National Environmental Coalition on Invasive Species
Great Lakes United * National Audubon Society * National Wildlife Federation * Natural Areas Association * The Nature Conservancy
January 26, 2011
The Honorable Ken Salazar
U.S. Department of the Interior
1849 C Street, NW
Washington, DC 20240
Dear Secretary Salazar:
On behalf of the National Environmental Coalition on Invasive Species, and our organization’s millions of members, supporters, and activists, we are writing to thank you for your efforts to prevent and manage invasive species and to ask for the prompt public release of a new, related Department report. In particular, we appreciate the priority that you and your staff have given to issues related to the listing of Asian carp species as injurious.
As you know, the Lacey Act provides the Department’s primary legal authority to prevent introductions of injurious non-native wildlife, via a listing process. We support your efforts to expand this list. However, listing species under the Lacey Act is usually too lengthy a process for a protective result; ecological and economic damage occurs before restriction of the import or interstate movement of injurious species is achieved. The several species of Asian carp are examples of species listed as injurious after they had already established and spread. The Burmese python, which has been released into the wild and now infests the Florida Everglades, remains unlisted and is another example of this delay.
In addition, the Government Accountability Office (GAO), in its 2010 report on live animal imports, found significant barriers to the inter-agency collaboration needed to reduce the risk of importing animal diseases. An overwhelming number of the experts GAO surveyed (52 of 56) believes that changes to the Fish and Wildlife Service’s (FWS) statutory and regulatory framework are needed.
Because of such problems, we were pleased when Assistant Secretary Strickland announced, in December 2009, that a comprehensive review of the FWS’s legal and regulatory authorities on invasive species was being performed. We understand that this review, including recommendations for potential legislative and regulatory measures to better address prevention of new introductions and management of existing ones, is complete – but that no date has been set for its release.
We ask that you make this review and its recommendations public as soon as possible and preferably by February 15, 2011. In the 111th Congress, the U.S. House of Representatives considered new legislation to improve FWS’s authority under the Lacey Act to better screen and prevent the import of harmful non-native wildlife and diseases. We expect the Senate to do the same in the 112th Congress. Thus, a prompt release complements the growing congressional interest in this important issue. Also, having the Department’s recommendations in hand would provide us and other stakeholders with specific ways to help you implement the report’s recommendations as quickly as possible.
We look forward to reviewing this report, and appreciate your consideration of our request for a timely release. Please feel free to contact the National Environmental Coalition on Invasive Species’ screening lead, Phyllis Windle, at 301-345-8516, if you have questions.
Vice President of Government Relations
National Audubon Society
National Wildlife Federation
Ruark L. Cleary
Board of Directors
Natural Areas Association
Director, Navigation and Invasive Species
Great Lakes United
Invasive Species Program Manager
The Nature Conservancy
cc: Tom Strickland, Assistant Secretary for Fish, Wildlife and Parks
Michael Bean, Counselor for Fish, Wildlife and Parks
Jason Goldberg, Fish & Wildlife Biologist, U.S. Fish and Wildlife Service