1. do you agree/disagree…

ERO number

019-1162

Comment ID

45350

Commenting on behalf of

Individual

Comment status

Comment approved More about comment statuses

Comment

1. do you agree/disagree that we should review the identified species and carrier for regulation under the Invasive Species Act, 2015
Strongly agree. Your species profiles, which I assume have also been the subject of risk assessment, suggest a high likelihood on establishment and subsequent environmental and economic damage. Especially in this period of unknown climate change impacts it has become more important than ever to protect and support natural ecosystems. Since we share may water bodies across boundaries and boarders it is also important to take a common approach to restricting the possession and movement of the listed species.

2. do you have information, including personal experiences, that would help us as this review proceeds
As a hunter and angler, and a retired conservation officer, I have seen firsthand the negative effects of invasive species (aquatic and terrestrial). It was especially dismaying to encounter boats on trailers travelling across Ontario, or entering into Ontario, with aquatic plants visible and sometimes with fully charged live wells or wet bilge holds, knowing the damage that could result but having no statutory authority to stop the activity. Despite years of public education this remains the experience of every officer in the province, we are overdue to take regulatory action in this area.

3. would the regulation of one or more of the proposed species or carrier have a positive or negative economic impact on you or your business
While I believe this question is intended to seek input from those in the aquarium and water garden trade I believe the failure to regulate these species, and the carrier vector, has and will continue to, have a negative economic impact on natural resources dependant businesses like tourism, and sport, bait and commercial fisheries, across Ontario.

4. what rules do you recommend be applied to some or all the identified species or carrier – see sections 6, 7, or 8 of the Invasive Species Act, 2015 for more information

Marbled crayfish - Section 7; requires aquarium trade inspection program
Tench – Section 7; also prohibit bait harvest from known waters; requires commercial bait inspection program
New Zealand mud snail – Section 7
European frogbit – Section 7; supported by watercraft carrier regulation
Yellow floating heart – Section 7; water garden trade inspection program
Prussian carp – Section 7; requires aquarium trade inspection program
Red swamp crayfish - Section 7; requires aquarium trade inspection program
Fanwort - Section 7; requires aquarium trade inspection program
Bohemian knotweed - Section 8
Giant knotweed - Section 8
Himalayan knotweed - Section 8
Mountain pine beetle – Section 7 and section 6 for wood product loads; exporters, importers and transporters of wood products must take reasonable steps to ensure shipments are clear;
Wild pigs – Section 8. The agricultural possession of pigs, other than domestic pigs, ought to be prohibited

5. should we consider exceptions to the prohibitions during the development of the regulatory proposal (e.g. allowing the import of the species provided individuals are dead)
Only in terms of pig carcasses.

Additionally
You should also consider a “white list” approach to species for the aquarium, live fish market and water garden trade sectors. This would allow business certainty and would avoid the development of supply and demand networks only to have the species in question prohibited at a later date.