J Agric Environ Ethics (2009) 22:81–88

DOI 10.1007/s10806-008-9127-4

Environmental Harm: Political not Biological

Mark Sagoff

Accepted: 24 September 2008 / Published online: 11 October 2008

Springer Science+Business Media B.V. 2008

Abstract In their fine paper, Evans et al. (2009) discuss the proposition that invasive
non-native species (INS) are harmful. The question to ask is, ‘‘Harmful to whom?’’
Pathogens that make people sick and pests that damage their property—crops, for exam-
ple—cause harms of kinds long understood in common law and recognized by public
agencies. The concept of ‘‘harm to the environment,’’ in contrast, has no standing in
common law or legislation, no meaning for any empirical science, and no basis in a
political consensus other than might be drawn from the Endangered Species Act. As a
generalization, the proposition that INS cause ‘‘environmental harm’’—since this concept
is empty of legal, scientific, and political meaning—must rest on definition, diktat, or
diatribe. As Evans et al. suggest, however, the idea of ‘‘harm to the environment’’ is not
always and certainly need not be arbitrary; it might gather significance in the context of a
particular place through a political process that weighs economic concerns with cultural,
religious, aesthetic, and other relevant beliefs, practices, and commitments that people who
care about that place present. It is not clear, however, that adaptive management, which
Evens et al. propose, will provide that democratic political process.

Keywords Invasive species
Adaptive management
Environmental harm

Evans et al. (2008) attribute to me the assertion that INS ‘‘are rarely if ever harmful, with
the implication being that … control activities aimed at INS (particularly plants) [are]
unjustified.’’ On the contrary, I applaud control activities aimed at any organism that
injures health or damages property. Pathogens and pests cause plenty of harm that amply
justifies the essential work of agencies such as the Animal and Plant Health Inspection
Service (APHIS) of USDA, which battles agricultural weeds and other nuisance species,
and of the Centers for Disease Control (CDC), which combats disease organisms. The term
‘‘environmental harm’’—unlike ‘‘economic harm’’ and ‘‘harm to human health’’—has no
meaning in science, policy, or law. I have questioned, therefore, whether the concept of

M. Sagoff (&)
Institute for Philosophy and Public Policy, University of Maryland, College Park, MD, USA
e-mail: msagoff@umd.edu

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‘‘environmental harm’’ can justify expensive and extensive programs to control INS that do
not damage property, particularly, agriculture, or threaten human health.

Economic Harm

In Executive Order 13112, President Clinton (1999) identifies an invasive non-native

species (INS) as any non-native species that ‘‘causes or is likely to cause economic or
environmental harm or harm to human health.’’ This statement defines ‘‘environmental
harm’’ only by distinguishing it from the kinds of harms the police power of government
properly prosecutes or prevents, i.e., harms to person and property. Economic harm is easy
to identify and often to measure. The economic harm caused by INS is often exaggerated
and overstated, however, in order to pump up political support for expensive research and
unneeded projects aimed at non-native organisms that in fact are not threats to public
health or to private property but are said to ‘‘harm’’ the environment.
I do not doubt that non-native species, like native ones, often cause damage to person
and property. Agencies such as APHIS and CDC exist to protect people and their property
against this kind of damage. Outside of the kinds of pathogens and pests that fall within the
missions of these agencies, the economic costs of NIS tend to be wildly exaggerated and
overstated for political purposes and do not justify the current animus against (or interest
in) these species. To be sure, anglers, hunters, and others may have complaints about or
praise for particular NIS depending on their effects on game; these can be handled on a
case-by case basis. Since nearly all crops are non-native, moreover, it is no surprise that
their predators and pests follow them.
One can claim that any species causes ‘‘economic harm’’ if one uses as a measure the
costs of controlling it. Evans et al. (2009) cite the ‘‘influential study’’ by Pimentel et al.
(2000) ‘‘that estimates INS annually cause over $100 billion of damages … in the United
States alone.’’ Pimentel et al. estimated that economic losses caused by non-indigenous
species total approximately $137 billion annually in the United States—and, therefore,
over $1 trillion since their paper was published. This study has become so entrenched by
constant and unquestioned citation that it now serves as the principal document to justify
public spending for research in the burgeoning field of invasion biology. The Pimentel
et al. study (2000, updated 2005), however, should be treated with incredulity and not (as it
usually is) with deference.
Pimentel et al. rely on the strategy (as Evans et al. describe it) of conflating ‘‘costs
associated with the control of INS with the supposed damages caused by these species.’’
For example, citing only a long-defunct web page as evidence, these authors write,
‘‘Loosestrife costs $45 million per year in control costs and forage losses.’’ Many gov-
ernmental agencies might want to bloat their budgets by obtaining millions of taxpayer
dollars to control a pretty non-native species like purple loosestrife, and, for that reason,
they may put up scary web pages about it. The more the agency spends to control an
organism, the higher ‘‘control costs’’ become, thus creating ‘‘economic costs’’ to justify
more spending. Except when people spend their own money, however, the costs of con-
trolling a species cannot be taken as a measure of the benefits.
By ‘‘using potential control costs as a surrogate for losses,’’ Pimentel et al. (p. 56)
reason that ‘‘pigeons cause $1.1 billion per year in damages’’ because ‘‘control costs for
pigeons are at least $9 per pigeon per year’’ and there are more than 100 million of them.
The same argument would apply to the passenger pigeon, a native bird which became
massively invasive in the agricultural landscape of the early nineteenth century (Neumann

