83 



114 I Harmful Non-Indigenous Species in the United States 



proaches to NIS risks generally (26), as have the 

 research and testing of new biological control 

 agents (ch. 5). The standard paradigm for analyz- 

 ing risks of these specialized releases relies much 

 more heavily on experimentation, including con- 

 trolled, small-scale trial releases, than is normally 

 done for other proposed NIS releases. 



Recent technological advances have made 

 some CTtpcnmcntal releases safer. For certain 

 species, scientists can ensure that released NIS 

 are infertile through sterilization, birth control, or 

 other manipulations such that no more than one 

 generation will survive (ch. 5). Fisheries biolo- 

 gists have used these techniques to assess new 

 introductions of fish and shellfish (51). Some 

 advocate the use of these reproductive control 

 techniques as a precondition for aU experimental 

 releases (67). 



Experimentation can provide data critical for 

 linking mathematical models to ecosystem be- 

 havior, especially for generalized theories of 

 ecosystem response to stress (39). Experimenta- 

 tion also informs the optimal design of monitor- 

 ing systems and the apportioimient of contain- 

 ment or control efforts according to the risks 

 involved. In one facility in England, experiments 

 on invasions are conducted in a large laboratory 

 with 16 connecting microcosm chambers (38). It 

 allows the assembly of a wide variety of plant and 

 animal communities in computer-controlled envi- 

 roimients. Still, organisms can behave quite 

 differently in the real world than they do in 

 experimental settings because of untested, often 

 tmantic^ated, influences. The possibility of chaos 

 in ecological systems suggests that making accu- 

 rate piredictions may be more con^lex than 

 anticq)ated (19,60) and not a matter necessarily 

 solved by accumulating more data for better 

 models. 



Experimental analyses for NIS (other than 

 GEOs and biological control agents) are not 

 consistently done or required by Federal or State 

 laws. Despite difficulties in interpreting results 

 from smaU-scale trial releases, experts have 

 called for more use of these and other experimen- 



tal approaches as providing better predictions 

 than the largely anecdotal "paper" studies that 

 dominate now (40). An experimental approach 

 would require more persoimel, funding, and time. 



RISK ANALYSIS BY FEDERAL AGENCIES 



Finding: 



Within the Animal and Plant Health Inspec- 

 tion Service (APHIS) of the U.S. Department of 

 Agriculture (USDA), there is great variation as 

 far as the stringency of its risk analysis 

 procedures for different types of NIS importa- 

 tion. Internal proposals to improve and stand- 

 ardize risk analysis procedures have not been 

 broadly implemented. XHJ LCxisting policie s 

 hamper the agenc y's effectiveness at keeping 

 new , harmful NI S from entering the countt;^ ': 

 Its lack of explicit focus on risks to non - 

 agricultural areas, and its general operation 

 under the presumption that unanalyzed iin - 

 ports will be admitted unless risks are proven. 

 Still, APHIS is more analytical than FWS. 

 FWS has implemented very little scientiFic risk 

 analysis for potentially harmful flsh and wild- 

 life. 



The primary Federal responsibility for regu- 

 lating NIS hes with USDA's APHIS and the 

 Department of Interior's FWS (see ch. 6). APHIS 

 can regulate both private and governmental ac- 

 tions that pose risks of introducing agricultural 

 and forestry pests, including weeds. FWS is 

 responsible for "injurious" fish and wildlife 

 under the Lacey Act, which, as applied, primarily 

 means species that threaten interests outside 

 agriculture. 



Animal and Plant Health Inspection Serv- 

 ice — ^Much of current APHIS risk analysis con- 

 sists of preparing a "decision sheet," which often 

 includes only a paragrsqjh or two on the biology 

 of a jjrospective plant pest (80). Great variation 

 exists within APHIS as far as the stringency of 

 analysis (26). Comprehensive assessments of 

 pirobabilities and risks are rarely undertaken. The 

 agency is revising a number of its regulatory 



