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# 52013SC0321

**COMMISSION STAFF WORKING DOCUMENT IMPACT ASSESSMENT Accompanying the document Proposal for a Council and European Parliament Regulation on the prevention and management of the introduction and spread of invasive alien species This report commits only the Commission's services involved in its preparation and does not prejudge the final form of any decision to be taken by the Commission /\* SWD/2013/0321 final \*/**

  

COMMISSION STAFF WORKING DOCUMENT

IMPACT ASSESSMENT

Accompanying the document

Proposal for a Council and European
Parliament Regulation on the prevention and management of the introduction and
spread of invasive alien species

This report commits only the
Commission's services involved in its preparation and does not prejudge the
final form of any decision to be taken by the Commission

Contents

1.      Introduction.. 4

2.      Procedural
Issues and Consultations.. 5

2.1.        Procedural issues. 5

2.2.        Consultation of interested parties. 5

2.3.        External expertise. 5

2.4.        Consultation of the Impact Assessment
Board.. 6

3.      Policy
context, Problem definition and Subsidiarity.. 6

3.1.        Problem definition.. 6

3.1.1.     An
ecological problem.. 7

3.1.2.     A policy
problem.. 11

3.2.        Who is affected and how?. 12

3.3.        Policy baseline. 14

3.4.        How will the problem evolve?. 17

3.5.        The EU's right to act and
justification.. 19

3.5.1.     The legal
basis for action. 19

3.5.2.     Promoting
solidarity. 20

3.5.3.     Subsidiarity. 20

4.      Objectives.. 21

5.      Description
of Policy Options.. 22

5.1.        Option 0 - Business as Usual
(baseline option) 22

5.2.        Option 1 – Enhancing cooperation and
supporting voluntary action.. 24

5.3.        Option 2 – A dedicated legislative
instrument.. 24

5.3.1.     Option
2.1: the basic legislative instrument 27

5.3.2.     Option 2.2:
introducing provisions on permits for the release of IAS of Member State
concern (i.e. basic legislative instrument with the addition of action C2). 29

5.3.3.     Option
2.3: introducing a strict ban on the release of any alien species, unless
included on an EU list of IAS approved for release (i.e. basic legislative
instrument with the addition of action C3). 30

5.3.4.     Option
2.4: introducing an obligation for rapid eradication of newly establishing IAS
of EU concern, with the possibility for derogations (i.e. basic legislative
instrument with alternative action D3). 30

6.      Analysis of the Options.. 32

6.1.        Economic impacts. 33

6.1.1.     Option 0:
Baseline. 33

6.1.2.     Option 1:
Cooperation and voluntary action. 34

6.1.3.     Option
2.1: the basic legislative instrument 35

6.1.4.     Option
2.2: Adding permits for releasing of IAS of Member State concern. 43

6.1.5.     Option
2.3: Include a strict ban on release of any alien species into the environment
unless it is included in a common EU list of species approved for release into
the environment 45

6.1.6.     Option
2.4: Obligation to rapidly eradicate newly establishing IAS of EU concern. 45

6.2.        Social impacts. 48

6.2.1.     Option 0:
Baseline. 48

6.2.2.     Option 1:
Cooperation and voluntary action. 48

6.2.3.     Option
2.1: The basic legislative instrument 48

6.2.4.     Option
2.2: Adding permits for releasing of IAS of Member State concern. 48

6.2.5.     Option
2.3: Introducing a strict ban for any release of any alien species unless
included in the  EU list of species approved for release into the environment 48

6.2.6.     Option
2.4: Obligation for rapid eradication of newly establishing IAS of EU concern. 48

6.3.        Environmental impacts. 48

6.3.1.     Option 0:
Baseline. 48

6.3.2.     Option 1:
Voluntary action. 48

6.3.3.     Option
2.1: The basic legislative instrument 48

6.3.4.     Option
2.2: Adding permits for releasing of IAS of Member State concern included in
national catalogues  48

6.3.5.     Option
2.3: Introducing a strict ban for any release of any alien species unless
included in the EU list of species approved for release into the environment 48

6.3.6.     Option
2.4: Obligation for rapid eradication of newly establishing IAS of EU concern. 48

7.      Comparing
the different Options.. 48

8.      Monitoring
and evaluation.. 48

8.1.        Progress indicators. 48

8.2.        Monitoring.. 48

8.3.        Evaluation.. 48

1.           Introduction

Alien species are
species that are transported, outside of their natural range across ecological
barriers, due to direct or indirect human action. Some of these species cannot
adapt to the new environment and die out quite rapidly, but others may survive,
reproduce and spread. A percentage of the species that become established can
have a significant negative impact on the ecology of their new location as well
as serious economic and social consequences: these are the Invasive Alien
Species (IAS). It has been estimated that of the 12,046 alien species
present in the European environment[1], 10-15 % have
reproduced and spread and cause environmental, economic and/or social damage[2].

IAS have significant
consequences for biodiversity and are considered to be second in importance
only to habitat loss as a driver of biodiversity loss and recognised as
being a major cause of species extinctions[3]. It is expected
that biological invasions in Europe will only increase[4]. When it
comes to social and economic impacts, IAS can be vectors of diseases or
directly cause health problems (e.g. asthma, dermatitis, allergies). IAS
can damage infrastructure and recreational facilities and hamper forestry or
cause agricultural losses, to mention but a few examples. IAS are estimated
to have cost the EU at least €12 billion/year over the past 20 years[5], and the
damage costs continue to increase.

Invasive Alien Species
may be introduced for a purpose or come into Europe accidentally, through
different pathways[6]. Roughly one
quarter of the IAS already present in Europe were intentionally introduced:
they were traded for a purpose, e.g. as ornamental plant species, as pet
species, for forestry or agriculture or as biocontrol agents. They had
therefore an economic value or yielded certain benefits that made them
desirable[7]. The
remaining three quarters of IAS came into the EU unintentionally, i.e.
accidentally either as contaminants of other commodities (e.g. ragweed seeds in
bird feed mixtures) or as “hitchhikers” and “stowaways” linked to people
travelling or transport vectors (e.g. organisms introduced via ballast water).

Seeing the economic
damage they cause, Member States are taking a number of measures to
tackle IAS, at an expense of around €1.4 billion/year. Action is
predominantly reactive, seeking to minimise the damage already being caused
without sufficient attention to prevention or to detect and respond to new
threats. Efforts are fragmented, not covering all EU and often poorly
co-ordinated, which means that their overall effectiveness is reduced.

While acknowledging that
it will not be possible to address or prevent the entry of all IAS at all
times, there is ample scope for a prioritised and proportionate approach that
would be introduced gradually and that builds on the existing efforts whilst
increasing the efficiency and effectiveness of current action. Such an approach
can respect subsidiarity by improving the coordination of the current
efforts whilst leaving suitable freedom to Member States to respond to their
own geographical circumstances. At the same time, a coordinated and
increasingly prioritised approach can allow for a shift towards a more
preventive approach and in so doing increase the efficiency of actions, and
over time could lead to lower damage costs and costs of action[8].

2.           Procedural
Issues and Consultations

2.1.        Procedural
issues

In 2008 the European Commission
published a Communication
"Towards an EU Strategy on Invasive Species (2008)" setting out
the case for tackling IAS. The 2010 Communication "Our life
insurance, our natural capital: an EU biodiversity strategy to 2020"
proposes action on IAS. Both Communications were preceded and followed by intensive
rounds of consultation. In preparing this Impact Assessment, a dedicated
Inter-Service
Steering Group was established within the Commission (see Annex I).

2.2.        Consultation of interested parties

A series of
intensive rounds of stakeholder consultations took place between
2008 and 2012, which attracted the whole spectrum of interested parties, from
nature conservation organisations to operators in the private sector, including
organisations representing Small and Medium-sized Enterprises (SMEs) relying on
alien species for their business. Main comments are provided in the
following sections and details in Annex II.

An online public
consultation held in 2008[9] showed
widespread backing for action on IAS at EU level. 91 % of respondents agreed on
the urgent need to bring in new measures to prevent the spread of such
organisms and 86 % thought that Member States should be legally obliged to take
action against the most harmful IAS. The same year, a working group of
Commission services, Member States and stakeholders produced a discussion paper[10] bringing
together the latest information and summarizing opinions on key issues. A
second online consultation focused on specific policy options was held from end
January to mid-April 2012 and attracted 5101 replies.

A stakeholder
consultation meeting was held in September 2010[11], followed in
2010-2011 by three working groups, which elaborated possible policy options to
address respectively prevention, early warning/rapid response and the
management of established species[12]. The stakeholder
consultation and the working groups were attended by Commission services, a
wide range of stakeholder groups, representatives from Member States and
experts from different backgrounds.

2.3.        External expertise

Over the last
five years the Commission's work on IAS has been supported by several external
studies and research[13]. In
particular, the EU-funded research project DAISIE[14] compiled an
inventory of  alien species in the EU. The Joint Research Centre is now
developing the European Alien Species Information Network (EASIN) to facilitate
the exploration of existing alien species information from distributed sources[15]. The
European Environment Agency has also been conducting projects in this area.
Annex III provides more details on this scientific work.

Furthermore,
all analysis performed in this report was based on scientifically robust data.
The major part of the data used to describe the problem and to analyse impacts
and costs was retrieved from peer reviewed scientific articles. Information on
damage cost, spread of species and the costs of measures in place were also
provided or checked by Member States. Particular efforts were put into
contacting directly the stakeholders involved in this issue, including those
sectors that may be negatively impacted by the introduction of measures to
tackle the IAS problem. Finally, the analysis also benefitted from the input of
the world's top experts on IAS within and beyond the EU, which provided
precious information and data on all aspects addressed by this report.

2.4.        Consultation
of the Impact Assessment Board

This impact
assessment has been discussed at the 05/12/2012 meeting of the IA Board. The
recommendations of the Board in the quality checklist and in its formal opinion
have allowed improving the report. The following elements were addressed:

·
Problem
definition: while ultimately what needs to be solved is an ecological problem,
it has been made clearer that what the EU action needs to address is a policy
failure brought about by a very fragmented policy framework at European and
national levels. From this new perspective, the text has improved the
distinction between the problem, the drivers and the consequences. , the ;

·
Definition
of objectives: the formulation of the objectives and their relation to each
other were clarified, namely through the introduction of tables. The evaluation
arrangements were also re-formulated and clarified;

·
Design
of the options: the design, assessment and comparison of options was
strengthened. In particular the text was streamlined so as to simplify the
assessment and a table summarising the benefits and drawbacks of the different
options was introduced. Cost estimates were clarified and the text screened to
ensure the use of consistent language;

·
Transposition
and compliance: these issues were analysed in greater detail and an analysis of
the interaction between the proposed measures and existing rules in Member
States was added in Annex;

·
Stakeholders'
views: the views of stakeholders and Member States were more systematically
introduced in the text and a section summarising the views of stakeholders was
introduced in Annex.

3.           Policy
context, Problem definition and Subsidiarity

3.1.        Problem
definition

There are two facets to
the problem of IAS in Europe: 1) the ecological problem created by the entry,
establishment and spread of IAS, 2) the policy failure caused by a very
fragmented and incoherent policy set up at EU and national levels that is
allowing the ecological problem to worsen.

3.1.1.     An ecological problem

An alien species
is defined in the Convention on Biological Diversity (CBD) as "a
species, subspecies or lower taxon, introduced outside its natural past or
present distribution, including any part, gametes, seeds, eggs, or propagules
of such species that might survive and subsequently reproduce." Some
of these alien species are unable to adapt to the new environment and simply
die off, other species (e.g. certain crop species) need careful tending to
survive and will not spontaneously reproduce in the environment. Other species,
however, may establish and reproduce in the new environment to an extent where
they start causing problems, i.e. they would become invasive. The CBD defines
an invasive alien species (henceforth IAS) as "an alien species
whose introduction and/or spread threaten biological diversity"[16]. IAS include animals, plants, fungi and micro-organisms,
and affect the EU’s continental landmass and water bodies, seas and islands.

Only a subset of the
alien species in Europe is invasive and has a negative environmental, social or
economic impact. It is estimated that 10-15% of the alien species present cause
damage[17] which is borne
by society at large as well as by businesses, including primary producers and
landowners. This Impact Assessment will focus on IAS that are alien to the EU:
species native in part of the EU but IAS in another will not be considered.

Climate change may
aggravate the problems of IAS, as changing climatic conditions can lead to
previously unsuitable ecological conditions becoming suitable, thus allowing an
alien species to reproduce and start spreading and cause problems[18]. On the
other hand it can be expected that alien species will naturally migrate to find
more suitable conditions to evolve as the global temperature rises. It is not
the intention of the Commission to hinder such natural and necessary
migrations. Therefore these are not considered as IAS for the purpose of this
exercise and would not be addressed.

IAS are a major, and
growing[19], cause of
biodiversity loss and species extinction, second in importance
only to habitat loss, especially on islands and in freshwater habitats[20]. Some IAS
lead to biodiversity loss by competition, predation or hybridisation with
native species. Others modify habitats and ecosystems to the detriment of
native species or have a broader impact on the environment, society and the
economy, for example by disrupting ecosystems and their services[21], causing
allergies or transmitting diseases, damaging infrastructure and properties[22] (see Table
1).

Table 1: Main
types of impact caused by IAS[23]; IAS often have
multiple impacts and an immediate direct impact can often lead to broader
consequences, leading to  loss or interference with the provision of ecosystem
services that sustain livelihoods and which are the basis of many economic
activities.

Impact || Sub-category of impact || Example || Consequences

On economic activities || Damage to infrastructure || Zebra mussels || Zebra mussels can cause damage by blocking pipes, vents or holes for the passage of water it is a major macrofoulant of power generating plants, industrial and municipal water systems.

Disruption of recreational activities || Water hyacinth || Water hyacinth creates dense floating mats on water bodies, interfering with recreational activities, such as boating and fishing.

Damaging agriculture || Coypu || The coypu feeds on crops causing agricultural production losses. Moreover, with its burrowing activities, coypu causes great damage to river banks, leading to increased risk and severity of flooding as well as damaging irrigation systems.

On human health || Disease vector || Asian tiger mosquito, raccoon dog || Tiger mosquitoes can spread the Chikungunya virus, yellow fever, Rift valley fever and dengue. Raccoon dogs carry rabies, besides being a reservoir and vector of parasites that infects humans, e.g. sarcoptic mange, trichinella worms and fox tapeworm.

Health impacts || Common ragweed, giant hogweed || Common ragweed is a common allergen causing rhinitis, dermatitis, asthma. Giant hogweed causes severe burning and dermatitis.

On ecosystem services || Interference with supporting services (necessary for the provision of other ecosystem services) || Japanese knotweed || Japanese knotweed builds up dense stands inhibiting growth of other plants, outcompetes native plants, disrupts invertebrate species communities, affects soil environment, its roots seriously damage infrastructure.

Interference with provisioning services (products obtained from ecosystems) || Pontic rhododendron, Spanish slug || Pontic rhododendron displaces native species and affects species diversity, alters the ecosystems, thus affecting timber production. The Spanish slug feeds on horticultural plants and damages private gardens and agricultural fields.

Interference with regulating services (benefits supplied by self-maintenance of ecosystem) || Yellow-legged hornet || The yellow-legged hornet is a highly effective predator of native bees and other beneficial insects, thus having an impact on the activities of pollinators.

Interference with cultural services (non-material benefits derived from an ecosystem) || Killer shrimp, tree of heaven || Killer shrimp can quickly dominate the invaded habitats directly affecting fisheries quality with consequent impacts on recreational use of water bodies. The tree of heaven is a fast growing plant that can create dense stands leading to profound changes in touristic and culturally important landscapes: Mediterranean islands show for example 24% decrease in species richness, leading to an impoverished landscape.

On biodiversity || Competition || Bullfrog || The bullfrog colonises a range of habitats and has the ability to outcompete indigenous amphibians

Predation || Common slider, harlequin ladybird || The omnivorous common slider predates on several species from insects to other invertebrates and vertebrates, including amphibians, reptiles, small mammals and birds. The harlequin ladybird predates on native ladybirds and caused the decline of several populations.

Disease vector || Red swamp crayfish, grey squirrel || The red swamp crayfish is a carrier of crayfish plague, which kills native crayfish. The grey squirrel is a carrier of Poxvirus a disease which kills the native red squirrel.

Hybridisation || Ruddy duck || The ruddy duck breeds with the native and vulnerable white headed duck and produce fertile hybrids which can gradually make the white headed duck species disappear.

Changing habitats and altering ecosystems || Black locust || Black locust is a nitrogen fixing species that can achieve early dominance on soils where nitrogen is a limiting factor for other species, thus leading to completely different species composition.

The ecological problem
has two main causes: 1) certain alien species are desirable and brought into
the EU e.g. through trade for a reason (e.g. commercial interests, ornamental
purposes, companion animals, biological control); 2) some alien species are
unintentionally introduced as contaminants of goods (trade in other
commodities), can be hitchhikers or stowaways in transport vectors or be
transported unwittingly by travellers. Some IAS can also travel through
transport infrastructure (e.g. Danube-Mainz canal). The growing pressure of IAS
on biodiversity is linked to the substantial increases in volume and extent of
trade and travel, leading to more species being transported across the globe[24].

Figure 1 analyses the
causal chain of the ecological problem: the top layer representing the drivers;
the second layer from the top illustrating the pathways into the environment;
the third layer from the top illustrating the state; and the bottom layer illustrating
the consequences of the presence of IAS in the environment in the EU.

Figure 1: Analysis of
the ecological problem, with estimates of the proportion of IAS intentionally
or unintentionally introduced in Europe through trade, of IAS intentionally
released in the environment, of IAS escaped from containment and IAS that
entered the EU as stowaways or contaminants and then established and spread in
the environment[25]

Based on research from
Genovesi and Scalera (2007) who studied IAS introduced in Europe[26], it is
estimated that 27% were intentionally introduced, while 76% were
unintentionally introduced[27]. These
figures show that for roughly three quarters of IAS introduced into Europe the
benefits would be negligible as these species were not meant to be brought into
the EU for any purpose. This is not the case for the remaining quarter of IAS
intentionally introduced purposely in Europe for their benefits.

Of the IAS intentionally
introduced into Europe, at least 74% were intended for release into the
environment and more than half of those are plants used for forestry,
landscaping or similar activities (e.g. black cherry in forestry). At least 44%
were intended to be kept in containment but escaped into the environment (e.g.
muskrat introduced for fur-breeding or pets), while 18% of the species were
intended for both release and keeping in contained conditions. Of the IAS unintentionally
introduced through trade into Europe and ending up in the environment, 71%
came as contaminants in a traded commodity (e.g. weed seeds in pots of
horticultural plants) and 45% as stowaways in a transport vector (e.g. marine
organisms in ship ballast water). 16% of IAS entered the EU through both
pathways (e.g. ragweed seeds contaminating animal feed grains and hitchhiking
on agricultural machinery). For more information on the pathways of
introduction see Box 1.

Box 1: pathways of release into the environment

The pathways of release in the environment vary considerably
according to the species group[28] (Figure 2). Plant
species mostly escape from cultivation (e.g. gardens) because their seeds
spread around (e.g. giant hogweed), with other important pathways being escapes
from agriculture, stowaways in transport vectors and seed contaminants[29]. Vertebrate
animals, besides escape (e.g. coypu escaping from fur farms), are also
released intentionally in the environment (e.g. for hunting), while invertebrate
animals often disperse unintentionally into the environment after being
introduced in Europe as a contaminant in a commodity or a stowaway in a
transport vector (e.g. zebra mussels on ship hulls). Transport networks are
corridors through which IAS can colonise new territories. To date this has
mainly been an issue for aquatic species (e.g. killer shrimp spreading
though the Danube-Mainz canal). The pathways of release into the environment
also vary across biomes. In freshwater ecosystems, for example, most
alien species are the result of intentional releases for aquaculture and
angling, although escapes from aquaculture are also important. In the marine
environment, most alien species are the result of unintentional releases,
i.e. from biofouling or mariculture escapes and ballast water contaminants.

Figure 2: Pathways of intentional and
unintentional release in the environment per species groups in the world[30]

The economic and social
costs are widely recognised as being significant. One estimate is that IAS have
cost the EU at least €12 billion/year over the past 20 years. Costs for
key economic sectors, including agriculture, fisheries, aquaculture, forestry
and health sectors account at over €6 billion/year[31], including damages costs and
management costs[32] of IAS.

The problem is not
limited to Europe: IAS are causing damage and management costs of similar
magnitude across the globe. Despite being difficult to compare as they were
collected with different methods, the data provided in Table 2 give an
indication of the magnitude of the damage and management costs caused by IAS.
The data may significantly underestimate the total economic cost as some costs,
such as the loss of biodiversity and the damage to ecosystem services, are not
fully quantified.

Table 2: Estimated
economic losses due to IAS across the globe[33]

|| Estimated economic losses due to IAS || Comments

Globally || c. €1 trillion/year (almost 5 % of global GDP) - Pimentel et al., 2001 || Includes damage costs and management costs, including also costs linked to human viruses and bacteria

US || c. €90 billion/year - Pimentel et al., 2005 || Includes damage costs and management costs, including costs linked to human viruses and bacteria (c. €5 billion/year),

China || c. €11 billion/year (1.36 % of China's GDP in 2000) - Xu et al., 2006 || Includes direct damage costs and management costs as well as estimated costs of ecosystem services loss (no costs linked to human viruses and bacteria)

New Zealand || c. €2 billion/year[34] || Includes damage and management costs for pests, weeds and pathogens (no costs linked to human viruses and bacteria).

EU || €12 billion/year - Kettunen et al., 2009 || Includes damage and management costs of IAS in Europe, including some organisms covered by animal and plant health (no costs linked to human viruses and bacteria).

UK || €2 billion/year - Williams et al., 2010 || Includes direct damage costs (losses) and management and management costs of IAS, including plant pathogens, but excluding viruses, microorganisms and diseases of animals.

Finally, over time the damage
and management costs have been observed to grow continuously[35] (see section
3.5): these economic losses stem from the costs of the increasing introduction
of new IAS in the EU and the costs generated by the continuing spread of IAS
already widely established in the European territory.

3.1.2.     A policy problem

All Member States are
taking some type of action to combat IAS. Few have comprehensive legal
frameworks to address the ecological problem; others rely on voluntary actions
or species specific programmes. Most Member States also appear to concentrate
their effort on tackling IAS that are long established, rather than on
prevention or early warning and rapid response. Annex V provides a detailed
analysis of the current national policy frameworks for the Member States. Moreover, the
responses to existing invasions are fragmented, uncoordinated and they do not
constitute a coherent approach[36].

As regards the EU policy
framework, it includes a variety of regulatory initiatives on IAS but these
only address few parts of the problem and provide a fragmented response. There
are substantial
gaps in
species covered and important inconsistencies between the use of
terms and concepts in legal texts[37], which are leading
inter alia to legal uncertainty in the context of the internal market. Similarly,
integration of IAS policies into other policy areas, such as border controls,
is largely absent Further details are given in section 3.4. .

The patchy approach in
the Member States has two important consequences:

1. Action in one Member
State is often undermined by lack of action in a neighbouring Member State, as
IAS respect no borders. This is the case for example of Wallonia (Belgium),
which is investing €0.5 mio/yr to eradicate giant hogweed, but efficiency and
effectiveness will remain suboptimal as France has no such programme, and there
will therefore be a permanent pressure of reinvasion along rivers entering the
region from France[38]. Similar
examples of measures on one species being taken in one Member States with no
action or non-comparable action being taken in neighbouring Member States
abound (e.g. the so far successful eradication campaign on ruddy ducks could be
undermined if no coordinated action is taken in all countries affected[39] - see also
Box 3).

2. Different restrictions
of commercialisation of IAS between Member States are highly
ineffective as species can easily be transported or spread across borders
throughout the EU. Such differentiated bans are moreover hampering
the free circulation of goods in the internal market and disrupting the level playing
field for those sectors using or trading alien species.

3.2.        Who is affected and how?

IAS affect
businesses, citizens, public authorities and the environment (See Table 3).
In particular, when it comes to small and micro enterprises, primary
producers in agriculture, animal husbandry, fisheries, aquaculture and forestry
are often affected by IAS and suffer considerable economic damage. Businesses linked
to tourism and recreational activities, which rely on pristine landscapes,
clean water bodies and healthy ecosystems are often also affected. In addition,
these businesses are burdened by the management costs to keep damaging IAS in
check, although the majority of these costs are usually faced by the public
authorities (see Annex VII). These enterprises suffer from a lack of
prevention and coordinated action to tackle IAS. However, other small and
microenterprises, e.g. traders in pets and horticultural species, draw benefits
from IAS as they focus largely on alien species trade. In such cases,
prevention and coordinated action to tackle IAS may pose some restrictions to
these businesses. IAS also affect society at large, through
biodiversity loss and compromising the ability of ecosystems to provide
ecosystem services; moreover they transmit diseases, damage properties and
affect the cultural heritage. A lack of prevention and coordinated action to
tackle IAS has negative consequences in social terms.

The costs and
benefits from IAS are typically distributed unevenly: those benefitting
from bringing IAS into the EU usually have few or no economic incentives to
minimise any IAS-related risks, while the costs associated with IAS damage and
management are generally met by primary producers, public authorities and
society.

Table
3: Examples of damage caused by IAS

IAS || Who is affected and how || Damage cost estimate

ECONOMIC DAMAGE

Ragweed (most of EU) || Farmers: yield reduction (its resistance to herbicides and the germination capacity of its seeds of more than 30 years makes it difficult to manage) || Hungary: yield losses of €130 mio/yr (Kemives et al. 2006) EU: agricultural damage of €1.302 to 3.307 billion/year (Bullock 2012)

American mink (most of EU) || Animal husbandry and aquaculture: predates free ranging chickens, reared game birds, farmed salmon || Germany: €4.2 mio/yr (Bonesi, 2009)

Zebra mussel (most of EU) || Fishermen and fisheries: interference with fishing gear, alteration of fish communities Aquaculture: fouling the cages Water and electricity companies: clogging the water intake pipes Aquatic transport: fouling the ship hulls and navigational constructions Recreation: sharp shells cause injuries || North America: annual multimillion losses (Zaiko & Olenin, 2009) US and Canadian water users: €370 mio/yr (Millennium Ecosystems Assessment, 2005)

Musk rat (most of EU) || Water utility companies, electricity companies, transport companies, public authorities: undermines riverbanks, railroads, dams and fences, irrigation structures and aquaculture || Netherlands: €23 mio/yr (Van der Wijden et al., 2007) Germany: additional expenditure for waterway maintenance €2.3 mio/yr (Reinhardt et al. 2003) and for maintenance of aquaculture facilities €1.6 mio/yr

Coypu (most of EU) || Water utility companies, electricity companies, transport companies, farmers, public authorities: undermines river banks and increases the risk and severity of floods || Italy: exceeded €10 million riverbank damage and exceeded €0.9 million impact on agriculture (Bertolino, 2009)

Japanese knotweed (most of EU) || Real estate companies, citizens, banks, public authorities, property owners: leads to loss of property value, refusal of mortgages || England, Scotland and Wales: €205 mio/yr (Williams et al., 2010) Germany: €7 mio/yr for embankment repair and €16.7 mio/yr for embankment reinforcement

SOCIAL DAMAGE

Ragweed (most of EU) || Citizens: allergic asthma and allergic rhinitis that cause severe public health problems || EU: medical costs of €118 to 763 million/year and workforce productivity loss of €0.049 to 1.361 billion/year (Bullock 2012) Germany: medical costs (prescribed medication) of €17-47 mio/yr (Reinhardt et al., 2003)

Giant hogweed (most of EU) || Citizens: severe skin burning, tens of thousands of people affected every year, in the worst cases being fatal || Germany: medical treatment costs of €1 mio/yr (Reinhardt et al., 2003)

Musk rat (most of EU) || Citizens: transmits echinococcosis that cause severe public health problems || Germany: medical treatment costs of €4.6 mio/yr (Reinhardt et al., 2003)

Tiger mosquito (IT, FR, ES) || Citizens: vector of at least 22 arboviruses including Chikungunya and Dengue, often fatal to children ||

ENVIRONMENTAL DAMAGE

Black cherry (most of EU) || Forest biodiversity and foresters: Hinders natural regeneration of trees, impedes forest management measures such as thinning, timber harvesting or planting || Germany: additional expenditures for thinning and timber harvesting at least €1.4 mio/yr, manifest additional expenses for planting not included (Reinhardt et al. 2003)

Harlequin ladybird (UK, FR, BE, LU, NL, DE, DK, CZ, AT, GR, IT, ES) || Displaces native ladybirds, causes decline in native biodiversity, could impact on the resilience of ecosystems and severely diminish the services they deliver (Roy et al. 2012) ||

Comb jelly (Black sea, Baltic sea, E-Mediterranean sea) || Marine biodiversity and fishermen: drastic decline in pelagic fish and fisheries catch || Black sea: several €100 million in total for collapse of fish stocks (Shiganova & Panov, 2009)

Canada goose (UK, IE, FR, BE, NL, DE, SE, FI) || Displaces native waterfowl, causes habitat modification, disturbs ecosystem functioning. ||

Grey squirrel (UK, IE, IT) || Drives the red squirrel to extinction (Genovesi and Bertolino, 2009), damage trees by stripping bark, which allows the entry of rot and staining fungi, and reduces damages trees and timber quality || In the UK, the cost of damage caused by grey squirrels to tree species and their services to be about €12.5 million in total, of which €10 million is the estimated cost to private estates and €2.5 million to publicly owned woods. This is not an annual cost but the loss of value of the woodlands[40].

IAS in general affect
all Member States, albeit perhaps at different times and by different
species (see also Annex VII). While some IAS affect most EU Member States,
others are only a problem in certain regions, or under certain ecological or
climatic conditions. As shown by Figure 3, all Member States have IAS in their
territories, with numbers varying, but within a similar order of magnitude
across all Member States. It can be assumed that countries with higher trade
volumes and numerous entry points are likely to suffer more introductions of
IAS. It is not possible to ascertain the magnitude or concentration of intra-EU
movements as there are no internal checks for commodities or monitoring of
aliens species moving in the wild across the borders. As IAS impacts are
relevant to the whole of the EU, coordinated action to tackle IAS would thus
benefit all EU Member States, while clearly requiring efforts from all Member
States.

Figure 3: Map of the
number of worst IAS (causing the most damage) per country and an approximate
estimate of their density, given as number of species per country per 1000 km2.

3.3.        Policy baseline

IAS are
widely recognised as a problem by international organisations[41], with a
significant number of international conventions focusing on IAS[42]. See Annex
IV for details.

Major EU trade partners have already
developed streamlined and stringent IAS policies, considerably more
advanced – in particular on the prevention side - than the current policies and
actions in the EU Member States. Interesting examples are New Zealand,
Australia, the US and Canada[43] where strict border
control and quarantine measures apply. Risk assessment procedures are in place,
not only applying to species (intentional introductions), but also to
commodities, pathways and modes of transport (unintentional introductions).
Both Australia and New Zealand are treating IAS, pathogens and pests through
the same system, thus implementing an integrated plant health, animal health
and IAS-regime. Both countries are following the strictest approach,
considering all alien species to be potentially invasive, unless a risk
assessment has declared them harmless. The US and Canada, by contrast, only
consider alien species to be harmful if proven so by a risk assessment.
Stakeholders in these countries tend to have a higher level of awareness of IAS
related problems than in the EU[44].

In terms of baseline,
the current and historical load of alien species in the EU is 12,046 out of
which 10-15% are IAS. Figure 4 shows that at the EU level few IAS are
addressed by legislation. Disease agents and pests of animals and plants and
their products are covered respectively by the animal health regime (various
regulations and directives) and by the plant health regime (2000/29/EC). These
policies adopt a preventive approach, and require rapid response in case of
outbreaks, similar to the approaches taken in the US and Canada. Action focuses
on list of priority species for the EU and is based on risk assessments, an
approach which has delivered significant results[45] (see also
Box 2). The Commission proposals for a revised animal and plant health regime
include pest and disease agents affecting wild plants and animals. The Wildlife
Trade Regulation (338/97) restricts the import of endangered species, including
the import of seven IAS[46]. The
Regulation concerning the use of alien and locally absent species in
aquaculture (708/2007) addresses the release of alien species for aquaculture[47]. The
regulations on plant protection products (1107/2009) and on biocides (528/2012)
address the intentional release of micro-organisms respectively as plant
protection product or biocide. Finally the Birds Directive (2009/147/EC) and
the Habitats Directive (92/43/EEC), the Water Framework Directive (2000/60/EC)
and the Marine Strategy Framework Directive (2008/56/EC) require the
restoration of ecological conditions and refer to the need to take into
consideration IAS. Nevertheless, existing EU action leaves most
IAS unaddressed and what action is taken at national level focuses on damage
mitigation rather than on addressing the drivers of the problem (see also Annex
V).

Figure 4: IAS
unaddressed by existing EU legislation – the non-shaded boxes describe what
species are currently unaddressed by EU legislation

Box 2 – lessons drawn
from the plant health regime (PHR)

The issue of plant pests
is close to that of IAS: in fact plant pests and diseases are IAS that are
already tackled by PHR. The measures in place through PHR have therefore
provided substantial inspiration for the proposed actions to tackle IAS. Since
its adoption, the PHR has successfully protected the EU against the
introduction and spread of many pests; however, with the increasing
globalisation of trade, the systems faced new challenges that brought about the
need to review its functioning.

The European Commission
carried out a review and commissioned an evaluation which thoroughly examined
the functioning of the system, including the opportunities to tackle more IAS.
The evaluation was conducted by the Food Chain Evaluation Consortium (FCEC) and
completed in 2010. The current revision and the FCEC study provided a useful
oversight of pitfalls and shortcomings of the system in place, from which
valuable lessons can be learnt: 1) prevention should be strengthened and  more
coordination of action will be needed to stop the spread of pests across the
EU, namely through surveillance, contingency planning, rapid outbreak
eradication and containment, were pests may have gone unnoticed during import
inspection; 2) more solidarity needed, with a move from  national to EU action;
3) implementation of some aspects of the regime has not always been consistent,
hampering the effectiveness of the system, more consistency of action needed
(see annex V for more details)

Most Member
States have taken regulatory or non-legislative initiatives on the IAS
which are not already covered by EU legislation (Table 4 and Annex V). However,
as outlined in section 3.1.2, those initiatives are predominantly reactive
rather than preventive and they are fragmented and uncoordinated, they do not
constitute a coherent approach[48] and leave substantial
gaps.

Table 4: Overview of
IAS-measures in the EU-27: legal provision (black), provision in preparation
(vertical lines), informal provision (horizontal lines) and scattered
initiatives (dots) (updated from Sonigo et al. 2011)

Note: this table
aims at giving an overview of different types of measures already taken at
national level, categorised according to broad categories of intervention. This
necessarily leads to a simplification and the table might not reflect
accurately some of the nuances of measures taken. The data was collected in
2011 and the situation may have evolved in some Member States.

3.4.        How will the problem evolve?

If
no action is taken to tackle the policy problem, the ecological problem will
get worse as new IAS establish themselves and those already established spread
further. This will result in an increase in damage costs and management costs.

Growing number of IAS - The number of
alien species introduced into the EU and in the environment has been steadily
growing (Figure 5): over the period 1970-2007 their numbers grew by 76%[49].

Figure 5: Cumulative
number of introduced alien plant species, with the number of species alien to
Europe continuously increasing (grey line)[50] over time in
Europe.

International
trade has been growing at an average of 12 % per year over the last decade and
is projected to carry on rising[51]. While increased
awareness might reduce the trade of IAS as commodities, this trade coupled with
limited deployment of bio-security measures will lead to continued
unintentional introductions of IAS. Furthermore, some established, but
not yet invasive, alien species may start showing an invasive behaviour after a
certain time lag[52].

IAS
have regularly been released in the environment intentionally, e.g. for
agriculture/forestry, hunting/angling or for purely ornamental purposes. While
the proportion of intentional releases has been observed to decrease due to
increased awareness of the problem[53], we can expect that new
species will continue to be released, as new needs/markets emerge. Based on the
above observations, we may reasonably assume that the number of IAS in the
environment will continue to increase.

Spread of IAS and
increased damage per IAS - A
characteristic of IAS is that, once established in the environment, they
rapidly reproduce and spread. If an IAS is allowed to spread, the damage it
causes will increase in line with its population size. Climate change,
pollution, habitat loss and land use change are expected to aggravate this
trend, by disturbing ecosystems and reducing their resilience to invasions.

Many
data are available on the damage cost of IAS (Table 3), but this data is hardly
ever available in the form of trends. Where such trends are available they are
mostly based on single species, but they consistently indicate that costs per
IAS tend to increase in line with their spread, as illustrated by the evolution
of costs of the zebra mussel invasion in the Ebro delta in Spain (see Figure
6). There is evidence that many IAS are continuing their expansion and,
consequently, it is reasonable to expect that the average damage per IAS will
increase.

Figure 6: Evolution
of the total annual cost of the zebra mussel invasion in the Ebro delta in
Spain from 2001 to 2009 (in €)[54]

Growing total damage by
IAS
-
As
new IAS will continue to enter into the EU, the number of IAS present and
causing damage will be increasing. This will add to the increasing damage of
established IAS reproducing and spreading. The overall result will be ever increasing
damage and management costs across the EU in the years to come. Table 5
identifies the five main aspects of the IAS problem where intervention would be
needed and illustrates the expected evolution of the problem.

Table 5: How
the problem would evolve without additional measures (based on problem
analysis in Figure 1)

Problem || Expected trend in IAS || Comments

A. Intentional introduction of IAS in the EU through trade || ↑ || Trade volumes will continue increasing, including trade in alien species, with consequently continuous intentional introductions of IAS in the EU

B. Unintentional introduction of IAS in the EU and unintentional release of IAS in the environment || ↑ || Trade volumes will continue increasing, which will lead to further unintentional introductions and releases of IAS in EU as contaminants of other commodities or as stowaways on transport vectors.

C. Intentional release of IAS in the environment || ↑ || Intentional release of IAS in the environment is expected to continue increasing

RESULT of A+B+C (in respect to number of IAS in the EU) || ↑↑ || Cumulative number of IAS in the environment will continue increasing (Figure 5)

D. Reproduction and spread of IAS in the environment || ↑↑ || The number of specimens per IAS in the environment will continue increasing

E. IAS causing economic, social and environmental damage || ↑↑ || The damage caused by every IAS will continue increasing (Figure 6)

RESULT of D+E (in respect to spread and damage from IAS) || ↑↑↑ || Total damage by IAS will be the sum of the damage increase per IAS, leading to increasing management costs

3.5.        The
EU's right to act and justification

3.5.1.     The legal basis for action

The EU has already acted
on pests and pathogens (plant and animal health) and developed measures towards
alien species in aquaculture. The right for the EU to act in the field of IAS
causing environmental damage is set out in Articles 191 and 192 of the Treaty
on the Functioning of the European Union requiring a high level of
protection and improvement of the quality of the environment and human health
in the EU. The management of species and habitats has trans-boundary
considerations and the principle of EU involvement in managing biodiversity
is now well established.

Tackling IAS has
important implications for the achievement of other EU legal obligations,
such as the targets of the Birds and Habitats Directives (favourable
conservation status), the Water Framework Directive (good ecological status) and
Marine Strategy Framework Directive (good environmental status), as well as
international commitments. Current EU legislation only addresses a small
proportion of IAS, as discussed in section 3.4. To address this gap, the
Commission adopted a Communication: "Towards an EU Strategy
on Invasive Species (2008)"[55], which was endorsed by
the Council on 25 June 2009[56]. In its
Conclusions of both 25 June 2009 and 21 June 2011[57] the Council
expressed its support for action on IAS, including legislative elements. Support
was also expressed by the Committee of Regions[58] and the
European Economic and Social Committee (2009)[59].

In March 2010, the EU
leaders endorsed a 2050 vision and an ambitious 2020 headline target[60] aiming at
"halting the loss of biodiversity and the degradation
of ecosystem services in the EU by 2020, and restoring them in so far as
feasible, while stepping up the EU contribution to averting global biodiversity
loss."
This was reflected at international level, in the context of the Strategic Plan
for Biodiversity 2011-2020[61] agreed in
the 10th meeting of the Parties of the CBD, when the following global target
was set: "By 2020, IAS and their pathways are identified and
prioritised, priority species are controlled or eradicated, and measures are in
place to manage pathways to prevent their introduction and establishment."

