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

Letter

Background

Invasive Species Threaten the Economy and the Environment

As we have reported in the past, the impact of invasive species in the United States is widespread, and their consequences for the economy and the environment are profound. 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.)

The Federal Government Conducts a Variety of Invasive Species Activities

More than 20 federal agencies in 10 departments—including USDA, Commerce, Defense, and the Interior—have responsibility for some aspect of invasive species management. (See fig. 2.) States also have a significant management role, but the extent of their involvement varies considerably. USDA has the largest federal role because of its responsibility to (1) conduct port-of-entry inspections and quarantine goods coming into the country, (2) manage more than 190 million acres of national forests and grasslands, (3) conduct research, and (4) provide technical assistance to the private sector and in large agricultural pest control projects. We reported that in fiscal year 2000, seven of the departments obligated more than $624 million for activities related to invasive species management. 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.

The United States and Canada Face Many Difficult Issues Related to Managing Invasive Species

The United States and Canada have a mutual interest in limiting the introduction or spread of invasive species across their borders. The two countries share more than 5,500 miles of terrestrial and aquatic border that provide potential pathways for invasive species. Each country is the other’s largest trading partner, sending and receiving a variety of goods, such as crops, livestock, wood, and horticultural products, that can harbor invasive species. Therefore, species that enter one of the two countries have opportunities to spread into the other.

The Great Lakes—a shared U.S. and Canadian resource—have been subject to invasion by nonnative species since the settlement of the region. At least 160 nonnative aquatic organisms have become established in the lakes since the 1800s, most of which have come from Europe, Asia, and the Atlantic coast. More than one-third of the organisms have been introduced in the past 30 years, a trend coinciding with the opening of the St. Lawrence Seaway in 1959 and other changes in ship operations. Ballast water in ships is considered a major pathway for the transfer of invasive aquatic organisms to the Great Lakes. Ballast is essential to the safe operation of ships because it enables them to maintain their stability and control how high or low they ride in the water. Ships take on or discharge ballast water over the course of a voyage to counteract the loading or unloading of cargo, and in response to sea conditions. The ballast that ships pump aboard in ports and harbors may be fresh, brackish, or salt water. These waters may contain various organisms that could then be carried to other ports around the world where they might be discharged and survive.

Canada adopted voluntary ballast water management guidelines in 1989 in response to the 1988 discovery of nonnative zebra mussels in Lake St. Clair. The Canadian guidelines were superceded by new guidelines in 2000 and encourage ships’ masters entering the Great Lakes and other waters under Canadian jurisdiction to employ management practices— such as exchanging ballast water in the open ocean—to minimize the probability of future introductions of harmful aquatic organisms. They also direct ships’ masters to provide ballast water details to Canadian authorities. 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.

More Comprehensive Analysis of the Economic Impacts of Invasive Species Would Better Inform Decision Makers

The scope of existing analyses of the economic impact of invasive species in the United States range from narrow to comprehensive. Narrowly focused analyses include estimates of past damages that are limited to commercial activities such as agricultural crop production and simple accountings of the money spent to combat a particular invasive species. These estimates typically do not include the economic impact of these species on natural ecosystems, the expected costs and benefits of alternative measures for preventing their entry or controlling their spread, or the impacts of possible invasions by other species in the future. On the other hand, more comprehensive—and rare—analyses are those that examine the past and prospective economic impact of invasive species to both commercial activities and natural ecosystems and the potential costs of preventing or controlling them. Few analyses have been done that examine the likelihood that new species will invade new locations and that estimate their costs. Although the estimates we reviewed may have served the purpose for which they were intended, the narrow scope of many of them may limit their usefulness to decision makers formulating federal policies on prevention and control. In general, the more comprehensive the approach used to assess the economic impacts of invasive species, the more likely its usefulness to decision makers for identifying potential invasive species, prioritizing their economic threats, and allocating resources to minimize overall damages. Federal agencies recognize the value of this type of analysis and have recently taken steps to use it more often. According to officials from several agencies, however, efforts to improve economic impact analyses are hampered by a lack of data on invasive species and a lack of economists assigned to assessing their economic impacts on commercial activities and natural ecosystems.

The Narrow Scope of Many Analyses May Limit Their Usefulness to Decision Makers

The narrow scope of many analyses of the economic impacts of invasive species may limit their usefulness to decision makers developing policies and allocating resources to address the problem. 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.

More Comprehensive Analyses Are Potentially More Useful to Decision Makers

While most of the analyses that we reviewed have limitations in their scope that lessen their usefulness to decision makers, some used a more comprehensive approach. Some analyses accounted more fully for the expected costs and benefits to producers and consumers of different control measures. For example, to further improve analysis of the expected costs and benefits of control measures, the Risk Assessment and Management Committee under the Aquatic Nuisance Species Task Force expanded the scope of existing federal risk assessment processes and methodologies to include the socioeconomic impacts of invasive species. 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.

Recent Actions May Prompt More Comprehensive Analyses

Recent federal actions may help to prompt further improvements in the economic impact analysis available to decision makers. Among other things, Executive Order 13112 calls on federal agencies to prevent the introduction of invasive species, and to detect, respond rapidly to, and control them in a cost-effective and environmentally sound manner. The executive order also directs agencies to determine that the benefits of any actions they take that are likely to cause or promote the introduction or spread of invasive species clearly outweigh the potential harm caused by the species and to take measures to minimize the risk of harm in conjunction with these actions. Implementing the order will thus require agencies to undertake more comprehensive studies of risks, costs, and benefits.

In addition, the federal Aquatic Nuisance Species Task Force has developed a process to evaluate the risk of introducing nonnative organisms into a new environment and, if needed, determine the correct management steps to mitigate that risk. 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.

The National Management Plan Lacks a Clear Long- Term Outcome, and Its Implementation Has Been Slow

While the National Invasive Species Council’s 2001 management plan, Meeting the Invasive Species Challenge, calls for actions that are likely to help control invasive species, it lacks a clear long-term outcome and quantifiable performance criteria against which to evaluate the overall success of the plan. Federal officials recognize that there are deficiencies in the plan and are working toward improving it. At present, however, the only available performance measure that can be used to assess overall progress is the percentage of planned actions that have been completed by the due dates set in the plan. By this measure, implementation has been slow. Specifically, the council departments have completed less than 20 percent of the planned actions that were called for by September 2002, although they have begun work on others. A large majority of the members of the invasive species advisory committee who responded to our survey believe that the pace of implementation is inadequate. In addition, some of the actions that agencies have reported to the council are not clearly linked to coordinated implementation of the management plan. Our survey and other evidence indicate numerous reasons for the slow progress, including delays in establishing implementation teams that will be responsible for carrying out the planned actions, the low priority given to implementation by the council, and the lack of funding and shortage of staff responsible for doing the work. Another factor contributing to slow progress was the need to transition to a new administration. However, while the national management plan calls for many actions that would likely contribute to preventing and controlling invasive species, even if the actions in the plan were more fully implemented their effect would be uncertain because they typically do not call for quantifiable improvements in invasive species management or control.

