Growing Risk. Addressing the Invasive Potential of Bioenergy Feedstocks. Aviva Glaser and Patty Glick 2012

Transcription

1 Growing Risk Addressing the Invasive Potential of Bioenergy Feedstocks Aviva Glaser and Patty Glick 2012 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 1

2 Growing Risk Addressing the Invasive Potential of Bioenergy Feedstocks Prepared by Aviva Glaser, Legislative Representative, Agriculture Policy Patty Glick, Senior Climate Change Specialist Acknowledgements This report was made possible due to the generous support of the Doris Duke Charitable Foundation. The authors wish to thank many people for their time and contributions to this report. We would like to thank the following National Wildlife Federation staff for providing valuable edits and feedback: Julie Sibbing, Bruce Stein, Doug Inkley, and Lara Bryant. Additionally, we would like to thank several experts for their time, input, and helpful review comments: Dr. Joseph DiTomaso, University of California, Davis; Dr. Doria Gordon, The Nature Conservancy; Bryan Endres, J.D., University of Illinois; Dr. Lauren Quinn, University of Illinois; Doug Johnson, California Invasive Plant Council; and Read Porter, J.D., Environmental Law Institute. Designed by Maja Smith, MajaDesign, Inc National Wildlife Federation Cover image: The highly-invasive giant reed (Arundo donax), a candidate species for bioenergy production, has taken over vast areas along the Rio Grande, as seen in this aerial view near Eagle Pass, Texas. Credit: John Goolsby, USDA. Suggested citation: Glaser, A. and P. Glick Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks. Washington, DC: National Wildlife Federation. i Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

3 Table of Contents Little bluestem, a native grass. Credit: NRCS. 1. Executive Summary 1 2. Overview 3 The Promise of Bioenergy 3 Risks from Bioenergy 4 A Focus on Invasiveness 4 3. Invasive Bioenergy Feedstocks: A Major Concern 7 Invasive Plans Can Wreak Havoc on Ecosystems and Society 7 Weediness: A Characteristic of a Good Biomass Plant 8 Harvesting Existing Invasive Plants: Win-Win or Pandora s Box? 9 Adding Climate Change to the Mix 10 Selective Breeding and Genetic Modification 11 The Myth of Total Sterility Case Studies of Feedstocks of Concern 14 Giant Reed (Arundo donax) 14 Miscanthus (Miscanthus species) 16 Genetically Modified Eucalyptus (Eucalyptus grandis x Eucalyptus urophylla) 18 Reed Canarygrass (Phalaris arundinacea) 20 Algae 22 Napiergrass (Pennisetum purpureum) Minimizing the Risks: The Importance of Embracing Precaution 26 Current Regulation of Invasive Species 26 Screening Tools Conclusions and Recommendations 34 Concluding Thoughts Endnotes 42 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks ii

4 1 Executive Summary W ithout question, America needs to transition to a cleaner, more sustainable energy future. As we move forward with our energy choices, we must be mindful of how shortterm economic decisions can come with unintended consequences and high long-term costs to society and the environment. Bioenergy is one homegrown source of renewable energy that could help meet some of our energy needs. However, in order to create a truly clean energy future, bioenergy must be produced in a way that has long-term economic viability, helps address climate change, and protects and enhances native habitats and ecosystems. Parabel grows non-genetically modified, native aquatic plants in Florida to use as a renewable energy feedstock. Credit: Julie Sibbing. In order to create a truly clean energy future, bioenergy must be produced in a way that has long-term economic viability, helps address climate change, and protects and enhances native habitats and ecosystems. The explosion in federal and state mandates and incentives for renewable energy in recent years has led to a greatly increased demand for cheap and plentiful biomass from a variety of plants and microorganisms. This increased demand for bioenergy has led to considerable interest in a number of non-native and potentially invasive species that are currently being cultivated or considered for use as bioenergy crops. In fact, some of the very characteristics that make a plant particularly useful as a source of biomass energy (e.g., rapid growth, competitiveness, tolerance of a range of climate conditions) are the same characteristics that make a plant a potentially highly invasive species. Widespread cultivation of exotic and genetically modified species for bioenergy is becoming increasingly likely. Should these species escape cultivated areas and enter nearby habitats, the results could be devastating for native ecosystems as well as the economy. Very little is known about the full potential scope of the problem, yet the industry is moving full speed ahead. Already, there are examples of intentional cultivation of biomass species that are known to be invasive or have the potential to become invasive. For instance: 4

5 Giant reed (Arundo donax) is being used as a bioenergy crop in Florida, despite the fact that it has been known to invade important riparian ecosystems and displace habitat for native species in states across the southern half of the country. Reed canarygrass (Phalaris arundinacea), which is considered to be one of the most harmful invasive species in America s wetlands, rivers, and lakes, is being proposed for cultivation as a bioenergy feedstock in several areas, including the Eastern Upper Peninsula of Michigan. Cylindro (Cylindrospermopsis raciborskii), a type of algae that is associated with toxic algal blooms in the Great Lakes region, is just one of many non-native or modified strains of algae under consideration for bioenergy, even though the fast growth rate of algae and the inherent difficulty in containing them is a major concern. Napiergrass (Pennisetum purpureum), also called elephant grass, has been listed as an invasive plant in Florida and described as one of the most problematic weeds in the world, and yet BP is currently developing a cultivated variety of it as an energy crop in the Gulf Coast Region. In addition, the use of already highly-destructive invasive plants for bioenergy, including Chinese tallow (Triadica sebifera), kudzu (Pueraria montana var. lobata), Eurasian watermilfoil (Myriophyllum spicatum), and common reed (Phragmites australis), is being proposed as a way to capitalize on the potential benefits of the plants while providing an opportunity for their control. While this may allow for a win-win for ecosystem restoration and renewable energy production, it also raises the concern that the active re-establishment of the invasive species, rather than their control, might be incentivized. The severity of this threat is by no means trivial. Every year, invasive species cost the United States billions of dollars and affect countless acres of native ecosystems. Researchers estimate that nearly half of the species listed as threatened or endangered under the U.S. Endangered Species Act are at risk, at least in part, due to the impacts of invasive species. Despite this, few safeguards exist in law and in practice to prevent the spread of invasive species. To date, current laws and regulations dealing with invasive species have been reactive and piecemeal. As a result, invasive species that we may have been able to inhibit are causing widespread environmental and economic harm. We now have an opportunity to prevent irreparable harm by heeding sensible precautions. With foresight and careful screening, we have important opportunities to minimize and, where possible, prevent negative impacts of biomass feedstocks on the nation s communities and ecosystems. We recommend some key actions to help ensure that the next generation of bioenergy does not fuel the next invasive species problem. 1. Future bioenergy development should encourage ecological restoration and improve wildlife habitat through the use of ecologically beneficial biomass feedstocks such as waste materials and sustainably collected native plants and forest residues. 2. Federal and state governments should conduct coordinated efforts to restrict or prohibit the use of known invasive species as dedicated bioenergy feedstocks through rigorous Weed Risk Assessment (WRA) screening protocols. 3. State and federal governments should implement rigorous monitoring, early detection, and rapid response protocols, paid for by feedstock producers through insurance bonding or other financial mechanisms. 4. Feedstock producers should adopt best management plans for monitoring and mitigation to reduce the risk of invasion. 5. The federal government should assign liability to feedstock producers for damages from and remediation of invasions by feedstock varieties that they develop. 6. Governments and businesses should better account for the economic risks associated with invasiveness of feedstocks when assessing relevant costs and benefits of potential bioenergy projects. Bioenergy can be an important part of a sustainable energy future, but only if it is produced in a way that safeguards native ecosystems and minimizes the risk of invasion. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 2

6 2 Overview A s the world focuses greater attention on finding alternatives to fossil fuels in order to meet our growing energy demands, reduce carbon emissions, and enhance global security, interest in expanding the use of bioenergy has grown considerably. Bioenergy also called biomass energy refers to the energy resources derived from plants and animals or their metabolic products. Sources of biomass can include trees, annual and perennial crop plants, algae, and other plants, as well as some organic waste materials and byproducts from other manufacturing processes (See Box 1, page 5). When these feedstocks are used to produce energy in the form of liquid fuels, such as ethanol and biodiesel, they are referred to as biofuels. Biomass can also be used to produce energy in the form of heat and electricity generation. Indeed, the use of wood for cooking and heating has long been a part of human history. The Promise of Bioenergy Native perennial grasses have great potential as energy crops. Credit: istockphoto.com/prairie Art Project. One of the attractions of bioenergy is that unlike fossil fuels, which have a finite global supply, bioenergy can be grown and used repeatedly and thus can be considered a form of renewable energy. One of the attractions of bioenergy is that unlike fossil fuels, which have a finite global supply, bioenergy can be grown and used repeatedly and thus can be considered a form of renewable energy. Renewable energy (including wind, solar, geothermal, and biomass energy) is becoming an increasingly important part of America s energy portfolio. According to the U.S. Energy Information Administration, renewable energy s market share reached 8 percent of total U.S. energy consumption in In addition, many states have enacted minimum renewable energy requirements for both transportation and electricity generation. Currently, biomass is the largest contributor to renewable energy in the United States and around the world, and accounts for about 11 percent of total primary energy consumed. 2 Research suggests that increased production of energy from biomass resources may have the potential to considerably offset the use of fossil fuels. 3,4 3

7 Credit: DOE Office of Biological and Environmental Research. In addition, the production and use of bioenergy is being widely touted as a way to help mitigate climate change. 5,6 Ideally, biomass fuel production and use would be at least carbon neutral. In other words, feedstocks absorb carbon dioxide (CO2) as they grow, and the carbon is released back into the atmosphere when the plants are harvested and used for energy, with no net gain in atmospheric carbon. In principle, feedstocks have the potential to even be carbon negative if more carbon is taken up than is released, as root stocks develop and store carbon. Ultimately, net increases in atmospheric CO2 would slow if truly carbon neutral bioenergy resources displaced the use of fossil fuels, which increase atmospheric carbon by transferring carbon from subterranean reserves into the atmosphere when combusted. However, it is critical to acknowledge that the greenhouse gas implications of bioenergy are complex, and that climate-related benefits cannot automatically be assumed. 7,8,9 Risks from Bioenergy As with all energy resources, it is important to recognize that development and use of bioenergy has both benefits and costs, and there is potential for considerable societal, economic, and environmental tradeoffs. There are a number of environmental concerns associated with the use of bioenergy, including the loss or degradation of native ecosystems, declining soil and water quality, and the invasive potential of the feedstocks themselves. 10,11 One of the key issues related to bioenergy is land use. As demand for bioenergy grows, so will the areas of land needed for growing biomass feedstocks. The implications of this for other current and potential uses of land to meet competing needs, such as food production, are significant. 12 Of particular concern for biodiversity conservation is the potential for natural areas such as forests or grasslands to be converted to cultivated bioenergy cropping systems or monocultures. Furthermore, as mentioned above, research has found that not all bioenergy is actually carbon neutral, and, depending on a number of factors, some forms of bioenergy may in fact lead to increased emissions of CO2 13,14 For example, it can take more than 50 years for trees to regrow and recapture the total carbon released when mature trees are used for bioenergy. While bioenergy holds great promise for meeting some of renewable energy needs, the impact of unsustainable bioenergy development could be devastating to natural resources. A Focus on Invasiveness While all of the concerns associated with the expansion of bioenergy require careful consideration, this report focuses on only one of these concerns the potential invasiveness of bioenergy feedstocks an issue that has only recently begun garnering significant attention. 25 Numerous studies have shown that some of the plants considered most promising in terms of bioenergy capacity may actually be extremely invasive and potentially quite harmful to native species in areas where they have been introduced. 26,37,28,29 History has repeatedly shown that introductions of invasive species, even when well-intentioned, can lead to widespread unintended environmental and economic consequences. As Raghu et al. (2011) aptly state, [t]he road to species introductions is often paved with good intentions, but is littered with their consequent legacy. 30 Invasive species (including plants, animals, and other organisms) are one of the primary threats to North America s native species and ecosystems. An invasive species is defined by the federal government as an alien species whose introduction does or is likely to cause economic or environmental harm or harm to human health. 31 While only a small percentage of the estimated Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 4

8 Box 1. The Importance of Fostering a New Generation of Bioenergy Feedstocks: Moving Beyond Corn-based Ethanol I n the early stages of bioenergy development, the primary feedstocks in the United States have included corn, sugar cane, and other annual food and feed crops for ethanol, wood for heat and electricity, and to a lesser extent, palm, sunflower, and rapeseed for biodiesel and other oils. Corn, in particular, has been the predominant bioenergy crop. In 2010, the United States produced 13.2 billion gallons of corn-based ethanol, making it the world s top producer of the fuel at 57.5 percent of global production. 15 Production and use of bioenergy in America is expected to continue to grow considerably over the next decade. Under the 2007 Energy Independence and Security Act, the nation has set a Renewable Fuel Standard (RFS) to significantly increase the proportion of bio-based fuels for transportation, from current production levels of over 13 billion gallons a year to 36 billion gallons by This would account for about 7 percent of the expected annual gasoline and diesel consumption above a business-as-usual scenario. 16 Under the law, the total use of ethanol from corn is capped at no higher than 15 billion gallons. Over the last few years, some troubling ecological and economic issues have arisen regarding the use of corn as a bioenergy feedstock. For example, a number of studies have found that the cultivation and production of corn-based ethanol typically consumes more energy than it ultimately generates, given the relatively large amount of fertilizers, pesticides, and other energy-intensive inputs and activities required. 17,18,19,20,21 Researchers have also found that expansion of corn production has led to reduced populations of already declining grassland Corn has been the predominant bioenergy crop in the U.S. Credit: Fishhawk on flickr. bird species. 22 In addition, there are concerns that the expansion of corn production for bioenergy could further exacerbate water quality problems in some areas due to expansion in the use of agricultural chemicals and nutrients such as nitrogen and phosphorous. 23,24 While the nation s demand for corn-based ethanol will likely continue to grow in the near-term until it reaches its cap, there has been strong interest and effort to identify new advanced or second generation bioenergy feedstocks that can optimize energy outputs with fewer economic or environmental (continued) 5 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

9 inputs. Particular emphasis is being placed on cellulosic bioenergy, which is produced from fibrous plant material from such things as perennial grasses [such as reed canarygrass (Phalaris arundinacea), switchgrass (Panicum virgatum), miscanthus (Miscanthus spp.), and giant reed (Arundo donax)] and fast-growing trees [such as poplar (Populus spp.), willows (Salix spp.) and eucalyptus (Eucalyptus spp.)]. Research is also being conducted on the potential for so-called third-generation bioenergy resources from algae and other micro crops. Ultimately, more than half of the total volume of the RFS must come from cellulosic (defined as renewable fuel derived from plants that achieves a 60 percent reduction in greenhouse gas emissions compared to gasoline) and advanced bioenergy (renewable fuel derived from biomass other than corn starch that achieves a 50 percent greenhouse gas reduction requirement). As this report highlights, however, these next generation feedstocks are not necessarily more benign than their predecessors. While they may be potentially more productive and efficient than first generation feedstocks, next generation feedstocks also pose a greater risk of becoming invasive. 50,000 non-native (exotic, alien) species in the United States are invasive, those that are can cause tremendous ecological problems and often lead to considerable economic impacts. 32,33,34 Once introduced into a new environment, invasive plants can out-compete native species for limited resources such as space to grow, light, nutrients and water. 35 Invasive animals (including insects) can harm native forage or prey species, as well as compete with native animals for forage and prey. Invasive diseases of plants and animals can spread rapidly in native species that have little or no resistance. Invasive species can have a significant impact on ecosystems as well as human societies by disrupting food webs, decreasing biodiversity, altering important ecosystem functions such as fire ecology, damaging agriculture and infrastructure, and harming human health. 36 In addition, researchers estimate that nearly half of the species that are listed as threatened or endangered under the U.S. Endangered Species Act are at risk due, at least in part, to the impacts of invasive species (including plants, animals, and microorganisms). 37,38 damage by invasive species in the United States is at least $120 billion annually. 40 The annual cost associated with plants alone is estimated at $34.5 billion. 41 This report: Reviews the current state of knowledge on the invasive potential of plants being considered for use for bioenergy, Profiles six of these potentially invasive feedstocks, Discusses methodologies for screening feedstocks and mitigating potentially invasive properties, Provides an overview of the legal and policy framework within the United States that could minimize or mitigate this risk, and Offers a series of policy recommendations. Efforts to control invasive species, combined with economic losses due to the degradation or destruction of critical ecosystem functions, can cost billions of dollars a year in the United States. 39 In fact, analysis suggests that the economic damage associated with control of and Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 6