The Commission
Communication "Our life insurance, our natural capital: an EU
biodiversity strategy to 2020"[62], endorsed by
the Council on 19 December 2011, responds to both the EU and the CBD and
mandates that "by 2020, Invasive Alien Species (IAS) and their pathways
are identified and prioritised, priority species are controlled or eradicated,
and pathways are managed to prevent the introduction and establishment of new
IAS". To achieve this target the Communication proposes to fill the
existing policy gap by developing a dedicated legislative instrument on IAS
by 2012. The European Parliament urged the Commission to
come forward with a legislative proposal to combat IAS[63].

Finally, action to
tackle IAS will contribute to the Europe 2020 Strategy responding
to the sustainable growth priority and contributing to other priority areas,
namely employment and poverty reduction (e.g. avoiding collapse of
Baltic Sea fishing industry due to an IAS)

3.5.2.     Promoting
solidarity

EU action on IAS
promotes the “solidarity principle”, since IAS and their impacts are unevenly
distributed across Member States. Indeed IAS may be more damaging in one
country than in another (e.g. water hyacinth affecting Mediterranean countries,
but unable to survive in North-European countries). Moreover, some IAS may be
invasive in one country, but extend their damage to other countries (e.g.
ragweed invasion in Hungary leading to pollen dispersal and allergenic problems
in Poland). In such cases, exercising the solidarity principle among Member
States will protect the interest of those that are likely to suffer the most
negative consequences. Tackling IAS will require efforts from Member States,
but it will bring significant benefits for the EU as a whole in the medium and
long term.

3.5.3.     Subsidiarity

Necessity test: IAS problems
are increasing and cross-border by nature: due to the lack of EU level
action, Member States are putting in place measures to cope with the problem at
national level. They are investing resources and efforts in eradicating a
harmful IAS but such efforts can be undermined by lack of action in a
neighbouring Member State where the species is also present. Equally, no
coordinated EU action exist to ensure that where IAS first enter the Union,
Member States take prompt measures to the benefit of other Member States not
yet affected. Furthermore, the protection of the internal market – and the free
circulation of goods – has to be taken into consideration: a coordinated
approach will ensure legal clarity and a level playing field for those
sectors using or trading alien species while avoiding a fragmentation of
the internal market due to different restrictions of commercialisation of IAS
between Member States.

EU Value
added-test: the fact that the number of IAS and damages are
increasing across the EU despite national/regional policies/initiatives, indicates
that the problem cannot be solved without EU action. Current efforts are highly
fragmented and inconsistent, leaving considerable policy gaps and leading to
ineffectiveness (see 3.1.2,
Table 4 and Annex V) and they do not solve the IAS problem. A mixture
of EU and national, regional and local measures will be needed, in line
with the principle of subsidiarity, and a coherent approach at EU
level will increase the effectiveness of the measures. Member States which
currently have legislation on IAS will benefit from a common approach which
will guarantee that neighbouring Member States take actions for the same
species (see Box 3).

4.           Objectives

The growing damage costs expected in the coming
years show the need for action to close the current policy gap. The general
objectives of this action are the following:

·
to
minimise the negative impact of IAS on biodiversity and the environment and to
contribute to the EU 2020 biodiversity target[64], by
fulfilling its Target 5 stating that: "by
2020, IAS and their pathways are identified and prioritised, priority species
are controlled or eradicated, and pathways are managed to prevent the
introduction and establishment of new IAS;

·
to
minimise the negative economic and social impact of IAS for the EU economy and
the Europeans and in particular protect their wellbeing and health, thus contributing
to the Europe
2020 Strategy.

While ultimately the EU
will need to tackle the ecological problem caused by IAS, it must be stressed,
that, given the current trade patterns and the rate at which species are
transported across the globe, action to address all of IAS in the EU would be
prohibitively expensive. Some IAS are already present in the EU (legacy of the
past) and are so widely spread that at most it will be possible to mitigate or
reduce the damage they cause. When it comes to preventing new IAS coming into
Europe, given the permeability of the EU borders with its long coastlines and
borders with third countries, and multiple harbours and airports, it must be
accepted that some species will anyway come in undetected.

Therefore the real added
value of EU actions stems from addressing the policy failure identified. Thus
action should not seek to deal with the problem in its entirety, but rather to
devise a cost-effective system, based on identified priorities for action and
improved responses. Therefore the specific objectives to address the
policy failure will be the following:

·
shifting
the current reactive to a more preventive approach towards IAS;

·
prioritising
action towards IAS where the highest net benefits are to be obtained;

·
fostering
a coherent approach on IAS across the EU.

Table 6:
Relation between general (columns) and specific (rows) objectives

|| General objectives

Specific objectives || EU 2020 Biodiversity Strategy and EU 2020 Strategy

1 - More preventive approach || Prevention will seek to reduce the number of new IAS coming into EU thus avoiding increasing threats to biodiversity and negative impacts on society and economy.

2 - Prioritising action || Prioritisation will allow acting efficiently by focusing resources on the worst IAS, i.e. where most benefit is to be obtained for biodiversity and for society and the economy

3 - Fostering a coherent approach || Acting in a coherent and coordinated manner across the EU will increase the effectiveness and efficiency of actions at EU level, i.e. avoiding action in one Member State being undermined by lack of action in another Member State

Based on the analysis of
the ecological problem (Figure 1), the policy failure will be addressed by
applying the 3 specific objectives to the five elements of the ecological
problem which constitute the five operational objectives (Table 7).

Table 7: Relation
between specific objectives (columns) and operational (rows) objectives

|| Specific objectives

Operational objectives || 1 - More preventive approach || 2 - Prioritising action || 3 - Fostering a coherent approach

A – Prevent intentional introduction of IAS of EU concern into the EU || More focus on preventing IAS being intentionally introduced into the EU || Focus resources to prevent the worst IAS from entering || Common approach to prevent the worst IAS from entering

B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || More focus on preventing IAS being unintentionally introduced into the EU and into the environment || Focus resources on the major pathways of introduction || Common approach addressing the major pathways of introduction

C – Prevent intentional release of IAS into the environment || More focus on preventing IAS being intentionally introduced into the environment || Focus resources to prevent the worst IAS from being released into the environment || Common approach to prevent the worst IAS from being released into the environment

D – Early warning and rapid response to prevent reproduction and spread of IAS of EU concern || More focus on a rapid eradication of IAS that circumvented the prevention measures || Focus resources to prevent the worst IAS from spreading || Common approach towards newly establishing IAS

E – Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || The above prevention efforts aim at  reducing and avoiding new invasions so as to avoid the need to manage established IAS || Focus resources to keep the worst damage under control || Common approach towards the worst established IAS

5.           Description
of Policy Options

Different
options have been identified to address the ecological problem and the policy
failure. All of the options address the five operational objectives, but with a
different level of ambition. The options were constructed using a dual
approach, which included at the same time an analysis of the measures needed to
tackle the operational objectives (the content), as well as the type of policy
instrument (the form). For each option identified, each of the operational
objectives was systematically addressed, proposing concrete measures to tackle
IAS.

5.1.        Option 0 - Business as Usual (baseline option)

This option maintains
the current policy actions as identified in the policy baseline.

Prevention - Prevention
of the intentional introduction into the EU through trade and transport (operational
objective A) would be possible for IAS included in the Wildlife Trade
Regulation (WTR) (see 3.4). The list of IAS covered could be extended;
moreover, WTR includes a provision to include rules on possession and holding
of certain species. As it is the case now, Member States would continue to
introduce trade bans on species problematic in their territory (see Annex V).
Existing voluntary codes of conduct (e.g. codes of conduct on horticulture and
on companion animals drawn within the Bern Convention) encourage sectoral
action to tackle IAS trade, marketing and transport.

The unintentional
introduction of IAS in the EU and their accidental release into the environment
(operational objective B) is currently addressed for certain groups of
species: pests and diseases, that are generally introduced unintentionally,
would continue to be addressed by the animal and plant health regimes[65].
The planned revision of the plant health regime will explicitly include
disease agents and pests of wild plants in its scope[66].
Similarly, the new animal health law will cover diseases of wild
animals, besides those of commercially reared animals, where the former could
threaten human or animal health or the environment. For the aquatic
environment, the Ballast Water Convention, once entered into force, will
address stowaways in ballast water; while biofouling is being addressed through
the voluntary application of dedicated guidelines (see 3.4). Existing voluntary
codes of conduct focus attention on pathways of introduction into the EU and
the environment. Member States have also developed a variety of measures at
national level (Table 4).

When it comes to the intentional
release of IAS into the environment (operational objective C), the EU Birds
Directive[67]
and Habitats Directive[68]
refer to the need to regulate or prohibit the release of IAS into the
environment, but it has led to a myriad of actions (some regulatory some
voluntary), which are often species-based and seldom coherent. The Regulation
on the use of alien and locally absent species in aquaculture (708/2007)
prohibits the release into the environment for aquaculture purposes of species,
unless they obtained a permit or were listed in the annex of the regulation,
while the legislation on plant protection products and on biocides
addresses the release of micro-organisms for plant protection and biocidal
purposes. Further, Member States would continue taking initiatives for those
species that pose problems in their territory (see Annex V).

Reaction - The EU has
early warning and alert systems (operational objective D) for disease agents
and pests affecting animal and plants – animal and plant health regimes. For
other IAS, there is no EU system although some intergovernmental networks
exist, for example NOBANIS[69],
a northern European network which includes 14 EU Member States. Efforts to
rapidly respond to newly establishing IAS are the responsibility of Member
States.

For the management of
established IAS (operational objective E) there is currently no obligation
to address the problem of already established IAS in the acquis.
Member States would continue to act on an ad hoc basis driven by damage costs
on a species basis. Such efforts are sometimes carried out in collaboration
with neighbouring Member States. Such initiatives can be supported by EU funds,
e.g. LIFE, ERDF and EAFRD. Management of established species could also be
driven by the aim of complying with the objectives of the Birds and Habitats
Directives (favourable conservation status), the Water Framework Directive
(good ecological status) and Marine Strategy Framework Directive (good
environmental status).

5.2.        Option 1 – Enhancing cooperation and supporting voluntary action

Fostering voluntary
action and enhancing cooperation would include the development of guidelines,
sectoral codes of conduct and other awareness and educational campaigns. This
would be in addition to what is already done with option 0.

Prevention - A
voluntary approach would not generate EU trade bans for certain species to
prevent the intentional introduction of IAS into the EU (operational objective
A), but the Commission could produce an inventory of any trade, marketing
and transport bans existing at Member State level. In particular, the
Commission could provide guidance for developing IAS regimes at national
of regional levels. It could also foster further development of codes
of conduct that different sectors could voluntarily adopt. Similarly, the
Commission could promote awareness-raising initiatives and communication
campaigns to encourage consumers and operators to refrain from buying, keeping
or trading IAS.

The Commission would
adopt a similar approach to address the unintentional introduction into the EU
and unintentional release (escape) into the environment by addressing the
pathways (operational objective B) as well as the prevention of
intentional releases of IAS (operational objective C). It would promote the
development of guidelines or codes of conduct to address the major pathways of
introduction of IAS into the EU and of release into the environment, be it
intentional or unintentional. The Commission could engage in awareness raising
campaigns to complement national initiatives and to alert consumers, and it
could promote the use of codes such as those developed under the Bern
Convention (e.g. for horticultural plants).

Reaction - In order
to encourage cooperation between Member States and achieve an early warning and
rapid response to prevent the reproduction and spread of newly establishing IAS
(operational objective D), the Commission would promote initiatives such as the
NOBANIS network, e.g. through communication campaigns. Actions to rapidly respond
to newly establishing IAS and to manage established IAS would,
however, mostly be left to Member States, albeit with some EU funding possible.

5.3.        Option
2 – A dedicated legislative instrument

Adding to option 0 and
1, the introduction of legal provisions to tackle the problems caused by IAS
would build on actions already being taken under the acquis (Option 0)
and voluntarily (Option 1) by Member States and sectors.

For such a fairly new
policy area, the legislative instrument could be based on a gradual approach,
whereby a set of priorities would be established in the proposal while
in-building the possibility of reviewing the regime after a first phase of
implementation when more coordinated experience is gained. The gradual approach
would be an inherent part of some of the provisions in particular as regards:

1. the number
the species that would be tackled through the regime which could be limited at
the beginning

2. the number of
routes of entry that would need to be addressed

3. the
information system underpinning the regime

These aspects would evolve
over time, starting with a simple and manageable framework to be reviewed (see
Box 4).

A legislative instrument
tackling the issue of IAS would need to set up a simple framework for action
and a process. It would not be possible to aim for an obligation of results
with predefined environmental objectives included therein. Rather, the
environmental objectives to be reached are included in other environmental
Directives (favourable conservation status under Habitats and Birds Directives,
good ecological status in the Water Framework Directive and the good
environmental status in the Marine Strategy Directive). The Member States would
be required to take certain actions against IAS and the Commission would screen
the measures taken for IAS pursuant to this legislation against the above
objectives. This entails that some control mechanisms need to be introduced
(notifications and exchange of information).

Box 4 – A
gradual approach to tackling IAS.

A gradual
approach is necessary to ensure that in a new area of EU policy such as this,
experience is gathered and developed before actual obligations start applying. 
This could be done through tackling a limited number of species, through
limiting the numbers of routes of entry to be addressed and through establishing
gradually an information system to underpin the regime. All of these aspects
would evolve over time as experience is gathered.

Such
mechanisms could be embedded in a dedicated legislative instrument: bans and
obligations would be applicable to a selected set of species considered to be
of concern for the EU, but before IAS are recognised as species of concern for
the EU, there would be the need to perform a full assessments of the risks
linked to that species, examining the impacts it has, its features, the
likelihood of entry into the EU and spread, its route of entry, its invasive
characteristics, etc. Thus before a species gets listed, and bans and
obligations start applying, Member States would have the chance to thoroughly
assess the candidate species and acquire extensive knowledge on it. Listing
would thus be done with full knowledge of the consequences involved and with
the full participation of Member States. Such list of species of EU concern
would need to be reviewed periodically, with the possibility of adding species
or removing species depending on need and in light of experience. Equally, the
measures to manage the pathways of introduction would only be applicable to
pathway deemed by Member States to deserve priority action, after the Member
States have performed several stages of analysis (screening of pathways,
identification of priorities, etc) that would provide them with a solid knowledge
base and experience on all aspects of pathways, which would enable them to
devise realistic and efficient measures. A similar gradual approach would apply
to the development of an information system, which could initially be a simple
interface to access and share existing information and gradually develop into a
tool to manage notifications linked to the early warning system and only later
develop into a more comprehensive information management system.

Linked to the
gradual approach is also the need to set up a mechanism to target action to a
limited number of priority species and pathways. This would need to be a core
feature of a dedicated legislative instrument. Listing of IAS of EU concern
would be based on precise elements to perform a thorough risk assessment,
giving a very clear idea now on which grounds the species would be listed, including
an assessment of the possible uses of the species, its potential benefits as
well as a quantification of its impacts so as to explicitly target the species
that justify action at EU level. Similarly, the management of pathways would be
limited only to those which the Member States concluded to be the route of
entry of a large number of IAS or of IAS with large negative impacts.

Based on feedback
from the consultation, different levels of ambition and/or intervention were
identified for each operational objective which resulted in different
sub-options for the design of the legislative instrument (Table 8). An initial
screening led to discarding sub-options which were unfeasible, or simply not as
effective as others (see Annex VI).

Table
8: Five operational objectives with three levels of intervention: retained
(bold) and discarded actions

Problems (see Figure 1) || Operational objectives (see Table 7) || Range of Options to address the operational objectives, with different level of ambition

-Intentional Introduction of IAS of EU concern into the EU (e.g. through species trade) || A - Prevent intentional introduction of IAS of EU concern into the EU || A.1 – list of IAS of EU concern Example: EU Wildlife Trade Regulation

A.2 - list of IAS of EU concern + emergency measures Example: EU Plant health regime

A.3 – all alien species considered to be potentially of EU concern, unless included in an EU list of approved alien species Example: EU Regulation on biocidal products

-Contained holding and escape -Contaminant in commodity and escape -Stowaway in transport vector and escape || B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || B.1 - Member States manage major pathways

B.2 - Member States manage major pathways, share information and Commission provides guidance

B.3 - Member States manage major pathways, share information and require approval from the Commission

Intentional release in the environment || C - Prevent intentional release of IAS into the environment || C.1 - IAS of EU concern are not allowed to be released into the environment.

C.2 – no release of IAS of EU concern + permitting system for IAS of Member State concern

C.3 – strict ban on any release of any alien species unless included in an EU list of species approved for release into the environment

Reproduction and spread in the environment || D – Alert and Rapid Response to prevent reproduction and spread of IAS of EU concern into the environment || D.1 - Member States eradicate, control or contain newly establishing IAS of EU concern

D.2 - Member States quickly eradicate, control or contain newly establishing IAS of EU concern, share information and Commission provides guidance

D.3 -Member States do not have the choice they have an obligation to quickly eradicate newly establishing IAS of EU concern and share information. If Member States wish to resort to control or containment instead, they need to seek the approval of the Commission.

- Environmental damage - Economic damage - Social damage || E - Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || E.1 - Member States eradicate, control or contain the IAS of EU concern

E.2 - Member States eradicate, control or contain IAS of EU concern, share information and Commission provides guidance

E.3 - Member States eradicate, control or contain IAS of EU concern, share information and require approval from the Commission for the measures envisaged

The problems and
objectives of this proposal can be addressed in a proportional and realistic
manner by the following sub-options retained for further analysis, presented
below.

The basic legislative
instrument, containing actions A2, B2, C1, D2 and E2, represents
the minimum level of EU intervention. The main delivery mechanism would be a
single list of IAS of EU concern, linked to certain harmonised EU obligations:
bans on import, holding, sale, purchase, exchange; no release into the
environment, early warning and rapid response to newly establishing IAS, as
well as eradication, control and containment of established IAS of EU concern.
Furthermore, there would be obligations linked to the management of pathways of
introduction and spread of IAS. Stakeholders supported also elements which go beyond
the basic legislative instrument, thus the following actions have been
considered, as add-ons or alternatives:

a) adopting a more
stringent approach and extending the scope of certain provisions to go beyond
the single list of IAS of EU concern for the release into the environment
by:

§
add-on
C2:
introducing provisions on permits for release of IAS of Member State concern;
or

§
add-on
C3:
strict ban on any release of any alien species unless included in an EU list of
alien species approved for release.

b) adopting a more
stringent and interventionist approach as regards early warning and
rapid response by:

§
alternative
action D3:
Member
States do not have the choice they have an obligation to quickly eradicate
newly establishing IAS of EU concern and share information. If Member States
wish to resort to control or containment instead, they need to seek the
approval of the Commission.

This resulted in the
analysis of the following variants of the legislative instrument:

§
option
2.1:
the basic legislative instrument (A2, B2, C1, D2 and E2)

§
option
2.2:
introducing provisions on permits for the release into the environment of IAS
of Member State concern (A2, B2, C1+C2, D2, and E2)

§
option
2.3:
introducing a general strict ban on the release of any alien species, unless
included on an EU list of IAS approved for release (A2, B2, C1+C3, D2 and E2)

§
option
2.4:
introducing an obligation for rapid eradication of newly establishing IAS of EU
concern, with the possibility for derogations (A2, B2, C1+C2, D3 and E2).

5.3.1.     Option 2.1: the basic legislative instrument

The basic legislative
instrument would be underpinned by a single list of IAS of EU concern.
The use of a list linked to obligations is an effective, reliable and
science-based tool to set priorities for regulating species. It has been used
with success in other policy areas, at EU level (e.g. animal and plant health),
by third countries (e.g. US and Canada) and by EU Member States (e.g. Germany,
France, Latvia, the Netherlands, Poland, Portugal). Notably, the mechanisms
governing the basic legislative instrument would be similar to those supporting
the EU plant health regime and would build on lessons learned therein[70].

This list would include
alien species proven to be invasive by risk assessment[71],
performed, as it is the case presently, by Member States, consortia of Member
States or other organisations (e.g. EPPO[72]), based on
pre-agreed criteria (including environmental as well as socio-economic
considerations)[73]. A technical process
would be established with Member States to decide on minimum standards to
perform the risk assessments, in order to ensure sufficient coherence and
mutual recognition amongst Member States. Risk assessments would then be
evaluated by a dedicated standing committee, which would include
Member States representatives and which would also decide on whether a species
should be included in the list or otherwise. In order to reduce administrative
burden the procedure to decide on listing of IAS should be triggered for
several species at a time.

Building up the single
list of IAS of EU concern will be a gradual process, as it is not expected that
all IAS will be listed immediately. The process could start with a limited
number of IAS. Furthermore, the list would be a dynamic one to enable the
inclusion of new IAS requested by Member States, whose invasiveness has been
ascertained based on new scientific evidence, as well as the exclusion of
listed species when justified. The risk entailed by the listed species would be
high enough to justify harmonised EU-wide action, even if the species is only
affecting certain Member States (see 3.6.2 on solidarity). Although it is not
possible at this stage to know how many species will be listed as IAS of EU
concern, the 167 species listed in the SEBI list of IAS threatening
biodiversity has been used as a reference[74] in this
Impact Assessment but they will not constitute the EU list.

The list of IAS of EU
concern is associated with obligations aiming both to stop listed species from
entering into the EU (prevention) and to address the listed species that
have already entered the EU and become established (reaction) to avoid
their further spreading. These species might also be listed in national lists;
in that case listed species would be subject to EU rules as well as to national
rules. The obligations triggered by the list of IAS of EU concern would be:

Prevention - Species
listed as IAS of EU concern would be banned from
trade/import/marketing/transport (operational objective A) as well
as from release into the environment (operational objective C). Similar
to the plant health regime, provisional emergency bans would be possible for
alien species that are not yet listed, but that are thought to be invasive and
should therefore be listed, while the risk assessment is in preparation. The border
checks, to establish whether plants and live animals intentionally
introduced are on the EU list, would be integrated within the border
control system of Regulation 882/2004: this would maximise the synergies of the
IAS legislative instrument with existing legislation, thus achieving
considerable cost savings. Other border control checks, including those to
detect illegal or unauthorised introductions, will be performed by customs
officials at EU entry points (e.g. airports, harbours). It is expected that
such checks would add to the current responsibilities of customs officers and
there would be a need to organise trainings or to develop guidelines to
facilitate their task.

A proportion of the
listed species would, however, be introduced unintentionally in
the EU and escape or disperse into the environment. Moreover, many other
unlisted alien species can be brought into the EU unintentionally and may
become invasive. To capture these species in the regime (objective B), it will be
necessary to manage their pathways of introduction and release. Pathway
management, which received special attention in the Council Conclusions[75],
would include, but would not be limited to, border checks (e.g. on cargo or
commodities shipments) to help detect IAS, alongside other biosecurity
measures. While the pathways of pests and diseases are very specific (i.e.
infected animals and plants), the pathways of IAS are varied and numerous (see
3.2).

Here again a gradual
approach could be proposed. The legislative instrument would concentrate on a
very limited number of priority pathways of introduction known to be major
routes of entry of IAS on all Member States (such as ballast waters) as well as
requiring Member States identify other pathways of relevance to their
territory.

Member States would then
be required to take action to control the limited set of priority pathways and
those they have identified at national level. The measures taken,
which could
include merely awareness and voluntary measures and possibly regulatory
measures, similar, for example, to the system under the plant health regime, would have to
be reported to the Commission. The latter could thus maintain an oversight of
the process and engage with the Member States to review the approach if need
be. The
system is designed to develop with increasing implementation experience.

Reaction – the
species listed as IAS of EU concern would also be subject to the following
obligations: listed IAS newly establishing in the environment would need to
trigger an immediate reaction (operational objective D). The choice of
the appropriate and proportionate type of reaction, to quickly eradicate,
control or contain that species, would rest with the Member States. They
would have to notify the Commission and other Member States of the presence
of that species on their territory and the measures taken.

Finally, the list of IAS
of EU concern may also include species that are already known to be established
in the territory of some Member States (legacy of the past). In these cases,
concerned Member States would be obliged to take action to manage such species:
they would be free to select the appropriate and proportionate measures for
the management (eradication, containment or control)[76]
of established IAS (operational objective E) and would have to inform the
Commission and other Member States of the measures taken. The Commission could
provide guidance, if appropriate, to optimise effectiveness across the EU.

In summary, Member
States would be required to notify the measures taken to 1) manage major
pathways for listed and unlisted IAS; 2) rapidly respond to newly establishing
listed IAS and 3) manage the established listed IAS. The Commission would
provide advice where appropriate.

The above package of
actions would need two implementing mechanisms: 1) a dedicated
standing committee (mentioned above for its role in evaluating risk
assessments and adding/removing species to/from the list of IAS of EU concern)
and 2) a repository of information to collect and exchange information
on IAS.
The notification obligations to report to the Commission on measures taken and
the sharing of information to the repository of information will act also as
implementation mechanisms: they will be check points enabling an overview of
the process and monitoring and measuring progress against the operational
objectives and against the targets set by the Birds and Habitats
Directives, the Water Framework Directive and the Marine Strategy Framework
Directive; they
will also facilitate improved co-ordination amongst Member States and the
Commission.

5.3.2.     Option
2.2: introducing provisions on permits for the
release of IAS of Member State concern (i.e. basic legislative instrument with the addition of action C2)

Besides banning the
release of IAS of EU concern, this alternative would require permits for
releasing IAS of Member State concern, aiming to prevent the release of
IAS that may cause considerable damage in the future. The idea of a stricter
approach to release into the environment was favoured by Member States
representatives and also by a number of stakeholders within the Working Groups
on IAS. The idea of permitting requirements was supported by almost 34% of
respondents to the 2012 online consultation, compared to compared
to 36% in favour of introducing a list of species approved for release and 12%
in favour of
simply focusing on the list of EU concern (basic legislative instrument) (Annex
II).

This additional
requirement would only apply to IAS not in the list of IAS of EU concern,
but for which Member States consider that the damage deriving from their
release, while not fully ascertained, could be significant. Member States
would have the freedom and responsibility to identify such species relevant for
their territories (see Figure 8) for which they have reasons to believe they
may become invasive, for example because they have shown invasive behaviour in
similar ecological conditions. Based on current practice, Member States may
identify a few dozen species each[77]. For these
species of Member State concern, the Member State would be required to
introduce a system of permits to allow their release into the environment,
which may be linked to conditions set by the Member State[78]. A
permitting approach is already in place for certain species in several Member
States (e.g. France, Germany and UK) and a similar system has been successfully
introduced with Regulation 708/2007 on the use of alien species in aquaculture.
The added value of EU-action would be that this system would be recognised
EU-wide, Member States would cooperate on the selection of IAS, and their
selection would become an important reference when considering new candidates
for listing as IAS of EU concern. Figure 8 provides a schematic representation
of the rough proportions of the problem addressed by the basic legislative
instrument with the addition of action C2.

Figure 8: Schematic
representation of the rough proportion of the problem to be addressed by the
basic legislative instrument (i.e. the IAS of EU concern) adding action C2
(i.e. list of IAS of MS concern).

5.3.3.     Option 2.3: introducing a
strict ban on the release of any alien species, unless included on an EU list
of IAS approved for release (i.e. basic legislative
instrument with the addition of action C3)

In addition to the basic
legislative instrument, action C3 introduces a very ambitious precautionary
approach to deal with the release of species into the environment: no alien
species would be allowed to be released unless proven to be harmless by risk
assessment[79].
The additional action will be based on a common EU list of alien species
allowed for release in the whole EU, besides the list of IAS of EU concern,
which would still be valid for obligations other than those linked to release.
Unlike the approach based on the IAS of Member State concern under action C2,
this common EU list would be established, managed and applied at EU level. The
idea of such stringent approach to address release into the environment was
proposed by a significant number of stakeholders within the Working Groups on
IAS, although it found less support from Member States representatives. The
idea of introducing an EU list of species approved for release was supported by
almost 36% of respondents to the 2012 online consultation (see Annex II).

5.3.4.     Option 2.4: introducing an
obligation for rapid eradication of newly establishing IAS of EU concern, with
the possibility for derogations (i.e. basic legislative
instrument with alternative action D3)

While the
basic legislative instrument leaves the choice between eradication, control and
containment to the Member States, with this alternative they will be obliged
to rapidly eradicate newly establishing IAS of EU concern. Member States
will be able to apply for a derogation and they will need to prove that
eradication is technically unfeasible, a thorough cost benefit analysis shows
that costs are exceptionally high and disproportionate or eradication methods
are not available or those existing have very serious negative impacts on human
health or the environment. The Standing Committee would decide upon it, within
a limited time. Pending the Committee's decision the Member State would be
required to take measures to contain the IAS and prevent its spread. The
eradication obligation entails a high level of EU intervention and was
discussed during the Working Groups on IAS: representatives from Member States
were cautious about this approach, recognising the need to have EU intervention,
but worried about an obligation to eradicate at all costs. Nature conservation
organisations tended to favour an approach with stricter obligations.
Eradication of IAS was supported by almost 39% of respondents to the online
consultation, but the majority (slightly over 62%) advocated an approach based
on cost/benefit analysis. The approach proposed, with the possibility for
derogations, seeks to address these views.

Table 9 below summarises
the role of different actors in providing for the variable actions and variants
of the legislative instrument.

Table
9: Responsibilities for the Commission and the Member States for establishing
the measures foreseen in the proposed options.

Operational Objectives || European Commission || Member States

A - Prevent intentional introduction of IAS of EU concern into the EU || Option 2.1, 2.2, 2.3, 2.4: Management of list of IAS of EU concern || Option 2.1, 2.2, 2.3, 2.4: Development of risk assessments and proposing species for listing as IAS of EU concern Border control on IAS of EU concern

B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || Option 2.1, 2.2, 2.3, 2.4 || Option 2.1, 2.2, 2.3, 2.4: Pathway management

C - Prevent intentional release of IAS into the environment || Option 2.1: no further action Option 2.2, 2.4: no further action Option 2.3: management of list of alien species not yet present but approved for release || Option 2.1: prevent release into the environment of IAS of EU concern Option 2.2, 2.4 (additional to 2.1): management of permitting system based on national catalogue Option 2.3 (additional to 2.1): prevent release of alien species unless listed in the EU list of alien species approved for release

D - Early Warning and Rapid Response to prevent reproduction and spread of IAS of EU concern into the environment || Options 2.1, 2.2, 2.3: - management of notification and EU early warning system for IAS of EU concern Option 2.4 (additional to above): - management of applications for derogation || Options 2.1, 2.2, 2.3: - surveillance on IAS of EU concern - notification of new populations of IAS of EU concern - rapid response to new populations of IAS of EU concern Option 2.4 (additional to above): - rapid eradication of new populations of IAS of EU concern or application for derogation

E - Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || Option 2.1, 2.2, 2.3, 2.4 || Option 2.1, 2.2, 2.3, 2.4: Management of IAS of EU concern

Horizontal measures || Option 2.1, 2.2, 2.3, 2.4: - Management of information system on IAS - Reviewing progress - Management of standing committee || Option 2.1, 2.2, 2.3, 2.4: - Participation in information system on IAS - Participation in standing committee

6.           Analysis of the Options

The different options will be analysed in the
following sections. Table 10 provides a summary of the provisions of the
different options.

Table 10: Summary of the provisions of the
different options per operational objective

Operational Objectives || Option 0 - Business as Usual (baseline option) || Option 1 – Non-legislative initiatives and voluntary action || Options 2.1, 2.2, 2.3, 2.4: – Dedicated legislative instrument

A - Prevent intentional introduction of IAS of EU concern into the EU || - Wildlife Trade Regulation (however unconnected to the other objectives) - Non-harmonised bans in MS disrupting the internal market || - Guidelines encouraging joint action among MS - Additional awareness raising || - Risk-based list of IAS of EU concern

B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || - Ballast Water Convention (when into force) - Voluntary codes of conduct || - Additional codes of conduct - Additional awareness raising || - Efforts towards a harmonised approach across the EU, which could include awareness raising and voluntary actions and regulatory measures

C - Prevent intentional release of IAS into the environment || - Alien species in aquaculture - Micro-organisms as biocides || - Guidelines encouraging joint action among MS - Additional awareness raising || - Option 2.1: Harmonised approach across the EU on the release of IAS of EU concern - Option 2.2, 2.4: adding a permit requirement for IAS of  MS concern - Option 2.3: in addition introducing a strict ban on any release of any alien species into the environment unless included in a common EU list of alien species approved for release

D - Early Warning and Rapid Response to prevent reproduction and spread of IAS of EU concern into the environment || - Voluntary initiatives || - Guidelines encouraging joint action among MS - Additional awareness raising || - EU-level early warning system - Option 2.1, 2.2, 2.3: Rapid response obligation (eradication, control or management) for newly establishing IAS of EU concern - Option 2.4: introducing the obligation to eradicate newly establishing IAS of EU concern with a possibility of derogation

E - Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || - Ad-hoc approach || - Guidelines encouraging joint action among MS - Additional awareness raising || - Obligation for MS to manage widely spread IAS of EU concern, though the choice of measures is left to them

One
inherent difficulty faced in analysing the impacts of different options was the
fact that it is impossible to know in advance how many and what sort of
invasions will need to be tackled. Similarly, it is not yet known what and how
many species will be included in the list of IAS of EU concern[80]. Finally,
the assessment would have benefitted from the availability of more data,
especially for certain sectors[81] and for
certain species[82], but until
recently large-scale and comprehensive economic studies on IAS in general have
been rare[83].

Another
important consideration to be made is that the sectors likely to be affected by
the legislative instrument are thought to include several SMEs, including
microenterprises. The Commission is concerned about the impact of
legislation on small and microenterprises and has a policy of minimising the
burden on these businesses; however, they would be expected to fall under the
scope of the legislation. IAS can have serious negative impacts on SMEs in
sectors such as forestry, agriculture, tourism and recreational activities,
businesses currently suffering from the lack of coordinated action on IAS.
These sectors would thus benefit from the introduction of coordinated measures
to tackle IAS. On the other hand, other SMEs, such as pet traders and the
horticultural sector, benefit from trading alien species and could be impacted
by the introduction of legislation to tackle IAS, which may pose some
restrictions on the use of alien species although it is generally recognised
that for most purposes there is always a choice of substitute species that do
not present invasive characteristics. Hence the SMEs may adapt their activities
without severe losses. Nevertheless, trade in pets and horticultural species
are recognised as important pathways of introduction of IAS. Therefore, SMEs
and microenterprises will be expected to fully apply the provisions of proposed
legislation that apply to them, as excluding these players would completely
undermine the effectiveness of the instrument in achieving the proposed goals.
Were the microenterprises to be excluded, action on IAS would mostly be taken
by public authorities. Action on prevention would be largely undermined as the
system would not cover some important sectors responsible for the introduction
of IAS into the EU. This would also lead to increased costs for public
authorities and other stakeholders in eradicating or otherwise managing IAS,
brought in by other sectors leaving unaltered the current situation, where
costs and benefits are unevenly distributed. SMEs and microenterprises would
thus need to comply with the proposed legislation. It must be underlined,
however, that the system envisaged caters for some flexibility to tackle these
sectors, while keeping the impact on small and microenterprises to a minimum[84].

6.1.        Economic impacts

6.1.1.     Option
0: Baseline

The analysis of the
baseline found that the total cost of this action amounts to €1.4
billion/yr (see Table 11 and Annex VII), mostly for predominantly reactive
action (management of damage) (see rows D and E in Table 11).

Table 11: Estimated cost
of action for option 0, based in so far as possible on current expenditure

Option 0 ||  Estimated cost || Expected trend in costs

A - Risk Assessments || Implementation cost of €3 mio/yr[85] for Member States || =

B - Pathway management || Implementation cost of ballast water treatment: € 109 mio/yr[86] and biofouling treatment: min. €13,700/vessel/event[87] for operators Some awareness campaigns in Member States || ↑↑ When Ballast Water Convention enters into force ↓↓ as the technologies for ballast water treatment evolve and become more efficient and cheaper

C - Release into the environment || Variety of systems in Member States, difficult to quantify || =

D – Surveillance || Implementation cost of €7 mio/yr[88] for Member States EEA: Nature Watch - pilot project on IAS[89] || =

D - Rapid eradication || Included in management of IAS || =

E - Management of IAS || Implementation cost of €1.309 bio/yr[90], for Member States, EU and citizens || ↑↑ or large damage increase (see 3.5)

Information system || Implementation cost of €3.4 mio/yr for Member States and EU, including information systems at Member State level (€3.3 mio/yr[91]), NOBANIS (€120,000-140,000/year[92]) and efforts by JRC into EASIN (€230,000/year[93]) || =

Policy management || Strategy development, policy development and coordination and policy support (studies): implementation cost of €2 mio/yr for Member States[94] || =

|| € 1.433 bio/yr || ↑↑ or large damage increase (see 3.5)

6.1.2.     Option
1: Cooperation and voluntary action

The actions
proposed under Option 1 include voluntary exercises to coordinate and
communication and awareness raising campaigns.

The
additional costs of option 1, compared to potion 0, are thought to be limited:
they would be limited to organising campaigns and voluntary actions, generally
cheaper than the actions needed to manage the damage of IAS. On the other hand,
a number of effective campaigns could reduce the cost increase of damage
management. It is nevertheless very difficult to assess the possible impacts of
cooperation and voluntary action: thus it can be reasonably assumed that their
impact on the massive damage management costs will remain limited. The cost of
option 1 will thus be considered within the same magnitude as option 0, thus
€1.4 billion/yr, although the cost increase in the future might be less
pronounced.

6.1.3.     Option
2.1: the basic legislative instrument

The basic
legislative instrument would introduce mandatory provisions aiming (1) at
preventing new species entering or establishing in the EU and (2) at
coordinating the management of established species so as to eliminate, minimise
or mitigate their damage.

The measures would lead
to a reorganisation of the current expenditure - focusing more on
prevention and less on reaction - and to a more efficient use of resources – through a
coherent prioritisation. Additional costs compared to the baseline
would be kept to a minimum – by making maximum use of existing provisions. Efficiency
gains will accrue from: 1) more focus on prevention, which will result in an
avoidance of damage costs growing by billions a year; 2) coordinated action
focusing on the list of IAS of EU concern, resulting in streamlined measures, avoiding
action in one Member State being undermined by lack of action in a neighbouring
Member State;
3) sharing information, thus avoiding parallel investment and the duplication
of efforts, e.g. investments in data collection and risk assessments; and 4)
integrating actions into existing systems in so far as possible by (a)
integrating IAS surveillance into the current surveillance of biodiversity, (b)
building an IAS information system based on current information systems and (c)
integrating the border control on intentional introductions of IAS into the
current border control in support of the animal and plant health regimes, thus
keeping additional costs to a minimum.

The costs of option
2.1 have been estimated on the basis of similar experiences in EU policy
implementation and in Member States or with other organisations (e.g. EPPO).
See Table 12 below. Based on an analysis of the current Commission staffing for
the Plant Health Regime, and on a comparison of the work needs deriving from
the two systems, it was concluded that no additional staff would be necessary
to manage the new policy compared to the current set up. The necessary
additional costs for the Member States for action stemming from Option 2.1
would be around €26-40 million/yr. This minimal increase compared to the
current costs of €1.4 billion/yr is due to the efficiency gains outlined
above.
How this cost of action develops over time will be a function of Member States'
efforts to manage pathways and IAS of EU concern. As this is uncertain, it is
difficult to predict how those costs will change, but it is possible that they
will decrease over time: Table 12 sets out a realistic scenario whereby due a
concerted action on a common set of listed IAS that would focus efforts of
several Member States on the same species, the population would be brought down
and a 50% reduction in the current management costs could be reasonably
expected, thus bringing the total costs over time to €1 billion/yr.