National Invasive Species Management Plan Does Not Clearly Define a Long-Term Outcome or Contain Performance Measures

The national management plan does not clearly define a long-term outcome or measures of success as are called for by sound management principles. The executive order states that the management plan shall “detail and recommend performance-oriented goals and objectives and specific measures of success for federal agency efforts concerning invasive species.” Consistent with that requirement, the council and its advisory committee adopted as one of their guiding principles that efforts to manage invasive species are most effective when they have goals and objectives that are clearly defined and prioritized. Both the executive order and this guiding principle are also consistent with the Government Performance and Results Act of 1993, which emphasizes setting measurable goals and holding agencies accountable by evaluating performance against those goals.

However, the council did not articulate in the plan a long-term outcome or condition toward which the federal government should strive. For example, the plan does not contain overall performance-oriented goals and objectives, such as reducing the introduction of new species by a certain percentage or halting the spread of established species on public lands. Instead, the plan contains an extensive list of actions that, while likely to contribute to preventing and controlling invasive species, are not clearly part of a comprehensive strategy.

Similarly, many of the actions in the plan call for the federal departments to take certain steps rather than achieve specific results and do not have measurable outcomes. For example, the plan calls for the council, starting in January 2001, to work with relevant organizations to “expand opportunities to share information, technologies, and technical capacity on the control and management of invasive species with other countries.” Another action item calls for the council to have outlined by June 2001 a plan for a campaign to encourage U.S. travelers to voluntarily reduce the risk of spreading invasive species overseas. Other actions call for the council to support international conferences and seminars. We believe that these types of actions are more process-oriented than outcome-oriented. Taken individually, the actions may be useful, but it will be difficult to judge whether or not they are successful and have contributed to an overall goal.

Respondents to our survey also raised concerns about the lack of measurability in the plan. While the majority of respondents (17 of 23) said that the plan is focused on the most important issues, 9 criticized it for a lack of specificity or a clear mechanism for measuring effectiveness or holding departments accountable for implementing it. Of these, several commented that it is unclear how we will know when actions are implemented and completed. Others noted that there are no consequences for the council, staff, or agencies if they miss deadlines. Other stakeholders made similar comments to us. For example, one person who was involved in the development of the management plan told us that it represents a “fundamentally misguided approach” and that it contains no coherent goal or measures of success. He said that the plan should have measures of success such as a reduction in the rate of introduction or spread of species. Another stakeholder said that the plan is unclear with regard to what actions would be enough to help solve the problem and echoed concerns about the difficulty measuring success. Eight respondents to our survey, however, made more positive comments about the degree of specificity in the plan, stating that the plan was clear, measurable, and achievable and that it had very specific actions with deadlines for agencies to implement.

The council acknowledged in the plan itself that many of the details of the actions called for would require further development in the implementation phase. The Department of the Interior’s Deputy Assistant Secretary for Performance and Management told us that the plan was developed with little input from people trained in performance management processes. In addition, the Executive Director of the council staff told us that, in her opinion, given the scope of this first-time effort, it would have been unrealistic and difficult to also agree on specific measurable goals. She also said that in many areas, the federal government does not have the data on invasive species conditions needed to set long- term goals and develop better performance measures. She said that many of the actions called for in the management plan are designed to help develop needed data. In their comments on our draft report, EPA and the Department of the Interior also noted that it would be difficult to apply performance measures to invasive species management activities.

The executive order calls for the council to revise the plan by January 2003. However, the Executive Director of the council told us that the council and the advisory committee had agreed not to begin revising the management plan until after the council prepares a progress report on the plan. That report is also due to the Office of Management and Budget (OMB) in January 2003.

The council is in the process of working with OMB on implementing one of the planned actions that should help to establish a desired outcome and relevant performance measures. The plan called for a crosscut budget proposal for federal agency expenditures concerning invasive species beginning in fiscal year 2003. The council and OMB are hoping to have a proposal ready for the fiscal year 2004 budget cycle. According to the Department of the Interior official responsible for this project on behalf of the council, the proposal will represent the beginnings of a strategic plan for the federal government’s invasive species activities. It will be performance-oriented with common long-term goals, intermediate goals, and definitions for the relevant departments. OMB will identify performance measures with help from a task team of federal stakeholders and will initially focus on early detection and rapid response, control, and prevention. According to the council, the proposal for fiscal year 2004 will not represent the totality of invasive species expenditures or efforts but will primarily focus on the activities of the Departments of the Interior, Agriculture, and Commerce.

National Invasive Species Council Departments Have Completed a Small Percentage of Actions in the Management Plan

While the council has not reported on implementation of the plan, we estimate that, as of September 2002, council departments had completed less than 20 percent of the actions that the plan had called for by that date. The departments have started work on other planned actions, including some that have a deadline after September 2002 and that the council believes are a high priority. When asked to assess implementation of the plan, 18 of the 21 advisory committee members who responded to that question said that the council was making inadequate or very inadequate progress. Survey comments and other evidence indicate various reasons for the lack of progress. Delays in implementing the plan will hamper agency efforts to prevent and control invasive species as intended by the executive order.

Lack of Departmental Reporting Hinders Measurement of Progress

It has been difficult to quantitatively measure the council’s progress in implementing the management plan because only 6 of the 10 member departments had submitted reports summarizing the steps they had taken to implement the plan. The plan calls for departments to submit such reports annually beginning in October 2001. Council staff aggregated the reports that were submitted into one summary of activities. These annual reports would be used to carry out yet another requirement of the executive order and management plan that calls for the council to revise the plan by January 2003.

Several survey respondents commented that it was difficult for them to evaluate the council’s progress in implementing the plan because information from the council had been inadequate. For example, some respondents wrote that the level of interaction between them and the council was not sufficient, and that feedback to the advisory committee from the council on implementation progress has been poor.