10 3 Invasive Bioenergy Feedstocks: A Major Concern Invasive Plants Can Wreak Havoc on Ecosystems and Society Exactly how many invasive plants species currently exist in the United States is unknown. However, we do know that some of the most harmful plants were brought in intentionally for horticultural, agricultural, and forestry purposes. 42,43,44,45 For example, three species originally introduced for landscaping and erosion control purposes, including purple loosestrife (Lythrum salicaria), kudzu (Pueraria montana var. lobata), and saltcedar (Tamarix spp.), have turned out to be among the most highly invasive and damaging species in the country. 46,47 Highly-invasive kudzu covering everything in its path. Credit: James H. Miller, USDA Forest Service, Bugwood.org. All too often, the extent of the problems created by an invasive species is not fully recognized until a landscape or ecosystem has been dramatically modified. Other problematic species were purposefully introduced for use as livestock forage [e.g., johnsongrass (Sorghum halepense)] or were released by accident via contaminated crop seed or other commodity imports [e.g., cheatgrass (Bromus tectorum) and cogongrass (Imperata cylindrica)]. 48 Even species that are native to some parts of the country have proven to be harmful invasives when introduced elsewhere. One notable example is smooth cordgrass (Spartina alterniflora). Smooth cordgrass is the predominant emergent salt marsh species throughout much of the Atlantic and Gulf coasts, where it plays an important role in the coastal ecosystem. Given its ability to control erosion, the species was introduced to parts of the Pacific Coast, where it has out-competed native marsh plants and significantly altered critical mudflats and other coastal habitats. 49 Very little attention has been given to the potential for non-native bioenergy feedstocks to host harmful diseases. The very real risk of disease in introduced plants is demonstrated by the fact that kudzu is a host species for Asian soybean rust (Phakopsora pachyrhizi), which was first reported in the continental United States 7

11 in It is a serious disease that can cause significant damage to soybean crops. 50 Similarly, members of the myrtle family (Myrtaceae), including eucalyptus trees, which are potential bioenergy feedstocks, have been found to host Puccinia psidii, a rust fungus that has severely damaged an endangered native myrtle species in Hawaii. 51 All too often, the extent of the problems created by an invasive species is not fully recognized until a landscape or ecosystem has been dramatically modified. 52 Studies have found that there is often a time lag of several decades or more between the time that a non-native species has been introduced and when we realize it has become a harmful invasive. By the time an invasive species has become established, they are exceedingly difficult to control, let alone eradicate. 53 In fact, evidence indicates that in most cases, species invasions are essentially irreversible. 54 Weediness: A Characteristic of a Good Biomass Plant Ultimately, the goal of bioenergy production is to create the greatest amount of energy possible while minimizing inputs such as fertilizer, agricultural chemicals, water, and planting and tillage operations. Thus, the optimal feedstock to maximize bioenergy production would be one that is fast-growing, highly productive, highly competitive, self-propagating or able to regrow rapidly, resistant to pest and insect outbreaks, and able to thrive in marginal environmental conditions including poor soil and drought. Unfortunately, many invasive species, by their very nature, exhibit these qualities as well (See Table 1). 55 Accordingly, plants considered to be good bioenergy candidates are often more likely to become invasive; researchers found that in Hawaii, for instance, approximately 70 percent of the plants proposed for use as biofuel feedstocks had a high risk of becoming invasive. 56 In fact, evidence indicates that in most cases, species invasions are essentially irreversible. Indeed, several exotic grass species that are currently under consideration for use as bioenergy feedstocks, including giant reed, reed canarygrass (Phalaris arundinacea), and miscanthus (Miscanthus spp.), are already considered invasive in some areas of the United States. 57 In California alone, more than $70 million dollars has been spent over the past 15 years to control giant reed, which has caused extensive damage to ecosystems and human infrastructure in many of the state s coastal and inland watersheds. 58 Reed canarygrass has displaced native species on thousands Table 1. Characteristics of Ideal Biomass Crops vs. Invasive Weeds 61 Characteristic of an Ideal Biomass Crop Characteristic Known to Contribute to Invasiveness Rapid growth rate x x Resistent to pests and diseases x x High water use efficiency x x C 4 photosynthesis* x x Perennial High yields x x Sterility Ability to grow in a wide range of climates and habitats x x Rapid regrowth or self-propagation x x * Plants with the C 4 photosynthetic pathway use water more efficiently under arid conditions than plants with C 3 photosynthesis. 62 x x Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 8

12 of acres of wetlands in southern Wisconsin. 59 In addition, some native species under consideration as bioenergy feedstocks have the potential to become invasive if introduced outside their native range. 60 Harvesting Existing Invasive Plants: Win-Win or Pandora s Box? Several studies suggest that some highly-problematic invasive plant species could be used for biomass, creating an economic incentive for controlling the species. For example, Sage et al. (2009) estimate that the amount of standing biomass of kudzu in naturally infested areas of Maryland, Alabama, and Georgia is high enough to significantly supplement existing biofuel feedstocks, assuming economical harvesting and processing techniques could be developed. 63 Given its invasive growth habit, the authors suggest that there would be little in the way of input costs for fertilizers, pesticides, planting, and stand management. Benefits may also accrue by offsetting some of the estimated $500 million per year cost to the nation from lost crop and forest productivity, expenditures for control, and property damage. Water hyacinth, seen in this picture invading a stream, has been suggested as a potential bioenergy feedstock. Credit: Kim Starr. Two other species, Chinese tallow (Triadica sebifera or Sapium sebiferum) 64 and saltcedar, 65 which are both listed by The Nature Conservancy as among the nation s Dirty Dozen least wanted intruders, have also been suggested as potential feedstocks for bioenergy. 66 Chinese tallow, for example, has become widely established across much of the South, and is known for its prolific production of oil seeds. One study suggests that conversion to commercial use of 500,000 acres of non-crop upland areas in southwestern Louisiana that currently host dense stands of tallow trees has potential to produce million barrels of biodiesel within a decade. 67 In addition, there is interest in using some of the world s most damaging aquatic invasive plants, including water hyacinth (Eichhornia crassipes), hydrilla (Hydrilla verticillata), Eurasian watermilfoil (Myriophyllum spicatum) and common reed (Phragmites australis), for bioenergy due to the desire for resource managers to control overgrowth, as well as the fact that these plants have significantly higher productivity rates than many terrestrial bioenergy feedstock candidates. 68,69 Researchers are also looking into the potential for using several invasive algae species, including Gracilaria salicornia, which is prevalent in coastal waters throughout the Hawaiian Islands, and Didymosphenia geminata, which is rapidly expanding in streams across the United States. 70,71.72,73 The primary issue regarding use of already-problematic invasive plants for bioenergy production is whether such uses will contribute to reducing the species invasion and restoring the invaded ecosystem, or whether potential economic gains from their use will encourage efforts to maintain their presence on harvested landscapes, or even lead to their cultivation and expansion into new areas. In fact, some researchers suggest that, instead of reduction, continued cultivation of the invasive species is acceptable, particularly in cases where the plants have become naturalized and where restoration to prior ecosystem composition and/or function is no longer feasible or possible such as with Chinese tallow. 74 However, Davis et al. (2010) describe such proposals as a Faustian bargain, with inadvertent creation of a lobby dependent upon maintenance of infested areas for fuel and employment. 75 It would likely be difficult for the bioenergy industry to refrain from supporting expansion of these feedstocks into new areas. Another issue of concern is that the active use of invasive feedstocks for bioenergy not only creates a sustained source of origin for propagules, it also creates a transportation infrastructure associated with harvest and use for bioenergy, which will undoubtedly increase the pathways for spread into other areas. 9 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

13 Soil erosion due to flooding. Climate change is likely to contribute to an increase in extreme events such as flooding, which can help spread invasive species long distances. Credit: NRCS. Furthermore, efforts focused specifically on reduction and control of currently-problematic plants must contend with the fact that the use of the particular feedstock is not sustainable once the resource is depleted, other feedstocks will be necessary to continue to support bioenergy production. A potential avenue to get around this dilemma would be through the creation of mobile bioenergy production facilities, which could move locations once a particular invasive species has been harvested and processed. Mobile production units may also help to reduce the risk of invasion created by transportation of invasive feedstocks. A number of companies are currently investigating this type of technology. Another idea is to purposefully establish a non-invasive, vigorously growing bioenergy feedstock in an area on which an invasive has been removed, thus preventing the invasive from becoming re-established and ideally stopping its spread. This idea would be particularly appropriate for areas in which the invasion has destroyed much of the native vegetation and the wildlife habitat value has been depleted. Adding Climate Change to the Mix Climate change is another issue that must be considered when assessing the potential invasiveness of bioenergy feedstocks. While bioenergy is often touted for its potential to help mitigate climate change by reducing net CO2 emissions, it is important to recognize that changes in the earth s climate system are already underway and will continue into the future, even under the best case scenario for mitigation. Several factors associated with climate change are likely to exacerbate the invasiveness of some bioenergy feedstocks. For example, studies have found that some invasive species may have a competitive advantage in systems disturbed by extreme events such as floods, droughts, hurricanes, and wildfires. 76 Scientists project that climate change will contribute to an increase in the frequency and intensity of such events in the coming decades. 77 Although impacts will vary across different regions, understanding where and how these changes might occur can help determine whether certain feedstocks under consideration for bioenergy production might have a potential to become invasive as conditions warrant. For example, the spread of several invasive species, including giant reed, saltcedar, and Eurasian watermilfoil, has been directly tied to flooding events, whereby their propagules can travel over long distances downstream well beyond the capacity of land owners to control them. 78,79 Furthermore, climate-related variables such as minimum winter temperatures often serve as a natural barrier to the expansion of invasive plants and animals into areas that are climatically unsuitable for them. Indeed, climate change is already contributing to an increase in average temperatures across the United States. Reflecting this change, the U.S. Department of Agriculture (USDA) recently issued the first revision since 1990 of its map of plant hardiness zones, 80 showing a shift markedly northward, consistent with climate change. In some areas, these changes may enhance the ability for potentially invasive plants to thrive where they may not have in the past. For example, recent research suggests that climate change is likely to contribute to a 2- to 10- fold increase in highly suitable habitat for saltcedar in the Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 10

14 Northwest. 81 Identifying areas with a suitable climate niche is one of the primary factors that managers will need to assess when locating bioenergy crops. 82 It will be important to consider not only the existing climate conditions, but also how climate change is likely to affect an area s future climate and thus its long-term suitability for specific biomass plants. Another wild card is how competitive relationships among plants will change with increases in atmospheric CO2. Several of North America s most noxious weeds, including Canada thistle (Cirsium arvense), spotted knapweed (Centaurea stoebe ssp. micranthos), cheatgrass (Bromus tectorum), leafy spurge (Euphorbia esula), and kudzu are more likely to benefit from changes in atmospheric carbon dioxide concentrations than are native plants, thereby giving them another competitive advantage. 83,84 As a general rule, plants with the C3 photosynthetic pathway (a trait associated with most trees and shrubs, and some grasses and sedges) are more likely to have enhanced growth from elevated CO2 than plants using the C4 pathway (including many feedstock candidates), assuming adequate water and nutrients for growth. However, the C4 photosynthetic pathway more efficiently uses water under warmer, drier conditions than C3 plants. In areas where climate change is projected to contribute to an increase in temperatures and more extreme droughts, conditions for the C4 candidate feedstocks may become more favorable. Selective Breeding and Genetic Modification Another issue of concern is the use of genetic modification (GM) and selective breeding to enhance or alter various characteristics, such as tolerance to cold, flooding, or salinity, for both non-native and native feedstocks, modifications that some studies suggest could significantly increase the risk of invasiveness. 85,86,87 In the agricultural industry, selective breeding and GM have been used for a number of purposes, including: increasing yield; enhancing nitrogen-use efficiency; and increasing resistance to conditions such as droughts, cold temperatures, pests, and diseases all characteristics that can give plants a competitive edge over non-altered, native plants. 88,89 Additionally, GM is increasingly being used to alter the fertility of plants in an effort to ensure that the plants are sterile. The purpose of sterility is both to limit the chance of the GM plants or their genes spreading outside of the area in which they are being cultivated, and to ensure that farmers will continue to purchase seeds for the modified crops....gm and conventionally altered plants may pose a contamination risk to the native ecosystems where they reside, should the modified versions spread. There is considerable concern that GM and conventionally altered plants may pose a contamination risk to the native ecosystems where they reside, should the modified versions spread. Research on the potential impacts of modified species that become established outside of target areas is still in its infancy, and considerable uncertainty remains about the risks that these species may pose relative to their wild relatives. Just as non-native species are not all necessarily invasive, modified plants do not all necessarily pose a risk to native ecosystems. The risk depends on the specific characteristics of the plant, where it is being cultivated, and whether wild relatives of the plant are in the region, among other considerations. One study of the use of GM poplars as a biofuel feedstock suggests that the scope of the ecological issues expected from their use is likely to be no greater than for conventional plantation culture. 90 Other studies indicate that the risks are likely much greater in cases where non-native species are modified to improve their adaptability in areas where they might otherwise not be able to survive. 91,92 That is because modified plants may be able to breed with wild relatives, resulting in potentially-invasive hybrids. In fact, research has found that hybridization between varieties or disparate source populations may promote evolutionary changes that enhance the invasiveness of exotic species over time. 93,94 Hybrids are particularly likely to occur in cases where there have been multiple introductions of a species or variety into a new area and where invasiveness has occurred after a lag period during which hybridization could occur. 11 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

15 Genetic modification has been used for many years for food crops, and thus it may be useful to look to these plants to better understand potential risks that GM may pose to ecosystems. According to a Government Accountability Office report, as of 2008 there were half a dozen documented cases in which GM crops were released into food, animal feed, or the environment unintentionally, but the total number of unauthorized releases into the environment was unknown. 95 In a more recent incident that was not included in the report, a study found that herbicide resistant GM canola (Brassica napus) has been found growing along roadsides across North Dakota. Almost half of the roadside plants sampled for the study were GM canola, indicating that not only had the plants escaped from the areas in which they were cultivated, but that they had become quite common. Additionally, the researchers found that the escaped plants could hybridize with each other, creating entirely novel combinations of transgenic traits. 96 Other studies have documented the transmission of the herbicide-tolerance gene from GM canola to wild relatives of the crop, such as wild turnips (Brassica rapa ssp. sylvestris). 97 The Myth of Total Sterility One way to reduce the risk of invasiveness is by promoting plant species that are unable to breed naturally. This can be achieved through several different means, one of which is to alter the fertility of the plants through genetic modification. In the case of GM eucalyptus, for example, scientists spliced in a gene known as the Barnase gene to limit the ability of the trees to reproduce; eucalyptus trees with the Barnase gene produce flowers without viable pollen. 98 Other times, companies rely on using hybrids between two species. Hybrids between two plant species in the same family are often sterile but not always. In fact, there have been a number of cases where species that were thought to be sexually sterile have nonetheless produced viable seed and become significant invaders. 99 Sterility can, in fact, break down and a very small number of viable seeds could be formed. 100,101 Even if this percentage is very small, the chance of reproduction may become significant when considering the fact that these species may be planted on a large scale. Giant miscanthus (Miscanthus x giganteus), for instance, is a sterile hybrid that is likely to be planted on hundreds of Genetically modified canola plants have been found to escape from the fields where they are cultivated. Credit: Karl Naundorf/Bigstock.com....by scaling up, we are also scaling up the chances of the sterile plant being able to create enough viable seeds that they may enter into nearby ecosystems. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 12

