Invasive Species: Clearer Focus and Greater Commitment Needed to Effectively Manage the Problem
Published: 2002-10-22T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Harmful invasive species--nonnative plants and animals that are spreading throughout the United States--have caused billions of dollars in damage to natural areas, businesses, and consumers. In 2001, the federal government issued a National Invasive Species Management Plan to focus attention on invasive species and coordinate a national control effort involving the 20 or so federal agencies that are responsible for managing them. This report discusses the economic impacts of invasive species, implementation of the management plan, and coordination of U.S. and Canadian efforts to control invasive species, including those introduced to the Great Lakes via the ballast water of ships.
section_title: What GAO Found
paragraphs: Existing literature on the economic impacts of invasive species is of limited usefulness to decision makers, although it indicates that the effects of invasive species are significant. Most economic estimates do not consider all of the relevant effects of nonnative species or the future risks that they pose. New initiatives may prompt more comprehensive analysis that could help decision makers make better resource allocations. While the National Invasive Species Management Plan calls for many actions that are likely to contribute to preventing and controlling invasive species in the United States, it does not clearly articulate specific long-term goals toward which the government should strive. In addition, the federal government has made little progress in implementing the actions called for by the plan. Even with high levels of compliance, U.S. regulations have not eliminated the introduction of invasive species into the Great Lakes via the ballast water of ships. The United States and Canada are working on strengthening the existing control system, but developing stronger regulations and the technology needed to meet them will take many years. The continued introduction of invasive species could have high economic and ecological costs for the Great Lakes.

section_title: Letter
paragraphs: Harmful invasive species— nonnative plants and animals that are spreading throughout the United States—have caused billions of dollars in damage to natural areas, businesses, and consumers. In 2001, the federal government issued a National Invasive Species Management Plan to focus attention on invasive species and coordinate a national control effort involving the 20 or so federal agencies that are responsible for managing them. This report discusses the economic impacts of invasive species, implementation of the management plan, and coordination of U.S. and Canadian efforts to control invasive species, including those introduced to the Great Lakes via the ballast water of ships.
Existing literature on the economic impacts of invasive species is of limited usefulness to decision makers, although it indicates that the effects of invasive species are significant.  Most economic estimates do not consider all of the relevant effects of nonnative species or the future risks that they pose.  New initiatives may prompt more comprehensive analysis that could help decision makers make better resource allocations.
While the National Invasive Species Management Plan calls for many actions that are likely to contribute to preventing and controlling invasive species in the United States, it does not clearly articulate specific long-term goals toward which the government should strive.  In addition, the federal government has made little progress in implementing the actions called for by the plan.
Even with high levels of compliance, U.S. regulations have not eliminated the introduction of invasive species into the Great Lakes via the ballast water of ships.  The United States and Canada are working on strengthening the existing control system, but developing stronger regulations and the technology needed to meet them will take many years.  The continued introduction of invasive species could have high economic and ecological costs for the Great Lakes.
GAO recommends that the National Invasive Species Council (1) incorporate data on the economic impacts of invasive species in developing the federal government’s budget; (2) add performance-oriented goals and objectives to its updated plan; (3) give high priority to an oversight strategy for measuring progress against results-oriented goals; and (4) examine whether the council is being hampered in its implementation of the plan by the lack of specific legislation. Agencies generally agreed with GAO’s recommendations.
The Honorable Ann M. Veneman Secretary of Agriculture The Honorable Gale A. Norton Secretary of the Interior The Honorable Donald L. Evans Secretary of Commerce Invasive species—harmful, nonnative plants, animals, and  microorganisms—are found throughout the United States, causing  damage to crops, rangelands, waterways, and other ecosystems that is  estimated in the billions of dollars annually. Some have termed invasive  species “biological pollutants.” Unlike some chemical pollutants that can  degrade over time, biological pollutants have the potential to persist,  multiply, and spread. In addition to their economic costs, invasive species  can have a devastating effect on natural areas, where they have strangled  native plants, taken over wetland habitats, crowded out native species, and  deprived waterfowl and other species of food sources. Conservation  biologists rank invasive species as the second most serious threat to  endangered species after habitat destruction. Overall, scientists,  academicians, and industry leaders are recognizing invasive species as  one of the most serious environmental threats of the twenty-first century.  We have issued two prior reports on this subject: one on funding to address  invasive species and the other on the government’s approach for quickly  responding to invasions by new species.
In February 1999, in response to the challenges faced by state and federal  agencies to minimize the spread of invasive species, President Clinton  issued Executive Order 13112. The order directs federal agencies to take  actions that will prevent the introduction of invasive species; provide for  their control; and minimize their impact on the economy, the environment,  and human health. The order established the National Invasive Species  Council, which now comprises the heads of 10 federal departments and  agencies, to provide national leadership and coordination in federal  invasive species activities and to issue a national invasive species  management plan. The order also directed the Secretary of the Interior  to establish an advisory committee to provide information and advice to  the council.
The problem of invasive species is an international one. Organisms are  brought, intentionally or unintentionally, from one country to another. They  may also spread on their own across international borders. Because of the  international aspects of the issue, as well as the seriousness of the problem  for both Canada and the United States, we undertook a review of federal  invasive species management in cooperation with the Office of the Auditor  General of Canada. One issue of particular importance to both countries is  preventing aquatic invasive species from entering the Great Lakes in the  ballast water of ships. We and the Auditor General are issuing  simultaneous but separate reports. The Office of the Auditor General’s  Report of the Commissioner of the Environment and Sustainable  Development to the House of Commons contains a chapter on Canada’s  invasive species management efforts.
The objectives of our review were to (1) assess the usefulness of analyses  that have estimated the economic impact of invasive species in the  United States to federal decision makers responsible for preventing and  controlling their spread; (2) assess the National Invasive Species  Management Plan, including the extent to which the plan has been  implemented; (3) provide the views of experts on the adequacy of  U.S. and Canadian federal government efforts to prevent the introduction  of invasive species into the Great Lakes via the ballast water of ships; and  (4) describe how the United States and Canada are coordinating invasive  species management efforts.
Among the efforts we undertook to analyze these issues was a survey  of all 32 members of the Invasive Species Advisory Committee. About  74 percent of the committee members responded to our survey and  68 percent completed it. We also observed meetings of the committee.  See appendix I for further details on our scope and methodology.
subsections: section_title: Background
subsections: section_title: Invasive Species Threaten the Economy and the Environment
paragraphs: As we have reported in the past, the impact of invasive species in the  United States is widespread, and their consequences for the economy  and the environment are profound. They affect people’s livelihoods and  pose a significant risk to industries such as agriculture, ranching, and  fisheries. The cost to control invasive species and the cost of damages they  inflict, or could inflict, on property or natural resources are estimated to  total billions of dollars annually. For example, according to the  U.S. Department of Agriculture (USDA), the Formosan termite causes at  least $1 billion annually in damages and control costs in 11 states (in 2001  dollars). USDA also estimates that, if not managed, fruit flies could cause  more than $1.8 billion in damage each year (in 2001 dollars).
According to the National Invasive Species Council, hundreds, and perhaps  thousands, of nonnative species have established populations in the United  States. Invasive species continue to be introduced in new locations, with  recent examples including the northern snakehead fish in Maryland and the  emerald ash borer in Michigan. Many scientists believe that invasive  species are a significant threat to biodiversity and are major or contributing  causes of population declines for almost half the endangered species in the  United States. Invasive species can alter entire ecosystems by disrupting  food chains, preying on critical native species such as pollinators,  increasing the frequency of fires, or—as in the case of some plants—simply  overshadowing and smothering native plants. Invasive species may arrive  unintentionally as contaminants of bulk commodities such as food, in  packing materials and shipping containers, or in ships’ ballast water. Others  may be introduced intentionally; kudzu, for example—a rapidly growing  invasive vine that thrives in the southeastern United States—was  intentionally introduced from Japan as an ornamental plant and was used  by USDA in the 1930s to control soil erosion. Other invasive species are  imported as crops, livestock, aquaculture species, or pets, and later escape  or are released into the environment. (See fig. 1 for details on the mute  swan, intentionally introduced to adorn parks and private bird collections.)
Not all nonnative species, however, cause harm. Many nonnative species,  such as cattle, wheat, soybeans, many fruits, and ornamental plants (such  as tulips and chrysanthemums), have been largely beneficial and their  propagation controllable. Various terms have been applied to invasive  species, including “alien,” “exotic,” “nonindigenous,” and “nonnative.”  In this report, we use the definition provided by Executive Order 13112,  which states that an invasive species is an alien species whose introduction  does or is likely to cause economic or environmental harm or harm to  human health. An alien species is one that is not native to a particular  ecosystem. (We used this definition, as well as other factors, in selecting  species to profile in this report.)
section_title: The Federal Government Conducts a Variety of Invasive Species Activities
paragraphs: More than 20 federal agencies in 10 departments—including USDA,  Commerce, Defense, and the Interior—have responsibility for some aspect  of invasive species management. (See fig. 2.) States also have a significant  management role, but the extent of their involvement varies considerably.  USDA has the largest federal role because of its responsibility to  (1) conduct port-of-entry inspections and quarantine goods coming into the  country, (2) manage more than 190 million acres of national forests and  grasslands, (3) conduct research, and (4) provide technical assistance to  the private sector and in large agricultural pest control projects. We  reported that in fiscal year 2000, seven of the departments obligated more  than $624 million for activities related to invasive species management.  According to the council, appropriations to those departments for such  activities increased in fiscal year 2001 to approximately $1.05 billion, of  which USDA received almost $975 million.
In February 1999, invasive species prevention and control efforts  received heightened attention with the issuance of Executive Order 13112.  The executive order established the National Invasive Species Council,  which is now made up of the secretaries and administrators of 10 federal  departments and agencies. The executive order required the Secretary  of the Interior to establish an advisory committee to provide information  and advice to the council. Accordingly, in November 1999, the  secretary established the Invasive Species Advisory Committee,  composed of 32 nonfederal members representing a range of interests  relevant to invasive species, including academia, environmental  organizations, industry, trade associations, Native American tribes, and  state government.
The executive order also required that the council develop a national  invasive species management plan using a public process and revise it  biennially. Among other things, the executive order called for the plan to  (1) recommend performance-oriented goals and objectives and specific  measures of success, (2) recommend measures to minimize the risk of new  introductions of invasive species, and (3) review existing and prospective  approaches and authorities for preventing the introduction and spread of  invasive species. The council and its staff worked with members of the  advisory committee and other interested parties to produce draft  management plans for public comment. In January 2001, the council issued  the final plan, which identifies nine categories of planned actions to aid in  the prevention, control, and management of invasive species in an effort to  minimize their economic, environmental, and human health impacts. (See  fig. 3.) The council’s plan calls for member departments to implement a  total of 86 discrete actions, each with an associated due date or start date.  Examples of the actions include establishing and coordinating long- and  short-term capacities for basic and applied research on invasive species  and gathering and disseminating information on the council’s Web site.
section_title: The United States and Canada Face Many Difficult Issues Related to Managing Invasive Species
paragraphs: The United States and Canada have a mutual interest in limiting the  introduction or spread of invasive species across their borders. The two  countries share more than 5,500 miles of terrestrial and aquatic border that  provide potential pathways for invasive species. Each country is the other’s  largest trading partner, sending and receiving a variety of goods, such as  crops, livestock, wood, and horticultural products, that can harbor invasive  species. Therefore, species that enter one of the two countries have  opportunities to spread into the other.
