Department of Environmental
Conservation
Management of Invasive Species

Report 2019-S-26 July 2020

OFFICE OF THE NEW YORK STATE COMPTROLLER

Thomas P. DiNapoli, State Comptroller

Division of State Government Accountability

 Audit Highlights
Objective
To determine if the Department of Environmental Conservation (Department) was effectively managing
invasive species to prevent and mitigate the harmful effects of invasive species populations in New York
State. The audit covers the period April 1, 2017 through November 22, 2019.

About the Program
Many species of plants and animals currently found in New York State are not indigenous, but rather
have been introduced by humans. Subsets of these species may cause habitat degradation, loss of
native species, risks to public safety, human illness, or damage to crops and livestock and are deemed
“invasive.” Invasive species aggressively outcompete native species, adversely affecting the ecological
integrity of the State’s natural communities and systems. In New York, invasive species management
is a collaborative effort between the Department and various other agencies and entities. However,
as the State’s environmental regulatory agency, oversight responsibilities generally rest with the
Department. Invasive species are generally classified as aquatic invasive species (AIS) or terrestrial
invasive species (TIS). AIS are commonly spread via fishing and boating activities. Boat stewards
are volunteers or paid members of the community who provide the public with important information
about precautions such as cleaning, drying, and draining watercraft to reduce the spread of AIS. The
Department is authorized to enact AIS preventive measures, including public education (e.g., boat
steward education/inspection program; warning signage at public boat launches) and is responsible
for implementing and maintaining a statewide, coordinated management program, including a permit
system to control activities (e.g., dredging, mining, construction) that could inadvertently spread AIS or
TIS. The Department also performs assessments to categorize and quantify the “invasiveness” of nonnative species and their social and economic implications. These assessments allow the Department
to control the spread of non-native species through regulation. Further, the Department actively
participates in early detection methods, such as trap checking and other forms of direct observation, to
identify specific forest-related TIS.

Key Findings
While the Department has been active in establishing programs to address invasive species,
improvements in its oversight, monitoring, and communication relating to boat inspections, permits, and
early detection and assessment of invasive species could strengthen its ability to mitigate the spread of
invasive species. For example:
ƒƒ Boat stewards did not always engage boaters exiting and entering waterbodies to provide AIS and
watercraft inspection training.
ƒƒ Educational signage was not always posted or posted conspicuously, limiting its usefulness in
educating the boating public about AIS and their role in preventing its spread.
ƒƒ The Department does not consistently apply or monitor its permit system to control activities,
such as mining, dredging, and construction, that can trigger invasive species spread and further
impact the State’s biological resources. Of those permits we sampled, 84 percent did not
include provisions to mitigate the spread of invasive species even though the type of work being
performed could be a source of spread.

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1

 ƒƒ The Department also did not provide guidance on how to monitor provisions of permits that
included invasive species management.
ƒƒ We also found assessments of non-native species were not always completed or were missing
information.

Key Recommendations
ƒƒ Develop a process to, among other things, communicate duties and responsibilities to boat
stewards and coordinate with other oversight entities to improve preventive efforts across
public boat launches statewide, ensuring consistency and compliance with signage and other
requirements.
ƒƒ Develop and implement policies, procedures, or guidance on issuing permits and monitoring
compliance relating to invasive species.

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2

 Office of the New York State Comptroller
Division of State Government Accountability
July 23, 2020
Mr. Basil Seggos
Commissioner
Department of Environmental Conservation
625 Broadway
Albany, NY 12233
Dear Commissioner Seggos:
The Office of the State Comptroller is committed to helping State agencies, public authorities, and local
government agencies manage government resources efficiently and effectively. By so doing, it provides
accountability for tax dollars spent to support government operations. The Comptroller oversees the
fiscal affairs of State agencies, public authorities, and local government agencies, as well as their
compliance with relevant statutes and their observance of good business practices. This fiscal oversight
is accomplished, in part, through our audits, which identify opportunities for improving operations.
Audits can also identify strategies for reducing costs and strengthening controls that are intended to
safeguard assets.
Following is a report of our audit entitled Management of Invasive Species. This audit was performed
pursuant to the State Comptroller’s authority under Article V, Section 1 of the State Constitution and
Article II, Section 8 of the State Finance Law.
This audit’s results and recommendations are resources for you to use in effectively managing your
operations and in meeting the expectations of taxpayers. If you have any questions about this report,
please feel free to contact us.
Respectfully submitted,

Division of State Government Accountability

Report 2019-S-26

3

 Contents
Glossary of Terms 

5

Background  

6

Audit Findings and Recommendations 

9

Boat Stewards and Signage 

9

Permitting 

11

Invasive Species Identification and Assessments  

13

Early Detection Efforts 

15

Recommendations 

15

Audit Objective, Scope, and Methodology 

16

Statutory Requirements 

18

Authority 

18

Reporting Requirements 

18

Exhibit A 

19

Exhibit B 

20

Agency Comments 

21

State Comptroller’s Comment 

24

Contributors to Report 

25

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4

 Glossary of Terms
Term
Ag and Markets
AIS
DART
Department
EDDMapS
GIS
Handbook
iMap
Parks
Plan
Council Report
TIS
WISPA

