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 < [email protected] >. 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 >
Send a copy to the Pet Industry Joint Advisory Council, 1220 19th Street, NW, Washington, DC 20036 or [email protected]. For more information, call PIJAC at 202-452-1525.
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 < [email protected] >. 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 >
Send a copy to the Pet Industry Joint Advisory Council, 1220 19th Street, NW, Washington, DC 20036 or [email protected]. For more information, call PIJAC at 202-452-1525.