16 thousands of acres in the next few years 102 by scaling up, we are also scaling up the chances of the sterile plant being able to create enough viable seeds that they may enter into nearby ecosystems. As Low et al. (2011) explain, The large scale of proposed biofuels plantings will ensure high propagule pressure, so that even plants with low invasion potential will have many opportunities to escape. 103 Indeed, there have been a number of examples of so-called sterile plants becoming invasive. Townsend s cordgrass (Spartina x townsendii) was a sterile hybrid developed in England that after a number of decades began producing fertile plants. 104 Similarly, the Bradford pear (Pyrus calleryana), which was thought to be sterile, ended up reproducing by seed and becoming invasive through cross-pollination with other cultivars; individual cultivars are not invasive themselves, but different cultivars within a region can combine and produce invasive plants. 105 In 1994, the Bradford pear was considered to have a very low invasion potential, but after 10 years of ornamental plantings, it was found to have invaded natural areas in at least 26 states. The species is now considered an invasive plant in at least six states, although it is not yet listed as a noxious weed in any U.S. state. 106 It is important to recognize that even if a plant is unable to create viable seeds, it is not necessarily incapable of reproduction. Many plants are very capable of reproduction through the growth of new plants through vegetative means, such as underground rhizomes. For example, giant reed plants do not produce viable seeds, but they propagate vegetatively (a form of asexual reproduction in which a new plant can grow from a part of the parent plant) from even small stem fragments a trait that enhances invasiveness. 107,108 Giant miscanthus, another sexually sterile plant, can spread through underground rhizomes, although the rate of spread is considered to be quite low. 109 Feed stocks of concern At least a dozen species of concern currently are being used or considered for use as bioenergy feedstocks in the United States. The following are just a few examples of some of these species. While not exhaustive, this list highlights some of the potential benefits as well as the risks both ecological and economic that we must consider as we continue to build our bioenergy economy. Although the Bradford pear was thought to be sterile, the trees have become invasive in a number of states. Credit: Kenneth Keith Stilger/Bigstock.com. 13 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

17 Giant Reed (Arundo donax) 4 Case Studies G iant reed (Arundo donax), also known as giant cane, is a large, fast-growing grass species native to India. This perennial grass can grow between 9 and 30 feet tall. 110 Originally introduced into the United States in the 1800s for erosion control and windbreaks, giant reed has become a nuisance weed in many states. However, its fast growth and high yield have led to its consideration as a biomass feedstock, and a number of projects across the country are underway and others have been proposed, despite the plant s invasiveness. Biomass Potential Because it is fast growing and hardy, giant reed is considered to be a high quality source of biomass, with the potential to generate more than 20 tons of biomass per acre within two years of initial planting. In some warmer areas, such as the Gulf Coast, the plant may produce as much as 35 tons per acre. 111 In addition to its high yield, giant reed can remove toxins from the soil, and so may have the added benefit of soil or remediation in degraded or polluted lands. 112 Invasive Status and Risk of Spread Giant reed is considered to be an invasive plant in much of its introduced range around the world; in fact, it has been listed as one of the world s 100 worst weeds. 113 In the United States, giant reed is listed as a noxious weed in Texas, 114 California, 115 Colorado, 116 and Nevada. 117 It has been noted as either invasive or a serious risk in New Mexico, Alabama, and South Carolina. 118 Giant reed in North America is not known to produce viable seeds, so technically it is considered to be sterile. However, the plant can spread through vegetative reproduction, either through underground rhizomes or, more often, through culm (stem) fragments, which can grow roots and form new clones. 119 Plant fragments can easily travel long distances downstream during storms, or become established along roadways after the grass has been harvested and is being transferred for processing. In fact, even a small Aerial view of Arundo donax invading riparian areas near Big Bend National Park, Texas. Credit: John Goolsby, USDA. vegetative nodal fragment of giant reed floating downstream can become established and form a large weedy stand. 120 Giant reed has been ranked as a likely invasive species on at least three published weed risk assessments (WRAs). 121,122,123 Researchers applying one such WRA to giant reed in Florida concluded that the plant should be rejected for use as a biofuel crop, saying that The combination of widespread distribution of giant reed propagules and inherent weedy characters greatly increases the likelihood of escape and subsequent environmental damage. 124 Furthermore, it is unknown how propagules may be spread in hurricane-prone regions of the country, where much of the production is proposed. Potential Impacts Because giant reed plants need lots of water, they commonly invade riverbanks, riparian areas, and floodplains, competing for scarce water supplies. In California as well as Texas, giant reed has formed virtual monocultures along streams and rivers, choking out native vegetation. 125 Close to 30,000 hectares of riparian land in Texas are now estimated to be dominated by Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 14

18 giant reed. 126 In California, a number of at-risk species, such as the Least Bell s Vireo (Vireo bellii pusillus), Southwestern Willow Flycatcher (Empidonax traillii extimus), and Yellowbilled Cuckoo (Coccyzus americanus), could be significantly impacted by the displacement of native riparian vegetation by giant reed. 127 Giant reed also provides less shade to streams than native woody vegetation, which can lead to increased water temperatures and invasion of other aquatic plants, in turn affecting the habitat quality for aquatic wildlife species. 128 Additionally, leaf litter in streams from giant reed that has invaded streambanks can lead to lower growth rates of aquatic invertebrates. 129 Current or Planned Biomass Uses and Risks Florida: Florida Statute limits cultivation of nonnative plants, including GM plants, for purposes of fuel production or other non-agricultural purposes in plantings greater in size than two contiguous acres. 130 However, the state has granted several notable exceptions via special permits. In April 2010, the state of Florida approved one such permit to White Technology, LLC, to allow the planting of 80 acres of giant reed for biomass energy. 131 In January 2011, another permit to White Technology was approved for an additional 87 acres. 132 Another company, Biomass Gas and Electric has also been interested in planting the species in Florida particularly along the Gulf Coast and has been funding a research project on genetic improvement on giant reed. 133,134 Giant reed has already invaded native plant communities in several parts of Florida. While it is not currently classified as an invasive species in the state (it is considered naturalized ), as of 2006, it was reported to be growing outside of areas where it was purposefully cultivated in 23 of the 67 counties in the state. 135 Oregon: Around 100 acres of giant reed have been planted in eastern Oregon for use as a biomass energy feedstock at the Boardman Power Plant. Based on the success of this project, Portland General Electric will consider planting as much as 70,000 to 80,000 acres of giant reed per year. 136 The town of Boardman is located along the Columbia River, which raises concerns given the plant s ability to invade riparian areas. North Carolina: ChemTex International, LLC is currently pursuing plans to cultivate giant reed and giant miscanthus for use as a biomass feedstock in North Carolina. The company applied for a loan guarantee under the Biorefinery Assistance Program for construction and operation of a biofuels refinery in Sampson County, North Carolina. According to the environmental assessment for the project, approximately 15-20,000 acres would be used for growing giant reed and/or giant miscanthus, with a production capacity of approximately 20 million gallons a year. 137 Additionally, the U.S. Environmental Protection Agency (EPA) recently issued a direct final ruling in response to a petition from Chemtex allowing giant reed to qualify as a cellulosic biofuels under the Renewable Fuel Standard. 138 After environmental groups, including the National Wildlife Federation, submitted public comments raising concerns that the agency did not evaluate the invasive potential of the feedstock, EPA issued a notice withdrawing the final rule. EPA is currently in the process of addressing the concerns through the full rule-making process. 139 Methods of Control Once it has invaded an area, controlling giant reed is difficult and costly. Manual removal techniques alone are often not effective, as the plant has deep rhizomes from which it propagates. Chemical control using pesticides is usually necessary, which can create pollution problems, particularly since so much of the habitat in which the plant has invaded is near streams and rivers. Other techniques for control include burning and biological control, though neither is very effective. Officials in a number of states are spending millions of dollars in an attempt to control the species. In California, for example, costs range between $5,000 and $17,000 per acre to eradicate the weed. Other estimates put that cost as high as $25,000 per acre. 140 While the net revenues for alternative bioenergy feedstocks will vary considerably based on their respective yields, input costs, and commodity prices, and time needed for the plants to reach maturity, the general range is likely to be in the area of a few hundred dollars per acre per year, by comparison Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

19 Miscanthus (Miscanthus species) A round 15 perennial species of grasses make up the genus Miscanthus. Because of their ability to thrive on marginal, non-crop lands and their fast growth rates, a number of these species have been considered for their biomass potential, including Miscanthus sinensis and Miscanthus x giganteus, also known as giant miscanthus. Giant miscanthus, which has shown greater promise as a bioenergy crop in the United States, is a sterile hybrid cultivar of two miscanthus species, Miscanthus sinensis and Miscanthus sacchariflorus. Biomass Potential Giant miscanthus has been widely grown in Europe for a number of years as a bioenergy source. Research in the United States has found that it is far more efficient than corn grown for ethanol and requires less land and inputs to grow. 142 Additionally, giant miscanthus grown in Illinois was found to produce higher yields than switchgrass, a native grass that the U.S. Department of Energy (DOE) has identified as a promising feedstock for cellulosic biofuel. 143 Invasive Status and Risk of Spread ability to reproduce vegetatively is a characteristic that is particularly associated with invasiveness. 150 Because it can resprout from rhizomes, giant miscanthus could potentially spread during storm events, via transport to and from production fields (e.g. falling off of trucks), through irrigation ditches and other waterways flowing near tilled field margins, or even through animals that uproot plants in the fields, or a host of other potential pathways. Studies have found that giant miscanthus has a fairly low rate of spread, 151 and has been given a low-risk Weed Risk Assessment score by at least two sets of authors. 152,153 Of much greater concern than plantings of sterile giant miscanthus is research that is currently underway to field test a variety of giant miscanthus that produces viable seed. 154 Giant miscanthus that produces fertile seeds would significantly lower planting and establishment costs, 155 but would also significantly increase the risk of invasion to an extent that is wholly unknown the wind could easily spread viable seed into natural habitats. Seed dispersal experiments with sterile giant miscanthus indicate that the seeds can travel at least 400 meters in the wind. 156 Given the invasive status of the parent species as well as the fast growth rate, large seed dispersal Miscanthus sinensis, the parent species of the giant miscanthus, is listed as invasive species in Connecticut. 144 Similarly, Miscanthus sacchariflorus, the other parent species of giant miscanthus, is listed on the Massachusetts prohibited plant list. 145 The invasive potential of giant miscanthus is not yet fully understood; large scale production and field-size trials of the plant have only begun to be implemented in the United States. 146 Giant miscanthus has been cultivated in Europe for over 30 years, and there have been no documented cases of the plant unintentionally spreading or escaping cultivation 147,148 While giant miscanthus is a sterile hybrid cultivar, there is still concern that it could reproduce vegetatively. A number of features of giant miscanthus make it an ideal invasive weed it has the ability to resprout from below the ground, it grows rapidly, and it has efficient photosynthetic pathways. 149 The MIscanthus. Credit: Hazel Proudlove/Bigstock.com. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 16

20 range, and low input requirements of the hybrid plant, the risk of invasion for seeded giant miscanthus could be quite high. Additional study is particularly needed on the potential for seeded giant miscanthus to escape and become invasive. The way that giant miscanthus plantings are established has major implications for how likely it is to become invasive. Current projects in the United States mostly use giant miscanthus that is vegetatively propagated, due to the fact that the seeds of the plants are sterile. However, this method leads to expensive planting costs, so other possibilities are being considered, including the creation of seed production fields which could be planted with the two parent species of giant miscanthus, M. sinensis and M. sacchariflorus. The fields would then generate the hybrid giant miscanthus seeds, which could in turn be planted by farmers. 157 The risk of viable seed production by the giant miscanthus plants would still be the same since they would still be sterile hybrid plants. Although the fields will be harvested for seed before the seeds disseminate, the creation of such seed production fields still creates an invasion risk, particularly given the invasive nature of the parent species. Potential Impacts Miscanthus sinensis can displace native grasses and dominate roadsides and pastures, likely because of its ability to tolerate harsh conditions such as poor soils, cold temperatures, and shade. 158 Studies have demonstrated that giant miscanthus may be more efficient and have higher yields than native, locally adapted varieties of switchgrass. 159 Should seeded giant miscanthus escape into natural ecosystems, it is certainly possible that it could outcompete native grass species. Current or Planned Biomass Uses and Risks In the spring of 2011, USDA made several announcements regarding funding for projects to grow biomass feedstocks through the Biomass Crop Assistance Program (BCAP), which was established as part of the 2008 Farm Bill. The program provides financial assistance to farmers in establishing energy crops in the form of a cost-share and annual payments for five years. 160 As part of the BCAP program, USDA is funding a project sponsored by Aloterra Energy and MFA Oil Biomass LLC to establish and produce 200,000 acres of giant miscanthus in Missouri, Arkansas, Ohio, and Pennsylvania. 161 After the final environmental assessment was published, USDA issued an addendum for the project, stating that farmers must only use the Illinois clone of giant miscanthus, which is sterile. Additionally, the addendum states that farmers must agree to a number of practices to reduce the potential for giant miscanthus to spread; for instance, farmers must monitor and report on the potential spread of giant miscanthus beyond the perimeters of the field, and they must not plant giant miscanthus within 1300 feet of any known M. sinensis or M. sacchariflorus plants to prevent cross-pollination. 162 Additionally, the USDA recently released a draft environmental assessment for another BCAP project, sponsored by the company REPREVE Renewables LLC, to pay farmers to plant an additional 58,000 acres in Georgia, South Carolina, and North Carolina. 163 All of these acres would be planted with vegetatively propagated giant miscanthus. In addition to the giant miscanthus projects, there are field trials underway across the country of a seeded variety of giant miscanthus. Mendel Biotechnology has created the PowerCane TM seeded miscanthus. The company is currently undergoing testing at sites across the country and development trials in Georgia, Tennessee, Kentucky, Indiana, and California, as well as creating a series of best management protocols for monitoring, reporting, and eradication. 164 Mendel is aiming for a commercial launch in 2014 or Methods of Control Giant miscanthus is only beginning to be planted in the United States and the economic costs of eradication are not yet known. Eradication studies indicate that 95 percent of the aboveground biomass can be successfully eliminated through spring tillage, followed by an application of the herbicide glyphosate; however, complete control of mature stands of giant miscanthus are likely to require more than one growing season Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