The Great Lakes—a shared U.S. and Canadian resource—have been  subject to invasion by nonnative species since the settlement of the region.  At least 160 nonnative aquatic organisms have become established in the  lakes since the 1800s, most of which have come from Europe, Asia, and the  Atlantic coast. More than one-third of the organisms have been introduced  in the past 30 years, a trend coinciding with the opening of the St. Lawrence  Seaway in 1959 and other changes in ship operations. Ballast water in ships  is considered a major pathway for the transfer of invasive aquatic  organisms to the Great Lakes. Ballast is essential to the safe operation of  ships because it enables them to maintain their stability and control how  high or low they ride in the water. Ships take on or discharge ballast water  over the course of a voyage to counteract the loading or unloading of cargo,  and in response to sea conditions. The ballast that ships pump aboard in  ports and harbors may be fresh, brackish, or salt water. These waters may  contain various organisms that could then be carried to other ports around  the world where they might be discharged and survive.
Canada adopted voluntary ballast water management guidelines in 1989  in response to the 1988 discovery of nonnative zebra mussels in  Lake St. Clair. The Canadian guidelines were superceded by new guidelines  in 2000 and encourage ships’ masters entering the Great Lakes and other  waters under Canadian jurisdiction to employ management practices— such as exchanging ballast water in the open ocean—to minimize the  probability of future introductions of harmful aquatic organisms. They also  direct ships’ masters to provide ballast water details to Canadian  authorities. The United States followed the Canadian lead and passed the  Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990. This  legislation directed the Secretary of Transportation to issue voluntary  ballast water guidelines and regulations for the Great Lakes. Joint United  States and Canadian voluntary guidelines, which closely tracked the 1989  Canadian guidelines, went into effect in March 1991. The U.S. Coast Guard  issued the first set of mandatory ballast water regulations for the  Great Lakes in April 1993. The National Invasive Species Act of 1996  amended the 1990 act and required the Secretary of Transportation to issue  voluntary ballast water guidelines for the rest of the United States.
section_title: More Comprehensive Analysis of the Economic Impacts of Invasive Species Would Better Inform Decision Makers
paragraphs: The scope of existing analyses of the economic impact of invasive species  in the United States range from narrow to comprehensive. Narrowly  focused analyses include estimates of past damages that are limited to  commercial activities such as agricultural crop production and simple  accountings of the money spent to combat a particular invasive species.  These estimates typically do not include the economic impact of these  species on natural ecosystems, the expected costs and benefits of  alternative measures for preventing their entry or controlling their spread,  or the impacts of possible invasions by other species in the future. On the  other hand, more comprehensive—and rare—analyses are those that  examine the past and prospective economic impact of invasive species to  both commercial activities and natural ecosystems and the potential costs  of preventing or controlling them. Few analyses have been done that  examine the likelihood that new species will invade new locations and that  estimate their costs. Although the estimates we reviewed may have served  the purpose for which they were intended, the narrow scope of many of  them may limit their usefulness to decision makers formulating federal  policies on prevention and control. In general, the more comprehensive the  approach used to assess the economic impacts of invasive species, the  more likely its usefulness to decision makers for identifying potential  invasive species, prioritizing their economic threats, and allocating  resources to minimize overall damages. Federal agencies recognize the  value of this type of analysis and have recently taken steps to use it more  often. According to officials from several agencies, however, efforts to  improve economic impact analyses are hampered by a lack of data on  invasive species and a lack of economists assigned to assessing their  economic impacts on commercial activities and natural ecosystems.
subsections: section_title: The Narrow Scope of Many Analyses May Limit Their Usefulness to Decision Makers
paragraphs: The narrow scope of many analyses of the economic impacts of invasive  species may limit their usefulness to decision makers developing policies  and allocating resources to address the problem. First, many of the  analyses we reviewed do not address the economic impact of invasive  species on natural area ecosystems. Instead, they reflect the impacts of  invasive species on commercial activities such as agricultural and  timber production and fisheries. This reflects the fact that most of the  management and control of invasive species in the United States has  focused on those species that damage agricultural crops and livestock.  For example, the Federal Interagency Committee for the Management of  Noxious and Exotic Weeds (FICMNEW) studied the economic impact of  weeds on the U.S. economy and found the estimated value of losses from  invasive weed species to be about $15 billion per year.12,  However, the  committee reported that the economic impact on most nonagricultural  sites was not available. Focusing solely on the impact of invasive species  on commercially valuable activities ignores the potential impact of invasive  species on ecosystems as a whole, possibly understating the impact of  these species. Consistent with that point, according to the Environmental  Protection Agency, the true cost of invasive species is underestimated if  estimates of damages do not include lost ecosystem services, such as water  purification and aesthetic values.
Federal Interagency Committee for the Management of Noxious and Exotic Weeds,  Invasive Plants: Changing the Landscape of America, Fact Book, Washington, D.C.:  FICMNEW, 1998.
Second, many of the existing analyses do not fully account for the expected  costs and benefits that are associated with different control methods for  invasive species. Two frequently cited summations of the aggregate  impacts of invasive species in the United States were based on estimates of  this type. The first, by the U.S. Office of Technology Assessment (OTA),  estimated that by 1991 at least 4,500 nonnative species had become  established in the United States, of which about 600 had caused severe  harm. The OTA was able to obtain data showing that the economic impact  of 79 of these species totaled about $118 billion between 1906 and 1991 and  impact included damage to agricultural crops, industrial activities, and  human health. The second effort was by researchers at Cornell University  who estimated in 1999 that approximately 50,000 nonnative plant and  animal species are known to have entered the United States—although not  all have established harmful populations—and that the overall cost of the  harmful species is about $137 billion annually. However, the estimates  that these aggregate studies relied on typically did not include an analysis  of whether control measures are desirable given their costs or what the  most cost-effective methods for preventing or controlling particular  invasive species would be. (Many of the estimates included in these  aggregate studies also lack information on the impact of invasive species  on natural area ecosystems.)
It is not unusual for analyses to lack information for the assessment of the  cost-effectiveness of prevention and control measures. The most complete  data on invasive species damages, and prevention and control costs and  effectiveness are available for known pests that the USDA has identified as  serious threats to agriculture on the basis of past invasions. These include  diseases and pests such as the virus that causes foot-and-mouth disease,  citrus canker, and the Mediterranean fruit fly. Yet, even for these pests,  relatively little is known about the likely success of alternative methods for  preventing their entry or controlling their spread. For example, an official  in charge of risk analysis for USDA’s Animal and Plant Health Inspection  Service (APHIS) told us that there is a general lack of information on the  likely success of different measures—short of outright bans on the  importation of some products—that could be used to prevent the  importation of invasive species into the country. He said that even for a  pest such as the one that causes foot-and-mouth disease, for which the  potential costs of an outbreak have been studied, data are not available on  the cost-effectiveness of many prevention methods. Prevention methods  could range from a ban of all products that might carry the disease from all  countries known to harbor it to less stringent restrictions that allow more  trade but that might provide less protection. For invasive species that have  previously entered the United States and caused damages, there is also  little information available on the likelihood that they will do so again at  particular times and by particular pathways. Even less information of this  nature is available for non-agricultural pests. More comprehensive analyses  that include such information may help decision makers allocate limited  resources among different prevention and control efforts.
A third way in which the narrow scope of many estimates may limit their  usefulness is that they focus on the impact of species that are known to  cause problems but do not provide decision makers with information on  the likelihood that new species will invade and cause damage. The typical  estimate includes data on the damages already caused by species or the  money spent to control them. The OTA and Cornell estimates mentioned  above are largely based on these types of estimates. Other examples  include USDA’s report that it cost about $26 million between 1996 and 2000  to remove trees infested with Asian long-horned beetle in New York and  Illinois and the estimate by North Dakota State University researchers in  1996 that three species of knapweed cause about $48 million per year in  damage to Montana’s economy. Data such as these can be used to  estimate the continued effects of a species in the same location or the  potential effects in a new location. For example, researchers used data on  the effects that the European green crab had had on East Coast fisheries to  estimate that this invasive species could damage native oyster, clam and  crab fisheries on the West Coast by as much as $54 million per year. (See  fig. 4 for more information on the European green crab.)
However, experts in biological invasions caution that it is difficult to  extrapolate from a past invasion event to introductions of new species that  have not occurred. According to an official with the Department of the  Interior, decision makers need guidance on which potential invasive  species pose the greatest threat to the United States and how to best design  policies for combating them. Some researchers suggest that the best way of  protecting ourselves from invasive species is to try to predict new arrivals  of potentially invasive species, study the basic biology of probable new  arrivals, and work on biological controls for them as part of a program for  early detection and rapid response. One environmental scientist has  suggested that one of the best ways to predict the introduction of and  damage from species new to the United States is to study recent  introductions of species into other countries that have ecosystems similar  to those in this country. While USDA and others have done some studies  of this type, particularly for agricultural pests, the preponderance of  economic analysis has focused on species that have already invaded the  United States rather than on new species that could invade in the future.
section_title: More Comprehensive Analyses Are Potentially More Useful to Decision Makers
paragraphs: While most of the analyses that we reviewed have limitations in their scope  that lessen their usefulness to decision makers, some used a more  comprehensive approach. Some analyses accounted more fully for the  expected costs and benefits to producers and consumers of different  control measures. For example, to further improve analysis of the expected  costs and benefits of control measures, the Risk Assessment and  Management Committee under the Aquatic Nuisance Species Task Force  expanded the scope of existing federal risk assessment processes and  methodologies to include the socioeconomic impacts of invasive species.  In a case study covering, in part, the effects of importing the Asian black  carp, U.S. Geological Survey (USGS) researchers balanced the potential for  economic gains from intentionally introducing this species—it eats snails  that may harbor parasites in fishponds and zebra mussels in the wild— against the potential for economic and environmental damage if it became  established in the wild. Risks were estimated by expert judgment. Based  upon the outcome of the assessment, the Aquatic Nuisance Species Task  Force decided that establishment of this species would create an  unacceptable level of potential harm. The U.S. Fish and Wildlife Service has  proposed amending its regulations to add the Asian black carp to a list of  injurious fish, crustacean, and mollusk species that are not allowed to be  imported into the United States.
Researchers also recently discussed how the benefits from integrating risk  assessment and benefit cost analysis into the regulatory process can  provide decision makers with more information than is available when only  a single dimension of information is considered. These two dimensions of  information give decision makers an opportunity to evaluate the tradeoffs  that they face when they choose among alternative regulatory measures.  The researchers addressed the question of the tradeoff between banning  the imports of commodities that may harbor invasive species and enjoying  the benefits of those commodities. As an example, they analyzed a partial  ban on imports of Mexican avocados and found that, based on the  assessment of invasion risk alone, the ban seemed to have greater benefits  than costs. However, when they incorporated into their analysis the costs  to U.S. consumers that the ban would impose in terms of reduced  availability of low-cost avocados, they found that less stringent regulations  would likely be more desirable than the ban.
As another example, the same researchers demonstrated the benefit of  integrating benefit cost analysis and risk assessment simultaneously into  the evaluation of risk management options for the invasive fungus that  causes Karnal bunt disease in wheat. In this case, they illustrated how  analyses that estimate invasion risks and costs and benefits for control  programs for this species but do not adjust benefit estimates of the control  program components for risk may not help decision makers choose control  policies with the greatest overall benefit. USDA had estimated that the  Karnal bunt fungus could cause more than $500 million per year in  damages to the U.S. wheat industry by reducing the amount of wheat  suitable for export and had adopted a program to control the spread of the  fungus. However, researchers found that the USDA’s estimate was  incomplete, in part because it focused on reducing the probability of an  outbreak of the disease by adopting multiple quarantine options but did not  examine whether each option was an economically efficient quarantine  policy. When the researchers examined these options individually, they  were able to identify the most efficient options, that is, those imposing the  least cost on producers. According to these researchers, by not adopting  only the most efficient options, the costs of the agency’s program for  controlling the spread of the fungus exceeded the program’s benefit. The  researchers suggest that failure to look at the expected marginal benefits  and costs of various quarantine options may have led to the adoption of an  unnecessarily costly quarantine policy.
