Recommendation: Consider adopting a modified "clean list" approach for propagative material, specifying what is permissible subsequent to risk assessment, rather than the current "dirty list" that prohibits or restricts specific articles only. To begin this process, work with subject experts to develop a prototype assessment process upon which subsequent regulation could be based. (Recommendation Number 108)

Comments:

• In reguards to a clean list of products and plants that would be allowed into the US instead of a dirty list of things not allowed. It seems that we the people would be the ones being told what we can do instead of the free market we already live in. This is shades of political powers that our fine counrty has stood against since the American Revolution. What will be the next thing that we are told we cannot do or say. Our current system works well when the rules are followed and inpsections by qualified personnel are done correctly. Maybe raising the pay of the inspectors would be a better place to start instead of trying to control things that would just make matters worse. How many business owners will be left out in the cold when the "clean list" comes out and it does not include what they import for no other reason than it was left off because knowone thought about it. Think this over very good before going forth and cutting off thousands of people from making a living including the inspectors who actually do the work. Once the "clean list" comes out the number of imports would go down considerably and the number of inspectors also.
  Submitted Aug 07 2000

• Modern stupidities do seem to multiply, with a life of their own, don't they? If people want to do something about the dangers related to the living world, try instead banning things like: our profligate use and abuse of energy, and the global warming it promotes; profiteering in mining the forests and every other aspect of the natural world; genetically engineered organisms; terminator/traitor genes (and the diabolical USDA involvement in their development); and the very notion of patenting of natural living organisms. Banning new importation of exotic species is one thing (and not good even then, if the price is private "ownership" of natural organisms) - but trying to exterminate plants and animals which have already become part of a new place (or might)?! "gimme a break"! for one thing, extermination won't succeed; for another, times change, environments change, humans being (presumably) the most active single agent of change; and finally, it seems highly unlikely that poisoning the environment to "fight alien invaders" is the lesser of two evils! ("When Monsanto tells you they 'want to help the environment', do you believe them?" the financial and regulatory environment, yes, but otherwise, no way...) As I said: Stupidities abound, and then multiply. Having said all that, it seems to me there is not enough information on the NWL Web site to come to an adequately informed conclusion on this - I for one would like to understand all the in's and out's much better than I do now, having read everything I find here...
  From Ken Crismier (kencris@gte.net) Submitted Aug 27 2000

• I am not in favor of "clean list" approach. I believe there are sufficient controls in place now that will do the job. The "clean list" approach assumes everything is guilty unless proven innocent. This is entirely too narrow-minded. If this approach had been used by the settlers to the colonies, we would have no apples, peaches or tulips! I assume we are going to make this retroactive and remove all the apple orchards and peach orchards and go to each homeowner and remove their tulips!? Oh, you say we won't go that far back in history to decide what may grow here. Why not? What makes you set the line where you want to? Could it be that the main goal of this "clean list" is to line to pockets of it's corporate backers, the herbicide manufacturers?
  Submitted Oct 17 2000

• The USDA has been responsible for the promotion and large-scale planting of many of the worst plant scourges in this country: kudzu, autumn olive, multiflora rose, Japanese honeysuckle... the list could go on. Now, suddenly, this same agency will pass judgment on the permissibility of all plants, already in cultivation here and not? The prospect is more than a little galling to those of us still dealing with the results of past USDA "expertise." I would certainly hope and expect that if there is to be a "clean list" for plants that it would include virtually every plant now in commerce (with obvious exceptions for plants already restricted as noxious weeds or invasives). Otherwise, this policy would be a huge disruption to the nursery business and and its millions of customers. Without this kind of grandfathering, a clean list approach raises grave doubts about the intentions of the broader policy, and will create popular resistance to the very goals the USDA, APHIS, etc. seek to reach. Another crucial indicator of whether this is to be a genuine effort at preventing ecological harm is the process for testing and approval of new plants. In cooperation with a university biologist, Heronswood Nursery in Washington state has begun testing many plants recently collected from abroad for possible invasive qualities, withholding them from sale until they're satisfied that they pose no significant threat. This is a sound, responsible process, a model for other nurseries with access to "new" plants. Cooperation with existing programs of this type, efforts to support the timely appearance of newly collected plants on the clean list, would be welcome. But massive, cumbersome, hugely expensive testing of the kind required for new drugs or agricultural chemicals would be completely inappropriate, and again would raise questions about the true intentions of this program.
  From Nell Lancaster Submitted Oct 22 2000

• I think the question is are we (humans) part of Nature or outside Nature. We act as if we are outside Nature. Burning of fossil fuels that involved millions of years of carbon sequestration in mere hundreds of years has created Global Warming. Indescriminate use of fertilizers and biocides has impoverished soils, by destroying soil biota and upsetting the balance between plant roots and soil biota. We have upset the balance between predators and prey, between diseases and resistance to disease. It is a constant battle to raise food crops, and this is a recent phenomenon. From my observations Nature is under severe stress. To focus on Native versus Exotic is to miss the big picture. Nature is making the best of what "she" has to continue to provide an environment with oxygen, water etc. for life to continue, including human life. Who says what is Good and what is Evil ? Perhaps humanity as a vector of exotics is the mitigating factor that redeems us for selfish mindless destruction. Are we going to stop international air travel to prevent the spread of exotic pathogens for the human species ? I think we are approaching a time when we will need to actively manage our forests, planting exotic species, to enable them to keep up with Global Warming. Sure, we have had periods of warming in the geological past, but it seems the current one is happening on a time scale inconsistent with the maturation period of trees. I think the quarantine laws are adequate as they are. It is the mindset that needs changing.
  From Tony Begg (Tony.Begg@DataVentures.com) Submitted Oct 25 2000

• I categorically reject efforts to restrict free movement of seed and other plant materials. I cannot accept changes that seem to be leading to a "National List" of acceptable materials such as rules in the EU countries. Current efforts at restricting so called noxious weeds and other organisms are bad enough in practice if not theory. No one wants economic and environmental problems. Thank you. Marshall S. Chrostowski
  From Marshall S. Chrostowski (mcfarm@silcom.com) Submitted Oct 28 2000

• Dear USDA people, I came here though a site addressed: www.geocities.com/nowhitelist . As a gardener and botanist, however, I know that invasive plants have become a serious threat to native biodiversity. I think a "white list" approach is the only appproach that will be even partly effective in stemming the tide of invasive species. My part of the country (the Upper Great Lakes region) is dominated by northern hardwood forests, with boreal forest in its northern portions. So far, most (but not all) non-indigenous plants capable of living in this region inhabit roadsides, cleared areas, logging roads, clearcuts, etc., because the nonindigenous plants that have found there way here (being either introduced intentinally or incidentally) are horticultural plants that will grow in gardens (in full sun), or or successional weeds of disturbed areas. However, the horticultural industry is more than ever intent on introducing plants from northern Russia, China, etc. that often can live in northern forests. These efforts must be halted, until good evidence is presented that these species will not escape. Please keep moving forward with your "white list" efforts. Yours truly, Steven C. Garske PO Box 4 Marenisco, MI 49947-0004 (e-mail above) PS I understand that a Gore victory on Tuesday will help considerably. Lets hope!
  From Steven C. Garske (sng@up.lib.mi.us) Submitted Nov 04 2000

• No White List. Let nature "be".
  From Clare Tucker (ocmitch@earthlink.net) Submitted Nov 14 2000

• I personally have spent hours in the field working on the removal of invasive plant species in restoration areas. Although I feel further investigation into the complex relationships between naturalized and invasive plant species should continue to be studied, I do not think that the so-called "Clean List" is the answer. The intention behind the "Clean List" seems to be broad based corporate control over the natural world under the umbrella of the government. I never will support this. Agencies continue to try to slip these deviant corporate agendas under the nose of the public while no one seems to be looking. We are watching. Do what is best for the natural world not what is best for the stockholders of Monsanto.
  From Erin Volheim (greencanopy@popmail.com) Submitted Nov 14 2000

• no white list, please! corporate control of nature is not a good idea!
  From Teresa Mueller (TreeOnly@aol.com) Submitted Nov 14 2000

• I am not in favor of the "White List." It will add to costs in the horticultural, inhibit the development of new cultivars, and smother legitimate trade in genotypes. Let freedom and global diversity prevail. If there is a problem with a noxious species, "black list" it and eradicate it. Don't mess with the remaining 99%.
  From Fred Thompson (Freddel@pacbell.net) Submitted Nov 25 2000

• I'm commenting about the White list, a proposed ban of all but designated plants. I feel it is a very bad idea. This ban concentrates control of genetic material in a very few hands. It will make collecting plants for whatever purpose even more difficult and expensive. Organizations like this Botanical Garden and the Rock Garden Society who havew clearly not been responsible for weed introduction would have most of their seed distribution activities cutailed as well Working in a Garden with the largest living species and family diversity in North America, I have seem very few "weeds". These weedy plants can be controlled early on banning outright is really stifleing science and research, an over reach of governmental power. Calling this a "Clean list" indicates the level of marketing involved in this. The aweb site
  From Peter Klement (oldroses@uclink4.berkeley.edu) Submitted Nov 28 2000

• I support the recommendation.
  From Paul Koloszar (thehorticulturist@home.com) Submitted Nov 28 2000