Table
12: Costs of option 2.1

Option 2.1 || Estimated costs || Expected trend in costs

A – List of IAS of EU concern || Some opportunity costs for traders of exotic species[95] || = The availability of alternatives will lead to a reduction of opportunity costs while newly listed species will raise the opportunity costs

A - Risk assessments || Implementation cost of €1.4 mio/year[96], mainly for Member States || ↓ Once a first list is in place the cost of additional risk assessments will decrease

A - Border control on intentional introductions || Limited implementation costs for Member States[97], thanks to integration with current controls on live animals and plants for planting (see 5.3.1) || =

B - Pathway management, incl. border control on unintentional introductions || €135.5 to 150.1 mio/year of implementation costs to be shared among Member States and transport operators. This amount includes an additional cost of  + €26 mio/yr[98] + € 0.5 mio/yr[99], optionally + €14.6 mio[100]/yr on top of €109 mio/yr baseline costs for ballast water treatment[101] || ↑ Gradual cost increase as pathway management develops

C - Release into the environment || Some opportunity costs for primary producers[102] || =

D - Surveillance || Implementation costs of €7 mio/year for Member States[103] || =

D – Rapid eradication || Included in Management of IAS || ↑ New IAS circumventing the prevention will more often be eradicated[104]

E - Management of IAS || Implementation costs to manage or eradicate IAS: €1.309 bio/year[105] || ↓ Expected to decrease to € 0.922 bio/yr for Member States[106]

Information system || Implementation cost (including some administrative costs for notification) of €3.6 mio/year[107] || = Expected to shift from Member States to Commission

Policy management || Implementation cost (including some administrative cost for reporting) of €2.1 mio/year[108] || =

TOTAL || €1.459-1.473 bio/yr plus some opportunity costs for traders of exotic species and primary producers || ? Expected to decrease to 1.072-1.086 bio/yr over time Although expected cost increase for IAS that circumvent the prevention measures In total, far less damage increase than under options 0 or 1 (see quantification of benefits)

A quantification of the benefits
of the basic legislative instrument is difficult as the benefits – or the
avoided damage costs – will depend on which IAS will threaten the EU and will,
through legislation, be prevented from entering, spreading and causing
excessive damage. As there are uncertainties on the number and invasiveness of
IAS, a preliminary assessment is made.

In terms of avoidance
of damage cost increase based on an estimation of the IAS that enter the EU
every year, assuming that half of those could be stopped by the legislative
instrument and taking into account cumulative benefits, it has been estimated
that a €2 billion/yr saving in the long term after 4 years[109] of
implementation could be achieved. Moreover, wherever newly establishing IAS
could not be prevented but would be listed and managed in a coherent way, even
more damage costs would be avoided. It will indeed not be possible to
completely eliminate increasing damage and costs of action through new
invasions. This estimate is of course rough, but illustrates the potential
benefits in a simplified manner.

In summary, the basic
legislative instrument would result in the current costs of damage and
management of at least €12 bio/yr not to increase as much as they would without
the EU action, thanks to

·
the
prevention of additional invasions and all related costs, although some IAS
will still circumvent the prevention measures;

·
coherent
and targeted action towards established IAS and unstopped new IAS, as to keep
their damage and management costs to a minimum.

The impacts of the
different measures are illustrated in the following paragraphs:

Single list of IAS of EU
concern banned from trade/transport/marketing and release into the environment – Current
total spending on risk assessments in the EU is estimated to amount to €3
mio/yr. Developing common risk assessments, which could be used by all Member
States, is estimated to cost roughly €42,000 per species[110].
Adopting a gradual approach with the development of 167 risk assessments over
the next 5 years (estimate based on the SEBI list), the estimated cost for the
whole EU could amount to €1.4 mio/yr, less than half the current yearly
expenditure (see Table 11). Thus developing such a list entails costs
for Member States and other organisations for carrying out risk
assessments. However, considerable savings can be made as risk
assessments will be used by all Member States and for compiling an EU list,
thus avoiding duplication of efforts.

Border controls on intentional
introductions would be integrated in the system of border controls already in
place for plants and live animals, at designated entry points, thus minimising
the costs of check on intentionally introduced IAS plants and animals: a
study to support the review of the plant health regime[111]
found that the additional costs of integrating border control on invasive alien
plants in the current system would be negligible, as no adaptation to current
practices would be required. The same can be assumed for invasive alien
animals, however, there will be some moderate extra costs for special training
for designated entry points' staff to enable them to detect IAS. Other border
inspections will be carried out by customs authorities at any EU entry points:
such checks would add to the current responsibilities of customs officers and
there will be a need to organise trainings or developing guidelines to
facilitate their task. The cost of these initiatives will be borne
partly by the Member States and partly by the Commission (see Table 12). As
many Member States already have trade bans on IAS in place, it is expected that
the additional costs of action would be moderate (see Table 12).

These prevention
measures will significantly benefit public authorities in terms of cost avoidance:
wherever the intentional introduction or release of a new IAS is prevented,
enormous subsequent damage and management costs are avoided[112] (see also
Annex VII).

Only in so far as
species of interest to a sector were banned, primary producers (mostly
small and microenterprises) would be affected by the introduction of a list of
IAS of EU concern, at least until the identification of suitable substitute
species. Based on input from stakeholders, non-invasive or native substitute
species would be readily available in most cases[113]. On the
other hand, primary producers would also benefit significantly from prevention:
wherever the intentional introduction or release of a new IAS is prevented,
enormous subsequent damage and management costs are avoided. For example, the
forestry sector suffers the consequences of the intentional introduction of
black cherry: had the introduction of this species been prevented, the sector
would not be burdened with the costs of management (e.g. € 3.4 mio/yr for
management in German forests[114]
- see Annex VII).

For traders or
breeders of exotic species, (also mostly small and microenterprises), the
introduction of a list of IAS of EU concern is expected to have an economic
impact, but the extent of this impact will depend largely on the number and the
species included in the list. The sectors involved recognise that IAS are a
problem, but stressed the need for any trade bans to be based on scientific
grounds. The SEBI list includes 27 species sold as pets. Most of these species
are not high value commodities and are traded in small volumes: many rarely
enter the regular pet trade but are rather exchanged by hobbyists[115].
Turtles, clawed toad and ring-necked parakeet are an exception as they are commonly
sold. Only koi was identified as a highly valuable species, the banning of
which would have rather heavy economic consequences on the sector.
Notwithstanding the considerable data gathering efforts, it was not possible to
precisely assess the impact on specialised dealers as those enterprises have no
obligation to register traded species. If there are traders that deal with a
limited number of species and these species were to be banned, then these
businesses would be negatively impacted. These concerns will be duly considered
by the Member States experts and representatives during the listing procedure[116].
For most species, however, it is thought that non-invasive or native substitute
species would be readily available.

One important benefit of
the introduction of the list of IAS of EU concern would be to ensure the smooth
functioning of the internal market by setting a harmonised and
transparent approach to risk assessment, representing a substantial
improvement compared to the current situation where Member States are
introducing non harmonised trade/marketing/transport bans, which hinders the
free movement of goods.

International trade of alien
species would be affected to the extent to which traded species were banned.
This disruption is likely to be limited as the species likely to be listed
would a) be traded in small volumes or b) not necessarily be high value
commodities, with some exceptions: indeed a high value species may be listed
where justified on the basis of risk[117]. In any case, any
ban on trade would be based on risk assessment and thus be compatible with WTO
and SPS agreement.

In terms of legal
certainty for business, including small and microenterprises, all sectors
using IAS would benefit from a clear framework, harmonised across the EU and
focused on a common set of species to be banned from trade/marketing/transport
and release that would ensure a level playing field across the EU. In terms of competitiveness
and profitability of business, certain sectors will face certain constraints
in choice. This will be the case for example for biomass producers: if a
valuable, fast-growing plant species were to be banned on account of its
invasiveness, certain operators may find themselves at a disadvantage compared
to international competitors. It has to be stressed, however, that major
trading partners such as the US and Canada already have stringent IAS policies
in place, which also place constraints on the choice of species for potential
competitors to EU businesses. These constraints concern only proven IAS and
they could be overcome by species substitution, which will imply more efforts
for businesses in their business strategies, being mindful of the invasiveness
potential of the species they select and understanding that substitution is not
always an immediate opportunity. Furthermore, there are some businesses that
rely heavily on a single species and their profitability would be seriously
undermined, were this species is to be banned. One example is the fur breeding
sector: an important and profitable sector in the EU, it relies heavily on the
American mink[118]
and would suffer a significant negative impact from a ban. Impacts on such
sectors and related supply chains will be thoroughly evaluated by the
Commission and the Member States representatives during the listing procedure.
Socio-economic impacts will be an integral part of the analysis and procedure
on the basis of which species will be listed.

Obligation to manage
major pathways of unintentional introduction into the EU and unintentional
release into the environment – the obligation to manage major
pathways seeks to address species coming in accidentally, which have been
estimated to represent roughly three quarters of all introductions. It is
therefore an important provision, addressing a substantial part of the problem
and enabling to go beyond what the list of IAS of EU concern could achieve, by
capturing new IAS arriving by accident. The need to address pathways was
recognised by the Member States during the consultations. Such provisions will
entail substantial costs of action, mostly for Member States (e.g. increased
controls on commodities or transport vectors), but potentially also for the
private sector (e.g. implementing more stringent biosecurity measures),
depending on the type of measures introduced. A gradual approach could be
introduced whereby action is required on a limited set of pathways known to be
major routes of entry of IAS into the EU and evolve further with the
identification of major pathways of relevance to the Member State. While it is
not possible to know in advance how many and what type of measures Member
States will establish, it is clear that the costs of action will be
proportional to the stringency of the measures (see Box 5). The same can be
said about the benefits, with the chances of stopping new IAS at the borders –
that would otherwise come in undetected – being higher with a more stringent
system and more impermeable borders. The fact that Member States will have
freedom to choose what measures to apply should provide them with enough
flexibility to ensure that costs are not disproportionate and do not exceed
benefits and allows an evolution over time.

Box 5 –
Provisions for pathway management

The routes by
which invasive alien species enter a new area or new habitats are known as
pathways. Since about three quarters of the IAS are unintentionally introduced
into the EU addressing pathways of unintentional introduction will be
increasingly important.

In the EU,
some pathways have been identified and actions have been taken on them hence
experience is being gained, like on ballast water contaminated with aquatic
organisms (Ballast Water Convention – not yet in force)

Many Member
States are starting to further address the issue, with a particular focus on
the collection and analysis of information on pathways of IAS. The option
analysed in this Impact Assessment, building on experience already gained at EU
level, would require that Member States identify the major routes of
introduction of IAS in their territory. This exercise has already been done by
some countries, such as France, as shown in Figure 9.

Figure 9:
Pathways of introduction into France (pink = plants, orange = invertebrates,
blue = fishes, purple = vertebrates) (Ménigaux, 2010)

The option
envisaged would also require Member States to take actions to control the major
pathways identified. Few Member States have developed targeted action towards
specific pathways of IAS. One example of such action is the UK "check
clean dry" campaign which cost approximately €100,000. This programme is
making water users aware of how they unknowingly are helping the spread of IAS
from one water body to another through equipment.

This would entail costs
for public authorities; they would be organising the campaigns or setting
the regulatory measures, as well as organising more stringent controls - under
the plant health regime pathway management currently costs €26-40 mio/yr (Table
12). Border controls for unintentional introductions in particular could entail
significant costs.

Depending on the type of
measures adopted, costs will also be faced by traders, transport companies
and operators: certain implementation costs may be entailed by the
introduction of biosecurity requirements on certain commodities or transport
vectors. There are already some Sanitary and Phytosanitary Standards besides
the rules regulating the release of alien species for aquaculture and the
provisions of the Ballast Water Convention. Nevertheless, for the other
pathways, limited initiatives have been taken, mostly consisting of the
development of awareness-raising campaigns and voluntary codes of conducts in
certain sectors. The obligation to manage pathways and the provision for EU
advice would be expected to stimulate and gradually strengthen a coordinated
approach. The cost involved needs to be measured against the cost of not
acting to manage pathways, which could become prohibitive in terms
of damages caused by IAS to be borne by society at large.

Some additional costs
are expected for traders of some commodities that can be contaminated by IAS
(e.g. animal feedstuff containing IAS seeds, wood containing IAS
invertebrates), who could be required to inspect their goods before entry into
the EU. However, such measures will significantly benefit public authorities:
wherever the unintentional introduction of an IAS is prevented, enormous damage
and management costs are avoided (e.g. €130 mio/yr of yield losses in Hungary[119]
would have been avoided if introduction of ragweed had been prevented, see
Table 3 and Annex VII for more examples).

Obligations linked to
early warning and rapid response action – requirements linked
to rapid response to species listed as IAS of EU concern include the costs
of surveillance and of notification to the Commission and other Member
States. These requirements will, however, rely in so far as possible on
existing structures and information systems, thus keeping new costs
for public authorities to a minimum. When it comes to eradication,
containment or control, the costs are highly variable and depend on the species
in question and the circumstances and environment where it is detected. To
provide an indication of the magnitude of costs entailed, it is useful to
consider that currently Member States are spending between €50,000 and €14
million per invasion to eradicate IAS[120]; containment and
control measures may be cheaper, but would continue indefinitely. These costs
are largely met by public authorities and to a lesser extent by affected
private sector operators. Again, the costs of taking early action may be
substantial, but will be largely offset by the benefit of cost avoidance
(see examples above, Table 3 and Annex VII).

Obligation to eradicate,
contain or control established IAS of EU concern – the obligation
to manage established species listed as IAS of EU concern will entail substantial
costs for Member States public authorities and the private sector because these
often spread over large areas. However, the exact cost is impossible to
calculate as it will largely depend on which and how many listed IAS will
already be established in Member States. Activities to manage widely spread IAS
in Member States (e.g. management of floating pennyworth in the Netherlands[121],
muskrat in Germany[122],
giant hogweed in Latvia[123],
IAS in waterways in the UK[124])
have costs ranging from €0.5 million to €24.5 million a year[125]
(see Table A-10 in Annex VII). The magnitude of the cost will also depend
largely on the effectiveness of the measures taken to prevent the introduction
into the EU and the establishment in the environment of IAS. During the
consultations, Member States mostly stressed the need to maintain flexibility
in addressing established IAS, but recognised the importance to take
coordinated action and recognised that provisions linked to a single EU list
would ensure coherent action across the EU. This would avoid waste of funds
(see 3.4) and yield benefits in terms of damage cost avoidance.

Implementing mechanisms – there is
currently no dedicated standing committee working on IAS, although some
work on aquatic IAS could be done through the existing legal structures
implementing the Marine Strategy Framework Directive the Water Framework
Directive and the Aquaculture Regulation. However, for terrestrial IAS or for
integration across regional seas, catchments and biogeographic regions, an
additional structure would be needed: based on costs of existing similar
structures supporting the implementation of the Wildlife Trade Regulation, a
dedicated structure could cost the European Commission around
€80,000/year, assuming three yearly meetings.

As regards the centralised
repository of information, there is currently a variety of information
systems in place at the international, EU, regional and Member States
level (see 3.4).
Average Member
States’ current expenditure, on collecting (excluding on surveillance on the
ground), managing and sharing information, amounts to €120,000/year per Member
State (roughly €3 mio/yr in total)[126]
and some Member States are already investing in a common early warning system
(NOBANIS). At EU level, the Joint Research Centre is working on the integration
of information on alien species in Europe which could evolve in a phased
approach as needs emerge and implementation experience is gained. Developing a
central repository would lead to a certain shift in costs from Member States
to the EU for gathering and processing data, but costs are not
expected to increase substantially compared to current national
expenditure.

In
conclusion, the basic legislative instrument could negatively impact on
international trade (but only if commonly traded high value IAS were banned)
and, in so far as suitable alternatives could not be found, on those small and
microenterprises cultivating IAS or trading pets and ornamental species. The
instrument would positively impact the efficiency of spending by Member
States public authorities and the legal certainty and market predictability for
businesses. It would prevent continuously growing damage and management costs
to the benefit of public authorities and small and microenterprises affected by
IAS. On balance the economic impact of the basic legislative instrument was
considered to be positive while some short term investments will be needed.

6.1.4.     Option
2.2: Adding permits for releasing of IAS of Member State concern

 A
summary of the costs of option 2.2 can be found in Table 14.

Managing
a system of permits for releasing certain species is would represent a cost
for public authorities, with additional staffing needs for some Member States;
however the cost cannot be estimated as the system set up will depend on the
Member States. Charging the permit applicants, who have a benefit from the
release of a species can help reducing the costs of the system. Member States
authorities would also have to evaluate which IAS they consider of Member State
concern and the basis on which permits for release could be granted. It is not
possible, however, to provide an estimate of total costs as this will depend on
the number of IAS and on the level of interest for releasing such species. It
has to be considered, however, that 14 Member States are already legally
restricting release into the environment (see Table 4 and Box 6), which means
that this action would entail limited or no additional costs for those Member
States. In addition Member States expressed their preference for requiring a
permit for any release of alien species in the environment. Also the public
consultation revealed that 34% were in favour (see Figure A-3 in Annex VI) of a
general permit requirement for releases. Such system would indeed entail significant
benefits. IAS of Member State concern would be released only in cases where
the benefits of their release would justify taking the risk. This option would
decrease the risk of new invasions, with benefits in terms of damage
avoidance.

Box 6 - Permitting
systems for IAS of Member States concern

The option
envisaged would require Member States to set up permitting systems for IAS
which they deem to be of concern. Today a majority of Member States already
have a permitting system in place regulating the release of alien species into
the environment. Permits are required for every single release. Most
Member States considered this as the most effective way of controlling the
release of species that can potentially cause significant environmental and
economic impacts. Some indications of the administrative cost of such system
can be given on the basis of existing permitting systems. For the Wildlife
Trade Regulation (WTR), including a similar permitting system, it was
calculated that each permit could cost around €157[127] (See Table
12) (this includes the human resources costs of handling the permit).

Looking into
Member States permitting systems for release into the environment yearly costs
can be estimated. The UK prohibits the release into the environment of
non-native species although a release may be authorised under a licence from
the competent authority (Natural England). Applications can be submitted online
and are processed within 30 working days.  The system relies on approximately 1
Full Time Equivalent (FTE) who acts as a licensing manager. In 2010 the system
received and processed 34 requests for release of alien species in the
environment and 37 in 2011. Denmark conveyed to the Commission that it devotes
150 man-hour/year (roughly 0.1 FTE/year) for the administration of permits for
releasing non-native species. In Germany, permits are handled at the Länder
level. Germany indicated that the number of applications for licenses is rather
limited, with for example, less than 10 applications per year in Rhineland
Palatinate and 1 in 2010 and none in 2011 in Hesse. Based on a realistic
estimate that Member States spend roughly between 0.1 and 1 FTE on permitting
(on the basis of information about staff time and volume of applications
processed), and given an average salary of average hourly tariff of a
technician or associate professional of €23.2, the cost of the permitting is
estimated to be €3,714 to 37,142 per Member State per year, or €100,000 to 1
mio for all 27 Member States. Comparing this cost estimate with the cost per
permit under the Wildlife Trade Regulation shows that this estimate is rather
on the high end of the range.

This indicates that the burden of the permitting systems for
IAS of Member States Concern would be limited particularly taking into account
that many Member States already have such system in place.

Primary producers, such as agriculture
and forestry, and the horticultural sector, would face costs for
collecting evidence in support of the application for a permit for the release
of IAS of Member State concern, and paying permit fees, where required
(although it may be expected that it would be rather the larger importers
seeking a permit to bring such species into the EU). This will entail costs,
which will also depend on the type of requirements linked to the permits by
Member States and on the degree of cost recovery by Member States[128]. This system
is expected to place some constraints on the choice of species that can
be released in the environment or brought onto the market. However, the impact
on the competitiveness and profitability of business for these sectors
will remain limited to the subset of IAS of Member State concern. The
system may require a shift in the business planning of certain operators that
will have to consider alternative species. However, considering the abundance
of species available, it is thought that substitution for certain species would
be possible.

It should also be
stressed that primary producers often suffer from the consequences of an
invasion of certain species and would therefore benefit from a more
proactive approach that prevented new invasions. According to the polluter
pays principle, those responsible for damage should pay: having to apply for a
permit to release certain species has thus the potential to help private
sectors players avoid future liabilities[129].

Other private sector
operators
would be affected in so far as the species they sell are meant to be released
into the environment. Traders of biological control agents could be
affected, nevertheless, the need for precaution in this sector is generally
more commonly accepted and Member States are gradually introducing obligations
in this regard (e.g. France). Some of the benefits in terms of
awareness-raising and knowledge gathering highlighted in the previous paragraph
would also apply to this sector.

A
permitting system would thus entail costs for public authorities and small and
microenterprises involved in primary production, besides placing some
constraints on the choice of species for release. However, the system would
focus on a limited number of species for which Member States seriously suspect
that that may have a negative impact. Furthermore, this proactive approach
would entail additional benefits for Member States and small and micro primary
producers in terms of avoidance of damage and management costs, offsetting the
negative impacts. Overall, the economic impacts of this action were found to be
positive for public authorities and moderately negative for
various economic actors.

6.1.5.     Option
2.3: Include a strict ban on release of any alien species into the environment
unless it is included in a common EU list of species approved for release into
the environment

A
summary of the costs entailed by option 2.3 can be found in Table 14.

Public
authorities would face the costs of carrying out the risk assessments to
be able to include species on the EU list of alien species approved for
release. The number of risk assessments to create a list of approved alien
species could be large, as it would include all new species intended for
release into the environment. It may also be more costly for public
authorities in terms of enforcement efforts. It has to be stressed,
however, that during the consultations, Member States representatives were
generally in favour of a precautionary approach to release into the
environment, some favouring a list of approved alien species. During the 2012
public consultation, 36% favoured a list of approved alien species (see Figure
A2 in Annex VI). The creation of an EU list of alien species approved for
release would also increase the burden on the European Commission in terms of
developing and maintaining the list of alien species approved for release
up-to-date, thus increasing the cost of running the supporting structures. The
benefit of this stringent option would be a further avoidance of damage.

Primary
producers
(mostly small and microenterprises in agriculture, forestry and horticulture),
would be negatively impacted by the introduction of a ban on release
unless a species was placed on an EU list of alien species approved for
release: they would face opportunity costs and their business and activities
would be disrupted for the period that the necessary risk assessments
are being carried out. This option would not only restrict the choice of
species for release, but would rather determine the limited choices available,
hampering business and negatively affecting the competitiveness and
profitability of these sectors, as also the possibility of using
substitutes would depend on a positive risk assessment. Such constraints will
be particularly felt by the sectors dealing with plant species, considering the
volume of alien plant species that are traded[130]. As primary
producers often suffer the consequences of an invasion, they would also benefit
from a more proactive approach, but at the cost of serious disruption of
certain activities.

Taking
all the above factors into account, despite the substantial benefits in terms
of prevention of new invasions, the negative economic impact on Member
States and on small and microenterprises involved in primary production was
considered significant.

6.1.6.     Option
2.4: Obligation to rapidly eradicate newly establishing IAS of EU concern

A
summary of the costs entailed by option 2.4 can be found in Table 14.

The
introduction
of the obligation for Member States to eradicate newly establishing IAS of EU
concern, unless derogation is granted by the Commission, entails significant
costs. Although costs of surveillance and notification to the
Commission and other Member States would be the same as for the basic
legislative instrument, the costs of eradication are likely to be
substantial and highly variable[131] and will
largely be met by public authorities.

There is evidence,
however, that an immediate eradication would entail significant
benefits for all actors involved, in particular the Member States public
authorities and the small and microenterprises involved in primary production
(farmers), as eradicating an IAS would permanently solve the problem, and thus
avoid the need for continuous management. The economic benefit of a rapid
eradication in the early invasion stage, rather than attempting eradication
later, once an IAS is fully established, is clearly illustrated in the UK
case in Table 13. All data show a substantial increase of costs along the
invasion stage. Determining the invasion stage will depend largely on the
species lifecycle, but it will also be a function of the number of specimens
and geographical spread: if the number of specimens is small enough and/or
sufficiently contained in a certain area for eradication to be readily
possible, then it is possible to talk of early invasion stage.

Table 13:
Eradication costs in earlier and later invasion stages in the UK (invasion
stage differs depending on the species’ life cycle)[132]

IAS || Eradication costs (€)

Earlier invasion stage || Later invasion stage

Asian long horned beetle || 39,000 || 1,524,974,000

Carpet sea squirt || 2,728,000 || 1,074,173,000

Water primrose || 85,000 || 280,129,000

Grey squirrel || 510,000 || 985,216,000

Coypu || 5,443,000 || 21,776,000

Preferring eradication
when it comes to rapid response has considerable cost-saving opportunities: the
UK successfully eradicated the coypu between 1981 and 1989 at a cost of €5
million. In Italy, the coypu was instead allowed to establish and spread,
costing €11.6 million in damage and €2.6 million in management activities
between 1995 and 2000, with projected future damage and management costs of
€9-12 mio/yr (Figure 10).

Eradication at an early
stage of invasion would need to focus on a relatively limited number of
specimens, presumably concentrated in a smaller geographical area, thus
rendering the eradication operations easier and quicker from a logistical and
operational point of view.

When and where
eradication proves impossible or no longer feasible Member States could ask for
derogation. This would entail some administrative cost for the Member
States, as the application would need to be motivated and backed by
evidence, and for the European Commission to evaluate such application.
However, it is expected that this Option will provide a stronger incentive to
Member States to attempt eradication wherever possible, thus avoiding damage
and management costs in the future, which is expected to off-set the initial
higher costs of eradication programmes.

Figure 10: Total number
of coypus removed (per year) in the successful eradication campaign in the UK
during 1981-1992 (black dots) and in the management operations in Italy during
1995-2000 (white dots)[133]

While small and
microenterprises involved in primary production would benefit in terms
of avoided damage costs, they may also face the burden of participating in
eradication efforts, albeit with some support from public authorities.

In conclusion, this
action is likely to entail higher costs for Member States and the Commission,
but the substantial benefits in terms of cost avoidance are expected to greatly
outweigh such costs. The economic impact would therefore be very positive
(see Figure 10).

Table 14: summary of the
additional costs of options 2.2, 2.3 and 2.4 in comparison with option 2.1

|| Option 2.2 || Option 2.3 || Option 2.4

A – List of IAS of EU concern || Same as option 2.1 || Same as option 2.1 || Same as option 2.1

A - Risk assessments || Same as option 2.1 || Same as option 2.1 || Same as option 2.1

A - Border control on intentional introductions || Same as option 2.1 || Same as option 2.1 || Same as option 2.1

B - Pathway management, incl. border control on unintentional introductions || Same as option 2.1 || Same as option 2.1 || Same as option 2.1

C - Release into the environment || Some additional opportunity costs and  some administrative costs for primary producers[134] || Much higher opportunity costs for primary producers[135] Much higher implementation cost (risk assessments) for Member States [136] || Same as option 2.2

D - Surveillance || Same as option 2.1 || Same as option 2.1 || Same as option 2.1

D – Rapid eradication || Same as option 2.1, however less new IAS will circumvent the prevention[137] || Same as option 2.1, however far less new IAS will circumvent the prevention[138] || More implementation costs for Member States (more IAS to eradicate), however more rapid eradication will further decrease the number of new invasions[139]

E - Management of IAS

Information system || Same as option 2.1 || Same as option 2.1 || Same as option 2.1

Policy management || Same  as option 2.1 PLUS · Permitting system: implementation cost of €100,000-1mio/yr[140] for Member States (see 5.3.2 and Box 6) || Same as option 2.1 PLUS · Implementation cost for management of EU list of approved species for the Commission || Same as option 2.1 PLUS · Administrative cost of handling derogations for Commission and Member States

TOTAL || Same as option 2.1 PLUS · €100,000-1mio/yr for Member States · Some additional opportunity costs and administrative costs for primary producers · More avoidance of damage increase than option 2.1 (see 6.1.4) || Same as option 2.1 PLUS: · Management cost Commission · Serious risk assessment cost Member States · Serious opportunity costs primary producers · Far more avoidance of damage increase than option 2.2 (more than option 2.4) (see 6.1.5) || Same as option 2.2 PLUS · More eradication cost for Member States · Administrative cost of handling derogations for Commission and Member States · More avoidance of damage increase than option 2.2 (see 6.1.6)

6.1.7.     Summary of distribution of
responsibilities and costs

Tabel 15 provides an
overview of the distribution of responsibilities and costs among the Commission,
the Member States and the economic operators for the measures foreseen in the
proposed options. It shows how additional costs are minor in comparison with
the ever increasing damage costs that could be avoided through them (see 6.1.3).
Member States and economic operators would benefit the most from the avoided
damage costs. The cost of the instrument will be met through existing dedicated
budgets, but within those budgets there will be a gradual shift from reaction
to prevention as well as a shift from the current fragmented approach to a
common set of prioritised species. Future fincancing of the instrument will
thus depend on the maintenance of those existing dedicated budgets, in
particular in the Member States. An analysis of the distribution of costs among
the Member States is provided in Table 16. The Commission is committed to
provide support and guidance to the Member States where needed in order to
facilitate the effective and cost-efficient implementation of the proposal.

Table
15: Responsibilities and costs for the Commission, the Member States and the
economic operators for the measures foreseen in the proposed options.

Operational Objectives || European Commission || Member States || Economic operators

A - Prevent intentional introduction of IAS of EU concern into the EU || Option 0, 1: - || Option 0, 1: Risk assessments: 3 mio/yr || Option 0, 1: -

Option 2.1, 2.2, 2.3, 2.4: Management of list of IAS of EU concern: current personnel || Option 2.1, 2.2, 2.3, 2.4: Risk assessments: 1.4 mio/yr Border control on IAS of EU concern: minimal || Option 2.1, 2.2, 2.3, 2.4: Opportunity costs in case of banned species

B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || Option 0, 1: - || Options 0, 1: very few initiatives || Option 0, 1: Ballast water treatment: €109 mio/yr

Option 2.1, 2.2, 2.3, 2.4: - || Option 2.1, 2.2, 2.3, 2.4: Pathway management: 135.5-150.1 mio/yr (could be recovered from operators) || Option 2.1, 2.2, 2.3, 2.4: Ballast water treatment: €109 mio/yr Additional costs depending on cost recovery by MS

C - Prevent intentional release of IAS into the environment || Options 0, 1: - || Options 0, 1: Current systems included in horizontal costs || Options 0, 1: Some opportunity costs

Option 2.1: - Option 2.2, 2.4: - Option 2.3: Management of list of alien species not yet present but approved for release: current personnel || Option 2.1: included in horizontal costs Option 2.2, 2.4: permitting system 0.1-1 mio/yr Option 2.3: serious management cost || Option 2.1: Some opportunity costs Option 2.2, 2.4: Some opportunity costs Option 2.3: Heavy opportunity costs

D - Early Warning and Rapid Response to prevent reproduction and spread of IAS of EU concern into the environment || Options 0, 1: - || Options 0, 1: - Surveillance: 7 mio/yr || Options 0, 1: -

Options 2.1, 2.2, 2.3: Management of notification and EU early warning system for IAS of EU concern: included in information system Option 2.4 (additional to above): Management of applications for derogation: current personnel || Options 2.1, 2.2, 2.3: Surveillance on IAS of EU concern: 7 mio/yr Notification of new populations of IAS of EU concern: minor cost Rapid response to new populations of IAS of EU concern: increase through shift of expenses from management to rapid eradication (see E) Option 2.4 (additional to above): Rapid eradication of new populations of IAS of EU concern or application for derogation: some more increase through shift of expenses from management to rapid eradication (see E) || Option 2.1, 2.2, 2.3, 2.4: -

E - Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || Options 0, 1: LIFE-projects || Options 0, 1: Management of IAS: 1.3 bio/yr + raising needs || Options 0, 1: Raising needs for IAS management

Option 2.1, 2.2, 2.3, 2.4: LIFE-projects || Option 2.1, 2.2, 2.3, 2.4: Management of IAS of EU concern: 1.3 bio/yr (gradual decrease through enhanced effectiveness, some shift of expenses to rapid eradication) || Option 2.1, 2.2, 2.3, 2.4: -

Horizontal measures || Options 0, 1: EASIN: 0.2 mio/yr   || Options 0, 1: Information system: 3.2 mio/yr Policy management: 2 mio/yr || Options 0, 1: -

Option 2.1, 2.2, 2.3, 2.4: EASIN: 0.4 mio/yr (expected to increase) Reviewing progress: current personnel Management of standing committee: 0.1 mio/yr || Option 2.1, 2.2, 2.3, 2.4: Information system: 3.2 mio/yr (expenses will shift to Commission) Policy management: 2 mio/yr || Option 2.1, 2.2, 2.3, 2.4: -

Table 16: Member States' cost distribution

|| Distribution of effect of IAS on Member States || Costs for Member States linked to a dedicated legislative instrument

Presence of IAS || - IAS present in all Member States with numbers varying, but within a similar order of magnitude - higher presence can be assumed for MS with high levels of trade, long trading history and numerous entry points || Costs linked to: - early eradication obligations - surveillance (using insofar as possible existing systems) - management obligations

Entry from outside the EU || - more frequent entries can be assumed for MS with high levels of trade and numerous entry points || Costs linked to: - border controls (using existing systems in so far as possible) - surveillance for early detections (using existing systems in so far as possible)

Intra-EU movements || - impossible to ascertain the magnitude of these movements as there are no internal checks for commodities or monitoring of aliens species moving in the wild across the borders || Costs linked to: - surveillance to monitor the spread - possible development of joint management actions with neighbouring MS

Impacts on biodiversity, human health and economy || These depend on: - how many IAS are invading - which species are invading - ecological or geographical circumstances of the affected territory - sectors affected || Costs linked to: - management actions and restoration actions

|| ||

Costs distribution || It is not possible to quantify how the costs will be distributed amongst the Member States as costs will be a function of: - presence of which and how many species listed as IAS of EU concern - rate of entry - rate of spread within MS and across borders - ecological, climatic and geographical/topographical  circumstances - actions already taken in MS and their interplay with EU measures (see Annex V)

6.2.        Social impacts

6.2.1.     Option
0: Baseline

Option 0 (status quo)
would introduce no change or limited change to the current situation with mixed
impacts on employment. On one hand, the absence of regulatory measures
may avoid certain impacts on the employment in certain sectors trading in alien
species. On the other hand, the negative effects on employment already felt by
sectors, such as forestry, agriculture or other sectors, e.g. tourism, relying
on pristine environments to thrive, would continue unabated and even worsen due
to the increase in biological invasions. As regards public health,
option 0 would have detrimental effects as the problems linked to IAS would
remain largely unaddressed.

6.2.2.     Option
1: Cooperation and voluntary action

Option 1 would add
guidelines, codes of conduct and awareness raising campaigns to option 0. Those
activities would be aimed at reducing social impacts. However, we assume that
this reduction will remain limited given the significant damage to public
health.

6.2.3.     Option
2.1: The basic legislative instrument

Single list of IAS of EU
concern and obligations to manage pathways – provisions linked to
prevention are expected to have a mixed impact on employment. The
introduction of a single list of IAS of EU concern would have a negative effect
on employment for those sectors who suffered from a ban on certain species (e.g.
in the pet trade sector) where no substitute can be found. It was estimated
that the economic impacts on the private sector would remain moderate.
Consequently, the effect on employment is thought to remain limited as
well. This would not be the case for sectors depending almost exclusively on
one species, such as mink fur farming: there are 7,200 mink
fur-farmers in the EU involving up to 60,000 full-time jobs[141].
If the
American mink was banned, the consequences on employment in the sector would be
negative.

It also has to be
considered that many IAS can have dramatic consequences on the ecosystem
services sustaining the livelihood of certain groups, and action to prevent
their introduction will have the positive impact of avoiding job losses. The
yellow legged hornet, for example, is an aggressive predator of honeybees and
can lead to significant beehive losses (preliminary observations in France
noted losses of 14,000 honey bees per hive per month)[142],
with negative consequences on jobs in apiculture (and broader impacts on
agricultural production due to loss of pollination services). Another example
relates to the collapse of pelagic fish catch in the Black Sea and Caspian Sea
(several hundred million € of damage[143]) due to the comb
jelly, with consequences on viability of fishing.

When it comes to public
health, the introduction of a ban on the species listed as IAS of EU
concern would have a beneficial effect as the most hazardous species
would be banned uniformly across the EU[144]. The
obligation to manage pathways of introduction will be particularly beneficial
for public health, as species with a negative impact on health are often
introduced unintentionally: with pathway management the chances of stopping
such hazardous species would increase. Such a system could have stopped the
ragweed unintentional introduction, which is currently causing medical costs of
€118 to 763 million/year in the EU[145]. Some IAS
are agricultural weeds or pests and preventing their entry and establishment in
the EU will have a positive impact on crop production and ultimately on food
security (e.g. ragweed is also an agricultural weed causing yield losses of
at least €1.3 billion/year in the EU[146]).

Society will also
benefit in terms of property value: prevention of IAS will protect private
properties and estates from IAS infestations which can severely decrease their
value. Infestation of Japanese knotweed in the UK, for example, is leading to
mortgages being refused for properties infested with this weed, which can
undermine constructions. Citizens will also benefit when it comes to recreational
activities: a ban on certain species may preserve the possibility to carry
out sport or leisure activities (e.g. boating or fishing hindered by waterways
invaded by invasive aquatic plants). Citizens may also be impacted in so far as
pathway management measures may touch upon certain recreational, outdoor or
sports activities (e.g. cleaning requirement for the equipment for angling,
hunting, boating) but the impact is estimated to be negligible. Benefits
for citizens include also the preservation of cultural patrimony,
including traditional landscapes. On the other hand, the banning of certain
species will have an effect on the choices of citizens (e.g. pet
owners and hobbyists) but given the availability of substitute species this
impact can be considered negligible.

Obligations linked to
early warning and rapid response and management of established IAS of EU
concern – the rapid response requirements and the management
obligations are expected to provide some employment opportunities: the
removal or management of certain species is labour intensive and requires
specialised skills as well as equipment, which is likely to bring about
employment opportunities. For example, in the UK a flourishing business has
emerged specialising in the eradication of Japanese knotweed with several
companies specialising in the management and removal of this weed. Works to
remove water hyacinth from the Guadiana River in Spain lasted from 2005 until
2009 and maintenance activities and awareness raising campaigns are on-going[147].
Such employment opportunities might be temporary for certain species, but some
established species will be impossible to eradicate and require on-going
management. Public health will benefit from the requirement to
remove or otherwise manage IAS which have an impact on health.

When it comes to citizens,
the early warning (and surveillance) requirements would have the benefit of
increasing their awareness and enable them to be prepared and take defensive
measures against new invasions. Surveillance will most likely involve the
citizens (citizens' science), thus increasing awareness. One sensitive effect
of rapid response or management, which may include eradication or other
management measures, is the need to confront the negative public opinion:
especially when it comes to mammals and birds, certain measures may be resisted
by the public. This resistance may be manageable, provided that appropriate
information campaigns are conducted. Benefits may also accrue to citizens in
terms of preservation of recreational value, e.g. clearing watercourses
of invasive aquatic plants.

In conclusion, the basic
legislative instrument is expected to yield benefits to society, in terms of
public health, preparedness and increased awareness of problems linked to IAS.
Some job opportunities may be created, although some localised negative
consequences may be felt in terms of employment, if certain sectors were to be
particularly hard hit by the banning of certain species. Benefits would also
accrue to citizens in terms of preservation of recreational opportunities and
cultural values. Balancing the above elements, the social impact is
therefore considered positive.

6.2.4.     Option
2.2: Adding permits for releasing of IAS of Member State concern

A permitting system of
IAS of Member State concern will affect employment as far as
certain sectors are affected, but the impact on employment is considered to be
insignificant.

A permitting system
would yield similar benefits to those of the basic legislative instrument, but
by placing more emphasis on prevention and by enlarging the focus to species
beyond those listed on the list of IAS of EU concern these benefits would be
more pronounced. Benefits would be particularly felt when it comes to public
health, as the system would limit or regulate the release into the
environment of IAS of Member State concern. By encouraging a more thorough
reflection on the possible consequences of release, it can be expected that a
reduced number of IAS detrimental to health would be released unwittingly into
the environment.

A more precautionary
approach will also yield significant benefits for citizens, in
particular landowners and property owners, as certain IAS can significantly
decrease the value of private property and land[148].