Another way in which some estimates have been more comprehensive is by  including an examination of the impact of invasive species on more than  just commercial commodities. For example, in estimating the effect of  gypsy moth caterpillars on forest trees, researchers estimated that benefits  from programs that would slow their spread would be between $1 billion  and $4.8 billion in present value, depending on their rate of spread and the  control programs adopted, in increased timber production, recreational  opportunities, residential and scenic land values, water quality and other  amenities, over 25 years. In another example, researchers used an  economic model based on property values to estimate damages to  lakefront properties in New Hampshire from milfoil, an invasive aquatic  weed that causes serious economic, recreational, and ecological damage.  Their estimates showed that between 1990 and 1995, property values on  milfoil-infested lakes were about 16 percent lower than similar properties  on uninfested lakes. According to an official with the Department of  Commerce, the state of New Hampshire adopted a program to control this  invasive weed on the basis of this study.
Finally, some analysts are taking more comprehensive approaches  by analyzing the likelihood that species will be introduced, become  established, and cause harm in particular geographic areas or via particular  pathways. For example, a researcher has built upon earlier USDA work on  pest risk assessment to evaluate the likelihood of establishment of  Eurasian poplar leaf rust.  The researcher combined information on the  incidence of the disease and the location of susceptible plant hosts in the  United States with data on past invasions of this species in similar  ecosystems abroad, to assess the likely danger to geographic areas in the  United States.
In another example, USDA examined the likelihood that the Eurasian  pine shoot beetle would enter and spread via various pathways and which  pathways would impose the greatest risk of harm. This beetle emerged as  a new and potentially serious pest of timber in the upper midwestern  United States in 1992. Potential losses from the beetle were large, and the  state of Michigan proposed 25 mitigation measures that would have  included large expenditures on pesticide sprays. USDA’s analysis, which  included a risk assessment of the likely pathways by which the beetle might  spread, showed that 99.8 percent of the risk of spread occurred by one  pathway in a 2-week period during the timber’s processing. Using this  information, the timber industry took appropriate control measures during  this 2-week period to effectively manage the risk at low cost and without  the need for regulation.
section_title: Recent Actions May Prompt More Comprehensive Analyses
paragraphs: Recent federal actions may help to prompt further improvements in the  economic impact analysis available to decision makers. Among other  things, Executive Order 13112 calls on federal agencies to prevent the  introduction of invasive species, and to detect, respond rapidly to, and  control them in a cost-effective and environmentally sound manner. The  executive order also directs agencies to determine that the benefits of  any actions they take that are likely to cause or promote the introduction  or spread of invasive species clearly outweigh the potential harm caused by  the species and to take measures to minimize the risk of harm in  conjunction with these actions. Implementing the order will thus  require agencies to undertake more comprehensive studies of risks, costs,  and benefits.
In addition, the federal Aquatic Nuisance Species Task Force has  developed a process to evaluate the risk of introducing nonnative  organisms into a new environment and, if needed, determine the correct  management steps to mitigate that risk. The task force has also developed  guidelines to provide direction to assist states in the development of their  own management plans for aquatic nuisance species. The guidance,  formally adopted by the task force in 2000, emphasizes a need for feasible,  cost-effective, comprehensive plans that can be developed quickly, and can  be used to focus on the most pressing species problems that can be  effectively managed. As an example of how these efforts have been used,  the U.S. Fish and Wildlife Service, USDA’s Animal and Plant Health  Inspection Service, and the National Oceanic and Atmospheric  Administration, in conjunction with state authorities, have prevented the  spread of the aquatic weed caulerpa in U.S. coastal waters.
USDA has also taken recent steps to refine its risk assessment practices.  Over the years, in making decisions about allowing the importation of  certain agricultural commodities from countries known to harbor  potentially serious plant pests, USDA occasionally used analysis that led to  partial rather than outright bans of those commodities in recognition of  both risks of invasion and the benefits that consumers would obtain from  access to that commodity. An impetus for doing more of this type of  analysis was international trade agreements that call for the United States  and others to use the least restrictive measures to protect against invasive  pests. In other words, the trade agreements prohibit countries from  imposing outright bans of certain agricultural commodities if biological and  economic data show that partial bans would be just as effective. Partly in  response to these agreements, USDA’s Animal and Plant Health Inspection  Service issued for the first time in August 2001 guidelines for the agency to  use when assessing the risks posed by diseases and pests. These  guidelines state that risk assessments should consider the probable  biological and economic consequences of the entry and establishment of  invasive species, as well as the likelihood that those species will enter.  However, according to the chief of APHIS Risk Assessment Systems,  agency assessments done in the past frequently focused on the  likelihood that species will enter and become established and, because of a  lack of credible data, were less focused on their biological and  economic consequences.
Moreover, USDA recently established a task team to improve the ways in  which risk assessment is incorporated into the department’s analyses of the  economic impacts of invasive species. Agency officials said that this effort  would better enable federal decision makers to adhere to Executive Order  13112’s emphasis on a risk-based approach to dealing with invasive species.  In addition, the officials said that the information generated by the task  team would also help the National Invasive Species Council implement the  national management plan, which calls for a risk-based approach to  preventing potential invasive species from becoming established.
Officials from the National Invasive Species Council staff and departments  within the council agreed that improved economic analysis would help  the federal government develop an overall budget for invasive species  programs. However, they cautioned that the capacity of the federal  government to do this work is limited. Specifically, there are limits to the  data available on the biology of invasive species and the impacts they  have—particularly on natural ecosystems—and the effectiveness of control  methods. The officials also stated that there are not enough resources  devoted to analyzing the impacts of invasive species.
section_title: The National Management Plan Lacks a Clear Long- Term Outcome, and Its Implementation Has Been Slow
paragraphs: While the National Invasive Species Council’s 2001 management plan,  Meeting the Invasive Species Challenge, calls for actions that are likely to  help control invasive species, it lacks a clear long-term outcome and  quantifiable performance criteria against which to evaluate the overall  success of the plan. Federal officials recognize that there are deficiencies  in the plan and are working toward improving it. At present, however, the  only available performance measure that can be used to assess overall  progress is the percentage of planned actions that have been completed by  the due dates set in the plan. By this measure, implementation has been  slow. Specifically, the council departments have completed less than  20 percent of the planned actions that were called for by September 2002,  although they have begun work on others. A large majority of the members  of the invasive species advisory committee who responded to our survey  believe that the pace of implementation is inadequate. In addition, some of  the actions that agencies have reported to the council are not clearly linked  to coordinated implementation of the management plan. Our survey and  other evidence indicate numerous reasons for the slow progress, including  delays in establishing implementation teams that will be responsible for  carrying out the planned actions, the low priority given to implementation  by the council, and the lack of funding and shortage of staff responsible for  doing the work. Another factor contributing to slow progress was the need  to transition to a new administration. However, while the national  management plan calls for many actions that would likely contribute to  preventing and controlling invasive species, even if the actions in the plan  were more fully implemented their effect would be uncertain because they  typically do not call for quantifiable improvements in invasive species  management or control.
subsections: section_title: National Invasive Species Management Plan Does Not Clearly Define a Long-Term Outcome or Contain Performance Measures
paragraphs: The national management plan does not clearly define a long-term outcome  or measures of success as are called for by sound management principles.  The executive order states that the management plan shall “detail and  recommend performance-oriented goals and objectives and specific  measures of success for federal agency efforts concerning invasive  species.” Consistent with that requirement, the council and its advisory  committee adopted as one of their guiding principles that efforts to manage  invasive species are most effective when they have goals and objectives  that are clearly defined and prioritized. Both the executive order and this  guiding principle are also consistent with the Government Performance  and Results Act of 1993, which emphasizes setting measurable goals and  holding agencies accountable by evaluating performance against  those goals.
However, the council did not articulate in the plan a long-term outcome  or condition toward which the federal government should strive. For  example, the plan does not contain overall performance-oriented goals and  objectives, such as reducing the introduction of new species by a  certain percentage or halting the spread of established species on public  lands. Instead, the plan contains an extensive list of actions that, while  likely to contribute to preventing and controlling invasive species, are not  clearly part of a comprehensive strategy.
Similarly, many of the actions in the plan call for the federal departments to  take certain steps rather than achieve specific results and do not have  measurable outcomes. For example, the plan calls for the council,  starting in January 2001, to work with relevant organizations to “expand  opportunities to share information, technologies, and technical capacity on  the control and management of invasive species with other countries.”  Another action item calls for the council to have outlined by June 2001 a  plan for a campaign to encourage U.S. travelers to voluntarily reduce the  risk of spreading invasive species overseas. Other actions call for the  council to support international conferences and seminars. We believe that  these types of actions are more process-oriented than outcome-oriented.  Taken individually, the actions may be useful, but it will be difficult to judge  whether or not they are successful and have contributed to an overall goal.
Respondents to our survey also raised concerns about the lack of  measurability in the plan. While the majority of respondents (17 of 23)  said that the plan is focused on the most important issues, 9 criticized it for  a lack of specificity or a clear mechanism for measuring effectiveness or  holding departments accountable for implementing it. Of these, several  commented that it is unclear how we will know when actions are  implemented and completed. Others noted that there are no consequences  for the council, staff, or agencies if they miss deadlines. Other stakeholders  made similar comments to us. For example, one person who was involved  in the development of the management plan told us that it represents a  “fundamentally misguided approach” and that it contains no coherent goal  or measures of success. He said that the plan should have measures of  success such as a reduction in the rate of introduction or spread of species.  Another stakeholder said that the plan is unclear with regard to what  actions would be enough to help solve the problem and echoed concerns  about the difficulty measuring success. Eight respondents to our survey,  however, made more positive comments about the degree of specificity in  the plan, stating that the plan was clear, measurable, and achievable and  that it had very specific actions with deadlines for agencies to implement.
The council acknowledged in the plan itself that many of the details  of the actions called for would require further development in the  implementation phase. The Department of the Interior’s Deputy Assistant  Secretary for Performance and Management told us that the plan was  developed with little input from people trained in performance  management processes. In addition, the Executive Director of the council  staff told us that, in her opinion, given the scope of this first-time effort, it  would have been unrealistic and difficult to also agree on specific  measurable goals. She also said that in many areas, the federal government  does not have the data on invasive species conditions needed to set long- term goals and develop better performance measures. She said that many  of the actions called for in the management plan are designed to help  develop needed data. In their comments on our draft report, EPA and the  Department of the Interior also noted that it would be difficult to apply  performance measures to invasive species management activities.
The executive order calls for the council to revise the plan by January 2003.  However, the Executive Director of the council told us that the council and  the advisory committee had agreed not to begin revising the management  plan until after the council prepares a progress report on the plan. That  report is also due to the Office of Management and Budget (OMB) in  January 2003.
The council is in the process of working with OMB on implementing one of  the planned actions that should help to establish a desired outcome and  relevant performance measures. The plan called for a crosscut budget  proposal for federal agency expenditures concerning invasive species  beginning in fiscal year 2003. The council and OMB are hoping to have a  proposal ready for the fiscal year 2004 budget cycle. According to the  Department of the Interior official responsible for this project on behalf of  the council, the proposal will represent the beginnings of a strategic plan  for the federal government’s invasive species activities. It will be  performance-oriented with common long-term goals, intermediate  goals, and definitions for the relevant departments. OMB will identify  performance measures with help from a task team of federal stakeholders  and will initially focus on early detection and rapid response, control, and  prevention. According to the council, the proposal for fiscal year 2004 will  not represent the totality of invasive species expenditures or efforts but  will primarily focus on the activities of the Departments of the Interior,  Agriculture, and Commerce.
section_title: National Invasive Species Council Departments Have Completed a Small Percentage of Actions in the Management Plan
paragraphs: While the council has not reported on implementation of the plan, we  estimate that, as of September 2002, council departments had completed  less than 20 percent of the actions that the plan had called for by that date.  The departments have started work on other planned actions, including  some that have a deadline after September 2002 and that the council  believes are a high priority. When asked to assess implementation of the  plan, 18 of the 21 advisory committee members who responded to that  question said that the council was making inadequate or very inadequate  progress. Survey comments and other evidence indicate various reasons  for the lack of progress. Delays in implementing the plan will hamper  agency efforts to prevent and control invasive species as intended by the  executive order.
subsections: section_title: Lack of Departmental Reporting Hinders Measurement of Progress
paragraphs: It has been difficult to quantitatively measure the council’s progress in  implementing the management plan because only 6 of the 10 member  departments had submitted reports summarizing the steps they had taken  to implement the plan. The plan calls for departments to submit such  reports annually beginning in October 2001. Council staff aggregated the  reports that were submitted into one summary of activities. These annual  reports would be used to carry out yet another requirement of the  executive order and management plan that calls for the council to revise  the plan by January 2003.
