October 22, 2012 the Honorable Tom Vilsack Secretary, U.S. Department
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October 22, 2012 The Honorable Tom Vilsack The Honorable Lisa Jackson Secretary, U.S. Department of Agriculture Administrator, U.S. Environmental Protection Agency The Honorable Steven Chu Secretary, U.S. Department of Energy The Honorable Ray LaHood Secretary, U.S. Department of The Honorable Leon Panetta Transportation Secretary, U.S. Department of Defense Dear Secretary Vilsack, Secretary Chu, Secretary Panetta, Administrator Jackson, and Secretary LaHood, As scientists in the fields of ecology, wildlife biology, forestry, and natural resources, we are writing to bring your attention to the importance of working proactively to prevent potential ecological and economic damages associated with the potential spread of invasive bioenergy feedstocks. While we appreciate the steps that federal agencies have made to identify and promote renewable energy sources and to invest in second and third generation sources of bioenergy, we strongly encourage you to consider the invasive potential of all novel feedstock species, cultivars, and hybrids before providing incentives leading to their cultivation. Studies have shown that some of the plants considered most promising in terms of bioenergy capacity may actually be highly invasive and potentially harmful to native species and ecosystems.1,2,3,4 In fact, many of the characteristics that make a plant appealing as an ideal source of biomass such as ease of establishment, rapid growth, resistance to pests and diseases, and low input requirements, are the same characteristics that make a plant more likely to become invasive.5,6 According to the non-federal members of Invasive Species Advisory Committee that provide independent advice to the National Invasive Species Council, “Absent strategic mitigation efforts, there is substantial risk that some biofuels crops will escape cultivation and cause socio-economic and/or ecological harm.”7 Many of today’s most problematic invasive plants – from kudzu to purple loosestrife – were intentionally imported and released into the environment for horticultural, agricultural, conservation, and forestry purposes. These invasive species already cost billions of dollars a year in the United States8 and are one of the primary threats to North America’s native species and ecosystems. It is imperative that we learn from our past mistakes by preventing intentional introduction of energy crops that may create the next invasive species catastrophe – particularly when introductions are funded by taxpayer dollars. Under Executive Order 13112, a federal agency cannot “authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.” To ensure ongoing compliance with the Executive Order and to prevent unintended consequences from the promotion of non-native and modified plants, algae, and microorganisms, we therefore request that federal agencies clearly assess the invasion risk of bioenergy feedstocks (including hybrids, varieties, genetically modified organisms, and cultivars) before these feedstocks can be eligible for federal incentives leading to their cultivation (through mandates, purchases, research grants, loans, and other means). Those species that may become invasive in the United States should be ineligible for incentives, unless the risk is low and, at a minimum, prudent measures are available and mandated to reduce the invasion risk and potential for harm. Tools for assessing the invasiveness of plant species and cultivars are widely available, including USDA APHIS’s newly revamped weed risk assessment.9 The National Invasive Species Council is best suited to coordinate this assessment process. A thoughtful, consistent, proactive approach to sustainable bioenergy production that avoids potentially invasive feedstocks, while encouraging the development and implementation of new energy crops to meet U.S. renewable energy goals, would demonstrate wise stewardship of federal funds and serve to benefit the agencies in the long run. By assessing and reducing risks up front, we can minimize the potential for bioenergy crops that are promoted with taxpayer dollars to become invasive and cause harm to natural ecosystems. It is much cheaper and easier to take the steps to prevent an invasive escape than it is to deal with it after it has occurred. Signed, Richard N. Mack, Ph.D. Bruce Robertson, Ph.D. Washington State University Bard College Pullman, WA Annandale-on-Hudson, NY Dale Gawlik, Ph.D., Wildlife Sciences James Miller, Ph.D. President, FL Chapter of the Wildlife Society Professor Emeritus Florida Atlantic University Mississippi State University Boca Raton, FL Starkville, MS Joseph M. DiTomaso, Ph.D. Scott L. Collins, Ph.D. University of California President, Ecological Society of America Davis, CA Washington, DC S. Raghu, Ph.D. Rakesh S. Chandran, Ph.D. Stuttgart, AR Extension Weed Specialist & Professor West Virginia