to develop a strong work program, and many agencies were actively 

engaged on this issue at this international meeting.



* The Department has funded several regional workshops with the Global 

Invasive Species Programme to help build cooperation to address this 

global problem. The Department with other USG agencies has helped 

facilitate the development of strategic plans to address the invasive 

species problem in several regions, including South and Southeast Asia, 

Southern Africa, Nordic-Baltic (which the Department has funded a 

follow-up workshop on information systems for invasive species), and 

South America. (“Recommendations” statements from our most recent 

workshops are attached, for your interest.):



* The Department is actively participating in the International 

Maritime Organization negotiations on development of ballast water 

standards (which is ongoing, Oct. 2002).



* The Department actively participates in the various relevant task 

teams set out in the National Invasive Species Management Plan and in 

the Advisory Committee meetings.



* The Department co-chairs the North America strategy task team, and 

participates in other North American fora that address invasive alien 

species.



* The Department takes an active role in raising awareness of the 

invasive species issue in bilateral and multilateral negotiations.



The following comments were provided by IJC:



The report highlights the sensitivity of the Great Lakes ecosystem to 

invasive species yet fails to recommend any action to protect this 

resource. Suggest that in its recommendations the GAO consider adding 

comment under action for executive.



In the face of the continuing invasion of the Great Lakes by invasive 

species, take action, in coordination with the government of Canada, to 

develop an effective approach to immediately improve the management of 

all ballast waters coming into the Great Lakes:



Add an action for Congress:



To continue strong support for invasive species control, promptly 

complete action on reauthorization of NISA.



Attachment: Final Recommendations, Arising from 2001 - 2002 Regional 

Workshops on Invasive Alien Species:



[End of section]



Appendix V: Comments from the National Invasive Species Council through 

the Department of the Interior:



United States Department of the Interior:



OFFICE OF THE SECRETARY Washington, D.C. 20240:



OCT 15 2002:



To: David G. Wood, Director of Natural Resources and Environment U.S. 

General Accounting Office:



Through: Dr. Jim Tate, Science Advisor to the Secretary U.S. Department 

of the Interior:



Mr. Tim Keeney, Deputy Assistant Secretary for Oceans and Atmosphere, 

U.S. Department of Commerce:



Dr. Jim Butler, Deputy Assistant Secretary for Marketing and Regulatory 

Programs, U.S. Department of Agriculture:



From: Lori Williams, Executive Director, National Invasive Species 

Council:



Subject: Council Comments on GAO report, Invasive Species:



Clearer Focus and Greater Commitment Needed to Effectively Manage the 

Problem (GAO-03-01) - DRAFT:



Attached are the comments of the National Invasive Species Council on 

the subject GAO report. This draft has also been sent to the Council 

member departments for their comment and approval. The co-chair 

departments are also providing separate comments to GAO.



I can be reached at 202-513-7243 should you need to discuss these 

comments further.



National Invasive Species Council Comments on the Draft GAO Report 

entitled, Invasive Species: Clearer Focus and Greater Commitment Needed 

to Effectively Manage the Problem (GAO-03-01):



Comments on Recommendations:



The Council concurs with the recommendation that the upcoming revision 

of the National Invasive Species Management Plan (Plan) the goal of 

incorporating information on the economic impacts and relative risks of 

different invasive species or pathways in the formulation of an 

invasive species crosscut budget. The Council notes that the current 

Plan (see, action items #44 and 46(a) under Research) calls for 

additional research on the economic impacts of invasive species, and 

increased emphasis on risk analysis (see: action items # 14, 15 and 19 

under Prevention). The Council also concurs with the note of caution 
that 

determining in advance what species are likely to be invasive through 

unintentional introductions could be problematic, as stated in the 
Department 

of Commerce comments on this section.



The Council agrees that better performance measures should, and will, 

be included in the revised version of the Plan. However, it is 

important to note that the Management Plan was this nation’s first 

attempt to draft a comprehensive blueprint on how to deal with invasive 

species issues across 23 Federal agencies and coordinate with state, 

local and private entities. The Plan has and continues to be used as a 

model for planning efforts by numerous states and other nations, 

including Canada. The Council is including performance measures in the 

current draft of the invasive species crosscut budget. It is also 

important to recognize that for many invasive species, baseline data 

may be lacking. Additionally, some activities essential to dealing with 

invasive species issues, including some elements of prevention (how do 

you confirm the absence of a species?), education and outreach, and 

research may not be easy to measure, at least in the near term. Despite 

these important caveats, the Council is supports including realistic 

and attainable performance measures as part of the revised Plan.