21 Genetically Modified Eucalyptus (Eucalyptus grandis x Eucalyptus urophylla) Nvarieties of eucalyptus that are highly productive are very ative to Australia, eucalyptus trees are extremely fast growing, making them a potentially ideal source for woody biomass. However, many of the sensitive to freezing temperatures, particularly when they occur as cold snaps rather than as progressively colder temperatures in a winter season. To get around this problem, researchers have genetically modified eucalyptus to improve the trees tolerance of cold temperatures as well as droughts. 166 These genetically modified, hybrid eucalyptus trees (Eucalyptus grandis x Eucalyptus urophylla) also include a gene splice that restricts the ability of the trees to reproduce. Biomass Potential Certain eucalyptus species make ideal woody energy crops because they have high biomass productivity, a short rotation time, and relatively high levels of cellulosic carbohydrates (the primary resource for energy production). 167 Some hybrid eucalyptus species have a potential to produce over 15 dry tons of biomass per acre per year. Within 27 months, eucalyptus trees can grow as high as 55 feet - which is extremely fast, particularly when compared with the pine plantations that are currently growing in the Southeast. 168 Invasive Status and Risk of Spread Genetically modified hybrid eucalyptus has not been grown in the United States until recently; the invasive potential of the species is unknown. One of the parents of the hybrid species, Eucalyptus grandis, is predicted to be invasive according to an assessment by the University of Florida. 169 Additionally, a number of other eucalyptus species are invasive in parts of the United States, including Eucalyptus globulus, which is listed in the California Invasive Plant Inventory. 170 Because GM eucalyptus trees are spliced with a gene that restricts their ability to reproduce, the companies that are producing the trees believe that there is little to no risk that the trees will Eucalyptus trees in Hawaii. Credit: Mike Brake/Bigstock.com. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 18

22 become invasive and overtake natural forests. Yet field trials are just beginning for these trees, so there is no real proof that the trees and their offspring will be 100 percent sterile. Upon granting the biotech company ArborGen a permit to begin field trials of GM eucalyptus trees in the southeastern United States, the USDA issued a Finding of No Significant Impact on the environment, noting in particular the small scale of the field trials and the specific conditions necessary for tree growth. 171 However, thousands of comments were submitted to the agency expressing concern about the potential environmental impacts of genetically modified eucalyptus, including comments from the Georgia Department of Natural Resources opposing the project in part because of concerns about invasiveness. 172 One such concern is whether there is a chance for the transfer of the cold-tolerance gene to non-sterile varieties of eucalyptus, which would increase its potential to inhabit areas previously considered too cold. While the conditions associated with gene transfer are complex and uncertain and would likely depend on the mechanism of sterility, the potential for such hybridization is not unprecedented between GM crops and their wild relatives. 173 Potential Impacts Because so little is known about GM eucalyptus, the potential impacts on biodiversity should the plants escape into the wild are uncertain. One concern is the potential for increased and widespread forest fires should the GM eucalyptus become widespread, due to the fact that the oils in eucalyptus trees may make the vegetation flammable and the bark of many can form fire brands that can spread fire far beyond the flaming front. 174 Additional concerns have been raised that widespread invasion or plantings of GM eucalyptus in the southeast could have serious hydrological impacts, including altered groundwater levels and/or stream flow, which could potentially impact aquatic and terrestrial species. 175 Furthermore, some eucalyptus species are known to have allelopathic qualities (i.e., they produce chemicals that impede the germination and growth of surrounding vegetation), which would limit the potential value of groves as wildlife habitat. 176 Current or Planned Biomass Uses and Risks In 2010, the USDA granted a permit to ArborGen, LLC to grow GM eucalyptus trees in field trials on 330 acres in 28 sites. The sites are spread out in seven states throughout the south: Texas, Louisiana, Alabama, Mississippi, Florida, Georgia, and South Carolina. This permit is in addition to a previous permit given to Arborgen to grow GM eucalyptus on 37 acres on 15 sites in the same seven states. 177 The new permit was granted after the USDA s Animal and Plant Health Inspection Service (APHIS) completed an environmental assessment for the controlled field trial and issued a Finding of No Significant Impact. 178 A number of environmental groups who were concerned that the environmental assessment was not thorough enough took legal action against the USDA, but the action ultimately failed. 179,180 Additionally, it should be noted that multiple other non-gm species and hybrids of eucalyptus are being developed for cultivation particularly in the southeast, some of which may be potentially invasive. Methods of Control Because genetically modified eucalyptus has not yet been widely adopted, the economic costs of control are unknown. However, invasions by other species of eucalyptus have been costly and difficult to control. For example, efforts to eradicate Eucalyptus globulus through logging and other measures in Angel Island State Park in California took ten years; however, with logging and herbicide treatments, along with extensive restoration of native communities, the efforts were successful Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

23 Reed Canarygrass (Phalaris arundinacea) Reed canarygrass invading a riparian area in Alaska. Credit: Tom Heutte, USDA Forest Service, Bugwood.org. Atall perennial grass, which can reach up to heights of nine feet, native of Europe, Asia, and North Africa, reed canarygrass was first introduced to the Pacific Northwest in the early 1900s. Over the years, this has been used as a breaking in crop to help prepare former forested land for cropping, as forage for livestock, and more recently as a water management tool. 182 There are different ecotypes of reed canarygrass, and some speculate that there may be an ecotype of the species that is in fact native to parts of the northwest United States, although there has not been scientific consensus on the issue. 183 Biomass Potential Reed canarygrass is a particularly hardy species due to its ability to grow in wet soils and to tolerate droughts better than most wetland species. 184 Combined with high yields (in some states it has been found to produce higher yields than switchgrass) reed canarygrass is a particularly good candidate for biomass production. 185 Additionally, reed canarygrass is a cool-season grass, while many other grasses cultivated for biomass like miscanthus and switchgrass are warm season grasses. Thus, it can be harvested in early summer when Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 20

24 warm-season grass biomass is not available, allowing for a more constant biomass supply for a region. 186 Invasive Status and Risk of Spread Reed canarygrass is currently present in 43 U.S. states. 187 It is considered to be an invasive or noxious species in three states: Connecticut, Massachusetts, and Washington. 188 Researchers at the University of Vermont have described reed canarygrass as one of the most noxious invasive species in North American wetlands, rivers, and lakes. 189 Reed canarygrass can spread through seeds or plant fragments, or vegetatively through rhizomes. The latter pathway is typically credited for its remarkable ability to spread. Reed canarygrass spreads particularly well in disturbed areas, although it has also been known to invade native wetlands. Potential Impacts Reed canarygrass can be particularly problematic in wetlands and disturbed areas, outcompeting native species, forming dense mats, clogging shallow streams and ditches, and even impeding water flow. 190,191 Once it has taken over wetland areas, the dense stands offer poor quality habitat for wildlife, such as waterfowl, that depend on wetlands for cover, habitat, and food. 192 Reed canarygrass is estimated to have invaded thousands of acres of wetlands throughout the country. 193 The weed is a particular problem for wet meadows in the Upper Midwest, where the grass forms dense monocultures and shades out native grasses and forbs. 194 Native species that begin to grow in the late spring are particularly impacted by reed canarygrass. 195 potential in the Eastern Upper Peninsula (EUP) of Michigan, for instance, looked at both the use of currently existing acres of the invasive weed as well as the possibility of planting more and concluded that, Reed canarygrass thus represents an economic potential for the EUP both in terms of reducing fuel costs and providing another source of income for area farmers. 197 Reed canarygrass has also been tested for use as a biomass feedstock in Pennsylvania, 198 Ohio, 199 Wisconsin, 200 and Iowa, 201 among other places. Methods of Control Because it is such a hardy species, reed canarygrass is particularly expensive and difficult to control. It is resistant to burning and flooding 202 and has an abundant seedbank that can last for years. 203 Typical management regimes to eradicate stands of reed canarygrass include a combination of hand pulling, mowing, burning, and chemical treatment over a few years, followed by monitoring for many more years. Current or Planned Biomass Uses and Risks Reed canarygrass is currently being cultivated on thousands of acres for biofuel production in Europe, 196 but it has yet to be adopted in the United States as a biomass feedstock in any capacity beyond research studies. However, there have been a number of studies devoted to assessing the potential of growing reed canarygrass in the United States for bioenergy production. A study looking at the weedy plant s A field of reed canarygrass. Credit: Chris Evans 21 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

25 Algae Ocyanobacteria) and macroalgae (e.g. seaweeds such as ne of the fastest growing fields in biofuels research is that of algae, including both microalgae (small unicellular organisms, including diatoms and Laminaria, Sargassum, and Gracilaria species). 204 This explosive growth has been driven in large part by the federal government, particularly the DOE, which has invested millions of dollars in algae biofuels research and created a National Algal Biofuels Technology Roadmap towards the commercialization of algal biofuels. Algae are especially promising sources of bioenergy because they do not require soil or arable land for growth rather, they are cultivated in freshwater or saltwater, either in open-air ponds or contained systems. There are thousands of species of algae, and both native and non-native algae species are being considered as biomass feedstocks in the United States. 205 Additionally, there has been considerable interest in genetically modifying algae to optimize biofuel production. 206 Biomass Potential Algae are being evaluated and tested for use as a feedstock for production of starches for alcohol (i.e. cellulosic ethanol), lipids for diesel fuel, as well as a source of hydrogen (H2) for fuel cells. Compared to terrestrial plants used for biomass, both microalgae and macroalgae more efficiently convert solar energy into usable energy. 207,208 For example, per unit area, microalgae can produce up to 250 times more oil than soybeans. According to some researchers, (p)roducing biodiesel from algae may be the only way to produce enough automotive fuel to replace current gasoline usage. 210 Additionally, algae are a particularly attractive feedstock for biofuels because some species can be grown in saltwater or wastewater, and can be used to produce a variety of fuel types. 211 Invasive Status and Risk of Spread A number of species of algae are listed on various invasive species lists in the United States. For example, there are approximately two dozen non-native macroalgae species found in Hawaiian waters, about half of which are reported as invasive. 212 Statewide, the economic cost of controlling these invasive algae is estimated at well over $20 million per year. 213 Given the vast number of algae species in existence and the rapid pace of algae research and Algae being processed for biofuel. genetic modification, there Credit: Sandia National Laboratories. is very little known about the invasion potential of the species that are currently being cultivated in labs and commercial facilities. However, several traits specific to algae suggest the potential for invasiveness. For example, microalgae can easily aerosolize and spread, leading to a high potential for such algae to escape from a biomass production facility; indeed, and there have already been cases of algae escaping into the environment from research labs. 214 Natural strains of algae from a Californiabased bioenergy company, for instance, have been carried out on skin, on hair, and all sort of other ways, like being blown on a breeze out the air conditioning system. 215 According to a researcher at University of Kentucky, complete containment of algae is completely impossible. 216 This raises particular concerns regarding the use of invasive, exotic, and genetically modified strains of microalgae. While open ponds will likely pose considerably higher risk, even in a closed system, algae might be able to escape through ventilation systems or even on the clothes of workers. Macroalgae, which grow from spores, also may be transported unknowingly to new areas and remain dormant for some time before their growth is spurred by favorable environmental conditions. 217 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 22

26 Potential Impacts Little research has been conducted on potential for nonnative or modified strains of algae cultivated for biomass energy to escape into natural ecosystems, and the potential impacts on biodiversity are not well understood. Proponents of genetically modified algae believe that the risks posed to native ecosystems are low and that the algae are unlikely to survive or thrive outside of highly controlled labs or facilities. However, the extraordinarily fast growth rate of algae as compared to other genetically modified crops, combined with their ability to adapt to a variety of environments, concerns many others. 218 Should algae cultivated for biomass escape and become invasive, the impacts on biological diversity, and particularly on aquatic habitats, could be devastating. For example, across the United States, the once-scarce Didyomosphenia geminata (also known as Didymo and rock snot ) has been rapidly expanding in streams, where it grows into huge, slippery mats that can expand the width of the river bed and crowd out native plants. In addition, the non-native cyanobacterium Cylindrospermopsis raciborskii (or Cylindro), another bioenergy feedstock candidate, has been associated with toxic algal blooms in the Great Lakes region. 219 Introduced macroalgae also can have significant impacts on native ecosystems and can change community dynamics through high abundance and monopolization of available space. 220 The macroalga Gracilaria salincornia, for instance, has become prevalent throughout the coastal waters of Hawaii, where it has rapidly overgrown and smothered coral reefs. 221,222 Current or Planned Biomass Uses and Risks At least a dozen oil companies and government research centers are currently working on genetically engineering algae for renewable energy production, 223 and many others are working on creating renewable fuels from non-genetically modified algae. There are also an assortment of different types of projects being investigated, including both closed systems and open air ponds, each of which carries different risks. Unfortunately, it is not always possible to find out which species a company is cultivating, whether the species is native or non-native, and whether they are modifying the species. Below is just a small sampling of some of the companies and research facilities that are currently working on creating energy from algae: University of Nevada, in conjunction with Enegis, LLC and Bebout and Associates, created the first demonstrationscale algae to biofuels project in Reno, Nevada. 224 While they began their research using single-celled algae that grow in saltwater, they now are experimenting with different types of algae that can be grown in wastewater, with the idea that the algae could both help to purify the wastewater and produce renewable fuel. 225 Solazyme: One of the most well known and successful algae energy companies is Solazyme, which recently signed a contract, along with some partners, to supply the U.S. Navy with 450,000 gallons of renewable fuels. The fuels will be made from used cooking oil as well as algal oil from Solazyme. 226 Using fermentation tanks, the company utilizes genetically modified microalgae in the absence of light to convert sugars from plant feedstocks such as sugarcane-based sucrose or corn-based dextrose to create oil. 227,228 Aquatic Energy: Based in Louisiana, Aquatic Energy has an open-pond, freshwater algae farm in southwestern Louisiana that they use to create algal oil and meal, both of which can be used by refineries to create fuels. According to their website, the company uses non-genetically modified proprietary algae strains, which are domestic and natural. 229 Methods of Control Should a species of algae become invasive and begin to affect biodiversity or lead to economic losses, the cost of eradicating the invader could potentially be considerable. For example, in southern California, the cost of eradicating one invasive marine macroalga, Caulerpa taxifolia, from one lagoon was approximately $3.34 million and took over five years. 230 In most cases, eradication of invasive algae probably is not even technologically feasible. 23 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

27 Napiergrass (Pennisetum purpureum) Na forage crop for livestock grazing, given its ability to quickly apiergrass, also called elephant grass, is a tall, clump-forming grass native to Africa. The plant has been introduced in many tropical regions for use as produce large amounts of biomass. 231 It was introduced in the early 1900s to areas of Texas and Florida and promoted by the Bureau of Reclamation as a forage crop, 232 but since then it has become a highly troublesome weed. Biomass Potential As with other fast-growing, rhizomatic grasses, napiergrass is considered a premier biomass plant. 233 In the 1980s, it was used as a feedstock for methane generation and also was co-fired with coal to produce electricity. Today, it is seen as a promising feedstock for cellulosic ethanol. In north-central Florida, it has yielded as much as 20 tons per acre per year in dry biomass, depending on available rainfall and fertilization. In addition, it can be harvested twice a year, making it particularly useful as a dedicated energy feedstock. Research is currently underway to try to develop non-invasive, genetically improved genotypes of napiergrass through elimination or reduction of gene dispersal of the species by pollen and seeds. 234 Invasive Status and Risk of Spread Napiergrass has been identified as one of world s most problematic weeds and is listed as a category 1 invasive species by the Florida Exotic Pest Plant Council. 235,236 Category 1 species are defined as Invasive exotics that are altering native plant communities by displacing native species, changing community structures or ecological functions, or hybridizing with natives. 237 Napiergrass has been documented in nearly 30 counties throughout the state, where it has taken over areas of canal and ditch banks, blocking access and impeding water flow. 238 Napiergrass was ranked as having a high probability of becoming invasive on at least two published weed risk assessments (WRAs). 239,240 Napiergrass can reproduce both vegetatively and through seed dispersal, Napiergrass being cultivated in Florida. Credit: Julie Sibbing. and it can grow very quickly. Because napiergrass is freezeintolerant, its potential spread (and use for bioenergy) is limited to southern regions. Potential Impacts Napiergrass is an invader of a number of different types of habitats and disturbed areas, including canal banks, fields, lake shores, swamps, croplands, and prairie habitats. 241 Because of its dense growth, the grass prevents regeneration of native species by crowding out grasses, herbs, and tree seedlings. 242 Additionally, the dense growth of napiergrass can reduce water flows and block access to canals. 243 Current or Planned Biomass Uses and Risks Vercipia Biofuels, owned by BP Biofuels North America, has plans in the works to build what they believe will be the first commercial-scale cellulosic biofuels production facility in the country. Located in Highlands County, Florida, the facility will use a variety of different perennial feedstocks, including napiergrass. 244 They are currently developing a seed farm to Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 24

