Subject: ERO #019-1162 –…

Subject: ERO #019-1162 – Seeking information on invasive species and carriers under the Ontario Invasive Species Act, 2015

The Ontario Federation of Anglers and Hunters (OFAH) is Ontario’s largest, non-profit, fish and wildlife conservation-based organization, representing 100,000 members, subscribers and supporters, and 725 member clubs. Invasive species harm biodiversity and ecosystems, hinder our recreational activities, and result in significant economic costs each year. The OFAH is pleased to see the Ministry of Natural Resources and Forestry (MNRF) is seeking input on 13 species and one carrier to inform the completion of risk assessments, as well as possibly developing a future proposal to list under the Invasive Species Act, 2015 (ISA). We have reviewed the proposal “Seeking information on invasive species and carriers under the Ontario Invasive Species Act, 2015” and offer the following comments for consideration.

The objectives of the ISA are focused on preventing the arrival and establishment of invasive species, and reducing the environmental and economic impacts of invasive species that have already arrived and become established in Ontario. Given this objective, we agree that the MNRF should be reviewing the 13 identified species and overland transport of watercraft as a carrier for potential listing under the ISA. This review must involve the completion of risk assessments for all species being considered and watercraft transport as a pathway, if they do not already exist. These risk assessments should consider socioeconomic impacts in addition to environmental impacts.

At this time, it is difficult to recommend the application of rules to the identified species without first reviewing each species’ completed risk assessment. The completion of risk assessments and determining how other jurisdictions are managing these species and pathway are important to ensure a science-based approach to listing and responding to invasive species in Ontario. As such, the potential listing of these species and carrier should be dependent on the outcomes of their risk assessments. We are pleased to see that, if developed, a future regulatory proposal will be made available for public review and comment. We would like to ensure that that proposal includes all completed, detailed risk assessments to provide the public with all necessary information needed to make an informed comment.

Throughout the process of developing risk assessments and any future regulatory proposal, the MNRF should be acquiring on-going feedback from a diversity of interested groups and maintaining transparency to enhance the quality of the final product. Many groups experience the impacts of invasive species first-hand, or have a considerable amount of knowledge and expertise that lends itself to an effective discussion about the benefits and risks associated with these 13 species and one carrier. The MNRF should consult academia, NGOs, and Indigenous partners on their initial drafts of all risk assessments associated with these potential additions before a regulatory proposal is put forward. This will ensure that all areas of consideration are included in the final decision-making process. Due to the severity and imminent threat posed by wild pigs, and because there is already a draft risk assessment, the OFAH strongly recommends listing this species without waiting for the other species.

Wild Pigs
When species pose an imminent risk to Ontario, there are powers under the ISA that can be utilized to rapidly respond. The OFAH is pleased to see that MNRF is proposing to use the ISA to respond to the risk wild pigs pose to Ontario’s natural environment and economy. Furthermore, we support the definition of a wild pig as “any pig outside of a fence” encompassing escaped domestic pigs, Eurasian wild boar, and their hybrids because all pigs, regardless of origin or breed, can be deleterious to our native plants, wildlife, and the agricultural industry if released into the wild.

The eradication of wild pigs before they become established in Ontario has been a major advocacy priority for the OFAH and we maintain that time is of the essence when addressing this threat. Wild pigs have an extremely high reproductive capacity – females become sexually mature as young as six months of age and produce up to two litters of four to ten piglets each year. This allows wild pig populations to exhibit exponential growth and rapidly outpace attempts to control them. Any delays in addressing this problem will only increase the cost of the inevitable control measures required.

If they become established in Ontario, wild pigs will have significant negative ecological and economic impacts. Wild pigs destroy native ecosystems and create ideal habitat for invasive plant species. Pigs are a generalist omnivore and, in addition to damaging plant communities, prey on and compete with native wildlife including game species such as white-tailed deer and wild turkey, and species at risk such as northern bobwhite. The cumulative effect is a significant decrease in biodiversity. In the United States, wild pigs cost the agricultural industry an estimated $1.5 billion annually through crop damage, livestock predation, and damage to equipment. Finally, wild pigs are vectors for many diseases including brucellosis, trichinosis, hepatitis, and African Swine Fever. The latter disease is currently a major concern for Ontario’s pork industry and many of the disease carried by wild pigs can infect humans, wildlife and livestock.

For the above reasons, the OFAH believes wild pigs should be listed under the ISA as soon as possible. If the intent is to create a proposal for the listing of these species in the near future, then wild pigs should be listed as a restricted species. This would make it illegal under the ISA to cause a wild pig to be released in Ontario and allow for the continuation of the pork industry, while giving the MNRF the ability to remove pigs from the wild. If the listing of wild pigs through this regulatory proposal is not going to occur within the next year then we recommend that the MNRF employ the provision under Section 5 of the ISA to temporarily designate wild pigs as a prohibited invasive species for the maximum two-year period. Exceptions could be provided for Sections 7 (a), (c), (d), and (e) to allow for the pork industry and pig owners to continue to possess and transport their pigs while making release illegal. The temporary designation would ideally work hand in hand with a 2-year eradication plan. Regardless of which regulatory option is used, Section 27 of the ISA (actions to control or eradicate invasive species) must be used to negate any concerns about whether the free ranging pigs are personal property and give the MNRF clear authorization to eradicate them.

