A Prevention ProgramA Prevention Program for the Mediterranean Strain of Caulerpa taxifolia Submitted to the Aquatic Nuisance Species Task Force By Sandra M. Keppner U.S. Fish and Wildlife Service Lower Great Lakes Fishery Resources Office 405 North French Road Amherst, NY 14228 and Russell T. Caplen Animal and Plant Health Inspection Service 4700 River Road, Unit 119 Riverdale, MD 20737 August 3, 1999 Executive Summary In October 1998, the Department of Interior (DoI) was alerted to the possibility that an aquarium-bred clone of the tropical green seaweed Caulerpa taxifolia could become established in U.S. coastal waters. Over 100 research scientists requested that the Secretary of Interior (Secretary) initiate immediate action to prevent the Mediterranean strain of C. taxifolia from entering and becoming established U.S. waters. In response the U.S. Fish and Wildlife Service (Service) lead an investigation and submitted its findings to the Aquatic Nuisance Species (ANS) Task Force in November 1998. Since its discovery off the coast of Monaco in the Mediterranean in 1984, C. taxifolia has spread rapidly severely impacting the coastal ecosystems of five Mediterranean countries (Croatia, France, Italy, Monaco, and Spain). It is believed to have been introduced into the Mediterranean as an aquarium release or escape. The introduced C. taxifolia is believed to be a genetic clone of a single plant, exhibiting characteristics and tolerances different from its parent plant. For example, the Mediterranean strain demonstrates a different reproductive strategy, forms dense mats rather than growing in small isolated clumps, reaches much greater heights in terms of growth, and tolerates a wider range of temperatures, surviving between the isotherms of 10-31ºC. Based on these thermal tolerances, its potential distribution in the U.S. is predicted to include coastal areas south of Virginia Beach, Virginia on the Atlantic coast, areas south of Stonewall Bank, Oregon on the Pacific coast, the Gulf of Mexico, Hawaii, Puerto Rico, the U.S. Virgin Islands, American Somoa, Guam, and the Northern Mariana Islands. The potential expansion of C. taxifolia throughout these waters threatens native flora and fauna, especially threatened and endangered species and poses potential economic impacts on revenues generated by commercial and recreational fisheries, tourism, and industrial facilities. In November 1998, the ANS Task Force determined that the risk of an unintentional introduction of C. taxifolia (Mediterranean strain) through identified pathways was significant and the adverse consequences of an introduction would likely be substantial. According to provisions of the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990, these findings warrant the development and implementation of a cooperative comprehensive prevention program to minimize the risk of introduction. The ANS Task Force requested that the Service and the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) jointly develop a comprehensive program to prevent the introduction and establishment of C. taxifolia in U.S. waters. These agencies subsequently drafted A Prevention Program for the Mediterranean Strain of Caulerpa taxifolia (Prevention Program). Development was guided by existing legislative authorities including the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 and the Federal Noxious Weed Act of 1974 and the Aquatic Nuisance Species Program developed by the ANS Task Force. Additional federal authorities are available to develop and enhance prevention activities for C. taxifolia including the Lacy Act, Executive Order 13089: Coral Reef Protection, and Executive Order 13112: Invasive Species. Successful implementation of objectives and actions presented within this Prevention Program are highly dependent on establishing and maintaining effective partnerships among international, federal, state, tribal, private and public organizations. In addition, existing information gaps demand the attention of scientific research to refine and update the Prevention Program to further minimize the risk of introduction, establishment, and spread of the Mediterranean strain of C. taxifolia in U.S. waters. Nine objectives and subsequent recommendations are identified in this draft Prevention Program Funding needs and visibility are higher for some of the objectives, however, this is not an indication of importance or priority. To minimize the risks of introduction, establishment, and spread of C. taxifolia, all of the objectives should be pursued and implemented as appropriate. The goal of the Prevention Program and nine objectives proposed are as follows: Goal Statement: Prevent the introduction, establishment, and dispersal of the invasive Mediterranean strain of Caulerpa taxifolia in U.S. waters. Objective I Coordination and Leadership Objective II Dispersal Mechanisms and Pathways Analysis Objective III Surveillance and Detection Objective IV Control Objective V Research Objective VI Regulatory Objective VII Legislation Objective VIII Education Objective IX International Activities Each of the recommended actions associated with the nine objectives require further prioritization. Comments received from the ANS Task Force and the public will be incorporated to establish preliminary prioritization of the recommended actions. These considerations will be presented in the final document. A Prevention Program for the Mediterranean Strain of Caulerpa taxifolia INTRODUCTION In October 1998, the Department of Interior (DoI) was alerted to the possibility that an aquarium-bred clone of the tropical green seaweed Caulerpa taxifolia could become established in U.S. coastal waters. Over 100 research scientists requested that the Secretary of Interior (Secretary) initiate immediate action to prevent this strain of C. taxifolia from entering and becoming established U.S. waters. This species has severely impacted the coastal ecosystems of five Mediterranean countries (Croatia, France, Italy, Monaco, and Spain). It spreads rapidly, forms dense mats, and eliminates biodiversity in coastal ecosystems. The Secretary assigned leadership to the U.S. Fish and Wildlife Service (Service) and requested an investigation of C. taxifolia and its potential for establishment in U.S. waters. In November 1998, the Service presented the findings of its investigation to the Aquatic Nuisance Species (ANS) Task Force. The