• COMMENTS AND QUESTIONS ON THE "CLEAN LIST" PROPOSAL I deeply regret having to make such negative comments to the USDA, as I have great respect for many in the department whom I count as friends, and for many of the valuable programs conducted by the Department. As a conservation biologist, I am very concerned by the USDA plans to institute a “clean list” system after "risk assessment" to be applied to all plants introduced into the U.S. The institution of such a sweeping, intrusive, expensive, and unprecedented policy must be fully justified on the basis of current scientific knowledge, it must be fully justified economically, and it must be fully justified ecologically. Such a policy must be practical and realistic - it must actually be possible to predict harm or invasiveness of the species screened. I am deeply disturbed that such a policy would be considered, and a timetable for its complete implementation imposed, entirely in the absence of effective screening methodologies, or even a theoretical basis for developing such methodologies. Such a policy, which will profoundly affect all sectors of our society, must not be hastily imposed. The public, the research community, landowners, farmers, and the business community must all be fully and openly informed of this policy and the full ramifications of its imposition. Adequate time must be allowed for full public discussion. I have found the research community in particular to be almost completely unaware of this proposed policy and the negative effects it will have on many areas of research and many important conservation strategies. The government has engaged in a pattern of biased reportage of the facts surrounding anthropogenically-dispersed species and has systematically excluded scientific evidence contrary to their agenda (see below for citations). The breathless hysteria-mongering of the government’s websites and press releases, and the systematic exclusion of opposing views cannot be justified. THE “INVASIVE SPECIES” CRISIS: Is it real? Purple loosestrife (Lythrum salicaria) is claimed to be “an aggressive invader, it has displaced native vegetation and destroyed waterfowl habitat by forming dense, nearly monotypic stands” (Hight 1993). The National Invasive Species Council (NISC) places it among their top invaders. However, Anderson (1995) reviewed 34 papers on loosestrife and found records of 29 native species of wildlife using the plant, and many records of native species outcompeting it. In 41 plots in Ontario, no significant difference in vascular plant species richness was found, regardless of the presence of purple loosestrife, no differences in number of introduced species, nor was species richness affected by increasing percent cover of loosestrife. A number of native species were more likely to grow in plots containing purple loosestrife (Treberg & Husband 1999). Hager and McCoy “traced the history of purple loosestrife and its control in North America and found little scientific evidence consistent with the hypothesis that [it] has deleterious effects… Loosestrife was initially assumed to be a problem without actually determining whether this was the case… there is currently no scientific justification for the control of loosestrife…” (Hager & McCoy 1998). Yet loosestrife is still touted as an “invader” - Pimental et al (2000) give it top billing and claim $45 million in control and loss costs in the U. S. alone, and the NISC features it prominently on their website. Although it has been five years since Anderson’s paper, and Hager and McCoy’s and Treberg’s papers are a couple of years old, I see no mention of their work or opposing views of purple loosestrife on USDA sites or linked sites. Have I just overlooked mention of opposing views, or has the USDA ignored their work? Malakoff (1999) claims saltcedar (Tamarix spp.) is an “ecological menace”, and has “proved disastrous for many native species, crowding out the cottonwood trees and willows… Fears that saltcedar will drive more species to the edge have put the plant at the top of ecologists’ hit lists.” The OTA (U.S. Congress 1993) claims it is one of the nation’s worst weeds and that it increases flooding and sedimentation, alters hydrology, and crowds out native plants. However, as early as 1980, Everitt (1980) pointed out that it is a “slow starter that does not compete well” and that “there is as yet no convincing evidence, although the literature is rampant with charges that saltcedar is a ‘potential flood hazard’…. [It] occupied land made available by the plow, the bulldozer, and the shrinking of a channel depleted of flow by upstream water development. Changes in both the physical environment and the native vegetation were well underway by the time tamarisk became widespread. There is no evidence that it actively displaced native species nor that it played an active role in changing the hydraulic or morphological properties of the river.” (Everitt 1998) [emphasis mine]. Also, saltcedar stands are artificially “maintained in a youthful ‘thicket’ stage by burning, chemical treatment, or mechanical disturbance, so that seral species are not able to occupy…” In a study of the free-flowing middle San Pedro River “mean values for 22 of 30 soil, geomorphology, and vegetation structure traits did not differ significantly between saltcedar and Fremont cottonwood stands. Twenty-six of the 30 traits had similar patterns of change over time… Saltcedar was functionally equivalent to Fremont cottonwood for about half of the traits construed as indicators of riparian ecosystem function. Also in contrast to the working paradigm, saltcedar appeared to enhance the maintenance of floristic biodiversity. Understory herbaceous cover and species richness were significantly greater than cottonwood stands… Stem densities of velvet mesquite (Prosopis velutina) and other woody successional species did not differ between saltcedar and cottonwood stands.” (Stromberg 1998). Saltcedar is said to salinize the soil, yet under natural flooding regimes, the salty leaf litter “is frequently flushed downstream” (Everitt 1998), and Anderson (1996) has pointed out that anthropogenic salinization frequently precedes saltcedar establishment, preventing the germination of native species. It is called a “water guzzler,” lowering water tables and drying springs, yet its evapotranspiration rate does not exceed native cottonwood. The U.S. Fish and Wildlife Service originally cite saltcedar as a cause of decline of the endangered southwestern willow flycatcher, yet 90% of Arizona’s 150 flycatcher pairs nest in it (Malakoff 1999). The extermination of beavers (Castor canadensis) in the Southwest has altered hydrology, water quality and species composition, and their reintroduction increased riparian habitat and raised water levels have killed saltcedar in some areas (Albert & Trimble 2000). It has declined in the middle basin of the San Pedro due to recent environmental changes, including flooding, greater stream flow and cattle exclusion. Clearly, this organism is anthropogenic, a disturbance indicator, and not a cause for alarm. Twenty years ago, Everitt (1980) eloquently stated that “An apparently widely held belief is the ‘devil theory’… widespread use of the terms ‘aggressive colonizer’ and ‘invader’… implies at least a subconscious belief that the species is somehow capable of actively destroying preexisting plant communities… It is doubtful whether many ecologists can be found who espouse such an anthropomorphic explanation of plant behavior…” and he made “A plea for research.” Sound advice indeed. Eucalyptus has been called “the tree Californians love to hate.” It is said to invade and destroy diverse native ecosystems by allelopathically suppressing understory and being of no value to native wildlife, as well as being an explosive fire-hazard. However, in reviewing research on the tree, Stein & Moxley (1992) note that California eucalyptus forests are “far from ‘faunal deserts’… a number of species not found [in surrounding chaparral] were found in eucalyptus plantings at Montana de Oro State Park. These species included monarch butterfly, Anna’s hummingbird, golden-crowned kinglet, starling, dark- eyed junco, great horned owl, and yellow-bellied sapsucker…. Forty-seven species of native birds were known to use eucalyptus in the Golden Gate National Recreation Area…” Eucalyptus understory in the GGNRA included 36 species, cover and abundance was correlated with moisture availability not tree density, and eucalyptus created a microclimate which “permits some native herbs, shrubs and trees to grow on sites that did not support these species before…” (Stein & Moxley 1992). I have found many sites on which native species cover, richness and diversity increase as one approaches a eucalyptus trunk (Theodoropoulos, unpublished field notes). A study found that 3 cm of eucalyptus mulch did not inhibit germination and establishment of 5 of 6 species of native plants (Yamada & Sandoval 2000). Eucalyptus do not spread at most California sites, and this is mostly unquantified, and site-specific (Stein & Moxley 1992). Eucalyptus groves are the preferred sites for monarch butterfly overwintering congregations in California - 17 of the most prominent 25 sites are in eucalyptus trees (another 4 sites are in other non- natives) (Marriott 1997). Eucalyptus were blamed for spreading the disastrous October 1991 Oakland hills fire, yet many homes were actually shielded from burning debris by the trees (Anonymous firefighter, personal communication), and often eucalyptus were untouched while neighboring houses were incinerated (Larson 1991). In spite of the lack of credible justification, hundreds or thousands of hectares of eucalyptus are being removed as “invaders”, including controversial projects such as at Angel Island, which destroyed valuable cultural, historical and scenic resources. Hydrilla (Hydrilla verticillata) is called one of Florida’s “most aggressive alien plant species.” Yet its presence is linked to increased nutrient loading of waters from agricultural and urban runoff. The plant increases benthic and epiphytic invertebrate populations and species density, provides a haven for juvenile fish and is important for maintaining a high yield of fisheries. It is heavily used by waterfowl, is an important food for ducks, coots and moorhens, and hydrilla supports the highest avian species diversity in Florida (Schmitz et al. 1993). Fish density, biomass, species diversity and composition were compared between H. verticillata and the natives Panicum hemitomon and Potamogeton illinoiensis in Lake Okeechobee, Florida. Hydrilla had the highest fish density and biomass, with 3.27 times the density, and 2.5 times the biomass as the native Panicum, and 6.3 times the density and 5 times the biomass as the native Potamogeton, and species density did not vary significantly between the types (Chick & McIvor 1994). Fish introductions are said to destroy native fish faunas. However, like other groups, they are primarily disturbance indicators. In Puerto Rican streams, the presence of dams was the determining factor in exotic fish presence, with natives abundant in undammed and below-dam streams, and exotics dominating above-dam (Holmquist & Schmidt 1998). In sampling a California reservoir, of 24 fish species, 5 native species accounted for 77% of catches (Vondracek et al. 1989). “The native non-game fishes have maintained large populations in the reservoir despite continued introductions of non-native species.” The “catastrophic” introduction of Nile perch (Laetes nilotica) is said to have “virtually wiped out an entire icthyofauna of several hundred endemic haplochromine species” in Lake Victoria (Coblentz 1990). However, there has been a recent resurgence of indigenous species. Many species thought to have disappeared survive in refugia, and other indigenous species persist and are abundant in open waters. Haplochromines have increased in Lake Kyoga with the spread of water hyacinth, which may provide cover (Chapman et al. 1996). Although introduced fish are often blamed for amphibian declines, in Yosemite, California, frog populations persisted in high numbers for decades after repeated yearly large scale introductions, and they also have disappeared from fish-free sites (Drost & Fellers 1996). “Are fish introductions a threat?… Because of the paucity of information, the effects of introductions on endemic species remain controversial.” (Crivelli 1995). The spread of introduced fire ants (Solenopsis invicta) is said to “obliterate most native ants, plus a good many spiders, worms, and other invertebrates” (Devine 1998), as well as eliminate small mammals and ground-nesting birds. Again, they are primarily disturbance-dependent (Tschinkel 1993) (Fig.4), and spread was aided by the Mirex fire-ant extermination program, which destroyed native ant species. Fire ants were suggested as being linked to decline of overwintering birds, loggerhead shrikes (Lanius ludovicianus) in particular (Lymn & Temple 1991), but Yosef & Lohrer (1995) found no association between fire ant density and shrike reproductive performance and found other causes for the decline, including ant-control pesticides. “In no case have we observed fire ants to attack or kill eggs, nestlings or adult shrikes.” Declining northern bobwhite (Colinus virginianus) populations have been blamed on fire ants, but experimental work (Brennan 1991, 1993) found “that fire ants have no influence on quail production …bobwhite density is 2 birds per ha, and the density of active fire ant mounds is 200 per ha… Still the fire ant myth persists, and must be eliminated through education.” Called “a destroyer of forests… rampaging across millions of acres in summertime blitzkriegs…” (Devine 1998), the gypsy moth (Lymantria dispar) actually causes selective mortality in eastern hardwood forests - weaker trees succumb, and outbreaks are correlated with disturbance and urbanization (Dahlsten 1986). Subsequent outbreaks are less damaging. Also, “thirty eight species of birds and small mammals” eat the moth (Sharples 1983). Chinese tallow tree (Sapium sebiferum) is called a “pernicious pest” in the South, where it is “one of the most destructive invasive plants in the U.S.” (Devine 1998). Young stands are nearly monospecific, but within 20 years native riparian trees and shrubs were present and increase with stand age. With time, a new type of woodland is expected (Bruce et al. 1995). Clearly, these few examples demonstrate that the simplistic view of an “invasive species crisis” trumpeted by the websites of various government agencies is not scientifically