The management plan also calls for the council to establish a “transparent oversight mechanism” that engages public involvement. The purpose of the oversight mechanism would be for use by federal agencies in complying with the executive order and reporting on its implementation, which includes the management plan. The plan called for the mechanism to be in place by April 2001, but according to the council staff, work has not yet begun.

The Council Has Completed Less Than 20 Percent of Planned Actions

Our review of the council’s summary of department actions, which focused on the 65 planned actions with due dates through September 2002 (an additional 21 planned actions have due dates after September 2002, for a total of 86), revealed that less than 20 percent of the actions due by September 2002 were complete. 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.

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

In our view, while it is apparent that the agencies are taking various actions to address invasive species issues, the actions the agencies have reported to the council often do not represent coordinated progress toward implementation of the plan or management of the problem. The executive order and the management plan both emphasized the need for coordination among agencies. As evidence of that emphasis, a majority of the actions in the management plan are to be carried out by multiple agencies. However, the actions that the agencies reported to the council often did not appear to be directly linked to each other or be directly responsive to the specific actions called for by the management plan. In our survey, several advisory committee members also commented that coordination has been inadequate.

For example, the management plan called for the council to implement by January 2002 a process for identifying high-priority invasive species that are likely to be introduced unintentionally and for which effective mitigation tools are necessary. One agency noted to the council that it had contracted with professional societies to provide a list of the most harmful insect, weed, and disease plant pests that are not yet present in the country or present but not widely distributed. It also noted that it has a risk assessment procedure for identifying pests that may be introduced with commodities such as agricultural products. A second agency noted that it had held a workshop to identify potentially invasive species that might enter the nation’s waters from Eastern Europe. A third agency indicated that it is providing training for firefighters to reduce the spread of weeds from one fire site to another. While these activities are related to the planned action, they do not indicate that the agencies are working together through the council to implement a process for identifying high priority species as called for by the plan.

The Executive Director of the council acknowledged that some of the actions reported by agencies did not seem to directly link to the management plan, although such information was useful for overall coordination purposes. She said that in the future implementation teams would help the agencies focus on those actions that are directly linked to the management plan. The Executive Director and one of the Assistant Directors of the council told us that they believe that increased coordination has been an important accomplishment and that agency officials are now routinely talking with each other about invasive species management issues. In comments on our draft report, the Department of the Interior also noted that coordination and communication among the agencies has increased.

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

Our survey and other evidence indicate that the slow progress in implementing the management plan has been caused by a combination of factors, including delays in forming teams responsible for developing specific implementation plans, the lack of priority given to the plan by the council as a whole and by the departments individually, and insufficient funding specifically targeted to support the plan. Progress was also slowed by the need to transition from the previous administration to the current administration.

Delays Forming Implementation Teams

In October 2000, before issuing the management plan, the advisory committee and council staff agreed that implementation teams made up of federal and nonfederal stakeholders were needed to put the management plan into action. The advisory committee members and council staff agreed that the teams should be under the auspices of the advisory committee and be closely aligned to the major sections of the management plan. Specifically, the teams would be responsible for “delivery” of the planned actions. For example, a prevention team would be responsible for guiding implementation of the actions relevant to prevention. However, for various reasons, most implementation teams were not formed until June 2002. Specifically: The Executive Director of the council told us that she did not believe it would have been appropriate to form the implementation teams until after the management plan was issued in January 2001.

The change in administration then delayed action on implementing the plan by about 6 months because it took time for cabinet secretaries— the members of the council—and other political appointees to be nominated and confirmed; departments were ready to move forward with forming the implementation teams in the fall of 2001.

By that time, the first term of all of the advisory committee members was approaching its end in November 2001 and because the advisory committee members were to be an integral part of the implementation teams, the Executive Director told us it did not make sense to form the teams until the next advisory committee was convened.

Appointment of the second set of advisory committee members was delayed until April 2002 for a number of reasons, including the temporary loss of e-mail and regular mail delivery at the Department of the Interior.

The second advisory committee held its first meeting in May 2002, and committee members and council staff decided that the implementation teams should not meet until after the advisory committee members had a chance to review the teams’ responsibilities and membership and discuss them at greater length at their next scheduled meeting in June 2002.

In June 2002, nine implementation teams were created that largely mirror sections of the management plan (all but two of the teams will comprise federal and nonfederal members).

The Executive Director of the council told us the decision to create implementation teams of federal and nonfederal members under the auspices of the advisory committee was in part in recognition of the importance of getting consensus from key stakeholders early in the implementation process. She told us that she recognizes that there are potential problems with the teams comprising a disparate group of federal and nonfederal stakeholders. Specifically, logistical problems in getting the teams together and disputes within the teams could delay the federal departments in taking action to implement the plan. She said that the council would have to monitor the teams closely to determine whether or not they are effective.

The delay in establishing the implementation teams has hindered the agencies in achieving an important objective of both the executive order and the management plan—coordinated action. Several respondents to our survey commented that they had not seen adequate increases in the amount of coordination, and some pointed to the delays in forming the teams as a cause. One respondent thought that federal departments and agencies were continuing to pursue their own mandates and programs with only a cursory regard for the framework and coordination that the council attempts to provide. The Executive Director of the council told us that she expected coordination to improve as the implementation teams become established.

In our view, the relationship of the advisory committee to the implementation teams has slowed progress on the plan and could continue to do so. While we understand why the council decided to form the implementation teams under the auspices of the advisory committee—to foster consensus among key stakeholders early in the implementation process—we believe that this decision may slow federal action. Specifically, it may be difficult for teams of federal and nonfederal stakeholders to put forth the concerted effort needed to implement the management plan. We are also concerned that it will be difficult to hold the departments accountable for carrying out the plan if they are relying upon the actions of teams with federal and nonfederal members.

Lack of Priority from the Council and Its Member Departments

About one-half of the respondents to our survey criticized the council and the departments for not giving the plan a higher priority. For example, several noted that it did not appear that the council had positioned itself to take a leadership role in implementing the plan or that the plan was not a high priority on the agendas of the leaders of the council’s member departments. In addition, numerous survey respondents said that the individual departments needed to give the plan higher priority by providing better support in staff and resources.