report, Caulerpa taxifolia: A Potential Threat to U.S. Coastal Waters provided an overview of important biological and ecological characteristics of the species, pathways or mechanisms of dispersal, ecological and economic impacts, potential range in the U.S., and several control alternatives that have been initiated in Europe. The ANS Task Force is an intergovernmental body established by the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 and provided an appropriate forum for further discussion regarding C. taxifolia and its potential impact on U.S. coastal ecosystems. Based on the report findings, the ANS Task Force determined that the risk of an unintentional introduction of C. taxifolia (Mediterranean strain) through identified pathways was significant and the adverse consequences of an introduction would likely be substantial. According to provisions of the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990, these findings warrant the development and implementation of a cooperative comprehensive prevention program to minimize the risk of introduction. The ANS Task Force requested that the Service and the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) jointly develop a comprehensive program to prevent the introduction and establishment of C. taxifolia in U.S. waters. These agencies subsequently drafted A Prevention Program for the Mediterranean Strain of Caulerpa taxifolia (Prevention Program). Implementation of the Prevention Program will however require the support and participation of many agencies and organizations. Lead agencies will be required to strengthen their working relationships with existing partners and work to establish new relationships with public and private sector entities potentially affected by the introduction of C. taxifolia or the execution of prevention activities. The cooperative Prevention Program presented in this document is intended to be dynamic and will likely require periodic updating. Research is a critical requirement to further developing and enhancing prevention strategies for C. taxifolia. Additional research addressing current information gaps will provide the necessary information to further reduce the risk of introduction, spread, and establishment of C. taxifolia in U.S. waters. BACKGROUND The green alga C. taxifolia was first detected in the Mediterranean Sea in 1984. This tropical species is believed to have been introduced into the Mediterranean as an aquarium release or escape. It is genetically identical to strains cultured and propagated in western European aquaria since the early 1970’s. The introduced C. taxifolia is believed to be a genetic clone of a single plant, exhibiting characteristics and tolerances different from its parent plant. For example, the Mediterranean strain demonstrates a different reproductive strategy, forms dense mats rather than growing in small isolated clumps, reaches much greater heights in terms of growth, and tolerates a wider range of temperatures, surviving between the isotherms of 10-31ºC. Since its discovery, it has become widespread across the northern and western coasts of the Mediterranean and in Adriatic coastal regions, crossing the borders of five countries. Like many successful invasion species, the Mediterranean strain of C. taxifolia spreads rapidly, possessing life history features enhancing its ability to spread and take over coastal areas. Perhaps contributing most significantly to its ability to proliferate, the Mediterranean strain of C. taxifolia exhibits vegetative or asexual reproduction. Small cuttings or plants fragments are capable of regenerating whole new plants. In addition, the Mediterranean strain is apparently able to adapt to a wide range of habitat conditions including substrate, light intensity, and water quality. C. taxifolia synthesizes toxic or repellent secondary metabolites as defense strategy against herbivory and epiphytism. These toxins affect local flora and fauna through both direct contact and indirect contact as the toxins are apparently released into the water causing chemical interactions with some species. The invasion of C. taxifolia has altered both the flora and fauna endemic to the coastal waters of the Mediterranean, reducing biodiversity. Competition and habitat modification are the two primary mechanisms used by C. taxifolia to influence and often exclude local populations. Through competitive interactions (light and space), indigenous flora are reduced or eliminated leading to monocultural stands of C. taxifolia. In addition, the production and release of toxins provides an effective competitive advantage to C. taxifolia. The dense mats formed by C. taxifolia change the bottom structure of the seafloor affecting benthic fauna. Changes in the benthic fauna as well as habitat modifications (e.g. loss of important spawning or nursery areas) are likely contributing to observed changes in ichthyofauna. The potential introduction and establishment of C. taxifolia in U.S. coastal systems is expected to cause similar impacts. Based on thermal tolerances of C. taxifolia, its potential distribution in the U.S. is predicted to include coastal areas south of Virginia Beach, Virginia on the Atlantic coast, areas south of Stonewall Bank, Oregon on the Pacific coast, the Gulf of Mexico, Hawaii, Puerto Rico, the U.S. Virgin Islands, American Samoa, Guam, and the Northern Mariana Islands. In the absence of natural control mechanisms, invasive species typically expand rapidly, often exponentially. This expansion will threaten native flora and fauna, especially threatened and endangered species. Also, economic impacts including revenues generated by commercial and recreational fisheries, tourism, and industrial facilities, will likely be evident. GOAL STATEMENT Prevent the introduction, establishment, and dispersal of the invasive Mediterranean strain of Caulerpa taxifolia in U.S. waters. EXISTING AUTHORITIES AND EXECUTIVE ORDERS Nonindigenous Aquatic Nuisance Prevention and Control Act Enacted in 1990, and reauthorized in 1996 as the National Invasive Species Act, this statute established an intergovernmental mechanism for the development of a national program to: 1) prevent the unintentional introduction and dispersal of nonindigenous species through ballast water management and other requirements; 2) coordinate federally conducted, funded, or authorized research, prevention control, information dissemination