Report 2019-S-26

Description
Department of Agriculture and Markets
Aquatic invasive species
Department Application Review Tracking system
Department of Environmental Conservation
Early Detection and Distribution Mapping System
Geographic Information System
New York State Watercraft Inspection Steward
Program Handbook
iMapInvasives, an invasive species tracking
database
Office of Parks, Recreation and Historic
Preservation
New York State AIS Management Plan
“A Regulatory System for Non-Native Species,”
issued by the New York Invasive Species Council
Terrestrial invasive species
Watercraft Inspection Steward Program Application

Identifier
Agency
Key Term
System
Auditee
System
Software
Policy
Database
Agency
Key Term
Guidance
Key Term
Key Term

5

 Background
Many species of plants and animals currently found in New York are not indigenous,
but rather have been introduced, intentionally or unintentionally, by humans.
While some are harmless or even beneficial, others are menacing. Subsets of
these species are deemed “invasive.” Invasive species aggressively outcompete
native species, adversely affecting the ecological integrity of the State’s fresh and
tidal wetlands, waterbodies and waterways, forests, agricultural lands, meadows,
grasslands, and other natural communities and systems. The health, economic,
and quality-of-life consequences can be enormous: shrinking wildlife habitat; loss
of native fish, wildlife, and tree species; diseased crops; contamination of water
resources; diminished recreational opportunities; and the cost to the State for its
management efforts.
In New York State, invasive species management is a collaborative effort among the
Department of Environmental Conservation (Department); Department of Agriculture
and Markets (Ag and Markets); Office of Parks, Recreation and Historic Preservation
(Parks); and various other agencies and entities. However, as the State’s
environmental regulatory agency, oversight responsibilities to protect, improve, and
conserve New York’s natural resources generally rest with the Department.
Invasive species are generally classified as aquatic invasive species (AIS) or
terrestrial invasive species (TIS) and can be plants or animals (including insects).
To meet its responsibilities, the Department has implemented a range of programs
and processes to help control the spread of both AIS and TIS. In November 2018,
the Department and Ag and Markets jointly published the New York State Invasive
Species Comprehensive Management Plan, which highlights successful invasive
species mitigation programs and provides guidance and structure for future efforts.
The Department also actively participates in early detection methods, such as trap
checking and other forms of direct observation, to identify specific forest-related TIS.
AIS are commonly spread via shipping activities and on fishing and boating gear
and equipment, and are especially rampant in the Great Lakes, Lake Champlain,
and Hudson River regions. The Department is responsible for overseeing preventive
measures to protect against AIS, including creating and posting educational
signage at public boat launches, and for implementing and maintaining a statewide,
coordinated AIS management program.
The Department is required to develop universal, downloadable AIS prevention
signage that directs the public to remove any visible mud, plants, fish, or animals
and to eliminate water before transporting equipment (e.g., watercraft or trailers).
The signage also states boaters should clean, drain, and dry anything that comes
into contact with the water. Signage is required to be conspicuously displayed by
site owners at all public boat launches. The Department is responsible for enforcing
signage requirements at Department-owned boat launches and public launches
within the Adirondack and Catskill Parks.
In July 2015, the Department released the updated New York State AIS Management
Plan (Plan), which includes an expansion of boat launch steward programs for
public and private boat launch sites and promotes consistency among them. Boat

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6

 stewards are volunteers or paid members of the community who provide the public
with important information about precautions, such as cleaning, drying, and draining
watercraft, to reduce the spread of AIS. Stewards also perform inspections of
watercraft exiting and entering State waterbodies to detect whether they are carrying
AIS. Stewards funded by the Department or Parks are required to follow the New
York State Watercraft Inspection Steward Program Handbook (Handbook). According
to the Handbook, boat stewards must:
ƒƒ Visually check boats, trailers, and gear for “hitchhiking” organisms and debris;
ƒƒ Demonstrate watercraft inspection to boaters to teach them how to conduct
inspections on their own;
ƒƒ Provide AIS spread prevention information to boaters; and
ƒƒ Collect and record standardized data, which is submitted to a Department
database.
The Department uses the Watercraft Inspection Steward Program Application
(WISPA) to standardize data collection during boat steward interactions, including
inspections, with boaters and anglers statewide. WISPA collects real-time data
on invasive species (noted during the course of a watercraft inspection or other
activities) from stewards at boat launches throughout the
State. According to Department officials, WISPA allows
them to analyze trends in boater preventive measures
and AIS awareness; track movement of boats that could
transport AIS; assess AIS risk for particular waterbodies;
and expand knowledge regarding the locations of
particular species.
According to the Plan, fishing is severely impacted by
invasive species, particularly in the State canal and
Hudson River systems where at least 154 non-native
species cause an estimated $500 million in economic
losses each year, 80 percent of which affects commercial
and sport fishing. Controlling the spread of an established
invasive species can be costly. For example, between
April 2017 and September 2019, the Department spent
nearly $1.8 million trying to control and stop the spread
of Hydrilla (see Images 1 and 2) from the Croton River
(Westchester County) to the Hudson River and its many
tributaries. The Department earmarked $6.8 million to
combat the spread of Hydrilla through December 2022.
As a pre-emptive management measure, the Department
administers a permit system to control activities, such as
dredging, mining, and construction, that have the potential
to impact New York’s biological resources by spreading

Report 2019-S-26

Images 1 and 2: Hydrilla or “water thyme”
(Hydrilla verticillata) is an aquatic plant from Asia
that is one of the most difficult aquatic invasive
species to control and eradicate in the United
States. The plant’s aggressive growth (its 20- to
30-foot stems can grow up to an inch per day)
forms thick mats that block sunlight to native plants
and can block intakes at water treatment, power
generating, and industrial facilities. Hydrilla can be
carried by currents, boats, boat trailers, and fishing
gear to new locations. These plants were observed
in Suffolk County in August (left) and June (right)
2018.