28 Napiergrass. Credit: Dan Clark, USDI National Park Service, Bugwood.org. ensure sufficient quantities of the feedstocks. 245 According to the EPA, continued development of napiergrass as a bioenergy crop is likely throughout much of Gulf Coast region, including Florida and southern portions of Texas, Louisiana, Georgia, Alabama, and Mississippi. 246 Additionally, the EPA had recently issued a direct final rule that would allow napiergrass (in addition to giant reed) to qualify as a cellulosic biofuels under the Renewable Fuel Standard. 247 However, after environmental groups submitted public comments raising concerns that the agency did not evaluate the invasive potential of the feedstocks, EPA issued a notice withdrawing the final rule. EPA is currently in the process of addressing the concerns through the full rule-making process. 248 Methods of Control The only ways to control napiergrass invasions are through mechanical or chemical means; however, because napiergrass can spread easily via vegetative cuttings, tillage is not recommended. In fact, according to researchers at the University of Florida s Institute of Food and Agricultural Sciences (IFAS) Extension, cultivation can actually cause larger infestations of napiergrass by breaking mature plants into pieces and distributing them throughout the field. 249 According to a researcher at the USDA, it is precisely because the species is so difficult to control and eradicate that it has become such a nuisance in tropical areas Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

29 5 Minimizing the Risks The Importance of Embracing Precaution As investments in bioenergy continue to grow, maximizing the benefits and minimizing the costs and unintended consequences associated with bioenergy development will be a key challenge. As this report has shown, the potential ecological and economic costs that would come if bioenergy feedstocks escape and become invasive are likely to be considerable. Yet, all too often the long-term costs associated with invasive species are not realized until it is essentially too late to avoid them. The potential for irreversible harm underscores the paramount importance of taking a precautionary approach. 251 America must strive to better understand the risks of invasions from current and proposed bioenergy feedstocks and to focus our strategies first and foremost on prevention. Most critically, crops that are currently invasive or pose a significant risk of becoming invasive should not be cultivated as bioenergy feedstocks without comprehensive mitigation strategies in place that greatly reduce the risk of escape and invasion. It is important to note that non-native and genetically modified feedstocks are not the only options available for bioenergy production. For example, using mixes of noninvasive plant species that are local to the region where they are being proposed for cultivation is a promising way to reduce the risk of invasion while still allowing for profitable bioenergy production (see Box 2). Current Regulation of Invasive Species Switchgrass, a native grass, being harvested for bioenergy. Credit: Oak Ridge National Laboratory. America must strive to better understand the risks of invasions from current and proposed bioenergy feedstocks and to focus our strategies first and foremost on prevention. In order to identify ways in which we can better reduce the risks from invasive bioenergy feedstock development, it is useful to understand the primary federal and state policies and programs governing invasive species 26

30 Box 2. Creating Energy from Native Plants N ot all bioenergy companies are focusing on non-native feedstocks. There are a number of promising projects using native, locally adapted species as feedstocks. Other projects use sustainably harvested wood from forests or rely on waste and byproducts from manufacturing operations. Show Me Energy The Show Me Energy Cooperative, based in Missouri, offers a great example of how growing native plants for bioenergy can be both profitable and environmentallyfriendly. Show Me Energy is a biomass cooperative that is owned and operated by over 600 farmers in 38 counties in Missouri and Kansas. These farmers collect residues from common agricultural crops, and also plant native perennial crops on 50,000 acres of marginal land using the best conservation practices available, including using polycultures and timing the harvest for the late fall to avoid bird nesting and brood-rearing season. The grasses and legumes currently used for the project include: big bluestem (Andropogon gerardii), switchgrass, indiangrass (Sorghastrum nutans), Canada wild rye (Elymus canadensis), Virginia wild rye (Elymus virginicus), purple prairie clover (Dalia purpurea) and Illinois bundleflower (Desmanthus illinoensis). 252 In May 2011, USDA announced that Show Me Energy would become the first dedicated energy feedstock project funded under the Biomass Crop Assistance Program. Parabel Previously called PetroAlgae, the Melbourne, Floridabased company Parabel uses micro-crops of tiny, non-genetically modified aquatic plants to create both a renewable energy feedstock as well as a protein source that can be used for animal feed and potentially as a human food. 253 The energy that the company creates Native aquatic plants being grown for energy at Parabel. Credit: Julie Sibbing. from the aquatic plants is in the form of biocrude, a type of oil made from biomass which can be converted into a number of different forms of energy. 254 Parabel currently has a commercial demonstration center in Fellsmere, Florida, which has been in operation since 2009, and is in the process of creating projects in Chile and Surinam using species that are local to the regions where the sites will be located. 255 Middlebury College Biomass Plant In 2009, Middlebury College began operations of its $12 million biomass gasification boiler as part of a campus plan to achieve carbon neutrality by The biomass plant is fueled by wood chips between 20 and 35 tons are delivered per day all of which come from wood that is harvested within a 75 mile radius of the campus. Most of the wood chips are byproducts from local logging operations or from mill waste. The biomass plant uses the wood to create steam, which then powers campus heating, cooling, hot water, and cooking operations. 256 The college is also investigating other potential sources of biomass, and is currently using test plots to determine the feasibility of growing willows near the campus Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

31 and genetically-engineered plants. Importantly, the development of policies to address invasive species has necessitated clear definitions of relevant terms, such as alien, exotic, non-native, invasive, and noxious weed as these terms often mean different things for different people (see Box 3). Federal Regulation of Plant Species While the problems associated with invasive species have long been a national concern, the federal laws that currently address invasive species are generally a mixture of diverse provisions and multiple jurisdictions, which often lack coordination and consistency. 263 In its 1993 assessment of the nation s invasive species programs, the Office of Technology and Assessment concluded that [t]he current Federal framework is a largely uncoordinated patchwork of laws, regulations, policies, and programs, and that invasive species issues often receive governmental attention on a piecemeal basis after major infestations have occurred. 264 Some of the most-developed laws regulating invasive species are those associated with threats to agriculture under the authority of the USDA, although there are also several laws that address threats to other economic sectors, as well as fish and wildlife. While a complete review of existing policies and programs is beyond the scope of this report, there are several key statutes relevant for bioenergy feedstocks. For example: Plant Protection Act of The Plant Protection Act of 2000 (PPA) consolidated USDA authority over noxious weeds and plant pests into a single statute. 265 Importantly, the PPA expands the definition of noxious weed, which previously had been defined under the 1974 Federal Noxious Weed Act, to include injury to the environment. 266 Inclusion of a species on the federal Noxious Weed List prohibits subsequent movement of the plant within the United States. The statute, however, provides authority for prevention of noxious weeds, but not eradication or remediation of already established noxious weeds on private lands. Moreover, terrestrial species are often not included on the federal Noxious Weed List until harm is well documented and the species is established over large ranges across the United States. 267 Although a 2004 amendment to the Box 3. Some Common Definitions Relevant to Invasive Species 258 Alien species. Generally defined as species that spread beyond their native range, not necessarily harmful, or species introduced to a new range that establish themselves and spread. 259 Similar terms include exotic species, introduced species, and non-native species. Non-native species. One of the most commonly used terms to describe plant or animal species not originally from the area in which it occurs. May be defined as a species whose presence is due to intentional or unintentional introduction as a result of human activity. 260 Invasive species. This term is often the subject of confusion and debate. Under Executive Order 11322, it is defined as an alien species whose introduction does or whose introduction is likely to cause economic or environmental harm or harm to human health. Noxious weed. Defined in federal law 261 and in most state codes, denoting special status of a plant as restricted or prohibited. Commonly defined as native or non-native plants, or plant products, that injure or cause damage to interests of agriculture, irrigation, navigation, natural resources, public health, or the environment. 262 As a general rule, plants designated as noxious have regulatory restrictions, while other designations (e.g., invasive or non-native) do not. Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 28

32 PPA authorized USDA to provide financial and technical assistance to state/local weed management agencies to control or eradiate established weeds, 268 Congress has not appropriated funding for this program. U.S. Executive Order # Although USDA has the primary responsibility for noxious plant species control at the federal level, at least thirteen federal departments and agencies exercise some authority over invasive species. To coordinate these efforts, in 1999 the President established via executive order the National Invasive Species Council (NISC). 269 Specifically, EO states: Each Federal agencies whose actions may affect the status of invasive species shall, to the extent practicable and permitted by law not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless the agency has determined that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions. Importantly, this executive order could apply to federal subsidies directed to bioenergy crops that may have invasive characteristics. 270 The new emphasis on prevention is important, as most prior efforts to address invasive species largely focused on those that had already been introduced into the country. However, the particular challenge in addressing the potential invasiveness of a bioenergy feedstock under the efforts established under EO is how decision makers ultimately determine the respective benefits versus the costs or harm from its use. 271 State Regulation of Invasive Plants State regulation of harmful plants dates back more than a century, as many states recognized the threats that noxious weeds posed to agriculture. Today, states still bear the primary responsibility for the on-the-ground prevention, control, and management of invasive species, and each state government has developed unique and diverse webs of authorities to address different species and, to a lesser extent, invasion pathways. 276 Typically, states use lists to identify species that should be restricted and those that are considered safe. The general rule has been the development of so-called black lists, which regulate only species that have been designated as problematic by the legislature or agency. White lists, on the other hand, identify species that the government deems safe all other species are presumed to be harmful unless they have undergone a process to determine that they are not. 277 Currently, administrative agencies in forty-seven states (usually departments of agriculture, but occasionally departments of natural resources) have authority to add species to Figure 1. Regulated plant species are a function of both federal and state noxious weed lists The Biomass Crop Assistance Program (BCAP). Congress established BCAP as part of the 2008 Farm Bill to provide assistance for farmers transitioning to biomass crops. 272 BCAP was the first federal subsidy program for the production of biomass. 273 The program provides matching payments for the collection, harvest, storage and transportation of biomass (commonly referred to as CHST payments), as well as separate payments for the establishment of perennial biomass crops. CHST payments are available for the collection, harvest, storage, and transportation of existing invasive and noxious species, 274 but USDA may not provide establishment payments in support of any plant that is noxious or invasive. 275 State noxious weed list (varies by jurisdiction) Federal noxious weed list (7 C.F.R ) 29 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

33 their respective state noxious weed list. However, lists at the state level tend to be highly reactive listing species only after there is significant damage to agricultural production or the environment. Additionally, state and regional Invasive Plant Councils (IPC) or Exotic Pest Plant Councils consisting of weed ecologists, land managers and other stakeholders have the technical competence to identify potential invasive plant species, but often do not have an advisory role, much less actual authority, to include these species on the state s official noxious weed lists. Demonstrating this disconnect between the IPCs and the noxious weed lists, a recent study found that, on average, official state noxious weed lists only included 19.6 percent of the species considered invasive by the respective state invasive plant council. 278 Only five states (MA, CT, OR, NH, and WA) had noxious weed lists that contained more than 50 percent of the invasive species identified by the respective IPC. The current multi-jurisdictional approach to noxious weed regulation leaves many terrestrial invaders largely unregulated at both the state and federal level, as these plant species often are not included on either federal or state noxious weed lists (see Figure 1). State noxious weed lists, designed to supplement the federal list by tailoring invasiveness to state-specific ecosystems, generally fail to include known invasive plants. Moreover, many states lack authority (or refuse to exercise their power) to enforce state weed control laws on private property. Civil liability for the spread of weeds onto an adjacent landowner s property also varies widely across states, with some courts reluctant to require control over natural plants. Accordingly, there is minimal incentive for individual landowners to control noxious plant species absent an impact on agricultural productivity. At least one state has been proactive in enacting a regulatory program designed to address the potential invasiveness of large-scale cultivation of bioenergy crops. In 2008, Florida implemented a permitting requirement for cultivation of non-native plants (including genetically engineered plants) intended for biofuel production. 279 Biomass plantings spanning more than two acres require a permit from the Florida Department of Agriculture and Consumer Services. The permit also includes a bonding requirement, the proceeds of which would fund eradication efforts of invasive bioenergy crops. The Department, in consultation with the University of Florida s Institute of Food and Agriculture Sciences (IFAS), may exempt non-native biomass plantings from the permit requirement if it determines that plant is not invasive. Conversely, because plant species have to be listed as noxious or invasive plants or be determined to be invasive to be denied permits, the permitting process does not necessarily prevent the cultivation of potentially invasive plants such as giant reed (Arundo donax) or napiergrass (Pennisetum purpureum) that are not listed on Florida s noxious weed list, unless the bond represents a sufficient disincentive that cultivation plans are abandoned. A proposed statute in Mississippi would enact a similar regulatory program, providing authority for the Department of Agriculture to deny permits for invasive plants or plants with the potential to constitute a nuisance. 280 The current multi-jurisdictional approach to noxious weed regulation leaves many terrestrial invaders largely unregulated at both the state and federal level, as these plant species often are not included on either federal or state noxious weed lists. Biotechnology Regulation As is the case with invasive species, the regulation of genetically-modified (GM) products is handled by multiple agencies under multiple statutes. 281 The United States regulates the field testing and commercialization of GM plants under a 1986 agreement known as the Coordinated Framework for the Regulation of Biotechnology (Coordinated Framework). 282 This complex, multi-agency agreement sets up a trifurcated regulatory system, with oversight by: 1) the USDA to prevent introduction of agricultural pests under its Federal Plant Pest Act (PPA) authority; 283 2) the EPA to regulate pesticides incorporated into plant tissue through Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 30

34 its Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) regulatory powers; 274 and 3) the U.S. Food and Drug Administration (FDA), via the Federal Food, Drug, and Cosmetic Act (FFDCA), 285 to ensure the general safety of food and feed products produced with the use of GM technologies. USDA s authority to review GM plants under the PPA is premised on two statutory provisions: whether the novel plant is a potential plant pest or a noxious weed. 286 Accordingly, USDA jurisdiction extends only to plants regulated as plant pests or noxious weeds not every plant altered through genetic engineering. A GM plant would fall under USDA plant pest jurisdiction if the donor, recipient, vector or vector agent used in the genetic engineering is listed as a plant pest in the USDA regulations or there is otherwise reason to believe it is a plant pest. If the GM plant is believed to be a plant pest, introduction of the plant material may be allowed without a permit, but only in accordance with specific criteria to ensure that it is contained. Only after field trials demonstrate no significant risk of invasiveness can a company petition APHIS for non-regulated status. Two recent USDA decisions discussed below illustrate how GM bioenergy crops may avoid review under the Coordinated Framework. In 2008, USDA determined that a GM petunia (Petunia) modified to produce a novel color was not subject to regulation under the PPA because neither the recipient, donor, vector, nor vector agent was a plant pest under existing regulations. 287 As a plant not intended for food or feed, the GM petunia also avoided FDA review under the FFDCA. Moreover, as the plant did not incorporate a pesticide or change the use of any externally applied pesticide, the EPA lacked jurisdiction to review the plant under its FIFRA authority. In sum, the petunia slipped through a loophole in the Coordinated Framework. In 2011, a variety of Kentucky bluegrass (Pao pratensis) genetically engineered to tolerate the herbicide glyphosate similarly evaded USDA review under the PPA. 288 Non-GM bluegrass was not listed as a plant pest and the organisms used as a source for the new genetic material to infer herbicide tolerance were similarly not regulated as plant pests. The USDA also rejected a parallel petition to regulate the GM bluegrass as a noxious weed due to its herbicide resistance. 289 Moving forward, to the extent that novel GM bioenergy Not all genetically modified plants are subject to regulation in the United States. Credit: Sebastian Duda/Bigstock.com. 31 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