Our review of agencies’ performance plans (prepared pursuant to the Government Performance and Results Act) also indicates that implementing the management plan is not a high priority for individual agencies. We reviewed the performance plans of the three cochair departments on the council (the departments of Agriculture, Commerce, and the Interior), as well as those of the Department of Transportation, the Environmental Protection Agency, and agencies within the Department of the Interior (National Park Service, Bureau of Land Management, Fish and Wildlife Service, and Geological Survey). While most of the agencies’ performance plans describe activities intended to control or manage invasive species—and are therefore consistent with the national management plan—none of the plans specifically identified as a measure of performance implementing actions called for by the council’s plan. As one official from the Environmental Protection Agency told us, activities that are not in the agency’s performance plan do not receive a high priority. Nevertheless, the Department of the Interior official responsible for pulling together the crosscut budget for invasive species programs told us that he believes that process—because of its emphasis on performance measures—will help departments link the management plan to their performance plans.

With regard to the notion that the council was not giving the plan a high priority, three of the 23 advisory committee members who responded to our survey commented on the absence of specific legislative authority establishing the council. One stated “the council needs to be approved legislatively so that they are their own entity with better options to act.” Another said “Congress or the President needs to make this a priority through legislation or funding. . . . Agencies need to be told this is a priority and given funding to accomplish their goals.” Because executive orders such as the one that established the council do not provide any additional authority to agencies, the Executive Director of the council noted that legislative authority for the council, depending on how it was structured, could be useful in implementing the management plan. Officials from USDA, the Department of Defense, and EPA who are departmental liaisons to the council also told us that legislative authority, if properly written, would make it easier for council departments to implement the management plan. The Congress has recently considered legislation that would give the council certain responsibilities; namely to provide input into decisions about allocating funds to local governments and other organizations for controlling invasive plants. However, the Executive Director of the council told us that such a requirement would be unworkable if the legislation did not also formally establish the council and a future administration decided to discontinue the executive order that created the council.

The management plan calls for the council to conduct an evaluation by January 2002 of the current legal authorities relevant to invasive species. The council has not completed the evaluation. According to the plan, the evaluation is to include an analysis of whether and how existing authorities may be better utilized and could be used to develop recommendations for changes in legal authority. However, it does not state that the analysis should address whether the council itself is hampered in its mission by not having specific legislative authority that would allow it to direct its members to implement the national management plan.

Insufficient Funding and Staff

In the management plan, the council stated that many of the actions could be completed or at least initiated with current resources but that without significant additional resources for existing and new programs it would not be possible to accomplish the goals of the plan within the specified timeframes. The council also noted in its comments on the draft report that it believes the timeframes in the plan are optimistic given current resources. Two of the actions in the plan called for federal agencies to request additional funding for separate management functions through the annual appropriations process beginning in fiscal year 2003. According to a summary prepared by the council, the President’s budget request for invasive species activities in fiscal year 2003 was at least 23 percent more than was requested in fiscal year 2002 (although slightly less than Congress appropriated in fiscal year 2002). The council went on to say in the plan that estimates of the additional support required would depend on the details of implementation schedules developed by federal agencies and stakeholders. As we described above, however, the council and the advisory committee have only recently created the teams that will be responsible for working out the detailed plans for implementation. Therefore, it is unclear what additional resources are needed and whether the requested appropriations will be adequate to implement the plan.

In response to several of the questions in our survey, advisory committee members cited the lack of funding as a key reason for poor implementation of the council’s management plan. (We did not independently assess the adequacy of funding.) Of the 18 who said that the council was inadequately implementing the plan, 9 said that funding was insufficient. A typical comment was that the council members need to make a better case to get Congress to support funding for an invasive species line item. Over 70 percent of the respondents to another question said that they knew of instances where federal agencies do not have the resources to carry out actions in the national management plan. While several respondents gave details on specific examples of where they believe federal agencies have underfunded invasive species programs, four others said that none of the agencies have the resources to implement the management plan in its entirety.

In addition, 19 of the 21 respondents to one question said that the council had inadequate staff resources to serve the needs of the council. (The council has had a staff of five to seven people in the last 2 years.) One respondent said that the “level of funding now is token only and serves to support the most minimal staffing one can imagine for a national effort of this scale. It’s embarrassing.” Many of the respondents said that the council’s staff are working hard and doing the best that they can. However, respondents also commented that the staff is overwhelmed, faced with substantial obstacles, and is not sufficient to support both the council and advisory committee. Several respondents emphasized that the council staff should be larger to more effectively push for implementation of the management plan.

Transition to New Administration

Finally, the Executive Director of the council staff told us that, in her opinion, progress on the management plan was slowed by the transition to a new administration. High-level political appointments are often vacant for months during the transition from one administration to another. A senior official from the Department of the Interior pointed out in July 2002 that many key managers relevant to the crosscutting budget proposal had been in office only a few months because of the time required to nominate and approve political appointees.

The Current Regulations Concerning Ballast Water Management Are Not Keeping Invasive Species Out of the Great Lakes

According to experts and agency officials we consulted, current efforts by the United States and Canada are not adequate to prevent the introduction of nonnative aquatic organisms into the Great Lakes via ballast water of ships, and they need to be improved. Compliance with regulations is high but nonnative aquatic organisms are still entering and establishing themselves in the Great Lakes ecosystem. U.S. and Canadian agency officials believe that they should do more to protect the Great Lakes from ballast water discharges. However, several time-intensive steps must be taken before the world’s commercial fleet is equipped with effective treatment technologies. In the meantime, the continued introduction of nonnative aquatic organisms could have a major economic and ecological impact on the Great Lakes.

Compliance with U.S. Regulations Is High, but Nonnative Aquatic Organisms Are Still Entering the Great Lakes

Since 1993, U.S. regulations have governed how vessels entering the Great Lakes from outside the Exclusive Economic Zone, a zone extending 200 nautical miles from the shore, must manage their ballast water. 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.

Regulatory Decisions, Technological Developments, and Ship Modifications Needed to Significantly Reduce Ballast Water Invasions Will Take Many Years

According to experts we consulted, it will take many years to solve the problem of nonnative aquatic organisms arriving in ballast water. The Coast Guard is now working to develop new regulations that would include a performance standard for ballast water—that is, a measurement of how “clean” ballast water should be before discharge within U.S. waters. In May 2001, the Coast Guard requested comments on how to establish a ballast water treatment standard and offered for consideration four conceptual approaches. The agency received numerous comments showing a wide range of opinion. As a result, it issued an advanced notice of proposed rulemaking and another request for comments in March 2002 on the development of a ballast water treatment goal and an interim ballast water treatment standard. The Coast Guard is expecting to have a final rule ready for interdepartmental review by the fall of 2004 that will contain ballast water treatment goals and a standard that would apply not only to ships entering the Great Lakes but also to all ships entering U.S. ports from outside the Exclusive Economic Zone.