On the whole, the
additional social impact of this action is considered very positive.

6.2.5.     Option
2.3: Introducing a strict ban for any release of any alien species unless
included in the  EU list of species approved for release into the environment

Introducing an EU list
of species approved for release will impact employment according to the
sectors to be affected. Considering the serious disruption that the
creation of a list of approved species would entail to business and activities
of primary producers the impact on employment was considered negative.

But this approach to
release into the environment would yield substantial benefits for public
health, as only species proven safe by risk assessment would be allowed for
release. This is due to the same reasons discussed above, but the benefits
would be even more pronounced than with the introduction of a permitting system
for IAS of Member State concern. The same can be said as regards the benefits
to citizens. Citizens may be faced with reduced choices, for example
when it comes to ornamental plants, and certain outdoor activities that involve
the release of species may be impacted (e.g. hunting and angling). However,
such activities would be able to continue but focusing on native species rather
than relying on the introduction of alien species.

On
the whole, this action was found to have a substantial positive impact on
public health and to yield benefits for private citizens. On the other hand,
employment could be negatively affected. On the whole, the social impact was
estimated to be positive.

6.2.6.     Option
2.4: Obligation for rapid eradication of newly establishing IAS of EU concern

The
rapid eradication obligation might create new employment
opportunities, as the removal or management of certain species is labour
intensive and requires specialised skills as well as equipment. The benefits in
terms of public health could be very significant, as there would be
greater emphasis on quickly eradicating IAS with a high impact on health.
Finally, substantial benefits are also expected to accrue for citizens
that from IAS invasions, as early eradication would avoid the establishment of
species and the subsequent devaluation of private property. The same can be
said for the preservation of amenities and recreational values. One
potential drawback of the emphasis on eradication would be the need to manage
negative public opinion, an important element not to be underestimated.
However, it has to be stressed, that a rapid eradication programme solving an
IAS problem indefinitely may be more acceptable than continuous management
measures. Balancing the above elements, the social impact was considered
very positive.

6.3.        Environmental impacts

6.3.1.     Option
0: Baseline

Maintaining the status
quo with option 0 would have a very negative impact on biodiversity,
seeing that IAS are a major cause of biodiversity loss. Lack of action is also
expected to have a very negative impact on the provision of ecosystem
services.

6.3.2.     Option
1: Voluntary action

Voluntary action
proposed by option 1 will only entail limited benefits and have been shown to
be ineffective in meeting all the challenges posed by the IAS problem[149].
Also option 1 would thus have a very negative impact on biodiversity
as well as on the provision of ecosystem services.

6.3.3.     Option
2.1: The basic legislative instrument

Single list of IAS of EU
concern and obligations to manage pathways – considering that IAS
are a major cause of biodiversity loss, with severe and documented impacts on
native species and ecosystems, provisions to prevent IAS from entering the EU
would be beneficial for biodiversity: of the 174 European species listed
as critically endangered, 65 are in danger because of IAS[150], thus an IAS
policy is important for the conservation of vulnerable native species. IAS can
also disturb the functioning of whole ecosystems (e.g. disrupt water and soil
systems), with negative consequences on ecosystem services and resilience[151]. Given the
high and growing proportion of unintentional introductions into the EU and
unintentional releases into the environment, pathway management, designed to
capture in the system the species introduced and released accidentally, is also
expected to have a beneficial impact on biodiversity as it will tackle
inflows or transfers of IAS, going beyond the species listed as IAS of EU
concern. The benefits of preventive measures would be particularly felt in
aquatic ecosystems: it is widely recognised that once an IAS establishes in
an aquatic environment, it is in most cases close to impossible to eradicate or
otherwise manage (with some exceptions, e.g. floating plant species). In such
cases, a failure on prevention would lead to significant damage caused to the
ecosystem, which would be very difficult to eliminate or mitigate. Effective
prevention would instead yield benefits in terms of species composition
(healthy fish stocks and diverse species communities) and structure of the
food chain, besides ensuring water quality and a clean environment
in which recreational activities can take place. Preventing the entry of
IAS would also be beneficial for animal welfare, as preventing invasions
would avoid any later need for eradication or management measures.

Obligations linked to
early warning and rapid response and management of established IAS of EU
concern – the requirement to rapidly respond to newly
establishing species listed as IAS of EU concern and the obligation to manage
established ones is expected to have a positive impact on biodiversity and
ecosystem services. Newly establishing IAS would not be allowed to
establish and spread: this would nip problems in the bud and avoid the onset of
the damages caused by IAS to native species and ecosystem services (see section
3.1). When it comes to established IAS, efforts to eradicate, contain or manage
will mitigate their negative consequences. As previously mentioned, 65 European
species that are listed as critically endangered are directly threatened by
IAS: these would be IAS already established in the EU and action to eradicate
or manage them would directly contribute to improving the status of those
threatened species. Management of established species is a reactive
approach, but it is still important as it is demonstrated that conservation
programmes aimed at managing IAS are useful: globally, 11 bird species (since
1988), 5 mammals (since 1996) and 1 amphibian (since 1980) have had their risk
of extinction substantially reduced due primarily to the successful management
or eradication of IAS[152]. Rapid
reaction and management provisions would also facilitate compliance with
other EU legislation and contribute to meeting the status required under
the Nature Directives, the Marine Strategy Framework Directive and the Water
Framework Directive, as well as the 2020 Biodiversity Strategy target. In terms
of animal welfare, these requirements may have a negative
impact: however, rapid eradication should follow humane standards
and would avoid the need for more and long term control and containment
methods. Considering all the above, the basic legislative instrument is
considered to yield positive benefits for the environment.

6.3.4.     Option
2.2: Adding permits for releasing of IAS of Member State concern included in
national catalogues

The benefits from
adding this action will be greater, due to the fact that the action encourages
a more thorough reflection on the possible consequences of releasing a species
in the environment. Adding to the precautionary approach the IAS of Member
State concern, there will be more benefits as more invasions could be
prevented, thus avoiding subsequent negative effects on biodiversity and
ecosystem services and the need to react to new invasions[153]. Such a
precautionary approach would also benefit animal welfare in that it
would avoid new invasions and the subsequent need to embark on eradication or
other management campaigns. On the whole the additional impact on the
environment was considered very positive.

6.3.5.     Option
2.3: Introducing a strict ban for any release of any alien species unless
included in the EU list of species approved for release into the environment

This option would be
from the environmental point of view the most ambitious. Indeed this
fully fledged precautionary approach would yield the highest benefits for
biodiversity and ecosystem services, compared to Options 2.1 and 2.2, as no new
alien species would be allowed to be released into the environment, unless
proven harmless by risk assessment. The type of benefits - similar to those
discussed above – would be significantly more pronounced given the stringent
precautionary approach proposed. This would also result in benefits in terms of
animal welfare, as eradication and control efforts may be limited to the
species already established. The environmental impact from adding this action
would be very positive.

6.3.6.     Option
2.4: Obligation for rapid eradication of newly establishing IAS of EU concern

The requirement to
rapidly eradicate newly establishing IAS of EU concern is expected to have a substantial
positive impact on biodiversity and ecosystem services as newly
establishing IAS would be quickly eliminated, wherever possible, thus avoiding
all their impacts on native biodiversity and the functioning of ecosystems, as
discussed above. This action will lead to more eradication programmes, with negative
consequences on animal welfare, however more long term management
requirements would be avoided (Figure 10). On balance however, given the
benefits for biodiversity and ecosystem services, as well as for the welfare of
native species, this action was considered to have a very positive
environmental impact although it needs to be taken into account that for
those species for which a derogation from eradication is granted, those will
need to be managed over time and this would yield less environmental benefits.

7.           Comparing
the different Options

Based on all previous
information, table 17 provides a summary comparison of the options in terms of
effectiveness, efficiency and coherence.

Option 0, although it
includes several pieces of EU and national legislation (see policy baseline),
leaves the large majority of species and pathways unaddressed (see Figure 4).
Hence it is not able to stop the increasing number of IAS in the EU
environment, which is leading to continuously growing damage. Option 1
has already been attempted to a certain extent under the framework of the Bern
Convention. Even with additional efforts in fostering voluntary action,
awareness-raising and sectoral guidelines, the voluntary nature of such
initiatives leads to conclude that despite the added value, Option 1 would
remain insufficient. The difference in effectiveness between the EU current
non-legislative approach and legislative approaches followed by other countries
is illustrated by the levelling off of the number of insects in the US and
Canada coinciding with the introduction of preventive measures, while in Europe
the numbers of insects increased (Figure 11). The failure of options 0 and 1 to
prevent the increasing negative economic, social and environmental impacts
means they are ineffective in reaching the objectives of this proposal, besides
seriously jeopardising the possibility for the EU to meet its 2020 biodiversity
target and even its 2020 Strategy.

Figure 11: Total number
of alien insects on woody plants in Europe compared to North America[154].

On the contrary, option
2.1 could significantly reduce the economic, social and environmental
impacts of IAS and allow achieving the overarching objectives. It would thus be
effective
as well as coherent with overarching objectives. While options
0 and 1 are estimated to cost €1.4 bio/yr already, option 2.1 would only add
€26 to 40 mio/yr. Moreover in time the overall cost could decrease to €1
bio/yr. Option 2.1 would thus also be more efficient than options 0 and 1.
Option 2.1 is thus preferable to options 0 and 1. This preference for a
legislative approach reflects the results of the 2012 consultation, where
a majority of respondent backed obligatory provisions: e.g. 83 % of the
respondents were in favour of some type of ban on IAS, while only 16 % did not
support any form of trade bans. Similarly, roughly 94% of respondents were in
favour of some restrictions to release of IAs in the environment, against
roughly 4% against any restriction[155]. The consultations with
Member States, stakeholders and experts provided similar feedback: (1) no
support for the baseline option or solely voluntary action, because
insufficient in tackling IAS and (2) an overall agreement that legal provisions
for an EU level approach would be beneficial.

In comparison with option 2.1, further costs of
action and additional benefits can be expected from the more stringent options
2.2, 2.3 and 2.4, although, due to several unpredictable elements, they are
very difficult to quantify.

Option 2.2, adding legal
provisions to restrict the release into the environment of IAS of Member State
concern would strengthen option 2.1, where only the release of IAS of EU
concern is addressed. This option would thus better address operational
objective C and make the approach more effective than option 2.1. The
additional cost would be very moderate, as the Member States would often build
upon existing systems, the option would thus be efficient. The option would
also improve the coherence with overarching objectives.

Option 2.3, adding legal
provisions to restrict the release into the environment of any new alien
species would further strengthen option 2.1, much more than option 2.2, where
only the release of IAS of EU and MS concern is addressed. This option would
thus be even more effective in addressing operational objective C. The option
would however at the same time impose a significant burden on certain economic
operators, in particular those involved in primary production, which would
negatively affect the efficiency of the approach. While coherence with the 2020
biodiversity objective would be better, the coherence with the EU 2020 Strategy
would be hampered by the economic cost.

Option 2.4, adding a legal
obligation to rapidly eradicate newly establishing IAS of EU concern, would
allow stopping the spread of such species more effectively that option 2.2.
This would be a significant improvement towards operational objective D and
again increase the effectiveness. The cost would nevertheless remain moderate.
Member States would be obliged to increase efforts only on newly established
IAS and a derogation system would be available for when the expenditure would
not be proportionate. The option would thus also be efficient, and would also
improve the coherence towards overarching targets.

In summary, option 2.3 is expected to generate
the best result in terms of effectiveness as on top of the provisions of option
2.1 on IAS of EU concern, it would be very strict in terms of releasing new
species into the environment. Its trade-off towards the economic domain is
however deemed too substantial and therefore its cost/benefit ratio is
estimated to be less favourable than for option 2.2. On the other hand, the
additional benefits of option 2.4 have been estimated to be substantial and to
outweigh the additional costs in comparison to option 2.2. Therefore, option
2.4 was selected as the preferred option, yielding the highest
benefit in relation to costs, although it is not the option yielding the
highest biodiversity benefits (which would be Option 2.3). Option 2.4
integrates the benefits of option 2.1 with the additional benefits of the
permitting system for release into the environment of IAS of MS concern and the
obligation of early eradication for newly establishing IAS of EU concern, but
does not include the substantial opportunity and administrative costs which
option 2.3 implies.

Choosing option 2.4, it
is to be expected that 1) the yearly cost of action would remain stable or
would even decrease over time, 2) the magnitude of the benefits (i.e. damage
and management cost avoidance) would continue to increase over the years, as
increasing numbers of invasions are avoided, 3) the overall costs of the
problem would not increase as much as it would without EU action.

Table 17: Comparison of
effectiveness, efficiency and coherence

|| Effectiveness || Efficiency || Coherence

Option 0- Baseline || No objectives achieved, damage by IAS continues increasing || €1.4 billion/year, mainly reactive costs, while damage by IAS continues increasing || Barrier towards achieving EU Biodiversity target and EU 2020 target

Option 1- Voluntary action || No objectives achieved, damage by IAS continues increasing || €1.4 billion/year, mainly reactive costs, while damage by IAS continues increasing || Barrier towards achieving EU Biodiversity target and EU 2020 target

Option 2.1- Basic legislative instrument || Operational Objectives A/C/D/E: step by step build-up of the list of IAS of EU concern –IAS are prevented from introduction and establishment (\*) and there is a coherent management of established IAS (\*\*) Operational Objective B: step by step development of pathway management – IAS are  prevented from unintentional introduction (\*) Significant reduction in economic, social and ecological damage || €1.5 billion/year, but may decrease to €1.1 billion/year, while damage increase by IAS is levelled off Significant benefit for very moderate cost increase or a cost decrease on the longer term || Reduction of barrier towards achieving EU Biodiversity target and EU 2020 target

Option 2.2- Basic legislative instrument and action C2 – permitting system for IAS of Member States concern || Additional to Option 2.1: Operational Objective C:  more pro-active approach on release into the environment – more IAS are prevented from intentional release (\*) Further reduction in economic, social and ecological damage in comparison to option 2.1 || Additional to Option 2.1: Some additional costs for operators, additional policy management cost for Member States (although often building upon existing systems), while damage increase by IAS is further levelled off Additional benefits (to option 2.1) were estimated to be substantial and to outweigh the additional cost || Reduction of barrier towards achieving EU Biodiversity target and EU 2020 target (better than under option 2.1)

Option 2.3- Basic legislative instrument (A2, B2, C1, D2 and E2) and action  C3 – strict ban on release of any alien species unless included in an EU list of species approved for release into the environment || Additional to Option 2.1 Operational Objective C: much more pro-active approach on preventing the release into the environment – many more IAS are prevented from intentional release (\*) Much further reduction in economic, social and ecological damage in comparison to option 2.2 || Additional to Option 2.1: Significant additional costs for operators, significant additional policy management cost for Member States, while damage increase by IAS is significantly levelled off Additional cost deemed substantial, in particular the additional burden on economic operators, the cost/benefit balance for the option 2.3 is estimated to be less favourable than for option 2.2. || Reduction of barrier towards achieving EU Biodiversity target and EU 2020 target (much better than under option 2.1), although serious trade-off towards the economic domain (significant additional costs for operators)

Option 2.4 Basic legislative instrument (A2, B2, C1 and E2), action C2 and alternative D3 – obligation to rapidly eradicate newly establishing IAS of EU concern, unless derogation granted || Additional to Option 2.2: Operational Objective D: stricter application of rapid eradication – more introduced IAS are  prevented from establishing (\*) Further reduction in economic, social and ecological damage in comparison to option 2.2 || Additional to Option 2.2: Some additional eradication costs for Member States, some additional policy management costs for Member States and Commission, while damage increase by IAS is further levelled off Additional benefits (to option 2.2) were estimated to be substantial and to outweigh the additional cost || Reduction of barrier towards achieving EU Biodiversity target and EU 2020 target (better than under option 2.2)

(\*) every prevented IAS leads to a cost
avoidance of €130 million/year of damage/control costs on the longer term +
avoidance of damage to biodiversity which is not readily quantifiable

(\*\*) coherent management
of IAS leads to an increased efficiency and could reduce management costs on
the longer term + decreased biodiversity loss which is not readily quantifiable

8.           Monitoring
and evaluation

8.1.        Progress indicators

Monitoring and
evaluation of the proposed instrument will be addressed via the periodical
reporting obligations embedded in the legal text (after 3 years and every 4
years thereafter, see Table 20) and the notifications transmitted by Member
States based on their surveillance systems. This data will feed
the Common Information System allowing to gather all the information centrally
based on existing systems and new data generated. On this basis the Commission
and other bodies will be able to report on the indicators established in Table
18 (after
4 years and everey 4 years thereafter, see Table 20) and thus periodically
evaluate the impact of the instrument, including the development of the list.

This monitoring system
will also be used to feed the integrated framework for evaluating progress
towards the 2020 biodiversity target being developed and managed by the
European Environment Agency and its European Topic Centre on Biological
Diversity in partnership with the European Commission. Finally, the Commission,
in consultation with the Member States, will develop, in time to provide
information for the mid-term review of the Biodiversity Strategy, a set of
indicators building on the 2010 core set[156], including coverage
on IAS which could build upon the indicators in Table 18. This set of
indicators will fully take into account and be streamlined with the reporting
framework to be adopted under the Convention on Biological Diversity (CBD) at
the Conference of the Parties in Hyderabad in October 2012. Those indicators
will deal with the measures put into place (Table 18) and the impact of IAS on
biodiversity (Table 19) and allow following compliance by the Member States.

Table 18: Indicators
assessing progress towards the operational objectives

|| Indicators on progress towards achieving the objectives

Specific objectives Operational objectives || More preventive approach || Prioritising action || Fostering a coherent approach

A – Prevent intentional introduction of IAS of EU concern into the EU || Number of interceptions of IAS of EU concern at border || Number of IAS of EU concern || Number of IAS of EU concern

B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || Number of pathways on which Member States are acting || ||

C – Prevent intentional release of IAS into the environment || Number of IAS of Member State concern || ||

D – Early warning and rapid response to prevent reproduction and spread of IAS of EU concern || Number of IAS detections generated by the surveillance systems || Number of rapidly eradicated new invasions of IAS of EU concern || Number of notifications exchanged between Member States

E – Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || || Number of IAS of EU concern that are subject to management measures and their impact on the objectives of other environmental legislation (See Table 19) || Number of joint management measures taken by several affected Member States.

Table 19: Indicators
assessing progress towards EU 2020 Biodiversity target

|| Indicators on the impact of IAS on biodiversity

Birds Directive / Habitats Directive || Percentage of species not in favourable conservation  status (partly) due to IAS Percentage of habitats not in favourable conservation  status (partly) due to IAS

Water Framework Directive || Percentage of rivers not in good ecological status (partly) due to IAS

Marine Strategy Framework Directive || Percentage of seas not in good environmental status (partly) due to IAS

8.2.        Monitoring

In order to gather the
information necessary to enforce obligations arising from the legislative
instrument and to feed into indicators, reporting provisions would be included
in the legal text. These provisions would build upon existing reporting
mechanisms such as those carried out under the Birds and Habitats Directives,
Water Framework Directive and Marine Strategy Framework Directive as well as
the Animal and Plant Health and Aquaculture regimes. Such provisions would be
limited to the strictly minimum required to ensure enforcement of the legal
text and other international commitments such as those under the CBD, so as to
avoid unnecessary administrative burden. These monitoring
provisions could be complemented by surveillance done by citizens on a
voluntary basis (also known as citizen science)[157].

8.3.        Evaluation

The legal text would
include a review clause and a periodical progress evaluation clause that would
allow updating the approach according to scientific and technical progress and
would allow a gradual further development in light of issues arising during the
implementation. The timing of reporting and reviewing is specified in Table 20.
The review of the list can lead to adding or removing species from the list.

Table 20: Reporting and
reviewing provisions allowing the development of a gradual approach

|| Year 1 || Year 3 || Year 4 || … || Year 7 || Year 8 || …

Member States || || 1st progress report || || || 2nd progress report || ||

Commission || Propose first list || || 1st progress report 1st review of list || || || 2nd progress report 2nd review of list ||

Impact Assessment Annexes

1.      Annex
I: Interservice Consultation.. 48

2.      Annex II: Stakeholder consultation.. 48

2.1.        Stakeholder
participation.. 48

2.1.1.     Statistics related to the 2012 online
consultation. 48

2.2.        Summary
of the positions of the main stakeholders. 48

2.2.1.     Prevention. 48

2.2.2.     Early warning and rapid response. 48

2.2.3.     Management of established species. 48

2.3.        Assessment
against Commission's minimum standards for consultation: 48

3.      Annex III: Technical support.. 48

4.      Annex IV: International Policy
Context.. 48

5.      Annex V: EU and National Policy
Baseline. 48

5.1.        EU
policy.. 48

5.1.1.     EU legislation addressing part of the IAS
problem.. 48

5.1.2.     Lessons learnt from the plant health regime
(PHR). 48

5.1.3.     EU policy gap analysis. 48

5.2.        The
2020 Biodiversity Strategy.. 48

5.3.        IAS
policies and initiatives in Member States. 48

5.3.1.     A fragmented policy field. 48

5.3.2.     Approaches across Member States. 48

5.3.3.     The interplay between existing national measures
and the measures proposed under the preferred option  48

6.      Annex VI: Screening of legislative
sub-options.. 48

7.      Annex VII: Analysis of costs and
benefits of the proposed measures.. 48

7.1.        Distributional
impacts. 48

7.1.1.     Member States. 48

7.1.2.     SMEs and microenterprises. 48

7.2.        The
basic legislative instrument.. 48

7.2.1.     Calculation of costs. 48

7.2.2.     Calculation of benefits. 48

7.2.3.     Introduction of a single list of invasive alien
species of EU concern, banned from trade/import/marketing/transport (component
A2) and banned from being released into the environment (component C1). 48

7.2.4.     Obligation to manage pathways to prevent the
unintentional introduction in the EU and the unintentional release into the
environment (component B2). 48

7.2.5.     Obligation to eradicate, contain or control new
IAS detected in the environment – early warning and rapid response (component
D2). 48

7.2.6.     Obligation to manage (eradicate, contain or
control) established IAS (component E2). 48

7.3.        Optional
add-ons for release into the environment.. 48

7.3.1.     Permitting requirements for releasing IAS of
Member States concern (add-on C2). 48

7.3.2.     Introducing a single EU list of species approved
for release into the environment (add-on C3). 48

7.4.        Optional
alternative action for rapid response. 48

7.4.1.     Obligation to eradicate newly establishing IAS. 48

8.      Annex VIII - Glossary.. 48

9.      Annex IX: References.. 48

1.
Annex I: Interservice Consultation

The IAS issue is a
multifaceted one, which touches upon and interesects with several policy areas.
Intense consultations have therefore been carried out with several services of
the European Commission, both via the establishement of a dedicated Inter-Service
Steering Group (ISG) on the impact assessment (IA) and via several rounds of
bilateral contacts with the units both in DG Environment and in other DGs,
concerned by the development of an instrument to tackle invasive alien species.

The Impact Assessment
ISG met 4 times: 23 September 2011, 6 December 2011, 15 February 2012 and 28
March 2012 and included representatives from the following DGs: ENV, SG, SANCO,
AGRI, MARE, MOVE, TRADE, ENTR, MARKT, EMPL, ENER, TAXUD, DEVCO, RTD and REGIO.
The meetings were useful to collect the reactions of its members and to
stimulate discussion. Furthermore, many participants provided written feedback
and drafting suggestions which have been taken into account in so far as
possible while drafting the Impact Assessment report.

There has also been
constant interaction at bilateral level, to ensure that synergies could be
found and that the IAS instrument could deliver on its promise to close the
policy gaps left by existing EU legislation. There has also been a considerable
effort to streamline policy ideas with existing requirements, structures and
processes, thereby seeking to minimise legislative complexity, administrative
burden and costs and avoiding contradictions.

Furthermore, the issue
of a forthcoming IAS instrument featured regularly on the agenda of the
Biodiversity Interservice Steering Group.

2.
Annex II: Stakeholder consultation

2.1.
Stakeholder
participation

An online public
consultation was published on Your Voice in Europe from 3 March 2008 to 5
May 2008, attracting 880 replies, three quarters of which from individuals.
Feedback was provided by means of an online summary report[158]. The
consultation revealed
widespread backing for action on IAS at EU level. Some 91% of respondents
agreed on the urgent need to bring in new measures to prevent the spread of
such organisms and 86% thought that Member States should be legally obliged to
take action against the most harmful IAS. The same year, a working group of
Commission services, Member States and stakeholders integrated the state of
knowledge and opinions in a discussion paper[159].

A stakeholder
consultation was organised in Brussels on 3 September 2010, based on an
open call and attracting 62 participants, representing a broad range of
interests, including from Member States ministries and institutions, NGOs,
trade associations. All details are available online[160]. Following
the consultation more written contributions were collected.

Between December 2010
and July 20122, the working group on invasive alien species of 2008 was
reconvened. Its structure was revisited and the membership renewed: this
resulted in the creation of three working groups, each focusing on one
of the three main axes of 1) prevention; 2) early warning and rapid response;
and 3) management of established species. The groups included experts from
Member States ministries and institutes, from academia and from stakeholder
organisations. Following an expression of interest, a selection was made, based
on the willingness to take on an active role in the Working Group and privileging
representatives from organisations with European membership. Selections were
made also on a sectoral basis, seeking to ensure an adequately balanced and a
fair representation of stakeholders. The main results and positions expressed
during the meetings of these working groups have been summarized by
stakeholders in ten dedicated reports[161], which are all
available and freely accessible online, on:

·
Priority
Species

·
Priority
Pathways

·
Risk
Analysis

·
Information
systems

·
Surveillance

·
Early
warning and rapid response

·
Citizen
science

·
Eradication,
management and restoration

·
Awareness
and Communication

·
Finance
and Liability

Finally, a second
online consultation was held from end January to mid-April 2012[162]. The
consultation attracted 5101 answers in total, the majority of which came from
citizens, followed by organisations, with a small percentage of replies coming
from public administrations. A wide range of sectors were represented, with
particularly high interest from associations of hobbyists interested in exotic
species, with several submissions from associations of breeders and keepers of
exotic birds. In terms of geographical representation, the majority of replies
came from the UK, which may reflect the linguistic bias due to the fact that
the questionnaire was available only in English; this possible linguistic bias
was duly taken into account. Interestingly, however, the majority of replies
tended to come from Member States which are actively involved in the IAS
debate: beside the UK, large part of the answers came from Spain, Belgium,
Germany, the Netherlands and France. These countries were also consistently and
actively involved in the Working Groups that were held between 2010 and 2011.
The number of answers may therefore reflect the active involvement and the
concerns of such countries, where the debate at national level is more active
than in other countries. The questionnaire comprised 11 questions focusing on
specific aspects of possible policy options to tackle IAS and grouped according
to the three-step hierarchical approach: prevention, early warning and rapid
response and management of established species.

2.1.1.
Statistics
related to the 2012 online consultation

A. Respondent's Profile

B. Prevention

C. Early warning and rapid response

D. Management and Restoration

2.2.
Summary
of the positions of the main stakeholders

The following chapter will summarise the
positions of the main stakeholders' groups. The material is organised according
to the three main axes of work according to the Convention on Biological
Diversity: prevention; early warning and rapid response; management of
established species.

2.2.1.
Prevention

Three main elements were debated in the
framework of the various meetings organised with stakeholders and with the
Working Group on invasive alien species: the possibility of using a list-based
system to address the introduction of IAS into the EU; the need to address
pathways of introduction into the EU; and the need to tackle the intentional release
of IAS into the environment.

As regards the listing of species, two
alternatives were discussed: 1) a list of restricted species, i.e. the listed
species to be banned from introduction into the EU; and 2) a list of allowed
species, i.e. no alien species to be introduced into the EU unless shown to be
harmless by risk assessment. The latter approach is the approach taken for
example by Australia and New Zealand. The majority of stakeholders favoured the
first approach, i.e. a list of banned species. More in details, Member
States were generally against the idea of banning every alien species
unless shown to be safe, conscious of the administration involved in managing
such an approach, conscious of the resistance of certain stakeholders group and
of the large costs such an approach would generate. Furthermore, Member States
underlined that while such an approach may be workable on an island, it could
result unfeasible at the EU scale, with long coast lines and borders with third
countries, as well as numerous entry points, such as harbours and airports.
Very few Member States expressed a preference for banning all alien species
unless proven safe and one proposed that a dual system could be considered with
a list of banned species for continental Europe, with the possibility for
Member States to introduce a list of allowed species for certain areas, such as
oversees regions.

Traders and users of invasive alien species, for example
the pet traders and the traders of ornamental species, were against the approach
of banning all alien species except those shown to be harmless, backed by the
organisations of hunters and anglers, as well as by the organisations of
farmers and foresters. On the contrary, nature conservation organisations
tended to favour the stricter approach afforded by a list of allowed species.
Strong support for the approach of listing the allowed species came especially
from the organisations working on animal welfare issues.

On the same topic, the online consultation
revealed that a majority of respondents (almost 44%) supported the idea of a
list of restricted species, proven to be harmful, although about a quarter of
the replies favoured instead the idea of restricting all alien species unless
proven harmless, i.e. by drawing a list of allowed species.

As regards the management of pathway of
introduction into the EU and release into the environment, there was
general agreement to the idea of addressing the main pathways of introduction
as there was consensus on the fact that several invasive alien species enter
the EU unintentionally and that therefore pathways should be addressed to stop
the inflow of species into the EU and in the environment. Member States
tended to adopt a favourable approach to pathway management and recognised the value
that action at EU level would have although cautioning against a too
prescriptive approach to a complex mosaic. Traders and users of invasive
alien species, including pet traders and  traders of ornamental species,
the organisations of hunters and anglers, tended to have a more defensive
approach, recognising in some cases the role played  by their sector in
introducing invasive alien species in the EU, but stressing the voluntary
action and the awareness raising activities that their sector are undertaking
and urging the Commission to favour such type of self-regulatory activities to
more prescriptive measures. Nature conservation organisations and animal
welfare organisations had a more proactive stance to pathway management,
calling for EU regulatory action in this field. Awareness-raising and provision
of information as one way of addressing certain pathways, was considered
important also by several respondents to the online consultation: when
it comes to ornamental plants a large majority of respondents (roughly 85%,
with roughly half in favour of a compulsory system and another half in favour
of a voluntary system) considered important to introduce an information system
alerting buyers of the possible harmfulness of the plants they buy. The results
were slightly different when it comes to pets: over 50% of respondents thought
that public awareness programmes should be organised to educate pet owners,
while a sizeable proportion (c. 44%) was in favour of a compulsory labelling
scheme for pets, alerting buyers of the potential risks of releasing such
species in the environment.

As regards the release of species into the
environment, there was widespread support for the idea of regulating the
release into the environment. The ideas debated included a system of permits or
the establishment of a list of species allowed for release, i.e. no alien
species would be allowed for release unless shown to be harmless.

Member States were in favour of
regulating the release of alien species into the environment; in fact a
majority of Member States already has a general ban for release into the
environment although with broad exceptions to such ban for certain uses, an
approach similar to the establishment of a list of species allowed for release.
Many Member States already have a permitting system in place to regulate the
release of alien species and saw the benefit of an EU wide system to tackle
this aspect of the problem. Nature conservation and animal welfare
organisations were in favour of strictly regulating the release into the
environment, in some cases favouring the approach based on a list of species
allowed for release. Also pet traders and users of alien species in
confined conditions (e.g. fur farmers) favoured a stricter approach to
release into the environment, as they have no interest in the release of the
species they use. On the contrary, users of alien species that are
introduced with the purpose of releasing them into the environment – such
as foresters and the agricultural sector – expressed concern that regulating
release into the environment could hamper their activities, although they
recognised that their sector is often also a victim of IAS. A majority of respondents
to the online consultation favoured a precautionary approach with roughly
35% of respondents in favour of establishing a list of alien species allowed
for release into the environment and roughly 33% favouring a system based on
permits for release.

2.2.2.
Early
warning and rapid response

There are two aspects to be considered: the need
to carry out surveillance so as to enable an early warning system to function
and the issue of what action should be taken to rapidly respond to new
invasions.

On early warning, there was general
consensus, and this was also observed in the responses to the online
consultation, that national authorities should be in charge of devising the
most appropriate surveillance systems, but that citizens should be involved in
the surveillance process and that existing monitoring systems should be used in
so far as possible.

Views were more divided on the issue of rapid
response. Member States generally recognised the need to act rapidly
and that early eradication is the cheapest and most cost effective instrument
to tackle a new invasion, however, several Member States urged caution in
setting an eradication obligation, worried about the costs and the implications
of a blanket eradication obligation. The same Member States recognised however
the importance of coordinated EU action when it comes to rapid response. Traders
and users of alien species were less vocal on this aspect, which touches
them less directly as rapid response tend to be considered as the
responsibility of public administrations. Nature conservation organisations
were on the contrary highly in favour of a rapid eradication obligation, which
would ensure those new invasions are promptly dealt with. Animal welfare
organisations stressed the need to focus first and foremost on prevention,
so as to avoid getting to a stage where eradication may be necessary, however
they recognised that early eradication would be necessary. They however urged
the Commission to ensure that animal welfare are taken into consideration when
designing eradication programmes. The online consultation focused its question
on what species should be subject to rapid eradication: any alien species found
in the environment, alien species found in the environment suspected to be
harmful or only the species banned from introduction into the EU. The majority
of respondent to the online consultation (c. 38%) thought that only
restricted species detected in the environment should be rapidly eradicated,
while roughly 35% favoured a more proactive approach where also non restricted
species found in the environment should be eradicated if suspected of becoming
harmful. Around 21% went further indicating a preference for eradicating any
new alien species detected in the environment.

2.2.3.
Management
of established species

When it comes to the management of established
IAS, the main issue discussed regarded whether an eradication obligation
should be introduced. Member States were generally not in favour of a
blanket eradication obligation, keen to retain their ability to manage
established IAS according to their national situations. Member States did,
however, recognise the need to have coordinated action and that management
activities should be carried out on a common set of species.  Nature
conservation organisations favoured the introduction of an eradication
obligation, as this would permanently solve the problems linked to a particular
invasion. Animal welfare organisations were more cautious: they accepted
the need to intervene to eradicate certain IAS but stressed the importance of
using humane methods to perform such programmes, and emphasised the need to
focus more efforts on prevention so as to avoid getting to the stage where
eradication is needed. Traders and users of alien species were less
vocal on this issue. Certain organisations, such as the hunters and anglers
organisations highlighted their potential role in certain eradication
programme. When it comes to the online consultation, there was a clear
preference for performing eradication on the basis of cost benefit analysis.
Around 25% of respondents thought instead that eradication should be attempted
in any case, except where physically impossible.

2.3.
Assessment
against Commission's minimum standards for consultation:

Minimum
Standard A: preparatory documentation

Participants to the
stakeholder consultation meeting organised in September 2010 have received a
background document[163] to allow
them to prepare their input. The consultation was introduced by presentations
on the development of an EU-strategy, the technical support and on other
relevant initiatives at the EU-level (plant health and wildlife trade).

The working group
discussions have been framed by scoping documents that were sent in advance to
the participants and that aimed at providing an overview of the issues to be
discussed, presenting potential policy options and a series of questions for
the groups to reflect upon. The documents focused on: "Prevention"[164], "Early
Warning and Rapid Response"[165] and "Eradication,
Management and Control"[166]. The working
methods of these groups and the approval procedure for the reports had been clearly
detailed in advance and discussed with the members of the groups.

As regards the online
consultations, background documents and access to all documentation available
online, was provided and facilitated by providing all links to the relevant
internet pages in the consultation announcement.

Minimum Standard B:
target groups

During the
entire process of consultation (2008 online public consultation, 2010
stakeholder consultation, 2010-2011 working groups, 2012 final online
stakeholder consultation), a wide range of relevant stakeholder organisations
had the opportunity to express their views. Furthermore, the consultation
involved several experts from academia and research centres as well as Member
States representatives. See table A1 for a full list of stakeholders that
provided input in the consultation.

·
Stakeholder
organisations involved in the movement of alien species (intentional and
unintentional), including pet traders, traders in ornamental species, cruise
shipping sector, ship owners, dredgers, the general public.

·
Stakeholder
organisations involved in the utilisation of certain alien species, including
bio-control sector, fur breeders, horticultural sector, hawkers, zoos and
aquaria, farmers, foresters, hunters, anglers, fishery sector, landowners,
forest owners, the general public.

·
Stakeholder
organisations concerned about the damage by IAS, including nature conservation
sector, water managers, farmers, foresters, hunters, anglers, fishery sector,
landowners, forest owners, the general public.

·
Stakeholder
organisations involved in the control of IAS, including chemical industry,
bio-control sector, farmers, foresters, hunters, anglers, fishery sector,
landowners, forest owners.

·
Stakeholder
organisations concerned about the control of IAS, including animal welfare
sector, the general public.

Table A1: Stakeholder
organisations that participated in the consultations

ADS Insight

Asociación Española de Distribuidores de Productos para Animales de Compania - AEDPAC

Bayer CropScience AG , Sustainable Development

Birdlife International

Boomkwekerij Gebr. Van den Berk BV

Bundesverband Garten-, Landschafts- und Sportplatzbau e. V.

Bureau of Nordic Family Forestry

CEEweb for biodiversity

Confederation of European Forest Owners - CEPF

COPA COGECA

Eurogroup for animals/Eurogroup for Wildlife and Laboratory Animals - EWLA

European Anglers Alliance

European Association of Zoos and Aquaria + national organisations

European Bureau for Conservation and Development

European Centre for Nature Conservation ECNC

European Community Shipowners' Associations - ECSA

European Cruise Council

European Dredging Association - EuDA

European Environment Bureau - EEB

European Fur Breeder Association - EFBA

European Landowners organisation

European Pet Organisation - EPO

European Squirrel Initiative

Federation of Associations for Hunting and Conservation – FACE

Federlegno Arredo

Finnish Association for Nature Conservation

Friends of the Earth Europe

Humane Society International - HSI

International Association for Falconry and Conservation of Birds of Prey + national organisations

International Biocontrol Manufacturers' Association - IBMA

International Union for the Conservation of Nature – IUCN

International Union for the Conservation of Nature – IUCN, Invasive Species Specialists Group

Joint Nature Conservation Committee

Natuurpunt vzw

Neobiota

Ornamental Fish International - OFI

Österreichischer Fischereiverband

Plantlife

Pro Wildlife

Schuman Associates s.c.r.l.