University Lee Van Wychen, Ph.D. Morgantown, WV Weed Science Society of America Alexandria, VA Joseph Sirotnak, Ph.D., Ecology Big Bend National Park Dean Urban, Ph.D. Big Bend, Texas Duke University Durham, NC Loretta Battaglia, Ph.D., Ecology Southern Illinois University Adam M. Lambert, Ph.D. Carbondale, IL Santa Barbara, CA Dawn Lawson, Ph.D., Ecology Elizabeth L. Middleton, Ph.D. San Diego, California Missouri Department of Conservation Clinton, MO Matthew Olson, Ph.D., Forest Resources West Plains, MO Kenneth Langeland, Ph.D. Professor, University of Florida IFAS, F. Bryan Pickett, Ph.D., Genetics Agronomy Department and Center for Aquatic Chicago, IL and Invasive Plants Gainesville, FL Lizbeth Seebacher, Ph.D., Invasive Species Biology Catherine A. McGlynn, Ph.D. Washington State Department of Ecology Northeast Illinois Invasive Plant Partnership Lacey, WA Chicago, IL Lowell Pritchard Jr., Ph.D., Natural Resource Donald C. Jackson, Ph.D., Fisheries Economics Mississippi State University Creation Care Inc. Mississippi State, MS Decatur, GA Douglas B. Inkley, Ph.D. Jo Anna Hebberger, Ph.D., Plant Ecology National Wildlife Federation Des Moines, IA Reston, VA Alton Kinlaw, Ph.D., R.Ph. Doria R Gordon, Ph.D. Indiana University Health The Nature Conservancy Indianapolis, IN Gainesville, FL Thomas Eubank, Ph.D., Weed Science Emma Hampton, Ph.D., Zoology Mississippi State University University of Texas at Austin Stoneville, MS Austin, TX William Faber, Ph.D., Wildlife Ecology Vicky Meretsky, Ph.D. Central Lakes College Indiana University Brainerd, MN Bloomington, IN Daniel C. Abel, Ph.D. Angie Shelton, Ph.D. Coastal Carolina University Indiana University Conway, SC Bloomington, IN Sarah Ward, Ph.D. Chris Habeck, Ph.D. Colorado State University Kutztown University Fort Collins, CO Kutztown, PA Leonard Bull, Ph.D. Reuben Keller, Ph.D. Cornell University Loyola University, Chicago New Haven, VT Chicago, IL Antonio DiTommaso, Ph.D. Victor Maddox, Ph.D. Cornell University Mississippi Cooperative Weed Management Ithaca, NY Area Mississippi State, MS John J. Jachetta, Ph.D. Dow AgroSciences LLC David R. Shaw, Ph.D. Indianapolis, IN Mississippi State University Miss. State, MS Sam Pearsall, Ph.D. Environmental Defense Fund John D. Byrd, Jr., Ph.D. Raleigh, NC Mississippi State University Mississippi State, MS Margaret K. Thayer, Ph.D. Field Museum of Natural History Bruce A. Stein, Ph.D. Chicago, IL National Wildlife Federation Washington, DC Frank Powell, Ph.D. Furman University James T. Green, Jr., Ph.D. Seneca, SC North Carolina State University Raleigh, NC Daniel R. Ludwig, Ph.D. Illinois Department of Natural Resources Kirk Howatt, Ph.D. Bartlett, IL North Dakota State University Fargo, ND Heather L Reynolds, Ph.D. Indiana University Daniel A. Ball, Ph.D. Bloomington, IN Oregon State University Pendleton, OR Carol Mallory-Smith, Ph.D. Betsy Von Holle, Ph.D. Oregon State University University of Central Florida Corvallis, OR Orlando, FL Thomas Wassmer, Ph.D. Vicki Jackson, Ph.D. Siena Heights University University of Central Missouri Adrian, MI Warrensburg, MO William R. Eddleman, Ph.D. Sarah Bois, Ph.D. Southeast Missouri State University University of Connecticut Cape Girardeau, MO Storrs, CT Christopher E. Comer, Ph.D. Mark VanGessel, Ph.D. Stephen F. Austin State University University of Delaware Nacogdoches, TX Georgetown, DE Li Kui, Ph.D. William A Overholt, Ph.D. SUNY-ESF University of Florida Syracuse, NY Fort Pierce, FL Brian D. Carver, Ph.D. Lyn Gettys, Ph.D. Tennessee Technological University University of Florida Cookeville, TN Davie, FL James R. Manhart, Ph.D. Jason Evans, Ph.D. Texas A&M University University of Georgia College Station, TX Athens, GA Scott Senseman, Ph.D. Donn Shilling, Ph.D. Texas A&M University University of Georgia College Station, TX Athens, GA Peter Kareiva, Ph.D. Lauren Quinn, Ph.D. The Nature Conservancy University of Illinois Seattle, WA Urbana, IL Kelly Lyons, Ph.D. Peter Alpert, Ph.D. Trinity University University of Massachusetts, Amherst San Antonio, TX Amherst, MA Jodie S Holt, Ph.D. Catherine Badgley, Ph.D. University of California University of Michigan Riverside, CA Ann Arbor, MI L. Jack Lyon, Ph.D. John Fike, Ph.D. University of Michigan Virginia Tech Missoula, MT Blacksburg, VA Larry G. Visser, Ph.D. Paul E. Bartelt, Ph.D. University of Michigan Waldorf College Ann Arbor, MI Forest City, IA Johannes Foufopoulos, Ph.D. M. Jahi Chappell, Ph.D. University of Michigan Washington State University, Vancouver Ann Arbor, MI Vancouver, WA Michael R. Moore, Ph.D. Kashka Kubzdela, Ph.D. University of Michigan Oakton, VA Ann Arbor, MI Charles P. Nicholson, Ph.D. Ivette Perfecto, Ph.D. Norris, TN University of Michigan Ann Arbor, MI Jeff Levengood, Ph.D. Champaign, IL William S. Currie, Ph.D. University of Michigan Jean O'Neil, Ph.D. Ann Arbor, MI W. Hatfield, MA Daniel Tufford, Ph.D. Ron Carroll, Ph.D. University of South Carolina Athens, GA Columbia, SC Ruth Douglas, Ph.D.