justifiable. They also demonstrate that the government agencies, including the USDA have either failed to do the most basic library research on the subject, or has engaged in deliberate deception of the American people by a selective and one-sided presentation of evidence. If there are any other possibilities than incompetence or dishonesty, please enlighten us. PREDICTION: Is it possible? “In dealing with invasions, ecologists are… attempting to predict the fate of diverse, often little-known organisms launched at diverse, complex, usually barely studied environments. And they are attempting to do so even though natural systems are so complex that it is usually very difficult to predict population size changes in well-studied organisms in well-studied environments.” (Ehrlich 1986) Attempts to predict invasion face the immediate limitation of the rudimentary state of our knowledge of the environment. We have named perhaps one-tenth of the earth’s species, and our knowledge of the ecology of the majority of these species is non-existent. Our knowledge of the capacities of individual species and the composition and properties of communities and ecosystems is so limited and fragmentary that prediction is effectively impossible. In spite of over 50 years of scientific study of wildlife-habitat relationships we are still unable to accurately model or predict the abundance and distribution of well-studied wildlife (Morrison 1991). Concerning predicting species ranges in response to climate change, Lawton (1998) states that the “overwhelming evidence” from history is that species “respond idiosyncratically” to change, existing interactions uncouple, and “totally new interactions” form. “Even though virtually all the species still survive, there are combinations of species (communities) from these earlier times that have no modern equivalents, and many modern communities that have no ancestors in the sub-fossil record.” Even well-recognized modern communities vary widely in species composition. Each site carries its own unique set of environmental factors, which may vary widely over small temporal and spatial scales. Single-year or regionally-restricted studies will lead to fallacious conclusions. Resident species may vary widely in habitats occupied, and interactions with other species change seasonally and among years. Species interactions vary continuously over wide ranges with changing conditions and stochastic events, and individual organisms are continuously confronted with novel conditions. Changing interactions with other species play key roles in determining the distribution and abundance of organisms, and metapopulation structure and source-sink dynamics change with changes in range (Lawton 1998). Each new species, whether native or exotic, entering an area where it is absent brings with it a new set of variables. “No prediction that fails to include all the variables in the case to be predicted can hope to succeed, yet each new invader introduces its own novel set of characters.” (Williamson 1999). New properties may arise, and new interactions are unknowable. Exotics in New Zealand did not inhabit the same realized niche as in their English homeland, but were pre-adapted to different niches (Wilson et al. 1988). Such unpredictable emergent phenomena are unknowable. “Predicting the ecological behavior of a species in a new environment may be effectively impossible.” (Williamson 1999). For example, the mild behavior of the zebra mussel in Europe, where it “invaded” long before it reached North America, is quite different from its behavior here. Intrinsic properties of individual species are not predictive. Berman et al. (1992) studied three species of introduced marine invertebrates and found “that ecological similarity among species is not an accurate criterion to predict either the mechanism of invasion or the means of persistence.” Analyzing introduced birds in New Zealand, Duncan (1997) found no support for the “hypothesis that successful and failed species were inherently different in their invasive abilities.” Typha spp. are troublesome aquatics weeds in North America, as is Cyperus papyrus in Africa and Asia, yet when naturalized in New South Wales they have shown no evidence of aggressive spread (Arthington & Mitchell 1986). Unknown intrinsic capacities of species that are not expressed in their current ranges may manifest in new environments. High genetic variability of founder populations has been proposed as making invasion more likely, but some of the world’s worst weeds are sterile, clonally-propagating species - Salvinia, Eichhornia, Oxalis, etc. (Barrett & Richardson 1986). Propagule pressure (introduction effort) may affect success of introduction, but Karieva et al. (1996) analyzed an extensive data set on weeds of the northwest U.S., and found that neither initial extent of inoculation or velocity of spread were predictive of ultimate range. Success of previous introduction may have small predictive power - “So far the only consistent predictor is success in previous invasions.” (Williamson 1999). However, failures of these species have never been analyzed, and Moulton & Sanderson (1999) found that previous introduction outcome did not predict success of passeriform introductions. Carp (Cyprinus carpio) is well-known for its ability to inhabit new regions (Courtenay 1993). Three strains have been introduced into Australia - ‘Prospect,’ ‘Singapore,’ and ‘Boolara’. Only Boolara spread rapidly outside the area of introduction, however it is now in decline (Arthington & Mitchell 1986). Brooke et al. (1995) found that extrinsic forces are more important than the intrinsic properties of invading species, and found no evidence that early successes are intrinsically superior invaders. Prediction is further compounded by the time lags between introduction or establishment and spread. This has been attributed to various causes, but in most cases time lags are likely an illusory artifact of the failure to account for changes in climate or anthropogenic disturbance regimes. Kowarik (1995) found the average time elapsed between woody plant introduction and escape into the wild is 147 years in Europe. Clearly, no amount of study short of multi-century, multi-site trials could test for this. Reasoning from this, anti-alien crusaders now consider all non-expanding introduced populations to be “incipient invasions.” The new selective pressures faced by immigrating species may cause genetic adaptation allowing dispersal. Changes in flowering time have been noted in invaders (Kowarik 1995). This continued adaptive evolution towards integration into new environments cannot be predicted. Future changes in environment whether climatic or anthropogenic will affect the range, population and dispersal of species. The nature, direction and extent of these changes are unknown, and further confound prediction. Williamson (1999) cites ten reasons why prediction may fail: target not precise enough, significance statistical but not useful, extrapolation fails, statistical shrinkage, base rate effect (disproportionate false positives), new variables, lack of phylogenetic correlation, time lags, non-linearity and chaos, and complexity and situation-specific detail. “All the theory pertaining to invasions developed to date assumes that there is a community with knowable properties to be invaded. If the community that is to be invaded is itself sufficiently variable, the predicting anything about an invasion will assume the status of a weather report.” (Roughgarden 1986) Although predicting establishment and dispersal is biologically problematic, attempts have been made to develop predictive models for assessing introduced species (Reichard & Hamilton 1997; Rejmánek & Richardson 1996). Although superficially appearing to have some success, a critical examination in light of the above points reveals serious inadequacies. Statistical analysis is no better than the data analyzed, and the subjective, anecdotal, qualitative and contaminated information-pool characterizing invasion biology is inadequate for accurate analysis. Failure to factor in anthropogenic disturbance, introduction effort, adequate lag time, suitability of habitat and failure to operationally define invasion (apparently, mere establishment = “invasion”) are further problems. Although these models were explicitly designed to apply to regulatory control of the movement of species based on the presumed harmfulness of invaders, there was no consideration of the type of impact on the recipient ecosystem, degree of ecological integration, positive interactions with other species or positive effects on ecosystem function, or conservation value of introduced populations. An unacceptably high rate of false positives is also apparent. Clearly, this brief overview of the difficulty or impossibility of predicting “invasion” illustrates that the USDA plans for implementing a “clean list" are scientifically unjustifiable. In their current status, models predicting “invasiveness” have all the legitimacy and accuracy of a newspaper astrology column. They are naive at best, and at worst will be a disaster, another expensive boondoggle, hamstringing scientific research and valuable conservation efforts, and will serve to discredit legitimate governmental regulation. ALTERNATIVES: Clearly, no “invasion crisis” exists which would warrant such sweeping changes to public policy. The effects of “invaders” on natural areas do not warrant any massive intervention, but a careful, case-by- case consideration. Clearly, “invasiveness” cannot be effectively predicted, and any system of pre- screening species will constitute an unacceptable roadblock to scientific research and conservation efforts, as well as going down in history as yet another porkbarrel boondoggle. We cannot afford to hamstring our scientific community with hastily-imposed regulatory roadblocks which are based on a popular hysteria, not sound science, and implemented via a fictitious ability to predict invasiveness. Our research and conservation communities need ready access to the earth’s biological diversity. Unnecessary and unjustifiable roadblocks to the free movement of biological materials will hamstring many areas of research and important conservation efforts. It will increase our dependence on foreign supplies of raw materials and decrease our competitiveness in world markets. It will slow the important work of diversifying our agriculture, and prevent the ex situ conservation of important germplasm resources. The weedy relatives of crop plants are a vital reservoir of genetic material used in crop breeding. With the advent of genetic engineering, the entire biota of the earth is a possible source for these genes. We cannot afford to cut ourselves off from the rest of the world. Even amateurs have an important role to play, as witnessed by the number of endangered species preserved in their gardens and by their efforts alone. The discovery of important genetic variability in Sophora toromiro, now extinct in the wild, in the hands of a Chilean nurseryman and other individuals outside of botanic gardens points to the importance of not restricting public access to biological diversity (Maunder 2000). If risk assessment is mandated, certainly it would be much more cost-effective and scientifically sound for the appropriate agencies to examine the literature to identify those species which are already known to cause clear problems elsewhere, and to list these in an appropriate “grey” list for further evaluation and possible inclusion on existing “blacklists.” Such a program would appear to fulfill any mandate for “risk assessment”, while being reasonable, efficient, and low-cost. Mere establishment or spread of a species outside its historic range should not be consideration for inclusion on a grey or black list, since such species often have considerable conservation value or manifest beneficial interactions with the recipient biota (e.g. Eucalyptus as monarch habitat in California). Clear and unambiguous evidence of harm must be the criterion for inclusion on any list. Comprehensive screening of all species simply cannot be justified. Invasion biology has been demonstrated to be a pseudoscience (Theodoropoulos 1999). Examination of the origins of “natural” communities, ongoing natural movements of species, and the plasticity of natural successional trajectories demonstrates that the concepts of “nativeness” and “alienness” on which invasion biology rests are non-operational constructs dependent on arbitrary spatial and temporal scales, and useless in the construction of testable scientific theory. In invasion biology literature, concepts are redefined at will, and all data are reinterpreted to support the theory of harm resulting from “invasion.” The literature of invasion biology is a deeply contaminated information-pool, with low standards of evidence, unsupported causal attributions, circular reasoning, selective data-mining, high dependence on anecdotal reports, undefined jargon, unfalsifiable hypotheses, and other pseudoscientific characteristics. Results depend on highly subjective judgements and are for the most part based on anecdotal reports. Dire warnings of harm from “invaders” are for the most part purely speculative. Invasion biology displays an extraordinary lack of rigor. Contradictory evidence is resisted, as witnessed by the failure of the USDA to include data on the beneficial effects of anthropogenically-dispersed species, or opposing views of anthropogenic dispersal. Public policy must be founded on objective reality, or its effects will be harmful and expensive, as witness the disastrous Mirex program. UNANSWERED QUESTIONS: 1. What is the nature of the methodologies proposed for "risk assessment"? What is the scientific basis for such methodologies? If methodologies have not yet been developed, on what factual basis does the USDA presume that they can be developed? How does the USDA propose to overcome each of the enormous obstacles to accurate prediction of “invasiveness” which are detailed above? On what factual basis does the USDA believe that such methodologies may be developed within the proposed schedule for implementation? What level of accuracy will be deemed acceptable, and what percentage of false positives will be acceptable, and how were these levels determined? How will the adopted methodologies be tested in the real world? 