The Council concurs that action item # 1 of the Plan establishing a 

transparent oversight mechanism for use by Federal agencies in 

complying with Executive Order 13112, be given a high priority.



The Council concurs that an evaluation of whether there should be 

statutory authority for the Council should be conducted.



It is appropriate for the Council’s individual members to respond to 

the final recommendation concerning their individual annual performance 

plans. The Council stands ready to assist in this effort. The Council 

notes that each member department and agency operates on different 

timelines regarding their performance and strategic plan.



General Comments:



Although the Council agrees that progress to date on completing action 

items in the Plan has been disappointing and is taking steps to 

accelerate progress, it is important to realize that the deadlines in 

the Plan were optimistic, given current resources and funding. As noted 

in the comments of the Department of Commerce, the report fails to 

evaluate whether the original deadlines contained in the Plan were 

realistic and attainable. The report underestimates progress under the 

report in the following ways:



1) It sites as progress, only those items (except in a few noted cases) 

that have been competed. This is despite the fact that GAO gathered a 

significant amount of information from the Council staff and the 

departments about progress toward completion of 40 to 50 percent of the 

action items --in addition to those completed. Many of the items in the 

Plan represent ambitious, broad goals requiring multi-agency planning, 

implementation, and sign-off --and reporting on progress toward those 

goals is important. For example, progress toward achieving a common 

monitoring protocol for invasive plants represent a significant step, 

despite the need to complete work on other taxa.



2) Progress toward an action item under the Plan by departments and 

agencies --either individually or as a group --is significant progress; 

regardless of if complete coordination has occurred or if a specific 

Council task team has been formulated. This especially applies to those 

where one or more lead agencies are identified in the Plan. Now that 

implementation task teams have been formulated, they are utilizing and 

building upon the work has already done by individual agencies or 

departments. Prior progress achieved individually or collectively will 

significantly expedite future progress on action items that have been 

the focus of departmental and agency efforts. For instance, the 

Pathways task team is using lists of pathways already developed or 

being developed by a number of agencies as initial input for completing 

action item #20.



3) The status of the implementation teams (by Federal agency officials) 

was built upon the scoping teams’ work, and the entire process should 

be considered in the evaluation. This will be explained in more detail 

in the specific comments. In the scoping process, Federal members of 
the teams 

(representing all Council member departments and agencies, not the 

Council staff or liaisons) met and approved draft procedures, 

identified key stakeholders, set priorities for work. They also decided 

individually whether it was important to include nonFederal 

stakeholders in the formulation of their group. This was done in 

advance of the formulation and approval of joint Federal/nonFederal 

subcommittees and task teams under the Invasive Species Advisory 

Committee. Current implementation teams have relied upon this work to a 

great extent.



There seems to be a misunderstanding about the role and function of the 

Plan implementation task teams and subcommittees. It should be noted 

that specific actions under the Plan (in almost all cases) must be 

implemented by those specific agencies and departments with budgetary 

and regulatory authority or appropriate an authorized program. Those 

specific departments and agencies must carry out the actual 

implementation of details involved with each action item with 

responsibility. Therefore, the role of the implementation teams is to 

provide general, overall guidance, ensure all the key action agencies 

are identified, set priorities among the many items in the Plan and 

provide for coordination with outside groups and stakeholders, if 

appropriate.



In general, the report undervalues progress toward increased 

coordination and cooperation among Federal agencies and departments on 

invasive species. The Council has assisted with coordination of 

legislative issues and briefings related to invasive species. As noted, 

the current effort to draft an invasive species crosscut budget 

proposal for FY04 has resulted in significant coordination efforts on 

budget and performance management issues, especially among the three 

Co-chair departments. The report fails to note monthly meetings devoted 

to coordination among the ten Council member liaisons. Working closely 

with the State department, the Council assisted with coordination and 

formulation of international positions regarding the International 

Plant Protection Convention, and the Convention on Biological 

Diversity, among others. Further examples are contained in the specific 

comments below, and in the comments of individual member departments.



Specific comments:



P. 6 - It is important to clarify whether the report is referring to 

non-native, or invasive species.



