Condiman
12-22-2004, 06:26 PM
The following is a critical issue, and comments are due by 12/27/04
PIJAC PetAlert
USDA PROPOSES TO LIST ALL CAULERPA SPECIES -- COULD BAN LIVE ROCK
ISSUE: The U.S. Department of Agriculture's (USDA) Animal and Plant Health
Inspection Service (APHIS) announced it would consider two petitions
requesting the addition of either (1) the genus Caulerpa or (2)the entire
species of Caulerpa taxifolia to the APHIS list of noxious weeds.
WHAT IT MEANS: If successfully listed as a noxious weed the trade of
Caulerpa
in the United States would effectively end as one would need a permit to
transport it. This also potentially means that the trade in live rock would
also be banned as live rock might be considered 'infested' with Caulerpa.
WHAT YOU NEED TO DO: Comments from the ornamental aquatics industry are
needed now to ensure that the USDA does not ban safe algae as well as LIVE
ROCK without a sound scientific justification. See below on how to submit
comments and what points to consider in your submission. Comments are due
by
Dec. 27, 2004.
BACKGROUND: The International Center for Technology Assessment (ICTA) and
Professor Susan L. Williams, University of California-Davis submitted two
petitions to the USDA APHIS requesting the listing of either the whole genus
Caulerpa or the entire species Caulerpa taxifolia to the APHIS list of
noxious weeds. These petitions were also signed by 104 invasive species
scientists and resource managers.
The USDA announcement at
http://www.aphis.usda.gov/ppq/weeds/caulerpa/index.html contains copies of
the key documents.
Federal Register Notice
http://www.aphis.usda.gov/ppd/rad/webrepor/ppq.html.
Petitioners argue that regulating (or, "listing") the genus Caulerpa or the
entire species C. taxifolia is scientifically sound given the presence of
multiple exceptionally invasive and highly variable forms in these groups;
the difficulty in identifying the single, currently regulated strain of this
species by eye; the frequency with which species are being co-mingled, sold,
and distributed in the United States and the world; and evidence that many
shipments of algae and other aquarium plants are neither identified
correctly
nor labeled accurately. They argue that allowing import of only those
species
deemed non-invasive (which in their opinion means no species of Caulerpa) is
the only effective way to regulate these marine algae.
Exhibits accompanying the petitions indicated that several importers
referred
to Caulerpa as "Algae green/in bags," "Grape algae," Algae Red," -- in most
instances the proper scientific names were included while some simply
indicated "Caulerpa Spec on Scleractinia." Petitioners claim that most
retailers had no idea of the species they handle and that "live rock" is a
major pathway despite the fact that the only surveys conducted did not find
any Caulerpa taxifolia on the live rock.
It should be noted that the strain C. taxifolia (Mediterranean clone) or
noted in the petitions as "C. taxifolia MC" is currently banned from import
into the US as well as in the State of California which has the support of
the industry. 8 other Caulerpa species are prohibited in California due to
being "look-alikes" or species where some data indicated potential problems
in California waters.
MAIN MESSAGE: Your comments to the USDA APHIS should state that they not
approve either petition at this time. Rather the USDA APHIS should work
within the framework of the Aquatic Nuisance Species Task Force's
inter-agency "National Management Plan for the Genus Caulerpa," currently in
its final stages of approval.
Other points are that the petitions fail to contain scientific or other
evidence justifying wholesale listing of an entire genus or the species C.
taxifolia and USDA should defer any action pending the receipt of reliable
data. As noted in the petitions C. taxifolia occurs as a native species in
parts of Hawaii and Florida and is not considered invasive thus any
contention that C. taxifolia is "naturally" an invasive species that wipes
out huge areas of native species is clearly false.
Secondly, again as noted in the petition, the C. taxifolia that is
considered
invasive in the Mediterranean "apparently underwent a genetic change while
being maintained in aquaria" and "this change is hypothesized to contribute
to its invasiveness." If this is true, as claimed, then the chances of C.
taxifolia from other areas around the World which have not been exposed to
long-term aquarium conditions (meaning Caulerpa on live rock etc.) having
undergone genetic change to become invasive is scientifically remote.
Thirdly, as noted on the web page of Dr. Susan Williams
(http://www.bml.ucdavis.edu/facresearch/williams.html) species of Caulerpa
commonly grow in many tropical marine waters around the world and remain in
the understory of seagrass beds which can outcompete Caulerpa. Thus, by her
own admission Caulerpa is not a renegade species of algae bent on carpeting
the ocean floor which is how her petition reads.
Fourthly, peer-reviewed and published research has shown that the extent of
the Caulerpa invasion in the Mediterranean has been overstated by an order
of
magnitude or more and the establishment of Caulerpa in a seagrass bed does
not automatically mean the demise of the seagrasses. All these points and
more demonstrate that there is no scientific evidence to support the listing
of the entire species or genus as a noxious weed. More research is required
as called for in the draft National Management Plan before listing.
DEADLINE: The comment period closes on December 27, 2004
ACTION: Submit written comments.
* Mail: send four copies of your comment (an original and three copies) to
Docket No. 04-037-1, Regulatory Analysis and Development, PPD, APHIS,
Station
3C71, 4700 River Road Unit 118, Riverdale, MD 20737-1238.
Make sure to state that your comment refers to Docket No. 04-037-1.
* E-mail: Address your comment to < regulations@aphis.usda.gov >. Include
your name, address, "Docket No. 04-037-1'" in the subject line, and your
comment in the body of your message. Do not include any attached files.