2. What operational definitions has the USDA established for key terms, such as “native”, “alien”, “invasion”, “harm”, etc? These must be operational definitions, suitable for constructing testable scientific theory, and based on objective, measurable criteria which may be universally applied, and objectively identified in the field. What temporal and spatial scales will be employed in these definitions, and what objective and factual basis exists for using them? If arbitrary and subjective definitions are to be employed, on what basis does the USDA believe that they will be adequate for the formulation of public policy? 3. What are the USDA’s criteria for “ecological harm” or "economic harm?" Again, these must be objective and measurable, not mere subjective speculation, and applicable to all species inhabiting a community, regardless of putative native or alien status. In the absence of such criteria, on what basis does the USDA intend to determine which species to control, exterminate, permit entry or prohibit entry? 4. What objective ecological criteria does the USDA intend to use to identify possible “invaders” or "weeds?" These must be sufficiently precise to allow any biologist to identify the “invaders” in an ecosystem through the measurement of the criteria, without prior knowledge of putative native or alien status. For example, they must allow distinguishing between “native” and “alien” monocultures, between expanding native and alien populations, and between the ecosystemic effects of native and alien species. If such objective criteria cannot be developed, this will demonstrate the entirely subjective and pseudoscientific nature of invasion biology. In the absence of such criteria, on what basis does the USDA justify actions taken against putatively “alien” species? 5. How will the USDA determine the cause of “invasion?” If anthropogenically-dispersed species are only present as the result of disturbance, will their extermination solve the “problem,” or will this just create a downward spiral of inappropriate intervention? Treating symptoms and not underlying causes is a recipe for disaster. 6. What attempts has the USDA made to fully inform the community of botanic gardens and zoological gardens of the full ramifications of comprehensive screening? How has the USDA solicited informed comment from these interested parties? What will the costs of screening be? Will even herbarium specimens have to be sterilized to insure non-viability of seeds or spores? How will this affect taxonomists needing living material for critical study? Will the USDA insure that adequate funding be made available to these grossly under-funded institutions? At a time when we should be greatly expanding the number of species maintained in these repositories, how will placing roadblocks in front of those who are “loading the arks” benefit the conservation of biological diversity? 7. How will USDA policies affect the important conservation strategies of translocation and ex situ conservation? When the creation of hyperdiverse preserves through species packing in safe new environments would appear to be an essential conservation strategy, how will placing roadblocks before such efforts benefit the conservation of biological diversity? 8. How will the USDA distinguish the harmless or beneficial establishment of a new species from “invasion,” particularly in the early stages? If all new species are seen as “incipient invasions,” and exterminated, valuable opportunities for ex situ conservation will be lost. What protocols has the USDA proposed for determining the conservation value of new populations of species which have been moved outside their historic ranges? Or does the USDA consider all such populations to be “invasions” to be exterminated without regard for their possible conservation value? For example, does the USDA, in common with other anti-“alien” extremists, consider introduced populations of the highly restricted at- risk endemic Cupressus macrocarpa “invasions” which must be exterminated? Certainly the mere presence of a species cannot be considered evidence for need to control. Does the USDA consider the mere presence of a species alleged to be non-native to be sufficient evidence for control or extermination? If so, on what factual basis does the USDA take such a position? If mere presence is not considered sufficient evidence for action, what are the criteria for action? Who will make these decisions, and under what authority? If there are disagreements as to whether a species is harmful, how will such disagreements be adjudicated? What processes will be put in place to insure that harmless species, or species of ex situ conservation value are not the object of harmful control or extermination measures? 9. What attempts has the USDA made to contact and fully inform new crops researchers and economic botanists of the ramifications of their policies? How has the USDA solicited informed comment from these interested parties? How will the USDA insure that these workers have continued ready access to germplasm, particularly of important weedy wild relatives of crop plants? Considering that economically important new crops such as amaranth and St. Johnswort were considered weeds mere decades ago, how will researchers of the future develop such crops if denied access to germplasm? Since some weeds and pests may have important undiscovered value, such as the valuable hepatoprotective compounds discovered in recent decades in milk thistle (Silybum) or the recent discovery of bioactive compounds in many species of insects such as the Colorado potato beetle, how will this research proceed if populations of such currently undesirable species are exterminated? 10. What attempts has the USDA made to hear skeptical voices and insure that all sides of the issue are fully and accurately presented to the public? 11. How has the USDA evaluated the possible harm to ecosystems from the greatly increased use of herbicides and other methods of control of species? What protocols will be instituted to insure that benefit will outweigh harm? What long-term monitoring of both the introduced species and the proposed methods of control will be instituted to insure that the introduced species is actually causing harm, that the possible beneficial effects of the new species are not overlooked, and that the proposed methods of control will not be harmful in themselves? Long term monitoring will be essential on a site-by-site basis, due to the fact that each species behaves differently on each site, and each site has entirely new sets of conditions and ecological interactions. How will such monitoring be funded? If funds for monitoring are not available, will extermination or control projects be allowed to proceed? 12. What form of independent oversight exists to determine that the USDA is fully and objectively informing the public and research communities of all facets of this complex issue, and to prevent the USDA from abusing its authority? 13. What is the period for public comment on the PP&Q Safeguarding Review? These are just a few of the questions which need to be answered - many more are implied by the information presented above. There are many other aspects of the PP&Q Safeguarding Review which deserve closer scrutiny that I have been unable to address here due to time constraints. We must demand a “cooling off” period during which the USDA makes honest attempts to fully inform the public and research communities of the full ramifications of its proposals, and makes an honest attempt to hear the increasing number of skeptical voices in the academic community. We must allow time for the current “invasion” hysteria to cool off. The number of skeptical papers being published in invasion biology is on the rise. We are clearly on the verge of a “paradigm shift,” and the hysteria which has characterized its proponents will give way to more reasoned and balanced approaches. 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Bulletin of the Torrey Botanical Club 122:215-225. Chapman, L. J., C. A. Chapman, R. Ogutu-Ohwaya, M. Chandler, L. Kaufman, and A. E. Keiter. 1996. Refugia for endangered fishes from an introduced predator in Lake Nabugabo, Uganda. Conservation Biology 10:554-561. Chick, J. H., and C. C. McIvor. 1994. Patterns in the abundance and competition of fishes among beds of different macrophytes: Viewing a littoral zone as a landscape. Canadian Journal of Fisheries and Aquatic Sciences 51:2873-2882. Coblentz, B. E. 1990. Exotic organisms: Dilemma for conservation biology. Conservation Biology 4:261-265. Courtenay, W. R. J. 1993. Biological pollution through fish introductions. Pages 35-61 in B. N. McKnight, editor. Biological pollution: The control and impact of invasive exotic species. Indiana Academy of Science, Indianapolis. Crivelli, A. J. 1995. Are fish introductions a threat to endemic freshwater fishes in the northern Mediterranean region? Biological Conservation 72:311-319. Dahlsten, D. L. 1986. Control of invaders. Pages 275-302 in H. A. Mooney, and J. A. Drake, editors. Ecology of biological invasions of North America and Hawaii. Springer-Verlag, New York. Devine, R. 1998. Alien invasion: America's battle with non-native animals and plants. National Geographic Society, Washington, D.C. Drost, C. A., and G. M. Fellers. 1996. Collapse of a regional frog fauna in the Yosemite area of the California Sierra Nevada, U.S.A. Conservation Biology 10:414-425. Duncan, R. P. 1997. The role of competition and introduction effort in the success of passeriform birds introduced to New Zealand. American Naturalist 149:903-915. Ehrlich, P. R. 1986. Which animal will invade? Pages 79-95 in H. A. Mooney, and J. A. Drake, editors. Ecology of biological invasions of North America and Hawaii. Springer-Verlag, New York. Everitt, B. L. 1980. Ecology of saltcedar - A plea for research. Environmental Geology 3:77-84. Everitt, B. L. 1998. Chronology of the spread of tamarisk in the central Rio Grande. Wetlands 18:658-668. Hager, H. A., and K. D. McCoy. 1998. The implications of accepting untested hypotheses: A review of the effects of purple loosestrife (Lythrum salicaria) in North America. Biodiversity and Conservation 7:1069-1079. Hight, S. D. 1993. Control of the ornamental purple loosestrife (Lythrum salicaria) by exotic organisms. Pages 147-148 in B. N. McKnight, editor. Biological pollution: The control and impact of invasive exotic species. Indiana Academy of Science, Indianapolis. Holmquist, J. G., and J. M. Schmidt. 1998. High dams and marine-freshwater linkages: Effects on native and introduced fauna in the Caribbean. Conservation Biology 12:621-630. Karieva, P., I. M. Parker, and M. Pascual. 1996. Can we use experiments and models in predicting the invasiveness of genetically engineered organisms? Ecology 77:1670-1675. Kowarik, I. 1995. Time lags in biological invasions with regard to the success and failure of alien species. Pages 15-38 in P. Pysek, Prach, K., Rejmánek, M., Wade, M., editors. Plant invasions: General aspects and special problems. SPB Academic Publishing, Amsterdam. Larson, F. 1991. Before and after. San Francisco Chronicle, San Francisco, 25 October 1991. Lawton, J. H. 1998. Small earthquakes in Chile and climate change. Oikos 82:209-211. Lymn, N., and S. A. Temple. 1991. Land-use changes in the Gulf Coast region: Links to declines in midwestern loggerhead shrike populations. Passenger Pigeon 53:315-325. Malakoff, D. 1999. Plan to import exotic beetle drives some scientists wild. Science 284:1255. Marriott, D. 1997. Where to see the monarchs in California. Monarch News: 6-9. Maunder, M., A. Culham, B. Alden, G. Zizka, C. Orliac, W. Lobin, A. Bordeu, J. M. Ramirez, and S. Glissmann-Gough. 2000. Conservation of the Toromiro tree: Case study in the management of a plant extinct in the wild. Conservation Biology 14:1341-1350. Morrison, M. L. 1991. Developing a methodology for wildlife habitat restoration plans. Restoration and Management Notes 9:125-127. Moulton, M. P., and J. G. Sanderson. 1999. Fate of passeriform introductions: Reply to Duncan and Young. Conservation Biology 13:937-938. Pimental, D., L. Lach, R. Zuniga, and D. Morrison. 2000. Environmental and economic costs of non-indigenous species in the United States. BioScience 50:53-65. Reichard, S. H., and C. W. Hamilton. 1997. Predicting invasions of woody plants introduced into North America. Conservation Biology 11:193-203. Rejmánek, M., and D. M. Richardson. 1996. What attributes make some plant species more invasive? Ecology 77:1655-1661. Roughgarden, J. 1986. Predicting invasions and rates of spread. Pages 179-188 in H. A. Mooney, and J. A. Drake, editors. Ecology of biological invasions of North America and Hawaii. Springer-Verlag, New York. Schmitz, D. C., J. D. Schardt, A. J. Leslie, F. A. J. Dray, J. A. Osborne, and B. V. Nelson. 1993. The ecological impact and management history of three invasive alien aquatic plant species in Florida. Pages 173-194 in B. N. McKnight, editor. Biological pollution: The control and impact of invasive exotic species. Indiana Academy of Science, Indianapolis. Sharples, F. E. 1983. Spread of organisms with novel genotypes: Thoughts from an ecological perspective. Recombinant DNA Technical Bulletin 6:43-56. Stein, A. B., and J. C. Moxley. 1992. In defense of the nonnative: The case of the eucalyptus. Landscape Journal 11:35-50. Stromberg, J. C. 1998. Functional equivalency of saltcedar (Tamarix chinensis) and Fremont cottonwood (Populus fremontii) along a free-flowing river. Wetlands 18:675-686. Theodoropoulos, D. 1999. Invasion of the aliens: Science or pseudoscience? 26th Annual Natural Areas Association Conference, Tucson, Arizona, October 1999. Treberg, M. A., and B. C. Husband. 1999. Relationship between the abundance of Lythrum salicaria (purple loosestrife) and plant species richness along the Bar River, Canada. Wetlands 19:118-125. Tschinkel, W. R. 1993. The fire ant (Solenopsis invicta): Still unvanquished. Pages 121-136 in B. N. McKnight, editor. Biological pollution: The control and impact of invasive exotic species. Indiana Academy of Science, Indianapolis. U.S. Congress, O. T. A. 1993. Harmful non-indigenous species in the United States. OTA-F-565. U.S. Government Printing Office, Washington, D.C. Vondracek, B., D. M. Baltz, L. R. Brown, and P. B. Moyle. 1989. Spatial, seasonal and diel distribution of fishes in a California (USA) reservoir dominated by native fishes. Fish Research (AMST) 7(1/2):31-54. Williamson, M. 1999. Invasions. Ecography 22:5-12. Wilson, J. B., J. C. E. Hubbard, and G. L. Rapson. 1988. A comparison of realized niche relations of species in New Zealand and Britain (UK). Oecologia (Berlin) 76:106-110. Yamada, E., and C. Sandoval. 2000. 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  From D. Theodoropoulos (dtethbot@netzero.net) Submitted Nov 29 2000