P. 11-The Council does not have a Risk Analysis Specialist or a Website 

Coordinator currently on the staff, nor has either been identified as a 

future position. Richard Orr assisted with risk analysis while he was 

on detail with the Council and is included in the Plan as a Council 

staff member. The National Agricultural Library manages our website on 

a day-to-day basis. Along with his other duties, Chris Dionigi 

(Domestic Policy Assistant Director) currently manages the website for 

the Council. The Council Co-chairs are currently evaluating the 

Council’s staffing needs.



P. 13 - Note in discussion of economic impacts that action items 44(a) 

and 46(a) call for increased research at the national and international 

level on the economic impacts of invasive species.



P. 23 - The Council believes that the Plan is a very positive, initial 

overall blueprint for Federal action to deal with invasive species. It 

contains important elements that need to be implemented to address this 

serious problem. Future revisions of the Plan should, and will, include 

more specific performance criteria and address the perceived 

deficiencies in the Plan, which will improve the Plan overall.



P. 24 - Including a specific performance measure regarding reducing the 

introduction of new species by a certain percentage would be 

problematic at this time. We do not have baseline data indicating the 

number of introductions now occurring. This example demonstrates the 

challenge of measuring exact performance for prevention activities.



P. 24 -The draft report appears to emphasize the response of nine (as 

opposed to the majority of 17) respondents who said that the plan is 

focused on the most important issues? This response seems to indicate a 

strong degree of support by ISAC members for the Plan. In addition, the 

Council believes all the members of ISAC are “prominent” in there 

fields and therefore are chosen to serve on ISAC.



P. 25 - The second paragraph quote of the Executive Director is 

incomplete and misleading. The important factors are that this was the 

first attempt to draft a comprehensive, Federal blueprint for managing 

and dealing with a wide range of taxa of invasive species for 23 

Federal agencies. Given the scope of this first-time effort, it was 

unrealistic and difficult to also agree on specific measurable goals. 

(The current DAS for DOI was not present during the drafting or 

approval of the Plan. His statement is accurate, however it is 

important to note that the Plan underwent full departmental and OMB 

review as well as public notice and comment. Budget and performance 

management staff were not excluded from the process.):



P. 25 - The crosscut proposal for FY04 represents a very significant 

effort; however as a first attempt, it will not represent the totality 

of invasive species expenditures or efforts. It will emphasize certain 

efforts and primarily focus on the activities of the three Council Co-

chairs.



P. 26 - The Council has provided extensive information about the 

progress of departments and agencies in addressing action items in the 

Plan. Council staff has also provided oral updates at most ISAC 

meetings. GAO staff observed many of the ISAC meetings, during which, 

they were provided with much of this information. A written, overall 

summary of progress is due to be completed in the next month.



P. 31-Work sited here is being utilized by Council implementation task 

teams, and is part of the crosscut budget discussions. Progress by 

individual agencies is crucial to progress under the Plan. [See text of 

general comments]



P. 31-The Executive Director did not say that it was improper to 

‘debate the agencies’. The Director stated that while some of the 

agency reports did not seem to directly link to specific action items, 

many if not most of the agency actions were accurate and helpful 

progress reports. In the Director’s view, it is difficult and 

counterproductive for Council staff to second-guess agencies have the 

expertise in these areas and believe their actions are relative to the 

Plan. In addition, the reporting of invasive species activities (even 

if not directly linked to the Plan) is important for overall 

coordination purposes, and useful to the Council.



P. 32 - The Executive Director did not say that there was “no reason to 

form implementation teams” until after the Plan was finalized. The 

Council departments and OMB had not approved the final Plan, and all 

comments had not been incorporated. It would have been inappropriate to 

formulate teams to implement a Plan that had not been approved or 

finalized.



P. 32 - The timeline is missing an important bullet and many actions 

that took place before the expiration of the terms of the last ISAC. 

Also, ISAC as a body did not expire. The charter for ISAC was renewed, 

and therefore the Committee itself continued to exist. What expired 

were the terms of the former ISAC members. Now terms are staggered 

among members to avoid future problems (This action has already been 

taken).



The missing bullet concerns the request by Council Federal officials to 

consider whether, how and who should formulate Plan implementation 

teams. This process began in June and July of 2001, well before I SAC 

terms expired. Those Federal officials from the Council who were 

interested met to discuss each of the teams proposed at the 

Shepherdstown meeting. (See the “Scoping” memorandum and draft terms of 

reference provided by Council staff to GAO.) At the scooping meetings, 

Federal officials agreed upon draft terms of reference (or operating 

procedures), discussed lead agencies, set initial priorities, and 

decided (at each scooping meeting for each team) whether non-Federal 

members should be included and thus the team should be formulated under 

ISAC. In most cases, Federal members were designated after these 

meetings. In all cases, the scoping meetings concluded non-Federal 

participation was desirable.