7

 AIS and TIS. However, not all such permits require measures for preventing the
spread of invasive species. The Department uses its Department Application Review
Tracking (DART) system to log and track the majority of, but not all, permits.
To further combat the spread of invasive species, the Department utilizes
assessment tools to quantify the biological “invasiveness” and the social and
economic issues, both positive and negative, posed by each non-native species.
The Department uses the tools to help categorize non-native species with sufficient
invasive characteristics into one of the following groups:
ƒƒ Prohibited Species: Unlawful to possess, import, purchase, transport, or
introduce except under a permit for disposal, control, research, or education.
ƒƒ Regulated Species: Legal to possess, sell, buy, and transport, but should not
be introduced into areas connected to public waters.
The main purpose of these assessments and groupings is to control the spread of
non-native species in the State through the regulatory process. Between February
2008 and November 2019, 566 non-native species have been assessed by the
Department, contractors, and Ag and Markets (beginning in 2012, the Department
took the lead on performing all the assessments). Effective March 10, 2015, a list of
153 invasive species (125 prohibited and 28 regulated) was approved.
The Department uses a report issued by the New York Invasive Species Council
– “A Regulatory System for Non-Native Species” (Council Report) – as guidance
for its assessment process. (The Council is a statutory body created to coordinate
efforts among State agencies and partners to address environmental and economic
threats of invasive species.) The Council Report recommends a regulatory system
for preventing importation and/or release of non-native animal and plant species, and
describes three steps for assessing unlisted or new non-native species: identifying
species for screening; prioritizing species for screening; and conducting a risk
assessment.
The Council Report identifies specific criteria to use as the basis for identifying
species for screening, including: species listed as invasive by a neighboring state
or region, non-native species in State waters that have not been reviewed, and
non-native species in nearby states or regions that have been problematic. Once
a non-native species has been identified, the prioritization process may include
consideration of the presence of the species in the State and the potential for
significant negative ecological, economic, and human health impacts. Furthermore,
reassessing species periodically is necessary because the information used to
assess both invasiveness and socio-economic impact can change over time.
The Department also uses iMapInvasives (iMap), an online invasive species
database and mapping tool, to document and share invasive species observation,
survey, assessment, and treatment data. According to Department officials, iMap
includes data on regulated invasive species as well as other non-native species that
are not yet regulated.

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8

 Audit Findings and Recommendations
The Department has been active in establishing programs and tools, such as iMap
and WISPA, to prevent and limit the spread of invasive species. For example, in
2017, the Department began using WISPA to collect and record standardized boat
inspection and interaction data. The Department also implemented a five-year
plan that includes expanding the boat steward program for public and private boat
launch sites to ensure program consistency. Furthermore, there are decontamination
stations in certain areas to help prevent the spread of invasive species. However, we
found the Department could improve its oversight, monitoring, and communication in
some areas for more effective management of invasive species.
We found boat stewards were not always engaging owners and operators of
watercraft exiting and entering waterbodies, and educational signage at launch sites
was not always present or was poorly located. We also found early detection efforts
could be improved, and assessments of invasive species were not always completed
or were missing information. In addition, the Department did not have policies and
procedures for issuing and monitoring compliance with permits for work that has the
potential to spread AIS or TIS, identifying conditions that could trigger assessments
of non-native species, and completing periodic testing of trap samples for potentially
invasive species. Policies and procedures in these areas would help bring direction
and consistency to daily operations and facilitate long-term strategic planning.

Boat Stewards and Signage
The Department has taken measures to combat the spread of AIS on State waters,
creating and posting required preventive signage and contracting or partnering with
boat stewards to inspect boats entering and exiting public waters and educating the
public on reducing the spread of AIS. According to Department records, stewards
completed and recorded over 242,000 watercraft inspections in WISPA in 2019.
However, we found several areas where the Department could improve its AIS
spread prevention efforts to mitigate the risk of harm to the State’s environment (e.g.,
destruction of native species) and economy as well as human health (e.g., through
consumption of harmful AIS, such as non-native fish containing high levels of heavy
metals).
Between January 2018 and June 2019, there were 837 public boat launches
throughout the State, including: launches with hard surface ramps that allow for
float off/on launching and retrieving for most trailered boats; trailer launches suited
for small, light boats that may not be able to be launched or retrieved with a trailer
due to shallow waters; and hand launches, where boats must be carried into the
water. With the aid of Geographic Information System (GIS) software, we used
boat launch and WISPA data to identify the presence of boat stewards and invasive
species at boat launches (see Exhibit A). We found stewards were present at 194 of
the 837 launch sites. Department officials stated they contract with stewards at 158
locations, and Parks, private lake associations, towns, and grantees contract with
the remaining 36. Department officials state they assign stewards to boat launches
based on factors such as the confirmed presence of AIS, volume of boat traffic, and
opportunities presented by location (e.g., where a steward at a roadside or “gateway”