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1985). ‘‘They had voracious appetites and would descend on forests and farmland like
locusts, wiping them clean of nuts, acorns, berries, grains, insects, snails and worms’’
(Reeve 2001). The extermination of pigeons, even if it were worth attempting, would
represent a one-time not an annual expense, especially if it led to extinction. Pimentel et al.
routinely treat one-time expenses as if they were recurring costs.
In the Great Lakes and elsewhere municipal water works, power plants, and other
facilities had to retrofit their intake valves to proof them against the zebra mussel (In
Europe, these facilities were constructed initially to resist the mussel). Referring to a
personal communication as evidence, Pimentel et al. estimate recurring annual costs to
these industries and municipalities at $100 million. At the height of the infestation,
however, New York Sea Grant (1997) ‘‘polled power generating plants, public and private
drinking water treatment plants, industrial facilities, and navigation lock and dam struc-
tures in 35 U.S. states and three Canadian provinces’’ to find out what they spent to control
the mussel and mitigate its effects. The survey determined the ‘‘actual impact cost to be
approximately $70 million over the past decade’’ (also reported in Kraft 1996). The annual
cost of about $700,000 in the decade when the infestation was at its worst is consistent with
empirical studies (Glassner-Shwayder 2000; Reutter et al. 1996, p. 43).
A report by the Pew Oceans Commission questions the Pimentel et al. (2000) estimate
of a $44 million annual economic impact of the European shore crab Carcinus on the
Pacific coast, since it ‘‘was based on a predicted, not an actual, value.’’ It also debunks the
estimate of ‘‘the cost of introduced shipworm damage at $205 million/year’’ because it
‘‘refers to an episode that occurred between 1919 and 1921’’ (Carlton 2001, p. 5). Pimentel
et al. cite papers edited by Isom (1986) to attribute costs ‘‘of about $1 billion per year’’ to
the Asian clam. No paper in the Isom collection provides a basis for this estimate. An
Office of Technology Assessment (1993) stated that ‘‘populations of the Asian clam have
begun to decline for unknown reasons.’’
Pimentel et al. (p. 56) suggest that outdoor and feral cats have cost us $170 billion over
the past decade. They justify this figure with an ‘‘estimate that cats kill approximately
568 million birds per year in the United States.’’ After attributing a value of $30 to each
bird, they conclude that the ‘‘total damage to U.S. bird populations is approximately
$17 billion each year.’’ Pimentel et al. do not show that cats kill the kinds of birds that bird
watchers, hunters, or anyone else values; indeed, cats often kill the starlings, pigeons, and
other non-native birds these authors deplore. Nor do they consider the role of cats in
controlling rodents that have become nuisances in suburban communities. They make no
attempt to balance the benefits of any NIS with its imputed costs.

Harm to the Environment

Invasion biologists and other ecologists never weary of repeating that they are concerned to
exclude, control, or eliminate not all non-native species in the environment but only ‘‘the
minority of species that are harmful’’ (Simberloff 2005, 601; Lodge and Shrader-Frechette
2003; Simberloff and Strong 2000). The question to ask is ‘‘Harmful to whom?’’ If an
organism threatens to harm a person’s health or to damage his or her property, that
individual can speak up. Agencies like CDC and APHIS are ready to help. What shall we
say about an NIS that does not threaten to injure anyone’s health or to reduce the value of
anyone’s property but creates changes in what is considered the natural environment? For
virtually any change in the natural environment, whatever that means, it may be possible to
find someone who is offended by or objects to it. If ‘‘environmental harm’’ refers to any