Sustainable Users Network

Table A2: Public
authorities that participated in the consultations

AT || Amt der Steiermärkischen Landesregierung

AT || Austrian Environment Agency

BE || Federal Public Service Health, Food Chain Security and Environment - DG Environment

BE || Agency for Nature and Forest - Fauna and Flora, Flanders

BE || Service Public de Wallonie, invasive species unit

CY || Ministry of Agriculture, Natural Resources and Environment

CZ || Ministry of the Environment

DE || Ministry of Environment

DE || Federal Agency for Nature Conservation - BfN

DE || Ministry of the Environment, Energy, Agriculture and Consumer Protection of Hesse

DK || Greenland Representation in Brussels

DK || Danish Forest and Nature Agency

DK || Danish AgriFish Agency

EE || Ministry of Environment

ES || Ministry of Environment -  Technical Assistance in the Ministry of the Environment and Rural and Marine Affairs - TRAGSATEC

ES || IHOBE S.A., Sociedad Pública de Gestión Ambiental del Gobierno Vasco

ES || Catalan Water Agency / Agència Catalana de l'Aiga - ACA

ES || Dirección General de Medio Natural, Agricultura, Alimentación y Medio Ambiente

ES || Subdirección General de Biodiversidad Dirección General de Medio Natural y Política Forestal

FI || Ministry of Agriculture and Forestry

FR || Ministry of Ecology, Energy, Sustainable Development and the Sea

FR || Direction générale de l'alimentation, ministère de l'agriculture

FR || Ministère de l'écologie, du développement durable, des transports et du logement, Direction de l'eau et de la biodiversité

HU || Institute of Ecology and Botany of Hungarian Academy of Sciences

HU || Ministry for Rural Development

HU || Vidékfejlesztési Minisztérium, Természetmegőrzési Főosztály, Természetvédelmi Monitorozó Osztály

IE || Species Protection Unit -Science and Biodiversity Section National Parks and Wildlife Service - Department of Environment Heritage and Local Government

IE || Inland Fisheries Ireland ( previously Central Fisheries Board)

IE || National Parks and Wildlife Service, Species Protection Unit

IT || Ministero dell’Ambiente e della Tutela del Territorio e del Mare

LT || Ministry of the Environment

LT || Ministry of Agriculture, State Plant Service

LU || Ministère du Développement durable et des Infrastructures - Département de l'environnement

LV || Ministry of Agriculture

MT || Office of the Prime Minister – EU Secretariat

MT || Biodiversity Strategic Policy, Ecosystems Management Unit, Environment Protection Directorate

NL || Food and Consumer Product Safety Authority, Invasive Alien Species Team

NL || Dutch Ministry of Economic Affairs, Agriculture and Innovation

NL || Provincie Limburg

NL || Dutch Permanent Representation, Environment and Nature Department

PL || General Directorate for Environmental Protection

PT || Environment Department / Direcció General del Medi Natural. Departament de Medi Ambient i Habitatge

SE || Environmental Protection Agency

SI || Ministry of the Environment and Spatial Planning

SK || State Nature Conservancy of SR, Regional Office

SK || Ministry of the Environment, Division of Nature Protection and Landscape Development

UK || GB Non-native Species Secretariat

UK || Department for Environment, Food and Rural Affairs

UK || Cayman Islands Department of the Environment

UK || Countryside Council for Wales

UK || Scottish Government

Table A3: Research
centres and academic institutions that participated in the consultations

BE || Belgian Biodiversity Platform

BE || Research Institute for Nature and Forest, Flanders

BE || Université de Liège Gembloux Agro-Bio Tech

BG || Institute of Biodiversity and Ecosystem Research

BG || University of Forestry

DK || Aarhus University

FR || Anses, Laboratoire de Santé Animale, Unité épidémiologie

FR || Université de Poitiers, Ecologie, Evolution, Symbiose

GR || Hellenic Centre for Marine Research - HCMR

IE || National Biodiversity Data Centre

IT || Sardinian Forest Service

IT || Institute for Environmental Protection and Research - ISPRA

IT || Sapienza University of Rome

LU || Musée d'Histoire Naturelle

PL || University of Silesia, Faculty of Biology and Environmental Protection

PT || Centre for Functional Ecology. University of Coimbra

PT || Escola Superior Agrária de Coimbra/Instituto Politécnico de Coimbra

PT || Department of Biology, University of Minho

PT || Centre of Marine and Environmental Research – CIIMAR

RO || University Ovidius Constanta

UK || Centre for Ecology and Hydrology

Table A4: International
organisations that participated in the consultations

CAB International

Council of Europe

European and Mediterranean Plant Protection Organization - EPPO

European Environment Agency - EEA

European Network of Invasive Alien Species - NOBANIS

European Topic Centre on Biological Diversity

Regional Euro-Asian Biological Invasions Centre

Minimum
Standard C: publicity

Announcements of the
online public consultations (2008 and 2012) were published on Your Voice in
Europe[167] as well as
on the DG Environment Europa website. A press release[168] was
published for both consultations on Rapid. In order to encourage further
spreading of the online consultation, an e-mail announcement was sent to lists
of Member States' representatives, stakeholder organisations and experts,
inviting them to further circulate the message.

The stakeholder
consultation meeting held in September 2010 was announced on both the DG ENV
Europa website (under the headings News and Consultations[169]) and Your
Voice in Europe[170].
Furthermore, an announcement was mailed to lists of Member States'
representatives, stakeholder organisations and experts, involved in previous
work on invasive species or biodiversity in general, inviting them to further
circulate the message to relevant contacts and colleagues.

The working
groups (December 2010- August 2011) were announced at the September 2010
stakeholder consultation. Later, an invitation was mailed to lists of Member
States' representatives, stakeholder organisations and experts, inviting them
to further circulate the message to contacts and colleagues.

Minimum Standard D: time

The 2008
online public consultation period took place from 3 March to 5 May 2008 (9
weeks). The stakeholder consultation (3 September 2010) was announced on 1 July
2010 (65 days in advance; registration by 14 July 2010). The working groups
(2010-2011) were announced on 21 October (48 days prior to the first working
group meeting on 8 December 2010; registration by 8 November 2010). The final
online public consultation remained open from 27 January to 12 April 2012 (11
weeks): the last consultation built on a solid basis of contributions collected
between 2008 and 2012, from the whole spectrum of interest groups and involving
Member States representation. The focus was on the policy measures being
considered, which were based on the input and feedback collected from all
relevant stakeholders in the process that started in 2008. The Consultation
therefore built on material collected in a participative manner from all
sectors involved and focused on very specific policy choices formulated in a
rather limited number of questions, which justified a slightly shorter period
of consultation (11 weeks instead of 12 weeks).

Minimum Standard E: acknowledgement

All
expressions of interest, as well as the written contributions were
acknowledged. All meetings were summarised in minutes, which are accessible by
all stakeholders via the dedicated page of the Europa website[171].

3.
Annex III: Technical support

Given the complex nature
of the issues related to invasive alien species, extensive technical support
was sought by the Commission since 2006. The studies and reports listed discussed
below, as well as Commission-backed research projects, have provided a wealth
of important and useful material to inform decision-making and were extensively
used in support of this Impact Assessment.

DAISIE project

Ground breaking progress
was achieved with the EU-funded research project DAISIE (2005-2008) -
Delivering Alien Invasive Species Inventories for Europe[172] -
which focused on the development of a pan-European inventory of invasive alien
species with the objective of mobilising existing expertise for species
records, including and describing alien species likely to enter the EU and
spread from neighbouring countries, and identifying priority species. DAISIE compiled
an inventory of 10,961 alien species in the EU, and elaborated a list of the worst
100 IAS in the EU, mainly for awareness-raising purposes.

Joint Research Centre
online information system pilot project

Information on alien
species in Europe is provided online by a large number of global, regional or
national databases. The Joint Research Centre (JRC) is currently developing the
European Alien Species Information Network (EASIN) that aims to facilitate the
exploration of existing alien species information from distributed sources
through a network of interoperable web services. EASIN will allow extraction of
alien species information from online information systems for all species
included in an alien species inventory (EASIN catalogue), which was produced by
reviewing and standardizing available information from 43 online databases. The
EASIN catalogue includes the basic information needed to efficiently link to
existing online databases and retrieve spatial information for alien species
distribution in Europe. Using search functionality powered by a widget
framework, it is possible to make a tailored selection of a subgroup of species
based on various criteria (e.g., environment, taxonomy, pathways) and to
produce ‘on the fly’ distribution maps of the selected species. EASIN can be
accessed from http://easin.jrc.ec.europa.eu/

External contracts

Further technical
support was engaged through several studies carried out by the Institute for
European Environmental Policy and by Bio-Intelligence Service,
providing a very thorough understanding of (1) the current impacts of IAS, (2)
the current IAS framework in and beyond the EU and scoping of policy responses
in Member States and other OECD countries, (3) information on costs and
benefits of IAS policy measures and (4) recommendations for the further
development of an IAS policy.

The reports are the
following: "Recommendations on policy options to minimise the negative
impacts of invasive alien species on biodiversity in Europe and the EU"[173],
"Assessment of the impacts of invasive alien species in Europe and the
EU"[174],
"Policy options to minimise the negative impacts of invasive alien species
on biodiversity in Europe and the EU"[175], "Analysis of
the impacts of policy options/measures to address IAS"[176],
"Assessment to
support continued development of the EU strategy to combat invasive alien
species"[177],
prepared by IEEP and "Comparative assessment of existing policies on
Invasive Species in the EU Member States and in selected OECD countries"[178],
prepared by BioIntelligence Service. These reports are available online on the
dedicated DG Environment webpage[179].

These studies resulted
in a preliminary estimate of the cost of inaction of roughly €12.5 billion per
year in Europe[180]
and a preliminary exploration and cost estimate of possible policy actions[181].
Such costs of action would be much lower than the cost of inaction and tend to
decrease overtime while costs of inaction would only increase. Those studies
also allow drawing lessons from the EU's international partners' experiences,
while taking fully into account the national efforts undertaken so far.

The €12.5 billion
estimate is based on an assessment of the documented monetary impacts of
a list of 125 species, chosen on the basis of their documented impacts on the
environment, society and the economy. The list was not meant to be exhaustive
but to provide an estimate of the possible magnitude of costs. Of this total,
the documented costs for the agricultural, fisheries, forestry and health
amount to roughly €6 billion a year. These costs were then extrapolated to give
a more accurate overview of the magnitude of costs at EU level: extrapolation
was done on the basis of available information on the area of coverage of IAS
impact and the total known range of the IAS in question. Using this method the
total cost to the EU could go up to €20 billion, which would still be an
underestimate, considering that these monetary costs refer only to a subset of
IAS.

The estimated annual
costs of key actions based on the indicative assessment produced by Shine et
al. (2010) suggests that the possible scale of total costs (not incremental
costs) of key actions only, at EU and national level, could amount to €40-190
million a year. The low estimate is largely based on existing costs: such level
of investment should therefore be considered as the baseline. For a significant
number of measures, some level of investment is already taking place at
national level. Cost of damage has been estimated to amount to roughly €9.6
billion a year. If we compare the cost of damage with the higher end range of
cost of action, €190 million a year, it is possible to see that the avoided
cost of IAS damage would be manifold to the cost of policy action.

It is to be considered
that the estimate of damage costs includes a number of costs related to plant
pest or animal diseases that fall under the scope of the EU plant health
regime, however costs caused by IAS non covered by any existing regime formed a
significant proportion of the estimate and the estimate is based on a sub-set
of IAS. The existing estimate of the costs is therefore likely to be a serious
underestimation. Furthermore, the available data on monetary costs remains scarce
and unevenly distributed between geographical areas and taxa. Moreover,
benefits in terms of biodiversity, recreational or cultural values are often
not available. Nevertheless, the comparison between the estimated cost of
action vs. the cost of inaction is thought to be robust and to provide a solid
idea of the magnitude of costs and benefits.

European
Environment Agency

Also the European
Environment Agency has been supporting the process identifying IAS within
the framework of the process of Streamlining European Biodiversity Indicators
(SEBI)[182],
commissioning a study on the development of an early warning and information
system for IAS threatening biodiversity in Europe and embarking on a pilot
project on the surveillance of IAS through citizen science (Nature Watch,
within the Eye on Earth project). The report "Towards an early warning and
information system for invasive alien species (IAS) threatening biodiversity in
Europe"[183]
is available online[184].

4.
Annex IV: International Policy Context

Convention on
Biological Diversity (CBD)

The Convention on
Biological Diversity[185],
to which the EU and the Member States are contracting party, is an
international legally-binding treaty with three main goals: conservation of
biodiversity; sustainable use of biodiversity; fair and equitable sharing of
the benefits arising from the use of genetic resources. The scope of the
Convention for Biological Diversity includes measures concerning the
introduction and spread of invasive alien species (IAS). At the 10th
meeting of the Parties to the Convention on Biological Diversity in 2010
(Nagoya, Japan), the 2020 20 biodiversity targets were agreed, including Target
9 specifically referring to IAS: "By 2020, invasive alien species and
pathways are identified and prioritised, priority species are controlled or
eradicated, and measures are in place to manage pathways to prevent their
introduction and establishment."

International Plant
Protection Convention (IPPC)

The international
framework for regulatory plant health is the International Plant Protection
Convention[186],
to which the EU and the Member States are contracting parties. The objective of
the IPPC is to protect cultivated and wild plants against the introduction and
spread of pests, while minimising interference with international trade. To
this end, the IPPC develops International Standards for Phytosanitary Measures
(ISPMs). Such standards may also be developed by regional organisations under
the IPPC. For the EU, the relevant regional organisation is the European and Mediterranean
Plant Protection Organisation (EPPO).

Overlap exists between
the scope of CBD and IPPC, CBD including non-native plants and animals as well
as non-native pests and pathogens of plants and IPPC focussing on 'pests' (the
equivalent for 'harmful organism' in the EU legislation) including invasive
alien plant species. While the IPPC-definition is applied in the EU
plant health regime, no IAS plants have been regulated so far under that regime
other than parasitic plants. Cooperation between the secretariats
of the CBD and IPPC is governed by a Memorandum of Cooperation signed in 2004
to promote synergies, avoid overlaps and duplication, and ensure effective
cooperation.

World Organisation for
Animal Health (OIE)

The OIE is the
intergovernmental organisation responsible for improving animal health
worldwide. Terrestrial animal means a mammal, bird or bee. Aquatic animals means all life stages
(including eggs and gametes) of fish,
molluscs, crustaceans and amphibians originating from aquaculture establishments
or removed from the wild, for farming purposes, for release into the
environment, for human consumption or for ornamental purposes. OIE has
established Terrestrial and Aquatic Animal Health Codes that are providing
frameworks to which EU rules are aligned.

The main objects of the
OIE are: 1) to promote and co-ordinate research work on contagious diseases of
livestock; 2) to collect and disseminate knowledge on the spread of epizootic
diseases and the means to control them, ensuring coordination between sanitary
services; 3) to examine international draft agreements regarding animal
sanitary measures and to provide signatory Governments with the means of
supervising their enforcement.

World Trade
Organisation (WTO) - Sanitary and Phytosanitary (SPS) Agreement

The WTO Sanitary and
Phytosanitary (SPS) Agreement[187],
to which the EU is also contracting party, provides a multilateral framework of
rules and disciplines to guide the development, adoption and enforcement of
sanitary and phytosanitary measures in order to minimize their negative effects
on trade. The SPS Agreement for this purpose acknowledges IPCC and OIE as
reference organisations. The SPS Agreement does not interfere with the
decisions of its Members concerning the appropriate level of protection of the
environment, but sets rules how that level may be achieved without undue
interference with trade. Sanitary and phytosanitary measures should be applied
only to the extent necessary to protect human, animal or plant life or health
and be based on scientific principles and evidence, so as not to discriminate
between Members where identical or similar conditions prevail.

International Maritime
Organisation (IMO)

The International
Convention for the Control and Management of Ships Ballast Water and Sediments
was adopted in 2004. It is expected to enter into force in 2012-2013. Parties
undertake to prevent, minimize and ultimately eliminate the transfer of harmful
aquatic organisms and pathogens through the control and management of ships’
ballast water and sediments. The Convention has been ratified by four Member
States (France, the Netherlands, Spain and Sweden). The International Maritime
Organisation (IMO) is also facilitating the development and application of
guidelines on the fouling of ship hulls with such organisms.

Convention on the
conservation of European wildlife and natural habitats (Bern Convention)

The Bern Convention is a
binding international legal instrument in the field of nature conservation,
which covers the natural heritage of Europe and some States of Africa. The
Convention aims at conserving wild flora and fauna and their natural habitats
and promoting European co-operation, with a particular focus on endangered
natural habitats and endangered vulnerable species, including migratory
species. Parties to the Bern Convention must promote national policies for the
conservation of wild flora and fauna, and their natural habitats and take them
in due consideration in planning and developing policies. Members also engage
in education and awareness-raising on the need to species of wild flora and
fauna and their habitats and encourage and co-ordinate research and sharing of
experience and best-practices.

To better focus the
implementation efforts, the Bern Convention created specialised groups of
experts, including one dedicated to Invasive Alien Species. The group collected
and analysed different national laws dealing with invasive species and proposed
work aimed at the harmonisation of national regulations on introduced species,
particularly on the fields of definitions, territorial scope of regulation,
listing of species whose introduction is undesirable, identification of
authorities responsible for permits, conditions for issuing such permits and
control involved. The group published in 2003 a European Strategy on IAS, which
has inspired several valuable initiatives in EU Member States.

5.
Annex V: EU and National Policy Baseline

5.1.
EU
policy

5.1.1.
EU
legislation addressing part of the IAS problem[188]

Animal health regime

The EU Animal Health
Regime, currently under revisions, focuses on prevention and an integrated
approach to animal health and welfare. The revision aims at establishing a
modernised single regulatory framework, to modernise and simplify the existing
legislation, and to adjust the harmonised EU framework for improved
coordination, as well as responsibility and cost-sharing. The revision will
support: risk-based prioritisation of EU interventions; improved border and
on-farm biosecurity; and improved science, innovation and research.

The revised regime aims
to covers the health of all animals in the EU, including wild animals, but it
does not address environmental risks associated with the import, release and/or
escape of alien animals. However, the framework contributes to IAS prevention
by providing a basis to regulate import and intra-EU movement of animals that
are vectors of diseases that could affect native biodiversity. For example, the
EU-wide ban on import of wild birds was adopted to prevent transmission of
avian flu and resulted in 2 million fewer birds being imported each year.
However, import restrictions do not apply to captive-bred species reared or
kept in captivity for breeding or re-stocking supplies of game; birds imported
for approved conservation programmes; pets accompanying their owner; or birds
imported for zoos or experiments.

Plant health regime

The plant health regime
establishes protective measures against the introduction into the EU and the
intra-EU spread of organisms harmful to plants or plant products. The EU plant
health regime is under revision to take account of emerging threats linked to
globalisation and climate change, consistent with key international
instruments, notably the IPPC. The scope of the revised plant health law will
cover pests and disease agents – harmful organisms – affecting plants, both
cultivated and wild ones. Nevertheless, the introduction of invasive alien
plant species will not be covered by the revised plant health law.

Wildlife Trade
Regulation (WTR)

The WTR regulates
border, import and transit controls in relation to trade in protected species
of wild fauna and flora and aims to ensure that trade will not have a negative
impact on their conservation. Its main focus is the implementation of the
Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES) but it also covers endangered EU species not threatened by
international trade to ensure policy coherence e.g. with the birds and habitats
Directives. The WTR provides a legal basis to suspend the import into the EU of
‘live specimens of species for which it has been established that their
introduction into the natural environment of the Community presents an
ecological threat to wild species of fauna and flora indigenous to the
Community’. Since 1997, seven animal species have been banned for import but
there is no restriction on their intra-EU movement/holding, no provisions
ensuring early warning or rapid response in case of detection of such species
in the environment, nor any management provision.

Regulation on
the use of alien and locally absent species in aquaculture

The Regulation on the
use of alien species in aquaculture establishes a dedicated framework to assess
and minimise the possible impact of alien and locally absent species used in
aquaculture on the aquatic environment. It is the only EU instrument to focus
on the ecological risks associated with alien species introductions by a
specific sector. Member States must ensure that all appropriate measures are
taken to avoid adverse effects to biodiversity, including ecosystem functions,
from such introductions / translocations and the spreading of these species in
the environment.

The Regulation has a
dual focus: intentional introduction of alien species (species / subspecies of
an aquatic organism occurring outside its known natural range and the area of
its natural dispersal potential) and intentional movement of locally absent
species (species / subspecies of an aquatic organism locally absent from a zone
within its natural range of distribution for biogeographical reasons). It also
covers environmentally harmful non-target species moved with introduced or
translocated organisms, excluding disease-causing organisms regulated under the
animal health regime. The Regulation does not cover translocations within
Member States except if there is a risk to the environment, nor to pet-shops,
garden centres or aquaria where there is no contact with EU waters. The
Regulation introduces a list of alien species that can be released without a
permit (effectively a list of permitted species).

Habitats and Birds
Directives

The Habitats Directive
and Birds Directive underpin EU biodiversity policy through two pillars of
activity: the Natura 2000 network of protected sites and a strict system of
species protection. Implementation measures should be designed to maintain or
restore, at favourable conservation status, natural habitats and species of
wild fauna and flora of Community interest, taking account of economic, social
and cultural requirements and regional and local characteristics. Both
Directives contain an explicit IAS prevention obligation. The Habitats
Directive requires Member States to ‘ensure that the deliberate introduction
into the wild of any species which is not native to their territory is
regulated so as not to prejudice natural habitats within their natural range or
the wild native fauna and flora and, if they consider it necessary, prohibit
such introduction’ (Art.22b). The Birds Directive more loosely requires MS to
'see that any introduction of species of bird which do not occur naturally in
the wild state in the European territory of the Member States does not
prejudice the local flora and fauna’ (Art.11). In practice, these provisions, worded
in general terms, have not led to the creation of regulate the introduction of
alien species in the environment, but led to a myriad of diverse and not often
coherent action, and have proved ineffective in preventing the continued
introduction and spread of IAS in the EU territory.

Certain measures under
the Directives may have unintended consequences for IAS: some alien species are
currently listed for protection and as priority species for co-financing;
certain species are protected in their whole current range although they are
native only in part of the European range; some bird species alien to the whole
of Europe are listed in the birds Directive and subject to the same
protection/management and derogation provisions as naturally occurring species;
for some habitat types, alien species are included in the EU Habitats
Interpretation manual as characteristic species.

Water
Framework Directive (WFD)

The WFD establishes a
framework for national measures to achieve or maintain a good ecological status
for European inland, transitional and coastal waters by 2015 and prevent their
further deterioration. It provides for indicators to assess and monitor water
status for this purpose. IAS are not mentioned in the WFD text but are included
as a ‘potential anthropogenic impact’ in an annex: IAS are a pressure that
alters taxonomic composition and detracts from naturalness, Member States
should therefore take their impacts into account as part of WFD implementation.
In 2009 a consultative process (ECOSTAT 2009) examined how alien species could
be more consistently incorporated in WFD implementation: however, some
constraints to achieving consensus on a single approach were identified, inter
alia the fact that Member States procedures for using alien species data in
ecological status classification vary widely, according to country, biological
element and surface water type.

Marine Strategy
Framework Directive (MSFD)

The MSFD requires each
Member State to develop a marine strategy, based on the ecosystem approach,
with the aim of achieving or maintaining ‘good environmental status’ in the
marine environment by the year 2020 at the latest. Actions should be based on
the principles of preventive action, rectification of environmental damage at
source and the polluter pays principle. IAS are explicitly covered by one of
the 11 descriptors of good environmental status: ‘non-indigenous species
introduced by human activities are at levels that do not adversely alter the
ecosystems’. This is particularly important in the marine environment where IAS
eradication and control are particularly challenging. The Member States initial
assessment of marine status (by 2012) should include an IAS inventory and
assess the entity of their pressure.

5.1.2.
Lessons
learnt from the plant health regime (PHR)

The
issue of plant pests is close to that of IAS: in fact plant pests and diseases,
as argued in this Impact Assessment, are IAS that are already tackled by PHR.
The measures in place through PHR have therefore provided substantial inspiration
for the proposed actions to tackle IAS. Since its adoption, the PHR has
successfully protected the EU against the introduction and spread of many
pests; however, with the increasing globalisation of trade, the systems faced
new challenges that brought about the need to review its functioning. In order
to assess its successes and shortcomings, the European Commission carried out a
review and commissioned an evaluation which thoroughly examined the functioning
of the system. The evaluation was conducted by the Food Chain Evaluation
Consortium (FCEC) and completed in 2010. The current revision and the FCEC
study provided a useful oversight of pitfalls and shortcomings of the system in
place, from which valuable lessons can be learnt.

The
FCEC evaluation in particular suggested that the plant health regime should
strengthen the measures on prevention and enhance coordinated action to prevent
the spread of harmful organisms that enter the EU. The study also recommended
more solidarity, i.e. moving from a MS based to EU approach for joint action to
tackle risks of EU significance. Recognising the importance of prevention as
the most cost effective way of avoiding problems related to IAS, the measures
proposed seek to refocus the use of resources currently spent on IAS (those not
covered by existing EU legislation) on prevention rather than on measures to
react to problems already established, in line with the approach of the PHR.
The FCEC study even highlighted the need to strengthen prevention in the plant
health regime by strengthening the instruments for the follow-up, including
surveillance, contingency planning, rapid outbreak eradication and containment,
should a harmful organism have gone unnoticed during import inspection. The
proposed measures to tackle IAS are fully in line with this recommendation and
establish a system which includes surveillance, early warning and rapid
response as well as management obligations for those IAS that enter and
establish in the EU. Furthermore, the introduction of provisions to address
unintentionally introduced IAS through pathway management seeks to further
strengthen the prevention element by going beyond the species listed as IAS of
EU concern.

The
FCEC study also highlighted the need for the PHR to place more emphasis on the
natural spread of pests, rather than simply on the movement of host plants, by
introducing more flexible provisions to contain the spread of harmful organisms
that could not be eradicated. The proposed measures reflect this message by
introducing management obligations for the IAS of EU concern, ensuring that
established IAS, if they cannot be eradicated, will be contained or controlled
so as to minimise or mitigate the damage they cause and avoid their spread in
the EU. At the same time, the management obligations provide enough flexibility
for Member States to select the most appropriate management options.

The FCEC evaluation also
found that implementation of some aspects of the regime has not always been
consistent, hampering the effectiveness of the system. The need for consistent
action is recognised by the proposed measures, which propose to set obligations
focusing on the IAS of EU concern. Conscious that limited resource may hamper
the implementation of certain measures, the system has been designed to cater
for flexibility, whenever possible, and to recognise the fact that Member
States are already taking some action to tackle IAS.

5.1.3.
EU
policy gap analysis

As seen in section
5.1.1, some IAS are already addressed by EU legislation. Figure A1 is
replicating the structure of the operational objectives (section 4 of the
Impact Assessment report) and is summarising the scope of existing legislation
in relation to those objectives.

Figure A1: Response
tree, identifying current international and EU legal provisions to address the
various aspects of the operational objectives in (Figure 7), labelled A, B, C,
D and E

Current EU legislation
has some clear shortcomings:

Gaps in species and
pathways coverage - taxonomic coverage of EU instruments is weakest
for alien animals and for alien plants that do not qualify as diseases or pests
and has gaps in relation to microorganisms causing ecosystem damage as well as
social or economic damage. Table A5 summarises the current situation
highlighting the species groups covered by existing legislation and identifying
the remaining policy gaps. When it comes to pathways, the EU legislation has
very limited scope: the Regulation on the use of alien and locally absent
species in aquaculture addresses the release into the environment of aquatic
species used for aquaculture purposes; the regulations on the use of biocidal
products and plant protection products regulate the release into the
environment of microorganisms used as biocides or as plant protection products.
The EU has also some rules on: wood packaging material carrying alien
invertebrates (2004/102/EC); animal feed carrying undesirable weed seeds
(2002/32/EC); plant reproductive material contaminated with other genera or
species (EU plant reproductive material regime). However, these are only a few
of the possible pathways of introduction, which are mostly left unaddressed,
beside some scattered national initiatives.

Examples on the
remaining gaps:

· Animals
grazing on terrestrial plants: Canadian goose overgrazing wetlands

· Animals
grazing on aquatic plants: common slider consuming all aquatic vegetation

· Animals
harming animals: grey squirrel outcompeting red squirrel

· Management of
invasive aquaculture species: aquaculture regulation is only addressing release,
not management of e.g. red swamp crayfish

· Management of
IAS banned from trade through Wildlife Trade Regulation: this regulation is
only addressing trade, not management of e.g. American bullfrog

· Animals
affecting public health: poisonous spiders

· Animals
causing ecosystem damage: sika deer disturbing forest ecosystems

· Animals
causing economic or social damage: musk rat damaging river banks, dams and
railroads

· Weeds
affecting terrestrial plants: ragweed causing loss of agricultural production

· Weeds affecting
aquatic plants: waterweeds outcompeting native vegetation

· Plants
affecting animal health: ragweed affecting livestock

· Plants
affecting public health: giant hogweed causing medical problems

· Plants
causing ecosystem damage: black cherry disturbing forests

· Plants
causing economic or social damage: Japanese knotweed damaging infrastructure

· Diseases to
aquatic plants:

· Micro-organisms
causing ecosystem damage: algal blooms of e.g. Chinese diatom

· Micro-organisms
causing economic or social damage

Complexity, legal
uncertainties and insufficient focus on prevention – The fact that
different IAS and different aspects of the IAS problems are addressed by
separate EU legislation creates complexity. The lack of a dedicated policy at
EU level leads to a situation where Member States take individual initiatives
on the IAS not already covered by EU legislation. Furthermore, except for
aquaculture organisms, EU legislation does not clarify the criteria on which
Member States may regulate IAS movement/holding without impeding operation of
the internal market, creating legal uncertainties. Finally, apart from the
animal and plant health regimes, the EU lacks an approach to managing IAS and
invasion pathways from pre-border to post-border and down to control and
management at appropriate scales. Current policies are insufficiently
precautionary and do not optimise efforts for prevention.

Other difficulties in
the current EU policy set up – Lack of a common EU definition of IAS
leads to different Member States adopting rules on the basis of different
definitions. While a wealth of data is often available, this is often not
readily accessible and, unlike in the areas of animal and plant health, there
is no EU system on IAS. This affects all areas of IAS policy, particularly early
warning and rapid response. Furthermore, IAS impacts on biodiversity and
ecosystem functions are not explicitly addressed in existing EU risk assessment
frameworks except for aquaculture. A few Member States have made substantial
investments to develop robust systems to assess a wider range of species, often
modelled on the EPPO Pest Risk Assessment methodology, but in most cases risk
assessments are not well coordinated with other national systems. When it comes
to management of established species, there are no EU instruments to support a
common approach. The use of existing funding, such as LIFE +, is not optimal,
due to a lack of a coordinated approach at EU level. Moreover the current focus
is often on the management of existing IAS problems rather than on prevention
of new invasions. Finally, the lack of awareness both at political and public
level often acts as an impediment to take action and there is no overarching
strategy or platform to foster awareness-raising of IAS as a transboundary problem.

5.2.
The
2020 Biodiversity Strategy

International
commitments

In October 2010, in
Nagoya, Japan, at COP10 of the Convention for Biological Diversity, the EU and
its international partners adopted a new Strategic Plan, which includes one
specific target related to IAS: target 9 aims to achieve that, by 2020,
invasive alien species and pathways are identified and prioritised, priority
species are controlled or eradicated, and measures are in place to manage
pathways to prevent their introduction and establishment.

The threats from
invasive alien species will have to be addressed in line with these
international commitments and if the EU is to achieve its own 2020 goal of
halting the loss of biodiversity and the degradation of ecosystem services in
the EU, restoring them in so far as feasible, while stepping up the EU
contribution to averting global biodiversity loss.

The EU commitments

Invasive Alien Species
(IAS) were already identified as an environmental concern in the 6th EAP and in
the 2006 Communication on Halting the Loss of Biodiversity.

In 2008 the
Communication “Towards an EU Strategy on Invasive Species” (COM (2008) 789) was
published and it was received positively at the highest political level:

§
The
Environment Council of June 2009[189] noted the fragmentation,
generality and lack of consistency of legislation at community level, national
and international level and called for a comprehensive Strategy to fill the
existing gaps, including new dedicated legislative elements and, where
necessary amending or incorporating existing provisions.

§
The
Committee of the Regions[190] expressed
support for a dedicated legislative measure to tackle the threat of IAS

§
The
Economic and Social Committee[191] echoed the conclusions
of the Committee of the Regions and also called for a creation of a European
Agency to monitor implementation.

Finally, the European
Council in March 2010 committed to halting the loss of biodiversity and the
degradation of ecosystem services in the EU by 2020, and restoring them in so
far as feasible, while stepping up the EU contribution to averting global
biodiversity loss by 2020. Being IAS one major driver of biodiversity loss, the
EU effectively committed itself to take action against IAS.

Delivering on the
commitments

In line with the
commitments (both international and at EU level) outlined above, the Commission
published, in May 2011, the EU 2020 Biodiversity Strategy – "Our
life insurance, our natural capital: an EU biodiversity strategy to 2020"[192] – which sets
a specific target to address the issue of IAS and proposes the publication of a
dedicated legislative instrument to tackle the problem.

Concretely, the new
Biodiversity Strategy proposes:

§
Target
5:
by 2020, Invasive Alien Species and their pathways are identified and
prioritised, priority species are controlled or eradicated, and pathways are
managed to prevent the introduction and establishment of new IAS.

The measures proposed to
help achieve this target are:

§
Action
15: Strengthen the EU Plant and Animal Health Regimes - The Commission
will integrate additional biodiversity concerns into the Plant and Animal Health
regimes by 2012 – these regimes are currently being reviewed by SANCO and this
is the area where close cooperation with DG SANCO is needed.

§
Action
16: Establish a dedicated instrument on Invasive Alien Species - The Commission
will fill policy gaps in combating IAS by developing a dedicated legislative
instrument.

Delivering
on action 15

One of the measures
proposed by the EU 2020 Biodiversity Strategy is to integrate IAS concerns into
existing instruments, mainly the animal and plant health legislation. As
described above, close cooperation has been maintained with DG Health and
Consumers (SANCO), to establish how the revised plant and animal health regime
could include further biodiversity concerns. The scope of the two instruments
will be widened to include pests and diseases of wild plants and animals.
However, the option of including invasive alien plants in the new plant health
law, which was considered in the plant health impact assessment was not
retained, mainly because this would have implied a change in the intervention
logic: while the plant health regime regulates disease agents and pests of
plants and plant products, the IAS-policy will deal with entire plants that can
be harmful.

The most promising
aspect of integrating biodiversity concerns into the animal and plant health
regimes is, however, the idea of integrating border controls on IAS within the
border controls that are already being carried out for animal and plant health.
This would avoid creating a parallel system of controls and would take
advantage of a well-functioning system with limited extra investment.

Delivering
on action 16

This is the
focus of the policy proposals, discussed in this impact assessment report.

5.3.
IAS
policies and initiatives in Member States[193]

A dedicated study was commissioned to provide an
inventory of existing policies and initiatives to tackle IAS in Member States.
The assessment was performed systematically, by evaluating each policy/initiative
against a set list of criteria.  The information was updated and confirmed in
November 2012 and is summarised in Table A6. The main findings are reported in
the paragraphs that follow, but the whole study can be accessed from this webpage:
http://ec.europa.eu/environment/nature/invasivealien/index\_en.htm.

5.3.1.
A
fragmented policy field

Most Member States have policies and initiatives
on IAS but these tend to be highly fragmented, leading to policy gaps. Most
Member States also appear to concentrate their effort on tackling IAS that are
long established rather than on prevention or early warning and rapid response.
However, a number of Member States have begun to adopt a black listing approach
in relation to trade and keeping of IAS but these lists in general are not
systematically supported by formal risk assessments and are potentially open to
challenge.

In summary, the EU has one of the best pools of
IAS information and experts worldwide[194] and, as awareness
of the IAS impacts increases, a variety of initiatives are taken to tackle such
problems. However, the disparate nature of the legislation/initiative leads to
a heterogeneous approach which leaves considerable policy gaps and there is a
rising awareness of the need to streamline national policies, by building upon
existing tools, particularly when it comes to risk assessment, information
sharing, early warning and rapid response.  Moreover, there is increasing
appreciation of the need to shift the emphasis away from long term management
of IAS towards prevention.

5.3.2.
Approaches
across Member States

A. Prevent intentional introduction

Risk assessment is a key tool to underpin
prioritisation and support decision making and it is also important in relation
to underpinning inhibition of trade.  Despite this, no Member State has a formal,
legally-binding risk assessment framework in place and only 8 Member States
have developed any risk assessment framework at all. These Member States use at
least 4 different methodologies which are also widely divergent, some are short
screening tools while others are comprehensive mechanisms (involving peer
review and expert panels), some consider only environmental impacts (excluding
economic and social impacts) while others do not cover all IAS taxa. The existing
complex situation is likely to become even more complex and divergent as
individual Member States develop further methodologies and, without and EU
framework, there will be substantial waste of resources as many Member States
will "re-invent the wheel".

To date 12 Member States have imposed import
restrictions on IAS with between 1 and 136 species listed per Member States
(overall 226 species are subject to prohibition on import in at least one
Member State). These 12 Member States apply restrictions both on import from
third countries and on intra-community trade, but comprehensive risk
assessments are rarely applied to back up import restrictions. Only 3 of
these Member States back up their import restrictions with any type of
risk assessment.

11 Member States have restrictions on the sale
of some IAS and again rarely are such restrictions backed by comprehensive risk
assessments. Only 3 of these 11 Member States back their
restrictions on sale with any type of risk assessment.

13 Member States also have restrictions on
holding/keeping of IAS with between 1 and 136 species subject to restrictions
per Member State.

B. Prevent unintentional introduction

No Member State has a comprehensive framework
for prioritising pathways and managing risk on pathways, although frameworks
for assessing risk on pathways and vectors are in development in a small number
of Member States. There is a serious risk of divergent approaches in this
complex area if these frameworks continue to develop in isolation. Contingency
plans are a key tool in the prevention agenda of the plant and animal health
regimes.  However, only one Member State has a contingency plan in place for an
IAS not yet present in its territory (and this is only for a single species).

C. Prevent intentional release into the
environment

While most Member States do have a
general prohibition on release of alien species into the environment, 8 Member
States do not have any such prohibition. Of the Member States which do have
this provision there is a bewildering array of different exceptions and few
countries define precisely the environment and/or what release into the
environment means. Liabilities related to release into the environment are
often not well-defined in the legal instruments.

D. Early warning and rapid response

Information systems and information sharing

As regards centralised information systems on
IAS, several Member States have relevant websites, often hosted by the national
environmental agencies or ministries, but only a few Member States have a
centralised dedicated website on IAS. Currently, some Member States cooperate
and share information with some other European countries via a common platform:
NOBANIS is an IAS joint-information system in place in 14 Member States in
northern and central Europe, and in another 4 non-EU countries and the European
part of Russia. The DAISIE database could also be a useful platform and
repository of information and knowledge on IAS. After the conclusion of the
project that created it, DAISIE has been updated in an ad hoc manner and based
on the initiatives of individual experts only. It was however recently
re-launched with updated information and the expert networks and data collected
could provide a scientifically sound basis for the development of other further
initiatives.

Early warning and alerts

Currently, no comprehensive early warning system
for IAS, similar to that in Plant and Animal Health, exists for IAS in the EU. 
Indeed, recognising
this gap, a recent EEA report stressed the needs for developing an EU-wide
early-warning system to detect and react to invasions[195].
Early-warning and alert measures for IAS are also generally missing at Member
State level, whether in terms of targeted monitoring and surveillance or
horizon scanning.

Rapid responses

Furthermore, virtually no Member States have any
rapid response protocol or framework for rapid action. This is reflected in the
paucity of rapid responses – only 8 Member States are carrying out (or have
carried out) national rapid response eradications on IAS and these have
involved only 14 IAS (5 Mammals, 2 Birds, 2 Amphibians, 2 Fish, 1 slug
and 2 Plants).  This is in
stark contrast to the much greater effort expended by Member States on
long-term control of species which involves 20 Member States and over 100
species (see point E below).

E.  Eliminate, minimise or mitigate damage

Only 5 Member States are carrying out (or
have carried out) large scale eradications on IAS where the objective is the
complete elimination of the species from the Member State.  The most ambitious
of these is the ongoing eradication of the Ruddy Duck but even this has taken
over 30 years and action is still lacking in many Member States.

In contrast most (20) Member States are carrying
out control on species that is large scale and/or is being funded by government
(national, regional, local). These Member States are controlling between 1 and
41 species each and in total approximately 110 species of IAS are involved.

5.3.3. The interplay
between existing national measures and the measures proposed under the
preferred option

The system envisaged aim to build upon existing
actions at national level and the measures envisaged were designed drawing
extensively on the experiences at Member States level as well as from third
parties.

The proposed approach is focused on a single
list of IAS of EU concern: Member States will have to apply a series of legal
obligations to these species, namely: prohibit and prevent the import, sale,
keeping, transport, release of the listed species. Member States will also have
to alert the Commission and the other Member States if they see a listed IAS
for the first time and proceed to rapid eradication. Finally, Member States
will have to manage the listed species if they are well established in their
territories.

Species listed as species of EU concern may also
be listed in national lists, in that case listed species would be subject to EU
rules as well as to national rules. As seen above, however, the majority of
national rules adopt approaches that are mirrored in the proposed approach,
e.g. bans on import, sale, possession. In other cases, listed species will not
be listed by Member States and in this case the EU rules will need to be
applied on the listed species.