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9

 launch location could provide coverage for multiple adjacent
waterbodies).
Based on our analysis of the watercraft launch and retrieval
data in WISPA, we determined that, of the 194 boat launch
sites where stewards were present, 42 were high-risk areas.
That is, at these sites, stewards recorded invasive species,
such as Eurasian Watermilfoil or Zebra mussels (see Image
3), on at least 25 percent of watercraft retrievals.
We conducted site visits at 30 of the 42 boat launches.
Stewards under the Department’s oversight were assigned to
14 of the sites; the others were overseen by Parks or other
entities (12) or did not have stewards assigned during the
2019 boating season (4).

Image 3: Zebra mussel (Dreissena
polymorpha) is an aquatic invertebrate
originally from Russia. It can reduce native
mussel and crayfish populations and produce
toxins that can kill animals and harm humans.
Zebra mussel infestations can also clog power
plants and drinking water intakes, and their
removal is costly to cities and power plants.
These zebra mussels were observed in
Oswego County in September 2018.

At the time of our visit, stewards were present at 11 of the 30
boat launches; 7 of the 11 sites fell under the Department’s
oversight. We found stewards were not inspecting all
watercraft launched and/or retrieved at 5 of the 7 sites. In
some instances, the location of the steward’s inspection
station did not allow a clear view of watercraft launching or
exiting, likely limiting the stewards’ ability to identify boats
for inspection. In other instances, stewards did not approach boaters leaving the
waterbody despite our observations that they were aware of the watercraft exiting.
Additionally, we found one boat steward did not record all inspections performed in
WISPA – information that is essential for addressing AIS across the State.

Stewards may benefit from increased communication and monitoring from the
Department regarding their responsibilities, including inspecting watercraft and
recording inspections in WISPA, to ensure duties are consistently being performed.
Additionally, we observed 140 watercraft launches and
178 retrievals at 23 of the 30 sites while boat stewards
were not present. We observed that, for 52 percent of the
watercraft retrieved, boat operators did not perform any
preventive measures, and for another 45 percent, only
limited preventive measures (e.g., limited cleaning) were
performed before leaving the launch site (see Image 4).
We also found instances of watercraft with visible debris
entering the waterbody or leaving the boat launch site.
The Department asserted that preventive measures can
be performed at locations other than the boat launch
where we made our observations, but cannot confirm
this happened. However, measures taken just before
entering or just after exiting would be the most effective in
preventing the spread of invasive species.

Report 2019-S-26

Image 4: We observed watercraft owners not
performing AIS spread prevention measures and
others attempting to perform such measures but
failing to remove all debris from their watercraft or
trailer before leaving the site.

10

 At 6 of the 23 launch sites where boat stewards were not present at the time of our
visit, we found no signage posted. At 2 other sites, signage was not conspicuously
displayed: at one, a barrier blocked the sign, and at the other, the sign was
small and distant from the launch site. The lack of clearly displayed AIS spread
prevention signage could be contributing to watercraft owners not taking reasonable
precautions.
We visited 100 of the remaining 643 boat launch sites where
no boat stewards were assigned to determine if appropriate
AIS signage was displayed, and found no AIS spread
prevention signage at 45. At another 8, the signage was not
conspicuously displayed (see Image 5).
According to the Department’s boat launch data, there had
been AIS sightings at 42 of the 53 sites where AIS signage
was not conspicuously displayed or not present at all. Of
the 53 sites, the Department was responsible for enforcing
signage requirements at 10. Although the Department is
not directly responsible for signage at the other locations,
coordination with other oversight entities would improve
preventive efforts across public boat launches statewide,
ensuring more consistent signage.

Image 5: Example of signage not
conspicuously displayed.

Outreach and education are effective ways to combat the spread of AIS. The more
people are made aware of the necessity of cleaning, drying, and draining boating and
fishing equipment before using it elsewhere, the less likely AIS will be spread to new
waters. The public may not be aware of their obligation or the dangers of spreading
AIS if signage is not present or visible or if boat stewards do not consistently inspect
watercraft and educate water recreationists.