Once the Coast Guard sets a new performance standard for how clean ballast water should be, firms and other entities will have a goal to use as the basis for developing and measuring treatment technologies. Government, industry, academia, and other nongovernment interests are investigating several technologies, including filtration, hydrocyclonic separation, and chemical and physical biocides such as ozone, chlorination, ultraviolet radiation, heat treatment, and vacuum. Each technology has its strengths and weaknesses. One major hurdle facing any technological solution is how to treat large volumes of water being pumped at very high flow rates. Container vessels and cruise ships, which carry a smaller volume of ballast water, may require different technologies than larger container vessels. As a result, it is likely that no single technology will address the problem adequately. To facilitate technology development, the Coast Guard and the Department of Transportation’s Maritime Administration are developing programs to provide incentives for ship owners to actively participate in projects designed to test treatment technologies.

To help with technology development, the National Invasive Species Act created a ballast water demonstration program that funds select proposals to develop and demonstrate new ballast water technologies. Under this program, the National Oceanic and Atmospheric Administration and the U.S. Fish and Wildlife Service have funded 20 ballast water technology demonstration projects at a total cost of $3.5 million since 1998. Other programs also support research, such as the National Sea Grant College Program, which has funded nine projects totaling $1.5 million. In addition, the National Oceanic and Atmospheric Administration, through the National Sea Grant College Program, and the U.S. Fish and Wildlife Service announced on June 6, 2002, that they expect to make $2.1 million available in fiscal year 2002 to support projects to improve ballast water treatment and management. In conjunction with this program, the Department of Transportation’s Maritime Administration expects to make available several ships of its Ready Reserve Force Fleet to act as test platforms for ballast water technology demonstration projects. In fiscal years 2001 and 2002, Congress appropriated $550,000 to the Coast Guard for research and development related to ballast water management. In addition, EPA and the Coast Guard expect to contribute $210,000 to fund a 3-year study on the transfer of aquatic organisms in ballast water. Nonfederal researchers in industry and academia are also studying the content of ballast water and prospective treatment technologies. For example, a Canadian shipping company funded the installation of a treatment system on one of its ocean- going ships and allowed the Michigan Department of Environmental Quality to perform testing on the system.

Once effective technologies are developed, another hurdle will be installing the technologies on the world fleet. 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).

The Continued Introduction of Nonnative Aquatic Organisms Via Ballast Water Could Have Major Economic and Ecological Effects on the Great Lakes

Although no estimates have been made, using the past as a guide, the continued introduction of nonnative aquatic organisms into the Great Lakes could have significant economic and ecological impacts on the Great Lakes basin. 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.

There Is a Growing Interest in Coordination between the United States and Canada, but a Comprehensive Approach Has Yet to Be Developed

The United States and Canada participate in a variety of bilateral and multilateral efforts to share information, conduct research, and coordinate efforts to reduce the threat of invasive species. The two countries’ long history of coordination has focused on particular segments of the issue such as shared boundary waters and agricultural research, and stakeholders have called for a more comprehensive strategy for joint prevention and management efforts. The National Invasive Species Council recognized the need for the United States to work with Canada (and Mexico) in a more comprehensive manner and has taken initial steps to develop a North American strategy as called for by the national management plan. It is too early to tell, however, what form a North American strategy will take or how existing organizations will be integrated.

Coordination Between the Two Governments Has Focused on Specific Issues or Geographic Regions

Historically, coordination between the United States and Canada has focused on specific pathways, species, or geographic areas rather than on a comprehensive coordinated approach. Primary examples of this coordination concern shared boundary waters and agriculture.

Shared Boundary Waters

One mechanism for coordination is the International Joint Commission, which was established by the Boundary Waters Treaty of 1909. The treaty established the commission to advise the U.S. and Canadian governments concerning issues along the boundary and approve certain projects in boundary and transboundary waters that affect water levels and flows across the boundary. The commission has focused much of its attention on the Great Lakes. The purpose of the 1978 Great Lakes Water Quality Agreement between the United States and Canada is to “restore and maintain the chemical, physical, and biological integrity of the waters of the Great Lakes Basin Ecosystem.” The International Joint Commission’s role with respect to the agreement includes evaluating and assessing the two countries’ programs and providing a report at least every 2 years that presents its findings, advice, and recommendations. Recent reports have contained recommendations to the governments on how to reduce the flow of invasive species through ballast water.

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.

Agricultural Research and Pest Control

There has also been a long history of coordination between the U.S. and Canada in the area of agricultural research and pest control. As we reported in July 2002, for over 30 years the two countries and Mexico have held regular meetings on animal health issues to make North America’s import requirements consistent and, more recently, to coordinate preventive actions and emergency response activities in the event of an outbreak of the nonnative foot-and-mouth disease. 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.

Stakeholders Have Called for Increased Coordination between the United States and Canada

While there are numerous examples of coordination between the United States and Canada on invasive species control, some stakeholders in this issue believe that not enough is being done. For example, in June 1999, the Great Lakes Panel on Aquatic Nuisance Species wrote that there was a lack of inter-jurisdictional consistency in laws, regulations, and policies directed at aquatic nuisance species prevention and control efforts, and that improvements were needed to ensure a more efficient and effective regional prevention and control program.

As noted previously, the International Joint Commission stated its belief that the two governments were not adequately protecting the Great Lakes from further introduction of aquatic invasive species and it made several recommendations regarding a binational approach to better management. In addition, according to EPA, there are numerous locations where there is a need for continuing regional cooperation to address aquatic invasive species in binational waterways, including the St. Croix River of New Brunswick and Maine; Lake Champlain of Quebec, Vermont, and New York; the Red River of North Dakota, Minnesota, and Manitoba; the Souris River of Saskatchewan, Manitoba, and North Dakota; and the Georgia Basin- Puget Sound of British Columbia and Washington. For example, in the Red River watershed of North Dakota, a proposed water diversion could introduce nonnative species into new locations. An official from EPA’s Office of International Affairs told us that, in his opinion, having an overarching policy with respect to aquatic invasive species along the border would help better address these situations more quickly or avoid them completely.