and other activities regarding aquatic nuisance species, 3) develop and carry out environmentally sound control methods to prevent, monitor, and control unintentional introductions of nonindigenous species from pathways other than ballast water, 4) understand and minimize economic and ecological impacts of nonindigenous aquatic nuisance species that become established, and 5) to establish a program of research and technology development and assistance to states in the management and removal of zebra mussels. The Act established the ANS Task Force, chaired by the Service and the National Oceanic and Atmospheric Administration (NOAA), to coordinate federal efforts and develop the national Aquatic Nuisance Species Program to prevent the introduction and dispersal of aquatic nuisance species, monitor, control, and research such species, and disseminate related information. The Act directs the ANS Task Force to establish and implement measures within the Aquatic Nuisance Species Program to minimize the risk of introducing aquatic nuisance species into U.S. waters including the identification of pathways by which aquatic organisms are introduced, assessing the risk that an organism may become an aquatic nuisance species, and evaluating prevention strategies. If the ANS Task Force determines that there is a significant risk of an unintentional introduction of an aquatic nuisance species by an identified pathway and that adverse consequences of such an introduction are likely to be substantial, the ANS Task Force shall, acting through the appropriate federal agency, and after opportunity for public comment, carry out cooperative, environmentally sound efforts with regional, state, and local entities to minimize the risk of such an introduction. The Act authorizes the appropriation of funds for each of the fiscal years 1997-2002 to develop and implement the provisions outlined in the Aquatic Nuisance Species Program. The Act authorizes funds to the DoI, the Department of Commerce, the National Sea Grant College Program, and the Cooperative Fisheries and Wildlife Research Unit Program of the Service. Federal Noxious Weed Act The Federal Noxious Weed Act of 1974 (P.L. 93-629, 7 U.S.C. 2801-2814) authorizes port-of-entry and follow-up activities (quarantine, treatment, disposal, control or eradication programs, etc.) by USDA to restrict the introduction and spread of non-native noxious weeds. Under the Act, no person shall import or enter any noxious weed identified in regulation, into or through the United States, or move any noxious weed interstate, unless done in accordance with regulations issued by the Secretary. The Act also authorizes permanent restrictions, after a hearing on the issue, and emergency regulations for temporary quarantines. Lacy Act Originally enacted in 1900, the Lacey Act, as amended in 1981 (P.L. 97-79. 16 U.S.C. 3371-3378) makes it illegal to import, export, sell, receive, acquire, or purchase fish, wildlife, or plants taken, possessed, transported, or sold in violation of U.S. or tribal law. In addition, this Act makes it unlawful to engage in interstate or foreign commerce involving any fish, wildlife, or plant material taken, possessed, transported or sold in violation of state or foreign law. Specific provisions authorize the federal government to prescribe requirements and issue permits for importation of wild animals and birds under humane and healthful conditions. This law may be applicable for regulating the introduction of non-native species, if only indirectly. For example, if a plant whose sale is illegal in one state is purchased in that state and then taken to another state, the purchaser/transporter may have violated the Act, since the federal Lacy Act can be triggered by violations of certain state laws combined with interstate transport. However, if the non-native plant is purchased in a state where its sale is allowed, and then simply brought into another state (e.g., as household effects), it is unclear whether the Lacey Act would apply. Executive Order 13089 - Coral Reef Protection President Clinton signed Executive Order 13089 on Coral Reef Protection (63 Fed. Reg. 32701, June 16, 1998), on June 11, 1998. This Executive Order seeks to protect coral reef ecosystems in Florida, Hawaii, American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands through enhanced coordination of federal activities that impact coral reefs. This would include federal initiatives regarding Aquatic Nuisance Species in marine environments. Executive Order 13112 - Invasive Species President Clinton signed Executive Order 13112 on Invasive Species (64 Fed. Reg. 6183, Feb. 8, 1999), on February 3, 1999, revoking President Carter’s 1977 Executive Order 11987 on exotic species. The new Executive Order seeks to prevent the introduction of invasive species and provide for their control and minimize their impacts through better coordination of federal agency efforts under a National Invasive Species Management Plan to be developed by an interagency Invasive Species Council. The order directs all federal agencies to address invasive species concerns as well as refrain from actions likely to increase invasive species problems. The Invasive Species Council, supported by an advisory committee, is also to develop recommendations for international cooperation, promote a network to document and monitor invasive species impacts, and encourage development of an information-sharing system on invasive species. Broad interpretation of the following statutes could also be applicable to C. taxifolia regulation and prevention activities. These Acts were generally designed to address specific issues other than invasive species. However, provisions within the legislation may be applicable and should be implemented if appropriate. Alien Species Prevention and Enforcement Act of 1992 Atlantic Coastal Fisheries Cooperative Management Act Coastal Zone Management Act of 1972 Endangered Species Act of 1973 Fish and Wildlife Conservation Act Fish and Wildlife Improvement Act of 1978 Florida Keys National Marine Sanctuary and Protection Act Interjurisdictional Fisheries Act of 1986 Marine Mammal Protection Act of 1972 Marine Protection, Research, and Sanctuaries Act: Part I - Marine Sanctuaries Marine Resources and Engineering Development Act of 1966 National Coastal Monitoring Program National Environmental Education Act National Environmental Policy Act