35 feedstocks follow the pathway carved by the GM petunia and bluegrass petitions, and do not include plant incorporated pesticides subject to EPA review, or have residual uses as food or forage that may trigger FDA s jurisdiction (e.g., USDA currently is conducting environmental assessments for eucalyptus trees genetically engineered for cold tolerance 290 ), many novel dedicated bioenergy plants may forego the Coordinated Framework entirely. Screening Tools The considerable ecological and economic threat posed by invasive species has generated national and international protocols to screen non-native species being considered for human uses in order to evaluate potential risks. For example, Australia has developed a model weed risk assessment (WRA) system to screen all new plants before they enter the country by applying a sieve approach, which applies a set of questions to determine potential invasiveness and then approves some species, rejects others outright, and conditionally rejects the rest. 291,292 Nearly a dozen independent studies found that the Australian WRA consistently was able to identify invaders. 293 Additionally, the use of WRA has been found to provide net economic benefits by allowing authorities to screen out costly invasive species, even after accounting for potential revenues lost if a small percentage of plants have been rejected despite ultimately proving to be non-invasive. 294 The USDA has its own weed screening tool that is based on the Australian WRA, 295 and a similar WRA approach has been developed specifically for aquatic plants. 296 Screening potential bioenergy feedstocks with programs like WRA is especially important because of the inherent invasive qualities of many potential feedstock plants. 297 For example, a study that applied the Australian WRA approach in Florida and other areas of the United States found that a majority of proposed bioenergy crops analyzed present an unacceptable invasion risk in their respective target regions. 298 In addition, a study that applied WRA to potential biofuel crops in Hawaii suggests that, when compared to a sample of introduced non-biofuel species, biofuel crops were twoto four-times more likely to be naturalized or invasive. 299 Genetically modified Kentucky bluegrass is currently not subject to regulatory review by USDA. Credit: NRCS. While WRA has proven to be an important and effective tool, several researchers suggest that some of the more commonly-used risk assessment protocols may not address all of the issues that might determine the potential invasiveness of bioenergy crops, suggesting that more rigorous, multi-tiered approaches should be used particularly in cases where initial analyses indicate conditional rejection. 300 This may not only help identify species that are likely to be more problematic than initial WRA may have indicated, but it also may help determine where the risk might be lower than originally thought. Davis et al. (2011), for example, found that additional quantitative analysis of Camelina sativa, which would have been rejected under the Australian WRA protocol, indicated that its invasive potential is only a concern if it is cultivated in areas with disturbed soils. 301 Other factors that warrant explicit consideration in WRA for bioenergy feedstocks include those related to cultivation and management practices. 302,303 For Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 32

36 Screening potential bioenergy feedstocks is especially important because of the inherent invasive qualities of many potential feedstock plants. example, many biofuel feedstocks are harvested in late fall, after they have produced seed. This enhances the risk that the plants will be spread unintentionally when the feedstocks are transported to storage or production facilities. 304 Invasive potential also may be enhanced if biomass crops are planted over large geographical areas, where there is greater opportunity for escape. Additionally, because there can be considerable difference in invasion potential between different varieties of the same species, 305 it is critical that WRAs be used for each individual cultivar under consideration, not just each species. The sterile Illinois clone of giant miscanthus, for instance, is likely to have a much lower WRA score than PowerCane TM giant miscanthus, which has viable seeds. Finally, ecological risk assessments for bioenergy must address potential impacts of climate change, both near-term and long-term. So-called climate niche analysis is already commonly used by farmers and horticultural experts to determine regions of agronomic suitability (i.e., the ability to thrive in the particular climatic conditions and therefore require minimal additional inputs such as irrigation), as well as to identify regions climatically suitable to a potential invasion. 306,307 Such studies will continue to be important for identifying potential suitable areas as well as potential invasion risks from bioenergy crops. In particular, species with a broad range of climatic tolerance (a large climate niche) often are considered among the best candidates for bioenergy feedstocks, a factor that also enhances their invasion risk. However, while such studies typically look at historical/current climatic conditions to determine suitability, they also must include projected changes in climatic variables due to climate change. It is no longer enough to say that because climatic conditions outside of areas being considered for bioenergy crop cultivation are unfavorable for the species, the risk of escape and invasion is necessarily low. Giant reed (Arundo donax), which is currently being cultivated for bioenergy in some states, has been ranked as a likely invasive species on at least 3 published weed risk assessments. Credit: James H. Miller, USDA Forest Service, Bugwood.org. 33 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

37 6 Conclusions & Recommendations G iven the enormous problems we face from our continued reliance on fossil fuels to meet our energy needs, finding meaningful alternative energy sources is an important national priority. Energy from biomass resources is likely to be a significant part of America s energy portfolio in the decades to come. As this report shows, however, the use of non-native and genetically modified native species as bioenergy feedstocks can pose significant risks to native ecosystems. The six case studies highlighted in this report demonstrate that, despite the known invasiveness and harm of many non-native feedstock plants for bioenergy, these plants are nonetheless actively being promoted and used for bioenergy production. If we continue to implement bioenergy feedstock programs without sufficient consideration of the potential ecological and long-term economic costs, it will be only a matter of time until great damage occurs, either ecologically, economically, or both. Other than some recent initiatives to improve coordination, such as the establishment of the National Invasive Species Council (NISC), 308 the federal government s regulation of invasive plant species has been reactive, incremental, piecemeal, and focused primarily on protecting agricultural productivity. Its ineffectiveness is apparent with the numerous invasive species, including kudzu, common reed, and purple loosestrife that are causing widespread environmental and economic harm across the United States. Current laws and regulations are entirely insufficient to adequately prevent the establishment of new invasives, and to control those already causing problems. Exacerbating the inadequacy of existing programs to prevent invasive species, federal agencies such as USDA face a conflict of interest when they not only promote and support agricultural commodity production, including for bioenergy, but also have the responsibility for enforcement of noxious and invasive species statutes. Miscanthus growing in the shadow of the Washington Monument. Credit: Marilyn Jordan, TNC. If we continue to implement bioenergy feedstock programs without sufficient consideration of the potential ecological and long-term economic costs, it will be only a matter of time until great damage occurs, either ecologically, economically, or both.

38 These challenges are great, but they do not mean that bioenergy development should not go forward; rather, we must ensure that appropriate precautions are taken to develop and use safe bioenergy feedstocks that can help maintain and restore, rather than threaten, native habitats. Efforts are underway to identify some key actions that our nation can take to address the bioenergy challenge without exacerbating the invasive species problem. The federal Invasive Species Advisory Council (ISAC) has recommended nine priority actions to the NISC that would help ensure that the United States is able to meet its commitments to expand bioenergy while at the same time ensure that our important efforts to fight invasive species are upheld (See Box 4). 309 Box 4. The Invasive Species Advisory Council Recommends the Following Actions to Address the Invasive Potential of Biofuels 1. Review/Strengthen Existing Authorities. 2. Reduce Escape Risks. 3. Determine Most Appropriate Areas for Cultivation. 4. Identify Plant Traits that Contribute to or Avoid Invasiveness. 5. Prevent Dispersal. 6. Establish Eradication Protocols for Rotational Systems or Abandoned Populations. 7. Develop and Implement Early Detection and Rapid Response. 8. Minimize Harvest Disturbance. 9. Engage Stakeholders. Similarly, the International Union for Conservation of Nature (IUCN) has developed a set of recommendations on reducing the risk of invasion from bioenergy feedstocks from an international perspective (See Box 5). 310 Building on these recommendations from ISAC and IUCN, we emphasize several key actions that we believe must be taken in order to avoid the risk that continued bioenergy development in the United States will also fuel a growing invasive species catastrophe. Because the ecological and economic costs of invasions are so high, we believe that a precautionary approach is warranted. 1. Future bioenergy development should encourage ecological restoration and improve wildlife habitat through the use of ecologically beneficial biomass feedstocks such as waste materials and sustainably collected native plants and forest residues. The use of native grasses and other plants for bioenergy production offers a promising opportunity to support our growing energy needs while at the same time providing important habitat for a range of fish and wildlife species. To maximize benefits to wildlife, research and development of feedstocks from native grasses should emphasize mixtures of grass species interspersed with forbs and shrubs. Once established, mixtures of native prairie grasses and forbs can enhance overall biomass yields, particularly on areas with degraded soils. Specifically, research has shown that high diversity plots were found to be up to 238 percent more productive than monoculture plots, including plots of monoculture switchgrass that had significantly reduced yields on degraded soils. 311 Moreover, while the establishment of mixed prairie is more complex than establishing a monoculture crop, the benefits of establishing mixed native plantings may go well beyond high yield. Together, these plant communities can obviate the need for chemical inputs, support numerous species of wildlife, and offer benefits for water management, carbon sequestration, and other important ecosystem services. For example, research shows that biofuels derived from these low-input high diversity mixtures of native grassland perennials can offer a carbon negative option, as net ecosystem CO2 sequestration is greater than the fossil CO2 released during the biofuel production process Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

39 Box 5: IUCN s Key Recommendations on Biofuels and Invasive Species 1. Follow a precautionary approach when choosing feedstocks. Species should be chosen that minimize the risks to ecosystems and livelihoods from invasion, either by the feedstock species, or associated pests and diseases. Developers should also account for the possible costs of an invasion when choosing species. 2. Work with stakeholders to build capacity. Existing regulations are often robust enough in theory to reduce and contain risks of invasions. The main barrier to their effective enforcement and success comes from lack of capacity and understanding for the need to follow best practices. 3. Comply with local, national, and regional regulations. Regulations add an administrative and financial burden to developers, but they exist to safeguard the environment, the livelihoods of local communities, and the long-term financial sustainability of projects. 4. Develop and follow Environmental Management Plans. Develop appropriate Environmental Management Plans (EMPs) that account for the full range of risks and specify actions to manage the site of production in such a way as to minimize the risk of escape and invasion of surrounding areas, and deal effectively with any potential or actual resulting invasion. 5. Extend planning, monitoring, and assessments beyond the field. Consider developments within the wider context of the landscapes and ecosystems in which they are situated. Risks may extend beyond the site of production especially where adjacent areas may be more susceptible to invasion and the dispersal mechanism enables species to spread beyond the immediate site of a project. Thus, adopting an ecosystem approach when planning developments is preferable to only considering the risks posed by individual species. Mixed prairie. Credit: Lynn Betts Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 36

40 Processing potentially invasive bioenergy feedstocks into pellets may reduce the risk of escape during transport. Credit: Anthony DiChello/Bigstock.com. Considerable attention has already been paid to switchgrass, which is native to the central and eastern United States. Within its native range, switchgrass requires minimal management and can be harvested for up to 10 years before replanting. Other grasses under consideration include broomsedge bluestem (Andropogon virginicus), little broomstem (Schizachyrium scoparium), big bluestem, and indiangrass. 313 It should be noted that concerns have been raised over whether native grasses, such as switchgrass, that have been selectively bred to be high-yielding sources of biomass, may pose a potential invasive risk to native prairie stands. Research is currently underway in Minnesota to better assess the invasive risk as well as the benefits of selectively breeding switchgrass for bioenergy production. 314 To reduce the risk of invasion, efforts should be made to avoid planting such species near areas where virgin native grasslands still exist. Similarly, as noted previously, there may be the potential for species native in some areas to become invasive outside of their endemic ranges - an important consideration in determining where certain feedstocks may or may not be appropriate. Waste materials from various sources can also serve as sustainable bioenergy feedstocks. These may include wood and food wastes, such as wood from cleanly separated municipal solid waste or construction and demolition debris, forest industry residues, food product wastes, sewage, and animal manures. 315 In some communities, for example, urban wood and yard wastes are now being systematically collected for a wide variety of renewable energy production systems. Residual wood products from commercial forestry operations are also being used for energy production, increasingly using newer, cleaner combustion technologies. Additionally, crop residues can offer another potentially sustainable source of biomass production, provided they are removed at sustainable rates that adequately protect soil. In fact, the USDA and DOE estimate that with 25 percent increases in yield, annual supplies of crop residues could provide 244 million metric tons of biomass nearly enough to fulfill the amount necessary to meet the requirements under the current Renewable Fuel Standard. 316 In addition, some scientists have suggested that residual wood from management of forests affected by major bark beetle infestations, wildfires, hurricanes, and other natural disasters could be used as bioenergy resource. For example, it is estimated that a one-time harvest of dead trees associated with mountain pine beetle outbreaks in areas of the Rocky Mountains in the United States and Canada could supply fuel for biomass power plants or other energy uses for 25 years, while at the same time help reduce the associated risks of major wildfires. 317 It is important to consider that downed trees and other forest debris left after disturbances as well as many logging operations play an important ecological role by protecting forest soils and providing habitat for wildlife, benefits that would be reduced by their removal. 318 As with using control efforts for currently-problematic invasive species (e.g., kudzu and Chinese tallow) as a source of biomass energy, efforts 37 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

41 to capitalize on harvest of dead trees are necessarily opportunistic and not necessarily sustainable over the long term. Efforts to promote the use of currently-invasive species and waste from disasters must first and foremost be focused on ecosystem restoration. 2. Federal and state governments should conduct coordinated efforts to prohibit or restrict the use of known invasive species as dedicated bioenergy feedstocks through rigorous Weed Risk Assessment (WRA) screening protocols. To embrace precaution, we must first and foremost take meaningful steps to ensure that species that are already highly invasive or likely to become invasive (as identified by a WRA) are prohibited for use in bioenergy production. The potential ecological and economic risks of a worsening invasive species problem are far too high for us to ignore our past mistakes especially where we have an opportunity to be proactive. Indeed, prevention of invasive species introduction is the cheapest and most cost effective means of reducing the risks to both human and natural communities. 319 However, relatively few resources are dedicated to preventing the introduction of invasive species compared to expenditures for management and eradication efforts after invasive species have gained a foothold, at which point the problem is far more expensive and difficult to address. 320 A first step towards prohibiting the use of known invasive species as dedicated bioenergy feedstocks is to ensure that federal and state mandates and incentives for bioenergy include consistent and well-coordinated prohibitions on the use of invasive or potentially invasive species. Through mandates, incentives, and agency purchases, the federal government is currently putting large amounts of money into bioenergy development. The Department of Defense, for instance, recently signed a contract to buy almost half of a million gallons of biofuels for the U.S. Navy. 321 With limited funds being spent to promote second and third generation bioenergy production, native and non-invasive species should be prioritized. At the very least, federal funds should not be used to promote or purchase bioenergy feedstocks, including through funding research projects, until the federal government has first demonstrated that the feedstocks are safe by fully identifying and characterizing the invasion risk for each feedstock prior to their use through an environmental assessment process, which includes a rigorous WRA. It is critical that each individual cultivar, not just each species, is fully assessed for its invasion potential. For those species with even a moderate risk of invasiveness, we must require carefullycontrolled field trials, and establish mandatory mitigation plans to reduce their risk of escape and invasion prior to federal support of those species. A first step towards prohibiting the use of known invasive species as dedicated bioenergy feedstocks is to ensure that federal and state mandates and incentives for bioenergy include consistent and well-coordinated prohibitions on the use of invasive or potentially invasive species. Another way to prevent the use of risky bioenergy feedstocks is by instituting federal and state permitting requirements for the commercial use of non-native or modified bioenergy species. Florida currently has a permitting requirement for cultivation of non-native plants (including GM plants) intended for biofuel production. 322 According to their requirement, non-native biomass plantings spanning more than two acres require a permit from the Florida Department of Agriculture and Consumer Services. While the permit process disincentivizes the use of invasive species, it does not necessarily restrict the cultivation of potentially invasive species such as giant reed and napiergrass that not are listed on Florida s official noxious weed list. Permitting programs can be tied to a WRA to evaluate potential bioenergy feedstocks and restrict or regulate use of any species with high probability of becoming invasive. As a basic starting point, comprehensive WRAs should be required for all varieties of potential bioenergy feedstocks prior to their use to help identify the specific sources of and reasons for potential risk of invasiveness. 323 Species Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 38