The National Invasive Species Council’s Assistant Director for International Policy, Science, and Cooperation told us that she believes that the United States could expand two existing interagency organizations—the Federal Interagency Committee for the Management of Noxious and Exotic Weeds and the Aquatic Nuisance Species Task Force—to include Canadian representation, or that Canada should be encouraged to develop similar organizations. She said this would make it much easier to establish dialogue between officials with similar responsibilities. The council’s Assistant Director also said she thought that the National Oceanic and Atmospheric Administration’s Sea Grant Program could be more effectively used to support educational programs developed and implemented in the United States and Canada. She noted that because tourists frequently cross the border to and from Canada it is important to address this pathway with a common education strategy. In this same vein, while we reported in August 2002 that the United States, Canada, and Mexico have worked to coordinate animal health measures, we also noted that there are differences in the countries’ policies and practices with regard to foot-and- mouth disease that could contribute to the risk that travelers may bring foreign animal disease across our mutual borders.

The National Invasive Species Council Has Taken Initial Steps Toward Developing a North American Strategy, but its Form Is Not Yet Known

The National Invasive Species Council recognized the need for the United States to work with Canada (and Mexico) in a more comprehensive manner. The management plan called for the council to outline an approach to a North American invasive species strategy by December 2001. The strategy was to be built upon existing tripartite agreements and regional organizations. The plan also called for the council to initiate discussions with Canada and Mexico for further development and adoption of the strategy. The council has taken initial steps but has not completed this planned action.

The council established the North America Strategy task team in January 2002. It comprises federal and nonfederal stakeholders, and is cochaired by the Department of State, the Environmental Protection Agency, and the Fish and Wildlife Service. In March 2002, the Department of State sent a cable to United States embassy staff in Canada and Mexico requesting that they notify officials in those two countries of the federal government’s desire to develop a North American strategy. According to one U.S. official involved in this project, Canadian representatives have responded positively to the idea.

In the time since it sent the memorandum, however, the team has done little to develop the strategy. The council staff and the advisory committee placed the team into a holding pattern in May 2002 when they decided that all of the implementation teams needed to be reviewed by the advisory committee. According to one of the cochairs of the team, among other things that the team will need to do is identify the objectives of the U.S. participation in the various North American organizations and determine what actions are being taken.

Two other multilateral organizations provide opportunities for a more comprehensive approach to an invasive species strategy across North American borders but do not have significant resources dedicated to the issue. The North American Commission on Environmental Cooperation, which is governed by a council composed of the Administrator of the United States Environmental Protection Agency, the Minister of the Environment in Canada, and the Secretary of the Environment and Natural Resources in Mexico, provides an opportunity for the United States and Canada to research and develop strategic plans for common ecosystems such as northern forests, grasslands, and aquatic ecosystems. 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.

Conclusions

While the available data are often inadequate to thoroughly describe the costs and risks associated with invasive species, it is apparent that their impacts on our environment and, thus, our economy are significant. At the same time, because of limitations in both the quantity and quality of economic impact analysis, it may not be readily apparent to decision makers in the federal government how they should most effectively allocate limited resources to prevent and manage invasive species. It is encouraging that the National Invasive Species Council and OMB are working on a crosscut budget that the federal government can use to plan resource allocations to and among departments. Such decisions would be better informed by information and data on the risk that nonnative species will enter the country, become established, spread, and cause harm. The ballast water management situation is a prime example. The federal government faces decisions about dedicating resources to fund ballast water technology research or standard setting, and ultimately about imposing more protective regulations. Decision makers could weigh the costs of those activities against the potential costs of the next zebra mussel or sea lamprey to arrive in U.S. waters, if such data were readily available.

Moving ahead with a comprehensive management plan to combat invasive species is clearly in the national interest. It also poses a daunting challenge. Success in this effort will depend in no small part on crafting a plan that calls for clearly defined, measurable outcomes and has a mechanism in place to hold departments accountable for carrying it out. The National Invasive Species Council now has the opportunity to improve upon its management plan in a revision due in 2003. Successful implementation of the plan depends in part on the members of the council making it a priority within their own departments and agencies and, recognizing the enormity of the task ahead, developing estimates of the resources needed. Statements from various stakeholders suggest it is possible that federal agencies could better coordinate their efforts to implement the management plan if the Congress established the council in legislation. The management plan states that the council will conduct an analysis of legislative authorities relevant to invasive species. We believe that the evaluation should also examine the question of whether the lack of legislative authority establishing the council is hampering the council in its efforts to implement the national management plan.

Recommendations for Executive Action

To better manage the threats posed by invasive species in the United States, we recommend that the cochairs of the National Invasive Species Council—the Secretaries of Agriculture, Commerce, and the Interior— direct council members to: Include within the revision to the National Invasive Species Management Plan a goal of incorporating information on the economic impacts and relative risks of different invasive species or pathways when formulating a crosscuting invasive species management budget for the federal government. Such a goal may require a commitment from the council to ensure that adequate resources are dedicated within the federal government to expand the capacity for conducting appropriate economic analysis.

Ensure that the updated version of the national management plan, due in January 2003, contains performance-oriented goals and objectives and specific measures of success.

Give a high priority to completing planned action #1, which calls for establishing a transparent oversight mechanism for use by federal agencies in complying with Executive Order 13112 and reporting on implementation of the management plan.

Include in its planned evaluation of current legal authorities an examination of whether the lack of legislative authority establishing the National Invasive Species Council and specifically directing its members to implement the national management plan hampers the council’s efforts to implement the plan.

To better ensure the implementation of the national management plan, we recommend that the members of the National Invasive Species Council who are responsible for taking actions called for in the plan recognize their responsibilities in either their departmental- or agency-level annual performance plans. The annual performance plans and performance reports should describe what steps the departments or their agencies will take or have taken to implement the actions that are specifically called for in the national management plan. For the existing (2001 version) of the national management plan, the member departments to which this applies include the Departments of Agriculture, Commerce, Interior, Defense, State, and Transportation, and the Environmental Protection Agency.

Agency Comments and Our Evaluation

We provided copies of our draft report to the Departments of Agriculture, Commerce, Defense, Treasury, State, Transportation, and the Interior; the Environmental Protection Agency; the U.S. Trade Representative; and the National Invasive Species Council. We received written comments from the Department of the Interior, the Department of State, the Environmental Protection Agency, and the National Invasive Species Council. We received oral comments from the Departments of Transportation, Agriculture, and the Treasury. The written comments from the Department of the Interior, the Department of Agriculture, the National Invasive Species Council, and EPA are in appendixes II through V.

