This is the second part of two posts. Read the first one here.
A few weeks ago I received a 2,500+ word email from the person behind J.L. Hudson. Turns out his name is David Theodoropoulos, and most of his comments (and any number of other interesting things) are available on his website (there is also an anti-Theodoropoulos website, much less populated, available here - I love that Theodoropoulos links to his “anti” site from his own website…is it also a matter of how his ideas are taken by his peers that there are no comments on the “anti” site?). The highlights of the email are as follows:
NAPPRA is an end-run around “Option 1,” otherwise known as the “white list,” or universal screening. The white list concept has already been adopted in Australia and New Zealand, and seems to mean that all “exotic” (non-native) species would have to be pre-approved for importation through a variety of tests. Right now, importation is relatively unrestricted unless the plant you are trying to import is on a “black list.” Recently, the USDA leveraged additional restrictions requiring all imported seeds to be accompanied by a “phytosanitary certificate” – the best I can figure out is that this certificate shows the seeds are free of weeds. But NAPPRA and the white list are both moves that would shift the burden of proof on importation. NAPPRA creates a new category (“Not Approved Pending Pest Risk Assessment”) that would basically put a hold on some imports while their risk is assessed. It is not a white list. The white list was originally proposed by Bruce Babbit when he was the chair of the National Invasive Species Council. The major argument against the white list seems to be that it risks corporatizing species – the kinds of testing that would be required to get “clean listed” would be very expensive and only affordable by major corporations. One proposal that has been floated is, evidently, to give the patent rights for the form of life to the corporation that bankrolls its testing; additionally, it has been proposed that the tester gain immunity if the species in fact becomes invasive. Theodoropoulos argues that NAPPRA (which is not quite a white list, in that will “initially list taxa of plants for planting that, to our knowledge, have not yet been imported into the United States but present a potential risk”) is the “camel’s nose in the tent” of the white list – note the word “initially” there.
The USDA’s evidence is bad. Theodoropoulos says that the three pests cited as reasons for the NAPPRA would not be stopped by it (briefly, citrus longhorned beetle came on maple trees but maple trees were already present here; Asian longhorned beetles are on untreated wood products not covered by NAPPRA; and Ralstonia solanacearum race 3 biovar 2 was found on geraniums which were already present in the US).
Exotic species aren’t so bad. Here’s where it gets a little strange. I had always thought (maybe reflexively, although I’d certainly read a bunch about invasive species for debate preparation) that exotic species were bad. Like, really bad. There’s all kinds of information across the Internets about this. Evidently the USDA’s main source for the costs of invasive species is a 2000 paper by Pimentel, et al. (it can be downloaded here, as well as any number of similar papers). The best part of Theodoropoulos’ email is his critique of their cost estimate, which I quote here for all the cat lovers among us:
In order to justify NAPPRA, the USDA cites Pimentel et al. (2000) as their primary source for the costs to society of non-indigenous species. This paper has been shown to be pseudoscientific and an example of serious misrepresentation many of the “costs” are grossly over-inflated and have no actual economic basis whatsoever. For example, economic loss from cats is placed at $17 billion, fully 12% of the total, yet this figure is derived through completely speculative estimates of the number of birds killed by pet and feral cats, then valuing each bird at $30 through a contorted and unjustifiable logic involving birdwatchers, hunters, EPA fines, and the costs of rearing birds by ornithologists for release. This figure is a “value” essentially picked out of the air and entirely outside of actual economic costs – no actual money was spent or lost on account of cat predation on birds. The estimate also did not account for economic savings provided by the number of “pest” birds like starlings taken by cats, nor was any accounting made of the tremendous economic gains from rodent control (the original reason for the long association between cats and man), nor of the value of the cats based on dollars spent acquiring, feeding, and providing veterinary care for pet cats. No estimate of any differential in predation rates between cats and missing native predators was included. While cats are not plants, it is important to note this as an example of the poor quality of Pimentel et al.’s data and reasoning, as well as the professional misconduct that this represents. If the USDA is citing this sort of misinformation to justify NAPPRA, this demonstrates a level of scientific incompetence that should disqualify the Department from making any determinations under NAPPRA.
There is no doubt that some invasive species, like the much-maligned zebra mussel, are bad, right? Not so fast, says Theodoropoulos. He claims that zebra mussels have improved water quality and clarity in the Great Lakes, leading to improved fish populations and decreased eutrophication. When you add in the argument that there’s no such thing as an “exotic” species, things begin to seem a lot more complicated.
We can’t determine what species will be “invasive.” Theodoropoulos points out that we simply do not have good methods for risk assessment – we can’t even assess what species may become “invasive,” since “invasiveness” is by definition a relationship between any number of other plants, animals, etc. in an ecosystem. As an example, consider the humble asparagus fern (not a “fern” at all, as it turns out). It is widely used all over the US but considered to be highly invasive in Florida – presumably because of climate conditions. This casts some doubt on the reliability of the “risk assessment” part of NAPPRA, especially as it related to stopping invasive species.
When researching this post, I found the website for the Center for Invasive Species and Ecosystem Health – interesting for any number of reasons, but mostly because I

Vinca...seems harmless, right?
was able to find and name all of the horrible vines that continue to infest our yard despite repeated diggings and prunings and burnings. Without fail, the recommendations for getting rid of these things involve combinations of pesticides I’ve never heard of and don’t particularly want to purchase.
Take the vinca major on the right (it’s periwinkle to some). It’s commonly sold in nurseries, and would not be held by NAPPRA, or white listed, or anything, since it’s already here. In our climate it is highly invasive. In New Mexico it is happily contained, makes some nice flowers, and that’s about it. I hate that it strangles our tomatoes and won’t go away, but I’m not about to go buy a bunch of pesticides to pour on it. We eat stuff that comes out of that soil, after all.
After all this, I’m not sure I have an opinion on NAPPRA. It doesn’t seem especially well conceived, and I do know that the US has fairly stringent laws regarding control of noxious weeds that should solve much of the problem. I am very sympathetic to the work done by J.L. Hudson and others trying to preserve global biodiversity by encouraging propagation of rare and endangered species. In particular, I am appalled at the idea of patenting those species, especially as a payoff for dubious-at-best risk assessment. I wish there was more of a moral to this story – especially for those of you who have struggled through to the end of this long post. Myself, I’m taking away the idea that even issues that seem obvious (“exotic species are bad”) are more complicated than they seem, and that their solutions may create other problems. Also I’m thinking about what I’m going to plant in the spring.