This letter discusses…

This letter discusses invasive plants species, but please extrapolate my comments to include ALL forms of invasive wildlife.

***PLEASE NOTE I COULD NOT FIT ALL THE FEEDBACK INTO THIS DIALOG BOX SO I ATTACHED A LETTER WITH THE COMPLETE FEEDBACK***

We are experiencing a global biodiversity crisis and climate emergency. Compounding these threats is the harm caused by invasive species which further erode the resilience of our ecosystems and undermine the essential foodwebs which support all life on this planet.

The Ministry of Natural Resources and Forestry must do more to ensure non-native plants known to spread into natural areas and outcompete our valuable native species are restricted from sale and intentional planting into our landscapes across Ontario. For example, Ottawa recently updated their municipal bylaw and restricted a list of species known to have invasive tendencies from being planted on their city Right-of-Ways, even though the plants are currently legal. Ottawa based this bylaw change on the Ontario's Auditor General’s suggested list of 30 species to be added to the Invasive Species Act.

While this was great, it was a major task for Ottawa residents to advocate at the grass-roots level for this enhanced eco-regulation in their local bylaw (I should know, as I wrote multiple emails to Ottawa City Council and Transportation Committee about it!). It is disheartening to think that every one of the 444 municipalities across the province would require residents to put forward similar substantial efforts just to advocate for municipalities to create policy which prevents the spread of invasive plants. Worse yet, all this effort could go to waste if local councillors failed to see the merit of these policy changes and ignored their constituent’s concerns.

Info on Ottawa's Bylaw:
https://ottawa.ca/en/planning-development-and-construction/residential-…

Ottawa's Use and Care of Roads Bylaw - see Schedule A for list of plants restricted for use on the ROW:
https://ottawa.ca/en/living-ottawa/laws-licences-and-permits/laws/laws-…

Most Ontario municipalities continue to favour monoculture turfgrass with outdated regulations that fail to support naturalization of private property. In fact, it is all too common to see Bylaw Officers penalizing residents engaging in their Charter-protected right to freedom of expression through natural gardening activities (see Bell v. Toronto (1996) and Counter v. Toronto (2002)). Even after precedent-setting court rulings, we continue to see litigation surrounding private property naturalization (see Smiths Falls case: https://ecologicaldesignlab.ca/project/by-laws-for-biodiversity/). What I am getting at here is that ecological restoration on private property is being hampered by archaic colonial bylaws and part of this problem stems from ignorance about plant-insect interrelationships and the foodwebs that support life. The public is largely unaware of the benefits and eco-system services native plant species provide, and by that same token they are also ignorant of the true measure of harm (both environmental and economic) caused by invasive plants. This is why we need a more consistent, top-down approach from the ministry to ensure science-based regulations are in place across the province. It shouldn’t be the responsibility of each municipality to adopt these changes. Legislation in Ontario is out of date and fragmented, and needs to be strengthened ASAP. Invasive species policy must be more pro-active in protecting natural green spaces from the incursion of non-native and invasive plants, instead of just reactive to invasive species spread - we must stop this from happening in the first place

At a minimum, I want to see the Ontario's Auditor General’s suggested list (follow link below) of 30 species added to the Invasive Species Act immediately. This change needs to be prioritized and rushed into law ASAP: https://www.auditor.on.ca/en/content/annualreports/arreports/en22/ENV_P…

But expanding the list with the OAG’s suggested 30 species is not enough. We desperately need enhanced regulation in the horticultural trade. I want to see this industry held accountable for their involvement in and exasperation of the problem of invasive plants. I would like your ministry to work with the Canadian Food Inspection Agency to develop legal requirements for plant labels to indicate species which are non-native, potentially invasive, or proven to be aggressive spreaders that can escape into the environment. The CFIA has failed to take effective action on this front, and I ask the ministry to collaborate on this issue ASAP. According to the Canadian Coalition for Invasive Plant Regulation “horticulture is the most significant pathway for the introduction of Invasive Alien Plants.” While Ontario’s Invasive Species Act provides regulatory tools to address the sale of invasive species, the species on the officially regulated list is FAR too short. Why? Because of the resource-heavy burden a long list would incur in order to actually enforce an expanded list. This is why it is imperative the ministry works with CFIA to address the massive gap between regulation and enforcement, to ensure a better management strategy is created.

To quote the OAG’s report, “The economic impact of invasive species in Ontario’s agriculture, forestry, fisheries, health care, tourism and recreation are an estimated $3.6 billion each year.”

I would like your ministry to collaborate with the federal government and advocate for a stronger regulatory framework. I’m watching the federal government pledge $4 million to lay the groundwork for a more sustainable and economically profitable horticulture sector, with funds being directed to such endeavors as making non-native roses more saleable, but I see no mention of enhanced public education about the impact of non-native plants on the environment or any attempts to shift this sector’s colonial-based culture and perspectives to mitigate its negative environmental impact:
https://landscapeontario.com/government-pledges-4-million-to-ontario-ho…

I want to see more education and engagement, including significant funding increases for organizations like the Invasive Species Centre, so resources can be made available for education, community action and management on a MUCH larger scale: https://www.invasivespeciescentre.ca

Minnesota’s Board of Water and Soil Resources provides grants to homeowners to replace non-native turfgrass with wildflowers and native grasses to support biodiversity and help lessen the sediment and nutrients entering lakes, rivers, and streams. I want us to emulate our neighbours to the south, exploring collaborations to leverage the untapped power of individual property holders, and to scale up education and restoration activities at all levels. Much of the property in our urban areas is privately owned, and I am a big believer in Douglas Tallamy’s Homegrown National Park idea where people replace lawn with diverse native plant habitat.

And finally, I want to see the prioritization of native plant species in policy. Beyond restrictions on the use and sale of invasive species, inverse policy should require the use of native plants in cities, along highways, and throughout the retail industry itself. Battling invasive species and landscaping with native plants species should be incentivized. Ontario’s Planning Act sets the policy foundation for regulating the development and use of land in ways that conserve biodiversity, but it clearly fails to address this issue adequately, and your ministry needs to lead change on this front.