5/29/24
Dear HISC Council Members,
I am writing to support adoption of a new subtitle and new chapters under Hawaii Administrative
Rules as Title 13, Subtitle 14, Chapters 325 “General Provisions” and 326 “Control and Eradicationof Invasive Species,” to effectuate chapter 194, Hawaii Revised Statutes, including a list of invasive
species that may be controlled on private and public property by the State, a county, or their agents.
As a resident of Hawaii and worker in conservation for the past 30 years, I have been actively
involved in efforts to protect the natural and cultural resources of our island home, and the uniqueplants and animals that are found nowhere else on earth. While I have been heartened by thestrides made in ecosystem and species preservation, I have been equally dismayed by the everworsening crisis of newly established invasive species that threaten to reverse or undo many of our
successful and ongoing conservation endeavors. Despite the collective efforts of public and private
agencies and organizations, devastating invasive pests and pathogens, such as the coconut
rhinoceros beetle, the fungal pathogens causing rapid ohia death, and ﬁre-promoting grasses likefountain grass, continue to establish and spread beyond their current known ranges and expand
their harmful impacts to new locations statewide.
While I am not naïve enough to think that adoption of new administrative rules will be sufficient tosolve this existential invasive species problem, I believe that we are long past the “all hands ondeck” moment of this crisis, and that every step taken to remedy this problem is a step in the right
direction. This problem is much bigger than any single agency can solve. Adopting theadministrative rules and establishing a process that gives HISC the ability to create lists of invasive
species for control or eradication by the State, a county, or their agents, as required by law, is theleast that can be done at this point.
I therefore urge you to consider taking all the necessary steps to proceed with the adoption of theadministrative rules, and look forward to attending public hearing on this critical matter in thefuture.
Mahalo for your consideration,
Chuck Chimera
Honokaa, HI
cgchimera@gmail.com

PO Box 22192
Honolulu, Hawai‘i 96823-2192

To: Co-Chair Chang, Co-Chair Hurd, and members of the Hawaii Invasive Species Council(HISC)
From: The Wildlife Society, Hawaii Chapter

Re: Agenda item 6: Request for approval to initiate rulemaking proceedings, including
conducting public hearings on adoption new subtitle 13-14. Hawaii Administrative Rules, toeffectuate chapter 194, Hawaii Revised Statutes (HRS), including by developing a list ofinvasive species that could be controlled or eradicated on private and public property by thedepartments of the Hawaii Invasive Species Council or a county or agent thereof;____________________________________________________________________________The Wildlife Society (TWS), Hawaii Chapter is in strong support of the HISC request to
initiate the rulemaking process to make active parts of chapter 194, Hawaii Revised
Statutes (HRS) including the development of a list of invasives species that can then becontrolled or eradicated on private and public property by HISC departments, counties,or their agents.
TWS is composed of wildlife professionals within the State of Hawai‘i and is dedicatedto the conservation and preservation of flora and fauna endemic to the HawaiianIslands.
Since being established in 2003, the HISC has had under its duties given by HRS
section 194-2(a)(6) the mandate to, “Identify and record all invasive species present inthe State”. Although the language did not specify how this needed to be done, a list ofinvasive species maintained by the HISC would reasonably fill that role. This is not tosay that the member departments of the HISC don’t already maintain lists that containinvasive species. These include the Hawaii Department of Agriculture’s list of Prohibited
Species and the Department of Land and Natural Resources’ Injurious Wildlife List.
However, it has been unclear if using those department lists could justify using theprivate and public property entry provisions of HRS sections 194-5 and 194-6.

TWS is supportive of establishing an invasive species list under the HISC and instead ofrecreating the list from scratch, make a process to automatically incorporate species
that have already been on existing lists as they are now and be added to the HISC listas these other lists are updated in the future. This should not preclude the HISC fromestablishing its own means to add to its invasive species list but would help get the list
established more quickly and be updated in the future.
The TWS is also supportive of the HISC members and their agents being able to use
HRS sections 194-5 and 194-6 to access private and public lands as well as compelling
the landowners and managers to remove invasive species known to be there. Being
unable to do so has hindered efforts to control and eradicate invasive species in atimely manner and has significantly reduced the effectiveness of HISC staff to prevent
further establishment and spread of priority invasive threats.
We understand initiating the rulemaking process is just the beginning. TWS supports
this effort and will be looking forward to participating in the public hearings as they areannounced.
Mahalo for the opportunity to comment on this submittal. Should you have any further
questions please contact our Conservation Affairs Chair, Patrick Chee at
tws.hi.cac@gmail.com .