Permitting
We found the Department could improve the process for issuing and monitoring
environmental permits to mitigate the potential spread of AIS and TIS. Because
DART does not specifically track whether environmental permits contain conditions
for preventing the spread of invasive species, officials could not provide a complete
population of all permits that contain these requirements. Additionally, the
Department does not have policies or procedures outlining when its regional offices
should include such conditions when issuing permits.
We analyzed DART data and found the Department issued 27,349 environmental
permits between April 2017 and October 2019 for activities that could potentially
contribute to the spread of invasive species. Permits were issued for activities such
as mining, construction of dams, dredging, dock repairs, and other projects in close
proximity. With the aid of GIS software, we used both the DART and Department
data reported in iMap to identify which of these permits were for activities close to
locations where invasive species have been observed – locations with a higher risk
of spreading invasive species. We identified 2,314 permits for activities located within

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11

 a quarter-mile of invasive species sightings between
April 2012 and March 2017 (see Exhibit B). The majority
of these permits were issued for work near a prohibited
invasive species, such as Giant Hogweed (see Images
6 and 7), which is not allowed to be transported,
introduced, or propagated.
Of the 2,314 permits, we sampled 150 from three
Department regional offices. We confirmed 146 (97
Images 6 and 7: Giant Hogweed (Heracleum
percent) described work activities that could potentially
mantegazzianum) is a large invasive plant that
spread invasive species. Most of these activities
can cause painful burns and permanent scarring.
included the use of construction equipment to move dirt, Brushing against or breaking the plant releases sap
dredge, install docks, or repair shorelines and banks.
that, combined with sunlight and moisture, can cause
a severe burn within 24 to 48 hours. These plants
We found 123 of the 146 permits (84 percent) did not
were observed in Cayuga County in July 2018.
include conditions to mitigate the potential spread of
invasive species. The remaining 23 included written
conditions to help control the spread of invasive species. However, while these
permits contained general monitoring conditions subject to inspection by the
Department, no guidance was provided to regional staff on how to monitor the
provisions of the permit relating to invasive species.
In some cases, regional staff did not monitor any provisions of the permits.
Additionally, while DART has several options for adding invasive species
management provisions to environmental permits, the Department has not provided
guidance on when staff should use these options. Rather, this is at the discretion of
regional staff, creating little consistency regarding the timing and types of conditions
added to the permits.
Also, while iMap is readily available to regional staff who develop permits, not all
are aware the tool exists and therefore are not utilizing it to assess invasive species
risks when issuing permits. Instead, regional staff rely on self-reported information
from the permittee or information provided on the application to make these
determinations.
The Department stated that discussions regarding the spread of invasive species
commonly occur in reviewing large projects, such as pipelines, because the risk for
spreading invasive species is a major concern when equipment must cross multiple
streams and wetlands during construction. However, as we found in our review,
Department efforts to limit the spread of invasive species through environmental
permits are inconsistent.
In addition to the environmental permits found in DART, the Department issues
general permits to five utility companies for maintenance and management of
vegetation near utility transmission lines. The Department developed a best practices
document to guide permittees on minimizing the spread of invasive species when
performing work under these general permits. Each time permittees want to perform
maintenance work under these permits, they must notify the Department through a
notice of intent. Each region is responsible for reviewing these notices to determine

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 whether there are any potential issues or whether any other controls or conditions
need to be assigned under the permit. However, the Department’s central office does
not monitor or oversee compliance with the permit terms or whether regional offices
are adequately monitoring compliance, nor is it notified when a permittee issues a
notice of intent.
Clear policies, procedures, and guidance would enhance consistency among regions
for mitigating the spread of invasive species and provide a standard the Department
could use in its oversight function.

Invasive Species Identification and Assessments
Assessments are essential for controlling the spread of non-native species in the
State, as they establish which species warrant regulation. Of the 566 non-native
species assessments conducted by the Department, contractors, and Ag and
Markets between February 2008 and November 2019, we found 100 were not
complete:
ƒƒ 34 non-native species designated as prohibited were not fully assessed for
socio-economic impact; and
ƒƒ For 66 non-native species, which were ultimately deemed not to be regulated
or prohibited, answers were missing for the assessment questions that serve
as the basis for classification and regulation decision making.
The Department recognized the gaps in the 34 assessments of prohibited invasive
species, and stated they were due to staffing issues at Ag and Markets when the
assessments were performed. Furthermore, the Department explained that, although
the Council Report provides assessment guidance, the rule-making process does
not require that assessments be conducted prior to establishing prohibited and
regulated species lists. However, it has been over five years since the species were
deemed prohibited in regulation. Without timely, complete assessments, the potential
harmful effects of these species on the State are not apparent. We encourage the
Department to complete these 100 assessments to ensure decision makers have
a thorough understanding of the impact of these invasive species. The Department
responded that it is working on this, but also indicated additional resources would be
needed.
The Department has made considerable efforts to identify potential invasive species
and has completed assessments on 566 non-native species. However, we identified
possible improvements. While the Council Report offers some guidance on the
identification of potential invasive species, it does not provide specifics for when a
full assessment is warranted. Similarly, the Department lacks any written policies or
procedures in this area.

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 Using both Department data reported in iMap and data reported in the Early
Detection and Distribution Mapping System (EDDMapS), a publicly available webbased mapping system similar to iMap maintained by the Center of Invasive Species
and Ecosystem Health at the University of Georgia, we identified an additional 279
non-native species unassessed by the Department that may pose a threat to the
State. EDDMapS defines invasive species in the same way as New York State and
combines information from other databases to create a national network of invasive
species distribution data, which is reviewed by state verifiers to ensure accuracy,
according to its website.
The Department explained that 91 of the 279 species reported but not assessed –
40 of which have had confirmed sightings in the State between January 2014 and
March 2019 (in some cases, with over 100 reported sightings of a single species)
– are currently being tracked in iMap and didn’t show invasive traits affecting the
environment, human health, or the economy. However, the Department was unable
to support its conclusion that full assessments were not warranted. We researched
some of these species and found evidence of potential adverse effects to human
health and the environment (see examples in Images 8–10).