P. 33 - By the time scooping was completed for all the teams in the 

fall, the process for choosing new ISAC members had begun. This did 

result in a delay of further meetings as suggested until the new ISAC 

was formulated and met in May and June 2002. The teams that have met 

thus far have relied greatly on the earlier work done by the Federal 

scooping meetings.



Final bullet should read, “all but two of the teams (International and 

Budget) include both Federal and non-Federal members.”:



As clarified above, the Executive Director did not state that there was 

any single decision made at one time to include non-Federal members on 

all implementation teams. In addition, Federal members made decisions 

during scoping; and by ISAC members for each individual team. The 

importance of getting consensus and participation by key stakeholders 

has been a critical factor in the decision making process.



P. 34 - Please see the Council’s General Comments about the 

misunderstanding of the role of the implementation teams. The ISAC does 

not have the authority in their Charter or otherwise to make decisions 

about implementing the plan at the Federal level. Those specific 

decisions are made by the appropriate agencies and departments with the 

legislative, budgetary and regulatory authority to take such actions. 

The implementation teams might more properly be termed “implementation 

guidance teams” and are not:



charged with making the type of decisions GAO references in this 

paragraph as inappropriate and outside the scope of ISAC’s charter.



The Council agrees that the delays have been unfortunate, but believes 

strongly in the value of getting stakeholder input, assistance and 

expert guidance in determining how many elements of the Plan should be 

implemented. Invasive species is not solely, or even primarily a 

Federal problem. Solutions cannot be solely Federal and would be 

successful if implemented in a vacuum. The Council supports looking 

carefully at the Plan action items to be implemented, and determining 

the best mechanism on a case-by case basis rather than excluding non-

Federal members from all Plan implementation guidance teams.



[End of section]



Appendix VI: Comments from the Environmental Protection Agency:



UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460:



OCT 11 2002:



Mr. David C. Wood:

Director, Natural Resources and Environment U.S. General Accounting 

Office Washington, DC 20548:



Dear Mr. Wood:



Thank you for the opportunity to comment on the General Accounting 

Office (GAO) draft report entitled, Invasive Species: Clearer Focus and 

Greater Commitment Needed to Effectively Manage the Problem (GAO-03-

01), received on September 25, 2002.



As requested in your recent letter to Administrator Whitman, we are 

pleased to provide EPA’s comments on the draft report. These were 

developed by our intra-agency Non-indigenous Species Work Group, 

comprised of representatives from our programs as well as our regional 

offices. The work group is very familiar with the invasive species 

problem and has been involved in the development of the Management Plan 

(hereinafter referred to as “the Plan”) pursuant to the Executive Order 

13112 on Invasive Species.



While the recommendations in the report seem reasonable, the 

conclusions are based on a survey of only 23 respondents. Nonetheless, 

we believe adoption of the recommendations would enhance the federal 

government’s approach to dealing with the problem of invasive species. 

The draft report is especially noteworthy because it: (1) highlights 

why existing analyses of the economic impacts of invasives are of 

limited use to decision-makers; (2) describes why good models must be 

developed to predict the spread of invasives as well as their ecosystem 

and economic impacts; (3) highlights how few resources agencies are 

allocating to invasives’ activities; and (4) highlights major 

limitations of the National Invasive Species Management Plan, including 

the fact that it isn’t a strategic plan with measurable goals and 

environmental outcomes, but is instead an inventory of planned agency 

actions.



Although the report is a curious mix of economic theory, ballast water, 

and a review of the National Invasive Species Council (NISC), we found 

it to be well-written and helpful in assessing the progress made in 

coping with invasive species. We believe the report could be 

strengthened, however, if it focused more on the NISC and the Plan. In 

particular, we suggest that the report focus on four questions: (1) is 

the NISC being managed efficiently given the various limitations; (2) 

do the members have sufficient resources (budget and full-time 

equivalents) to achieve their action items; (3) what progress has been 

made to achieve their action items; and (4) is the extent of progress 

commensurate with available resources?



Recycled/Recyclable . Printed with Vegetable Oil Based Inks on 100% 

Recycled Paper (40% Postconsumer):



In addition to these general comments, there are several issues that we 

want to bring to your attention.



