CENTER FOR INVASIVE SPECIES PREVENTION 

In the course of our advocacy work, the Center for Invasive Species Prevention sometimes takes stands in the form of letters to Congressional committees or the Administration, briefs in court cases, or other documents.  Unfortunately, our website does not allow us to post these directly.  Instead, we list here a brief description of each document and ask that you contact us, using the button on the "Contact Us" page, to request a copy of the document in which you are  interested.


1) CISP testimony to Congress supporting funding for APHIS and USFS programs for several Fiscal Years. Usually this testimony was submitted in collaboration with others in one of two coalitions - the Coalition Against Forest Pests or the Sustainable Urban Forest Coalition.


2) Then CISP President Peter Jenkins filed a Friend of the Court (Amicus) brief in the DC Circuit Court of Appeals on behalf of CISP, the Natural Areas Association and The Wildlife Society, in a case argued on April 1, 2016. USARK et al. v. Sally Jewell et al. ​This case is vital to maintaining the strength of the already-too-weak injurious species provision of Lacey Act (18 USC sec. 42). If the appellee, US Association of Reptile Keepers, wins their legal challenge, then interstate commerce regulation of all injurious species, e.g., Asian carps and zebra mussels, will be largely thrown out, affecting all past and future listings unless Congress amends the statute.  The Amicus brief supported the Department of the Interior position that the Federal power to regulate interstate commerce is crucial and has long been recognized. 


3) Testimony presented by then Vice President Faith Campbell before the Senate Committee on Energy and Natural Resources, Subcommittee on Public Lands, Forests and Mining on 28 April, 2016. The hearing was on management of invasive species on federal lands.


4) Article co-authored by CISP Vice President Faith Campbell (& 15 others!) on introduced forest pests' severe impacts and policy changes that could minimize the risk -- article available at  www.caryinstitute.org/tree-smart trade or from Faith Campbell (see contact information above).


5) The Amended CISP Petition filed with the Secretary of the Interior on December 8, 2016, entitled, ​ Petition: To Amend 50 CFR §16.13 to List 42 High Risk Fish, Crayfish, and Mollusk Species as Injurious Species under the Lacey Act. This is a multi-species listing petition that is based on Ecological Risk Screening Summaries prepared by the Fish and Wildlife Service for each of the 42 species, in which a finding of "high risk" was made.  CISP urges the Service to publish this listing proposal in the Federal Register for public comment and then to grant the Petition, that is, to formally declare the species as injurious.  Then they will be prohibited from international importation. 


6) The Center for Invasive Species Prevention has joined 8 other members of the National Environmental Coalition on Invasive Species in sending letters to Senator Kirsten Gillibrand (D-NY) and Representative Elise Stefanik (R-NY-21) to thank them for introducing legislation to strengthen the Lacey Act (described under the "Invasives 101" tab on our website).

The “Invasive Fish and Wildlife Prevention Act” (S. 3210 and H.R. 6362) would dramatically improve the ability to make rapid, science-based decisions on whether a non-native wildlife species should be considered harmful to human, economic, or environmental health under the Lacey Act. The bills would provide the U.S. Fish and Wildlife Service with the regulatory certainty needed to prevent the introduction of new invaders, including wildlife diseases. The bills also correct an error in the current law which courts have found does not allow USFWS to regulate transport of listed species among the contiguous 48 States and Alaska. Instead, the bills would authorize USFWS to regulate transport of federally listed injurious species across state lines.

In addition, S. 3210 and H.R. 6362 would provide a streamlined process for reviewing the designation of injurious species under the Lacey Act. The bills provide a clearly defined process and timeline for listing and delisting as well as the solicitation of input from states, Native American tribes, and the public.

To obtain a copy of the letter, contact Faith Campbell using the “contact” button on our website.


7) The Center for Invasive Species Prevention has submitted comments to the USDA Animal and Plant Health Inspection Service (APHIS) objecting to its proposal to stop regulating movement of wood, nursery stock, and other items that can transport the emerald ash borer (the borer is described here). APHIS' responsibilities are described under the "Invasives 101" tab.


To obtain a copy of the comments, contact Faith Campbell using the "contact" button on our website.