After conversation with APHIS I redid my first WRA for Perilla
“John,
I reviewed your draft assessment to provide you with some feedback. It may or may not be relevant for the meeting, but at least you get a feel for the process. Based on the evidence you have provided (not necessarily your answers) I get the impression this is an invasive species (in the strict sense (ie, can naturalize and spread)) but there really isn’t any significant evidence of impact. While not common, these kinds of results make sense. I am sure we can all think about several native species that are widely distributed but uncommon elements in the landscape. There are several exotic species like this, and in my opinion, are well behaved (e.g., the Hellborine orchid). Currently, and perhaps after revision, your species will fall out in the High Risk region, but will have a very low to nonexistent impact score. This is a perfect example of where managers need to look at a species’ entire risk profile to make an appropriate decision. In this case, I would probably choose not to regulate this plant simply due to the low impact score. Again, keep in mind I am going directly off of the evidence you provided.
Hope this helps you understand better our process and some of the types of scenarios you may have.
Tony”