Prior to either form of designation, the MNRF should work with farmers to provide a brief window to retrieve any escaped pigs and once designated, the MNRF must work swiftly to remove any wild pigs from the landscape. The MNRF should also work with the Ontario Ministry of Agriculture Food and Rural Affairs (OMAFRA) to reduce the likelihood of escapes from farms through mandatory fencing requirements, with the goal of removing the source of wild pigs on the landscape. Additionally, mandatory traceability requirements for all pigs in Ontario and an established reporting mechanism for future escapes will ensure that pigs are reported, dealt with swiftly, and allow for the MNRF to lay appropriate charges.

Perhaps most importantly, listing wild pigs under the ISA gives the MNRF the clear legal authority to take the steps necessary to prevent wild pigs from becoming established in Ontario. This is critical as the OFAH maintains that due to the threat they pose, wild pigs should be addressed with the same seriousness and dedication of resources that the MNRF currently devotes to fighting forest fires and rabies outbreaks.

Overland Movement of Watercraft as a Carrier
For over 28 years, the OFAH has worked in partnership with the MNRF to deliver the Invading Species Awareness Program (ISAP). The ISAP takes a proactive public education approach to preventing the introduction and spread of invasive species. We recognize that transient watercraft are a potential vector for the spread of aquatic invasive species (AIS) and therefore, deliver the Clean, Drain, Dry message via educational outreach programs (e.g., Operation Boat Clean and Clean Boats, Clean Tournaments) to engage anglers, hunters, recreational boaters, and organizations that use watercraft. The ISAP is successful in engaging millions of Ontarians on the issue of invasive species every year. While education and outreach are critically important to preventing the introduction and/or spread of invasive species, we acknowledge that this approach would benefit from an enhanced regulatory framework.

The OFAH is supportive of the MNRF’s review of potentially regulating the overland movement of watercraft as a carrier under the ISA. Addressing pathways of spread can be an effective approach to preventing the arrival and establishment of invasive species. However, it is equally important that MNRF reviews the potential negative social impacts of regulating the movement of watercraft, while ensuring the approach is practical, feasible, and enforceable. We encourage the MNRF to look at the wording Michigan and Wisconsin are using to help guide the development of this regulation. These jurisdictions require boaters to remove visible aquatic organisms from all parts of their boat and trailer, as well as removing drain plugs and emptying live wells. These actions are straightforward and enforceable, and will likely have a meaningful impact on the reduction of invasive species spread. While we do not yet know the details of a potential regulation, the OFAH would like to ensure the consequences of a carrier regulation under the ISA do not negatively impact sustainable heritage activities, such as fishing, hunting, and trapping. The OFAH looks forward to providing additional comments on potentially regulating overland movement of watercraft when the regulatory proposal is posted.

Conclusion
The OFAH operates under the principle that anglers, hunters, and trappers are part of the solution to the threats posed by invasive species – not part of the problem. Well-informed anglers, hunters, and trappers play a critical role in the early detection and reporting of new species and occurrences, which informs potential management actions. Therefore, it is important that we continue to engage and educate them in awareness and prevention measures. Reviewing the benefits and impacts of any potential regulations alongside key stakeholder groups, like the OFAH, will help in the development of a suite of priority actions for a collaborative approach to minimizing invasive species impacts and avoiding conflicts with recreational users.

It is important to note that regulating the 13 species and one carrier identified in this proposal will only go so far with respect to preventing the arrival and establishment of invasive species and reducing harm to Ontario’s environment, economy, and society. Any new regulatory efforts should be complemented by education, outreach, and an increased capacity for enforcement – which requires investment. The current level of investment is not enough - new resources will be required from MNRF to ensure the successful implementation and enforcement of a new regulation under the ISA. However, through the OFAH/MNRF partnership delivering the ISAP, there are existing mechanisms in place that can effectively and efficiently support education, outreach, and enforcement priorities. Therefore, we strongly urge the government continue their commitment to the ISAP, including restoring previous funding levels and multi-year agreements.

The OFAH is supportive of the potential listing of these 13 species and of overland transport of watercraft as a carrier of invasive species. We encourage the MNRF to acquire on-going feedback from key stakeholder groups and maintain transparency throughout this process to ensure the draft regulation will be both realistic and effective. We look forward to providing continued input to this discussion, and identifying opportunities to utilize the ISAP to support invasive species priorities in Ontario.

Yours in Conservation,

Resource Management Specialist