of 1969 Plant Pest Act of 1912 Plant Quarantine Act Regional Marine Research Program OBJECTIVES AND ACTIONS Successful implementation of the objectives and actions presented within this Prevention Program is highly dependent on establishing and maintaining effective partnerships among international, federal, state, tribal, private and public organizations. In addition, existing information gaps demand the attention of scientific research to refine this Prevention Program and further minimize the risk of introduction, establishment, and spread of C. taxifolia in U.S. waters. The objectives and recommended actions identified below are not listed in any order of priority. Funding needs and visibility are higher for some of the objectives, however, this is not an indication of importance. To minimize the risks of introduction, establishment, and spread of C. taxifolia, all of the objectives should be pursued and implemented as appropriate. Objective I -- Coordination and Leadership Implementation of an effective prevention program requires centralized coordination and leadership along with the support and participation of many federal agencies and organizations. Lead agencies will be required to strengthen their working relationships with existing partners and establish new relationships with public and private sector entities that could be impacted by the introduction and/or establishment of C. taxifolia in U.S. waters. These working relationships would form a strong foundation for the collaborative formulation of cost effective and environmentally sound regulatory policies. Recommended Actions 1. Establish a Caulerpa taxifolia Prevention Committee of the ANS Task Force to lead and coordinate implementation of the Prevention Program and refine ongoing prevention activities and the Prevention Program as new scientific information becomes available. a. Maintain committee membership at a reasonable level to ensure appropriate representation and decision-making capabilities. b. Assign committee chair or lead to appropriate federal agency based on ANS Task Force recommendation. 2. Establish Work Groups within the Caulerpa taxifolia Prevention Committee to address specific issues, objectives, or actions of the Prevention Program to ensure effective and efficient execution of prevention activities. a. Maintain Work Group membership at a reasonable level to accomplish the identified charge(s) or action(s). b. Open membership to non-member agencies of the Caulerpa taxifolia Prevention Committee to ensure appropriate expertise is incorporated into prevention activities. c. Assign Work Group leadership or chair to appropriate federal agency based on the recommendation of the Caulerpa taxifolia Prevention Committee. Objective II -- Dispersal Mechanisms and Pathways Analysis Development of effective prevention strategies for nonindigenous aquatic species like C. taxifolia requires a thorough understanding of potential pathways and means of dispersal that could introduce and spread an invasive aquatic species. The most direct and effective prevention strategy is to identify and eliminate known and potential dispersal pathways. Although some dispersal mechanisms are natural and therefore difficult to interrupt, many if not most are related to anthropogenic activities including international, national, regional, and local activities. All of these could potentially facilitate the introduction and spread of C. taxifolia into U.S. waters. C. taxifolia reproduces vegetatively therefore the disruption and subsequent transport of small plant fragments by any means may result in the establishment of a new population. Activities such as dredging, mechanical removal or control, anchoring, commercial fishing, boating, ocean currents, and storms have all contributed to the expansion of C. taxifolia in the Mediterranean. Additional pathways, although less direct in terms of disruption and transport, may pose higher risks to waters outside the Mediterranean. C. taxifolia is commonly used in the aquarium industry for display purposes. The importation of this species and its eventual release or escape could pose a risk to U.S. waters. Other potential pathways for C. taxifolia introduction into U.S. waters include use as packing material for imported shipments of fresh seafood, bait imports, and ballast water from transoceanic vessels. Each of these pathways pose a potential threat to U.S. coastal systems if C. taxifolia plant fragments survive shipment and are released into U.S. waters. A combination of research and risk analysis is required to determine the pathways that most significantly threaten U.S. waters including introduction and subsequent spread. Priority should be given to these objectives since the refinement of prevention strategies hinges on a sound understanding of pathways of introduction and spread. Recommended Actions 1. Conduct a formal pathways analysis and risk assessment to determine the risk of introduction and/or spread posed by individual dispersal mechanisms. a. Apply the "Generic Nonindigenous Aquatic Organisms Risk Analysis Review Process" or another appropriate and ANS Task Force approved model to determine the risk of introduction and/or spread via specific pathways. 2. Examine geographic and temporal patterns of dispersal mechanisms, including the importation of aquarium plants, fresh seafood (packing material), and bait. a. Identify and investigate foreign source populations, domestic entry locations, interstate transport mechanisms, and final destinations of imported shipments. b. Investigate current and routine disposal practices for algal packing materials, water, and any other materials contained in shipments. c. Estimate the amount of potential host materials imported into the U.S. annually and the likelihood that those materials may include C. taxifolia. d. Apply this information to the risk assessment process. 3. Identify and investigate other possible mechanisms of entry into the U.S. through delivery and mail order services (e.g. Postal Service, United Parcel Service, FedEx, etc.). a. Identify Internet mail order and sales companies. b. Develop inspection and enforcement programs to minimize the risks associated with these entry mechanisms, if appropriate. c. Monitor the use of these mechanisms at regular intervals to determine if associated risks change. d. Apply this information to the risk assessment process. 