* On line comments can be submitted and viewed via the agency web site: Go
to
< http://www.aphis.usda.gov/ppd/rad/cominst.html >
PIJAC PetAlert
USDA PROPOSES TO LIST ALL CAULERPA SPECIES -- COULD BAN LIVE ROCK
ISSUE: The U.S. Department of Agriculture's (USDA) Animal and Plant Health
Inspection Service (APHIS) announced it would consider two petitions
requesting the addition of either (1) the genus Caulerpa or (2)the entire
species of Caulerpa taxifolia to the APHIS list of noxious weeds.
WHAT IT MEANS: If successfully listed as a noxious weed the trade of
Caulerpa
in the United States would effectively end as one would need a permit to
transport it. This also potentially means that the trade in live rock would
also be banned as live rock might be considered 'infested' with Caulerpa.
WHAT YOU NEED TO DO: Comments from the ornamental aquatics industry are
needed now to ensure that the USDA does not ban safe algae as well as LIVE
ROCK without a sound scientific justification. See below on how to submit
comments and what points to consider in your submission. Comments are due
by
Dec. 27, 2004.
BACKGROUND: The International Center for Technology Assessment (ICTA) and
Professor Susan L. Williams, University of California-Davis submitted two
petitions to the USDA APHIS requesting the listing of either the whole genus
Caulerpa or the entire species Caulerpa taxifolia to the APHIS list of
noxious weeds. These petitions were also signed by 104 invasive species
scientists and resource managers.
The USDA announcement at
http://www.aphis.usda.gov/ppq/weeds/caulerpa/index.html contains copies of
the key documents.
Federal Register Notice
http://www.aphis.usda.gov/ppd/rad/webrepor/ppq.html.
Petitioners argue that regulating (or, "listing") the genus Caulerpa or the
entire species C. taxifolia is scientifically sound given the presence of
multiple exceptionally invasive and highly variable forms in these groups;
the difficulty in identifying the single, currently regulated strain of this
species by eye; the frequency with which species are being co-mingled, sold,
and distributed in the United States and the world; and evidence that many
shipments of algae and other aquarium plants are neither identified
correctly
nor labeled accurately. They argue that allowing import of only those
species
deemed non-invasive (which in their opinion means no species of Caulerpa) is
the only effective way to regulate these marine algae.
Exhibits accompanying the petitions indicated that several importers
referred
to Caulerpa as "Algae green/in bags," "Grape algae," Algae Red," -- in most
instances the proper scientific names were included while some simply
indicated "Caulerpa Spec on Scleractinia." Petitioners claim that most
retailers had no idea of the species they handle and that "live rock" is a
major pathway despite the fact that the only surveys conducted did not find
any Caulerpa taxifolia on the live rock.
It should be noted that the strain C. taxifolia (Mediterranean clone) or
noted in the petitions as "C. taxifolia MC" is currently banned from import
into the US as well as in the State of California which has the support of
the industry. 8 other Caulerpa species are prohibited in California due to
being "look-alikes" or species where some data indicated potential problems
in California waters.
MAIN MESSAGE: Your comments to the USDA APHIS should state that they not
approve either petition at this time. Rather the USDA APHIS should work
within the framework of the Aquatic Nuisance Species Task Force's
inter-agency "National Management Plan for the Genus Caulerpa," currently in
its final stages of approval.
Other points are that the petitions fail to contain scientific or other
evidence justifying wholesale listing of an entire genus or the species C.
taxifolia and USDA should defer any action pending the receipt of reliable
data. As noted in the petitions C. taxifolia occurs as a native species in
parts of Hawaii and Florida and is not considered invasive thus any
contention that C. taxifolia is "naturally" an invasive species that wipes
out huge areas of native species is clearly false.
Secondly, again as noted in the petition, the C. taxifolia that is
considered
invasive in the Mediterranean "apparently underwent a genetic change while
being maintained in aquaria" and "this change is hypothesized to contribute
to its invasiveness." If this is true, as claimed, then the chances of C.
taxifolia from other areas around the World which have not been exposed to
long-term aquarium conditions (meaning Caulerpa on live rock etc.) having
undergone genetic change to become invasive is scientifically remote.
Thirdly, as noted on the web page of Dr. Susan Williams
(http://www.bml.ucdavis.edu/facresearch/williams.html) species of Caulerpa
commonly grow in many tropical marine waters around the world and remain in
the understory of seagrass beds which can outcompete Caulerpa. Thus, by her
own admission Caulerpa is not a renegade species of algae bent on carpeting
the ocean floor which is how her petition reads.
Fourthly, peer-reviewed and published research has shown that the extent of
the Caulerpa invasion in the Mediterranean has been overstated by an order
of
magnitude or more and the establishment of Caulerpa in a seagrass bed does
not automatically mean the demise of the seagrasses. All these points and
more demonstrate that there is no scientific evidence to support the listing
of the entire species or genus as a noxious weed. More research is required
as called for in the draft National Management Plan before listing.
DEADLINE: The comment period closes on December 27, 2004
ACTION: Submit written comments.
* Mail: send four copies of your comment (an original and three copies) to
Docket No. 04-037-1, Regulatory Analysis and Development, PPD, APHIS,
Station
3C71, 4700 River Road Unit 118, Riverdale, MD 20737-1238.
Make sure to state that your comment refers to Docket No. 04-037-1.
* E-mail: Address your comment to < regulations@aphis.usda.gov >. Include
your name, address, "Docket No. 04-037-1'" in the subject line, and your
comment in the body of your message. Do not include any attached files.
* On line comments can be submitted and viewed via the agency web site: Go
to
< http://www.aphis.usda.gov/ppd/rad/cominst.html >