42 with low risk of invasion could be permitted, and those with even a moderate risk of invasion would have to meet certain requirements, such as having monitoring and eradication protocols, in place (See Recommendation #4). The USDA recently released an updated weed screening tool to identify invasive potential. 324 While WRAs alone may not be enough to fully and accurately assess risk, and the screening tools must be continuously be improved upon as our understanding of invasive risks deepens, the WRA offers a good place for agencies to start. 3. State and federal governments should implement rigorous monitoring, early detection, and rapid response protocols, paid for through insurance bonding or other financial mechanisms. All too often, the cost of controlling an invasion by a non-native species is borne by state and federal governments. In California, for instance, more than $70 million dollars have been spent over the past 15 years to control giant reed; invasion by the plant has caused extensive damage to ecosystems and human infrastructure in many of the state s coastal watersheds. 325 Putting resources up front into monitoring, early detection, and rapid response can save money in the long-term. Both state and federal agencies have established so-called Early Detection-Rapid Response (EDRR) programs to provide an important early line of defense against invasive species, before they cause potentially irreparable harm to natural systems. 326 Volunteers cleaning up invasive seaweed in Hawaii. Credit: NOAA. However, the burden of developing such actions should not fall exclusively on the government and taxpayers. Companies who grow potentially invasive bioenergy feedstocks should be required to pay up-front costs for control of the specific species they are growing into a state account. These funds should be sufficient to cover costs associated with containment, control, management, and subsequent restoration efforts. Those growing varieties that have higher risk according to a WRA would pay higher fees than those scoring lower risk. The state of Florida currently has such a bonding program for bioenergy feedstocks that is tied to its permitting program. The proceeds of the bonding program go to fund eradication efforts of invasive bioenergy crops. Bonding requirements can be set up to include rigorous monitoring, detection, and eradication protocols. Bonding requirements are currently used in a variety of commercial operations including hazardous waste treatment facilities, mining, and oilcarrying vessels Feedstock producers should adopt best management plans for monitoring and mitigation to reduce the risk of invasion. Because the full risk of invasion from biomass feedstocks is often unknown, having a clear plan for monitoring and remediation is critical, even for projects using species with a low risk of invasion. Before any feedstock becomes commercialized, companies that grow potentially invasive bioenergy feedstocks should be required to establish management plans that embrace best practices for establishing, harvesting, transporting, and storing feedstocks to reduce the risks of invasion. 328 Best management practices may include timing harvests to minimize spread of seeds, maintaining clean equipment, using closed transportation systems to transfer feedstocks to production facilities, and putting an eradication plan into place before production. 329 For example, studies suggest that, with advances in processing equipment, potentially invasive plant feedstocks can be processed into useable forms such as pellets where they are harvested, before they are transported to the energy production facilities. 330 Such plans should also include avoidance and monitoring for pests and pathogens that might spread from cultivation sites and production facilities, both to protect the bioenergy crop and other species that might be 39 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

43 impacted. Frequent monitoring of nearby fields and roadways during the duration of the project and beyond also should be a key component of any management plan. In addition, bioenergy developers should be required to regularly monitor their processes, from cultivation and harvest to delivery and production, and they must develop comprehensive contingency plans that establish specific actions in the event of escape. 331 Additionally, there are a number of voluntary certification programs for sustainable biomass feedstocks that currently exist or are being established, including the Roundtable on Sustainable Biofuels, 332 the Council for Sustainable Biomass Production, 333 and the Forest Stewardship Council. 334 Many of these certification processes include carefully considered guidelines that can help companies in feedstock selection, mitigation and monitoring of potentially invasive biomass species. 5. The federal government should assign liability to feedstock producers for damages from and remediation of invasions by feedstock varieties that they develop. As mentioned above, once an invasive species spreads into native ecosystems, the costs for eradication, monitoring, and ecosystem restoration are often borne by the state or federal government. There is currently minimal incentive for individual landowners to control the spread of weeds from an intentional planting or introduction onto an adjacent landowner s property, with civil liability for the spread of weeds onto an adjacent landowner s property varying widely across states. Accordingly, there is minimal incentive for bioenergy producers to prevent the spread of invasive species. As the pace of research and experimentation with nonnative and GM crops grown for bioenergy continues to accelerate, it is critical that companies be held accountable for the unintended consequences should the feedstocks become invasive and spread. Assigning liability for damages and remediation will incentivize those companies to take precautionary measures to reduce the risk of invasion those producers who have in good faith implemented best management practices (see recommendation #4), including choosing low-risk feedstocks, would not then be held liable. This idea of a polluter pays principle for bioenergy feedstocks has been recommended by IUCN, who states that This will help to clarify where responsibility lies for covering any costs related to an invasion and encourage the adoption of best practices to protect economic investments in biofuels in the region Governments and businesses should better account for the economic risks associated with invasiveness of feedstocks when assessing relevant costs and benefits of potential bioenergy projects. In decisions concerning the cultivation of non-native species, the benefits of the species use must be weighed against the potential ecological and economic risks that may arise should the species become invasive. In fact, while the 1999 Executive Order was established to help protect the nation against actions that cause or contribute to the introduction of harmful invasive species, exceptions are granted provided that the benefits of such actions clearly outweigh the potential harm. 336 In addition to identifying the ecological risks of alternative bioenergy feedstocks, there is a critical need to improve our understanding and consideration of the potential economic risks associated with species that have or may become invasive. The particular challenge here is that, while identifying the economic benefits of bioenergy is relatively straightforward, it is much more difficult to compute the economic costs associated with the ecological impacts of invasive species, especially since many of the costs will be realized over the longterm. 337,338 Without truly acknowledging the full potential costs of invasions, decisions will likely more often than not skew in favor of the economic gains from bioenergy. Certainly the economic, social, and ecological costs associated with climate change, global security, and other major problems associated with fossil fuels that are the impetus for bioenergy development are by no means inconsequential. However, as Low, Booth, and Sheppard (2011) argue, the [p]romotion of biofuels as solution to urgent global problems encourages trivialization of weed problems. What we need are meaningful policies and programs that help promote a healthy, sustainable bioenergy economy, while ensuring that our important ecological values which are often undervalued in the marketplace are protected. 339 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 40

44 Concluding Thoughts Native grasses not only reduce the risk of invasion, but they also provide habitat for species such as this wild turkey. Credit: NRCS. As this report has shown, the rapid expansion of bioenergy production in the United States has generated considerable interest in the use of non-native and genetically modified biomass feedstocks that have the potential to become ecologically-damaging invasives. Should these species escape and become established in nearby natural areas, the results could be costly and devastating for native ecosystems. Despite this, few safeguards exist in law to prevent the spread of invasive species through bioenergy cultivation, and current risk assessment methodologies alone may not be sufficient. Policy makers, federal and state agencies, landowners, feedstock producers, and the public all need to become more aware of the potential for bioenergy feedstocks to become invasive. As we move towards a clean energy future, we must do so cautiously and responsibly. Invasive species can wreak havoc on ecosystems and economies; as we try to address the problem of global climate change, we must avoid worsening the invasive species problem. With foresight and careful screening, we have important opportunities to minimize and, where possible, prevent negative impacts of biomass feedstocks on functioning ecosystems. By implementing common-sense policies based first and foremost on precaution, we can significantly reduce the risk of invasion and help ensure a truly sustainable bioenergy industry. As we move towards a clean energy future, we must do so cautiously and responsibly. Invasive species can wreak havoc on ecosystems and economies; as we try to address the problem of global climate change, we must avoid worsening the invasive species problem. With foresight and careful screening, we have important opportunities to minimize and, where possible, prevent negative impacts of biomass feedstocks on functioning ecosystems. 41 Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

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50 166 USDA APHIS, 2010a. 167 Hinchee, M., W. Rottman, L. Mullinax, C. Zhang, S. Chang, M. Cunningham, L. Pearson, and N. Nehra Short-rotation woody crops for bioenergy and biofuels applications. In Vitro Cellular and Developmental Biology. Plant. 45: Voosen, Paul. USDA Weighs Plan to Bring GM Eucalyptus to Southeast Pinelands. The New York Times. January 29, (accessed March 12, 2012). 169 University of Florida. Australia/New Zealand Weed Risk Assessment adapted for Florida. Eucalyptus%20grandis_WRA.pdf (last modified January 27, 2011) 170 Cal-IPC California Invasive Plant Inventory. Cal-IPC Publication California Invasive Plant Council, Berkeley, CA. 171 USDA APHIS. 2010b. National Environmental Policy Act Decision and Finding of No Significant Impact. Field testing of genetically engineered Eucalyptus grandis X Eucalyptus urophylla. aphis.usda.gov/brs/aphisdocs/08_014101r_ea.pdf (accessed March 12, 2012). 172 Forster, Dan Comments from the Georgia Department of Natural Resources, Wildlife Resources Division to USDA-APHIS regarding the permit application by ArborGen LLC for planting of Eucalyptus grandis x E. Urophylla Tiedje, J.M., R.K. Colwell, Y.L. Grossman, R.E. Hodson, R.E. Lenski, R.N. Mack, and P.J. Regal The planned introduction of genetically engineered organisms: Ecological considerations and recommendations. Ecology 70: Dennis, Carina Burning Issues. Nature 421: Farley, K.A., E.G. Jobbágy, and R.B. Jackson Effects of afforestation on water yield: A global synthesis with implications for policy. Global Change Biology 11: Zhang, C. and S. Fu Allelopathic effects of eucalyptus and the establishment of mixed stands of eucalyptus and native species. Forest Ecology and Management 258 : USDA APHIS, 2010b. 178 Biofuels Journal. 2010c. USDA APHIS Allows Field Trials of GM Eucalyptus for Biomass Production. articles/usda_aphis_allows_field_trials_of_gm_eucalyptus_for_ Biomass_Production html (posted May 13, 3010). 179 BioConomy GM Biofuel Eucalyptus Held Up in Court. bioconomy.net/2011/03/04/gm-biofuel-eucalyptus-held-up-in-court/ (accessed March 12, 2012). 180 Gonzalez, Sarah. APHIS wins in biotech case over eucalyptus tree trials. AgriPulse. asp#.to95epcusum.twitter (accessed March 8, 2012). 181 Boyd, David Eucalyptus Removal on Angel Island. In California Exotic Pest Plant Council, 1997 Symposium Proceedings, California Invasive Plant Council, Sacramento, CA. 182 Stannard, M. and W. Crowder Reed Canarygrass. USDA NRCS Plant Guide. USDA Pullman Plant Material Center, Pullman, WA. 183 Merigliano, MF and P Lesica The native status of reed canarygrass (Phalaris arundinacea L.) in the Inland Northwest, USA. Natural Areas Journal 18: Casler, M Biofuel potential of reed canarygrass: A literature review. In: Brummer, EC, CL Burras, MD Duffy, and KJ Moore (eds.) Switchgrass production in Iowa: Economic Analysis, Soil Suitability, and Varietal Performance. Iowa State University, Ames, IA. 185 Ibid. 186 Ibid. 187 Indiana Department of Natural Resources Reed Canary Grass. Aquatic Invasive Species. (accessed March 13, 2012). 188 USDA NRCS. Phalaris arundinacea L. reed canarygrass. USDA PLANTS Profile. (last modified March 8, 2012). 189 Lavergne, S. and J. Molofsky Control strategies for the invasive reed canarygrass (Phalaris arundinacea L.) in North American Wetlands: the need for an integrated management plan. Natural Areas Journal 26: Witt, Indiana Department of Natural Resources, Ibid. 193 Witt, USGS. Reed Canary Grass. invasive_species/reed_canary_grass.html (last modified March 15, 2011). 195 Stannard, M Biology, history, and suppression of reed canarygrass (Phalaris arundinacea L.) USDA NRCS Technical Notes: Plant Materials Stannard and Crowder, Zimmerman, Gregory and Do-Hong Min. Potential of Reed Canary Grass as a Biofuel in Michigan s Eastern Upper Peninsula. michigan.gov/documents/dleg/reedcanarygrassreport_243249_7. pdf (last modified July 25, 2008). 198 Adler, P.R., S.J. Del Grosso, and W.J. Parton Life-cycle assessment of net greenhouse-gas flux for bioenergy cropping systems. Ecological Applications 17: Wright, N.A Screening of herbaceous species for energy crops on wet soils in Ohio. In: Janick, J. and J.E. Simon (eds.) Advances in New Crops, edited by Timber Press, Portland, OR. 200 Tahir, M., Casler, M.D., Moore, K.J., Brummer, E Biomass yield and quality of reed canarygrass under five harvest management systems for bioenergy production. BioEnergy Research. 4: Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