4. Estimate the risks of introduction associated with ballast water transfer. a. Examine shipping patterns and routes, ballast exchange practices, and ballast loading and discharge for all vessels departing from invaded areas. b. Conduct similar examination for domestic shipping vessels to determine the risk of spread within U.S. waters. Include all domestic ports of call in assessment as ships may load cargo and discharge ballast at more than one location or take on ballast from more than one location. c. Apply this information to the risk assessment process. 5. Examine movement patterns of commercial and recreational fishing and tourism vessels in the U.S. and in areas already invaded by C. taxifolia. a. Assess the risk of spread from the Mediterranean to other foreign waters posed by such movements and the subsequent risks of dispersal to U.S. waters from those areas. b. Estimate spread potential through these mechanisms within U.S. waters if C. taxifolia was introduced. c. Apply this information to the risk assessment process. Objective III -- Surveillance and Detection Detection and surveillance are critical components of prevention and control strategies. Management and policy decisions are often based on the information gathered through effective surveillance programs. The implementation of surveillance provides managers with an opportunity to: 1) detect newly established populations early, 2) track the expansion or spread of introduced species, 3) predict potential impacts of introductions or range expansions by gathering baseline data on pre-existing populations and habitat, and 4) evaluate prevention and control strategies. Like most invasive species, the likelihood of successful control and eradication of C. taxifolia if introduced into U.S. waters is highly dependent on early detection. The various dispersal mechanisms used by C. taxifolia require a multi-faceted approach to detection and surveillance accounting for introductions through importation, shipping, etc. This approach requires the cooperation of federal, state, tribal and public and private organizations. Law enforcement and inspection agencies as well as marine biologists and researchers will play significant roles in surveillance and detection activities. The information gained through a cooperative comprehensive approach to detection and surveillance will contribute to refining this Prevention Program and future decisions regarding the risks of introduction and spread, potential impacts to native fauna, and the need to continue prevention activities. Recommended Actions 1. Develop effective and efficient field surveillance protocols to detect newly established populations and potential range expansions. a. Incorporate protocols into the Immediate Response Plan (Objective IV, Action 4) to determine the extent of infestation and advance control and spread prevention decisions. b. Develop specific protocols for critical habitat areas of endangered and threatened species, marine sanctuaries, and estuarine reserves to minimize disruption of these areas. 2. Conduct field surveillance at locations where C. taxifolia is likely to be introduced and become established based on dispersal mechanisms. a. Incorporate scientific recommendations from pathways analyses and risk assessments as they become available to refine and prioritize sampling efforts. b. Target identified critical habitat areas of endangered and threatened species, marine sanctuaries, and estuarine reserves to ensure early detection. c. Identify researchers and agencies already participating in surveillance or monitoring efforts to advance partnership and cooperation. d. Designate appropriate federal agency to coordinate surveillance reports of participants and act as a central clearinghouse for surveillance information. Report confirmed sitings to the U.S. Geological Survey in Gainesville, Florida. 3. Employ Geographic Information System (GIS) technology to refine the potential range of C. taxifolia in U.S. waters and prioritize surveillance efforts. a. Identify existing data sources including physical, chemical, and biological habitat parameters of U.S. coastal systems. b. Incorporate habitat and population/community data collected through surveillance efforts to refine range predictions. c. Target identified critical habitat areas of endangered and threatened species, marine sanctuaries, and estuarine reserves to predict potential vulnerability to C. taxifolia invasion. 4. Develop and implement sound inspection protocols to effectively monitor imported commodities and detect the presence of C. taxifolia. a. Employ inspection protocols at foreign ports of origin in areas already invaded by C. taxifolia through cooperative efforts with foreign government officials. b. Employ inspection protocols at all domestic ports of entry to monitor compliance with federal regulations regarding the importation of C. taxifolia. 5. Develop and implement sound inspection protocols to detect C. taxifolia in imported shipments that arrive in the U.S. through alternative mailing, shipping, and delivery services. Objective IV -- Control Like most invasive species, if C. taxifolia becomes established and widespread, control or complete eradication may not be possible. In the absence of natural predators, invasive species populations expand rapidly, often exponentially. However, if detected early, there may be a brief window of opportunity to control and possibly eradicate small isolated populations. Successful eradication is therefore dependent on several factors, first early detection and second, control readiness. It is imperative to develop effective surveillance and detection protocols as well as control alternatives that can be implemented quickly and efficiently. Generally, three types of alternatives are considered when developing control strategies, physical, chemical, and biological. To date, attempts to control C. taxifolia in the Mediterranean have not been successful. Although prevention is the optimum control alternative available, it is essential to prepare for potential infestations. Research initiatives focusing on short-term eradication and control are a priority to eliminate founder populations. Recommended Actions 1. Apply Integrated Pest Management principles to develop and implement C. taxifolia control strategies. The development of various control strategies will allow for flexibility and enhance the likelihood of execution if a founder population is detected. 