Deer Ked
(Lipoptena cervi)

Japanese Yew
(Taxus cuspidata)

Dasy; Red Alga
(Heterosiphonia japonica)

Image 8: Traditionally found in
Norway, Sweden, and Finland,
this species of biting deer fly has
been found to carry diseases
such as Lyme disease.

Image 9: Potentially one of the
most poisonous woody plants
in the world, it can be harmful to
humans, livestock, wild animals,
and fish.

Photo Source:
iStock.com/Hendrick_L

Photo Source:
iStock.com/Yicheng Du

Image 10: Native to Asia, it
can reduce oxygen levels in
water and can take nutrients
native species rely on,
reducing the diversity of local
species.
Photo Source:
iStock.com/Philip Openshaw

We reviewed all invasive species observations in EDDMapS from April 2017 to
June 2019 in New York State and certain states’ counties directly bordering New
York State (Connecticut, Massachusetts, New Jersey, Pennsylvania, and Vermont).
Because these counties directly border New York, the ecosystems are similar and
likely susceptible to the same invasive species. We compared EDDMapS and iMap
data and identified 188 invasive species the Department was not tracking on iMap.
These species were not assessed, are not scheduled to be assessed, and are not
being tracked in iMap.

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 Early Detection Efforts
We also found the Department may be missing opportunities
for early identification of potential invasive species. Based on
interviews with regional staff, we found they were unaware
of iMap and the data it contains – information that could be
useful for managing the spread of invasive species. Also,
while the Department actively participates in early detection
methods, such as trap checking and other forms of direct
observation, to identify specific forest-related TIS, the traps
are not always thoroughly checked for all potential invasive
species. For example, only after the U.S. Forest Service
requested the Department check trap samples for a potential
invasive species, similar to the emerald ash borer (see Images
11 and 12), was the non-native species identified in one area
of the State. The Department explained some trap samples
(prioritized by location) are thoroughly analyzed, while others
are not. Officials state a lack of staffing prevents them from
checking all traps for all potential invasive species.

Recommendations
1.  Develop a process to:

Images 11 and 12: Emerald ash borer
(Agrilus planipennis) is an invasive beetle
from Asia that infests and kills North American
ash species including green, white, black, and
blue ash. All of New York’s native ash trees
are susceptible to the beetle. Infestations are
now present in more than 40 counties in the
State. The emerald ash borer and its activity
were observed in Albany County in June 2018
(left) and September 2018 (right).

ƒƒ Communicate duties and responsibilities to boat stewards;
ƒƒ Monitor steward performance and compliance against standards
outlined in the Handbook; and
ƒƒ Coordinate with other oversight entities to improve preventive efforts
across public boat launches statewide, ensuring consistency and
compliance with signage and other requirements.

2.  Develop and implement policies, procedures, or guidance on:
ƒƒ Issuing permits and monitoring compliance relating to invasive species;
ƒƒ Circumstances that warrant adding specific invasive species
management mitigation provisions to permits;
ƒƒ Identifying non-native species and conditions that should trigger
assessments for non-native species; and
ƒƒ Periodic complete testing of trap samples for potentially invasive
species.

3.  Communicate the existence of and potential uses of iMap to regional staff.
4.  As soon as practicable, finish all incomplete assessments.

Report 2019-S-26

15

 Audit Objective, Scope, and Methodology
The objective of our audit was to determine if the Department was effectively
managing invasive species to prevent and mitigate the harmful effects of invasive
species populations in New York State. The audit covers the period April 1, 2017
through November 22, 2019.
We examined the Department’s internal controls and assessed their adequacy as
they related to our audit objective. We reviewed applicable policies, procedures,
laws, and regulations, and interviewed Department staff responsible for managing
invasive species and permitting.
We obtained and used data from several Department sources, including WISPA,
DART, and assessments data. We generally found the data to be sufficiently reliable
for purposes of our audit. To accomplish our objective, we obtained and reviewed
the Department’s data on 837 public boat launch sites across the State and obtained
WISPA data. We found the data, while in some cases incomplete (WISPA) or of
undetermined completeness (boat launch data), was sufficiently reliable for our
audit purposes. None of the samples selected for our audit testing were projected or
intended to be projected across the populations as a whole.
With the aid of GIS software, we used both the boat launch and WISPA data to
identify the presence of boat stewards at 194 launch sites and the absence of
boat stewards at 643 of the 837 launch sites from January 2018 to June 2019. We
further analyzed the WISPA data and found 42 of the 194 boat launch sites were
high-risk areas where invasive species could potentially be spread. At these sites,
WISPA data showed that stewards recorded the presence of invasive species on
watercraft at least 25 percent of the time upon the retrieval of the watercraft from
the waterbody. We selected a judgmental sample of 30 (of the 42) boat launch sites
to visit to determine if the public is taking AIS spread prevention measures and if
the appropriate educational signage was present. Our selection of the 30 sites was
based on WISPA data, which identified sites with at least 25 percent more watercraft
launches recorded than retrievals. Of the 643 launch sites, we judgmentally selected
a sample of 100 launch sites to visit to determine if the appropriate educational
signage was present. Our selection of the 100 sites was based on the type of
launches (non-hand launch).
From the Department’s DART data, we reviewed 32 different active permit types
from April 2017 to October 2019. We identified 13 types (27,349 permits) that include
permitted activities, such as mining operations, construction of dams, or dredging,
that could potentially contribute to the spread of invasive species. We also obtained
and reviewed the Department’s data reported in iMap. We could not test to determine
the reliability of the data; however, the information we used is publicly available
and the application is commonly used by the Department and other entities such
as environmental groups, all of whom have a vested interest in the accuracy of this
data, which provides some control of its reliability. We used iMap to determine what
steps the Department may be taking based on the publicly reported information. With
the aid of GIS software, we used both the DART and data reported in iMap to identify
which of these permits have a higher risk of potentially spreading invasive species