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environmental change someone does not like, everything—not just NIS—potentially

harms the environment.
Ecologists point to myriad environmental effects associated with NIS (Parker et al.
1999), but they have no scientific basis for regarding any of these changes as good or bad.
Biologists speaking ex cathedra pronounce a preference for less recent over more recent
arrivals. The following diktat is illustrative: ‘‘We use environmental harm to mean bio-
logically significant decreases in native species populations, alterations to plant and animal
communities or to ecological processes that native species and other desirable plants and
animals and humans depend on for survival’’ (NISC 2006). Natural populations fluctuate.
What kind of decrease is ‘‘significant’’? Why are species that arrive earlier (and are thus
deemed ‘‘native’’) more ‘‘desirable’’ than those that naturalized themselves later? Why is
native—however, that idea is construed—better? As Mark Twain wrote in another context,
‘‘The researches of many commentators have already shed considerable darkness on this
subject and it is probable that, if they continue, we shall soon know nothing about it.’’
I am sympathetic to the view that native is better but not that science can tell why. ‘‘The
words ‘good’ and ‘bad’ constitute value judgments and so lie beyond the bounds of
science,’’ Rosenzweig (2001) has written. ‘‘Were exotic species to reduce diversity by
30%, no ecologist could test whether that loss of species would be a bad thing.’’ The term
‘‘environmental harm,’’ as Rosenzweig suggests, may possess an aesthetic, religious,
spiritual, historical, cultural, or some other meaning to society; perhaps it can be explicated
on these grounds. The concept of ‘‘environmental harm,’’ however, has no referent in
biology or in any other science. Science on occasion may be able to tell us what is false or
true but it can never tell us what is bad or good.

Invasive Species and Biodiversity

Evans et al. correctly attribute to me the view that ‘‘a primary justification for controlling
INS—averting the risk of extinction—actually has very little empirical merit in the most
common case of nonnative plants introduced into continental ecosystems.’’ The IUCN Red
Book database suggests that the causes of extinction ‘‘included the effects of invasive
species’’ in 91 cases of all those extinctions the causes of which are known (Clavero and
Garcı́a-Berthou 2005). A recent article in the New York Times, reporting on research by
Sax and Gaines (2008) notes that the introduction of predators in small island or island-like
environments (such as lakes) account for many of these—the tree snake in Guam and the
Nile Perch in lake Victoria are notorious examples. A few exotic predators in enclosed
environments can destroy endemic fish, birds, and other animals; predation is a real
problem. On the other hand, as the Times article states, ‘‘competition from exotic species
shows little sign of causing extinctions’’ (Zimmer 2008).
The article explains, ‘‘New Zealand is home to 2,065 native plants found nowhere else
on Earth.’’ There are now about 22,000 non-native plants that grow in New Zealand and of
these ‘‘2,069 have become naturalized: they have spread out across the islands on their
own.’’ If competition by invasive plants were a significant cause of the extinction of native
ones, one would expect that the endemic flora of New Zealand would have disappeared.
Instead, ‘‘The number of documented extinctions of native New Zealand plant species is a
grand total of three’’ from all causes, including habitat change (see Sax et al. 2002). The
introduction of non-native flora in New Zealand has caused the number of plant species
(species richness) to increase by an order of magnitude. If one excludes those species that

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depend on cultivation, the richness of New Zealand flora has doubled so far with more
additions no doubt to come.
What one observes nearly everywhere as a result of the global mixing of species is not a
decrease but a dramatic increase in the richness or variety of species especially that of
plants. According to Sax and Gaines (2008, 11,492), ‘‘the average increase observed across
oceanic islands is highly regular, with most islands showing a strikingly consistent dou-
bling in net plant richness.’’ The naturalization of introduced species is continuing at such a
pace that ‘‘many islands are now coming close to matching the species richness levels of
continental environments’’ (Sax and Gaines 2008, 11,493). The same trend applies to
animals. ‘‘In Hawaii, for example, 40 new species of freshwater fish have become estab-
lished, and the 5 native species are still present’’ (Zimmer 2008).
Introduced species also add to overall species diversity by stimulating the evolution of
new kinds of organisms. Pressure from exotic species may stimulate native species to
evolve in different ways in different places, thus increasing overall diversity (Lau 2006).
The new arrivals themselves also ‘‘radiate’’ to fill new niches (Zimmer 2008). Biologists in
the field find that invasions by exotic species, far from depleting the diversity of species,
‘‘create almost ideal conditions for promoting evolutionary diversification’’ (Vellend et al.
2007, 481). Separated from their former populations, introduced species diverge in mor-
phology and in behavior, forming new kinds of populations. Exotic species also hybridize
with natives to produce novel lineages (Allendorf and Lunquist 2003). For many reasons,
‘‘the net consequence of these invasions is generally an increase in total species richness’’
(Sax et al. 2007, 466). New varieties emerge; homogenous populations diverge; evolution
accelerates; biodiversity flourishes.
The question remains, however, whether this dramatic increase in the variety of plants
and animals is a good or bad thing. The answer may depend on a religious or theological
position. If one believes, as many Christians do, that God created all living things and that
human beings are essentially corrupt or sinful, one may then conclude that any human-
induced change in Creation, such as that caused by non-native species, is bad. Indeed, by
including as ‘‘native’’ only those species that arrived at a place without human assistance
(‘‘other than as a result of an introduction’’), Executive Order 13112 reflects the Christian
view that nature as God created it has a kind of integrity or goodness or balance that human
influence (by moving species around, for example) may only corrupt or upset.
The same principle provides a basis for defining ‘‘biodiversity’’ to exclude organisms
that result from human invention. This exclusion or ban would apply to genetic engi-
neering. Since genetic recombination can splice genes across nearly any two species, it has
the potential of producing a limitless amount of biodiversity, unless the idea of biodiversity
is specifically reserved (perhaps on religious grounds) to apply to only ‘‘naturally-occur-
ring’’ organisms. Man is excluded from nature because of Original Sin. Only ‘‘natural’’
organisms, i.e., those that were neither created by humans nor introduced with human
assistance, are ‘‘native’’. As Simberloff (2005, 603) correctly observes, it is troublesome
that ‘‘‘native’ is implied but omitted as a modifier of ‘biodiversity.’’’