The Department of the Interior concurred with the recommendations in the report and said that it would work with the other cochairs of the National Invasive Species Council to implement the recommendations in a timely manner consistent with current budget and authority. While agreeing with the recommendations, the department expressed the view that our draft report did not adequately acknowledge the extensive invasive species activities that federal agencies are doing outside of what is called for by the national management plan. We agree that federal agencies are engaged in other invasive species management activities and have described many of them in prior reports. A principle objective of this review, however, was to assess the implementation of the national management plan, and not all federal activities. The department also commented that it believes that the Fish and Wildlife Service, the National Oceanic and Atmospheric Administration, and the Maritime Administration are demonstrating substantial progress in developing technologies to treat ballast water. We agree that progress is being made, but continue to believe that much important work remains to be done. To illustrate this, we reported the Coast Guard’s estimate that it may be at least 10 years before ships must meet a new performance standard for ballast water treatment, a step critical to real progress. The department suggested several other minor changes that we have incorporated where appropriate.

The Department of State commented that it did not fully concur with our finding that the slow progress on the national management plan is due to lack of priority given to the plan by the Council and departments. The department claimed that it places a high priority on accomplishing the goals of the management plan, and it itemized numerous activities in support of that statement. We do not disagree with the department’s claims. However, we did not evaluate the efforts or progress of one department versus another; instead, we evaluated implementation of the management plan overall. The letter from the Department of State also included comments from the International Joint Commission. The commission suggested that we include a recommendation that the federal government work with Canada to develop an effective approach to immediately improve the management of all ballast waters coming into the Great Lakes. Our report describes the current and expected situation with respect to ballast water in the Great Lakes. We believe that the decision to take more immediate action to solve the problem is a policy decision best left to the Congress or the administration. The commission also suggested that we ask the Congress to consider completing reauthorization of the National Invasive Species Act. While we recognize the importance of the commission’s suggestion, we did not evaluate the current proposal to reauthorize the act. The department and the commission also offered minor corrections, which we have made.

The National Invasive Species Council concurred with our recommendations but made several clarifying comments. In particular, it noted that the management plan’s deadlines were optimistic and suggested that we should have evaluated whether the deadlines were realistic or attainable. We believe that an assessment of its deadlines is an appropriate task for the council when it revises the management plan. In addition, the council commented that the report undervalued the progress being made toward coordination and cooperation among federal agencies and gave examples of such activity. We acknowledge that coordination between departments has increased as a result of the creation of the council and the management plan, and we have added language to support this point. Nevertheless, the report provides support for the position that improvement can still be made in this area. Finally, the council made other minor comments that we have incorporated where appropriate.

The Environmental Protection Agency commented that our recommendations were reasonable and believes that their implementation would enhance the federal government’s response to dealing with the problem of invasive species. The agency also noted that the report is well written and helpful in assessing the progress made in coping with invasive species. The agency also made several clarifying comments that we have incorporated where appropriate. The agency questioned whether we should have based our conclusions about the pace of implementation of the management plan solely on the results of our survey of the members of the first term of the advisory committee, given the small size of the population and their possible biases. We did not draw our conclusions about the pace of implementation solely, or even primarily, from the survey. Our statement that less than 20 percent of the plan has been implemented is based on our analysis of information from the National Invasive Species Council staff and the council’s member departments. EPA also noted that the report’s section on ballast water focused on the Great Lakes and pointed out that work is being done and needs to be done in other parts of the country. We agree that ballast water is an important issue in other parts of the country. However, our objective, as part of our coordinated review with the Canadian Office of the Auditor General, was to focus on the Great Lakes. Finally, EPA made a number of technical clarifications that we have incorporated, where appropriate, in the report.

The invasive species coordinator for the Department of Agriculture said that our comments on the implementation of the national management plan were fair and on target. This official also provided two minor clarifying comments that we have incorporated.

The Department of Transportation’s Director for Performance Planning in the Office of Budget and Program Performance provided oral comments on the draft. He told us that the department disagreed with our draft recommendation calling for the members of the National Invasive Species Council to incorporate the national management plan into their annual performance plans. He said that the department does not believe that it is appropriate to include performance goals with respect to invasive species in its performance plan because managing invasive species is not one of its core missions. In addition, he told us that the agencies within the department that have a more direct role with respect to invasive species, such as the Coast Guard, Maritime Administration, and Federal Highway Administration, are at liberty to include invasive species management goals in their annual performance plans. In response to this comment, we modified the wording of the recommendation to specify that the national management plan should be addressed in the most appropriate annual performance plan, whether at the departmental level or the agency level. The department also commented that there are many mechanisms other than ballast water by which invasive species are introduced into the environment. We agree, and noted some of them in the report. However, our objective specifically focused on the issue of ballast water in the Great Lakes.

A representative with the Office of Planning in the Department of the Treasury's U.S. Customs Service told us that because the current national management plan does not call for the Customs Service to undertake significant activity on invasive species, it does not believe that it is appropriate for it to address the management plan in its annual performance plan as called for in our recommendation. We acknowledge that the current plan does not have action items directed to the Customs Service, and we modified our recommendation to clarify its applicability to those member agencies that are specifically responsible for action items in the existing (2001) national management plan. If future versions of the plan specify action items for other agencies, we would encourage them to follow the same practice with regard to their department- or agency-level annual performance plans. The Customs Service made no technical comments.

We are sending copies of this report to the other members of the National Invasive Species Council: the Secretaries of State, Defense, Transportation, Health and Human Services, and Treasury, and the Administrators of the Environmental Protection Agency and the U.S. Agency for International Development. We are also sending copies of this report to the Chairmen and Ranking Minority Members of the following congressional committees: the Senate Committee on Agriculture, Nutrition, and Forestry; the Senate Committee on Commerce, Science, and Transportation; the Senate Committee on Environment and Public Works; the Senate Committee on Energy and Natural Resources; the Senate Committee on Foreign Relations; the Senate Committee on Appropriations; the House Committee on Agriculture; the House Committee on Resources; the House Committee on Science; the House Committee on Transportation and Infrastructure; the House Committee on Energy and Commerce; the House Committee on International Relations; and the House Committee on Appropriations. We will make copies available others upon request. This report is also available on our Web site at www.gao.gov. If you have any questions concerning this report, I can be reached at (202) 512-6878. Major contributors to this report include Trish McClure, Ross Campbell, Patrick Sigl, Don Cowan, Anne Stevens, and Amy E. Webbink.

