Madrid. 22-09-1999

Dear everybody,

Please, find enclosed a very important paper published in ANIMAL PEOPLE. It is high time to stand up for the defense of defenceless animals, targeted as so-called alien or invasive species.

In the name of eco-diversity, protection of native species or what have you, an appalling mass murder is being planned (sometimes it is already being perpetrated) by humans against thousands upon thousands of animals who have committed no offence against humans.

Thus the purported environmentalist end does (whether sincerely or not) justify the means: a slaughter, that is to say a massacre, of animals who are our relatives, who feel pain and distress, who have their life-companions, their families, their social groups, who well be bereft by the human mass- killers.

Best wishes. Lorenzo Peña


Representatives of the 175 nations that have endorsed the United Nations Convention on Biological Diversity -- including the U.S. -- are to assemble in Nairobi, Kenya, in May 2000 to draft guidelines for purging and blocking the spread of alleged invasive species. The guidelines are to be presented for ratification by the CBD members in 2001.

Once ratified, they could constitute a global mandate in support of the forthcoming recommendations of the cabinet-level Invasive Species Council created by U.S. President Bill Clinton on February 2, under orders to «mobilize the federal government to defend against aggressive predators and pests.» The mobilization is to be under way by August 2000.

The definition of «aggressive predators and pests» addressed by both the CBD and Invasive Species Council could include -- among many other species -- feral cats; feral pigs; the mountain goats of Olympic National Park in Washington state; street pigeons; starlings; the parrot colonies of San Francisco, Florida, and the New York City metropolitan area; and all wild horses and burros on public land except Bureau of Land Management holdings, where they enjoy limited «squatters' rights» under the 1971 Wild And Free Ranging Horse and Burro Protection Act.

Most of these species are specifically mentioned in the CBD Subsidiary Body on Scientific, Technical, and Technological Advice document UNEP/CBD/SBSTTA/4/8, dated February 15, 1999, and presented as part of the agenda for a June 21-25 meeting of the subsidiary body held in Montreal. The subsidiary body is known as SBSTTA.

Japanese government officials disclosed the CBD timetable to the Kyodo News Service on June 26, one day after the SBSTTA meeting ended. Species likely to be targeted in Japan, they indicated, include raccoons, weasels, marten, common mongooses, and black bass.

The announcement came two weeks after the Japan Environment Agency announced a plan to cull 250 of the 300 native Sika deer in the Odaigahara highlands, to protect an ancient spruce forest from bark nibbling.

«This is the first time the Environment Agency has decided to preserve an ecosystem by killing wild animals,» wrote Sally Fisher of the Hong Kong-based South China Morning Post. In absence of strong public protest, however, the deer cull will doubtless not be the last such project.

Virtually ignored by U.S. and Canadian media, and by the international humane community, SBSTTA has been planning a worldwide war on non-native animals and plants since May 1998, when it adopted «Decision IV/1.C on alien species that threaten ecosystems, habitats or species.»

According to a «Note by the Executive Secretary» prefacing the February 15 document, «The COP [Conference of the Parties to the CBD] requested SBSTTA to develop guiding principles for the prevention, introduction and mitigation of impacts of alien species.»

The document, amounting to a summary SBSTTA anti-invasive species agenda, is markedly less partisan than the political context surrounding it -- but there is still much in it to cause concern that non-native so-called nuisance wildlife may be aggressively, inaccurately, and inhumanely targeted for allegedly causing extinctions of endangered species and economic damage which may actually result from global warming, pollution, and other habitat change caused by human activity.

Blaming invasive species could, for instance, enable regulators to waive restrictions on development that might otherwise be required under the U.S. Endangered Species Act. Habitat could be further destroyed, while a program to kill a non-native species passed as a mitigation measure.

Looking at related Congressional action, Defenders of Wildlife Greenlines editor Roger Featherstone in an August electronic alert warned, «Sources indicate that Interior Secretary Bruce Babbitt has persuaded Senator Slade Gorton (R-Washington) to introduce an amendment to the Senate Interior Appropriations bill to limit funding for critical habitat designations under the Endangered Species Act. Earlier this year,» Featherstone explained, «Babbitt worked behind the scenes with Senator Pete Domenici (R-New Mexico) in an attempt to gut the critical habitat provisions of the ESA. Environmentalists believe Babbitt wants Congress to give only $1 million for critical habitat so the agency can plead poverty when faced with lawsuits challenging their failure to list critical habitat. The ESA requires that critical habitat be designated when a species is listed, yet more than 90% of the listed species have none designated.»

