Archive | March, 2012

Invasive Species: Costs of Inaction

Laws protecting America from invasive species go back a hundred years and provide a basis for preventing importation of potential, invasive wildlife, such as the notorious Burmese python, snakehead, and lionfish.  Yet, virtually no regulation restricting entry of “injurious” wildlife actually has taken place—at least not until after the invasions occur.  Economists find that invasive wildlife species cause damages estimated in the tens of billions of damage each year.  This suggests a total mismatch between the costs from regulating entry of exotic pets and certain other species, which often are very low, versus the potential benefits.

All invasive plants and animals (not just the pets) contributed to an estimated 40% of endangered species listings.  Ironically, protection of these endangered species in the U.S., after they are listed, has imposed huge costs.  An ounce of prevention could have saved billions of dollars.

If someone wants to import a snake to sell in an exotic pet store, they first check a U.S. Fish and Wildlife Service (FWS) List of Injurious Wildlife.  Until this year, you could import any reptile in the world, except the brown tree snake.  After six years of hard work, FWS just finalized a rule that will add the Burmese python and certain other constrictors to their List of Injurious Wildlife.  The list of injurious birds identifies only six bird families, which include familiar names like “sparrow” and “starling.”  There are eight wildlife family types listed in the “Fish, Mollusks, and Crustaceans” category, but they include 4 carp varieties, as well as the zebra mussel and snakehead, wildlife families which already include major invasive species.  If we are looking for scary critters where the FWS List of Injurious Wildlife successfully protects us by prohibiting entry into the U.S., the list is very short.

Successful regulation under current rules will require considering the thousands of wildlife types that enter the U.S. and finding the small percentage whose “survival capabilities, ability to spread, impacts on habitats,”  threat to endangered species, and for whom our ability to control them imply a need for FWS to evaluate them for a possible injurious species rule writing.  This is not an insurmountable task, but the job of evaluating thousands of species and developing rules for those selected for regulation will require substantially more resources than FWS currently assigns.  It might also be necessary to expedite rule development, to avoid government costs of a process that now can take six years.  The process wisely considers economic costs and benefits of excluding a species from entry into the U.S.  So an evaluation strategy might begin with wildlife headed for certain exotic pet stores and other opportunities, where the costs of excluding a critter from entry into the U.S. often are very low.  Some strategies also call for major legislative changes to address invasive species.

Exotic pet stores represent a very modest portion of the U.S. economy, and these stores surely can substitute other exotic creatures for sell when FWS determines that certain species need inclusion in their List of Injurious Wildlife.  Costs of continued inaction could be immense.

Posted in Paying for Conservation0 Comments

Defenders offers recommendations for sage-grouse conservation

Defenders offers recommendations for sage-grouse conservation

Photo: C. Robert Smith Elk Meadow ImagesNational Geographic Stock

Defenders submitted comments today to the Bureau of Land Management and the Forest Service highlighting important issues as the agencies undertake to revise their land use plans to conserve and recover the greater sage-grouse. A few key points from our comments:

  • A scientific panel selected by the BLM outlined conservation measures that are an important starting point for this process in the 2011 ‘Report on National Greater Sage-Grouse Conservation Measures’These conservation measures should be put into practice to the fullest extent possible throughout the greater sage-grouse range.
  • The agencies indicate that they plan to use “adaptive management”. In order to do so effectively, we urge them to develop a scientifically legitimate adaptive management strategy that commits to reduce uncertainty and improve conservation through the use of ecologically grounded quantitative triggers rather than simply providing the agencies with flexibility and discretion that result in “trial and error” management.
  • BLM and the Forest Service should not assume that as long as “some” regulatory mechanisms are put in place, they will be adequate to avoid listing under the ESA.  There are other factors that will go into a decision whether to list the greater sage-grouse, and these two agencies represent only part of the picture.  Instead, they should approach this process understanding that listing could still occur, and use this analysis and planning to both try to avoid listing and to be better prepared if listing is unavoidable.
  • A targeted multispecies approach is more efficient than a narrow single-species approach; by looking at what other wildlife species can benefit from sagebrush ecosystem conservation, the agencies take advantage of the opportunity at hand, and gain additional benefits from work already being done.
  • The agencies should develop a mitigation framework and policies that achieve a measurable “net conservation benefit” standard.  It is necessary that any development within the sage-grouse range leave the bird better off than it was – holding steady at the status quo will not be enough to recover the species.
  • The Forest Service should play a key role.  They operate under wildlife protection regulations and policies that are unique from those that govern the BLM.  They must meet all of their existing statutory, regulatory and policy obligations in this conservation and decision making process.  In addition, the Forest Service must strive to embrace emerging conservation policy goals found in the new National Forest Management Act planning regulations.
  • We encourage BLM and FS to fully consider the risks caused by renewable energy development to sage-grouse and the sagebrush steppe ecosystem and to err on the side of caution in the development of new management standards and conservation measures.

You can read our full comments here.

Posted in Imperiled Wildlife, Public Lands0 Comments

Biofuel Certification Design Flaws

European leaders offer a biofuel certification program which appears to deny markets to biofuels that are produced unsustainably, but this program will not work.  Economic analysis finds that vegetable oil that fails certification for biodiesel use can simply be sold as food, without any reduction in price, to countries like China and India which are major importers of vegetable oil.  In addition, the damage to tropical forest and other ecosystems caused by biofuel demands are indirect, as biofuel expansion raises crop prices for vegetable oil, corn, and wheat.  These higher crop prices cause an estimated 25 million hectares net forest conversion to crop uses, or potentially several times that amount if we consider all forest, savanna, and prairie land conversions.  Biofuel certification programs in Europe and elsewhere fail to confront these indirect price effects, as well as failing to deny markets to uncertified biofuel.

Certifying all vegetable oil, not just the portion used as biofuel, would be far more effective at protecting tropical forests compared to the European Commission approach that just certifies the portion of vegetable oil used as biofuel.  However, any remedy that successfully protects forest and savanna ecosystems will cause additional crop price increases.  Crop producers in exporting countries could see profit increases estimated in the tens of billions of dollars due to the higher crop prices from any program that protects tropical forests and savannas.  The world’s poor, who depend on vegetable oil for calories would experience the majority of these costs.  Researchers find that crop price increases can pose sustainability problems affecting billions of poor people in developing countries.

China, India, and other poor countries spend immense amounts of money trying to protect their consumers from today’s high crop prices, so they are unlikely to participate in vegetable oil certification programs that raise vegetable oil and other basic food prices further.  Without the participation of these major importers of vegetable oil, and of other poor country importers, oil crop certification programs likely will remain ineffective.

Recognizing the above design flaws regarding certification remedies to ecosystem and to hunger problems caused by biofuel subsidies and mandates could lead to consideration of more effective policy options.  These options should include reducing biofuel subsidies and mandates in Europe and reducing biofuel mandates in the U.S.

Posted in Energy, Paying for Conservation0 Comments


dotWild is the blog of scientists and policy experts at Defenders of Wildlife, a national, nonprofit membership organization dedicated to the protection of all native animals and plants in their natural communities.

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