The proposed approach goes beyond the list of
species of EU concern in two aspects: the management of pathways of
introduction and the release into the environment. In the first case, as
discussed in section 4.4.2, there is hardly any initiative taken at Member
States level to manage pathways of introduction beyond what is already mandated
by other EU legislation. It is left however to the Member States to take stock
of their national situation and define their priority pathways of introduction
and devise ways of managing them. When it comes to release into the
environment, if species are not listed as IAS of EU concern, but are considered
risky by Member States, then only the requirement for the permit for release
into the environment would apply in additional to national obligations. Table
A5 summarises the interplay between the proposed measures and national
legislation.

Table A5: interplay
between the proposed measures and national measures

Operational objectives || Measures of the preferred option || Interplay with national rules

A - Prevent intentional introduction of IAS of EU concern into the EU ||  A.2 - list of IAS of EU concern + emergency measures || · EU listed species will be subject to import/sale/transport bans across the EU · If the same species were also listed in national lists, the EU rules plus the national rules would apply. In case of contradictions, EU law takes precedence. · 8 MS already have import restrictions and would not face an additional burden if the species they ban were on the EU list · Species listed in national lists, but not under the EU list, would only be subject to national rules. NB – national measures must be in line and compatible with trade and internal market rules.

B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || B.2 - Member States manage major pathways, share information and Commission provides guidance || · Obligations linked to pathway management are not linked to EU listed species · Efforts required of MS to address their priority pathways · Very little action taken at national level on managing pathways of introduction. Large flexibility given to Member States to devise measures to manage pathways, so any initiative already taken could continue unhindered by the proposed measures

C - Prevent intentional release of IAS into the environment || C.2 – no release of IAS of EU concern + permitting system for IAS of Member State concern || · EU listed species would be subject to a ban on release into the environment. · If the same species were also listed in national lists, the EU rules plus the national rules would apply. In case of contradictions, EU law takes precedence. · 19 MS have a general ban on release into the environment · Species listed in national lists, but not under the EU list, would be subject to a permit requirement in addition to national obligations.  In case of contradictions, EU law takes precedence. · MS devise their own permitting system; the proposed measures therefore are not incompatible with existing permitting systems.

D – Alert and Rapid Response to prevent reproduction and spread of IAS of EU concern into the environment || D.3 - obligation to quickly eradicate newly establishing IAS of EU concern and share information. Possibility of derogations. || · EU listed species would be subject to rules on early warning and rapid response. · If the same species were also listed in national lists, the EU rules plus the national rules would apply. In case of contradictions, EU law takes precedence. · Species listed in national lists, but not under the EU list, would only be subject to national rules. · The proposed system of early warning is not incompatible with existing early warning or information sharing systems. · The rules on early eradication would not be incompatible with possible eradication rules at national level.

E - Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || E.2 - Member States eradicate, control or contain IAS of EU concern, share information and Commission provides guidance || · EU listed species would be subject to rules on management if well established in Member States. · If the same species were also listed in national lists, the EU rules plus the national rules would apply. In case of contradictions, EU law takes precedence. · Species listed in national lists, but not under the EU list, would only be subject to national rules. · 20 MS are already carrying out long-term control of species. The proposed measures would not be incompatible with existing management efforts, given the flexibility given to MS to select the most appropriate management measures for the EU listed species.

Table A6:
Overview of measures on specific IAS in the EU-27: trade ban (black), sale ban
(X), keeping ban (Z), eradication (vertical lines), management and control
(grid) and other measures (dots)

6.
Annex VI: Screening of legislative sub-options

When it comes to the
legislative measures, it was necessary to examine the different objectives so
as to be able to select the most appropriate level of ambition and EU
intervention to ensure effectiveness, while balancing costs and benefits. Based
on the suggestions expressed during the consultations, three different
sub-options were identified for each operational objective, reflecting
the different types or levels of intervention that are possible. An initial
quick screening exercise led to the discarding of the sub-options that were
considered unfeasible or simply not as effective as others, with feasible and
effective sub-options retained for further analysis.

This is described below
and summarised in table A7.

Operational objective A
- Prevent the intentional introduction of IAS of EU concern into the EU through
trade, marketing and transport. Three sub-options have been identified to
prevent the intentional introduction into the EU of invasive alien species:

A1:    a list
of IAS of EU concern could be developed. This list would include alien species
proven to be invasive by risk assessment. These species would be banned from
trade, marketing and transport. Unlisted alien species would face no such ban.
Example: EU Wildlife Trade Regulation.

A2:    a list
of IAS of EU concern could be developed as in A1, but the possibility to
establish emergency measures would be introduced to address alien species not
yet listed but for which there may be evidence of invasiveness. This would be
temporary measures allowing to, for example, ban trade while a risk assessment
is being performed in view of potential listing on the EU list. Example: EU
Plant health regime.

A3:    an
EU-list of approved alien species could be developed, where only alien species
proven not to be invasive by risk-assessment are allowed to be traded, marketed
or transported. Unlisted species would not be allowed unless proven safe.
Example: EU Biocides regulation.

While being attractive
for its simplicity, sub-option A1 was discarded as it was not considered
to be sufficiently effective in reaching the overall objective of prevention:
by allowing unlisted species to be brought into the EU without the possibility
for emergency measures, it would eliminate the possibility of a rapid response
during the early stages of invasion, when costs could be contained. Emergency
measures have proven successful within the plant and animal health regime and
it would be a missed opportunity not to include this mechanism. Sub-option
A3 would be the most precautionary and most effective approach and as such
it was the preferred option of some animal welfare and nature conservation
organisations consulted, as well as of 24 % of the respondents in the 2012
public consultation (Section 2.1.1 of Annex II). This approach is implemented
in some countries, like New Zealand. However, it was discarded because
it would be disproportionate and extremely costly to develop such
a system at the European level given the intensity of trade relations and the
porous borders with several entry points of the EU. Under this option no alien
species would be allowed for trade unless proven safe, implying that a large
number of species that are currently traded as well as new species entering the
market would first need to be risk assessed. Considerable investment of
resources would be needed to develop all the necessary risk assessments, in
terms of money, human resources and time. Considering that large numbers of
alien species are traded – e.g. more than an estimated 6000 pet species are
currently traded in Europe, and the number of traded horticultural species is
likely to be significantly larger (e.g. there are at least 55,000 woody plants and perennials available for sale[196]) – having to prepare risk
assessments for every traded species or for any new species to be brought onto
the market would entail a major disruption to trade as it would take years to
develop those risk assessments and trade would put on hold for the time being.
This would represent a considerable opportunity cost for traders which would be
unable to trade those species for a prolonged period of time. . The lack of
proportionality was also stressed by a large number of stakeholders consulted,
including pet traders, hunters, sustainable use and landowners' organisations,
who found the idea of a list of IAS of EU concern as more manageable. Of the
three sub-options only sub-option A2 was retained. 58% of the respondents
of the 2012 public consultation were in favour of a list of banned species (See
section 2.1.1 of Annex II).

Operational objective B
- Prevent the unintentional introduction into the EU and unintentional release
(escape) in the environment of IAS by addressing the pathways. There would
be a legal obligation to tackle the pathways of unintentional introduction and
unintentional release (escape) of IAS. The three sub-options identified relate
mainly to the level of EU-level centralisation or decentralisation of the
system:

B1:    the
decision on which measures should be taken to manage the pathways is left
entirely to the Member States

B2:    Member
States can decide what measures to take to tackle pathways, but have an
obligation to share information with the Commission, which may provide advice.

B3:    Member
States draw up measures to tackle pathways but need to have these measures
approved by the Commission.

Sub-option B1 was
discarded for not being as effective as B2. Indeed despite the legal
obligation to manage pathways, it would give no indication or obligation to
inform the Commission of the measures taken, thus maintaining the current
fragmented approach, effectively the status quo or the baseline. As the number
of introductions of IAS is increasing and the proportion of unintentional
introductions is increasing as well, tackling pathways will become increasingly
important in the future. Moreover, as pathways often cross borders, this option
would miss the chance to work towards a more coordinated EU-approach. This lack
of coordination would be corrected by sub-option B3, which requires the
formal approval of the Commission and would thus ensure coordination. However,
sub-option B3 was discarded because of its disproportionate administrative
burden on both the Commission and on Member States. A formal approval
system would imply that the Commission supervise and approve all management
measures which may be diverse across the EU: this would entail staff time,
expertise required as well as management of the process. Also Member States
would face a burden as they would be required to seek approval for each measure
planned. Member States would need to wait for formal approval from the
Commission, which could entail delays and in general a slower, less nimble procedure
with consequent administrative costs.Pathway management is new in the EU and
Member States should be encouraged to explore mechanisms to address pathways.
Adding such layer of administrative burden may act as a deterrent to action
leading to a loss of effectiveness. Of the three sub-options only
sub-option B2 was retained. In this option, the Commission may provide
advice wherever appropriate, thus including a chance for coordination without
adding a disproportionate administrative burden. Within the animal and plant
health regimes, pathway management is organised at the European level.

Operational objective C
- Prevent intentional release of IAS into the environment.

Three sub-options have
been identified to prevent the intentional release of invasive alien species
into the environment:

C1:    The
species on the list of IAS of EU concern (sub-option A2) would also be banned
from release into the environment. Unlisted alien species would face no such
ban.

C2:    The
species on the list of IAS of EU concern (sub-option A2) would also entail a
ban on release into the environment. Unlisted species, however, could be
considered of Member States concern and placed on a national catalogue by
Member States, which would establish a permitting system for the release of
those species in the environment.

C3:    An
additional EU-list of alien species approved for release could be developed
(EU-list of species approved for release), and only those alien species not yet
present that are proven (by risk-assessment) to be non-invasive would be
allowed to be released in the environment.

All of the three options
described here were considered to be effective, to a greater or lesser
degree, in preventing the intentional release of IAS into the environment.
During the consultations there was an agreement that release of IAS into the
environment should be restricted (94% of respondents to 2012 public
consultation, see section 2.1.1 in Annex II), but views diverged as regards the
precautionary approach towards the release of alien species. 69.34% of the
respondents to the 2012 consultation indicated that any release into the
environment should only be allowed if proven harmless or after obtaining a
permit. Pet
traders stressed the importance to focus on restricting release into the environment
(i.e. importance of objective C), minimising the need of a list of IAS of EU
concern that would affect trade (objective A), thus favouring a more
precautionary approach on release in the environment. The forestry and the
renewable energy sector, on the other hand, were not in favour of permitting
requirements or other restrictions to release into the environment, worried
that this would entail a lack of flexibility when it comes to introducing new
species for example for climate change adaptation or for biomass production.
They prefer more emphasis on risk based restrictions to
trade/marketing/transport (i.e. favouring C1). Another element to be taken into
consideration is that Regulation 708/2007 on the use of alien species in
aquaculture adopted the approach of developing a list of species allowed to be
released (approach similar to C3). Given the above elements and given that all
three sub-options were considered to be effective in preventing the
intentional release of IAS into the environment, no sub-option was discarded
at this stage.

Operational objective D
- Early Warning and Rapid Response to prevent the reproduction and spread of
IAS of EU concern. The possibility of eliminating IAS from the
environment before they start reproducing and spreading needs a solid early
warning and alert system. The legislative option would include a notification
obligation for Member States to be distributed to all other Member States. When
it comes to the type of rapid response that detection and notification of a
species on the list of IAS of EU concern would trigger, the following options
were identified:

D1:    The
decision on what rapid response measures should be taken is left entirely to
the Member States.

D2:    Member
States would have an obligation to rapidly act when a newly establishing IAS of
EU concern is found in the environment and they may select the most appropriate
course of action to eradicate, contain or control the species. Member States
would be required to notify the measures taken to the Commission, which may
provide advice.

D3:    Member
States would have an obligation to rapidly eradicate newly establishing IAS of
EU concern detected in the environment. In cases where eradication is
unfeasible or no longer possible, Member States could decide to take other
measures (containment and/or control). Member States should notify such
proposed measures to the Commission and get approval for them before they can
derogate from the rapid eradication obligation.

Sub-option D1 was discarded
because it was not considered as effective as sub-option D2, because of
missing chances for coordinated action and effectively maintaining the current
fragmented approach (similar to sub-option B1). Sub-options D2 and D3 were
retained as they were both considered effective, to a greater or lesser
extent, to meet the objective of preventing the reproduction and spread of IAS.
During the consultations, Member States representatives stressed that an
unconditional eradication obligation would entail disproportionate costs. However,
other organisations, while recognising that an unconditional eradication
obligation may not be practicable, called for eradication to be considered the
preferred options wherever possible.

Operational objective E
- Eliminate, minimise or mitigate damage by managing IAS of EU concern
established in the environment. There would be a legal obligation to
manage the established species, if listed on the list of IAS of EU concern, in
order to eliminate, minimise or mitigate their negative impacts. The three
sub-options identified relate mainly to the level of EU-level centralisation or
decentralisation of the system:

E1:    The
decision on which measures should be taken to manage established IAS of EU
concern is left entirely to the Member States.

E2:    Member
States can decide what measures to take to manage established IAS of EU
concern, but have an obligation to share information with the Commission, which
may provide advice.

E3:    Member
States draw up measures to manage established IAS of EU concern but need to
have these measures approved by the Commission.

Sub-option E1 was
discarded for not being as effective as sub-option E2. It would miss the chance
of coordinated action and effectively maintaining the current fragmented
approach and the status-quo (similar to sub-options B1 and D1). This would be
corrected by sub-option E3, which requires the approval of the
management measures by the Commission and would thus ensure a level of
coordination, although leading to a disproportionate administrative burden on
both the Commission and on Member States (similar to sub-option B3). A formal
approval procedure would requires resources for the Commission to examine all
measures proposed and it would place a burden on Member States that would need
to submit detailed plans to the Commission to explain the measures taken.
Member States would then need to wait for formal approavl before enacting the
proposed measures, thus causing delays in tackling IAS where quick action is
often of essence. This was confirmed by the feedback received during the
consultations preceding the preparation of this Impact Assessment where Member
States representatives considered requiring EU-approval for management as
disproportionate and not respecting subsidiarity, but recognised the need of a
level of EU intervention to ensure that management measures are taken in a
timely fashion and to ensure coordinated action and streamlined efforts at EU
level. Of the three sub-options only sub-option E2 was retained.

Retained sub-options

To
summarise, only 8 of the 15 sub-options described were retained for further
analysis (Table A7). The retained sub-options are the following: A2, B2, C1,
C2, C3, D2, D3 and E2.

Table A7: Five operational objectives with three levels of
intervention each: retained (grey) and discarded (white) sub-options

Objective || Level of ambition and/or EU intervention

Operational objective A - Prevent intentional introduction of IAS of EU concern into the EU || A.1 – list of IAS of EU concern Example: EU Wildlife Trade Regulation || A.2 - list of IAS of EU concern + emergency measures Example: EU Plant health regime || A.3 – all alien species considered to be potentially of EU concern, unless included in an EU list of approved alien species Example: EU Regulation on biocidal products

Operational objective B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || B.1 - Member States manage major pathways || B.2 - Member States manage major pathways, share information and Commission provides guidance || B.3 - Member States manage major pathways, share information and require approval from the Commission

Operational objective C - Prevent intentional release of IAS into the environment || C.1 - IAS of EU concern cannot be released into the environment. || C.2 – no release of IAS of EU concern + permitting system for IAS of Member State concern included in national catalogues || C.3 – no release of any alien species unless included in an EU list of species approved for release into the environment Example: Regulation on alien species in aquaculture

Operational objective D - Early Warning and Rapid Response to prevent reproduction and spread of IAS of EU concern into the environment || D.1 - Member States eradicate, control or contain the IAS of EU concern, no EU intervention || D.2 - Member States rapidly eradicate, control or contain newly establishing IAS of EU concern, share information and Commission provides guidance || D.3 - Member States rapidly eradicate newly establishing IAS of EU concern, share information and require approval from the Commission if they want to resort to control or containment

Operational objective E -Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || E.1 - Member States eradicate, control or contain the IAS of EU concern, no EU intervention || E.2 - Member States eradicate, control or contain IAS of EU concern, share information and Commission provides guidance || E.3 - Member States eradicate, control or contain IAS of EU concern, share information and require approval from the Commission for the measures envisaged

7.
Annex VII: Analysis of costs and benefits of the
proposed measures

This Annex provides more
details on the costs and benefits of the retained sub-options compared to the
baseline option (Table A8). The distributional impacts of legislative action on
IAS are also briefly discussed.

The retained sub-options
were combined in a basic legislative instrument, representing the minimum level
of EU intervention, including components A2, B2, C1, D2 and E2 (see Table A8).
However, each component has been examined individually and the impacts of the
two implementing mechanisms – a standing committee and a centralised
information system – were included in the discussion.

When it comes to release
into the environment (operational objective C) the basic legislative
instrument could be made more stringent, by increasing its ambition and
strengthening the level of EU intervention:

·
either
by introducing provisions on permits for release of IAS of Member State concern
(add-on C2)

·
or
by introducing an EU list of species approved for release (add-on C3)

When it comes to early
warning and rapid response (operational objective D), the basic legislative
instrument could be made more stringent and ambitious with a higher level of EU
intervention:

·
by
introducing the obligation for Member States to eradicate newly establishing
IAS, unless a derogation was granted by the Commission (alternative action D3)

These three more
ambitious elements described were also analysed but separately.

Table A8: Sub-options
retained after initial screening and for which the in depth analysis will
follow (basic legislative instrument in grey, optional add-ons in white):

Objective || Level of ambition and/or EU intervention

Operational objective A - Prevent intentional introduction of IAS of EU concern into the EU || || A.2 - list of IAS of EU concern + emergency measures Example: EU Plant health regime ||

Operational objective B - Prevent unintentional introduction of IAS into the EU and unintentional release into the environment || || B.2 - Member States manage major pathways, share information and Commission provides guidance ||

Operational objective C - Prevent intentional release of IAS into the environment || C.1 - IAS of EU concern cannot be released into the environment. || C.2 – no release of IAS of EU concern + permitting system for IAS of Member State concern included in national catalogues || C.3 – no release of any alien species unless included in an EU list of species approved for release into the environment Example: Regulation on alien species in aquaculture

Operational objective D - Early Warning and Rapid Response to prevent reproduction and spread of IAS of EU concern into the environment || || D.2 - Member States rapidly eradicate, control or contain newly establishing IAS of EU concern, share information and Commission provides guidance || D.3 - Member States rapidly eradicate newly establishing IAS of EU concern, share information and require approval from the Commission if they want to resort to control or containment

Operational objective E -Eliminate, minimise or mitigate damage by managing IAS of EU concern established in the environment || || E.2 - Member States eradicate, control or contain IAS of EU concern, share information and Commission provides guidance ||

The analysis of the
costs and benefits of the different components has encountered several
difficulties:

·
It
is not possible to predict how many and what sort of invasions will need to be
tackled

·
It
is not possible to predict which invasive alien species will establish, invade
and require management

·
It
is not possible to predict the damage they will cause over the years to come.

·
It
is not yet known which and how many species will be listed as IAS of EU
concern.

To overcome some of
these difficulties for the analysis, the SEBI-list of IAS[197]
was used as a reference. This should in not be interpreted as an indication
that the SEBI-list will be adopted as list of IAS of EU concern, but rather as
an exercise to make the assessment of the impacts more concrete. The SEBI-list
contains 167 IAS threatening biodiversity in Europe, recognised as being
particularly harmful.

The assessment would
have been facilitated had more data been available, but until recently,
large-scale and comprehensive economic studies on IAS in general have been rare[198]:
it has often been necessary to reply on studies focusing on specific IAS.

7.1.
Distributional
impacts

7.1.1.
Member
States

Invasive alien species
can be plants, animals or other organisms, belonging to any taxon. This diverse
group will have different impacts and consequences depending on several
environmental and ecological factors. This means that while many IAS are
causing impacts EU-wide, other species are only problematic in certain regions,
or under certain ecological and climatic conditions, creating a complex mosaic
in the EU.

Because of the
complexity of the picture and the impossibility to predict how many new
invasions may occur in time, it is impossible to quantify the exact nature of
the distributional impacts in the EU. At any given moment, a certain IAS may
affect certain Member States more than it does others, but in other cases other
Member States would be affected by a different IAS. So if we consider a single
IAS, the impacts will be different in different areas, but if we consider the
problem has a whole, i.e. all of the IAS that are established and spread or
that may invade in the future, all Member States will be affected albeit
perhaps in different moments, and by different species. It can be
assumed that countries with higher trade volumes and numerous entry points are
likely to suffer more introductions of IAS. It is not possible to ascertain the
magnitude or concentration of intra-EU movements as there are no internal
checks for commodities or monitoring of aliens species moving in the wild
across the borders. Overall, therefore, it was found that given the variety of
distributional impacts that characterise this issue, it was not possible to
note particularly strong imbalances between different regions or Member States.
It is also to be considered that where countries may suffer more from certain
species, they will face a larger burden in terms of action to be taken, but
would also be the ones benefitting more from an EU approach to the issue.

Certain species are
problematic in warmer areas of the EU and cannot establish or spread in such a
way to cause a problem in northern parts of the EU, such as the prickly pear
cactus, the silver wattle, the Asian tiger mosquito. On the other hand other
species are problematic in northern Europe, but not for countries in southern
Europe protected by ecological barriers, such as the Alps or the Pyrenees, such
as the giant hogweed.

Furthermore, islands are
likely to be more vulnerable to invasive alien species due to their small size,
isolated evolution and fragility. Species whose impact may be mitigated in the
mainland may exert enormous pressure on native species on islands.

As regards the impact of
the proposed legislation, Member States will be at times victims of an invasion
and would benefit from action taken by other Member States. However, in other
occasions, the same Member States may be called to take actions for the benefit
of other Member States. Besides the geographic and climatic conditions, the
impacts of legislation will also vary depending on the nature and structure of
Member States' economies and businesses.

Depending on what
species will be considered as IAS of EU concern, some sectors may be impacted
negatively or, on the contrary benefit, from the proposed measures. Assuming
that an IAS important for the horticultural sector were banned from the EU,
this would have more of an impact in countries with a thriving horticultural
sector. On the contrary certain countries may benefit from EU action on certain
IAS: assuming that one IAS very detrimental to the forestry sector were banned,
then the benefit would be felt particularly strongly by those Member States
with a stronger forestry sector.

It was therefore
impossible to detect any particularly strong imbalances in the burden, or in
the benefits, that the proposed measures would bring about.

7.1.2.
SMEs
and microenterprises

IAS affect businesses,
including SMEs and micro enterprises.

In particular, primary
producers in agriculture, animal husbandry, fisheries, aquaculture and forestry
are often affected by IAS and suffer considerable economic damage. For example,
coypu causes crop losses and disruption to irrigation systems to agricultural
crops, while black cherry negatively impacts forestry by hindering the natural
regeneration of trees and impeding forest management measures. Businesses
linked to tourism and recreational activities, which rely on pristine
landscapes, clean water bodies and healthy ecosystems are often also affected.
For example, water hyacinth creates dense floating mats on water bodies,
interfering with recreational activities, such as boating or fishing. These
businesses are currently suffering from the lack of coordinated action on
IAS and would thus benefit from legislation

In addition, these
businesses are burdened by the management costs of keeping damaging IAS in
check, although the majority of these costs are usually faced by the public
authorities.

On the other hand, other
SMEs, such as pet traders and the horticultural sector, draw benefits
from IAS as they focus largely on alien species trade and may be negatively
impacted by certain measures proposed that could put restrictions on the import
and sale of certain species.

Despite significant
efforts, through contacts with the sectors involved and research, the data
found on the structure of these sectors were scarce. From consultations with
stakeholders, however, it was possible to infer that the sectors with a
commercial interest in certain alien species are likely to include several
retailers (thought to include several microenterprises) trading alien species
directly with the public and sourcing their products from larger players,
importing such species into the EU. The larger players are thought to be a
heterogeneous group, including a proportion of SMEs. Some of the proposed
measures would be relevant to these larger players, rather than to the
microenterprises in the retail sector.

The Commission is
concerned about the impact of legislation on small and microenterprises and has
a policy of minimising the burden on these businesses; however, they would be
expected to fall under the scope of the legislation.

Indeed, trade in pets
and horticultural species are important pathways of introduction of IAS and
excluding these players would undermine the effectiveness of the instrument in
achieving the proposed goals. The system envisaged, however, focuses only on
invasive alien species - and primarily on those listed as IAS of EU concern -
and it also caters for some flexibility to tackle these sectors, while keeping
the impact on small and microenterprises to a minimum.

7.2.
The
basic legislative instrument

7.2.1.
Calculation
of costs

In order to compare the
cost of the basic legislative instrument with the baseline option (option 0),
the cost of the latter is summarised in Table A9.

Table A9:
Estimated cost of action for options 0 and 1[199], based in so
far as possible on current expenditure

|| Cost per Member State || Costs by others || Total cost || Expected trend in costs

A - Risk Assessments || €117,900/yr/MS[200] || 0 || €3 mio/yr || =

B - Pathway management || Few initiatives, primarily raising awareness || Ballast water treatment: € 109 mio/yr[201] Biofouling treatment: min. €13,700/vessel/event[202] || Ballast water treatment: € 109 mio/yr[203] || ↑↑ When Ballast Water Convention enters into force ↓↓ as the technologies for ballast water treatment evolve and become more efficient and cheaper

C - Release into the environment || Existing systems, difficult to quantify || Existing burden difficult to quantify || No quantification || =

D – Surveillance || €260,000/yr/MS[204] || EEA: Nature Watch - pilot project on IAS || €7 mio/yr || =

D - Rapid eradication || Variety of costs[205]: €1.309 bio/yr[206] (see Annex VII) || €1.309 bio/yr || =

E - Management of IAS || ↑↑ (see 2.5)

Information system || €122,000/yr/MS[207] NOBANIS: €120,000-140,000/year[208] || JRC: €230,000/year[209] || €3.4 mio/yr[210] || =

Policy management || Strategy development, policy development and coordination and policy support (studies): €74,000/year || 0 || €2 mio/yr || =

TOTAL || € 1.433 bio/yr || ↑↑

The cost of the current
management measures (including rows D and E of Table A9) has been calculated
following the steps described below:

1. Table A10
gives an overview of the current costs of management of certain IAS in EU
Member States.

2. On the basis
of the information collected by Table A10, an average current cost of
management per group of IAS was estimated (see first column Table A10)

3. On the basis
of Table A6 (Annex V), which summarises the IAS on which Member States are
taking action at the national level, the number of Member States addressing
each IAS was counted and species were grouped according to taxon. The number of
Member States, acting on each IAS, was summed up for every group of species.
Finally, these figures were multiplied by the average current cost of
management (last column of Table A11).

4. The results
(number of Member States acting on species belonging to a group multiplied by
the average current cost of management) were summed, and this provided a rough
estimate of the current cost of management by the Member States in the EU: €
1.309 billion/year. This is an underestimate as many very local measures on IAS
are not included (e.g. municipalities and NGOs).

Table A10: Cost of
management measures under the policy baseline (option 0)

IAS managed by Member States Estimated average management cost/IAS/MS/year || Available management costs

Mammals €1 million/IAS/MS/year || -Italy - coypu (1995-2000) - removal of over 220,000 coypus: €2.6 million (Bertolino, 2009) -UK – coypu eradication: €5 mio/11 yrs (Baker, 2006) -Germany - muskrat: €4 million/year (Reinhardt et al., 2003) -Wallonia - muskrat: €0.7 million/year (Sonigo et al., 2011) -Germany - American mink: €5 million/year (Reinhardt et al., 2003)

Birds €1 million/IAS/MS/year || - UK - ruddy duck eradication: €4.4 mio/5 yrs (Shine et al. 2010)

Amphibians €1 million/IAS/MS/year || -UK - American bullfrog eradication:  €36,000 (Lorvelec and Détaint 2009)

Aquatic organisms €3 million/IAS/MS/year || - UK - crayfish in the UK: €3.3 mio/year (Williams et al., 2010)

Aquatic weeds €4 million/IAS/MS/year || -Great Britain - New Zealand pigmyweed: €1.45 to 3 million over a period of 2-3 years (Leach and Dawson, 1999) -Great Britain - IAS in waterways: €24.5 million/year (Williams et al., 2010) -Netherlands - floating pennyworth: €2-4 million/year (van der Wijden et al., 2007) -Flanders - invasive alien aquatic plants: €1 million/year for 108 km of river (Van Gossum, pers. comm.) -Spain - removing water hyacinth from the Guadiana river (for around 75 km of river): €14.7 million for 2005 to 2008 (EPPO, 2008)

Trees €5 million/IAS/MS/year || Management cost of black cherry -Germany: €3.4 million/year for tree removal in conservation areas and €20.7 million/year for Management measures in forestry (Reinhardt et al., 2003) -Flanders: 4.6 million (1994-2010) for Management measures in forestry (Buysse, 2012)

Shrubs €5 million/IAS/MS/year || -Germany: €6.2 million/year (Reinhardt et al., 2003)

Other plants €5 million/IAS/MS/year || Costs of hogweed management: -Germany: €12 million/year (Reinhardt et al., 2003) -Denmark: €3.25 million/year + 39,900 working hours (IEEP, 2009) -Latvia: up to €3.5 million/year; Great Britain: €1.1 million/year; Wallonia: €0.5 million/year; Estonia: €472,000/year (Sonigo et al. 2011) Costs of ragweed control: -EU: €179 million/year (Bullock, 2012)

Table A11:
Assessment of total current management cost

|| Average management costs for  type of species/year/MS || Number of species of a certain taxa currently subject to management measures in EU27 || Sum of Member States acting on that type of species || Current expenditure on management per taxa for EU27 in €/year

Mammals || €1 million || 30 mammals || 104 MS || 104 million

Birds || €1 million || 17 birds || 32 MS || 32 million

Amphibians and reptiles || €1 million || 11 amphibians or reptiles || 35 MS || 35 million

Aquatic organisms || €3 million || 41 aquatic organisms || 73 MS || 219 million

Aquatic weeds || €4 million || 22 Aquatic weeds || 41 MS || 164 million

Plants (including trees) || €5 million || 52 plants || 151 MS || 755 million

TOTAL Management cost for all IAS (except terrestrial invertebrates) || || || || 1.309 billion

After having estimated
the costs of the baseline option, Table A12 provides an overview of the
additional costs that the basic legislative instrument (option 2) would entail.

Table A12: Costs of the basic legislative instrument and add-ons (option
2) in comparison with options 0 and 1 (+ stands for additional costs, = stands
for no extra costs)

|| Options 0 and 1 || Option 2: Changes in comparison to options 0 and 1 || Option 2

Member States || Economic operators || European Commission

A – List of IAS of EU concern || 0 || See policy management (see second last row below) || Opportunity costs (see 6.2.1) || See policy management (see second last row below) || Opportunity costs

A - Risk assessments || €3 mio[211]/year || From €3 mio to €1.4 mio/year [212] SAVING: €1.6 mio/year || 0 || C3: See policy management (see 6.2.1) || €1.4 mio/year C3: additional administrative costs

A - Border control on intentional introductions || 0 || Limited operational costs[213], thanks to integration in current controls on live animals and plants for planting (see 6.2.1) || 0 || 0 || Limited operational costs

B - Pathway management, incl. border control on unintentional introductions || Ballast water treatment: € 109 mio/yr[214] || + €26 mio/yr[215] + € 0.5mio/yr[216], optionally + €14.6 mio[217]/yr or even more (over time) || Operational costs (traders and transporters, see 6.2.1) || See policy management || €135.5 to 150.1 mio/year,  or possibly more (over time)

C - Release into the environment || Existing systems, difficult to quantify || C2: Permitting system (see 6.2.1): +€100,000-1mio/yr[218] || Opportunity costs (producers, see 6.2.1) C2: + C3: ++ || C3: Managing EU list of species approved for release (see 6.2.1) || Administrative and opportunity costs C2: additional administrative costs: +€100,000-1mio/yr C3: significant additional administrative and opportunity costs

D - Surveillance || €7 mio[219]/year || = || = || = || €7 mio/year

D – Rapid eradication || €1.309 bio/year[220] || Shift from ad hoc reactive to targeted rapid response approach, cost expected to decrease over time D3: stronger shift to rapid eradication  (see 6.2.1) || Ad hoc management costs, difficult to estimate || Coordination and risk-based prioritisation of current support || Current management costs will decrease over time:  €1.309 bio/year could decrease to € 0.922 bio/yr[221] D3: stronger shift to rapid eradication

E - Management of IAS

Information system || €3.4 mio[222]/year || Expected to decrease over time as EU-system develops || 0 || + €170,000[223]/year, expected to increase over time || €3.6 mio/year

Policy management || €2 mio[224]/year || = || 0 || + €80,000[225]/year (steering group) Managing list of IAS of EU concern || €2.1 mio/year

TOTAL || €1.433 bio/yr || || || || €1.459-1.473 bio/yr, expected to decrease to 1.072-1.086 bio/yr C2: +€100,000-1mio/yr C3: ++ D3: +

7.2.2.
Calculation
of benefits

A quantification of the
benefits of the legislative package is very difficult as the benefits – or the
avoided costs – will depend on which invasive alien species will threaten the
EU and will, through legislation, be prevented from entering, spreading and
causing excessive damage. If the proposed legislation prevented 30 invasions
similar to the current 30 invasions most addressed by the Member States, as
described in Table A13 (based on Table A6 in Annex V), and using as a proxy of
the damage caused, the data on damage of the species listed in Table 3, section
2.3 of the main text, it was estimated that the avoided damage costs would
amount to €3.86 billion/year, with an average of €130 million/IAS/year[226],
a
rough figure which can nevertheless provide an estimation of the order or
magnitude of avoided damage. This means that, assuming a rather stable cost
of action, the avoided costs would cumulate as every year more invasions would
be prevented: avoiding €0.5 billion per year in the long term after preventing
4 IAS in year 1, avoiding €1 billion per year in the long term after preventing
an additional 4 IAS in year 2, €1.5 billion per year in the long term after
preventing another 4 IAS in year 3, €2 billion per year in the long term after
preventing another 4 IAS in year 4, etc

Table A13: Assessment of
avoided damage under the legislative option (option 2), assuming future similar
invasions of new IAS would be prevented

IAS Management led by more than 4 MS (number of MS acting) || Available damage costs || Assessment of damage cost assuming future similar invasions of new IAS

Mammals: American mink (12), raccoon dog (11), muskrat (10), rat (8) , raccoon (6), coypu (6), fallow deer (5), North American beaver (4), wild rabbit (4), mouflon (4) || American mink: predates free ranging chickens, reared game birds, farmed salmon Germany: €4.2  million/year (Bonesi, 2009) Musk rat: undermines riverbanks, railroads, dams and fences, irrigation structures and aquaculture + transmits echinococcosis Netherlands: €23 million/year (Van der Wijden et al., 2007) Germany: additional expenditure for waterway maintenance €2.3 million/year (Reinhardt et al. 2003) and for maintenance of aquaculture facilities €1.6 million/year Public health: Germany: medical treatment costs of €4.6 million/year (Reinhardt et al., 2003) Coypu: undermines river banks and increases the risk and severity of floods Italy: exceeded €10 million riverbank damage and exceeded €0.9 million impact on agriculture (Bertolino, 2009) || Assuming an average damage of €5 million/year/IAS/MS Total: €350  million/year

Birds: ruddy duck (WTR), Canada goose (5) || Canada goose: displaces native waterfowl, causes habitat modification, disturbs ecosystem functioning Ruddy duck: threatens white-headed duck through hybridisation || Total: more native species would be threatened

Amphibians: American bullfrog (WTR), common slider (5) || American bullfrog: feeds excessively on many native species || Total:  more native species would be threatened

Aquatic organisms: signal crayfish (7), zebra mussel (4), red swamp crayfish (4), stone moroko (4) || Comb jelly: drastic decline in pelagic fish catch Black sea: several €100 million in total (Shiganova and Panov, 2009) Zebra mussel: interference with fishing gear, alteration of fish communities, fouling aquaculture equipment, clogging water intake pipes, fouling the ship hulls and navigational constructions, sharp shells cause injuries North America: annual multimillion losses (Zaiko and Olenin, 2009) US and Canadian water users: €370 million/year (Millennium Ecosystems Assessment, 2005) || Assuming an average cost of €10 million/year/IAS/MS Total: €190  million/year

Insects || Tiger mosquito: vector of at least 22 arboviruses including Chikungunya and Dengue, often fatal to children Harlequin ladybird: displaces native ladybirds, causes decline in native biodiversity, could impact on the resilience of ecosystems and severely diminish the services they deliver (Roy et al. 2012) || Total: more fatalities and more native species would be threatened

Aquatic weeds: primrose (6), pennywort (4), parrot feather (4) || Blocking canals and rivers, affecting transport, drainage, recreation, biodiversity, angling. || Total: more disturbances

Trees: tree of heaven (6), black cherry (4) || Black cherry: hinders natural regeneration of trees, impedes forest management measures such as thinning, timber harvesting or planting Germany: additional expenditures for thinning and timber harvesting at least €1.4 million/year, manifest additional expenses for planting not included (Reinhardt et al. 2003) || Assuming an average cost of €2 million/year/IAS/MS Total: €20  million/year

Shrubs: Japanese knotweed (10) || Japanese knotweed: leads to loss of property value, refusal of mortgages Great Britain: €205 million/year (Williams et al., 2010) Germany: €7 million/year for embankment repair and €16.7 million/year for embankment reinforcement || Assuming an average cost of €20 million/year/IAS/MS Total: €200  million/year

Other plants: hogweed (15), Himalayan balsam (11), ragweed (8), iceplant (6), goldenrod (6), pampas grass (4), Jerusalem artichoke (4), Japanese rose (4), cord grass (4) || Ragweed: yield reduction (its resistance to herbicides and the germination capacity of its seeds of more than 30 years makes it difficult to control) + allergic asthma and allergic rhinitis Hungary: yield losses of €130 million/year (Kőmíves et al. 2006) Germany: medical costs (prescribed medication) of €17-47 million/year (Reinhardt et al., 2003) EU: agricultural damage of €1.302 to 3.307 billion/year, medical costs of €118 to 763 million/year and workforce productivity loss of €0.049 to 1.361 billion/year: TOTAL: 1.469 to 5.431 billion/year (Bullock 2012) Giant hogweed: severe skin burning, tens of thousands of people affected every year, in the worst case being fatal Germany: medical treatment costs of €1 million/year (Reinhardt et al., 2003) || Assuming an average cost of €50 million/year/IAS/MS Total: €3.1  billion/year

TOTAL || || Total: €3.86  billion/year

7.2.3.
Introduction
of a single list of invasive alien species of EU concern, banned from
trade/import/marketing/transport (component A2) and banned from being released
into the environment (component C1)

This list would include
alien species proven to be invasive by risk assessment[227]
based on criteria that would include environmental as well as socio-economic
considerations.  Risk assessments would continue to be performed, as it
is the case presently, by Member States, consortia of Member States or other
organisations (e.g. EPPO[228]).
However, a technical process would be established with Member States to decide
on minimum standards to perform those risk assessments, in order to ensure
sufficient coherence for them to be mutually recognized among Member States.

The validation would be
done via a dedicated Standing Committee or expert group, which will be
assisting the Commission in developing the list of IAS of EU concern and
keeping it up-to-date. Once a species is listed this would trigger a complete
ban throughout the EU, including from trade/marketing./transport/holding and
release into the environment. For unlisted species and when the risk has not
yet been assessed emergency trade bans could be established, while a risk
assessment is being performed, similar to the provisions of the plant health
regime. This provisional ban would be subject to the available evidence and
periodic review. The introduction of a single list of IAS of EU concern,
triggering EU-wide bans and obligations will have costs as well as benefits.

Member States and public
authorities

When it comes to public
authorities the list will be beneficial in that it provides a harmonised
and transparent approach to managing IAS at EU level. This will first and
foremost avoid efforts being undermined by lack of action in neighbouring
countries. For example, the Walloon region of Belgium is attempting to
eradicate giant hogweed with a budget of €0.5 million/year. At the same time
France is taking no action on this invasive alien plant, with a high
probability of reinvasion in the Walloon region.

Furthermore, Member
States are currently applying a variety of bans on import, trade and/or
marketing of IAS that have already been established in 13 Member States,
creating a regulatory patchwork. The single list of IAS of EU concern would
enable uniform conditions across the EU, thus ensuring the effectiveness of
actions taken and arming the Member States that have not yet undertaken similar
bans with a new tool to combat invasive alien species.