• Dear Mr. Theodoropoulos:

  The Safeguarding Recommendation E-46 recommends APHIS, PPQ to : "Consider adopting a modified "clean list" approach for propagative material, specifying what is permissible subsequent to risk assessment, rather than the current "dirty list" that prohibits or restricts specific articles only. To begin this process, work with subject experts to develop a prototype assessment process upon which subsequent regulation could be based."

  The Risk Assessment Issue Group to which this recommendation has been assigned appreciates you taking the time to share your comments and concerns about this recommendation. The Risk Assessment Group has been working on action plans for other recommendations, and we have not yet addressed recommendation E-46. We will take your comments under consideration as we address this recommendation. For more complete information on how this recommendation came to be, I suggest that you read the Safeguarding American Plant Resoures Report which can be accessed at http://www.aphis.usda.gov/ppq/safequarding or at //www.safeguarding.org. Background on this issue is found on pp. 51-53. Other recommendations which follow from this background are E-44, E-45, E-47, E-48, E-49, and E-50.

  At the www.safeguarding.org/ site, if you click on "What is this review", it will tell you all about how the Safeguarding Report came to be and all about the process for how the recommendations generated are being addressed. You can also access lists of members of the various committees involved. Several of the “unanswered questions” you raise (questions in points 6, 9, 10, 11, 12, and 13) deal with the process by which the recommendations are addressed and the gathering of stakeholder input.

  The implementation process was designed to gather stakeholder input. The Risk Assessment Issue Group will use a variety of means, including scientific meetings, the Safeguarding website, and potentially other internet sites or links to gather input on the recommendation and consider alternatives offered by stakeholders prior to the development of the action plan. The action plans include a section called "Findings and Recommended Action" in which a course of action is recommended. This can include implementing, modifying, or not implementing the recommendation. Descriptions of other options that were considered, the effects of adopting the recommended course of action and the reasons therefore must be provided. The action plans also include an "Impacts" section in which possible impacts (including costs) of the proposed action on the affected public and industry are discussed. Any potential impacts of the proposed plan on germplasm and biodiversity collection, preservation, and enhancement activities will be addressed in that section. In your comments, you list a "grey list" approach as a possible alternative to the "clean list" approach. The Risk Assessment Issue Group will endeavor to solicit and evaluate several alternatives or options as well as the recommended action for their feasability, their impacts, and their ability to achieve the intended phytosanitary goals.

  Once an action plan is drafted, it goes through various stages of review by internal linked issue groups and peer review groups. It is then sent to a PPQ Steering Committee, which reviews it to ensure that it is complete and ready for review by PPQ Management's Executive Team. After review by the Executive Team, it will be posted on the official Safeguarding website where anyone can comment on the action plans. The comment period lasts for at least 2 weeks. If there are no substantive comments that need to be addressed, the plan would be considered final, and it would be turned over for implementation. In the case of recommendation E-46, given the considerable interest that this recommendation has generated, a longer comment period might be warranted. Even if the recommendation were to adopted, any subsequent regulatory changes which might be proposed would be subject to public notice and comment during rulemaking under the Administrative Procedures Act. In this case, interagency review would also take place. The National Program Leader for Germplasm Preservation of USDA Agricultural Research Service, the USDA Plant Introduction Stations, and the USDA Plant Germplasm Quarantine Office and other potential stakeholders involved in the collection and preservation of germplasm and biodiversity such as zoological and botanical gardens, herbariums, private collectors, nonprofit organizations, private and public crop researchers, economic botanists, and other stakeholders will have many opportunities for input before any potential rulemaking takes place.