Adaptive Management

Evans et al. wonderfully describe the tumultuous history of recent attempts to manage the
Kings Bay/Crystal River ecosystem, one of Florida’s most important habitats for endan-
gered West Indian manatees. The reader comes away with the impression that everything
that could go wrong, did. Whatever managers attempted, they accomplished if anything the

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opposite result, which half the time was better than the one they intended. The problem did
not lie in an absence of citizen input and participation. On the contrary, Evens et al. write,
for example, that ‘‘The Southwest Florida Water Management District … sponsored many
meetings of stakeholder groups’’ and convened a ‘‘Kings Bay Water Quality Subcommittee
(KBWQS), a citizen council that formally advised the City of Crystal River on water
quality issues.’’
The question these authors ask is how management can work better. One could also ask,
why bother to manage this ecosystem at all? To answer this question is necessarily to
propose some goal or value—to make game fish more abundant, to remove non-native
species, to accommodate navigation, to restore the ecosystem to some pristine or earlier
state, to save the manatee, to improve water quality and clarity for recreation, to produce
water hyacinth as a crop, to engage in industrial aquaculture, to drill, baby, drill for
petroleum that might lurk there, or any of a number of other useful purposes. These goals
often conflict or compete with each other. Which to choose? Why?
This kind of question is essentially either a scientific one, or it is not. If it is, then one
looks into one’s scientific oracle to proclaim the goal of social policy, e.g., economic
efficiency, ecological integrity, environmental restoration, sustainability, biodiversity, or
something, and then one pleads for more funding for research to determine what that goal
requires in the given context. Evans et al. suggest, however, that the ‘‘profound social
uncertainty about problem definition, apparent lack of any ‘right or wrong’ answer, and
very real possibility that any intervention could create an even worse problem suggest that
Kings Bay provides an almost textbook example of a ‘wicked problem,’’’ i.e., the kind of
problem that science lacks the language or vocabulary to ask much less to answer.
Evans et al. recommend the analytic framework of adaptive management which, as they
say, was ‘‘developed as a means of managing forests and fisheries through the use of
systems ecology models and iterative scientific monitoring regimes.’’ This sounds like
science of a sort. Evans et al. also recognize that what is needed is a political process that
includes ‘‘direct involvement of citizen (i.e., non-scientist and non-manager) stakeholders’’
and gives them ‘‘a direct voice in management decisions that affect their environments and
lives.’’ If ‘‘adaptive management’’ is a political process, however, it should turn on
compromises stakeholders make in the dim light of whatever science they may want to
bring to bear. The first thing stakeholders might do, then, is to remove the scientists and the
managers from the decision-making process—to deny them a direct voice—limiting their
role to that of consultants on an ad hoc basis.
The recent history of the Kings Bay/Crystal River ecosystem poses the question whether
environmental management involves principally scientific or political decisions. To appeal
to the analytic framework of adaptive management is to punt this question. This framework
may produce a decision either (1) that is not scientifically valid, insofar as the scientific
community has had to cave into the stakeholder community, or (2) that is not politically
legitimate, insofar as the scientific community has used its authority to trump the stake-
holder community. More likely, different scientists will align with different stakeholders,
resulting in no decision but a process of indecision, influenced by unexpected events, and
affected by changing interests. As far as I can see, the method of adaptive ecosystem
management provides an academic blessing for this kind of ‘‘group grope’’—a way to
institutionalize paralysis by analysis and to guarantee indecision over the long run. The
managers of the Kings Bay/Crystal River ecosystem, even without the benefit of the
methodology of adaptive management, appear to have reached this result. Perhaps without
knowing it, they have been applying the method all along.

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