Several survey respondents commented that it was difficult for them to  evaluate the council’s progress in implementing the plan because  information from the council had been inadequate. For example, some  respondents wrote that the level of interaction between them and the  council was not sufficient, and that feedback to the advisory committee  from the council on implementation progress has been poor.
The management plan also calls for the council to establish a “transparent  oversight mechanism” that engages public involvement. The purpose of the  oversight mechanism would be for use by federal agencies in complying  with the executive order and reporting on its implementation, which  includes the management plan. The plan called for the mechanism to be in  place by April 2001, but according to the council staff, work has not  yet begun.
section_title: The Council Has Completed Less Than 20 Percent of Planned Actions
paragraphs: Our review of the council’s summary of department actions, which focused  on the 65 planned actions with due dates through September 2002 (an  additional 21 planned actions have due dates after September 2002, for a  total of 86), revealed that less than 20 percent of the actions due by  September 2002 were complete. Several actions completed on time  related to the development of the council’s Web site, which is found at  www.invasivespecies.gov. Another completed action concerned a series of  regional workshops on invasive species for policymakers that the council,  led by the Department of State, cohosted with countries such as Brazil,  Costa Rica, Denmark, Thailand, and Zambia. Also in accord with the plan,  the National Oceanic and Atmospheric Administration, the Coast Guard,  the Department of the Interior, and EPA have sponsored research related to  ballast water management.
Departments and the council staff have also started work on over  60 percent of the other planned actions, including some that have a due  date beyond September 2002. For example, departmental representatives  and the council staff are working with the President’s Council on  Environmental Quality on guidance to federal agencies on how to consider  the issue of invasive species as they prepare analyses required by the  National Environmental Policy Act. However, the guidance is not expected  to be ready until early 2003, past its August 2001 target date. USDA has  begun work on additional regulations to further reduce the risk of species  introductions via solid wood packing materials, but the department did  not meet the management plan’s January 2002 deadline. (See fig. 5 for  information on the Asian long-horned beetle, an invasive species that  entered the United States in solid wood packing material.) Council  departments have begun work on a national public awareness campaign— cataloging existing public awareness programs and conducting a survey of  public attitudes toward invasive species—and are seeking budget approval  for starting the campaign in fiscal year 2004. They missed the June 2002  completion date called for in the plan. Among those actions that the  council is working on that are not due until after September 2002 is a  risk-based comprehensive screening system for evaluating first-time  intentionally introduced nonnative species, which is due by  December 2003. According to council staff, the complexities of  implementing a screening system dictate that the departments work on this  now. According to council staff, work is also underway on a coordinated  rapid response program due by July 2003.
There are also actions in the plan that the council has not started to work  on. For example, the council has not acted on the item in the plan that  called for draft legislation by January 2002 to authorize tax incentives and  otherwise encourage participation of private landowners in restoration  programs. Nor has the council moved to ensure that a clearly defined  process and procedures be in place by July 2001 to help resolve  jurisdictional and other disputes regarding invasive species issues.  Two respondents to our survey commented on the lack of council progress  toward a resolution process, citing the need for it in cases such as one  where federal agencies are taking contradictory actions with respect to an  invasive rangeland grass (see fig. 6 for more on buffelgrass). In its  comments on our draft report, EPA emphasized the significance of this  deficiency and noted that there are other situations where a resolution  process is needed, such as fish stocking to enhance recreational fisheries  and using genetically modified organisms in aquaculture and agriculture.
The majority of the advisory committee members responding to our survey  noted the lack of progress made by the council agencies. Eighteen of the 21  members who responded to a question about implementation said that that  the council was making inadequate or very inadequate progress. One noted  that the only clear achievement to date is the council’s Web site.
section_title: Some of the Agencies’ Actions Are Not Clearly Linked to Coordinated Implementation of the Management Plan
paragraphs: In our view, while it is apparent that the agencies are taking various actions  to address invasive species issues, the actions the agencies have reported  to the council often do not represent coordinated progress toward  implementation of the plan or management of the problem. The executive  order and the management plan both emphasized the need for coordination  among agencies. As evidence of that emphasis, a majority of the actions in  the management plan are to be carried out by multiple agencies. However,  the actions that the agencies reported to the council often did not appear to  be directly linked to each other or be directly responsive to the specific  actions called for by the management plan. In our survey, several advisory  committee members also commented that coordination has  been inadequate.
For example, the management plan called for the council to implement by  January 2002 a process for identifying high-priority invasive species  that are likely to be introduced unintentionally and for which effective  mitigation tools are necessary. One agency noted to the council that it had  contracted with professional societies to provide a list of the most harmful  insect, weed, and disease plant pests that are not yet present in the country  or present but not widely distributed. It also noted that it has a risk  assessment procedure for identifying pests that may be introduced with  commodities such as agricultural products. A second agency noted that it  had held a workshop to identify potentially invasive species that might  enter the nation’s waters from Eastern Europe. A third agency indicated  that it is providing training for firefighters to reduce the spread of weeds  from one fire site to another. While these activities are related to the  planned action, they do not indicate that the agencies are working together  through the council to implement a process for identifying high priority  species as called for by the plan.
The Executive Director of the council acknowledged that some of the  actions reported by agencies did not seem to directly link to the  management plan, although such information was useful for overall  coordination purposes. She said that in the future implementation teams  would help the agencies focus on those actions that are directly linked to  the management plan. The Executive Director and one of the Assistant  Directors of the council told us that they believe that increased  coordination has been an important accomplishment and that agency  officials are now routinely talking with each other about invasive species  management issues. In comments on our draft report, the Department of  the Interior also noted that coordination and communication among the  agencies has increased.
section_title: Slow Progress on Management Plan Is Due to a Combination of Factors
paragraphs: Our survey and other evidence indicate that the slow progress in  implementing the management plan has been caused by a combination of  factors, including delays in forming teams responsible for developing  specific implementation plans, the lack of priority given to the plan by the  council as a whole and by the departments individually, and insufficient  funding specifically targeted to support the plan. Progress was also  slowed by the need to transition from the previous administration to the  current administration.
subsections: section_title: Delays Forming Implementation Teams
paragraphs: In October 2000, before issuing the management plan, the advisory  committee and council staff agreed that implementation teams made up of  federal and nonfederal stakeholders were needed to put the management  plan into action. The advisory committee members and council staff agreed  that the teams should be under the auspices of the advisory committee and  be closely aligned to the major sections of the management plan.  Specifically, the teams would be responsible for “delivery” of the planned  actions. For example, a prevention team would be responsible for guiding  implementation of the actions relevant to prevention. However, for various  reasons, most implementation teams were not formed until June 2002.  Specifically:  The Executive Director of the council told us that she did not believe it  would have been appropriate to form the implementation teams until  after the management plan was issued in January 2001.
The change in administration then delayed action on implementing the  plan by about 6 months because it took time for cabinet secretaries— the members of the council—and other political appointees to be  nominated and confirmed; departments were ready to move forward  with forming the implementation teams in the fall of 2001.
By that time, the first term of all of the advisory committee members  was approaching its end in November 2001 and because the advisory  committee members were to be an integral part of the implementation  teams, the Executive Director told us it did not make sense to form the  teams until the next advisory committee was convened.
Appointment of the second set of advisory committee members was  delayed until April 2002 for a number of reasons, including the  temporary loss of e-mail and regular mail delivery at the Department of  the Interior.
The second advisory committee held its first meeting in May 2002, and  committee members and council staff decided that the implementation  teams should not meet until after the advisory committee members had  a chance to review the teams’ responsibilities and membership and  discuss them at greater length at their next scheduled meeting in June  2002.
In June 2002, nine implementation teams were created that largely  mirror sections of the management plan (all but two of the teams will  comprise federal and nonfederal members).
The Executive Director of the council told us the decision to create  implementation teams of federal and nonfederal members under the  auspices of the advisory committee was in part in recognition of the  importance of getting consensus from key stakeholders early in the  implementation process. She told us that she recognizes that there are  potential problems with the teams comprising a disparate group of federal  and nonfederal stakeholders. Specifically, logistical problems in getting the  teams together and disputes within the teams could delay the federal  departments in taking action to implement the plan. She said that the  council would have to monitor the teams closely to determine whether or  not they are effective.
The delay in establishing the implementation teams has hindered the  agencies in achieving an important objective of both the executive order  and the management plan—coordinated action. Several respondents to our  survey commented that they had not seen adequate increases in the  amount of coordination, and some pointed to the delays in forming the  teams as a cause. One respondent thought that federal departments and  agencies were continuing to pursue their own mandates and programs with  only a cursory regard for the framework and coordination that the council  attempts to provide. The Executive Director of the council told us that she  expected coordination to improve as the implementation teams  become established.
In our view, the relationship of the advisory committee to the  implementation teams has slowed progress on the plan and could continue  to do so. While we understand why the council decided to form the  implementation teams under the auspices of the advisory committee—to  foster consensus among key stakeholders early in the implementation  process—we believe that this decision may slow federal action.  Specifically, it may be difficult for teams of federal and nonfederal  stakeholders to put forth the concerted effort needed to implement the  management plan. We are also concerned that it will be difficult to hold the  departments accountable for carrying out the plan if they are relying upon  the actions of teams with federal and nonfederal members.
section_title: Lack of Priority from the Council and Its Member Departments
paragraphs: About one-half of the respondents to our survey criticized the council and  the departments for not giving the plan a higher priority. For example,  several noted that it did not appear that the council had positioned itself to  take a leadership role in implementing the plan or that the plan was not a  high priority on the agendas of the leaders of the council’s member  departments. In addition, numerous survey respondents said that the  individual departments needed to give the plan higher priority by providing  better support in staff and resources.
Our review of agencies’ performance plans (prepared pursuant to the  Government Performance and Results Act) also indicates that  implementing the management plan is not a high priority for individual  agencies. We reviewed the performance plans of the three cochair  departments on the council (the departments of Agriculture, Commerce,  and the Interior), as well as those of the Department of Transportation, the  Environmental Protection Agency, and agencies within the Department of  the Interior (National Park Service, Bureau of Land Management, Fish and  Wildlife Service, and Geological Survey). While most of the agencies’  performance plans describe activities intended to control or manage  invasive species—and are therefore consistent with the national  management plan—none of the plans specifically identified as a measure of  performance implementing actions called for by the council’s plan. As one  official from the Environmental Protection Agency told us, activities that  are not in the agency’s performance plan do not receive a high priority.  Nevertheless, the Department of the Interior official responsible for pulling  together the crosscut budget for invasive species programs told us that he  believes that process—because of its emphasis on performance  measures—will help departments link the management plan to their  performance plans.
With regard to the notion that the council was not giving the plan a high  priority, three of the 23 advisory committee members who responded to  our survey commented on the absence of specific legislative authority  establishing the council. One stated “the council needs to be approved  legislatively so that they are their own entity with better options to act.”  Another said “Congress or the President needs to make this a priority  through legislation or funding. . . . Agencies need to be told this is a priority  and given funding to accomplish their goals.” Because executive orders  such as the one that established the council do not provide any additional  authority to agencies, the Executive Director of the council noted that  legislative authority for the council, depending on how it was structured,  could be useful in implementing the management plan. Officials from  USDA, the Department of Defense, and EPA who are departmental liaisons  to the council also told us that legislative authority, if properly written,  would make it easier for council departments to implement the  management plan. The Congress has recently considered legislation that  would give the council certain responsibilities; namely to provide input into  decisions about allocating funds to local governments and other  organizations for controlling invasive plants. However, the Executive  Director of the council told us that such a requirement would be  unworkable if the legislation did not also formally establish the council and  a future administration decided to discontinue the executive order that  created the council.