1. We believe that members of the Invasive Species Advisory Committee 

(ISAC) should not serve on federal committees intended to implement the 

Plan. While EPA salutes the excellent job the NISC and its staff have 

done to reach out to constituent groups and stakeholders, mixing 

federal with non-federal staff on implementation committees has, in our 

opinion, led to some confusion and delays in implementing the Plan. It 

is the federal government that is responsible for implementing the 

Executive Order and not a Federal Advisory Committee (FACA). A FACA can 

only advise and should not be responsible for implementation.



2. As previously stated, we believe that GAO’s somewhat critical view 

of the Plan and the concern over the lack of progress in implementing 

the Plan are based on a survey of only 23 respondents. Further, these 

respondents were or are members of the ISAC and likely do not have 

unbiased perspectives. While it is true that the pace of implementation 

has not been as fast as the immigration of new invasives, we wonder if 

it is suitable to base the conclusions on such a small sample. The tone 

of the GAO report might be different if more of the federal agency 

staff and state resource managers were surveyed.



3. While the concept of performance measures is laudable, in most cases 

they will have to be regional and species specific. An example with 

vector control might be “to reduce the rate of new introduction into 

San Francisco Bay by 50% by 2010.” But these standards would not apply 

to other west coast ports, which have different invasion rates, 

susceptibility, etc. Also, in many cases (except perhaps with 

agricultural pests), we do not have the baseline information to 

determine if we have achieved the standard. As written, the draft 

report comes across somewhat voluble regarding performance standards. 

We believe the document should recognize the difficulties of 

identifying and measuring performance standards in ecological systems 

being stressed by a highly stochastic stressor.



4. We believe the ballast water section is very “Great Lakes centric.” 

We realize that there has been much attention given to the Great Lakes, 

but there is also work being done in marine and estuarine waters. The 

effects of invasive species on these ecosystems should be expanded, and 

the need for research, prevention, and control in this area should 

receive more emphasis. The Smithsonian Environmental Research Center 

maintains a clearinghouse of information related to biological 

invasions from ballast water discharges.



In addition to these general comments, we have enclosed detailed 

comments on specific portions of the text that should provide 

additional clarification of EPA’s position on key issues raised by the 

draft report.



We appreciate the opportunity to respond to this draft report. Should 

you have questions of would like additional information, please contact 

Mr. Michael Slimak on 202-564-3324 or slimak.michael@epa.gov.



Paul Gilman:



Science Advisor to the Agency:



Signed by Paul Gilman:



[End of section]



FOOTNOTES



[1] A concept basic to invasiveness is that these species have been 

introduced into an environment in which they did not evolve; thus, they 

usually have no natural enemies to limit their spread.



[2] U.S. General Accounting Office, Invasive Species: Federal and 

Selected State Funding to Address Harmful Nonnative Species, GAO/

RCED-00-219 (Washington, D.C.: Aug. 2000) and Invasive Species: 

Obstacles Hinder Federal Rapid Response to Growing Threat, GAO-01-724 

(Washington, D.C.: July 2001).



[3] Council members include the Secretaries of State, Defense, 

Treasury, Agriculture, Commerce, Transportation, Health and Human 

Services, and the Interior, and the administrators of the Environmental 

Protection Agency and the U.S. Agency for International Development. 

The Secretaries of Agriculture, Commerce, and the Interior are the 

cochairs of the council.



[4] Ballast water is deliberately pumped into tanks within a ship to 

control or maintain the trim, draft, stability, or stresses of the 

vessel. Because ballast water is pumped from oceans or rivers, it can 

contain living aquatic organisms found in those locations.



[5] GAO/RCED-00-219.



[6] See GAO/RCED-00-219. The Department of the Treasury’s Customs 

Service, the Department of Health and Human Services, and the 

U.S. Agency for International Development also have expenditures 

related to invasive species but were not included in our report.



[7] The Secretary of Health and Human Services and the Administrator of 

the U.S. Agency of International Development were not specifically 

named as members of the council by the executive order, but were 

invited to join as permitted by the executive order. The Secretary and 

Administrator joined the council in February 2001.



[8] See Voluntary Guidelines for the Control of Ballast Water 

Discharges from Ships Proceeding to the St. Lawrence River, which were 

superceded in 2000 by the Guidelines for the Control of Ballast Water 

Discharge from Ships in Waters Under Canadian Jurisdiction and amended 

in 2001. Even though the guidelines are voluntary, the Canadian Coast 

Guard can impose a fine under the Canada Shipping Act for an operator 

who knowingly provides false information to a vessel traffic regulator.