Report 2019-S-26

16

 because the activities being done are very near invasive species. We identified
2,314 permits with activities performed within a quarter-mile of confirmed sightings
of invasive species between April 2012 and March 2017. Of the 2,314 permits, we
judgmentally sampled a total of 150 from three of the nine regional offices, selecting
those with the greatest number of permits issued and invasive species sightings to
identify permits at high risk of spreading invasive species.
We also obtained and reviewed invasive species observation data from April 2017
to June 2019 from EDDMapS. Similar to iMap data, we could not test to determine
the reliability of the EDDMapS data; however, the information we used is publicly
available and the application is commonly used by entities such as environmental
groups.
As part of audit procedures, the audit team used GIS software for geographic
analysis. As part of the geographic analysis, we developed visualizations (see
Exhibits A and B) to improve understanding of our report. Portions of the maps
contained in this report include the intellectual property of ESRI and its licensors and
are used under license. Copyright © 1987-2020 ESRI and its licensors. All rights
reserved.

Report 2019-S-26

17

 Statutory Requirements
Authority
This audit was performed pursuant to the State Comptroller’s authority in Article V,
Section 1 of the State Constitution and Article II, Section 8 of the State Finance Law.
We conducted our performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform
the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objective. We believe the evidence
obtained provides a reasonable basis for our findings and conclusions based on our
audit objective.
In addition to being the State Auditor, the Comptroller performs certain other
constitutionally and statutorily mandated duties as the chief fiscal officer of New
York State. These include operating the State’s accounting system; preparing
the State’s financial statements; and approving State contracts, refunds, and
other payments. In addition, the Comptroller appoints members to certain boards,
commissions, and public authorities, some of whom have minority voting rights
These duties may be considered management functions for purposes of evaluating
threats to organizational independence under generally accepted government
auditing standards. In our opinion, these functions do not affect our ability to conduct
independent audits of program performance.

Reporting Requirements
A draft copy of the report was provided to Department officials for their review and
comment. Their comments were considered in preparing this final report and are
attached in their entirety at the end of it, along with our own State Comptroller’s
Comment addressing specific Department statements. In general, officials agreed
with our recommendations.
Within 180 days after final release of this report, as required by Section 170
of the Executive Law, the Commissioner of the Department of Environmental
Conservation shall report to the Governor, the State Comptroller, and the leaders of
the Legislature and fiscal committees, advising what steps were taken to implement
the recommendations contained herein, and where recommendations were not
implemented, the reasons why.

Report 2019-S-26

18

 Exhibit A

 

Click to View the Interactive Map

 

Invasive Species and Stewards at NYS Boat Launches?

 

 

 

Legend
I Presence of Invasive Species but No Steward

CI Presence of Invasive Species and Steward

 

 

I No Presence of Invasive Species

 

?Bcat launch information, including presence of invasive species, as of June 2019.
Presence of boat stewards is between Januaryr 2018 and June 2019.

Esri, HERE, Garmin, DpenStreetMap contributors, and the GIS user community

 

 

 

 

Report 2019-8-26 19

Exhibit 

 

Click to View the Interactive Map

 

Permitted Activity at Risk of Spreading Invasive Species*

 

 

 

  
 
  

Legend
I Presence of Prohibited Species
0 Presence of Regulated Species .
0 Presence of Other {Non-Native) Species 
I No Presence of Invasive or Non-Native Species

 

 

 

*Perrnits were classified based on the presence of invasive species between April 2012 and March 201?
within ?Ai mile associated with the type of permitted activities between April 201il and October 2019.

 

 

Esri, HERE, Garmin, OpenStreetMap contn'butors, and the GIS user community

 

 

Report 2019-8-26 20

Agency Comments

 

OFFICE QF THE COMMISSBONER

New York State Department of Environmental Conservation
625 Broadway, 14th Floor, Albany, New York 12233-1010
P: (518) 402-8545 i F: (518) 402-8541

JUN 18 2020

Mr. Mark Ren

Office of the State Comptroller

Division of State Government Accountability
110 State Street 11th Floor

Albany, New York 12236-0001

Dear Mr. Ren:

The Department of Environmental Conservation (DEC) has reviewed the Office of the
State Comptroller?s Draft Audit Report entitled Management of Invasive Species. 
comments with respect to this report are contained in the enclosed document. Please
contact Andrew Fischler, Director of Internal Audit, at (518) 402-9761 if you have any
questions.