The management plan calls for the council to conduct an evaluation by  January 2002 of the current legal authorities relevant to invasive species.  The council has not completed the evaluation. According to the plan,  the evaluation is to include an analysis of whether and how existing  authorities may be better utilized and could be used to develop  recommendations for changes in legal authority. However, it does not state  that the analysis should address whether the council itself is hampered in  its mission by not having specific legislative authority that would allow it to  direct its members to implement the national management plan.
section_title: Insufficient Funding and Staff
paragraphs: In the management plan, the council stated that many of the actions could  be completed or at least initiated with current resources but that without  significant additional resources for existing and new programs it would not  be possible to accomplish the goals of the plan within the specified  timeframes. The council also noted in its comments on the draft report that  it believes the timeframes in the plan are optimistic given current  resources. Two of the actions in the plan called for federal agencies to  request additional funding for separate management functions through the  annual appropriations process beginning in fiscal year 2003. According to a  summary prepared by the council, the President’s budget request for  invasive species activities in fiscal year 2003 was at least 23 percent more  than was requested in fiscal year 2002 (although slightly less than Congress  appropriated in fiscal year 2002). The council went on to say in the plan  that estimates of the additional support required would depend on the  details of implementation schedules developed by federal agencies and  stakeholders. As we described above, however, the council and the  advisory committee have only recently created the teams that will be  responsible for working out the detailed plans for implementation.  Therefore, it is unclear what additional resources are needed and whether  the requested appropriations will be adequate to implement the plan.
In response to several of the questions in our survey, advisory  committee members cited the lack of funding as a key reason for  poor implementation of the council’s management plan. (We did not  independently assess the adequacy of funding.) Of the 18 who said that the  council was inadequately implementing the plan, 9 said that funding was  insufficient. A typical comment was that the council members need to  make a better case to get Congress to support funding for an invasive  species line item. Over 70 percent of the respondents to another question  said that they knew of instances where federal agencies do not have the  resources to carry out actions in the national management plan. While  several respondents gave details on specific examples of where they  believe federal agencies have underfunded invasive species programs, four  others said that none of the agencies have the resources to implement the  management plan in its entirety.
In addition, 19 of the 21 respondents to one question said that the  council had inadequate staff resources to serve the needs of the council.  (The council has had a staff of five to seven people in the last 2 years.) One  respondent said that the “level of funding now is token only and serves to  support the most minimal staffing one can imagine for a national effort of  this scale. It’s embarrassing.” Many of the respondents said that the  council’s staff are working hard and doing the best that they can. However,  respondents also commented that the staff is overwhelmed, faced with  substantial obstacles, and is not sufficient to support both the council and  advisory committee. Several respondents emphasized that the council staff  should be larger to more effectively push for implementation of the  management plan.
section_title: Transition to New Administration
paragraphs: Finally, the Executive Director of the council staff told us that, in her  opinion, progress on the management plan was slowed by the transition to  a new administration. High-level political appointments are often vacant  for months during the transition from one administration to another. A  senior official from the Department of the Interior pointed out in July 2002  that many key managers relevant to the crosscutting budget proposal had  been in office only a few months because of the time required to nominate  and approve political appointees.
section_title: The Current Regulations Concerning Ballast Water Management Are Not Keeping Invasive Species Out of the Great Lakes
paragraphs: According to experts and agency officials we consulted, current efforts by  the United States and Canada are not adequate to prevent the introduction  of nonnative aquatic organisms into the Great Lakes via ballast water of  ships, and they need to be improved. Compliance with regulations is high  but nonnative aquatic organisms are still entering and establishing  themselves in the Great Lakes ecosystem. U.S. and Canadian agency  officials believe that they should do more to protect the Great Lakes from  ballast water discharges. However, several time-intensive steps must be  taken before the world’s commercial fleet is equipped with effective  treatment technologies. In the meantime, the continued introduction of  nonnative aquatic organisms could have a major economic and ecological  impact on the Great Lakes.
subsections: section_title: Compliance with U.S. Regulations Is High, but Nonnative Aquatic Organisms Are Still Entering the Great Lakes
paragraphs: Since 1993, U.S. regulations have governed how vessels entering the  Great Lakes from outside the Exclusive Economic Zone, a zone extending  200 nautical miles from the shore, must manage their ballast water. To  be allowed to discharge ballast water into the Great Lakes, ships must  exchange their ballast water before entering the zone and in water deeper  than 2,000 meters. Exchanging ballast water before arriving in the  Great Lakes is intended to serve two purposes: to flush aquatic organisms  taken on in foreign ports from the ballast tanks and to kill with salt water  any remaining organisms that happen to require fresh or brackish water. If  a ship bound for the Great Lakes has not exchanged its ballast water in the  open ocean it may hold the ballast in its tanks for the duration of the  voyage through the lakes. Under some circumstances—such as bad  weather making an open-ocean exchange unsafe—the Coast Guard may  approve a ship master’s request to do the exchange in an alternative  exchange zone in the Gulf of St. Lawrence.
The U.S. Coast Guard, the Saint Lawrence Seaway Development  Corporation, and the Canadian St. Lawrence Seaway Management  Corporation inspect ships as they enter and travel through the St. Lawrence  Seaway. The Coast Guard also inspects ships at U.S. ports throughout the  Great Lakes. Data from the Coast Guard show that the percentage of ships  entering the Great Lakes after exchanging their ballast water has steadily  increased since the regulations took effect in 1993 and averaged over  93 percent from 1998 through 2001. (See fig. 7.) Representatives of the  Coast Guard and the seaway corporations told us that the high exchange  rate indicates that the current regulations for the Great Lakes are being  effectively enforced. Experts have concluded, however, that numerous  nonnative aquatic organisms have entered the Great Lakes via ballast water  and established populations since the regulations were promulgated. (See  fig. 8.) Two such species are the fish-hook water flea (Cercopagis pengoi),  discovered in 1998, and an amphipod (a small crustacean) known as  Echigogammarus ischnus, discovered in 1995.
Experts have cited several reasons for the continued introductions of  nonnative aquatic organisms into the Great Lakes despite the ballast water  regulations. First, the Coast Guard has not applied the ballast water  exchange regulations to ships with little or no pumpable ballast water in  their tanks; approximately 70 percent of ships entering the Great Lakes  during 1999 through 2001 were in this category. These ships, however, may  still have thousands of gallons of residual ballast and sediment in their  tanks. This could harbor potentially invasive organisms from previous  ports of call and could be discharged to the Great Lakes during subsequent  ballast discharges.
Second, there are also concerns that exchanging a particular percentage of  ballast water does not remove an equivalent percentage of organisms from  the tank. The Environmental Protection Agency and the Aquatic Nuisance  Species Task Force reported that ballast water exchange with open-ocean  water flushed 25 to 90 percent and 39 to 99.9 percent, respectively, of the  organisms studied. Researchers explain this range by pointing out that  organisms in sediment at the bottom of the tanks may not be flushed out by  an exchange.
Third, there is some uncertainty regarding what percentage of the water in  the tanks is actually flushed out during a typical ballast water exchange.  When determining whether tanks have been flushed and refilled in the open  ocean, the Coast Guard tests the new ballast water to see if it has a salt  concentration of at least 30 parts per thousand. However, given  uncertainties about the salinity of a ship’s original ballast water and  evaporative losses that occur during transit, it is not clear from a basic  salinity test what percentage of the original ballast water—and the  potentially invasive aquatic organisms it may contain—has been removed.
Fourth, there is growing concern that freshwater organisms may be able to  survive the saline environment created by mid-ocean exchange. Certain  organisms have a stage in their life cycle during which they are “resting  eggs” or “cysts” and may be tolerant of salt water. Once discharged into the  Great Lakes freshwater system, these organisms can regain viability. There  are also examples of species—including alewives and the sea lamprey— that normally spend part of their lives in salt water and part in freshwater,  but have been able to thrive despite being “locked” into the freshwater of  the Great Lakes.
In an effort to reduce the further introduction of nonnative species, the  Saint Lawrence Seaway Development Corporation and its Canadian  counterpart, the St. Lawrence Seaway Management Corporation, amended  their joint regulations in February 2002 to require all commercial ships  entering the Seaway system to comply with Great Lakes shipping industry  codes for ballast water management. These codes contain “best  management practices” that are intended to reduce the number of  organisms in ballast tanks. Such practices include not taking on ballast at  night—when marine organisms are more likely to be near the surface—and  regularly cleaning tanks.
section_title: Regulatory Decisions, Technological Developments, and Ship Modifications Needed to Significantly Reduce Ballast Water Invasions Will Take Many Years
paragraphs: According to experts we consulted, it will take many years to solve the  problem of nonnative aquatic organisms arriving in ballast water. The  Coast Guard is now working to develop new regulations that would include  a performance standard for ballast water—that is, a measurement of how  “clean” ballast water should be before discharge within U.S. waters. In  May 2001, the Coast Guard requested comments on how to establish a  ballast water treatment standard and offered for consideration four  conceptual approaches. The agency received numerous comments  showing a wide range of opinion. As a result, it issued an advanced notice  of proposed rulemaking and another request for comments in March 2002  on the development of a ballast water treatment goal and an interim ballast  water treatment standard. The Coast Guard is expecting to have a final rule  ready for interdepartmental review by the fall of 2004 that will contain  ballast water treatment goals and a standard that would apply not only to  ships entering the Great Lakes but also to all ships entering U.S. ports from  outside the Exclusive Economic Zone.
Once the Coast Guard sets a new performance standard for how clean  ballast water should be, firms and other entities will have a goal to use  as the basis for developing and measuring treatment technologies.  Government, industry, academia, and other nongovernment interests are  investigating several technologies, including filtration, hydrocyclonic  separation, and chemical and physical biocides such as ozone,  chlorination, ultraviolet radiation, heat treatment, and vacuum. Each  technology has its strengths and weaknesses. One major hurdle facing any  technological solution is how to treat large volumes of water being pumped  at very high flow rates. Container vessels and cruise ships, which carry a  smaller volume of ballast water, may require different technologies than  larger container vessels. As a result, it is likely that no single technology  will address the problem adequately. To facilitate technology development,  the Coast Guard and the Department of Transportation’s Maritime  Administration are developing programs to provide incentives for ship  owners to actively participate in projects designed to test treatment  technologies.
To help with technology development, the National Invasive Species Act  created a ballast water demonstration program that funds select proposals  to develop and demonstrate new ballast water technologies. Under this  program, the National Oceanic and Atmospheric Administration and the  U.S. Fish and Wildlife Service have funded 20 ballast water technology  demonstration projects at a total cost of $3.5 million since 1998. Other  programs also support research, such as the National Sea Grant College  Program, which has funded nine projects totaling $1.5 million. In addition,  the National Oceanic and Atmospheric Administration, through the  National Sea Grant College Program, and the U.S. Fish and Wildlife Service  announced on June 6, 2002, that they expect to make $2.1 million available  in fiscal year 2002 to support projects to improve ballast water treatment  and management. In conjunction with this program, the Department of  Transportation’s Maritime Administration expects to make available  several ships of its Ready Reserve Force Fleet to act as test platforms for  ballast water technology demonstration projects. In fiscal years 2001 and  2002, Congress appropriated $550,000 to the Coast Guard for research and  development related to ballast water management. In addition, EPA and the  Coast Guard expect to contribute $210,000 to fund a 3-year study on the  transfer of aquatic organisms in ballast water. Nonfederal researchers in  industry and academia are also studying the content of ballast water and  prospective treatment technologies. For example, a Canadian shipping  company funded the installation of a treatment system on one of its ocean- going ships and allowed the Michigan Department of Environmental  Quality to perform testing on the system.