[9] P.L. 101-646 (1990), as amended by the National Invasive Species 

Act of 1996, P.L. No. 104-332 (1996), codified at 16 U.S.C. §§ 

4701-4751.



[10] 33 C.F.R. §§ 151.1500-151.1516.



[11] While we examined estimates of the impact of invasive species with 

respect to their scope and methodology, we did not attempt to verify 

the accuracy of the estimates of economic impact.



[12] Federal Interagency Committee for the Management of Noxious and 

Exotic Weeds, Invasive Plants: Changing the Landscape of America, Fact 

Book, Washington, D.C.: FICMNEW, 1998.



[13] All dollars in this section were adjusted to 2001 dollars unless 

otherwise noted.



[14] Economic damages to natural ecosystems are measured in terms of 

individuals’ willingness to pay for the goods and services provided by 

an ecosystem. For example, the gain in value associated with a specific 

improvement in environmental quality, such as a day of birding in a 

natural ecosystem that has been freed of invasive species, is measured 

by an increase in people’s willingness to pay for this experience.



[15] Lee and Chapman, Nonindigenous Species-An Emerging Issue for the 

EPA, Vol. 2, U.S. EPA, May 2001, available on the Web from http://

www.epa.gov/owow/invasive_species/workshop/nisvol2.pdf.



[16] U.S. Congress, Office of Technology Assessment, Harmful Non-

Indigenous Species in the United States, OTA-F-565, Sept. 1993, 

available on the Web from http://www.wws.princeton.edu/~ota/disk1/

1993/9325_n.html.



[17] Pimentel et al., “Environmental and Economic Costs Associated with 

Non-Indigenous Species in the United States,” BioScience, Jan. 2000. 

This estimate has not been adjusted for inflation. The researchers 

combined dollar estimates representing different years from different 

studies without adjusting them for inflation.



[18] USDA, APHIS, Pest Risk Assessments: Pest Risk Assessment for 

Importation of Solid Wood Packing Materials into the United States, 

App. B: Case Histories of Previous Introductions of Forest Pests, 

Aug. 2000, available on the Web from http://www.aphis.usda.gov/ppq/

pra/swpm/.



[19] Hirsch and Leitch, “The Impact of Knapweed on Montana’s Economy,” 

Agricultural Economics Report No. 355, Department of Agricultural 

Economics, North Dakota State University, July 1996.



[20] Lafferty and Kuris, “Biological Control of Marine Pests,” Ecology, 

77(7), Oct. 1996.



[21] Lafferty and Kuris.



[22] Quinn, “Workshop on development of regional invasive species 

information hubs in North America and Southern Africa,” Aliens 

newsletter, World Conservation Union, No. 13, 2001, available on the 

Web from http://www.issg.org/aliens_newsletter/Aliens13.pdf.



[23] National Science and Technology Council, Committee on Environment 

and Natural Resources, Ecological Risk Assessment in the Federal 

Government, CENR/5-99/001, Chapter 4: Nonindigenous Species, May 1999, 

available on the Web from http://www.nnic.noaa.gov/CENR/ecorisk.pdf.



[24] Nico and Williams, “Risk Assessment on Black Carp,” USGS, Report 

to the Risk Assessment and Management Committee of the Aquatic Nuisance 

Species Task Force, Oct. 1996.



[25] 67 Fed. Reg. 49280 (July 30, 2002).



[26] Orden, Narrod, and Glauber, “Least Trade Restrictive Sanitary and 

Phytosanitary Policies: The Analytic Framework Is There, the Specific 

Answers Are Not,” Oct. 2000, available on the Web from http://

www.usda.gov/agency/oce/oracba/papers/orden.htm.



[27] 60 Fed. Reg. 34832 (July 3, 1995).



[28] 62 Fed. Reg. 24753 (May 6, 1997).



[29] Leuschner et al., “Potential Benefits of Slowing the Gypsy Moth’s 

Spread,” Southern Journal of Applied Forestry, 20(2), 1996.



[30] Halstead et al., “An Hedonic Analysis of the Effects of an Exotic 

Invader (Myriophyllum heterophyllum) on New Hampshire Lakefront 

Properties,” paper presented at the Annual Conference of the 

Northeastern Agricultural and Resource Economics Association, Bar 

Harbor, Maine, June 2000.



