The Invasive Species proposal(s) being floated today are the result of four years of intensive organization and concerted effort by bureaucrats, environmentalists, rich lobby groups, academics, states, businesses, and others to pass legislation under this rubric. I strongly believe that it will further diminish the Constitutional authorities of the states over all plants and animals (except those specifically covered in Treaties like migratory birds) while expanding the authority of Federal bureaucrats and allied powerful environmental groups and animal rights groups over private property and the full range of citizen activities involving both wild and domestic plants and animals. It will be quickly expanded to cover every "non-native" or "exotic" plant and animal because of the Endangered Species Act experiences of the past 30 years no matter how it is worded. Preventing passage of such legislation (along with reform of the Endangered Species Act) is the most pressing legislative need of the present day, in my opinion.

I ask that you oppose these proposals because they are wrong and harmful in many ways. I suggest respectfully that you affirm the Constitutional jurisdiction of state governments over all wild and domestic plants and animals within their state while affirming the sound concept that damage by plants or animals is of no different concern or of no Federal moment merely because it is a recently arrived species as contrasted with one that has been here since the ice age. In other words non-native or exotic species are every bit as much under the primary jurisdiction of state governments as the turkeys and white oaks descended from the ones which were here in 1778 or 1492 for that matter. I suggest that legislation is needed to do this.

You could simultaneously affirm the strong and powerful commitment of the Federal government to manage their own Constitutional responsibilities to regulate import, export, and interstate commerce of all plants and animals so as to reinforce state management and damage control priorities. You could order a report by USDA of all state damage management priorities reduced to recommendations for research and damage management operations that the states want and recommendations for Federal land management agencies to do on Federal lands WITHIN EACH STATE TO COMPLY WITH STATE PRIORITIES IN THAT STATE. Some grant money could eventually be made available to states, at their discretion, where large Federal landholdings exist or where many states want to work together on common problems. University money should go through states to meet the needs of a particular state. This protects property owners and keeps academics in a support role where research belongs. Not distinguishing exotics reduces future mischief (going after brown trout, pheasants, day lilies, etc.) to a minimum and not growing Federal power in this area reduces the desire to Federalize. So I would propose a hearing or proposed legislation to do something like the following.

NATIONAL ENVIRONMENTAL MANAGEMENT ACT

Purpose: To assure Federal cooperation with state government activities to minimize environmental and other damage from wild and domestic plants and animals in order to assure a healthy and productive national environment.

Background: Recognizing the complimentary legal and management roles of the state and Federal governments regarding both wild and domestic plants and animals such that the state governments have jurisdiction over all plants and animals within their borders with the exception of those specifically named in Treaties such as the various Migratory Bird Treaties with foreign powers and further recognizing the specific role of the Federal governments to regulate the import, export, and interstate commerce involving all plants and animals and further recognizing the need to both minimize current damage caused by plants and animals while further reducing the threat of increasing such damage through interstate commerce, import, or export of plants or animals: it is therefore seen to be salutary to coordinate all such governmental activities as much as possible.

Therefore be it resolved that:

• All Federal land unit managers (right term??) will consult with the governments of the state wherein they are located and that they will manage and plan operations on those land units to compliment the plant and animal damage priorities of that state.
• The USDA will inventory the plant and animal damage management priorities of each state and report (by XXX) to Congress on how Federal land management, import, export, and interstate activities can be coordinated to compliment those priorities within current budgets.

The USDA and USDoI will cooperate and submit a report to Congress (by XXX) detailing the research needs that reflect state priorities to minimize plant and animal damage to the environment accompanied by a budget recommendation for a national research grant program to make research money available to states for the states, at their discretion, to contract with universities or private researchers to develop the information necessary to make state plant and animal damage efforts as effective as possible.