  Most of your comments, concerns, and "unanswered questions" numbered 1 - 5, 8 and 11 deal with defining, assessing, and managing invasive or weedy plant species. Just to be clear, recommendation E-46 makes no mention of using herbicides and other methods to control introduced species or to monitor introduced species. While the concerns raised in the Safeguarding American Plant Resources report giving rise to this recommendation include the potential for propagative material to harbor plant pests of quarantine significance to the United States, the concern was also raised that propagative material should also be evaluated for its weediness or invasiveness potential. There are several other safeguarding recommendations that address these issues and that could potentially have some linkage, overlap, or impact on E-46; therefore, it would be premature and inappropriate for me to try to address all of these questions at this time. I will bring your comments to the attention of the co-leaders of the Safeguarding Issue Groups which are handling those recommendations for their consideration as well. Safeguarding recommendation E-49 recommends that APHIS "Coordinate noxious weed and invasive species initiatives with review of 7 CFR 319.37 and 330.200 based on rigorous risk assessment". This recommendation was assigned to the Authorities Safeguarding Issue Group, and it is being addressed in a combined action plan for recommendation E-4 which states "Begin its quarantine revision process with the revision of its Fruits and Vegetables (Q56) and Nursery Stock (Q37) quarantines. Target completion within 5 years". This action plan has already been submitted to the Steering Committee. Recommendation P-24, which is assigned to the Science and Technology Safeguarding Issue Group, recommends that APHIS "Develop a list of invasive plant species which, in addition to those listed in the Noxious Weed Act, would be restricted through permit requirements. This list should be developed in cooperation with and using expertise of the states, weed science and environmental organizations, universities and industry.". An action plan for this recommendation has not yet been developed. In addition, there are several other Safeguarding recommendations that deal with implementing the Executive Order on Invasive Species.

  If you have any further questions about the implementation process, please direct them to Ms. Paula Henstridge at Paula.Henstridge@aphis.usda.gov.
  From Susan Koehler, Risk Assessment Issue Group Submitted Nov 30 2000

• As a scientist, I am very concerned by the NISC plans to institute a screening system to be applied to basically every living organism in the U.S. I am even more concerned about the means to implement the ban on "outlawed" organisms. I oppose the use of herbicides or insecticides. They don't help to protect native flora and fauna, but make for an even more disturbed environment. They poison the soils and waters and the air they pretend to protect. If you eradicate life from a certain area, then you provide the perfect place for one or a very few species to take over in this area. Since many years, I have observed stands of non-native plants and their development. I can not agree that a species in itself is evil and should be banned as such. And I cannot agree that non-native "invaders" are any more invasive than certain natives. A species becomes invasive if it is given the opportunity, in most cases man made opportunities. Therefore I oppose the white list or clean list, I oppose comprehensive screening, and I oppose further usage of herbicides, insecticides etc. on public lands.
  From Karoline Mueller (kmueller@uh.edu) Submitted Nov 30 2000

• I am vehemently opposed to the recomendation of a "white list" which would place the control of genetic diversity of flora and fauna in this country into the hands of this list's corporate sponsors - herbicide manufactures and "life patent" corporations. I am outraged that in addition to the massive overload of toxins which would be rained upon the land, water, and air in the form of chemical herbicides and pesticides used to enforce the ensuing ban, the release of genetically-engineered bio-control organisms has also been promoted. Of course both of these strategies would greatly benefit the aforsaid corporations.
  From Margaret Rose Simons (jlee@industryinet.com) Submitted Dec 01 2000

• GREETINGS, Thank you for providing an opportunity to comment. Please continue to use this response technology to clarify the viewpoints of the American people. Granted, in many cases our responses may not appear 'scientific', yet even a purely 'emotional' response may well be rooted in an unconcious collective intelligence that is very capable of understanding the scientific effect the 'white' list may have. So I respond emotionally, and intellectually, with the following: As a citizen of the United States of America, and of the world, I ask that you investigate closely the reasons why so many people here have commented against the white list. The are responding from many differing viewpoints, yet there is a common thread if you look closely. That common thread must be found and deciphered for its fullest meaning, for within the thread lies the scientific and emotional reasoning needed to BEST answer the question the USDA has, to implent, or not to implent, the white list. My comment, my response is: I do not like the idea of the white list, it is an infantile,yet understandable, response to a percieved threat. It has little thought, besides fear, motivating its inception. I do not support it. With respect, Sincerely, Leland Daugherty
  From Leland Daugherty (makingthings@yahoo.com) Submitted Dec 01 2000

• To whom it may concern: I find this proposal repugnant and ill advised. You are trying to put out of business every plant dealer, seed exchanger and local gardening cooperative that exchanges or sells plant materials. This is basically biological censorship. It really does look like the major lifescience corporations are going to get payback for their investments in the politcal parties in Washington. Only they will be able to afford the lab tests to "prove" safety of plant materials--oh, and I suppose that perhaps they will patent the some aspect of the material at the same time as a reward for their investigations. This kind of thing is why government is distrusted by the American people, at least the one's that still are not anesthetized by sports and consumerism. I have a QUESTION and would like a response since I have pumped plenty of money into the federal budget through my taxes. Who is paying for the activities of the commitee that will decide this question? And, what measures are in place to prevent conflicts of interest as mentioned above? Thank you very much--awaiting your response.
  From chris ward (freewebpage2000@yahoo.com) Submitted Dec 23 2000

• This would be funny were it not so scary. You guys remind me of Buck Turgidson in Dr. Strangelove, 'protecting vital fluids'. Are you really prepared to shut down all horticulture, all gardening, all food plant research, just to make Monsanto happy? The enormity of the idiocy of this proposal is amazing. Clearly none of you proposing this really have gardens, ever read a seed catalog, or care to step outside your offices to see what a monstrous thing this would be: no new flowers, no old flowers from new sources, no different varieties of fruit...just the 3 kinds of plants available at the local mega store. And by the way, fuchsias, lettuce, tea roses, pears, tulips, crocus, geraniums---none of them native to the US. I would like to see the real source of the funding for this proposal...and how much money is being put into this. And the government thinks Microsoft is non-competitive!
  From Judith Miller Submitted Jan 01 2001

• We do Not need a "white list", we already have enough laws on the books on noxious weeds and invasive species. Invasiveness is impossible to predict, except for well known agricultural weeds. Please, NO White List! You will be punishing the gardeners of this country for no needful reason.
  From Dan Ackermann (dnlbn@brainerd.net) Submitted Jan 02 2001

• I would like to register my strongest opposition to the "white" or "clean" list proposal. The horse is gone there's no sense in locking the barn door. We have introduced so many non-native species, and they have been propagating and adapting for so long now, that any attempt to limit further introduction is laughably inadequate. One can only be sure that in the current modern era worldwide overnight mail, the proposal would be completely uninforceable anyway. Dismiss this proposal. David O. Gray, B.S. Horticulture, Botany, B.A.
  From David O. Gray (NCCPS@aol.com) Submitted Jan 06 2001

• What could be more arrogant than deciding that there can be an inclusive list which contains only "good" plants? Even during my lifetime I have seen the growth and decline of several species in my own neighborhood with some plants becoming dominant at times then eventually disappearing. Should the plants which are growing at an increasing rate be "controlled" through eradication and poisoning? Do we know enough to predict what will happen? Which are the good plants and which ones are the bad ones? What about plants being developed in the US? What about plants being engineered in the lab? Are they good? Are they bad? I think that there is enough uncertainty about the risk of invasive species and about what plants are inherently good and inherently bad that this change in regulation is unwise. It is always fun to chase a new problem, but I think that the original focus on preventing known "dirty" plants is a much better and much more productive approach than the xenophobic response of banning everything but a select few. However, if this body is powerful enough to enact the regulation and manage to prevent any not nice species from entering the country, could you please come by my house and read your regulations to the dandelions in my yard. I'd like them to go back where they came from.
  From Jack Dahlgren (JackDahlgren@hotmail.com) Submitted Mar 12 2001

• I wish to register my strong opposition to the notion that only approved species of plants should be allowed into the United States, which is the subject of proposed legislation. In a free society, government should not bar actions that it has not approved in advance. Government should bar only identifiable, known and serious risks to our country's health, safety and prosperity. I oppose the creation of a USDA "White List". Sincerely, Jonathan Wilcox 121 Croydon Way, Woodside, CA 94062
  From Jonathan Wilcox (jonathan@menai.com) Submitted Aug 06 2001

• This is the most restrictive form of control possible and the ramifications to our diversity of plants available to us could be reduced to the point where it harms not only our private gardens but our economy! Once the "white List" is in place it will bog down in government red tape and destroy free trade. This is a Bad idea at best and should never have been considered by rational people. To ban certain plants that are a problem is one thing but to ban All plants till proven otherwise. That can take years to clear a plant and even then the tests will be inconclusive due to the very fact that it will be impossible to test it under all the possible growing conditions and climates found within a single state much less the nation! So the end result is that all non natives will be banned and may never be approved! We do not need this type of law nor do we need the tax payers to find themselves supporting the size beuracracy it would take to implement it! Let' see some good old horsesense applied to this!
  From Brenda Essig (Zanymuse2@yahoo.com) Submitted Aug 14 2001