[31] Cohen, “Evaluating the Risks of Importation of Exotic Pests Using 

Geospatial Analysis and a Pest Risk Assessment Model,” Proceedings of 

the First International Conference on Geospatial Information in 

Agriculture and Forestry, Lake Buena Vista, Florida, June 1998, 

available on the Web from http://www.aphis.usda.gov/ppd/

evaluating.pdf, (building on Orr et al., “Generic NonIndigenous Pest 

Risk Assessment Process,” USDA, APHIS, Nov. 1993).



[32] Ahl, “The Role of Risk Analysis in Integrated Pest Management,” in 

K. Smith, Reducing Environmental and Health Risks from Agricultural 

Chemicals; Policy Considerations, available on the Web from http://

ers.usda.gov/publications/mp1542/MP1542e.PDF.



[33] The task force was established pursuant to the Nonindigenous 

Aquatic Nuisance Control and Prevention Act of 1990 to coordinate 

government efforts related to nonindigenous aquatic species in the 

U.S.with regional, state, and local entities. It is cochaired by the 

Fish and Wildlife Service and the National Oceanic and Atmospheric 

Administration. “Generic Nonindigenous Aquatic Organisms Risk Analysis 

Review Process,” report to the Aquatic Nuisance Species Task Force, 

Oct. 1996, available on the Web from http://www.anstaskforce.gov/

gennasrev.htm.



[34] Aquatic Nuisance Species Task Force, “Guidance for State and 

Interstate Aquatic Nuisance Species Management Plans,” Nov. 2000, 

available on the Web from http://www.anstaskforce.gov/

state_guidance.htm.



[35] Keppner and Caplen, “A Prevention Program for the Mediterranean 

Strain of Caulerpa taxifolia,” submitted to the Aquatic Nuisance 

Species Task Force, Aug. 1999, available on the Web from http://

www.anstaskforce.gov/Caulerpa.htm.



[36] National Plant Board, Preventing the Introduction of Plant 

Pathogens: The Role and Application of the “Systems Approach” (draft 

document), Feb. 2002, available on the Web from http://

www.aphis.usda.gov/ppq/systemsapproach/.



[37] Risk Assessment Review Standards, USDA Animal and Plant Health 

Inspection Service, Aug. 2001.



[38] National Invasive Species Council, Meeting the Invasive Species 

Challenge: Management Plan, 2001.



[39] P.L. 103-62 (1993).



[40] The plan called for several of the actions to start by a certain 

date, while most were to be completed by a certain date.



[41] To avoid the problem of the advisory committee becoming 

temporarily inactive, the Executive Director told us that the council 

has modified the terms of the advisory committee members so that half 

have 2-year terms and half have 3-year terms. As a result, the 

committee will operate continuously.



[42] The council’s budget summary did not include data for all relevant 

agencies. Missing were data from the Army Corps of Engineers, the 

Environmental Protection Agency, and the Bureau of Reclamation.



[43] These requirements also apply to ships traveling in the Hudson 

River north of the George Washington Bridge in New York. The National 

Invasive Species Act also tasked the Secretary of Transportation with 

promulgating voluntary national ballast water guidelines. On May 17, 

1999, the Coast Guard promulgated interim voluntary guidelines, 

including ballast water exchange, applicable to vessels entering U.S. 

waters from outside the Exclusive Economic Zone and calling on U.S. 

ports other than those in the Great Lakes or on the Hudson River. The 

guidelines became final December 21, 2001. They also require that 

arriving ships report information on their ballast water, although they 

do not impose penalties for nonreporting.



[44] The National Invasive Species Act currently allows vessels to use 

alternative environmentally sound ballast water management methods but 

requires that they be “as effective as ballast water exchange” in 

preventing and controlling the influx of aquatic organisms; under the 

regulations, the Coast Guard Commandant must first approve their use. 

To date, no alternative methods have been approved.



[45] In contrast, compliance with the mandatory reporting requirements 

that apply to the rest of the country has been low. A Coast Guard 

official testified before the Congress on May15, 2002, that the 

consistently low rate of reporting makes it impossible to accurately 

assess compliance and effectiveness. Congress mandated that the 

voluntary ballast management guidelines become mandatory if the 

Secretary of Transportation determines that compliance is low.