Sincerely,



Basil Seggos
Commissioner

Department of
Environmental
Conservation

ZJ/?rrtw
YORK


 

 

 

Report 2019-8-26

21

Department of Environmental Conservation
Management of Invasive Species
2019-S-26
Response to OSC Draft Report
The Department of Environmental Conservation (DEC) has reviewed the Office of the State Comptroller’s,
March 5, 2020, draft report in connection with the management of invasive species. DEC’s Bureau of Invasive
Species and Ecosystem Health (BISEH) places the highest priority on early detection of and rapid response to
high-impact invasive species that may threaten the health of our lands and waters. BISEH collaborates with
numerous stakeholders including Federal and State agencies and non-governmental organizations to provide
expertise, assistance, and action where invasive species are a threat within the State. These efforts have
minimized the introduction, establishment and spread of exotic pests like Eurasian boar, northern snakehead,
hydrilla, and Asian longhorned beetle.
The following is DEC’s response to the report’s findings and recommendations.
Findings – Invasive Species Assessments
• Pages 1, 9, and 13: There are references to “missing information and/or answers” associated with
DEC’s assessments of invasive species. These instances refer to assessments of invasive species
wherein select questions were completed with the answer of “unknown.” An answer of unknown does
not constitute an incomplete assessment, it means that information was not available. Assessments of
invasive species with “unknown” responses to questions are complete assessments.

Comment 1

• Page 13: Regarding the sentence stating, “we found 100 (non-native species assessments) were not
complete,” we agree that 34 of these were not complete; however, the remaining 66 are complete. As
previously explained, these assessments included “unknown” as the answer to questions, which does not
make them incomplete.
Recommendations
1. Develop a process to:
• Communicate duties and responsibilities to boat stewards;
• Monitor steward performance and compliance against standards outlined in the Handbook; and
• Coordinate with other oversight entities to improve preventive efforts across public boat launches
statewide to ensure consistency and compliance with signage and other requirements.
DEC Response: We generally agree with the recommendation and will work to further strengthen
internal controls associated with the monitoring of boat stewards, subject to DEC oversight, to ensure
they are performing their assigned duties. DEC will continue to encourage communication with boaters,
anglers, and other recreational water users to raise awareness about aquatic invasive species and
practices that reduce the chance of spreading aquatic invaders.

1

Report 2019-S-26

22

 2. Develop and implement policies, procedures, or guidance on:
• Issuing permits and monitoring compliance relating to invasive species;
• Circumstances that warrant adding specific invasive species management mitigation provisions to
permits;
• Identifying non-native species and conditions that should trigger assessments for non-native species; and
• Periodic complete testing of trap samples for potentially invasive species.
DEC Response: We generally agree with the recommendation and have undertaken additional steps to
improve the consistent and appropriate inclusion of permit conditions related to the control of invasive
species. During DEC’s permitting process, it is common for staff to address concerns regarding the
spread of invasive species where the project involves equipment, such as boat, gear, or trailers, crossing
multiple streams or wetlands during construction.
3. Communicate the existence of and potential uses of iMap to regional staff.
DEC Response: We generally agree with the recommendation and in order to make iMap more fully
known and consistently utilized, DEC has scheduled training to educate regional staff on its effective
use and will continue future trainings as necessary.
4. As soon as practicable, finish all incomplete assessments.
DEC Response: We agree, generally, with the recommendation that assessments should be complete.
However, we disagree with the finding that 100 assessments were not complete and will therefore
complete assessments of the 34 that we agree were incomplete.

2

Report 2019-S-26

23

 State Comptroller’s Comment
1. Although during the initial assessments, some of which date back to 2008, there may have been

information that was unknown at the time, Department officials have not updated the assessments
or determined if this information has since become known to answer critical questions (e.g.,
ecological impact, difficulty of control). As of the time of our audit, officials could not state whether
the information was still “unknown” or whether the assessments were simply not updated.
Therefore, for purposes of our audit, we considered them incomplete.

Report 2019-S-26

24

 Contributors to Report
Executive Team

Tina Kim - Deputy Comptroller
Ken Shulman - Assistant Comptroller

Audit Team

Steve Goss, CIA, CGFM - Audit Director
Mark Ren, CISA - Audit Director
Heather Pratt, CFE - Audit Manager
Brandon Ogden - Audit Supervisor
Andre Spar, MBA - Examiner-in-Charge
June-Ann Allen - Senior Examiner
Mark Womeldorph - Senior Examiner
Rachelle Goodine - Mapping Analyst
Rachael Southworth - Mapping Analyst
Mary McCoy - Supervising Editor
Andrea Majot - Senior Editor

Contact Information
(518) 474-3271

StateGovernmentAccountability@osc.ny.gov

Office of the New York State Comptroller
Division of State Government Accountability
110 State Street, 11th Floor
Albany, NY 12236

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For more audits or information, please visit: www.osc.state.ny.us/audits/index.htm