2. Investigate control alternatives used in the Mediterranean. a. Evaluate, when possible, if application errors accounted for the lack of success. b. Determine whether any of these alternatives should be further investigated. 3. Identify and investigate additional control alternatives, including physical, chemical, and biological options that can be conducted in a cost effective manner while minimizing the risk of environmental harm and protecting human health and welfare. a. Federally funded, authorized, or approved research projects must follow accepted and ANS Task Force approved research protocols for aquatic nuisance species. b. Investigate short-term control alternatives as well as long-term control alternatives. Share long-term control alternatives with international partners to reduce populations at important ports of origin and throughout the Mediterranean. 4. Develop an Immediate Response Plan outlining effective and efficient control alternatives to be implemented in the event that C. taxifolia is detected in U.S. waters. Employ short-term control alternatives to maximize effectiveness and efficiency. 5. Develop site specific control alternatives for areas identified as critical habitat areas for endangered and threatened species, marine sanctuaries, and estuarine reserves to minimize the risk of harm to those environments, protect public health and welfare, and ensure cost effectiveness. 6. Conduct an economic assessment analyzing the cost of control and prevention strategies relative to the potential cost of introduction and establishment of C. taxifolia. Incorporate various scenarios or levels of control and prevention implementation from no action to full implementation of prevention and control alternatives. Objective V -- Research The prevention objectives and actions recommended in this document are based on the current state of knowledge. Current information gaps limit the scope and potential effectiveness of this Prevention Program. Additional knowledge gained through research is critical to the successful prevention of C. taxifolia infestations in U.S. waters. The refinement, update, and execution of this Prevention Program should reflect the information gained through future research efforts. Research initiatives that advance the implementation of this Prevention Program are a priority. The identification of critical information needs and gaps will assist funding agencies in justifying and prioritizing proposed initiatives. The actions recommended below reflect several research needs identified by the authors in drafting this Prevention Program. This list should not be considered complete. Recommended Actions 1. Identify and communicate with researchers from universities, government agencies, and public and private organizations in areas where C. taxifolia has already become established. 2. Identify researchers from universities, government agencies, and public and private organizations in the U.S. with expertise in marine biology, algology or invasion biology. a. Provide researchers with information regarding the urgency and importance of C. taxifolia research initiatives, potential funding sources, and identified information gaps. 3. Conduct a thorough literature search to identify work already completed. a. Translate information not currently available in English. b. Review literature available and evaluate for scientific merit, including experimental design, analysis, interpretation, and conclusions. 4. Coordinate workshop(s) to further refine information needs and gaps to determine research priorities. a. Identify potential funding sources. 5. Ensure that all federally funded, authorized, or approved research projects follow accepted and ANS Task Force approved research protocols for aquatic nuisance species. 6. Investigate environmental tolerances of C. taxifolia to determine distribution or range expansion limitations. a. Investigate salinity tolerance to determine potential expansion in bays, tidal areas and estuaries. b. Apply this information to GIS database as an overlay to known habitat parameters in U.S. coastal systems. 7. Assess potential viability of C. taxifolia plant fragments in ballast water tanks, imported commodities, and attached to fishing and boating equipment and anchors. Consider all dispersal mechanisms. Determine threshold parameters for survival, if appropriate (e.g. time, temperature, relative humidity, etc.). 8. Conduct thorough ecological impact analysis, identifying critical habitat areas for endangered and threatened species, marine sanctuaries, estuarine reserves, or coral reefs that may be impacted by the introduction and establishment of C. taxifolia. a. Identify endemic seagrasses that could be reduced or eliminated as a result of the introduction of C. taxifolia. Investigate the importance of these seagrasses to native species, especially endangered or threatened species such as the manatee. Consider direct and indirect effects of potential changes. b. Apply GIS technology to estimate changes in benthic communities. Apply tracking information for endangered or threatened species such as the manatee to estimate potential changes in distribution and habitat use, or further declines in population abundances. Conduct similar investigations for economically or ecologically significant species whose habitats are expected to overlap. Consider direct and indirect effects. c. Investigate the direct and indirect impacts associated with the production and release of the toxin, caulerpenyne on native species. Identify threatened or endangered species restoration efforts that may be hindered by direct or indirect affects of the toxin. 9. Investigate physiological stresses potentially applicable to control alternatives. 10. Identify potential natural control mechanisms already present in U.S. coastal waters. 