[46] As with an earlier shipborne invader known as the spiny water flea 

(Bythotrephes cederstroemi), scientists are studying the fish-hook 

water flea’s impact on zooplankton biomass. Zooplankton is a common 

item in young fishes’ diets and the fish-hook water flea has the 

potential to disrupt fish populations by preying on their food supply. 

In addition, the fish-hook water flea clumps together into large mats 

that tangle fishing lines, which could adversely affect the commercial 

and recreational fishing industries. The amphipod Echigogammarus 

ischnus was first discovered in the Detroit River in 1995, where it 

occupied a habitat typical of the native amphipod Gammarus fasciatus, 

suggesting the possibility of competition between the two species.



[47] The salinity of seawater varies in various parts of the ocean from 

30 to 39 parts per thousand, but is fairly close to 35.5 parts per 

thousand in the middle of the North Atlantic.



[48] 67 Fed. Reg. 8885 (Feb. 27, 2002).



[49] A recent study analyzing the market for future treatment 

technologies reported that there are over 47,000 vessels in the world 

fleet where ballast water treatment technologies could be applicable.



[50] The Boundary Waters Treaty of 1909 established the International 

Joint Commission. The treaty established the commission to, among other 

things, advise the U.S.and Canadian governments concerning 

transboundary water quality issues. The commission has six members; 

three appointed by the President of the United States, with the advice 

and approval of the Senate, and three appointed by the Governor in 

council of Canada, on the advice of the Prime Minister. The Great Lakes 

Fishery Commission was created in 1955 by the Convention on Great Lakes 

Fisheries between the U.S.and Canada.



[51] The National Invasive Species Act is due for re-authorization in 

2002. House and Senate re-authorization bills, H.R. 5396 and S. 2964, 

respectively, were introduced on September 18, 2002.



[52] The commission also recommended that the governments of the United 

States and Canada develop uniform protocols for performance testing of 

ballast water and ensure that all ships built after a certain date have 

treatment technology incorporated into their construction to be allowed 

entry into the Great Lakes.



[53] Several states outside the Great Lakes have passed ballast water 

legislation, including California, Hawaii, Maryland, Oregon, Rhode 

Island, and Washington. None of these laws require sterilization.



[54] 40 C.F.R. § 122.3(a). This program regulates pollutant discharges 

to the nation’s waters.



[55] The IMO is an organization of 160 member countries with observers 

from governmental, industry, environmental, public interest, and labor 

organizations. To achieve its objectives, the IMO has promoted the 

adoption of some 30 conventions and protocols, and has adopted well 

over 700 codes and recommendations concerning maritime safety, the 

prevention of pollution, and related matters.



[56] The Coast Guard has estimated the impact of ballast water 

regulations on the shipping industry but has not done a comprehensive 

analysis of the benefits that the regulations would yield or the costs 

of inaction. The only specific economic impact cited by the Coast Guard 

as justification for the regulations was the cost of the zebra mussel 

infestation.



[57] Great Lakes Water Quality Board, Report to the International Joint 

Commission, Alien Invasive Species and Biological Pollution of the 

Great Lakes Ecosystem (Windsor, Ontario: May 2001).



[58] Knight et al., Detection and Enumeration of Fecal Indicators and 

Pathogens in the Ballast Water of Transoceanic Cargo Vessels Entering 

the Great Lakes, 1999.



[59] According to EPA, in 1998, the United States and Canada called 

upon the International Joint Commission to help the two countries 

develop and implement new and improved binational approaches to manage 

and protect major shared watersheds. Aquatic invasive species would be 

covered by this long-term initiative.



[60] The Great Lakes Panel is made up of U.S. and Canadian federal 

officials and representatives from the eight Great Lakes states and the 

province of Ontario.



[61] U.S. General Accounting Office, Foot and Mouth Disease: To Protect 

U.S. Livestock, USDA Must Remain Vigilant and Resolve Outstanding 

Issues, GAO-02-808 (Washington, D.C.: July 2002).



[62] The term “phytosanitary” refers to measures taken to prevent the 

introduction and/or spread of plant pests.



[63] The task force does have Canadian representation in an “invited 

observer” status.



[64] This organization was created under the auspices of the North 

American Agreement on Environmental Cooperation, which complements the 

environmental provisions of the North American Free Trade Agreement.



[65] Member agencies are the U.S. Fish and Wildlife Service, the 

Canadian Wildlife Service, and Mexico’s Ministry of Environment and 

Natural Resources.



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