Currently, risk
assessments are performed in an isolated manner by Member States. Current
expenditure on risk assessment is estimated to range from €10,000 to 225,000 a
year per Member State, with an average of €117,900 a year per Member State[229]. That
represents a total current expenditure, mainly for the public authorities, of
€3 million/year for the EU[230]
on species risk assessments. A harmonised way of listing would facilitate
prioritisation and coordination of the work on risk assessments, thus avoiding
duplication and leading to economies of scale as there would be an incentive
for Member States to develop risk assessments in consortia with other Member
States. EPPO has concluded 9 risks assessments on invasive alien plants
and based on its estimates, it was calculated that risks-assessments costs
around €42,000 per assessment[231].
If in the next five years, risk assessments were carried out for 167
species, taking the size of the SEBI list as reference, at a pace of 33 species
per year, this would cost approximately €1.4 million/year. Compared to
the current expenditure of €3 million/year in the EU, a harmonised system would
bring about €1.6 million/year of cost savings in total and considerably
reduce the administrative burden involved in the elaboration of these
assessments.

There is
currently no dedicated standing committee. Based on costs of existing
similar structures supporting the implementation of the Wildlife Trade
Regulation, a dedicated structure could cost the European Commission
around €80,000/year, assuming three yearly meetings. This Committee would decide upon
the listing or unlisting of species and on emergency measures and provide
guidance on the implementation of the IAS-policy in Member States.

To avoid intentional
introductions in the EU, border controls on IAS of EU concern will have
to be performed. To maximise synergies and avoid the creations of parallel
systems, border controls on the intentional introduction of species would be
integrated within existing systems. At Designated Entry Points, border controls
for live animals and plants are being carried out in support of animal and
plant health[232].
Checks to establish whether the imported plants or animals are banned by the
IAS legislation could be performed at the same entry points. The Food Chain
Evaluation Consortium (2011) estimated that the cost of adding border control
on IAS-plants to the current plant health checks to be negligible, as no
adaptation to current practices is required (e.g. no special detection methods or
diagnostics required, visual inspection of trained and informed inspectors
appears to be sufficient). It seems reasonable to assume that this will also be
the case for IAS-animals. Moderate extra costs would include special training
to enable designated entry points staff to detect IAS. Other border controls
would occur at any EU entry point to detect other intentional and unlawful
introductions of banned species. This would be carried out by the customs
authorities. Also in this case there would be a need to develop trainings and
guidelines on how to spot hidden IAS or on risk profiling. Moreover,
cooperation agreements would be put in place to ensure taxonomic expertise from
the IAS competent authority could be provided to customs when needed. Once inside
the EU, IAS of EU concern would be traced through surveillance.

To support
the measures proposed, Member States would be required to share information
with the EU and with the other Member States through a centralised
repository of information, which could be gradually built up on the basis
of existing systems. There is currently a variety of information
systems in place at the international, EU, regional and Member States
level. The average
Member
States’ current expenditure, on collecting (excluding on surveillance on the
ground), managing and sharing information, amounts to €120,000/year per Member
State (roughly €3 million/year in total)[233] and on top of this
some Member States are already investing in a common early warning system
NOBANIS, while the Joint Research Centre is working on the integration of
information on IAS in Europe. Developing a central repository within the work
presently undertaken would lead to a certain shift in costs from Member
States to the EU, but costs are not expected to increase substantially.

Besides the benefits of
a uniform approach, which would support the effectiveness of the actions
proposed, public authorities will benefit substantially in terms of damage
and cost avoidance. Some example to illustrate the large savings that could
be made through cost avoidance are provided in Table A14. The scheme would lead
to a reduced likelihood of invasive alien species establishing and spreading
into the environment, causing substantial environmental, economic and social
damage. This would also allow Member States to contribute to the EU
biodiversity targets, by preventing the entry into the EU of species known to
have detrimental effects on biodiversity and ecosystem services. It would also
contribute to the achievement of the environmental objectives of several EU
pieces of legislation such as the Habitats and Birds Directive, the Water
Framework Directive and the Marine Strategy Framework Directive.  When it comes
to the damage on society, some IAS are recognised as having a very significant
negative effect on public health. Member States will benefit as a ban on
such species would avoid extra strain being placed on their public health
systems – besides being beneficial for the well-being of citizens - as the most
hazardous species would be banned uniformly across the EU. For example, a
uniform approach across the EU could help in preventing the entry into the EU
of parthenium weed, which is native to the subtropics of North and South
America. This species, still absent in the EU, has established in Australia,
US, India, Ethiopia and several other countries, including Israel. All other
Mediterranean countries are considered at risk from this plant. Besides causing
major negative impacts on pastures and crops, this species can produce serious
allergenic reactions, such as dermatitis, hay fever and asthma in humans and
livestock (horses in particular)[234].

Table A14: Damage costs which could be avoided or reduced
with effective preventive actions

Aquatic plants || Blocks waterways: Management of New Zealand pigmyweed in Great Britain has cost EUR 1.45 to 3 million over a period of 2-3 years (Leach and Dawson, 1999), management of IAS in waterways costs EUR 24.5 million/year in Great Britain (Williams et al., 2010), management of floating pennyworth in the Netherlands is costing EUR 2-4 million/year (van der Wijden et al., 2007), Flanders is spending approximately EUR 1 million/year on the management of invasive alien aquatic plants (Sonigo et al., 2011), in Spain, removing water hyacinth from the Guadiana river (for around 75 km of river) was EUR 14.7 million for 2005 to 2008 (EPPO, 2008)

Japanese knotweed (most of the EU) || Damages construction and infrastructure: costs EUR 205 million per year to the British economy (Williams et al., 2010) and between EUR 24 and 46 million/year in Germany

Coypu (most of the EU) || Damages river banks and increases the risk and severity of floods in many central and southern European countries: in Italy (1995-2000), the removal of over 220,000 coypus cost EUR 2.6 million whilst riverbank damage exceeded EUR 10 million and impact on agriculture exceeded 0.9 million (Bertolino, 2009)

Musk rat (most of the EU) || Damages riverbanks, railroads, dams and fences, irrigation structures and aquaculture: in the Netherlands causing damage of EUR 23 million/year (Van der Wijden et al., 2007), Wallonia is spending EUR 0.7 million per year on the management of musk rat (Sonigo et al., 2011), in Germany, annual damage costs are estimated at EUR 12.4 million (Genovesi, 2009)

International
and intra-EU trade

The introduction of a
single list of IAS of EU concern could negatively affect import volumes,
as it would ban certain species from being traded and exported by some third
countries. This disruption was, however, not considered excessively negative
as, according to the input from stakeholders, including traders, the type
of species likely to be listed would a) not necessarily be in trade, b) some of
the species are traded in relatively small volumes, and b) several of the
species trade, with few exceptions, would not be highly valuable commodities.
Furthermore, the introduction of a single list of IAS of EU concern would have
the advantage of being underpinned by risk assessment, based on minimum EU
standards, and thus be fully WTO and SPS agreement compatible. The
system will thus be harmonised and transparent, fully in line with the systems
regulating the plant and animal health regimes and not unfamiliar to the EU
trading partners.

Furthermore, the list of
IAS of EU concern would ensure the smooth functioning of the internal market
by setting a harmonised and transparent approach to risk assessment,
representing a substantial improvement compared to the current situation where
Member States are introducing non harmonised trade/marketing/transport bans.
This would also provide legal certainty to users and traders on alien species.

Users/traders
and breeders/primary producers

Because certain species
may be banned for trade, marketing, holding, as well as being banned from
release into the environment, some traders, users of IAS and primary
producers - forestry, agriculture, animal husbandry and aquaculture - will
be affected and may bear some economic losses, at least until a suitable
substitute species is found. For most of the species, it is thought that
non-invasive or native substitute species would be readily available, with some
exceptions. However, for some other cases such as scientific research
or ex-situ conservation, substitution may not be an option. For those cases
where an overriding interest is demonstrated, a system of derogation with a
permit (safety conditions to avoid release into the environment) could be
envisaged. This would entail some administrative burden in terms of permitting
requirements but may allow researchers in the EU to be allowed to use the
necessary species for their research.

As regards the sectors
of forestry and agriculture, the banning of certain species in the EU
may have a negative impact, although based on an assessment of the species
included in the SEBI list, it was estimated that this impact should remain
moderate. No species of agricultural interest was identified in the SEBI-list
and only one species with forestry interest was identified therein (black
locust).

When it comes to traders
and breeders/growers of ornamental species, the situation vary according to
the nature of those ornamental species trade. Taking the SEBI-list as
reference, out of the 167 species, according to information provided by the
European Pet Organisation, the Sustainable Users Network, an organisation with
close links to the pets and ornamental species industry, and Ornamental Fish
International (OFI), there are 27 animals traded, including two fish: the
sunfish and the koi. Moreover, according to information collected through the
horticultural industry, the SEBI list includes 11 plants which are used for
horticultural purposes. This means that 38 species out of 167 have a commercial
interest, that is around 25%.

As regards trade in
pets, the impact of banning trade, sale and holding of certain species is not
easily quantifiable, nevertheless, thanks to qualitative information provided
by the European Pet Organisation (EPO) it is possible to assess that a trade
ban on certain species may indeed affect the sector. Nevertheless, the majority
of the pet species in the SEBI-list are bred inside the EU in relatively
low volumes by hobbyists and are rarely imported. Thus the disruption to
international trade of these species would be limited. Furthermore, EPO
clarified that these species rarely even enter the regular pet trade, but are
rather exchanged by hobbyists: quantities of such species in retail trade have
been reported by EPO as negligible, except for turtles, clawed toad and
ring-necked parakeet, which are commonly sold in pet shops. However, the
assessment in the previous paragraph shows that roughly 75% of the species in
the SEBI-list would rather be introduced in the EU without commercial
intentions and their ban would thus not bring about losses for the economic sectors.

Most of the traded
species in the SEBI-list are not very high value commodities with two
exceptions: the koi and the American mink. According to EPO, the koi represents
an industry worth tens of millions of euro with millions of specimens being imported,
which creates employment. A ban on such species would have a very negative
effect on the industry. EPO also stressed that the likelihood of koi being
released or escaping is unlikely given these are valuable specimens, which
suggests that continuing trade and keeping may be justified. The American
mink is reared for its fur and it accounts for 92% of the stock of fur
farmed animals in Europe. American minks are high value animals are meant to be
kept in captivity but there have been and continue to be incidents with large
numbers of American minks being illegally released into the environment.
American mink negatively impacts free ranging chickens, reared game birds,
salmon farming and the eco-tourism industry, through predation on ground
nesting birds. Damage by American mink in Germany alone is estimated to be €4.2
million euro a year[235].
However, a ban on the mink or similar species with a high economic value could
have a serious economic impact on a sector which produces pelts for a
value of around €1.5 billion euro a year[236], with Denmark being
the biggest producers of mink furs in the world, followed by the Netherlands.
This would also lead to a negative effect on employment: there are 7,200 fur-farmers
in the EU, and this generates up to 60,000 full-time jobs[237]. All these
environmental and economic aspects will need to be duly taken into account by
the policy-makers when establishing the list of IAS of EU concern.

Worth mentioning is also
the case of some plants used for biomass production which usually are
selected for their fast growth and adaptability, characteristics that can make
an alien species invasive. This is particularly the case of black locust,
which, besides being appreciated in soil rehabilitation for its pioneer
characteristics and nitrogen fixing capacity, produces wood which is much
appreciated for its hardness, durability and resistance to rot, as well as
having high energy content. This was, however, the only species with a forestry
commercial interest that was identified in the SEBI list. As the situation
stand, disruption to trade, and hence profitability and employment, would seem
to be limited when it comes to biomass and energy production.

When it comes to the horticultural
sector, the situation may be somewhat different as their business relies
substantially on trading, growing, marketing ornamental plants, which are often
alien to Europe and are intended to be planted in gardens and parks, with the
consequences that seeds can spread and the plant species may establish and spread
into the environment. It is not simple to quantify the impacts to the
horticultural sector, but an example from Belgium may be useful. According to
the Alter-IAS project[238],
53% of the IAS-plants present in Belgium is offered for sale in the
horticultural sector and 93% is available in nurseries. Thus a ban on certain
invasive plant species would have a negative impact on the horticultural
sector. However, when the economic value of the single species was considered,
it was found that only a minority of the nursery owners considered some of
those species as species of economic value (see Figure A4). Furthermore,
alternative plant species are readily available[239],
including native species and therefore the impact on these businesses, and the
employment they generate, is estimated to be fairly moderate.

Figure A4: IAS-plants
considered of economic value by nursery owners in Belgium (Halford et al.
2011).

The aquaculture sector
is already addressed by Regulation 708/2007 on the use of alien and locally
absent species in aquaculture and will not, therefore, be further discussed
here.

In conclusion, given
that some few species have a high economic interest, it can be expected that
the economic value benefits of alien species will also be assessed, were such
species to be considered for inclusion in the single list of IAS of EU concern.

However, it needs to be
highlighted that in particular these sectors (forestry, agriculture,
animal husbandry and aquaculture) are the ones which are going to be benefitting
the most from a harmonised EU approach to the introduction of IAS given the
losses they suffer from IAS invasions. That is the case for instance of a
highly invasive alien plant, black cherry that negatively impacts cultivations
and that is already causing damage and management costs in the EU forestry
sector. The table below (Table A15) shows some examples of the damage and
management costs that certain species may entail for primary producers.

Table A15:
damage and management costs of certain species

Black cherry (present in most of the EU) || Forestry sector and biodiversity: Hinders natural regeneration of trees, impedes forest management measures such as thinning, timber harvesting or planting: overall loss to the German economy through yield reduction and management costs was estimated at 25 million euro per year (Reinhardt et al. 2003), a similar figure was estimated for the Netherlands (Olsthoorn and van Hees 2002), various management methods cost between 150 and 1,500 euro per ha per year (Spaeth et al. 1994) (Starfinger, 2010)

Rhododendron (UK, IE, BE, NL, FR) || Forestry sector: Hinders natural regeneration and outcompetes native trees and shrubs, very difficult to control: estimated to cost EUR 10.3 million/year to the British economy (Williams et al., 2010)

Ragweed (most of the EU) || Agriculture: Reduces yields in the cultivation of maize, wheat, sunflowers, millet, peanuts, soybeans and potatoes: its resistance to herbicides and the germination capacity of its seeds of more than 30 years makes it difficult to control. Agricultural costs in the EU amount to €1.302-3.307 billion/year (Bullock 2012).

As discussed, if certain
sectors were to suffer from the ban of certain IAS, this would have negative
repercussions on employment. However, since the substitution of banned
species with other non-invasive of native species, is expected to be possible
for most species, the negative effect should be moderate. Furthermore, certain
IAS can have dramatic consequences on the livelihood of certain sectors and
measures to prevent their introduction would thus prove beneficial to preserve
existing jobs:
for example, the comb jelly inflicted significant economic losses for the Black
sea and Caspian sea coastal countries due to the drastic decline in pelagic
fish catch (estimated to several 100 million euros for the Black sea[240])
and causing significant loss of employment. Taking all the above
factors it seems that the number of jobs possibly affected by IAS is higher
than the number of jobs that can be affected by measures to combat IAS.

Citizens

Citizens will particularly
benefit from a ban on the introduction of IAS, when these species have
negative repercussion on health as these IAS would be uniformly banned across
the EU. Bans on IAS will also prove beneficial to land owners: some of
these species negatively affect their properties, both the landscapes and
housing. Indeed the presence of Japanese knotweed in properties leads sometimes
in the UK to the refusal of bank loans and losses in property value[241]. 
Small businesses linked to some recreational activities such as angling,
hunting and tourism may be affected by the introduction of new rules on
invasive alien species. The introduction of a ban on the species included in
the list of IAS of EU concern may have an indirect effect on these industries,
not so much because of the ban on trade/marketing/holding, but mostly because
of the ban on release into the environment. Should angling in certain areas
suffer from the ban of certain prized species, it is possible that the small
business flourishing around lakes and rivers used by anglers may suffer a
negative impact as well. The same argument could apply to businesses ancillary
to hunting activities. However this possible negative effect would be dependent
on the disruption of angling and hunting activities. This is considered highly
unlikely as, even if some species may be banned from release, fishing or
hunting activities could simply focus on other non-invasive (and therefore
non-banned) species and native species.

At the same time many
other recreational activities will benefit from a ban on certain species.
It would avoid for instance by preventing that boating or fishing activities
are disrupted in waterways invaded by invasive aquatic plants, or recreational
areas are not accessible due to some other invasive species, or marine aquatic
areas are not suitable anymore for diving purposes. Preventing the introduction
of IAS would have avoided very serious damages to ecological and cultural
patrimony such as the on-going destruction of more than 4.000 ancient
trees, dying due to the presence of a US native invasive parasite along the
Canal du Midi, a very popular tourist destination in France for which the tree
landscape has caused that the UNESCO designated the area patrimony of Humanity.
Thus the positive impacts on recreational values and services clearly outweigh
the negative impacts. Finally,
the banning of certain species may have an effect on the choices of some
citizens, such as pet owners and hobbyists, but given the ready
availability of alternative species this impact may be considered negligible.

7.2.4.
Obligation
to manage pathways to prevent the unintentional introduction in the EU and the
unintentional release into the environment (component B2)

Member States would be
required to identify pathways of introduction of alien species, to develop
measures to tackle those pathways and implement them, thus Member States will
have the freedom and the responsibility to take stock of their own national
situation and take action where needed. The common attention to
pathways would be a first step towards a coherent approach towards pathways at
the EU level. Currently,
limited initiatives have been taken at Member State level to tackle pathways of
introduction and they mostly consist of awareness raising campaigns, guidelines
and voluntary codes of conduct developed together with certain sectors, thus
focusing on soft law approaches. Exception to that is the management and
treatment of Ballast water and measures taken under the plant and animal health
regimes, i.e. existing legally binding provisions. However, these are part of
the baseline option and would be taking place even if no action was taken in
terms of designing a dedicated legal instrument on IAS.

Member States and public
authorities

Pathway management is
probably one of the most necessary measures to be taken to prevent the
introduction of IAS, since it deals with the large proportion of IAS entering
the EU unintentionally and since it allows going beyond the list of IAS of EU
concern, by potentially capturing in the system other IAS that are not listed.
It is one area requiring substantial resources, both human and financial. A
decision needs to be made on how impermeable to IAS the EU wants to make its
borders and its environment. The more the EU aims for a closed system the
higher the control expenses but those would need to be balanced against a
higher protection of the EU's biodiversity and ecosystem services and lower
damage costs. Other benefits of pathway management would be felt in public
health as IAS negatively impacting human health often are brought
unintentionally. For example, through pathway management, further spread of
ragweed could be avoided, or the further introduction of tiger mosquito into
the EU could be addressed.

Costs for pathway
management are likely to be substantial: under the plant health regime border
control currently reaches €26 million/year. However, significant costs can be
spared by doing an efficient and targeted identification of pathways and using
already existing controls systems which will allow focusing on those
constituting major routes of introduction of IAS. As those pathways are
extremely diverse, currently there are little measures on pathways and we have
no indication of which measures Member States are going to take, the cost of pathway
management for public authorities is very difficult to quantify. As the
measures are not yet developed, the cost will probably be limited at the
beginning, but might increase as priority pathways and the appropriate measures
are identified. Currently limited initiatives have been taken and mostly
consist of the development of awareness-raising campaigns and voluntary codes
of conduct developed with certain sectors. Initiatives are therefore already
being taken, although the obligation to manage pathways would be expected to
stimulate further similar initiatives across the EU. This could also be
reflected in the impact on employment: assuming a trend towards the
introduction of more pathway management requirements, the impact on employment
may be mixed, evolving from negligible to negative, although in some cases job
opportunities may also be linked to growing pathway management.

Measures may, for
example, include certain biosecurity measures on traded commodities (or
their means of transportation) if identified as a pathway of introduction (e.g.
animal feed with ragweed seeds). To avoid the unintentional release into the
environment, many measures can be taken. We can rely on examples to provide
an idea of the magnitude of the costs involved in managing certain pathways of
release in the environment. One such example is the UK
"Check-clean-dry" campaign[242], which tackles
pathways of aquatic invasive alien species. Its impact is limited to the local
level and it takes the form of requirements for operators and users to clean
their equipment and be alert of the danger of possible transfer of organisms to
separate water bodies. The UK foresees to spend approximately €50,000/year on
this campaign for the next two years (pers. comm.).

If all Member States
organised one such campaign during the next five years (or several smaller
campaigns) this would entail costs for the public authorities organising such
campaigns of around €20,000/year per Member State, in total €540,000/year.
However, these measures are expected to yield substantial benefits in terms of
avoiding unintentional releases and escapes into the environment, thus leading
to avoidance of substantial eradication, control or containment costs.

In a more developed
system of pathway management, certification systems could be applied. The
current system of plant passports under the plant health regime is costing
€14,574,239/year[243].

Private sector/primary
producers/citizens

The obligation to manage
pathways may lead to the introduction of requirements for the traders or the
shipping companies, as it is the case with the provisions of Ballast Water
Convention. Similarly citizens may be required to comply with certain basic
biosecurity measures when they engage in certain recreational activities (e.g.
cleaning boating/water sports equipment). However, as discussed in previous
sections, businesses/primary producers and citizens alike are expected to
benefit from a preventive approach to IAS and therefore the burden or
inconvenience would be outweighed by the benefits in terms of avoided damage
costs, public health, maintained recreational and land/property values.

7.2.5.
Obligation
to eradicate, contain or control new IAS detected in the environment – early
warning and rapid response (component D2)

Member States would have
an obligation to rapidly respond when a new species listed on the single
list of IAS of EU concern is found in the environment. They may select the most
appropriate course of action to eradicate, contain or control the species, but
would be required to notify the measures taken and their results to the
Commission, which may provide guidance where needed. An EU-wide obligation to
act will avoid any effort being undermined by lack of action in neighbouring
countries.

Member States
and public authorities

Requirements linked to early
warning include the costs of surveillance and of notification to the
Commission and other Member States. The surveillance requirement will rely in
so far as possible on existing systems, thus additional surveillance costs
should be avoided. It is extremely difficult to quantify the costs of the rapid
response requirement as this will largely depend on what species each
Member States will detect on its national territory and also on the feasibility
of the eradication, but it could run into millions of euro per year. Current
costs of eradication vary from €50,000 to 14 million per invasion per Member
State[244],
depending on the invasion stage of the IAS. However, if the eradication costs
rise quickly, Member States might soon resort to containment and control, to
avoid the eradication costs which initially may be higher. Rapid response will
necessarily have implications for public authorities which will be
largely responsible for organising and financing these actions, although EU funding
mechanisms could be involved to support them (LIFE, ERDF, EAFRD). There will
also be administrative costs involved, i.e. sharing information on the rapid
response with the EU and the other Member States.

Wherever an IAS could be
completely eradicated, ALL long term damage or management costs would be
avoided. Those avoided costs are very difficult to estimate and are expected to
rise over time if containment cannot be guaranteed. FCEC (2011) estimated, in
support of the plant health impact assessment, the eradication and containment
of established IAS plants to cost €3 million per IAS, if the IAS is
widely spread amounting to €10 to 30 million per IAS, not including
damage costs. For example, if ragweed could have been eradicated every time it
was first observed (its negative impacts were known from the US), damage costs
of €1.469-5.431 billion/year could have been avoided[245].
If IAS were not eradicated, but just controlled and contained, those costs
would not be avoided, but at least the increase would be reduced. If
eradication were to be attempted at a later stage, costs would be significantly
higher (see Table A16). Benefits would also accrue in terms of biodiversity
and ecosystem services preservation, as well as in terms of public
health, given as the aim would be to remove or contain and control noxious
species.

These significant
benefits of rapid response are expected to easily outweigh the short
term costs.

Table A16: Eradication
costs in earlier and later invasion stages in the UK[246].
Invasion stage varies according to the species life cycle

IAS || Eradication costs (euro)

Earlier invasion stage || Later invasion stage

Asian long horned beetle || 39,000 || 1,524,974,000

Carpet sea squirt || 2,728,000 || 1,074,173,000

Water primrose || 85,000 || 280,129,000

Grey squirrel || 510,000 || 985,216,000

Coypu || 5,443,000 || 21,776,000

Private
sector/primary producers and citizens

Businesses and citizens would not
normally bear the costs of the rapid response obligation, unless it was
possible to prove (and this is rarely the case) that they were responsible for
the release. Indeed, in very rare cases, when the polluter could be identified,
costs of rapid response could be recovered from the polluter.

On the contrary some benefits
would be expected for the private sector. The removal of certain species is
extremely labour intensive and requires specialised skills as well as
equipment, and business specialising in this type of work could emerge, with
the creation of new employment opportunities. This is already happening
in several Member States. In the UK, for example, a flourishing business has
emerged specialising in the eradication of Japanese knotweed, for example: a
quick internet search reveals several companies specialising in the control and
removal of this invasive plant. The removal of water hyacinth from the Guadiana
River in Spain employed a mixture of techniques including mechanical and manual
removal. The eradication programmes lasted from 2005 until 2009 and maintenance
activities as well as awareness raising campaigns are on-going. The campaign
employed about 125 people in 2006 and 95 in 2007, with labour costs amounting
to respectively 1,000,000 euro and 760,000 euro[247].

Furthermore, the benefit
of avoided damage and management costs will be felt by primary producers, as
well as by business that are affected by the presence of IAS (e.g. electricity
producers). Also citizens might be positively affected in terms of
avoided damage costs, e.g. invasive alien species that may negatively affect
recreational opportunities or devalue their properties.

7.2.6.
Obligation
to manage (eradicate, contain or control) established IAS (component E2)

Member States would have
the freedom and responsibility to select the appropriate measures for the
management (eradication, containment or control) of established IAS, with the
obligation to notify the measures they intend to take to the Commission. The
measures could be discussed at transboundary level to improve coordination.

Member States and public
authorities

The obligation to manage
established populations of IAS of EU concern will entail substantial costs
for public authorities, although the exact impact is impossible to
calculate as it will largely depend on which and how many species will be
established in Member States, as well as on the methods available and selected
to manage a species. The cost of management of IAS through LIFE-projects can
give some indication of the order of magnitude of the cost of managing species
(or one species) usually in one site: the expenditure through LIFE-projects
currently ranges between €30,000 and 360,000 per year per Member State
(roughly €3-12 million per year), but many other management programmes
and efforts are being carried out at national level independently from LIFE.
FCEC (2011) estimated, in a study to support the plant health impact
assessment, that the eradication and containment of established IAS plants
could cost €3 million euro, and, if widely spread could amount to €10-30
million/year per IAS. Some examples of management activities already taking
place are summarised in Table A17 and include efforts to control IAS in waterways
in the UK, costing €24.5 million/year; the control of floating
pennyworth in the Netherlands, costing €2-4 million/ year; the removal
of water hyacinth from the Guadiana river in Spain took 3 years and has cost
€14.7 million; the removal of coypus in Italy has already cost €2.6
million; the control of hogweed in Latvia costs €3.5 million/year.

Table A17: Examples of
costs to manage IAS

IAS || Control  or eradication costs

Aquatic plants || -Great Britain - New Zealand pigmyweed: €1.45 to 3 million over a period of 2-3 years (Leach and Dawson, 1999) -Great Britain - IAS in waterways: €24.5 million/year (Williams et al., 2010) -Netherlands - floating pennyworth: €2-4 million/year (van der Wijden et al., 2007) -Flanders - invasive alien aquatic plants: €1 million/year (Sonigo et al., 2011) -Spain - removing water hyacinth from the Guadiana river (for around 75 km of river): €14.7 million for 2005 to 2008 (EPPO, 2008)

Japanese knotweed (most of the EU) || -Germany: €6.2 million/year (Reinhardt et al., 2003)

Black cherry (most of the EU) || -Germany: €3.4 million/year for tree removal in conservation areas and €20.7 million/year for management measures in forestry (Reinhardt et al., 2003) - Flanders: 4.6 million (1994-2010) for management measures in forestry (Buysse 2012)

Giant hogweed (most of the EU) || -Germany: € 12 million/year (Reinhardt et al., 2003) -Latvia: up to €3.5 million/year -Great Britain: €1.1 million/year -Wallonia: €0.5 million/year -Estonia: €472,000/year (Sonigo et al. 2011)

Coypu (most of the EU) || -Italy (1995-2000) - removal of over 220,000 coypus: €2.6 million (Bertolino, 2009)

Ruddy duck (UK, IE, ES, FR, BE, SE) || -UK – eradication: €4.4 million over 4-6 years (Shirley, 2009)

Musk rat (most of the EU) || -Germany: €4 million/year (Reinhardt et al., 2003) -Wallonia: €0.7 million/year (Sonigo et al., 2011)

American mink (most of the EU) || -Germany: €5 million/year (Reinhardt et al., 2003)

The total current cost,
while difficult to estimate (see 7.2.1 for a rough estimate), is expected to
rise exponentially due to the rising numbers of IAS and their increasing
damage over time (see chapter 2.5 and Table 2), therefore the magnitude of the
cost will also depend largely on the effectiveness of the measures taken to
prevent the introduction into the EU and the establishment in the environment
of IAS. Administrative costs for Member
States would be limited to periodically informing the Commission of the
measures taken and uploading information on the measures in the centralised
information system.

However, public
authorities are also expected to reap the benefits of management in
terms of avoided damage and costs. Such benefits would be more
pronounced in case eradication was achieved, but if a species were to be
effectively controlled, damage and consequent costs could be kept to a minimum.
For example, the on-going ruddy duck eradication programme carried out in the
UK is expected to cost €4.4 million over 4-6 years. Success in eradicating this
species would avoid the need to continuously spend to keep the species under
control to avoid the extinction of the native white headed duck.

Efforts to eradicate,
contain or manage established species will mitigate the negative consequences
that IAS can have on native biodiversity and the functioning of ecosystems. One
relevant example of a species already present in the EU is that of the killer shrimp:
a voracious predator of native shrimp and a wide range of other
native fauna, the killer shrimp disrupts ecosystems through direct predation
and also indirect effects across trophic levels. Changes in trophic
interactions could alter distributions of fish, whilst parasites carried by
killer shrimp could reduce fish stocks. Furthermore, loss of diversity can
affect assessments of water quality.

Further, the requirement
to manage established species is expected to be particularly beneficial when it
comes to public health. Some of the IAS of EU concern with a negative impact on
public health will indeed already be present in the EU, with the consequent
medical expenses, lost work days and suffering. One important example which is
very relevant in the EU is that of ragweed, a common aeroallergen,
already well-established in Eastern Europe, Northern Italy, and the Rhone river
valley. In studies performed in Europe and North America, approximately 10-15%
of the population is sensitive to the pollen of common ragweed (Bohren, 2006)
causing rhinitis, oculorhinits, asthma, and dermatitis (Bass et al.
2000). Costs of ragweed allergies in North America are estimated to run up to
millions of dollars every year in health care costs and lost labour hours
(Bohren, 2006). The problem is of similar magnitude in the EU: studies carried
out in Germany estimated that the medical cost (prescribed medication) incurred
by ragweed infestation is €17-47 million/year (Reinhardt et al. 2003).
For the EU as a whole, this cost was estimated to amount to 118-763
million/year (Bullock, 2012). Another plant with significant impact on
public health is giant hogweed: direct skin contact with the plant induces
extreme photosensitivity, which in turn can lead to severe, slow-to-heal burns
and scarring. An estimate found that medical costs linked to giant hogweed in
Germany may amount to over €1 million a year.

Private sector/primary
producers and citizens

Traders and users of IAS
as well as primary producers – forestry, agriculture and animal husbandry) –
will be unlikely to be directly affected and bear the costs of management
measures, unless it was proven, and this happens very rarely, that they were
directly responsible for the release of the  IAS of EU concern.

Primary producers will benefit
from initiatives to eradicate or control IAS as they are often the victims of
IAS invasions and they would suffer less damage costs and in some case less
management costs. For example, in Germany €20.7 million/year are being
spent to control black cherry in forestry[248]. Management at EU
level of IAS can control the numbers of IAS, thus leading to fewer costs to
private operators.

Furthermore, new private
businesses may flourish, thanks to the need of specialised skills and machinery
and new employment opportunities could be created.

Citizens are expected
to derive benefits from the obligation to manage IAS: where, for example, tourism
and recreational activities are hindered by the presence of IAS. For
example the presence of Zebra mussels can interfere with fishing gear, floating
mats of aquatic plants may hinder the availability of water courses for boating
or angling activities.

7.3.
Optional
add-ons for release into the environment

When it comes to release
into the environment (operational objective C) the basic legislative
instrument, which focuses exclusively on the species listed in the list of IAS
of EU concern, could be made more ambitious and with a higher level of EU
intervention:

·
either
by introducing provisions on permits for release of IAS that are not listed in
the EU list of IAS of EU concern but that are considered by Member State to be
of concern for them (add-on C2)

·
or
by introducing an EU list of species approved for release (add-on C3) in
parallel to the list of IAS of EU concern

7.3.1.
Permitting
requirements for releasing IAS of Member States concern (add-on C2)

Add-on C2 proposes a
more pre-cautionary approach to achieve operational objective C on preventing
the intentional release of IAS in the environment. Besides banning the release
of species listed on the list of IAS of EU concern (i.e. demonstrated to be
invasive), this sub-option would have a broader focus on preventing or
controlling the release of IAS for which the damage of their release has not
yet been ascertained but cannot be assumed to be non-existent.

Member States would have
the freedom and responsibility to identify such species relevant for their
territories and develop catalogues of species for which they have reasons to
believe they may become invasive, for example because they have shown invasive
behaviour in similar ecological conditions. These species would not be allowed
to be released into the environment unless they obtained a permit from
the Member State competent authorities.

Member States and public
authorities

Regulating the release
into the environment would represent a cost for public authorities,
although part of these costs could be recovered by charging the operator or
sector with an interest in releasing a particular species and thus benefitting
from such release. It is not possible to provide an estimate of total costs as
this will depend on the IAS to be identified as of Member State concern and on
the level of interest for releasing these species. Member States authorities
will also face the cost of drafting the national catalogues of IAS of Member
State concern and to evaluate the risks of such release. Similar systems
are already in place in France and UK for selected IAS and Regulation 708/2007
on the use of alien species for aquaculture is based on a permitting system:
these schemes involve some administrative costs for the competent authorities
and for the economic operators that need to apply for a permit to release those
alien species, but there is no indication that the costs of the existing
systems are disproportionate.

While managing such
system would entail costs, these could be outweighed by the benefits of
adopting this more precautionary approach. IAS for which the damage of
release has not yet been ascertained but cannot be assumed to be non-existent
would indeed still be allowed to be traded, but their release would be
regulated. This would contribute to avoiding new invasions and bring about
benefits in terms of damage avoidance. For example, the musk rat, which
undermines riverbanks, railroads, dams and fences, irrigation structures and
aquaculture, is causing damages of €23 million/year in the Netherlands[249]
and €2.3 million/year in Germany for additional waterway maintenance[250].
Minimising the risk of new invasions would also avoid the management costs
ensuing from IAS establishing and causing damage: current costs of IAS
eradication range from €50,000 to 14 million euro per invasion per Member
State[251],
depending on the invasion stage of the IAS.

Such precautionary
approach would also yield benefits in terms of public health: an example of a
species, whose introduction might have been avoided, had some form of
preliminary judgement been made ahead of release, is that of giant hogweed,
which was introduced and released in Europe for ornamental purposes and which
costs millions of euros, e.g. in Germany giant hogweed costs €1
million/year in medical costs. Similarly, the musk rat, which can
transmit echinococcosis, costs €4.6 million/year in medical costs[252].
The broader focus will contribute to avoiding the growing problems caused by
certain noxious species being introduced and allowed to spread. The more
proactive approach would be beneficial for biodiversity and ecosystem services
while, at the same time, avoiding the negative consequences of listing a
species on the single list of IAS of EU concern. For example, a broader focus
on regulating or restricting the release into the environment for certain
species may bring about a situation where certain species may be allowed to be
traded (i.e. would not be listed), thus avoiding the negative economic impact
that a ban for the EU would entail (e.g. American mink). It would however
enable the restriction or prohibition of release into the environment of such
species, with positive repercussions on biodiversity. A prohibition to release,
unless in possession of a permit, would provide tools to public authorities to
effectively prohibit releases, by not granting a permit. Releases would thus be
illegal and tools could be developed to control such unauthorised releases.

Private sector/primary
producers/citizens

Some primary producers
(agriculture, forestry) as well as the traders of ornamental species (horticultural
sector) or of biological control agents may be facing administrative
costs, to seek a permit to release certain species in the environment, and may
be charged to obtain a permit or authorisation, in case a cost recovery scheme
was put in place. The exact magnitude of such costs will depend however, on the
number of IAS intended for release into the environment which are considered of
Member State concern. It is thought unlikely that species used for agricultural
purposes (fruits and crops) may fit this description as these species
usually need intensive management and require constant input in order to
thrive. The situation may be different for species used in forestry or
biomass production as species are selected also for their growth rate and
ability to grow even in difficult conditions, the characteristics that can make
a species invasive. It was however estimated that about 100 alien species have
been introduced in European forestry over the past century, so an average of 1
new species every year, a relatively limited burden for the sector, also
considering that such new species may not fit the description of species for
which the damage of release cannot be assumed to be non-existent.

When it comes to users
of IAS and primary producers interested in releasing species into
the environment – e.g. forestry, agriculture – it is to be stressed that they
are often suffering from the consequences of an invasion of certain species
(e.g. weeds for farmers) and would thus also benefit from a more proactive
approach. An example already mentioned is that of black cherry, which hinders
natural regeneration of trees and hinders forest management measures such as
thinning, timber harvesting or planting. Thus the benefits of a proactive
approach can counterbalance the negative impacts.

The horticultural
sector imports large number of ornamental species: it has been estimated
that in Europe there are at least 55,000 woody plants and perennials available
for sale[253].
Beside house plants, these plants are intended to be planted outdoors, i.e. to
be released. The system however, would not ban the release of all alien
species, but would seek to regulate at Member State level the release of those
for which the damage of release has not yet been ascertained but cannot be
assumed to be non-existent, thus limiting the negative impact of a permitting
system.

When it comes to the biological
pest control sector, the system may entail costs. The species employed for
biological pest control are either predators or have characteristics that allow
them to control other species. This could lead to the conclusion that extra
precaution should be taken to assess whether the release of such species may cause
damage. The need of a more cautious approach in this sector is, however, more
commonly accepted and Member States are gradually introducing obligations in
this regard (e.g. France).

This system is expected
to place some constraints on the choice of species that can be released
in the environment or brought onto the market. However, the impact on the competitiveness
and profitability of business for these sectors will remain limited to the
subset of IAS that would be of Member State concern. Consequently, the
negative consequences that this system could have on employment were also
considered moderate, even offset by the benefits that these sectors would
derive from a more precautionary approach. Furthermore, as it was argued also
in previous sections, IAS may lead to employment losses (e.g. collapse of
fisheries due to comb jelly in the Caspian and Black Sea) and a more
precautionary approach to releases into the environment may contribute to avoid
similar situations from occurring.

Other private sector players would be not
be affected as long as the species they trade are meant to be kept in contained
holding. Pet traders would therefore be unlikely to be affected. Similarly, the
system would not affect the sector of animal husbandry (e.g. fur
breeders) as also their animals are not meant to be released in the
environment.

In
some cases, a system to regulate species for which the damage of release has
not yet been ascertained, but cannot be assumed to be non-existent, may hinder
the release of species prized for certain activities, such as hunting and
angling. However, this impact was considered moderate because even
if release into the environment was restricted, fishing or hunting activities
could focus on other non-invasive alien species or native species.

Furthermore, in general citizens
would benefit from a more precautionary approach to the release of alien
species in the environment as this would more proactively try to avoid the
onset of further invasion which may have negative consequences for example for
land or property owners amenities and recreational activities.

7.3.2.
Introducing
a single EU list of species approved for release into the environment (add-on
C3)

Add-on C3 also proposes
a more proactive and pre-cautionary approach to achieve operational objective C
on preventing the intentional release of IAS in the environment. Alien species
not yet present would not be allowed to be released into the environment unless
proven harmless by risk assessment. This add-on would introduce the concept of an
EU list of species approved for release, beside the single list of IAS of EU
concern which would of course be automatically banned from release, having been
risk assessed and found invasive.