11. Conduct genetic analyses to substantiate identification as C. taxifolia. Determine if the strain should be considered a separate species. a. Investigate the development of control alternatives using genetics. Objective VI -- Regulatory In an amendment to the Federal Noxious Weed Act of 1974, regulations restricting and requiring permits for the importation of the Mediterranean clone of C. taxifolia were promulgated in March 1999. However, resource constraints have prevented consistent implementation of the regulations at various ports. In addition, distinguishing the invasive Mediterranean strain from non-invasive strains already present within U.S. waters has been problematic. Preventing the introduction of C. taxifolia in commercial imports requires the cooperation of federal and state inspection and enforcement agencies. Federal agencies likely to contribute to C. taxifolia prevention through enforcement responsibilities include the Food and Drug Administration (FDA), NOAA, the Service, U.S. Customs Service, and APHIS. Education initiatives, cooperation, and consistent enforcement are critical to successfully preventing C. taxifolia introductions through commercial imports. Recommended Actions 1. Develop cooperative multi-agency inspection program to effectively and efficiently monitor imported commodities for the presence of C. taxifolia and enhance the likelihood of detection. a. Incorporate all appropriate federal, state and tribal enforcement agencies responsible for inspecting commodities entering the U.S. Consider all dispersal and transport mechanisms as well as all entry routes. b. Develop inspection protocols that are pathway specific to focus efforts and resources at potential high risk entry sites. c. Identify current limitations to individual enforcement agencies. Work cooperatively to overcome limitations. Encourage cross-programmatic training. d. Establish enforcement agent network to efficiently report and verify the detection of C. taxifolia and confiscate products containing C. taxifolia. 2. Develop holding, treatment, and disposal protocols for enforcement agents to employ in the event C taxifolia is detected. 3. Develop package labeling requirements so that all contents are reported, including packing materials. Identification of materials should be specific so that enforcement agents can readily examine package labels and packaged goods. a. Develop requirements in cooperation and consultation with foreign and domestic export and import industry representatives. 4. Develop enforcement agency programs to monitor or evaluate industry compliance with permitting and labeling requirements and regulations. a. Submit annual compliance reports to a designated lead agency. b. Ensure that accepted and ANS Task Force approved research protocols for aquatic nuisance species are followed. 5. Develop partnerships and cooperative agreements with foreign governments to inspect and regulate the use of C. taxifolia in commercial shipments exported to the U.S. Objective VII -- Legislation Existing legislative authorities available to resource and enforcement agencies to prevent the introduction and spread of C. taxifolia are limited in scope. The Federal Noxious Weed Act is the only current existing authority that regulates the movement of C. taxifolia into the U.S. Although there are provisions regarding interstate transport, there are no restrictions on intrastate movement. Preventing the introduction and spread of C. taxifolia in the U.S. requires consistent and complete federal and state legislative authorities imposing strict and severe penalties for noncompliance. Recommended Actions 1. Conduct a thorough review and analysis of existing legislative authorities identifying additional authorities that may be applicable to prevention actions. a. Determine potential application of existing authorities to implementing this Prevention Program. b. Determine potential application of existing authorities to enhancing the regulation of C. taxifolia. 2. Review ongoing and proposed legislative initiatives including amendments to existing legislation. Assess potential applicability to prevention of C. taxifolia introduction and spread. a. Incorporate language to enhance prevention efforts and advance regulatory authority as appropriate. b. Support proposed initiatives as appropriate through information sharing and testimony as requested by legislative leaders. i. The proposed Plant Protection Act would repeal the Plant Pest Act, Plant Quarantine Act and portions of the Federal Noxious Weed Act, replacing them with a unified federal plant health authority. The proposed authority provides the Secretary of Agriculture with broader discretion to regulate plants (including noxious weeds), plant products, and plant pests. 3. Develop new legislative and regulatory initiatives to expand the scope of existing legislation and eliminate current gaps minimizing the risk of the introduction and spread of C. taxifolia in U.S. waters. a. Develop regulatory initiatives designed to mitigate specific pathways. 4. Identify and communicate with state agency representatives to enhance prevention efforts and regulatory authorities through state legislative initiatives. a. Review existing and proposed legislative authorities to determine potential applicability to preventing the introduction and spread of C. taxifolia in the U.S. b. Cooperate with state agency representatives and multi-state organizations or commissions providing assistance as necessary to develop and enforce consistent state regulations to enhance prevention efforts. c. Target all states identified as potential entry sites or potentially affected by the introduction and/or spread of C. taxifolia, or the implementation of prevention efforts. Consider all dispersal mechanisms. Objective VIII -- Education Public support and cooperation is required to successfully implement any comprehensive prevention or control program. Public support has made significant contributions to detection, prevention, and control of other introduced invasive species. However, without continued exchange of timely, accurate and consistent information, the public can unknowingly contribute to the introduction, spread, and establishment of invasive species like C. taxifolia. Effective education ensures a clear understanding of the risks associated with C. taxifolia introduction and/or establishment. Entities likely to be impacted by C. taxifolia require knowledge and awareness to incorporate actions that minimize the risk of introduction and/or dispersal. Educational initiatives should also focus public attention on regulations and regulatory initiatives regarding C. taxifolia. Public understanding is imperative to enforcement and compliance. Public awareness of the risks associated with C. taxifolia introduction, dispersal mechanisms, and prevention strategies will aid decision-making and advance prevention efforts. Recommended Actions 1. Identify entities potentially affected