• I posted this message to the NO WHITE LIST group some time ago but it was censored by the list moderator. Hopfully some of those list members will now read my response in full. In response to, "and after learning what they are doing in Australia and New Zealand, I feel it is not only foolish, but dangerous." I'm sorry you feel this way about our recognition of our past mistakes. It only took us 170 years. Fortunately we are heavily supported by the general public in our cause to prevent the introduction of any more invasive species and I include the many nursey operators, plant breeders and researchers I deal with on a day to day basis. Of course some people are not be happy at being told they can't have some of the species from their proposed list of imports, but on the whole they can bring in the vast majority of plants on their lists. A most significant point is that out of the ten thousand plus species I have assessed over the last five years there have been only two people who disagree and asked for a review of the assessment. We have not closed down the nursery industries, they still trade as profitably as ever, seed merchants and researchers still import germplasm material and horticulturalists and plant collectors still bring in material from all over the world. The result has not seen an increase in the use of pesticides, in fact the opposite should be the result as there are less plant species establishing that would require herbicides. We tend to find them sooner nowadays anyway as the public bring in anything remotely weedy looking and ask if they should remove it. Often we have to temper thier eagerness by explaing that the weed they have brought in is very common and there is no possibility of eradicating it or its one of our spiny natives. The pesticide industry is in no way involved in this initiative and I would know as I have been involved since the very inception of the program. GMO's in Australia are very heavily assessed for environmental suitability before release even if the parent species is already grown commonly within Australia. In Australia people call or write letters or send emails asking why we don't do more to stop the weed, insect, disease... problems etc. We have community groups applying for NHT (National Heritage Trust) funding to control weeds in forests and remnant urban bushland. There are "friends of..." groups forming all the time to work on weed issues all around Australia. When a gardening magazine or TV gardening show says to plant this or that (and its an invasive species) they get dozens of letters from irate gardeners complaining about that article or segment and how they should not be promoting this weed. The bottom line, while you feel we are involved in a foolish even dangerous pursuit, the vast majority of Australians I talk to understand these issues and support our work. They often complain that we don't do enough and ask for increased protection in beefing up our quarantine. Personally I feel I am making a positive contribution to the long term sustainable development of Western Australia as well as positively helping to protect and maintain our diverse native ecosystems.
  From Rod Randall (rprandall@agric.wa.gov.au) Submitted Oct 03 2001

• Like the majority of people who have placed comments under this section, I am absolutely, categorically opposed to the proposed modified white list. It is unreasonable to assume that sufficient funding would ever be available - no matter how high you drive "user fees" - to provide adequate staff, sufficiently knowledgeable in all plant species on this planet to prepare a list that was in any way meaningful, let alone provide meaningful, unbiased and intelligent assessment of unknown plants. We should be encouraging horticultural diversity, not restricting it. The proposal is not realistic, nor is it necessary.
  From Marge Talt (mtalt@clark.net) Submitted Dec 04 2001

• No white list! I'm totaly against it! Even if we have lots of problems with invasive species I don't think white list is an answer! It's succeptible to way too much possible abuse! Think positive, DIVERSITY IS GOOD! What's next, a white list for people??????
  From dzejna valentic (dzejna66@cs.com) Submitted Jan 10 2002

• As a master-gardener and informed horticultural advocate, I am totally against a white-list which includes many or most life forms. I am aware of the need to protect indigenous plants and to avoid mistakes such as planting kudzu or pepper trees. However, each life form merits individual consideration. We often do not understand the need for certain species until after we have eradicated them and and then discover the part they played, e.g., the common coyote. This white list must not place the stewardship of life in the hands of corporations or governmental control. Patricia Patterson Tursi, Ph.D.
  From Patricia Patterson Tursi, Ph.D. (ptursi@arkansas.net) Submitted Feb 24 2002

• I am very much in support of a white list for new horticultural introductions. This may not provide enough protection, but it is better than the current policy, which will only reveal a problem after "the genie is out of the bottle". We need to think in innovative ways to explore and exploit our resources that we have already, rather than to impulsively seek the novel. Our impact needs the tempering of what the, seemingly, only reasoning species (that's us) can provide.
  From Fran Lawlor (flawlor1@twcny.rr.com) Submitted Feb 27 2002

• The very concept of "Guilty until proven innocent" is antithetical to a scientific approach, as well as American legal and social tradition. The "Noxious Weed" clean-list proposal is noxious to the vast majority of American citizens. I question the origin of such a proposal. I question it's true motivation.
  From Grant Houston (granthouston@webtv.net) Submitted Mar 30 2002

• I am opposed to the "white list" not only from the standpoint of a gardener and seed trader as well as preserving native species but as a taxpayer. I question who is funding this, who decides based on what for a plant to go on the "white list" and bottom line, who profits? Is this one more step for corporate giants like with the GMO's? Is this one more step towards government control of private lives? Each step leads the way for another to follow. Keep the invasive weed program, educate the public to help and do not implement a "white list".
  From Roxanne Brown (elemclay@cloudnet.com) Submitted Apr 01 2002

• Absolutely not do I endorse a white list. I could list a hundred reasons why this will do more damage than good. However, I will just emphatically say this is the worst plan I have ever heard of. Laurie AE O'Meara Artist and Horticulturist
  From Laurie A.E. O'Meara (Laurie@laeom.com) Submitted Apr 14 2002

• WHAT ARE YOU DOING!!! The White List or "clean list" IS A COMPLETELY STUPID IDEA, PLEASE CEASE AND DESIST. I doubt you can do a better job than mother nature.
  From NataLee DeMichele (demichen@pixelwitch.com) Submitted Apr 23 2002

• My suggestion is to stick to your 'dirty list' and bring it up to date! With all the plants there are and all the plants that are still being identified, I feel your efforts would be more worth while tending to business, not Big Business.... If cash crops and synthetic green lawns are all that are left --- then you will have been the ones to have messed with the environment.. as if progress and urban sprawl hasn't done enough. Barbara A. Thacker
  From Barbara A. Thacker (rdkllalice@yaoo.com) Submitted Apr 23 2002

• The "clean list" approach is not only unnecessary, it is potentially dangerous. If you look beyond the stated reasons for using this approach and look at how it might be abused, there is no question in my mind that this is wrong. Even the stated goals are questionable. When we set out to annihilate entire species in an ecosystem, we really don't have full understanding of the ripple effects our methods will cause. The ones who would benefit most from this kind of policy are the chemical industry and big agri-businesses. As a U.S. citizen, I must oppose these measures whole-heartedly. Peter Gaeta Huntley, IL pgaeta@mindspring.com
  From Peter Gaeta (pgaeta@mindspring.com) Submitted Apr 24 2002

• ... Who are you to try to control everything that goes on around you? I do not agree with this proposed act and am hereby expressing my opinion about it...I DISAGREE!
  From Meggan P. O'Brien (melonhead7@msn.com) Submitted Apr 25 2002

• The White List (or "clean list") is proposed policy which will extend government and corporate control over the possession, importation and movement of anything that is alive - plants, animals, fungi, microorganisms, everything. Under current law, the government controls or prohibits a limited list of pest species - agricultural weeds, insect pests, dangerous pathogens, etc. Only species known to cause problems are controlled. Under the White List, the government will draw up a limited list of species it deems "safe", which will continue to be legal to possess, move or import. All other species, an estimated 99.75% of the Earth's biota will be considered "guilty until proven innocent", presumed harmful or dangerous, and will be prohibited. Once in place, only the limited "white list" of government-approved species will be permitted - all other species will be considered contraband, with penalties for possession and mandated extermination. To add a species to the White List, expensive "safety testing" and "risk assessment" will be required for approval. Randy Westbrooks, of the USDA, stated that the testing should be similar to the 30 to 40 million-dollar safety testing required to market a new toxic chemical. To offset the cost of testing, a new form of life patent will be granted, giving sole rights to the entire species and its genome to the corporation paying for the testing (it being unlikely that individuals will be able to afford such testing), and granting complete immunity to the patent holder of the species becomes a pest. This will place over 99% of the natural world off-limits - it is the greatest "theft of the commons" from humanity, and the greatest extension of government and corporate control over the natural world in history. While placing the Earth's living biodiversity into private corporate ownership, it will also create self-perpetuating bureaucratic sinecures - an army of unelected bureaucrats, unanswerable to the public, with the power of life and death over all species. Once federal legislation is in place, the states will soon follow, controlling all movement of native species between states. The White List/National Weed Strategy will mandate the extermination of all unapproved species. Not only will this include unapproved "foreign" species from outside the U.S., but will inevitably include hundreds of U.S. native species which happen to have moved outside their historic boundaries - many native species with expanding ranges are already being exterminated wherever they are deemed "invaders" by decision-makers. At a prairie restoration in New York 5 species of native trees and shrubs were declared "invaders", cut and burned. In Illinois, a native Solidago killed with herbicide; in an Indiana nature preserve native Red Cedar girdled and burned; at Curtis Prairie, University of Wisconsin, native aspens declared "invaders", girdled and cut; at Dolomite Hill Prairie Restoration in Illinois, 4 native trees and shrubs cleared with brush hogs, herbicide and burning; in California, native red fox declared an "alien predator" and killed; in San Diego County a native Encelia was declared "a threat to genetic and ecosystem integrity" and exterminated. Even the endangered Monterey Cypress is killed mere miles from its last remaining wild stands as a "weed tree" and "non-native fire hazard". The propagation and reintroduction of endangered wild plants has been called a "risk to the genetic integrity of wild plant populations" and a threat to "native plant communities". This is a government seizure of the power to dictate the natural range of every species, and to dictate the exact species composition of all natural areas and every ecosystem in the nation. Private property will not be excluded - even under current law the government has the power to enter private land and destroy pest species. If you are found with an unapproved species on your land, the "infestation" can be declared a public nuisance, exterminated, and you can be billed for the costs of "abatement". I vehemently oppose this planned legislative change. It is un-American in its concept, and totalitarian in its goals. This is a path to the abyss for America and for the world. HRBaxter
  From HRBaxter (hrbaxter@yahoo.com) Submitted Apr 25 2002