Targeting non-native species could also reinforce tax-funded programs to encourage hunting, fishing, and trapping -- like the thus far futile effort to rid Lake Yellowstone of rainbow trout via sport fishing. The rainbow trout were introduced to Yellowstone National Park in the first place to increase fishing opportunities. The influential Louisiana delegation to Congress might seek federal subsidies for trapping nutria. The Wild and Free Roaming Wild Horse and Burro Protection Act might be repealed on the pretext that it contradicts an international treaty, much as the 1990 Dolphin Protection Act was recently amended to eliminate the provision barring imports of tuna netted «on dolphin.»

Most obviously, the federal and international invasive species eradication programs together form a politically safe pretext for continuing the increasingly unpopular and ecologically destructive USDA Wildlife Services branch. Formerly known as Animal Damage Control, the program changed names in 1997. As always since it was formed in 1930, Wildlife Services kills mainly coyotes, prairie dogs, and other species accused of either preying upon or competing with livestock -- but in recent years it has sought to promote an image of protecting endangered species, as in killing coyotes at the Julia Hansen Butler Refuge in southern Washington to increase the survival of formerly endangered Columbia white-tailed deer fawns.

Jointly chaired by Interior Secretary Bruce Babbitt, Commerce Secretary William Daley, and Agriculture Secretary Dan Glickman, the Invasive Species Council provided a boon to Senators from western ranching states by securing the status of Wildlife Services within the federal budget -- and was announced on the eve of Clinton's impeachment trial before the U.S. Senate, for allegedly misusing his office and lying to Congress about his sexual liaisons with former White House aide Monica Lewinsky.

Wildlife Services briefly lost more than a third of its $28.8 million fiscal 1999 allocation in June 1998, when the House of Representatives axed it as a boondoggle -- but the cut was rescinded within days, under intense regional political pressure.

Coincidentally, the sum Clinton allocated to fulfil the recommendations of the Invasive Species Council was also $28.8 million: enough to precisely double the Wildlife Services budget.


Hired as Invasive Species Council executive director was Gordon Brown, co-author with Cornell university professor David Pimentel of a recent study which claims alien plants and animals are already costing the U.S. $138 billion a year, including $300 million in various other forms of federal spending, and are responsible for jeopardizing 42% of the species on the U.S. endangered species list.

The monetary figures include all costs of rat control, the estimated $30 million- a-year cost of treating dog bites, $10 million in livestock losses purportedly caused by dogs, and $6 million a year for the lost insect-eating capacity of birds believed to have been killed by outdoor cats.

Brown reportedly told Knight Ridder Newspapers science reporter Seth Borenstein that he envisions forming an organization «something like a cross between the Centres for Disease Control and Prevention and a wildfire fighting force, that can parachute in to contain the spread of exotics.»

But plant ecologist Marcel Rejmanek of the University of California at Davis told Borenstein that he doubts a combative rather than preventive approach can succeed.

«Unless new species are discovered very early,» Rejmanek said, «we have to switch from an offensive strategy to a defensive strategy. We don't have any chance to eradicate any species that is widespread.»

Animal control cat-killing provides a quick example of that. Except on small islands of extremely harsh climate and limited food supply, catch-and-kill has never lastingly depressed cat populations. Aggressive neuter/return programs have brought feral cat population crashes, however, in every locale where results have been monitored over several years. Cats, like many other «invasive» animals, have evolved high enough fecundity to withstand predation at rates of up to 100% population turnover per year. Reducing the fecundity of the animals already in the habitat, rather than accelerating extermination, is the key to gradually eliminating their presence.


The success of neuter/return notwithstanding, the hunter/conservationists and cat- aversive birders who dominate wildlife agencies continue to seek ever deadlier cat-killing methods. In Australia, for instance, the federally funded National Heritage Trust -- in the name of protecting biodiversity -- announced on July 22 that it will underwrite trials of a poison called FTC-2, engineered by the Victorian Institute for Animal Science to kill only cats. The estimated 15 million Australian feral cats kill about four million native animals per year, the project planners explained, apparently without mentioning that the cats are also the leading predators of rabbits.