Once effective technologies are developed, another hurdle will be installing  the technologies on the world fleet. New ships can be designed to  incorporate a treatment system. Existing ships, on the other hand, were not  designed to carry ballast water technologies and may have to go through an  expensive retrofitting process. With each passing year without an effective  technology, every new ship put into service is one more that may need to be  retrofitted in the future.
Public and private interests in the Great Lakes have expressed  dissatisfaction with the progress in developing a solution to the problem  of nonnative aquatic organism transfers through ballast water. An industry  representative told us that she and other stakeholders were frustrated with  the Coast Guard’s decision to make a second request for public comment  on a treatment standard; she said they were anticipating that the agency  would publish a proposal rather than another request for information. More  broadly, in a July 6, 2001, letter to the U.S. Secretary of State and the  Canadian Minster of Foreign Affairs, the International Joint Commission  and the Great Lakes Fishery Commission stated their belief that the two  governments were not adequately protecting the Great Lakes from further  introductions of aquatic invasive species. They also noted that there is a  growing sense of frustration within all levels of government, the public,  academia, industry, and environmental groups throughout the Great Lakes  basin and a consensus that the ballast water issue must be addressed now.  The two commissions suggested that the re-authorization of the National  Invasive Species Act is a clear opportunity to provide funding towards  implementing research aimed at developing binational ballast water  standards. The International Joint Commission recommended in its 2002  11th Biennial Report that the U.S. and Canadian governments fund  research recommended by expert regional, national, binational panels, task  forces, and committees.
In an effort to prevent the introduction of nonnative aquatic organisms into  their waters, several Great Lake states have considered adopting ballast  water legislation that would be more stringent than current federal  regulations. For example, the legislatures in Illinois, Minnesota, and  New York are currently considering ballast water legislation that would,  among other things, require ships to “sterilize” their ballast water—a  standard that would exceed even those for drinking water. The Michigan  legislature also debated a proposal that would have required ships to  sterilize ballast water before discharge. The stringency of that proposed  legislation was a result of one Michigan legislator’s frustration with the  federal government’s slow progress in implementing an effective national  plan to protect the Great Lakes from invasions through ballast water. The  bill that passed into law in Michigan, however, has requirements similar to  those in the federal program.
Citing inadequacies in the United States’ regulatory program, an  environmental organization petitioned EPA in 1999 on behalf of  15 nongovernmental, state, and tribal organizations to address ballast  water discharges under the Clean Water Act. The petition asked the agency  to eliminate the exemption that currently excludes ballast water discharges  from regulation under its National Pollutant Discharge Elimination System  program. Eighteen members of Congress followed the petition with a  letter also requesting that the agency examine whether the Clean Water Act  could be used to provide effective regulation of nonnative aquatic  organisms in ballast water. In its September 10, 2001, draft response to the  petition and the congressional letter, the agency concluded that the  exemption should not be lifted because regulation of ballast water  discharges under the Clean Water Act would be more problematic than the  process already in place under the National Invasive Species Act. The  agency asserted that issuing uniform discharge requirements would require  significant federal and state agency resources and would not necessarily  provide protection greater than the National Invasive Species Act. The  agency also stated that the using the Clean Water Act would likely subject  ship operators to multiple and potentially different state and federal  regulatory regimes.
On the international level, the United States is also an active member of the  International Maritime Organization (IMO), a specialized United Nations  agency that is also addressing ballast water management. In 1997, the  organization adopted “Guidelines for the Control and Management of  Ships’ Ballast Water to Minimize the Transfer of Harmful Aquatic  Organisms and Pathogens.” The IMO requests that all maritime nations  adopt and use these voluntary guidelines that call for, among other things,  open-ocean ballast water exchange. Member nations are also working  toward an international convention to address ballast water management.  According to a State Department official who is a member of the  U.S. delegation to the IMO, the organization is developing a new  convention for possible adoption in the fall of 2003. The State Department  official told us that the convention would probably include ballast water  exchange as an interim method and would likely include provisions for  modifying the performance standard over time to correspond with and spur  improvements in technology. Even if a convention were available for  signature in the fall of 2003, it would take some years for it to enter into  force and for effective treatment technologies to be installed on the  world fleet. Recognizing the time needed to develop and install new  technologies, the Coast Guard has suggested to the Marine Environment  Protection Committee that the date by which ships must meet a new  performance standard be 10 years after the organization adopts a  convention (in this case, 2013).
section_title: The Continued Introduction of Nonnative Aquatic Organisms Via Ballast Water Could Have Major Economic and Ecological Effects on the Great Lakes
paragraphs: Although no estimates have been made, using the past as a guide,  the continued introduction of nonnative aquatic organisms into the  Great Lakes could have significant economic and ecological impacts on the  Great Lakes basin. In a May 2001 report, the International Joint  Commission noted that the past and ongoing economic impacts of invasive  species introductions to the Great Lakes region represent hundreds  of millions of dollars annually. As a result, experts dread the introduction  of the “next zebra mussel.” The zebra mussel was introduced to the  Great Lakes in 1988 and is continuing to wreak havoc on the ecosystem and  surrounding economies. Zebra mussel control measures alone are  estimated to have cost municipalities and industries $69 million from  1989 through 1995. (See fig. 9 for more on the zebra mussel.)
Such fears appear to be well founded because scientists predict that  additional invasions will occur if effective safeguards are not placed on the  discharge of ballast water from ocean-going ships. We have discussed two  species and listed others that have been introduced since ballast water  regulations were implemented. (See fig. 10.) In addition, scientists have  identified 17 species from the Ponto-Caspian region (Caspian, Black, and  Azov Seas) of Eastern Europe alone that have a high invasion potential, are  likely to survive an incomplete ballast-water exchange, and are considered  probable future immigrants to the Great Lakes.
The continued introduction of nonnative aquatic organisms could further  damage a U.S. and Canadian Great Lakes sport and commercial fishing  industry that is valued at almost $4.5 billion annually and supports  approximately 81,000 jobs. Aggressive fish that have invaded the lakes in  the past (such as the sea lamprey, the Eurasian ruffe, and the round goby)  have harmed native fish by directly preying either on them or on their food  supply. Two of the potential species from the Ponto-Caspian region, the  amphipods Corophium curvispinum and Corophium sowinskyi, could  significantly alter biological communities along shorelines and food chains  in North American river systems. Invasive species can also carry parasites  and pathogens that could affect existing fish populations. For instance, fish  pathologists fear that continued introductions of species such as the  Eurasian ruffe may facilitate the introduction of new and potentially  harmful parasites and pathogens, such as viral hemorrhagic septicemia,  a serious disease of rainbow trout in Europe that could affect  North American fish populations.
Ballast water is also known to carry human pathogens, although the  risks they pose to human health has not been determined. One study  performed during the 1997 and 1998 shipping seasons sampled ballast  water in ships passing through the St. Lawrence Seaway en route to ports  in the Great Lakes. Human pathogens, such as fecal coliform, fecal  streptococci, Clostridium perfringens, Escherichia coli, and Vibrio  cholerae, as well as multiple species of Cryptosporidium, Salmonella, and  Giardia, were detected in the samples. According to the Coast Guard,  these organisms are also found in bodies of water that are influenced by  human development.
section_title: There Is a Growing Interest in Coordination between the United States and Canada, but a Comprehensive Approach Has Yet to Be Developed
paragraphs: The United States and Canada participate in a variety of bilateral and  multilateral efforts to share information, conduct research, and coordinate  efforts to reduce the threat of invasive species. The two countries’ long  history of coordination has focused on particular segments of the issue  such as shared boundary waters and agricultural research, and  stakeholders have called for a more comprehensive strategy for joint  prevention and management efforts. The National Invasive Species Council  recognized the need for the United States to work with Canada (and  Mexico) in a more comprehensive manner and has taken initial steps to  develop a North American strategy as called for by the national  management plan. It is too early to tell, however, what form a North  American strategy will take or how existing organizations will be  integrated.
subsections: section_title: Coordination Between the Two Governments Has Focused on Specific Issues or Geographic Regions
paragraphs: Historically, coordination between the United States and Canada has  focused on specific pathways, species, or geographic areas rather than on a  comprehensive coordinated approach. Primary examples of this  coordination concern shared boundary waters and agriculture.
subsections: section_title: Shared Boundary Waters
paragraphs: One mechanism for coordination is the International Joint Commission,  which was established by the Boundary Waters Treaty of 1909. The treaty  established the commission to advise the U.S. and Canadian governments  concerning issues along the boundary and approve certain projects in  boundary and transboundary waters that affect water levels and flows  across the boundary. The commission has focused much of its attention on  the Great Lakes. The purpose of the 1978 Great Lakes Water Quality  Agreement between the United States and Canada is to “restore and  maintain the chemical, physical, and biological integrity of the waters of  the Great Lakes Basin Ecosystem.” The International Joint Commission’s  role with respect to the agreement includes evaluating and assessing the  two countries’ programs and providing a report at least every 2 years that  presents its findings, advice, and recommendations. Recent reports have  contained recommendations to the governments on how to reduce the flow  of invasive species through ballast water.
Protection of the Great Lakes fisheries against the nonnative sea lamprey  was a motivating factor behind the creation of the Great Lakes Fishery  Commission in 1955 in the Convention on Great Lakes Fisheries between  the U.S. and Canada. The fishery commission, which is jointly funded by  the two countries, has been largely successful in controlling, although not  eradicating, the sea lamprey. Another primary objective of the fishery  commission is to formulate a research program or programs to determine  the need for measures to make possible the maximum sustained  productivity of fish of common concern. One of the commission’s goals is  to ensure that no nonnative fishes will be unintentionally introduced into  the Great Lakes. The commission has stated that it will intensify its work  with partners to address those vectors for invasive species, such as ship  ballast water, that pose the greatest threat to the lakes.
Another mechanism that has promoted coordination between the United  States and Canada is the establishment of regional panels to address  aquatic invasive species. The Nonindigenous Aquatic Nuisance Prevention  and Control Act of 1990 authorized the establishment of the Great Lakes  Panel on Aquatic Nuisance Species, which comprises U.S. and Canadian  public- and private-sector representatives. Its activities include identifying  Great Lakes priorities for aquatic nuisance species, coordinating  information and education efforts, making recommendations to the federal  government, and advising the public about control efforts. Two other  U.S. panels recently established under the National Invasive Species Act of  1996 in the West and the Northeast also include Canadian members.
As noted earlier, the United States and Canada are also working together  on managing ballast water coming into the Great Lakes through the  St. Lawrence Seaway. Cooperative efforts by the two countries were  most recently demonstrated by the joint decision of the United States’  Saint Lawrence Seaway Development Corporation and Canada’s  St. Lawrence Seaway Management Corporation to require all ships entering  the seaway to follow established best management practices.
section_title: Agricultural Research and Pest Control
paragraphs: There has also been a long history of coordination between the U.S. and  Canada in the area of agricultural research and pest control. As we  reported in July 2002, for over 30 years the two countries and Mexico have  held regular meetings on animal health issues to make North America’s  import requirements consistent and, more recently, to coordinate  preventive actions and emergency response activities in the event of an  outbreak of the nonnative foot-and-mouth disease. In 2000, the three  countries held joint exercises to test their foot-and-mouth disease  communication and response plans and to assess their response systems.  As a result of this exercise, the three governments signed a memorandum  of understanding to formally establish the North American Animal Health  Committee. According to USDA, the United States and Canada have also  worked very closely in the past several years on jointly assessing the threat  from two other foreign animal diseases—bovine spongiform  encephalopathy (also known as “mad cow disease”) and chronic wasting  disease. Another emerging animal and public health issue that the United  States and Canada have worked together on is the West Nile virus, which is  transported by migratory birds and by insects such as mosquitoes. (See  fig. 10 for more details on the virus.)