• this clean list crap is facist insanity, & the people who support this idea scare the hell out of me
  Submitted Apr 28 2002

• This is a very bad idea. Any laws that are bad for people in general are bad ideas. What's good for business is NOT necessarily good for people. What could the possible benefits be to creating a "clean list"? It's ridiculous.
  From Amanda Calder (jazzypanda@yahoo.com) Submitted May 07 2002

• If you considering that the goverment refuses to require large corporations to label foods that contain genetically modified organisms and they have found a way to help these corporations join the organic bandwagon with new rules and intervention, this shuld be the last straw. They are trying to eliminate all but the largest "corporate welfare" farms. At some point it is time to say that enough is enough.
  From Terry Brown (tvbrown@naxs.net) Submitted Jul 12 2002

• If you considering that the goverment refuses to require large corporations to label foods that contain genetically modified organisms and they have found a way to help these corporations join the organic bandwagon with new rules and intervention
  From Terry Submitted Jul 12 2002

• We should do this right after we win the war on drugs, the war on terrorism, and the war on poverty (anyone even remember when that was declared?) Just don't spend MY tax money on it. We can't even finish what we have going now. Don't you make your kids clean their plates before going back to the buffet line? No? Well I do.
  From Michael Parks (Nuttyducks@aol.com) Submitted Jan 11 2003

• We are totally opposed to any sort of "clean list," "white list," "restricted list," or whatever you may choose to call it. The very notion of "guilty until proven innocent" is contrary to our deepest values, and would ridiculously restrict not only private gardeners, but also botanical gardens and research scientists. The pricetag for getting a plant declared "okay" would be so steep that only large companies could afford it. also, declaring plants already in commerce illegal would result in further fascistic invasions of citizens' privacy, and more "big government," something Republicans are *supposed* to be against. This seems like a VERY BAD IDEA. --Bruce and Wendla Duncan hatter@calweb.com
  From Bruce and Wendla Duncan (hatter@calweb.com) Submitted Jan 11 2003

• I want to look at this a little differently. Perhaps they are right, introduced species do create problems...concider the white europeans who came here and killed off the native americans....maybe we should all just go "back where we came from"...god knows He didn't want us here.So, yes, lets all rid this counrty of the menace which are introduced exotics...starting with the old white men in charge of this government.
  From Michael Parks (Nuttyducks@aol.com) Submitted Jan 11 2003

• I am definitely NOT in favor of the proposed "white list". The current "dirty list" certainly needs to be updated, but arbitrarily banning species by not including them on the list shows an irresponsible lack of initiative. Energy should be spent investigating species that might be harmful, and even (perhaps especially) investigating species that have already been introduced and are beginning to take over. I don't refer to plants such as honeysuckle, kudzu, and certain other notorious genera, but those that have just begun to naturalize themselves and show a threat to the native ecosystem, even if it be a minor one. One example, in my region (the Wasatch mountain foothills), is Euphorbia mysinities, very popular with gardeners because of its tolerance to extreme heat and aridity. It has escaped and nobody seems to have noticed (government-wise) that it is becoming a serious threat to the native flora, and therefore fauna. I also don't trust the agency that brought us honeysuckle and kudzu and mass-planted them all over the country to choose their "white list" wisely.
  From C Cerling (cec9@utah.edu) Submitted Mar 03 2003

• So now plants as well as people are to be presumed guilty until proven innocent? Ridiculous! This sucks. It is poor science, and yet another attempt to lock everything on earth up for the rich (for only they could afford to prove a plant "innocent." I'm totally against it, and I imagine a LOT of home gardeners will also oppose this idiocy when they find out. I'm going to post the information at my local nursery, and write my representatives against this stupidity. --Bruce Duncan
  From Bruce Duncan (hatter@calweb.com) Submitted Mar 21 2003

• I am absolutely OPPOSED to this recommendation. We already have enough regulations in place concerning noxious weeds and plant pests. This regulation cannot be reasonably enforced and to attempt to do so will cost millions in tax monies. This recommendation will unreasonably restrict my freedom of choice concerning those food plants I grow in my garden. I have severe chemical allergies and must have completely organically grown food. I become very ill from the residues of chemicals in my food. To broaden my food base I have been experimenting with little known edible plants from many other places to extend the range of foods which can be grown here on our natural rainfall of 12 inches per year or less. This regulation would severely curtail my research and cause me further hardship by continuing to require my growing of conventional food crops which need supplemental watering. Such watering costs me as much as $120 per month during the summer and in some years many plants have been lost anyway due to restrictions from the water company. This regulation will further retard my reclamation of marginal and disturbed areas on my property. Disturbances due to overgrazing in the past and current destruction of native species by trespassers on ATV's have caused severe erosion on steep hillsides. Currently native species do not seem to be able to move into these areas to stop the erosion. But there are some plants I have heard about that may be able to grow in these places and hold the soil in place, at least long enough that the native plants can come back in. These regulations would prevent my easy access to finding and utilizing such plants. There are many other reasons that I am opposed to these regulations, but I think the above is enough to give you an idea of why. Thank you Mary Edendfield
  From Mary Edenfield (ladymari@cybertrails.com) Submitted Jun 03 2003

• Although I oppose the daily importation of non-native species at the rate of 2,000 plants a day (into the port of Los Angeles alone, I do not condone your idea of a white list, for many of the reasons already stated in the comments thus far on the "White List". What I really fear in this ill-conceived idea, is the potential for corporate or goverment greed in patenting any new plant-or any plant for that matter, and then robbing all others of it's use for reserch or profit or preservation or whatever, and to top it off, to have immunity from responsibility such as clean-up or errdication of that patented living organism, and to be able to sue others to erradicate the organism at the cost to the victims of invasion by the patented species. Thus is exactly what has happened to farmers who's crops have been invaded by alien genetically engineered corn and soy. How many more times must we suffer losses to corporate greed maquerading as environmentally or socially responsible corporations!!!
  From Christine Todd (ctgarden@pacbell.net) Submitted Jun 26 2003

• I think that this is a very bad idea. If this happens, we will truly no longer be free.
  Submitted Jul 12 2003

• The current paranoia about invasive species is not based on sound science, but is rather fueled by the demonization of plants that are able to adapt to new environments, as has been happening throughout the biological history of Earth. These new species will eventually be integrated into native ecosystems, not supplanting them as many fear. The purported "monocultures" of purple loosestrife and saltcedar that supposedly don't support native species of bird and insects one hears about have been shown to support native species after all. The FEARS are UNFOUNDED. The "clean list" is an unprecedented government control of the spread of plants, fueled by unfounded fears.
  From Gordon Hogenson (ghogen@microsoft.com) Submitted Jul 10 2004

• I am utterly opposed to any "white list." It's bad biology, and bad practice. "Guilty until proven innocent" is a fascist attitude, whether applied to plants or people, and this whole scam is a ploy on the part of those who want to patent all lifeforms, and prohibit anything that isn't patented.
  From Bruce Duncan (hatter@calweb.com) Submitted Mar 01 2005

• The only "invasive species" that needs to be controlled is the narrow-minded, fascist, anti-nature controller-dominators who have hijacked this country (you know, the land of the FREE)! I'm referring to the socio-political-medical-military industrial complex, the interconnected web of wanna-be-Demi-Gods who seek to dominate and subdue nature (under the guise of protecting us) while keeping their eyes on the monetary prize raked in by corporate profiteers as they pillage the Garden of Eden. NO WHITE LIST -NO! Keep your Hitler approach to horticulture in your narrow little minds! Humans are part of nature, we have no business selectively playing God. Biodiversity is directly linked to sustaining all of life on the planet, including humans. Not everyone believes in the End Times, not everyone thinks nature is God's gift to be used up. We are eternal and eternally connected to all of life. Support life and informed choice, not fear, propaganda and paranoia. NO WHITE LIST! Blessed be our gardens, protected forever and free to grow!
  From Lynn Norene Phoenix Boulay (firebird@pngusa.net) Submitted Mar 13 2005

• The idea of a "safe list" is very troubling to me. While invasive species do pose a very real threat (I am more concerned about animals than plants), such effort to limit all imports is dangerous. There is no doubt in my mind that this effort is being pushed by large corporations that seek to control all plant material for profit. If there had been a safe list 500 years ago, would corn, tomatoes, and potatoes made their way to Europe? Would wheat have been allowed in the Americas? The government and especially large corporations using the powers of the federal government should not control our ecological futures.
  Submitted Jul 08 2005

• I am completely against the concept of a "clean" or "white" list for flora and/or fauna. Rather than summarily delegating any one thing as "bad" or good", the practical approach to resolving potential conflict with a non native (and native species that are found outside of their traditional boundries) species is on a case by case basis. If an organism is discovered to be a problem in a specific instance, it can be dealt with accordingly, but a policy that leads to automatically ban any and all future occurance (and thus mandate it's destruction) of a species can only be described as a short sighted, illogical "shotgun" approach.
  From Melody Hobbs (whitestar@intergate.com) Submitted Nov 07 2005

• I would sooner establish a "clean list" for politicians and bureaucrats. Mankind has learned thousands of years ago that proscriptive law is far more economical than is permissive law. One tool that has been used all that time to establish the efficacy of proposed laws is "cui bono?" -- whom will this benefit? Please follow the money back to its source and we will know whom a "white list" law will benefit. Meanwhile, I am now taking steps to preserve rare and heirloom plant life. These will be the Anne Franks of the twenty-first century.
  From Robert Biddle (rmbiddle@nethere.com) Submitted Dec 26 2006