Member States and public
authorities

Add-on C3 which limits the
ability to release species into the environment only to some authorised species
in the EU would provide the highest level of environmental protection and
guarantee a uniform approach at EU level, but this would entail substantial
costs for public authorities to develop the numerous assessments
needed to establish the list of species approved for release. This add-on would
also entail considerable enforcement efforts and costs. Being the most
stringent approach to release into the environment, this add-on will also yield
benefits in terms of public health and on environment and
biodiversity.

Private sector/primary
producers/citizens

Primary producers
(agriculture, forestry) as well as the traders of ornamental species (horticultural
sector) or of biological control agents are expected to face negative
impacts as their business and activities would be disrupted,
while the necessary risk assessments are being carried out. This option would
not simply restrict the choice of new species for release, but would rather
determine the limited choices available, seriously hampering business and
negatively affecting the competitiveness and profitability of these sectors,
as the possibility to bring in new species would depend on a positive risk
assessment. Such constraints may be particularly felt by the sectors dealing
with plant species, considering the volume of plant species that are traded (it
has been estimated that in Europe there are at least 55,000 woody and perennial
plant species available for sale[254]).
This may in turn have negative consequences on employment. It is also to
be said that since primary producers often suffer the consequences of an
invasion, they would also benefit from a more proactive approach, but at
the cost of serious disruption of certain activities.

7.4.
Optional
alternative action for rapid response

When it comes to early
warning and rapid response (operational objective D), the basic legislative
instrument could be made more stringent and ambitious with a higher level of EU
intervention, by introducing the obligation for Member States to eradicate new
IAS, unless a derogation was granted by the Commission (alternative action D3).

7.4.1.
Obligation
to eradicate newly establishing IAS

While the basic
legislative instrument left the choice between eradication, control and
containment, with alternative action D3, Member States would have an
obligation to rapidly eradicate newly establishing IAS of EU concern. Since
eradication is not always possible or feasible, and in those cases when it is
ascertained that a newly detected species is actually well established in a
territory, Member States would have the possibility to apply for a derogation
from the obligation, with the approval of the Commission, and resort to other
management measures. The Commission would have a limited time to provide its
decision. Pending the decision from the Commission the Member State would be
required to take measures to contain the IAS and prevent its spread.

Member States
and public authorities

It is extremely
difficult to quantify the costs of the rapid eradication requirement as
this will largely depend on what species Member States will detect on their
national territories. The Member States will also have to assess whether: 1)
the species detected is newly establishing, or if it is actually
well-established, but was not detected before and 2) eradication is actually
feasible. Having established that eradication is feasible, Member States will
have the legal obligation to proceed with it and this will entail at first higher
costs than with the basic legislative instrument, which leaves to the Member
States the possibility to select whether to eradicate, contain or control a
species (containment and control measures tend to be cheaper than eradication
at first).  Public authorities will be largely responsible for the
higher upstream costs, although with possible EU funding (LIFE, ERDF,
EAFRD).

The derogation
mechanism will entail additional administrative costs for Member States
that will need to prepare and motivate their application for derogation and for
the Commission, which will have to examine all dossiers submitted and approve
or reject the applications for derogation.

However, such high
initial investment would yield substantial benefits: wherever an IAS could be
completely eradicated, ALL long term damage or management costs would be
avoided, costs that may easily go into millions of euro per IAS per year. The
greater focus of this action on early eradication is expected to lead to the
eradication of more species than it would be the case under the basic
legislative instrument, where Member States are left with the choice between
eradication and other (cheaper) measures, such as containment and control. The
benefits of quickly solving the problem for good are thus expected to be more
pronounced than with the basic legislative instrument. Substantial benefits
will also accrue in terms of public health and environmental
protection. It can be estimated that those additional benefits will counterbalance
the additional short term costs.

Private sector/primary
producers/citizens

When it comes to the
obligation to rapidly eradicate IAS of EU concern, the private sector would
normally not bear the costs of the rapid response obligation, unless it was
possible to prove (and this is rarely the case) that they were responsible for
the release. In very rare cases, when the polluter could be identified, costs
of rapid response could be recovered. On the contrary, considering that primary
operators and citizens are often the victims of IAS invasions, then
a greater focus on early eradication could yield substantial benefits in terms
of damage avoidance, public health and environmental protection.

8.
Annex VIII - Glossary

The following definitions are working
terminology to enable a better understanding of the Impact Assessment report.
They should not be taken to be legal definitions.

Alien species - a species, subspecies
or lower taxon, introduced outside its natural past or present distribution,
including any part, gametes, seeds, eggs, or propagules of such species that
might survive and subsequently reproduce

Invasive alien species (IAS) - means an
alien species whose introduction or spread has been found, through risk
assessment, to threaten biodiversity and ecosystem services, or to have a
negative impact on the environment, society and the economy.

IAS of EU concern – these species will be
the ones proven to be invasive by risk assessment, based on criteria that would
include environmental as well as socio-economic considerations, and which are
deemed by the Commission and Member States to be the ones on which action at EU
level should focus, given their impact. The recognition of an alien species as
an IAS of EU concern will trigger obligations for the Member States to tackle them.

IAS of MS concern - IAS not included in
the list of IAS of EU concern, but for which Member States consider that the
damage deriving from their release, while not fully ascertained, could be of
significance. The decision on whether an alien species can be considered of MS
concern will rest with each Member State. The only obligation that this will
imply is that the Member States introduce a permitting system for the release
into the environment of the species they consider of their concern (MS concern).

Eradication - means the complete
and permanent removal by physical, chemical or biological means of a population
of an invasive alien species.

Control – means any action
aimed at keeping the numbers of individuals of an IAS in check and avoiding excessive
proliferation.

Containment – means any action
aimed at keeping an IAS within a certain geographical area and avoid their
spatial spread.

Management - shall consist of any
physical, chemical or biological action aimed at the eradication, control or
containment of a population of an invasive alien species so that it no longer
poses any significant risk to biodiversity and ecosystem services, as well as
to plant, animal and human health, society and the economy

Pathway management – any action aimed at
addressing the unintentional introduction into the EU as well as the release
into the environment of IAS through managing their routes of biological
invasions, i.e. the mechanisms and vectors that allow the introduction and
spread of IAS. Pathway management actions may range from awareness raising and
voluntary measures to, possibly, regulatory measures, including border checks
on cargoes and commodities or other biosecurity measures.

9.
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Reinhardt, F., Herle,
M., Bastiansen, F. and Streit, B. (2003), Economic impact of the spread of
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Roques A. (2010)
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Roques, A. (2011)
Invasive patterns of alien terrestrial invertebrates in Europe, pp. 199-226, in
Pimentel, D. (2011) Biological Invasions, Economic and Environmental Costs of
Alien Plant, Animal, and Microbe Species, CRC Press

Rortais, A. (2008) The
Asian hornet Vespa velutina: a new invasive species and honeybees
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Roy, H.E., Adriaens, T.,
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[1] DAISIE-project, "Delivering Alien Invasive Species Inventories for
Europe", http://www.europe-aliens.org/

[2] Vilà et al., 2009

[3] Millennium Ecosystems Assessment, 2005

[4]
Sala et al. 2000

[5] Kettunen et al. (2009) estimated
the yearly cost of IAS in Europe based on an inventory of all possible costs
related to IAS (management
costs + all types of damage
costs) over the last 20 years. See section 3.3 and Annex III.

[6] Pathways: this term refers to the routes
of biological invasions, i.e. the mechanisms and vectors that allow the
introduction and spread of IAS.

[7] Under the Nagoya Protocol, the benefits
arising from the commercial and other utilization of genetic resources should
be shared with the Party providing these resources. This issue is addressed in
the Impact Assessment accompanying the Proposal for a Regulation implementing
the Nagoya Protocol in the European Union. While the Nagoya Protocol is
addresses the benefits of alien genetic resources, the IAS legislative
instrument addresses the threats of alien living species.

[8] By cost of action it is meant any cost related to tackling the issue of
IAS, ranging from prevention, early warning and rapid response to newly
establishing IAS and management of established IAS.

[9]
http://ec.europa.eu/environment/nature/invasivealien/docs/results\_consult.pdf

[10] http://www.acceptance.ec.europa.eu/environment/nature/invasivealien/docs/ias\_discussion\_paper.pdf

[11]
http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/stakeholder\_03092010&vm=detailed&sb=Title

[12]
http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/working\_prevention&vm=detailed&sb=Title

[13] All studies are accessible from 
http://ec.europa.eu/environment/nature/invasivealien/index\_en.htm

[14] DAISIE (2005-2008). More information at:
http://www.europe-aliens.org/index.do

[15] http://easin.jrc.ec.europa.eu/

[16] The CBD definition will be used throughout this impact assessment,
although also economic and social impacts will be taken into consideration.

[17] Vila et al., 2010

[18] The interactions of IAS with climate change can be complex. Climatic changes may lead to ecosystems becoming stressed and less resilient to pressure
from IAS, with previously
harmless alien species
suddenly finding  the niche to outcompete native species. IAS may also lead
to ecosystems becoming stressed and reduce their ability to adapt to climate
change.

[19] Global Biodiversity Outlook 3, 2010

[20] Millennium Ecosystems Assessment, 2005

[21] Ecosystem services: the services provided
by the natural environment that benefit people, e.g. catchments that provide
drinking or irrigation water to a city or farming area, indigenous forest and
vegetation that reduce hillside erosion, wetlands that purify water or reduce
the risk of tidal floods.

[22] Scalera et al., 2012.

[23] Based on EEA report "The
environmental and socio-economic impacts of IAS in Europe"- Scalera
et al., 2013

[24] Rasplus, 2010

[25] Data from Genovesi and Scalera, 2007

[26] The study focused on 380 species, the selection was based on an exercise
which collated the existing lists of known IAS in Europe (the European and Mediterranean
Plant protection Organisation list, the SEBI list, the DAISIE list, the NOBANIS
factsheets, the EU Wildlife Trade Regulation).

[27]The two percentages do not add up to 100 %
because some species belong to the two categories, i.e. traded for a purpose
and also entering unintentionally as contaminants or stowaways/hitchhikers.

[28]
Hulme et al., 2007

[29]
Hulme, 2007

[30]
Hulme et al., 2008

[31] Kettunen et al. 2009

[32]By management costs it is meant the cost to
tackle species that are already established in the EU, either by eradication,
containment or control measures.

[33] Some scientific papers consider human
viruses and bacteria as IAS. This paper addresses the vectors of human viruses
and bacteria, however the control of those viruses and bacteria is not included
as this is considered as public health policy.

[34] http://www.biosecurity.govt.nz/files/pests/surv-mgmt/economic-costs-of-pests-to-new-zealand.pdf

[35] Hulme et al. 2009, Roques 2010, Genovesi et al 2011.

[36] Shine et
al. 2010, Sonigo et al. 2011

[37] e.g. definition of
alien species or IAS vary between Member States, but also in different
legislation within one country.

[38] Currently giant hogweed is targeted in
Belgium, Czech Republic, Denmark, Estonia, Spain, Hungary, Ireland, Italy,
Luxemburg, Latvia, Poland, Sweden, Slovakia and the UK.

[39] UK ruddy duck eradication programme project bulletin, April 2012

[40] http://www.europeansquirrelinitiative.org/RevChap6.pdf

[41]Including the European and Mediterranean
Plant Protection Organisation (EPPO), the World Organisation for Animal Health
(OIE), the World Trade Organisation (WTO) and the International Maritime
Organisation (IMO)

[42]Including the Convention on Biological
Diversity (CBD)[42], the Bern
Convention on the Conservation of European Wildlife and Natural Habitats[42],
the International Plant Protection Convention (IPPC)[42],
the WTO Sanitary and Phytosanitary (SPS) Agreement[42]
and the International Convention for the Control and Management of Ships
Ballast Water and Sediments (BWC)

[43] Sonigo et al., 2011

[44] Sonigo et al. 2011

[45] See impact assessments on the revision of the animal and plant health
regimes (2012)

[46] Ruddy duck, painted turtle, American
bullfrog, red-eared terrapin, Pallas’s squirrel, grey squirrel, Eastern fox
squirrel

[47] Except aquatic organisms belonging to Bacteria

[48] Shine et
al. 2010, Sonigo et al. 2011

[49]
Butchart et al. 2010

[50]
Lambdon et al. 2008

[51]
WTO, 2009

[52]
Essl et al. 2011

[53] Hulme et al. 2008

[54] Perez y Perez and Chica Moreu, 200

[55] COM(2008) 789 final

[56] Environment Council Conclusions, 25 June 2009

[57] Environment Council Conclusions, 21 June
2011

[58] Opinion of the Committee of the Regions on
a new impetus for halting biodiversity loss, DEVE-IV-039

[59] Opinion of the European Economic and Social Committee on the
Communication from the Commission to the Council, the European Parliament, the
European Economic and Social Committee and the Committee of the Regions –
Towards an EU strategy on invasive species

[60] European Council Conclusions, 25-26 March 2010

[61] COP 10 Decision X/2 Strategic Plan for Biodiversity 2011-2020

[62] COM(2011) 244

[63] 2011/2307(INI)

[64] EU 2020 Biodiversity target: "halting
the loss of biodiversity and the degradation of ecosystem services in the EU by
2020, and restoring them in so far as feasible, while stepping up the EU
contribution to averting global biodiversity loss."

[65] The plant and animal health regimes are
addressing pathways of pests and diseases through certification systems for
traded plants and animals.

[66] The option of including invasive alien
plants in the scope of the revised plant health law, which was considered in
the plant health impact assessment, was not retained. See Annex V for more
details.

[67] Birds Directive, Art 11: Member States
shall see that any introduction of species of bird which do not occur naturally
in the wild state in the European territory of the Member States does not
prejudice the local flora and fauna.

[68] Habitats Directive, Art 22(b): In
implementing the provisions of this Directive, Member States shall: (b) ensure
that the deliberate introduction into the wild of any species which is not
native to their territory is regulated so as not to prejudice natural habitats
within their natural range or the wild native fauna and flora and, if they
consider it necessary, prohibit such introduction.

[69] The European Network on Invasive Alien
Species (NOBANIS) is a gateway to information on alien and invasive species in
North and Central Europe: http://www.nobanis.org/

[70]The FCEC evaluation of the plant health
regime recommended that the system should be modernised through strengthening
the measures on prevention and enhancing coordinated action to prevent the
spread of harmful organisms that enter the EU. The evaluation also highlighted
the need for prioritisation and for strengthening the EU approach for joint
action to tackle risks of EU significance. The proposed measures draw
extensively from the existing plant health regime and learnt lessons from the
FCEC evaluation. A preventive approach is proposed, including surveillance,
early warning and rapid response as well as management obligations for those
IAS that enter and establish in the EU.

[71]Risk assessments evaluate the invasiness of
species under given conditions, potential geographical distribution and
negative impacts. They allow for a prioritisation between species on the basis
of their occurrence and damage.

[72]The European and Mediterranean Plant
Protection Organisation (EPPO) is currently performing risk assessments for
invasive alien plants.

[73] The analysiss is based on the
assumption that the EU risk assessments would be modelled on the EPPO risk
assessment protocol, which focuses primarily on the environmental risks presented
by species, although it includes some socio-economic considerations;
nevertheless, it has been considered a good model for the purpose of assessing
IAS. The socio-economic considerations are indeed expected to be put forward in
the risk assessments and then further developed and discussed by the Commission
and the Member States representatives in the standing committee discussions.

[74]The SEBI list includes 167 IAS recognised
as particularly threatening to biodiversity in Europe, identified in the framework
of an exercise to streamline indicators of biodiversity in Europe, led by the
European Environment Agency.

[75] Environment Council
Conclusions, 19 December 2011

[76]The choice of what provision to apply will
largely depend on the IAS and on the circumstances: for some species
eradication is still possible (e.g. ruddy duck), for other species control, i.e. keeping numbers down, is still possible (e.g. black cherry),
while for other species containment, i.e. avoiding their spread, could be the only option left (e.g. killer shrimp).

[77]By way of illustration, some Member States
produce list of species not yet detected in their environment but considered
likely to have a negative impact: e.g. Belgium lists 14 species, Ireland lists
c. 50 species. In these two cases the majority of the species listed are
intentionally introduced. EPPO also produces lists for species that are not yet
present or present in a limited area in the European region and that may
present a risk: currently EPPO lists around 22 such species.

[78]For example, limited number of specimens released, requirement of pilot
phase, or compulsory contingency planning.

[79] It is not possible to know in advance how
many alien species would need to be risk assessed although it could presumably
be many since it will be needed for any new alien species intended for release.
It is not possible to know in advance how many of these species would be found
safe for release.

[80] For the sole purpose of being able to
ascertain possible impacts of a list, the SEBI list of 167 IAS was used as a
reference This should not be interpreted as an indication that the SEBI list
will be adopted as the list of IAS of EU concern.

[81]Many sectors that have a stake in the IAS
debate, either as users or as victims of IAS, are largely small and
microenterprises, which do not have the resources to collect or maintain
comprehensive data sets on their own business. The pet industry and the
horticultural sector, for example, provided mostly qualitative data on the
structure of their business and on the volume of species traded

[82] Information on microorganisms, algae, fungi
tends to be scares, while more is available for plants and vertebrate animals,
in particular birds and mammals.

[83] Scalera, 2009

[84] Despite significant efforts, through contacts
with the sectors involved and research, the data found on the structure of
these sectors were scarce. From consultations with stakeholders, however, it
was possible to infer that the sectors with a commercial interest in certain
alien species are likely to include a large number of retailers (mostly
microenterprises) trading alien species directly with the public and sourcing
their products from larger players, importing such species into the EU. The
larger players are thought to be a heterogeneous group, including a sizeable
proportion of SMEs. Some of the proposed measures would be relevant to these
larger players, rather than to the microenterprises in the retail sector.

[85] Total cost of current risk assessments in Member States (Shine et al. 2010)

[86] Pending Ballast water Convention: €8,000/year/vessel
(based on http://globallast.imo.org/Monograph\_19\_Economic\_Assesment\_web.pdf) x 13,616 vessels in the EU (based on http://www.ecsa.eu/images/files/downloads\_annualreports/Rapport%202010-2011.pdf)

[87] Shine et al. 2010

[88] Total cost of current surveillance in Member States (Shine et al. 2010)

[89] No cost estimate available

[90] Based on data on current management costs, an average cost per acting MS
per addressed IAS per year was estimated for a series of species groups (Table
A10, Annex VII). Next, building on the overview of IAS which MS are currently
managing at the MS-level (Table A6, Annex V) and on the cost estimates in Table
A10, the total current management cost was estimated per species group (Table
A11, Annex VII), leading to an estimated total current IAS management cost of €1.309 bio/yr. See Annex VII for further details.

[91] Shine et al. 2010: current average
of €122,000/year/Member State

[92] Estimated investment in NOBANIS, has been funded by some Member States

[93] Estimated investment by the Joint Research Centre: €690,000 in 3 years
= €230,000/year

[94] Shine et al.
2010: (1) current average for
"IAS policy development and coordination" of €40,000/year/MS
(together €1 million/year) + (2) "development of strategies for the
MS" that do not yet have them and strategy revisions (current average of
€130,000 to 1.5 million/strategy) and "policy assessment and support"
assuming one study (current average of €50,000/study) every 3 years (all
together roughly another €1 million/year), thus cost of (1) and (2) = €2
million/year

[95]Only in so
far as species of interest to a sector were banned, traders of exotic species (mostly
small and microenterprises) would be affected by the introduction of a list of
IAS of EU concern, at least until the identification of suitable substitute
species,
see 6.1.3 for more details.

[96]Shine et al. 2010: current cost of
EU-level risk assessment is €42,000 per assessment. Assuming that all 167 IAS
on the SEBI-list would be assessed during the next 5 year, this would make 33
risk assessments/year or 1.4 mio/year. The cost per risk assessment could be
higher, in particular when adding more economic information, but potentially
replacing 27 risk assessments by one risk assessment will lead to considerable
cost savings.

[97]Thanks to integration in current controls
on live animals and plants for planting. Based on the costs of similar
exercises coordinated by the services in charge of customs and taxation of the
Commission, it was estimated that a small project to develop guidelines for
customs on IAS consisting of 3-4 meetings of 10 experts would costs
€20,000-30,000 in total, using Commission facilities and excluding translation
costs

[98]Current costs for border control in plant
health: €26 mio/yr (Food Chain Evaluation Consortium (FCEC), 2010). As harmful
organisms are never introduced intentionally, the total plant health border
control cost can be considered as border control on unintentional
introductions.

[99]Costs of pathway management are extremely
difficult to estimate as this area of work is not yet developed. One example of
is the UK "check clean dry" campaign, costing roughly €50,000/year
over 2 years. Assuming all MS organise one such campaign in the next 5 years
(or several smaller campaigns), this would make €20,000/MS/year, in total
€540,000/year.

[100]Current costs of regulatory pathway
management within the plant health regime: €14,574,239/year (Food Chain
Evaluation Consortium (FCEC), 2010)

[101]Pending Ballast Water Convention – expected
to come into force in 2012-2013 (see Annex IV). These costs would be part of
the baseline as they would not derive from this proposal.

[102]Only in so
far as species of interest to a sector were banned, primary producers (mostly
small and microenterprises) would be affected by the introduction of a list of
IAS of EU concern, at least until the identification of suitable substitute
species,
see 6.1.3 for more details.

[103] Shine et al. 2010: current average
of €260,000/year/MS

[104] Very unpredictable and
thus impossible to quantify

[105] See cost of option 0

[106] Out of the 173 IAS that are currently
contributing to the control cost (see Annex VII), 74 are listed in SEBI. We
used this as an indication of the number of IAS contributing to the control
cost that might be listed. Assuming that the concerted action towards those IAS
could lead to a reduction of their future control costs by 50 %, and taking
into account the control cost in Table A11 in Annex VII, this would lead to a
cost saving of € 387 mio/yr.

[107] Current cost of €3.4 mio/year (see
baseline) PLUS estimation for the expansion of the work by JRC of
€170,000/year, TOGETHER €3.6 mio/year, details in Table A12

[108]Current cost of €2 mio/year (see baseline)
PLUS €80,000/year (steering group - based on costs Wildlife Trade Regulation,
assuming 3 meetings/year and 1 representative/MS, assuming a maximum travel and
subsistence cost of €800 euro/MS/meeting and €426/translation/slot for 6
languages, this would bring the cost for the Commission to €80,000/year),
TOGETHER €2.1 mio/year, detals in Table A12

[109] In terms of avoidance of damage cost
increase on the basis of data from NOBANIS, it is estimated that roughly 8 new
IAS are entering the EU each year (although many more alien species enter every
year). Based on the data on damage of the species listed in Table 3, Table A6
(Annex V) and Table A13 (Annex VII), it was estimated that the 30 IAS currently
most addressed by the Member States are causing in the longer term a damage of
€3.86 billion/year, i.e. an average of €130 million/IAS/year. This means that
if 8 new introductions a year would occur, these 8 IAS would cause a damage of
roughly €1 billion/yr in the longer term. It also means that these damages
would accumulate as every year more new IAS would enter: €1 billion/yr in the
long term after the introduction of 8 IAS in year 1, €2 billion/yr in the long
term after the introduction of an additional 8 IAS in year 2, €3 billion/yr in
the long term after the introduction of another 8 IAS in year 3, €4 billion/yr
in the long term after the introduction of another 8 IAS in year 4, and so on.
If out of the 8 new IAS entering the EU every year, 4 could be prevented from
entering or spreading, this would generate an avoided cost of roughly €0.5
billion/yr in the long term after preventing 4 IAS in year 1, avoiding €1
billion/yr in the long term after preventing an additional 4 IAS in year 2,
€1.5 billion/yr in the long term after preventing another 4 IAS in year 3, €2 billion/yr
in the long term after preventing another 4 IAS in year 4, and so on.

[110] Shine et al., 2010

[111] Food Chain Evaluation Consortium, 2011

[112] €23 mio/yr in the Netherlands (Van der Weijden et al., 2007)[112] alone could have been saved had the
introduction of species like muskrat been avoided; €205 mio/yr in England,
Scotland and Wales (Williams et
al,. 2010)[112] saved if Japanese knotweed had not been
introduced

[113] Taking the SEBI list as a reference, no
species of agricultural interest were identified. When it comes to biomass
production, and forestry, species are usually selected for their fast growth
and adaptability, characteristics that can make an alien species invasive.
However, for these sectors, only one species of commercial interest, black
locust, is in the SEBI list, thus a list of IAS of EU concern will have a
limited impact. As for the horticultural sector, which relies especially on the
growing and sales of ornamental (often alien) species, the SEBI list includes
11 plants with a commercial interest. However, these plants are generally not
of high value – only 4 of these species were considered of economic value by
nurseries – and species substitution with non-invasive or native species would
generally be possible (more
information in Alter IAS project).

[114]
Reinhardt et al., 2003

[115]
European Pet Organisation, pers. comm.

[116] Listing of species will be based on risk
assessments (see section 5.3.1), carefully evaluating positive and
negative impacts of the concerned species, and taking into consideration directly
and indirectly depending businesses, including SMEs, and the whole supply
chain.

[117] Listing of species will be based on risk
assessments (see section 5.3.1), carefully evaluating positive and
negative impacts of the concerned species, and taking into consideration
directly and indirectly depending businesses, including SMEs, and the whole
supply chain.

[118] American mink accounts for 92 % of the
stock of animals bred for fur in Europe. Europe accounts for 60% (31.3 million
pelts) of world mink production (EFBA)

[119] Kemives et al. 2006

[120] Shine et al., 2010

[121] Van der Wijden et al., 2007

[122] Reinhardt et al., 2003

[123] Sonigo et al. 2011

[124] Williams et al., 2010

[125] This figure is
higher than the interval of 50,000 and €14 million per invasion to eradicate
IAS because it refers not only to eradication but also containment and control
of widely spread species that need to be pursued indefinitely

[126] Shine et al. 2010

[127] Estimation of the cost of the
CITES-permitting system (incl. permitting and scientific advise), based on
current costs in Member States: 1.5 to 3 FTE, issuing <100 to 1000 permits
per year, would cost €60,000 to €112,500 per year. Taking a very rough
average of those figures, 550 permits would cost €86,250, or €157 per permit.

[128] Aggregated data on
similar provisions already in place was not available, since such schemes are
usually managed at the local administrative level.

[129] This is because having to carefully
consider the implications of releasing a species will force operators to look
at the possible consequences of such release, protecting them from future
liabilities in case a species became problematic, if they can demonstrate that
they complied with the permit requirements. Additional benefits of such
approach would be that operators, on the basis of the knowledge gathered in
preparing permit applications, would become more aware of the possible
consequences of their activities and potentially reconsider certain practices,
which could lead to a business model mindful of the issue of IAS.

[130] It has been estimated
that in Europe there are at least 55,000 woody plant and perennial species
available for sale. See http://www.alterias.be/en/list-of-invasive-and-alternative-plants/alternative-plants

[131] They will depend on the species in question and the
circumstances and environment where it is detected

[132]
Williams et al., 2010

[133]
Panzacchi et al., 2007

[134]Only in so
far as additional species of
interest to a sector were requiring a permit for release, primary
producers
(mostly small and microenterprises) would be affected by the introduction of
IAS of Member
State
concern, see
6.1.4 for more details.

[135]Primary
producers (mostly small and microenterprises in agriculture, forestry and
horticulture), would be negatively impacted by the introduction of a ban on
release unless a species was placed on an EU list of alien species approved
for release: they would face opportunity costs and their business and
activities would be disrupted for the period that the necessary risk
assessments are being carried out – very difficult to quantify.

[136] Public authorities
would face the costs of carrying out the risk assessments to be able to include
species on the EU list of alien species approved for release. The number of
risk assessments to create a list of approved alien species could be large, as
it would include all new species intended for release into the environment.

[137] Very unpredictable and thus impossible to quantify, however through IAS
of MS concern less IAS will circumvent the prevention

[138] Very unpredictable and thus impossible to quantify, however thanks to
the EU list of approved alien species far less IAS will circumvent the
prevention

[139] Very unpredictable and thus impossible to quantify, will end up between
option 2.2 and option 2.3

[140] 0.1 to 1 FTE/yr for 27 MS at €23.2/hr x
1600hrs/yr = €100,224 to 1,002,240/yr

[141] European Fur Breeders' Association - http://www.efba.eu/

[142] Rortais, 2008

[143] Shiganova and Panov, 2009

[144] For example, if giant hogweed, which was introduced intentionally and
causes severe burns, had been prevented by an EU-wide system, health impacts
and related costs could have been avoided (giant hogweed costs Germany €1
mio/yr of medical costs. See
Reinhardt et al., 2003

[145] Bullock, 2012

[146] Bullock, 2012

[147] EPPO, 2008

[148] Substantial damage to
properties and infrastructure in the UK would have been avoided, had it been
possible to prevent the introduction of Japanese knotweed, by taking a more
precautionary approach to its release.

[149] Burt et al, 2007

[150] Shine et al. 2010

[151] Pontic rhododendron displaces native
species and affects species diversity, leading to ecosystems alterations and
losses in timber production Scalera et al., 2012

[152] Global Biodiversity Outlook, 2010

[153] For example, the black cherry was
intentionally introduced in Europe for soil improvement and wood production on
sandy soils where it grows easily. The species has now proven to be invasive
and causes significant negative impacts on forestry: a more thorough analysis
of the consequences of release might have prevented the introduction.

[154] A. Roques, Invasive patterns of alien
terrestrial invertebrates in Europe (in: Pimentel, 2011)

[155] This is also in
line with the 2008 stakeholder consultation  where 71 % of respondents
considered it very important to prevent the import of IAS into the EU and 82 %
considered it very important to prevent the introduction of IAS into the
environment.

[156]See EU 2010 set from the Streamlining
European Biodiversity Indicators initiative at:
http://biodiversity.europa.eu/topics/sebi-indicators

[157] cf. Nature Watch,
including a pilot project on IAS, is presently under development at the
European Environment Agency

[158]
http://ec.europa.eu/environment/nature/invasivealien/docs/results\_consult.pdf

[159]
http://www.acceptance.ec.europa.eu/environment/nature/invasivealien/docs/ias\_discussion\_paper.pdf

[160] http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/stakeholder\_03092010&vm=detailed&sb=Title

[161] http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/working\_prevention&vm=detailed&sb=Title

[162] The results are available online: http://ec.europa.eu/environment/nature/invasivealien/docs/results\_consultation.pdf

[163]http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/stakeholder\_03092010&vm=detailed&sb=Title

[164]http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/working\_prevention/working\_prevention&vm=detailed&sb=Title

[165]http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/working\_prevention/working\_response&vm=detailed&sb=Title

[166]http://circa.europa.eu/Public/irc/env/ias/library?l=/general\_information/working\_prevention/management\_restoration&vm=detailed&sb=Title

[167] http://ec.europa.eu/environment/consultations\_en.htm#closed

[168] IP/08/373 in March 2008 and IP/12/199 in February 2010

[169] http://ec.europa.eu/environment/consultations/invasive.htm

[170] http://ec.europa.eu/yourvoice/consultations/2010/index\_en.htm

[171]http://ec.europa.eu/environment/nature/invasivealien/index\_en.htm

[172] http://www.europe-aliens.org/index.do

[173]
Shine et al. 2009

[174]
Kettunen et al. 2009

[175]
Shine et al.2008 and its annexes

[176] Shine
et al. 2009

[177] Shine
et al. 2010

[178]
Sonigo et al., 2011

[179]
http://ec.europa.eu/environment/nature/invasivealien/

[180]
Kettunen et al., 2009

[181] Shine
et al,. 2010

[182]
http://www.eea.europa.eu/data-and-maps/indicators/invasive-alien-species-in-europe/invasive-alien-species-in-europe

[183]
Genovesi et al., 2007

[184]
http://www.eea.europa.eu/publications/information-system-invasive-alien-species

[185]
http://www.cbd.int/convention

[186]
https://www.ippc.int/IPP/En/default.jsp

[187]
http://www.wto.org/english/tratop\_e/sps\_e/spsagr\_e.htm

[188]
Based on Shine et al. 2010

[189]
http://ec.europa.eu/environment/nature/pdf/council\_concl\_0609.pdf

[190]
https://toad.cor.europa.eu/BrowseDocuments.aspx?type=1&folder=cdr\deve-iv\dossiers\deve-iv-039

[191]http://eescopinions.eesc.europa.eu/EESCopinionDocument.aspx?identifier=ces\nat\nat433\ces1034-2009\_ac.doc&language=EN

[192] COM(2011)244

[193] Based on Sonigo et al. 2011 and
feedback from Member States representatives that participated in the IAS
Working groups.

[194] Hulme and Weser, 2011, Diversity and Distributions, 1-9.

[195] EEA Technical report No5/2010

[196]
http://www.alterias.be/en/list-of-invasive-and-alternative-plants/alternative-plants

[197] SEBI-list:
list of 167 IAS threatening biodiversity in Europe, recognised as being
particularly harmful in Europe, across ecosystems and major taxonomic groups
produced in the framework of SEBI (Streamlining European Biodiversity
Indicators), see http://www.eea.europa.eu/publications/technical\_report\_2007\_11

[198] Scalera, 2010

[199] The additional costs of option 1 are
thought to be very limited in comparison with option 0 (policy management
including additional guidelines, voluntary codes of conduct and awareness
rising), therefore the cost of action of these two options has been estimated
to be similar.

[200] Shine et al. 2010

[201] €8,000/year/vessel
(based on http://globallast.imo.org/Monograph\_19\_Economic\_Assesment\_web.pdf)
x 13,616 vessels in the EU (based on
http://www.ecsa.eu/images/files/downloads\_annualreports/Rapport%202010-2011.pdf)

[202] Shine et al. 2010

[203] Pending Ballast water
Convention

[204] Shine et al. 2010

[205] Those costs are currently borne by public authorities (EU (LIFE),
Member State and local level) and private operators

[206] Based on data on current management costs, an average cost per acting MS
per addressed IAS per year was estimated for a series of species groups (Table
A10, Annex VII). Next, building on the overview of IAS which MS are currently
managing at the MS-level (Table A6, Annex V) and on the cost estimates in Table
A10, the total current management cost was estimated per species group (Table
A11, Annex VII), leading to an estimated total current IAS management cost of €1.309 bio/yr. See Annex VII for further
details.

[207] Shine et al. 2010: current average
of €122,000/year/Member State

[208] Estimated investment in NOBANIS, has been funded by some Member States

[209] Estimated investment by the Joint Research Centre: €690,000 in 3 years
= €230,000/year

[210] (27 MS x €122,000/year) + €120,000-140,000/year + €230,000/year

[211] Shine et al. 2010: based on current
average of €117,900/year/MS

[212] Shine et al. 2010: current cost of
EU-level risk assessment is €42,000 per assessment. Assuming that all 167 IAS
on the SEBI-list would be assessed during the next 5 year, this would make 33
risk assessments/year or 1.4 mio/year. The cost per risk assessment could be
higher, in particular when adding more economic information, but potentially
replacing 27 risk assessments by one risk assessment will lead to considerable
cost savings.

[213] Thanks to integration in current controls
on live animals and plants for planting. Based on the costs of similar
exercises coordinated by the services in charge of customs and taxation of the
Commission, it was estimated that a small project to develop guidelines for
customs on IAS consisting of 3-4 meetings of 10 experts would costs
€20,000-30,000 in total, using Commission facilities and excluding translation
costs

[214] Pending Ballast Water Convention –
expected to come into force in 2013 (see Annex IV). These costs would be part
of the baseline as they would not derive from this proposal.

[215]Current costs for border control in plant
health: €26 mio/yr (Food Chain Evaluation Consortium (FCEC), 2010). As harmful
organisms are never introduced intentionally, the total plant health border
control cost can be considered as border control on unintentional introductions.

[216]Costs of pathway management are extremely
difficult to estimate as this area of work is not yet developed. One example of
is the UK "check clean dry" campaign, costing roughly €50,000/year
over 2 years. Assuming all MS organise one such campaign in the next 5 years
(or several smaller campaigns), this would make €20,000/MS/year, in total
€540,000/year.

[217]Current costs of regulatory pathway
management within the plant health regime: €14,574,239/year (Food Chain Evaluation
Consortium (FCEC), 2010)

[218] 0.1 to 1 FTE/yr
for 27 MS at €23.2/hr x 1600hrs/yr = €100,224 to 1,002,240/yr

[219] Shine et al. 2010: current average
of €260,000/year/MS

[220] Based on data on current management costs, an average cost per acting MS
per addressed IAS per year was estimated for a series of species groups (Table
A10, Annex VII). Next, building on the overview of IAS which MS are currently
managing at the MS-level (Table A6, Annex V) and on the cost estimates in Table
A10, the total current management cost was estimated per species group (Table
A11, Annex VII), leading to an estimated total current IAS management cost of €1.309 bio/yr

[221] Out of the 173 IAS that are currently
contributing to the control cost (see Table A11 in Annex VII), 74 are listed in
SEBI. We used this as an indication of the number of IAS contributing to the
control cost that might be listed. Assuming that the concerted action towards
those IAS could lead to a reduction of their future control costs by 50 %, and
taking into account the control cost in Table A11 in Annex VII, this would lead
to a cost saving of € 387 mio/yr.

[222] Shine et al. 2010: current average
of €122,000/year/MS

[223] Estimate for the continuation of the
current work by JRC: €400,000/year, which is €170,000/year more than the
baseline

[224] Shine et al. 2010: (1) current
average for "IAS policy development and coordination" of
€40,000/year/MS (together €1 million/year) + (2) "development of
strategies for the MS" that do not yet have them and strategy revisions
(current average of €130,000 to 1.5 million/strategy) and "policy
assessment and support" assuming one study (current average of
€50,000/study) every 3 years (all together roughly another €1 million/year),
thus cost of (1) and (2) = €2 million/year

[225] Based on costs Wildlife Trade Regulation,
assuming 3 meetings/year and 1 representative/MS, assuming a maximum travel and
subsistence cost of €800 euro/MS/meeting and €426/translation/i-slot for 6
languages, this would bring the cost for the Commission to €80,000/year

[226] €3.860 bio/year for 30 IAS makes 130 mio/year/IAS

[227] It is not yet known what and how many
species would need to be included in the EU list of banned IAS as the list
would be built on the basis of risk assessment and discussions with Member
States.

[228]The European and Mediterranean Plant
Protection Organisation (EPPO) is currently performing risk assessments for
invasive alien plants.

[229] Based on an analysis of current costs of risk assessment frameworks and
risk assessments within the EU

[230] Shine
et al., 2010

[231] Shine
et al., 2010

[232] See impact assessment revision Regulation 882/2004 on Official Control

[233] Shine et al,. 2010

[234] EPPO Alert List  Parthenium hysterophorus RS 2011/068

[235] Bonesi, 2009

[236] European Fur Breeders' Association

[237] European Fur Breeders' Association

[238] Project Alter- IAS: http://www.alterias.be/

[239] See for example the list of alternative
plants produced by the project Alter-IAS: http://www.alterias.be/en/list-of-invasive-and-alternative-plants/alternative-plants

[240]
Shiganova & Panov, 2009

[241]https://consultations.rics.org/gf2.ti/f/275138/6179845.1/pdf/-/Japanese%20Knotweed%20and%20residential%20property.pdf

[242]
https://secure.fera.defra.gov.uk/nonnativespecies/index.cfm?sectionid=98

[243] Current costs of registration and certification within the plant health
regime

[244] FCEC, 2011

[245] Bullock  (2012)

[246] Williams et al., 2010

[247] http://archives.eppo.int/MEETINGS/2008\_conferences/eichhornia\_files/06\_cifuentes/cifuentes42.HTM

[248]
Reinhardt et al., 2003

[249]
Van der Weijden et al., 2007

[250] Reinhardt et al., 2003

[251] Shine et al, 2010

[252] Reinhardt et al., 2003

[253] http://www.alterias.be/en/list-of-invasive-and-alternative-plants/alternative-plants

[254] http://www.alterias.be/en/list-of-invasive-and-alternative-plants/alternative-plants

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