Another non-native species, introduced for hunting in 1856, rabbits swiftly occupied the burrows of extirpated native marsupials, proliferated to become a nationally decried pest species within 15 years, and purportedly now cost Australian farmers about $600 million annually in lost production and control expense. But other introduced species are favoured against rabbits: the flea-borne disease mixomiatosis; and rabbit haemorrhagic disease, also called rabbit calicivirus.

At urging of the Universities Federation for Animal Welfare, some British humane societies began using neuter/return instead of catch-and-kill to control feral cats as early as 1973, 18 years before major neuter-return projects debuted in the U.S.

The success of that approach may have influenced the British Forestry Commission to pursue the development of contraceptives to replace lethal methods in trying to keep introduced American grey squirrels from out-competing and hybridizing with native red squirrels. «The search for a contraceptive solution has moved out of the laboratory and field tests are being carried out,» a Foresty Commission spokesperson (told A.J. McIlroy of the London Daily Telegraph on July 19.

«The aim,» the spokesperson continued, «is to control the population of grey squirrels, not to exterminate them.»

Non-lethal reproductive control may be the most humane and most practical approach to handling any sentient invasive species. But it may not satisfy the demand of people annoyed by a particular animal to see it fall down dead.


Concern over invasive species was written into the Convention on Biological Diversity right from the start, when it was produced as the central achievement of the 1992 Earth Summit in Rio de Janeiro, Brazil.

CBD Article 8 states that «each Contracting Party shall, as far as possible and as appropriate., prevent the introduction of, control, or eradicate alien species which threaten ecosystems, habitats or species.»

Explained the February 15 SBSTT'A agenda, «At subsequent meetings of SBSTTA and of the COP, Panics recognized that negative impacts of alien species on biological diversity concern not only marine and coastal, but also inland water, agricultural and forest ecosystems. Further, alien species pose problems to indigenous and local communities and negatively affect local and national economies. This ultimately led the COP to decide, at its fourth meeting, that alien species is a cross-cutting issue for implementation of many of the themes of the Convention.»

In other words, alien species moved up in February 1999 from being one CBD concern among many to becoming Priority One.

This represented a major behind-the- scenes victory for the biotechnology industry, largely based in the U.S. and other developed nations; for hunter/conservationists, who prefer to blame invasive species rather than sport hunting and poaching done under cover of sport hunting for the decline of many so-called trophy species; and, especially, for U.S. Vice President Albert Gore.

Gore, as presiding officer of the U.S. Senate, has the primary constitutional responsibility for negotiating and securing ratification of international treaties.

When the CBD was formed, the underdeveloped nations which make up the majority of membership tried to centre discussion on genetic property rights -- still the most divisive issue on the CBD calendar.

If an underdeveloped nation preserves habitat within which animals or plants with genes of future value to biotechnology are discovered, Third World representatives contend, that nation should receive royalties on any applications of the discovery.

Nations with advanced biotech industries, led by the U.S., have resisted the royalty concept as an infringement on intellectual property rights.

Advancing the invasive species issue has neither resolved nor sidetracked the genetic property rights dispute, so far. But producing an global plan for invasive species control will provide a pretext for offering aid to underdeveloped nations whose official philosophies on biodiversity coincide with those of the developed nations, perhaps tipping the balance in the semi-stalemated genetic property rights debate toward the U.S. perspective.


The scientific foundation of the CBD drive against non-native species is the 1995 Global Biodiversity Assessment published by the United Nations Environment Program. The Global Biodiversity Assessment, however, cited invasive species as only one among five major threats to endangered species, also including loss of habitat, changes in habitat quality, habitat fragmentation, and persecution and exploitation of populations.

From that relatively conservative position, the SBSTTA agenda now asserts, «It is common scientific understanding that, globally, the negative impacts of alien species on native communities are second only to habitat destruction,» lumping all three forms of habitat damage together.

«These threats are particularly serious on oceanic islands of small area and characterized by species having a highly specific ecological function,» the SBSTTA agenda continues. «However, even in ecosystems covering larger areas there is no guarantee of durability of the native species once alien ones have been introduced. In addition to those alien species interacting with the native species' ecological niches, the latter species are also threatened by hybridization,» a position seeming to ignore that hybridization is one of the major engines of evolution.