To further strengthen communication and collaboration on invasive  species and trade-related matters, USDA’s Animal and Plant Health  Inspection Service established an office in Ottawa, Canada, in 2000. The  office oversees a preclearance program throughout Canada that conducts  inspections, treatments and/or other mitigation measures in Canada to  identify and/or mitigate the risk of exotic pest introductions via agricultural  commodities before the commodities are cleared through the  U.S. Customs Service.
Another vehicle for coordination in the agriculture sector is the  North American Plant Protection Organization, created as a regional  plant protection organization under the International Plant Protection  Convention of 1951. The convention called for the governments to establish  regional plant protection organizations responsible for coordinating  activities under the convention, such as the development and promotion of  the use of international phytosanitary certificates. For example, through  the plant protection organization, the United States, Canada, and Mexico  worked together to develop a standard for treating solid wood packing  materials. According to USDA, the United States and Canada are also  working together to develop an international standard for evaluating the  environmental impact of invasive species. This standard, which the USDA  expects to be adopted by the International Plant Protection Convention in  2003, would provide a common framework for assessing the invasive  potential of pests and thereby ensure a more rigorous but common  approach to dealing with them.
section_title: Stakeholders Have Called for Increased Coordination between the United States and Canada
paragraphs: While there are numerous examples of coordination between the United  States and Canada on invasive species control, some stakeholders in this  issue believe that not enough is being done. For example, in June 1999, the  Great Lakes Panel on Aquatic Nuisance Species wrote that there was a lack  of inter-jurisdictional consistency in laws, regulations, and policies directed  at aquatic nuisance species prevention and control efforts, and that  improvements were needed to ensure a more efficient and effective  regional prevention and control program.
As noted previously, the International Joint Commission stated its belief  that the two governments were not adequately protecting the Great Lakes  from further introduction of aquatic invasive species and it made several  recommendations regarding a binational approach to better management.  In addition, according to EPA, there are numerous locations where there is  a need for continuing regional cooperation to address aquatic invasive  species in binational waterways, including the St. Croix River of New  Brunswick and Maine; Lake Champlain of Quebec, Vermont, and New York;  the Red River of North Dakota, Minnesota, and Manitoba; the Souris River  of Saskatchewan, Manitoba, and North Dakota; and the Georgia Basin- Puget Sound of British Columbia and Washington. For example, in the Red  River watershed of North Dakota, a proposed water diversion could  introduce nonnative species into new locations. An official from EPA’s  Office of International Affairs told us that, in his opinion, having an  overarching policy with respect to aquatic invasive species along the  border would help better address these situations more quickly or avoid  them completely.
The National Invasive Species Council’s Assistant Director for International  Policy, Science, and Cooperation told us that she believes that the United  States could expand two existing interagency organizations—the Federal  Interagency Committee for the Management of Noxious and Exotic Weeds  and the Aquatic Nuisance Species Task Force—to include Canadian  representation, or that Canada should be encouraged to develop similar  organizations. She said this would make it much easier to establish  dialogue between officials with similar responsibilities. The council’s  Assistant Director also said she thought that the National Oceanic and  Atmospheric Administration’s Sea Grant Program could be more effectively  used to support educational programs developed and implemented in the  United States and Canada. She noted that because tourists frequently cross  the border to and from Canada it is important to address this pathway with  a common education strategy. In this same vein, while we reported in  August 2002 that the United States, Canada, and Mexico have worked to  coordinate animal health measures, we also noted that there are  differences in the countries’ policies and practices with regard to foot-and- mouth disease that could contribute to the risk that travelers may bring  foreign animal disease across our mutual borders.
section_title: The National Invasive Species Council Has Taken Initial Steps Toward Developing a North American Strategy, but its Form Is Not Yet Known
paragraphs: The National Invasive Species Council recognized the need for the  United States to work with Canada (and Mexico) in a more comprehensive  manner. The management plan called for the council to outline an  approach to a North American invasive species strategy by December 2001.  The strategy was to be built upon existing tripartite agreements and  regional organizations. The plan also called for the council to initiate  discussions with Canada and Mexico for further development and adoption  of the strategy. The council has taken initial steps but has not completed  this planned action.
The council established the North America Strategy task team in  January 2002. It comprises federal and nonfederal stakeholders, and is  cochaired by the Department of State, the Environmental Protection  Agency, and the Fish and Wildlife Service. In March 2002, the Department  of State sent a cable to United States embassy staff in Canada and Mexico  requesting that they notify officials in those two countries of the federal  government’s desire to develop a North American strategy. According to  one U.S. official involved in this project, Canadian representatives have  responded positively to the idea.
In the time since it sent the memorandum, however, the team has done  little to develop the strategy. The council staff and the advisory committee  placed the team into a holding pattern in May 2002 when they decided that  all of the implementation teams needed to be reviewed by the advisory  committee. According to one of the cochairs of the team, among other  things that the team will need to do is identify the objectives of the  U.S. participation in the various North American organizations and  determine what actions are being taken.
Two other multilateral organizations provide opportunities for a more  comprehensive approach to an invasive species strategy across  North American borders but do not have significant resources dedicated to  the issue. The North American Commission on Environmental  Cooperation, which is governed by a council composed of the  Administrator of the United States Environmental Protection Agency,  the Minister of the Environment in Canada, and the Secretary of the  Environment and Natural Resources in Mexico, provides an opportunity  for the United States and Canada to research and develop strategic plans  for common ecosystems such as northern forests, grasslands, and aquatic  ecosystems. One objective in its 2001 draft Strategy for the Conservation  of Biodiversity in North America, is to promote the development of  concerted efforts to combat invasive species in North America. In  March 2001, participants at a workshop sponsored by the commission  recommended five priority areas for cooperation in North America on  invasive species. Because of limited resources, however, the commission  has decided to proceed with just one of those areas—identifying invasive  species and invasion pathways that are a concern of two or more countries  (within North America)—and determine priorities for bi- or tri- lateral cooperation.
The Trilateral Committee for Wildlife and Ecosystem Conservation and  Management is composed of the wildlife agencies from the United States,  Canada, and Mexico, and also has the ability to look at approaches for  managing invasive species more broadly. The committee has not analyzed  invasive species in depth, although the issue was on its meeting agenda in  April 2002 in order to set it as a topic for discussion at a later meeting.  According to a State Department official who attended the meeting, the  committee decided to add invasive species to the portfolio of the “working  table” on biodiversity information.
section_title: Conclusions
paragraphs: While the available data are often inadequate to thoroughly describe the  costs and risks associated with invasive species, it is apparent that their  impacts on our environment and, thus, our economy are significant. At  the same time, because of limitations in both the quantity and quality  of economic impact analysis, it may not be readily apparent to  decision makers in the federal government how they should most  effectively allocate limited resources to prevent and manage invasive  species. It is encouraging that the National Invasive Species Council and  OMB are working on a crosscut budget that the federal government can use  to plan resource allocations to and among departments. Such decisions  would be better informed by information and data on the risk that  nonnative species will enter the country, become established, spread, and  cause harm. The ballast water management situation is a prime example.  The federal government faces decisions about dedicating resources to fund  ballast water technology research or standard setting, and ultimately about  imposing more protective regulations. Decision makers could weigh the  costs of those activities against the potential costs of the next zebra mussel  or sea lamprey to arrive in U.S. waters, if such data were readily available.
Moving ahead with a comprehensive management plan to combat invasive  species is clearly in the national interest. It also poses a daunting challenge.  Success in this effort will depend in no small part on crafting a plan that  calls for clearly defined, measurable outcomes and has a mechanism in  place to hold departments accountable for carrying it out. The National  Invasive Species Council now has the opportunity to improve upon its  management plan in a revision due in 2003. Successful implementation of  the plan depends in part on the members of the council making it a priority  within their own departments and agencies and, recognizing the enormity  of the task ahead, developing estimates of the resources needed.  Statements from various stakeholders suggest it is possible that federal  agencies could better coordinate their efforts to implement the  management plan if the Congress established the council in legislation. The  management plan states that the council will conduct an analysis of  legislative authorities relevant to invasive species. We believe that the  evaluation should also examine the question of whether the lack of  legislative authority establishing the council is hampering the council in its  efforts to implement the national management plan.
section_title: Recommendations for Executive Action
paragraphs: To better manage the threats posed by invasive species in the United States,  we recommend that the cochairs of the National Invasive Species  Council—the Secretaries of Agriculture, Commerce, and the Interior— direct council members to:  Include within the revision to the National Invasive Species  Management Plan a goal of incorporating information on the economic  impacts and relative risks of different invasive species or pathways  when formulating a crosscuting invasive species management budget  for the federal government. Such a goal may require a commitment from  the council to ensure that adequate resources are dedicated within the  federal government to expand the capacity for conducting appropriate  economic analysis.
Ensure that the updated version of the national management plan, due  in January 2003, contains performance-oriented goals and objectives  and specific measures of success.
Give a high priority to completing planned action #1, which calls for  establishing a transparent oversight mechanism for use by federal  agencies in complying with Executive Order 13112 and reporting on  implementation of the management plan.
Include in its planned evaluation of current legal authorities an  examination of whether the lack of legislative authority establishing the  National Invasive Species Council and specifically directing its members  to implement the national management plan hampers the council’s  efforts to implement the plan.
To better ensure the implementation of the national management plan,  we recommend that the members of the National Invasive Species Council  who are responsible for taking actions called for in the plan recognize their  responsibilities in either their departmental- or agency-level annual  performance plans. The annual performance plans and performance  reports should describe what steps the departments or their agencies will  take or have taken to implement the actions that are specifically called for  in the national management plan. For the existing (2001 version) of the  national management plan, the member departments to which this applies  include the Departments of Agriculture, Commerce, Interior, Defense,  State, and Transportation, and the Environmental Protection Agency.
section_title: Agency Comments and Our Evaluation
paragraphs: We provided copies of our draft report to the Departments of Agriculture,  Commerce, Defense, Treasury, State, Transportation, and the Interior;  the Environmental Protection Agency; the U.S. Trade Representative;  and the National Invasive Species Council. We received written comments  from the Department of the Interior, the Department of State, the  Environmental Protection Agency, and the National Invasive Species  Council. We received oral comments from the Departments of  Transportation, Agriculture, and the Treasury. The written comments  from the Department of the Interior, the Department of Agriculture, the  National Invasive Species Council, and EPA are in appendixes II through V.
The Department of the Interior concurred with the recommendations in the  report and said that it would work with the other cochairs of the National  Invasive Species Council to implement the recommendations in a timely  manner consistent with current budget and authority. While agreeing with  the recommendations, the department expressed the view that our draft  report did not adequately acknowledge the extensive invasive species  activities that federal agencies are doing outside of what is called for by the  national management plan. We agree that federal agencies are engaged in  other invasive species management activities and have described many of  them in prior reports. A principle objective of this review, however, was to  assess the implementation of the national management plan, and not all  federal activities. The department also commented that it believes that the  Fish and Wildlife Service, the National Oceanic and Atmospheric  Administration, and the Maritime Administration are demonstrating  substantial progress in developing technologies to treat ballast water. We  agree that progress is being made, but continue to believe that much  important work remains to be done. To illustrate this, we reported the  Coast Guard’s estimate that it may be at least 10 years before ships must  meet a new performance standard for ballast water treatment, a step  critical to real progress. The department suggested several other minor  changes that we have incorporated where appropriate.
