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in part, developing risk assessment and risk management processes to evaluate en- 

 vironmental pests as well as pests causing more traditional economic damage. This 

 task force will address NIS in non-agricultural areas as well. APHIS recognizes that 

 its services can benefit non-agricultural areas. Likewise, APHIS' programs to control 

 certain types of noxious weeds and vertebrate pests are protecting native 

 ecosystems. APHIS is willing to work with Congress and other agencies in any way 

 to determine the necessary resources, and/or priorities to address issues related to 

 non-indigenous species. 



In addressing the problems associated with non-indigenous species in Hawaii, 

 OTA suggested that a greater Federal role may be warranted. OTA also recognized, 

 however, that increased Federal involvement in domestic arrival inspections in Ha- 

 waii would require a change in APHIS' mandate, as well as increased staffing and 

 other resources for the Agency. As a means of further protecting Hawaii, APHIS is 

 currently working on implementing a program for inspection of first-class mail ft-om 

 the mainland to Hawaii which was authorized by the Alien Species Prevention and 

 Enforcement Act of 1992. APHIS has had several meetings with the U.S. Depart- 

 ment of Interior, the U.S. Postal Service, and the Hawaii Department of Agriculture 

 in Honolulu and in Washington. APHIS is working to develop appropriate Memo- 

 randums of Understanding with the Department of Interior, and other agencies. 



The OTA also noted that "APHIS does not consistently prevent repeated importa- 

 tion of pest species that are already established here. New, different strains of some 

 species potentially may be imported, worsen effects, and spread into areas where 

 the pest is not yet well-established." We acknowledge this potential type of danger; 

 protecting against these tj^jes of pests is not inconsistent with the Agency's mission. 

 However, we do not currently attempt to prevent introduction of all pest species 

 that are already established here for a number of reasons. While we have authority 

 to regulate introductions of plant pests, regardless of whether or not they are al- 

 ready present in the United States, our exclusion decisions must comply with exist- 

 ing international trade agreements, and must be in accord with science-based risk 

 information. 



We believe that improvements can be made, and are being made, to current pro- 

 grams to measure effectiveness and to analyze risk. OTA acknowledges that com- 

 plete exclusion of pests from the United States by APHIS probably is infeasible. 

 However, OTA also asserts that the overall success of APHIS' efforts to exclude 

 pests is difficult to evaluate, in part because the Agency lacks performance meas- 

 ures to determine the effectiveness of port inspection activities and programs in pest 

 exclusion. In recognition of the potential value of improved performance measures, 

 we have initiated a pilot project to develop goals and indicators to measure the re- 

 sults of the exclusion function, including tne Agricultural Quarantine Inspection 

 (AQI) program. This project is to be one of the pilot projects of the Government Per- 

 formance and Results Act of 1993. The goal of the project is to enable APHIS to 

 better articulate desired program outcomes and to measure whether those desired 

 outcomes are being achieved. 



We are also responding to the identified need for improvement in the U.S. system 

 of monitoring agricultural diseases and pests. We already conduct the National Ani- 

 mal Health Monitoring System, which provides scientifically sound and statistically 

 valid data regarding the incidence, trends, and economic impact of food animal dis- 

 eases and pathogens. Our Cooperative Agricultural Pest Survey (CAPS) provides for 

 the timely collection, storage, processing, and distribution of significant plant pest 

 and disease information for Federal agencies and State departments of agriculture. 



The OTA notes that biological control agents that are not microbes, are exempt 

 from the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and fall under 

 APHIS' jurisdiction. OTA also notes that APHIS has not yet promulgated regula- 

 tions specifically for such agents; instead APHIS requires researchers and producers 

 to follow procedures and permitting requirements developed for plant pests under 

 existing authority. APHIS is reviewing biocontrol organisms that are non-indigenous 

 on the basis of their potential for plant pest risk. Many biocontrol organisms are 

 exotic species being introduced for the first time, often to control their pest hosts 

 which are also non-indigenous. Good biocontrol organisms should have limited po- 

 tential to cause harm to unintended targets. We intend to have permitting require- 

 ments commensurate with the level of risk. We are participating in an interagency 

 group reviewing biological control organisms. As mentioned earlier, we are now de- 

 veloping regulations to cover the introduction, interstate movement, and release into 

 the environment of non-indigenous organisms. 



The OTA points out several perceived weaknesses with APHIS' risk analysis proc- 

 ess. In recent years, APHIS has sought to improve and standardize its risk assess- 

 ment procedures; we will continue to work to modify these procedures, and will con- 

 tinue well into the future. With respect to APHIS' requirement for demonstrated 