Scope and Methodology

To determine the usefulness to decision makers of economic impact studies for invasive species in the United States, we reviewed economics and other policy literature that analyzes invasive species’ effects on the U.S. economy and ecosystems. We also reviewed the literature that describes and evaluates U.S. regulatory policies for invasive species. We paid particular attention to the literature that evaluates how well cost- benefit analyses of invasive species’ effects, and of regulatory policies to control them, have been adjusted to reflect uncertainties and risks associated with these assessments. To further determine the usefulness of the existing studies, we selected and interviewed experts, including some authors of studies, and government officials involved in both authoring and using the economic impact studies. We identified these experts through our literature search.

To assess the National Invasive Species Management Plan, including the extent to which the United States government has implemented it, we first analyzed the content of the plan in relation to the requirements spelled out in Executive Order 13112. In particular, we analyzed the extent to which it contained “performance-oriented goals and objectives and specific measures of success for federal agency efforts concerning invasive species.” The plan contains 57 enumerated actions. However, several of those actions have distinct subparts. In consultation with council staff, we agreed that there are a total of 86 distinct actions called for by the plan. To evaluate the extent to which the plan has been implemented, we focused primarily on those actions that had a start or completion date of September 2002 or earlier. There are 65 actions in that category. To determine whether actions had been completed, were in progress, or had not been started, we relied on the National Invasive Species Council’s summary of agency progress, materials provided to us by agency officials, and interviews with council staff and agency officials. For those actions that had been started but not completed, we did not attempt to characterize the extent to which they had been completed. In only a few instances did we attempt to determine when incomplete actions would be complete.

To assist in our evaluation of the plan and our assessment of its implementation, we surveyed the 32 people serving on the Invasive Species Advisory Committee for a 2-year term beginning in December 1999. We had several reasons for surveying this group: (1) they participated in developing the national management plan; (2) they represented a wide range of interests relevant to the invasive species issue; and (3) by virtue of their professions and their involvement with the committee, they were likely to have information and opinions on how the management plan was being implemented. The Secretary of the Interior reappointed 15 of these 32 people for another term on the advisory committee beginning in April 2002.

One of the members of the original advisory committee told us that he had resigned from the committee partway through his term and did not believe that he was informed enough about events surrounding the council, the committee, or the management plan to respond to our survey. Therefore, for the purposes of calculating a response rate, we are using 31 as the size of our survey population. Twenty-one of the 31 members of the committee completed our survey, while 2 others completed a small portion of the survey. Therefore, while the response rate was 74 percent, the completion rate was 68 percent. Thirteen of the 15 people reappointed to the committee responded to the survey.

The survey instrument contained questions that asked for either numerical or open-ended answers. The survey, including a tally of the numerical answers, is in appendix IV. Because we did not take a sample of the committee members, the numerical answers are presented as a straight percentage of the total number of respondents. There are no error rates associated with the results. We did not reprint the open-ended answers in the report because they are too numerous and lengthy.

To determine the experts’ views on the adequacy of U.S. and Canadian efforts to control the introduction of invasive aquatic species into the Great Lakes via the ballast water of ships, we selected and interviewed experts from various stakeholder interests. We identified experts through a literature search and by soliciting the names of other expert contacts throughout our review. In the end, we contacted experts from U.S. federal agencies, academic institutions, and the shipping industry. We also met with staff from two binational agencies—the International Joint Commission and the Great Lakes Fishery Commission—and with representatives of the Great Lakes Commission. In addition, we attended a conference on aquatic nuisance species to obtain opinions from a range of stakeholders on ballast water and associated shipping vectors.

To describe the current management of ballast water in the Great Lakes, we researched U.S. and Canadian legislation, regulations, and guidelines. In order to determine the compliance rate and effectiveness of the current regulatory regime for the Great Lakes, we obtained compliance and other data from the Coast Guard Marine Safety Detachment and the Saint Lawrence Seaway Development Corporation in Massena, New York. The Saint Lawrence Seaway Development Corporation also showed us the U.S. ballast water inspection procedures on a vessel docked in Montreal, Canada, and bound for the Great Lakes. We also reviewed studies on the introduction of nonnative aquatic organisms traced to ballast water, paying particular attention to those that have invaded after the ballast water regulations for vessels entering the Great Lakes took effect in 1993. We interviewed both United States and Canadian scientists on the significance of the continued invasions since 1993.

For the international perspective on ballast water management, we reviewed the history and development of the current International Maritime Organization policies and guidelines. We also met with members of the U.S. delegation to the organization to determine the status of negotiations on a future international agreement related to ballast water. These officials represent the United States on the Marine Environmental Protection Committee and lead the correspondence group that is tasked with developing a performance standard for the future International Maritime Organization Convention on ballast water management.

To describe coordination between the United States and Canada, we interviewed officials from departments in the National Invasive Species Council to determine if their departments were involved in any significant efforts to coordinate with Canadian officials on invasive species management. From these discussions, we learned that coordination efforts on a binational (or in some cases trinational) level have focused primarily on shared boundary waters and agriculture. We obtained further information from the relevant departments on the nature of those coordination efforts. To learn more about how nonfederal organizations can play a role in coordinating the work of the two countries, we interviewed and obtained documents from officials representing the International Joint Commission, the Great Lakes Fishery Commission, the Great Lakes Commission, and the North American Commission on Environmental Cooperation. We also obtained documentation that described relevant work being done by the International Plant Protection Organization, the North American Plant Protection Organization, the North American Animal Health Committee, and the Trilateral Committee for Wildlife and Ecosystem Conservation and Management. Finally, we relied on previous GAO work on foot-and-mouth disease.

In choosing invasive species to profile, we judgmentally selected species that (1) illustrate problems in a variety of environments (aquatic, terrestrial, managed, and natural areas), (2) are drawn from a wide variety of taxonomic groups (vertebrate, invertebrate, virus, and plant), (3) include some that are well known by the public and others that are not, and (4) provide a selection whose distribution collectively covers a large portion of the United States. We collected and reviewed data on the species from federal agencies, academic institutions, and previous GAO reports. We obtained photographs of species from the U.S. Geological Survey and USDA.

We conducted our review from November 2001 through September 2002 in accordance with generally accepted government auditing standards.

Survey of Charter Members of the Invasive Species Advisory Committee

Comments from the Department of the Interior

Comments from the Department of State

Comments from the National Invasive Species Council through the Department of the Interior

Comments from the Environmental Protection Agency

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