To the Environmental…

To the Environmental Registry of Ontario
Re: Regulating 13 invasive species and watercraft as a carrier of invasive species under Ontario’s Invasive Species act, 2015

June 4, 2021

The Algonquin to Adirondack Collaborative (A2A) is pleased to have the opportunity to provide comment on the list of invasive plants that are proposed for regulation as well as the proposal to review the potential benefits of regulating watercraft movement over land as a carrier under the Invasive Species Act, 2015 (ISA).

The A2A region encompasses Adirondack Park, in New York State, and Algonquin Park, in Ontario, and the lands and waters connecting them. It is one of the last major intact north-south forest and wetland corridors in Eastern North America. It provides essential habitats for a vast number of species: mammals, migratory birds, and many other organisms. Scientists have recognized for decades what First Nations peoples have known for generations: that the A2A region has a unique and essential role to play in wildlife conservation in North America.

A2A is a multi-national (U.S., Canadian and First Nations) organization of over 50 partners dedicated to conserving and connecting lands and people across the Algonquin to Adirondacks region. We promote a healthy environment for wildlife and people. Connected habitat allows animals and plants to fulfill their needs and survive adversities such as climate change. A2A has identified Invasive Species as a one of 5 major threats to achieving our mandate. Providing strict regulation of these species on a provincial level is a key first step to halting their spread.

The A2A Collaborative has initiated a multistage project to bring Conservation Action Planning (CAP) to the A2A Region. The CAP framework is made up of four basic components: defining a conservation project; developing conservation strategies and measures; implementing the strategies and measures; and using project results to adapt and improve. This framework is applied around the world in almost every type of ecoregion.

One of the goals of CAP is to ensure that conservation and community activities and investment in the area are as collaborative, strategic, efficient and measurable as possible. A2A has now undertaken a CAP to deal with the invasive plant species spreading within the Frontenac Arch Biosphere region. Specifically, threats identified in the CAP include invasive aquatic and wetland species and invasive terrestrial species. A2A is leading this CAP, partnering with, among others, Parks Canada, the Ontario Invasive Plants Council, Charleston Lake Park, Ontario Nature and the Nature Conservancy of Canada, with guidance from the St. Lawrence Eastern Lake Ontario Partnership for Invasive Species Management (SLELO).

Based on our findings thus far, here are A2A’s recommendations:

1 We support the proposal by the MNRF 2 Ontario Invasive Plant Council Comments on ERO-019-1162 to regulate European Frog-bit (Hydrocharis morsus-ranae) as Prohibited, and the following plants be regulated as Restricted.
• Yellow Floating Heart (Nymphoides peltata)
• Carolina Fanwort (Cabomba caroliniana)
• Bohemian Knotweed (Reynoutria × bohemica
• Giant Knotweed (Reynoutria sachalinensis)
• Himalayan Knotweed (Koenigia polystachya)

2 A2A further suggests that the following species and their subspecies and cultivars be listed and that consideration be given to reviewing existing risk assessments conducted elsewhere in North America (and/or conducting MNRF’s own risk assessments immediately or within the coming year).
• Tree of Heaven, (Ailanthus altissima)
• White Mulberry (Morus alba)
• Flowering Rush (Butomus umbellatus)
• Winged Burning Bush (Euonymus alatus)
• Oriental/Asiatic Bittersweet (Celastrus orbiculatus)
• Norway Maple (Acer platanoides)
• Common (Rhamnus cathartica) and Glossy Buckthorn (Frangula alnus)

3 Landowners and managers of public lands who have identified invasive plants on their properties need assistance from the Province, given that many invasive plants are now threatening large portions of the southern parts of the province, particularly in south-eastern Ontario. A2A recommends that an Invasive Species Fund be created, to support efforts by non-profits to eliminate or control invasive plants on priority lands, both public and private. Criteria for what constitutes “priority lands” should be defined the province. Best Management Practices have already been established by organizations such as the Ontario Invasive Plant Council, and could serve as the backbone of the projects, which could end up providing excellent summer jobs for student interns.

4 We feel that the strictest possible regulations be in place to prevent the movement of invasive species from one water body to another through the vector of watercraft and trailers. Watercraft owners need to take responsibility for the condition of their crafts when leaving a water body and entering another. Thus A2A also supports the proposal in regard to overland carrier transport as a step in the right direction. Preventing the establishment and spread of invasive species is more effective and makes better economic sense than trying (and usually failing) to manage impacts after an invasive species has become established. A2A supports implementing tighter regulations such as requiring standard cleaning practices be undertaken to remove all aquatic plants from the external and internals parts of boats, trailers and other equipment that may have entered the water from the boat and then funding the capacity for enforcement. Teaching standardized procedures is essential, since boaters have different conceptions of what effective cleaning practices are.

A2A recommends that the Province of Ontario establish cleaning stations at major entry points into lakes, as has been done in New York State, to provide opportunities for boaters to learn correct procedures and to complement regulation. Boat licensing may also provide opportunities to ensure that boaters are knowledgeable about the impacts of invasive species and their transport. At the very least, signage at launching points to waterways is required, to be complemented by the creation of a public awareness campaign, such as Clean, Drain, Dry, a program we could import from other jurisdictions.

Thank you for considering these recommendations.

Respectfully yours,

Executive Director
A2A Collaborative

Director and
Past President (2002-2016)