by the introduction of C. taxifolia and/or the implementation of prevention activities. Some example include: a. Federal enforcement/inspection officials b. Commercial fishermen c. Recreational fishermen d. Recreational/tourism boat owners e. Divers f. Aquarium industry g. Pet industry (personal aquariums)(wholesalers, retailers, etc.) h. Import industry representatives i. International partners (export industry; harvest industry) j. Researchers (university, private) k. Coastal property owners l. Government officials/ policy-makers (federal, state, tribal, and local) m. General public 2. Develop C. taxifolia educational and outreach initiatives targeting general audiences and specific entities. a. Use existing mechanisms to facilitate effective and efficient information transfer. i. ANS Task Force Regional Panels ii. National and State Sea Grant Programs iii. National Nonindigenous Species Database iv. Aquatic Nuisance Species Hotline 3. Coordinate workshop to investigate and develop C. taxifolia identification techniques that can be broadly disseminated for use by scientific and non-scientific entities. a. Develop educational materials for broad distribution outlining identification techniques. b. Develop multi-agency training materials and required courses or course sessions for enforcement/inspection officials. 4. Develop voluntary public surveillance and detection networks. Include all entities involved with coastal activities (commercial/recreational fishermen, boaters, divers, universities, coastal property owners/associations, etc.) a. Develop educational materials, collection, holding, and reporting protocols, and annual mail-in reporting surveys to evaluate participation. b. Designate appropriate federal agency to receive, coordinate, and respond to network reports, including confirmation of potential sitings and completion of the annual evaluation. 5. Establish central C. taxifolia information clearinghouse, including published articles, ongoing research initiatives, prevention efforts, regulations, and legislative initiatives. a. Establish Internet accessibility to information (web page and appropriate address links). 6. Develop traveling education displays for use at public aquariums and other forums. Focus public attention on overall risks posed by invasive species, including C. taxifolia, basic prevention strategies, regulations, and the importance of public participation. a. Encourage aquariums, zoos, museums and other public facilities using aquatic organism displays to feature native species. 7. Develop educational materials and curriculums for youth education. Include materials targeting elementary, middle, and high school aged youth. a. Incorporate materials into existing invasive species curriculums as appropriate (e.g. State Sea Grant programs). Objective IX -- International Activities A unified global effort is required to minimize the risk of invasive species introductions. Efforts to prevent the introduction of species such as C. taxifolia will be enhanced through cooperative initiatives with foreign governments and other international partners. Invasive species issues and concerns have recently gained increased visibility and recognition as a global threat. This provides a unique opportunity to develop and execute cooperative international prevention programs to minimize the risk of future introductions. As previously discussed, the most effective control alternative is prevention through the interruption of pathways. Effective cooperative programs with international partners will therefore minimize the risk of transporting C. taxifolia to the U.S. Recommended Actions 1. Identify and establish contacts with appropriate foreign government officials and agencies in countries and localities where C. taxifolia is established. a. Educate and inform international partners about current C. taxifolia regulations in the U.S. b. Identify foreign industries potentially transporting C. taxifolia to the U.S. (Consider all possible dispersal mechanisms.) 2. Collaborate with foreign governments and export industry representatives to identify alternative international transport policies to minimize the risk of moving C. taxifolia to new locations. a. Investigate seaweed harvest mechanisms (general versus species specific). Identify harvest mechanisms that minimize the risk of collecting and transporting C. taxifolia. b. Identify other intentional uses of seaweed in addition to use as a packing material for fresh seafood, ornamental aquarium displays, and bait industry. c. Investigate the origin and use of water in packaging and transport. Identify treatment options to minimize the risk of transporting plant fragments. d. Investigate the invoice or packing slip listing requirements currently used by industry for shipments containing seaweed products. Identify alternative methods for encouraging listing of C. taxifolia. 3. Develop Point of Origin Risk Mitigation Protocols with foreign governments and export industry representatives. a. Monitor compliance and evaluate effectiveness. 4. Develop a "Caulerpa taxifolia Free" Certification Program for all imports containing aquatic materials or water. Require compliance from both infested and uninfested areas to ensure that undetected invasions or spread do not result in a U.S. introduction. a. Develop strategies to market the Certification Program to U.S. entities that have the potential to inadvertently import C. taxifolia into the U.S. 5. Establish cooperative agreements with foreign governments in areas where C. taxifolia has not been introduced or become established. a. Cooperatively identify all areas of potential vulnerability to C. taxifolia invasion and establishment. Identify the risk of transport to U.S. waters from each vulnerable area. Jointly develop similar prevention strategies in vulnerable areas. Consider all dispersal mechanisms. b. Educate and inform foreign representatives about current U.S. regulations and prevention strategies regarding C. taxifolia. Each of the recommended actions associated with the nine objectives require further prioritization. Comments received from the ANS Task Force and the public will be incorporated to establish preliminary prioritization of the recommended actions. These considerations will be presented in the final document. APPENDIX A Federal Noxious Weed Act Amendment APPENDIX B Nonindigenous Aquatic Nuisance Prevention and Control Act