51 201 Ibid. 202 USGS, Indiana Department of Natural Resources, Carlsson, A.S., J.B. van Beilen, R. Möller, and D. Clayton Micro- and Macro-Algae: Utility for Industrial Applications. CPL Press, U.K. 205 DiTomaso, J.M., J.K. Reaser, C.P. Dionigi, O.C. Doering, E. Chilton, J.D. Schardt, and J.N. Barney Biofuel vs. bioinvasion: Seeding policy priorities. Environmental Science and Technology 44 : Beer, L.L., E.S. Boyd, J.W. Peters and M.C. Posewitz Engineering algae for biohydrogen and biofuels production. Current Opinion in Biotechnology 20: Ibid. 208 Dismukes, GC, D Carrieri, N Bennette, et al Aquatic phototrophs: Efficient alternatives to land-based crops for biofuels. Current Opinions in Biotechnology 19: Hossain, A, A Salleh, A Boyce, P. Chowdhury, and M. Naquiuddin Biodiesel fuel production from algae as renewable energy. American Journal of Biochemistry and Biotechnology 4: Ibid. 211 Radakovits, R, RE Jinkerson, A Darzins, and M Posewitz Genetic engineering of algae for enhanced biofuels production. Eukaryotic Cell 9: O Doherty, D.C. and A.R. Sherwood Genetic population structure of the Hawaiian alien invasive seaweed Acanthophora spicifera (Rhodophyta) as revealed by DNA sequencing and ISSR analyses. Pacific Science 61: Wang, Liu, and Wang, Maron, D. F The race to make fuel out of algae poses risks as well as benefits. New York Times, July 22, com/cwire/2010/07/22/22climatewire-the-race-to-make-fuel-outof-algae-poses-ris html?pagewanted=all (accessed March 12, 2012). 215 Ibid. 216 Crocker, M. The Risks of Synthetic Biology and the Genetic Modification of Algae: Impacts on Biomass Energy, Environment, Public Health & Food Safety. Congressional Briefing, U.S. Capitol Visitor Center, October 1, Lardizabal, S. Beyond the Refugium: A Macroalgae Primer. Reefkeeping. (accessed March 8, 2012). 218 Maron, Hong, Y., A. Steinman, B. Biddanda, R. Rediske, and G. Fahnenstiel Occurrence of the toxin-producing cyanobacterium Cylindrospermopsis raciborskii in Mona and Muskegon Lakes, Michigan. Journal of Great Lakes Research 32: Schaffelke, B and CL Hewitt Impacts of introduced seaweeds. Botanic Marina 50: Goreau, T.J., J.E. Smith, E.J. Conklin, C.M. Smith, and C.L. Hunter Fighting algae in Kaneohe Bay. Science 319: Martinez, J.A., C.M. Smith, and R.H. Richmond Invasive algal mats degrade coral reef physical habitat quality. Estuarine, Coastal and Shelf Science 99: Hanson, J. New regulations needed for genetically engineered algae that could threaten our health and the environment. Center for Food Safety Comments for Congressional Staff Briefing. U.S. Capitol Visitor Center, October 1, University of Nevada, Reno. Success for first outdoor, large-scale algae-to-biofuel research project in Nevada [Press release]. January 28, (accessed March 12, 2012). 225 University of Nevada, Reno Cushman, Harper teaming up to produce fuel from algae. College of Agriculture, Biotechnology & Natural Resources Quarterly Newsletter Fall Solazyme. Dynamic Fuels and Solazyme partner to supply renewable fuel to U.S. Navy [Press Release]. December 5, (accessed March 12, 2012). 227 Solazyme. Company/Overview. company-overview (accessed March 8, 2012) 228 BusinessGreen. Solazyme brews up fresh funding for algae fuel plans. (posted August 10, 2010). 229 Aquatic Energy. (accessed March 8, 2010). 230 Woodfield, R and K Merkel Eradication and surveillance of Caulerpa taxifolia within Aqua Hedionda Lagoon, Carlsbad, California. Fifth Year Status Report, January to December Prepared for the Steering Committee of the Southern California Caulerpa Action Team. 231 Odero, D.C. and C. Rainbolt Napiergrass: Biology and control in sugarcane. University of Florida IFAS Extension, Publication #SS- AGR The U.S. Bureau of Reclamation, H.T. Cory, and F.W. Hanna Development of Unused Lands: Letter from the Secretary of the Interior Transmitting Report on the Development of the Unused Lands of the Country. Washington Government Printing Office, Washington, D.C. 233 Woodard, K.R. and L.E. Sollenberger Production of biofuel crops in Florida: Elephantgrass. University of Florida IFAS Extension, Publication #SS-AGR USDA Research, Education & Economics Information System (REEIS). Developing non-invasive, genetically improved genotypes of the biofuel and forage crop napiergrass. crisprojectpages/ html. (accessed March 8, 2012). 235 Odero and Rainbolt, Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 48

52 236 Florida Exotic Pest Plant Council. Florida EPPC s 2011 Invasive Plant Species List. (last modified November 2, 2011) 237 Ibid. 238 University of Florida IFAS Extension Center for Aquatic and Invasive Plants. Plant Management in Florida Waters: An Integrated Approach. (accessed March 12, 2012). 239 Gordon, et al., Buddenhagen, Chimera, and Clifford, Florida Exotic Pest Plant Council. Pennisetum purpureum Schumach. purpureum.pdf (last modified November 9, 2000) 242 US Forest Service. Pennisetum purpureum Shumacher. (last modified September 10, 2003) 243 Florida Exotic Pest Plant Council. Pennisetum purpureum Schumach. 244 Ellerbusch, Sue. Cellulosic Biofuels: A Strategic Option for an Oil Company. BP alternative energy. Speech dated December 7, tid= Vercipia biofuels. Vercipia s Seed Farm. commercial-projects/construction-update.aspx?galleryid=3 (accessed March 8, 2012). 246 U.S.Environmental Protection Agency (EPA) Regulation of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel Standard Program. 40 CFR Part 80, EPA-HQ-OAR U.S. Environmental Protection Agency (EPA). 40 CFR Part 80 EPA- HQ-OAR ; FRL_XXXX-X RIN 2060-AR07. Regulation of Fuels and Fuel Additives: Identification of Additional Qualifying Renewable Fuel Pathways Under the Renewable Fuel Standard Program. Direct Final Rule. 11/30/ Regulation of fuels and fuel additives: Identification of additional qualifying renewable fuel pathways under the renewable fuel standard program. Federal Register 77(43): Odero and Rainbolt, U.S. Forest Service. Plants Profile: Pennisetum purpureum Schumach. (accessed March 12, 2012). 251 Chornesky, E.A., A.M. Bartuska, G.H. Aplet, K.O. Britton, J. Cummings-Carlson, F.W. Davis, J. Eskow, D.R. Gordon, K.W. Gottschalk, R.A. Haack, A.J. Hansen, R.N. Mack, F.J. Rahel, M.A. Shannon, L.A. Wainger, and T. B. Wigley Science Priorities for Reducing the Threat of Invasive Species to Sustainable Forestry. USDA Forest Service National Agroforestry Center, University of Nebraska, Lincoln, NE. 252 BCAP Seed LLC. (accessed March 8, 2012) 253 Parabel. About Parabel. (accessed March 8, 2012) 254 BiofuelsDigest. The Food vs Fuel flip-around: PetroAlgae re-focuses on making feed, feedstock from microcrops. com/bdigest/2011/12/07/the-food-vs-fuel-flip-around-petroalgaere-focuses-on-making-feed-feedstock-from-microcrops/ (posted December 7, 2011) 255 Parabel. Sites. (accessed March 8, 2012) 256 Flagg, Kathryn. Middlebury College fires up $12 million biomass plant. Addison County Independent. com/200902middlebury-college-fires-12-million-biomass-plant (accessed March 8, 2012) 257 Middlebury. Testing willow as biomass. edu/sustainability/energy-climate/willow/willow_feasibility (accessed March 8, 2012) 258 Ecology/Invasive Species Glossary. Ecology/Invasive_Species_Glossary. (accessed March 9, 2012). 259 Jeschke, J.M. and D.L. Strayer Invasion success of vertebrates in Europe and North America. Proceedings of the National Academy of Sciences 102: Booth, B.D., S.D. Murphy, and C.J. Swanton Weed Ecology in Natural and Agricultural Systems. CABI Publishing, Cambridge, MA. Some state regulatory regimes specifically define the term native species. See California Food & Agriculure Code 80061; Colorado Revised Statutes ; New York Environmental Conservation Law (6). 261 Federal Plant Protection Act, 7 U.S.C. 7702(10). 262 Heutte, T. and E. Bella Invasive plants and exotic weeds of Southeast Alaska. USDA Forest Service, Anchorage, AK. 263 Corn, M.L., E.H. Buck, J. Rawson, A. Segarra, and E. Fischer Invasive Non-Native Species: Background and Issues for Congress. Congressional Research Service, The Library of Congress, Washington, D.C. 264 U.S. Congress, Office of Technology Assessment Harmful Non-Indigenous Species in the United States, OTA-F-565. U.S. Government Printing Office, Washington, D.C. 265 Public Law , 114 Stat. 454 (2000) (codified at 7 U.S.C et seq.) U.S.C. 7702(10). 267 Lodge, D.M., S. Williams, H.J. MacIsaac, K.R. Hayes, B. Leung, S. Reichard, R.N. Mack, P.B. Moyle, M. Smith, D.A. Andow, J.T. Carlton, and A. McMichael Biological invasions: Recommendations for U.S. policy and management. Ecological Applications 16: Noxious Weed Control and Eradication Act, Public Law , 118 Stat (2004) Federal Register 6183 (Feb. 8, 1999). 270 Joseph M. DiTomaso, et al Biofuel vs. Bioinvasion: Seeding Policy Priorities. Environmental Science & Technology 44: Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

53 271 Raghu et al., Section 9001 of the 2008 Farm Bill, Public Law Endres, J. M No Free Pass: Putting the Bio in Biomass, Natural Resources & Environment 26,,: Federal Register 66202, (Oct. 27, 2010) Federal Register 66202, (Oct. 27, 2010). 276 Environmental Law Institute Status and Trends in State Invasive Species Policy: Washington, D.C. 277 Burgiel, S., G. Foote, M. Orellana, and A. Perrault Invasive Alien Species and Trade: Integrating Prevention Measures and International Trade Rules. Center for International Environmental Law and Defenders of Wildlife, Washington, D.C. 278 Quinn, L., J. Barney, J. McCubbins, and A.B. Endres. (in review) Navigating the noxious and invasive regulatory landscape, or lack thereof: Where do biofuels fit? BioScience. 279 Biomass Plantings, Florida Administrative Code 5B Mississippi House Bill 634 (2012 Legislative Session). 281 Pew Initiative on Food and Biotechnology Guide to U.S. Regulation of Agricultural Biotechnology Products Fed. Reg (June 26, 2006) 283 The repeal of the Federal Plant Pest Act by the Plant Protection Act in 2000 transferred USDA s jurisdictional authority over potential plant pest in the genetic engineering context from the FPPA to the PPA, but to date has had no effect on USDA s regulatory approach U.S.C. 136 et seq U.S.C. 301 et seq C.F.R In January, 2004, USDA proposed to regulate genetically engineered plants under its noxious weed authority, in addition to the established plant pest authority. 69 Federal Register 3271 (Jan. 23, 2004). Although the USDA has not yet finalized this proposed rule, the agency s recent review of genetically engineered Kentucky Bluegrass under the noxious weed provisions of the Plant Protection Act provides a secondary regulatory route for genetically engineered plants. See International Center for Technology Assessment and the Center for Food Safety; Noxious Weed Status of Kentucky Bluegrass Genetically Engineered for Herbicide Tolerance, 76 Federal Register (July 7, 2011). 287 USDA, Biotechnology Regulatory Service, Letter to New Zealand Crop and Food Limited dated May 19, 2008, available at Scotts Miracle-Gro Co.; Regulatory Status of Kentucky Bluegrass Genetically Engineered for Herbicide Tolerance, 76 Federal Register (July 7, 2011). 289 International Center for Technology Assessment and the Center for Food Safety; Noxious Weed Status of Kentucky Bluegrass Genetically Engineered for Herbicide Tolerance, 76 Federal Register (July 7, 2011) 290 ArborGen, LLC Availability of an Environmental Assessment for Controlled Release of a Genetically Engineered Eucalyptus Hybrid. 77 Federal Register Standards Australia, Standards New Zealand and CRC Australian Weed Management HB National Post-border Weed Risk Management Protocol. Standards Australia International Ltd., Sydney and Standards New Zealand, Aukland. 292 Davis, et al., Koop, AL, L Fowler, LP Newton, and BP Caton Development and validation of a weed screening tool for the United States. Biol. Invasions 14: Keller R.P., Lodge, D.M. & Finnoff, D.C. (2007) Risk assessment for invasive species produces net bioeconomic benefits. Proceedings of the National Academy of Sciences, 104, Koop et al., Champion, P.D., J.S. Clayton, and D.E. Hofstra Nipping aquatic plant invasions in the bud: Weed risk assessment and the trade. Hydrobiologia 656: Pheloung, P.C., P.A. Williams, and S.R. Halloy A weed risk assessment model for use as a biosecurity tool evaluating plant introductions. Journal of Environmental Management 57: Gordon et al., Buddenhagen, Chimera, and Clifford, Davis, et al., Davis, P.B., F.D. Menalled, R.K.D. Peterson, and B.D. Maxwell Refinement of weed risk assessments for biofuels using Camelina sativa as a model species. Journal of Applied Ecology 48: DiTomaso et al., Cousens, R Risk assessment of potential biofuel species: An application for trait-based models for predicting weediness. Weed Science 56: DiTomaso, Barney, and Fox, Low, Booth, and Shephard, DiTomaso, Barney, and Fox, Barney and DiTomaso, Federal Register 6183 (Feb. 8, 1999). 309 National Invasive Species Council (NISC) Biofuels: Cultivating Energy, not Invasive Species. 310 IUCN Guidelines on Biofuels and Invasive Species. Gland, Switzerland: IUCN. 20pp. 311 Tilman, D., J. Hill, and C. Lehman Carbon-negative biofuels from low-input high-diversity grassland biomass. Science 314: Ibid. 313 Harper, C.A. and P.D. Keyser. Potential impacts on wildlife of switchgrass grown for biofuels. UT Biofuels Initiative, University of Tennessee. URL: Documents/SP704-A.pdf. Accessed January 19, Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks 50

54 314 Eckberg, J Evaluation of switchgrass as a biofuels crop. Minnesota Environment and Natural Resources Trust Fund M.L Work Plan. workplans_may/_06c_workplan.pdf 315 Kemp and Sibbing Fargione et al Ibid. 318 Pedlar, J.H., J.L. Pearce, L.A. Venier, and D.W. McKenney Coarse woody debris in relation to disturbance and forest type in boreal Canada. Forest Ecology and Management 158: Emerton, L. and G. Howard A Toolkit for the Economic Analysis of Invasive Species. The Global Invasive Species Programme, Nairobi, Kenya. 320 Davies and Johnson, Medici, Andy. DoD Makes Record Biofuel Purchase for U.S. Navy. DefenseNews. December 6, DEFSECT03/ /DoD-Makes-Record-Biofuel-Purchase-U- S-Navy 322 Biomass Plantings, Florida Administrative Code 5B DiTomaso et al., Koop, AL, L Fowler, LP Newton, and BP Caton Development and validation of a weed screening tool for the United States. Biol. Invasions 14: Giessow et al., Westbrooks, R.G New approaches for early detection and rapid response to invasive plants in the United States. Weed Technology 18: ] Boyd, James. Financial Responsibility for Environmental Obligations: Are Bonding and Assurance Rules Fulfilling Their Promise? Washington, DC: Resources for the Future, RFF-DP pdf (accessed March 13, 2012). 328 Barney and DiTomaso, Barney and DiTomaso, Young, S.L., G. Gopalakrishnan, and D.R. Keshwani Invasive plant species as potential bioenergy producers and carbon contributors. Journal of Soil and Water Conservation 66: 45A-50A. 331 Barney and DiTomaso, Ecole Polytechnique Federale de Lausanne (EPFL). Roundtable on Sustainable Biofuels RSB. (accessed March 9, 2012) 333 Council on Sustainable Biomass Production. CSBP Provisional Standard for Sustainable Production of Agricultural Biomass now available. (accessed March 9, 2012) 334 Forest Stewardship Council. (accessed March 9, 2012) 335 IUCN Guidelines on Biofuels and Invasive Species. Gland, Switzerland: IUCN. 20pp Federal Register 6183, (Feb. 8, 1999). 337 Davis, et al., Simberloff, D The politics of assessing risk for biological invasions: The USA as a case study. Trends in Ecology and Evolution 12: Low, T., C. Booth, and A. Sheppard Weedy biofuels: What can be done? Current Opinion in Environmental Sustainability 3: Growing Risk: Addressing the Invasive Potential of Bioenergy Feedstocks

55 A mixture of native grasses and forbs, which can support bioenergy production as well as provide important habitat for a range of fish and wildlife species. Credit: Lynn Betts, NRCS. W e now have an opportunity to prevent irreparable harm by heeding sensible precautions in order to avoid the risk that continued bioenergy development in the United States will fuel a growing invasive species catastrophe. With foresight and careful screening, we can minimize and, where possible, prevent negative impacts of biomass feedstocks on functioning ecosystems. Bioenergy can be an important part of a sustainable energy future, but only if it is produced in a way that safeguards native habitats and minimizes the risk of invasion.

56 National Wildlife Federation National Advocacy Center 901 E St. NW, Suite 400 Washington, DC