The Department of State commented that it did not fully concur with our  finding that the slow progress on the national management plan is due to  lack of priority given to the plan by the Council and departments. The  department claimed that it places a high priority on accomplishing the  goals of the management plan, and it itemized numerous activities in  support of that statement. We do not disagree with the department’s claims.  However, we did not evaluate the efforts or progress of one department  versus another; instead, we evaluated implementation of the management  plan overall. The letter from the Department of State also included  comments from the International Joint Commission. The commission  suggested that we include a recommendation that the federal government  work with Canada to develop an effective approach to immediately  improve the management of all ballast waters coming into the Great Lakes.  Our report describes the current and expected situation with respect to  ballast water in the Great Lakes. We believe that the decision to take more  immediate action to solve the problem is a policy decision best left to the  Congress or the administration. The commission also suggested that we  ask the Congress to consider completing reauthorization of the National  Invasive Species Act. While we recognize the importance of the  commission’s suggestion, we did not evaluate the current proposal to  reauthorize the act. The department and the commission also offered  minor corrections, which we have made.
The National Invasive Species Council concurred with our  recommendations but made several clarifying comments. In particular,  it noted that the management plan’s deadlines were optimistic and  suggested that we should have evaluated whether the deadlines were  realistic or attainable. We believe that an assessment of its deadlines is an  appropriate task for the council when it revises the management plan. In  addition, the council commented that the report undervalued the progress  being made toward coordination and cooperation among federal agencies  and gave examples of such activity. We acknowledge that coordination  between departments has increased as a result of the creation of the  council and the management plan, and we have added language to support  this point. Nevertheless, the report provides support for the position that  improvement can still be made in this area. Finally, the council made other  minor comments that we have incorporated where appropriate.
The Environmental Protection Agency commented that our  recommendations were reasonable and believes that their  implementation would enhance the federal government’s response to  dealing with the problem of invasive species. The agency also noted that  the report is well written and helpful in assessing the progress made in  coping with invasive species. The agency also made several clarifying  comments that we have incorporated where appropriate. The agency  questioned whether we should have based our conclusions about the pace  of implementation of the management plan solely on the results of our  survey of the members of the first term of the advisory committee, given  the small size of the population and their possible biases. We did not draw  our conclusions about the pace of implementation solely, or even primarily,  from the survey. Our statement that less than 20 percent of the plan has  been implemented is based on our analysis of information from the  National Invasive Species Council staff and the council’s member  departments. EPA also noted that the report’s section on ballast water  focused on the Great Lakes and pointed out that work is being done and  needs to be done in other parts of the country. We agree that ballast water  is an important issue in other parts of the country. However, our objective,  as part of our coordinated review with the Canadian Office of the Auditor  General, was to focus on the Great Lakes. Finally, EPA made a number of  technical clarifications that we have incorporated, where appropriate, in  the report.
The invasive species coordinator for the Department of Agriculture said  that our comments on the implementation of the national management plan  were fair and on target. This official also provided two minor clarifying  comments that we have incorporated.
The Department of Transportation’s Director for Performance Planning in  the Office of Budget and Program Performance provided oral comments on  the draft. He told us that the department disagreed with our draft  recommendation calling for the members of the National Invasive Species  Council to incorporate the national management plan into their annual  performance plans. He said that the department does not believe that it is  appropriate to include performance goals with respect to invasive species  in its performance plan because managing invasive species is not one of its  core missions. In addition, he told us that the agencies within the  department that have a more direct role with respect to invasive species,  such as the Coast Guard, Maritime Administration, and Federal Highway  Administration, are at liberty to include invasive species management goals  in their annual performance plans. In response to this comment, we  modified the wording of the recommendation to specify that the national  management plan should be addressed in the most appropriate annual  performance plan, whether at the departmental level or the agency level.  The department also commented that there are many mechanisms other  than ballast water by which invasive species are introduced into the  environment. We agree, and noted some of them in the report. However,  our objective specifically focused on the issue of ballast water in the  Great Lakes.
A representative with the Office of Planning in the Department of the  Treasury's U.S. Customs Service told us that because the current national  management plan does not call for the Customs Service to undertake  significant activity on invasive species, it does not believe that it is  appropriate for it to address the management plan in its annual  performance plan as called for in our recommendation.  We acknowledge  that the current plan does not have action items directed to the Customs  Service, and we modified our recommendation to clarify its applicability to  those member agencies that are specifically responsible for action items in  the existing (2001) national management plan.  If future versions of the  plan specify action items for other agencies, we would encourage them to  follow the same practice with regard to their department- or agency-level  annual performance plans.  The Customs Service made no technical  comments.
We are sending copies of this report to the other members of the  National Invasive Species Council: the Secretaries of State, Defense,  Transportation, Health and Human Services, and Treasury, and the  Administrators of the Environmental Protection Agency and the  U.S. Agency for International Development. We are also sending copies of  this report to the Chairmen and Ranking Minority Members of the following  congressional committees: the Senate Committee on Agriculture, Nutrition,  and Forestry; the Senate Committee on Commerce, Science, and  Transportation; the Senate Committee on Environment and Public Works;  the Senate Committee on Energy and Natural Resources; the Senate  Committee on Foreign Relations; the Senate Committee on Appropriations;  the House Committee on Agriculture; the House Committee on Resources;  the House Committee on Science; the House Committee on Transportation  and Infrastructure; the House Committee on Energy and Commerce; the  House Committee on International Relations; and the House Committee on  Appropriations. We will make copies available others upon request. This  report is also available on our Web site at www.gao.gov. If you have any  questions concerning this report, I can be reached at (202) 512-6878. Major  contributors to this report include Trish McClure, Ross Campbell,  Patrick Sigl, Don Cowan, Anne Stevens, and Amy E. Webbink.
section_title: Scope and Methodology
paragraphs: To determine the usefulness to decision makers of economic impact  studies for invasive species in the United States, we reviewed economics  and other policy literature that analyzes invasive species’ effects on the  U.S. economy and ecosystems. We also reviewed the literature that  describes and evaluates U.S. regulatory policies for invasive species. We  paid particular attention to the literature that evaluates how well cost- benefit analyses of invasive species’ effects, and of regulatory policies to  control them, have been adjusted to reflect uncertainties and risks  associated with these assessments. To further determine the usefulness of  the existing studies, we selected and interviewed experts, including some  authors of studies, and government officials involved in both authoring and  using the economic impact studies. We identified these experts through our  literature search.
To assess the National Invasive Species Management Plan, including the  extent to which the United States government has implemented it, we first  analyzed the content of the plan in relation to the requirements spelled out  in Executive Order 13112. In particular, we analyzed the extent to which it  contained “performance-oriented goals and objectives and specific  measures of success for federal agency efforts concerning invasive  species.” The plan contains 57 enumerated actions. However, several of  those actions have distinct subparts. In consultation with council staff, we  agreed that there are a total of 86 distinct actions called for by the plan. To  evaluate the extent to which the plan has been implemented, we focused  primarily on those actions that had a start or completion date of September  2002 or earlier. There are 65 actions in that category. To determine whether  actions had been completed, were in progress, or had not been started, we  relied on the National Invasive Species Council’s summary of agency  progress, materials provided to us by agency officials, and interviews with  council staff and agency officials. For those actions that had been started  but not completed, we did not attempt to characterize the extent to which  they had been completed. In only a few instances did we attempt to  determine when incomplete actions would be complete.
To assist in our evaluation of the plan and our assessment of its  implementation, we surveyed the 32 people serving on the Invasive Species  Advisory Committee for a 2-year term beginning in December 1999. We had  several reasons for surveying this group: (1) they participated in developing  the national management plan; (2) they represented a wide range of  interests relevant to the invasive species issue; and (3) by virtue of their  professions and their involvement with the committee, they were likely to  have information and opinions on how the management plan was being  implemented. The Secretary of the Interior reappointed 15 of these 32  people for another term on the advisory committee beginning in April 2002.
One of the members of the original advisory committee told us that he had  resigned from the committee partway through his term and did not believe  that he was informed enough about events surrounding the council, the  committee, or the management plan to respond to our survey. Therefore,  for the purposes of calculating a response rate, we are using 31 as the size  of our survey population. Twenty-one of the 31 members of the committee  completed our survey, while 2 others completed a small portion of the  survey. Therefore, while the response rate was 74 percent, the completion  rate was 68 percent. Thirteen of the 15 people reappointed to the  committee responded to the survey.
The survey instrument contained questions that asked for either numerical  or open-ended answers. The survey, including a tally of the numerical  answers, is in appendix IV. Because we did not take a sample of the  committee members, the numerical answers are presented as a  straight percentage of the total number of respondents. There are no error  rates associated with the results. We did not reprint the open-ended  answers in the report because they are too numerous and lengthy.
To determine the experts’ views on the adequacy of U.S. and Canadian  efforts to control the introduction of invasive aquatic species into the  Great Lakes via the ballast water of ships, we selected and interviewed  experts from various stakeholder interests. We identified experts through a  literature search and by soliciting the names of other expert contacts  throughout our review. In the end, we contacted experts from U.S. federal  agencies, academic institutions, and the shipping industry. We also met  with staff from two binational agencies—the International Joint  Commission and the Great Lakes Fishery Commission—and with  representatives of the Great Lakes Commission. In addition, we attended a  conference on aquatic nuisance species to obtain opinions from a range of  stakeholders on ballast water and associated shipping vectors.
To describe the current management of ballast water in the Great Lakes,  we researched U.S. and Canadian legislation, regulations, and guidelines. In  order to determine the compliance rate and effectiveness of the current  regulatory regime for the Great Lakes, we obtained compliance and  other data from the Coast Guard Marine Safety Detachment and the  Saint Lawrence Seaway Development Corporation in Massena, New York.  The Saint Lawrence Seaway Development Corporation also showed us the  U.S. ballast water inspection procedures on a vessel docked in Montreal,  Canada, and bound for the Great Lakes. We also reviewed studies on the  introduction of nonnative aquatic organisms traced to ballast water, paying  particular attention to those that have invaded after the ballast water  regulations for vessels entering the Great Lakes took effect in 1993. We  interviewed both United States and Canadian scientists on the significance  of the continued invasions since 1993.
For the international perspective on ballast water management, we  reviewed the history and development of the current International  Maritime Organization policies and guidelines. We also met with members  of the U.S. delegation to the organization to determine the status of  negotiations on a future international agreement related to ballast water.  These officials represent the United States on the Marine Environmental  Protection Committee and lead the correspondence group that is tasked  with developing a performance standard for the future International  Maritime Organization Convention on ballast water management.
To describe coordination between the United States and Canada, we  interviewed officials from departments in the National Invasive Species  Council to determine if their departments were involved in any significant  efforts to coordinate with Canadian officials on invasive species  management. From these discussions, we learned that coordination efforts  on a binational (or in some cases trinational) level have focused primarily  on shared boundary waters and agriculture. We obtained further  information from the relevant departments on the nature of those  coordination efforts. To learn more about how nonfederal organizations  can play a role in coordinating the work of the two countries, we  interviewed and obtained documents from officials representing the  International Joint Commission, the Great Lakes Fishery Commission, the  Great Lakes Commission, and the North American Commission on  Environmental Cooperation. We also obtained documentation that  described relevant work being done by the International Plant Protection  Organization, the North American Plant Protection Organization, the North  American Animal Health Committee, and the Trilateral Committee for  Wildlife and Ecosystem Conservation and Management. Finally, we relied  on previous GAO work on foot-and-mouth disease.
In choosing invasive species to profile, we judgmentally selected  species that (1) illustrate problems in a variety of environments (aquatic,  terrestrial, managed, and natural areas), (2) are drawn from a wide  variety of taxonomic groups (vertebrate, invertebrate, virus, and plant),  (3) include some that are well known by the public and others that are not,  and (4) provide a selection whose distribution collectively covers a large  portion of the United States. We collected and reviewed data on the species  from federal agencies, academic institutions, and previous GAO reports.  We obtained photographs of species from the U.S. Geological Survey  and USDA.
We conducted our review from November 2001 through September 2002 in  accordance with generally accepted government auditing standards.
section_title: Survey of Charter Members of the Invasive Species Advisory Committee
section_title: Comments from the Department of the Interior
section_title: Comments from the Department of State
section_title: Comments from the National Invasive Species Council through the Department of the Interior
section_title: Comments from the Environmental Protection Agency
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