«When addressing the issue of alien species,» the SBSTTA agenda stipulates, «it is important to differentiate between natural invasions and human introductions of species. Species do spread naturally,» SBTTA concedes. «For example, climatic variation provides opportunities for the introduction of species into new ecosystems. As a general rule,» SBTTA adds, «when a species enters an ecosystem in which it previously did not occur, it has some effects on the ecosystem composition, but not always large, observable effects on the ecosystem processes.»

Thus the SBTTA agenda stops short of slating all species introductions for attempted reversal -- because to target agricultural introductions, for instance, including genetically modified species, would be to take on foes of vastly greater clout than anyone defending feral wildlife.

«Most of the invasions are human-induced,» the SBTTA agenda proceeds. «in most cases, species are introduced for food purposes and for providing other services to people. In most of the world it is indeed imported species that provide the large extent of food sources. Further, to maintain the health of economically important introduced species, the introduction of additional species is often required, the latter being used in biological control programs.»

The SBTTA agenda even acknowledges that, «Human introductions may have enriched the biological diversity of certain geographical areas, such as in the case of the British mammalian fauna and the central European flora.»

In other words, the CBD does not propose to take on either British animal rights activists or horticulturalists.

The SBTTA agenda further admits that, «There are no records of global extinction of a continental species as a result of invasive species.» The SBTTA agenda cites instead local declines to argue that non-native species may harm continental biodiversity.

Finally, the SBTTA agenda states, «Eradication of invasive species using currently available methods can be very expensive or even impossible. While large mammals can be reduced in numbers and even exterminated on small islands or in restricted areas, smaller animals and invasive plants are almost impossible to eradicate in any situation. The cost of finding and introducing natural parasites and predators for the large number of invasive species is also prohibitive, bearing in mind safety considerations for other species, and such procedures have often resulted in further ecological disasters. Additionally, when local species have been exterminated (such as in the case of island and aquatic systems), recovery proves to be impossible. Measures to prevent the introduction of species into new environments are therefore to be preferred.»


If the Invasive Species Council chose to emphasize a preventive approach, instead of trying to wipe out feral animals, the humane community might hope for new restrictions on the exotic pet traffic, and an end to introductions of species to be hunted, such as Sika deer and Chinese pheasants. The focus of the Invasive Species Council might be on such matters as the arrival of microorganisms with ballast water from foreign vessels.

Currently, observes Jim Brewer, co-founder of Pigs: A Sanctuary, and now coordinator of an ad hoc committee seeking to gain humane representation on the Invasive Species Council advisory panel, «it would appear that the focus presented to the public is going to be weeds. I doubt that we are going to hear anything about the eradication of animals,» even though «the executive order pertaining to noxious weeds and invasive plants pertains also to animal pests and predators.»

But Brewer thinks the Invasive Species Council is unlikely to stop at weeds. The efforts of the American Bird Conservancy and National Audubon Society to promote war on feral cats are ongoing, as is the disregard of The Nature Conservancy for humane standards in its 20-year push to kill feral pigs and goats in Hawaii, and pigs, goats, and sheep in the Channel Islands off southern California. People for the Ethical Treatment of Animals has since 1993 urged a boycott of TNC over conduct of the Hawaiian purges.

Audubon and other conservation groups also pushed the proposed extermination of mountain goats in Olympic National Park for allegedly harming rare native plants, even though the goats documentedly killed only six endangered milkvetch plants in 10 years.

On environmental matters, Albert Gore makes no secret of taking his cue from the hunter/conservationists.

Says Brewer, «I cannot understand why the multi-million-dollar animal groups with multi-person offices aren't jumping on this. Just from my brief readings of the preliminary documents, non-native animals are in for bigtime eradication.»
Animal People. September 1999
News for People Who Care About Animals
POB 960. Clinton, WA 98236-0960
ISSN 1071-0035
FAX 360-579-2575.
Copyright (C) 1999
Prof. Lorenzo Peña - Editor of SORITES
CSIC - Institute of Philosophy
Pinar 25, E - 28006 Madrid, Spain

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