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The U.S. Fish and Wildlife Service (USFWS) developed an invasive species risk assessment procedure, presented in Marcot et al. (2019), consisting of an existing rapid assessment process for plants and animals (Ecological Risk Screening Summary; ERSS) and a new probability-based Bayesian network model (Freshwater Fish Injurious Species Risk Assessment Model; FISRAM), that may be used to help prioritize invasive freshwater fish species for Federal injurious wildlife listing evaluation by USFWS under the Lacey Act. Hill et al. (2020) provided a rebuttal letter of Marcot et al. (2019) but did not critique FISRAM, the main subject of that paper. They focused instead on the ERSS process and on our characterization of several other existing risk assessment models and procedures. Here we provide our reciprocal rebuttal by addressing their criticisms. Hill et al. (2020) implied that we equate the Fish Invasiveness Screening Kit (FISK) and Aquatic Species Invasiveness Screening Kit (AS-ISK) to the USFWS risk analysis process for listing species as injurious, their “apples to oranges.” However, the USFWS process for evaluating species to list is an extensive risk analysis process explained in our paper that follows laws and standards and optionally includes ERSS as a rapid screen in an early stage. Their interpretation that we compared our rigorous listing process to the risk screening tools FISK and AS-ISK was incorrect. We explain how we use expert opinion and reiterate that the information inputs for the ERSS reports, primarily climate match and invasiveness history, are good predictors of species invasion and are appropriate for a rapid screen for use in many situations. Their criticism of a lack of regional calibration of ERSS is answered by the ERSS climate-matching heat maps that show a color-calibrated continuum of climate match for the contiguous United States. We further explain our comprehensive peer review process and why their suggestion to have each ERSS report peer reviewed is infeasible. We also discuss their letter’s misrepresentation of the injurious wildlife listing process, which can use ERSS and FISRAM to advise prioritization and to provide documentation and decision support. All models described in our paper have value, and management entities should review the literature published by the respective developers to learn of their individual utility.

Comparing Invasive Species Risk Screening Tools FISRAM, ERSS, and FISK/AS-ISK as a response to Hill et al. (2020)