Restricted Invasive Species…

Restricted Invasive Species
While I support the listing of these species as “restricted”, and think the exemptions to possession are reasonable, I believe there is a critical gap in the MNRFs system of monitoring those who would import, sell or propagate the plant species. MNRF must take advantage of the inspector appointment provisions of the Invasive Species Act and develop, train and support an effective inspection program. MNRF cannot continue to rely on their overburdened enforcement program to also operate as their sole invasive species inspection program. This is neither appropriate nor effective.

Pigs
It is not enough to prohibit the “release” of a pig – release being an active term, a planned action. The regulation must also include a term such as “permit the release” of a pig. In this way farmers must practice due diligence by keeping up fences and burrowing preventing structures. Current hog containment practices are very lax – this needs to be addressed.

Watercraft
Using the term “reasonable measures to remove aquatic plants” in a regulation will render the regulation unenforceable - the rule must be more prescriptive. These regulations fall into the “strict liability” category of offences, this means due diligence is a defense available to an accused person. Make the law monitory and allow the charged person to explain how their actions were reasonable in the circumstances.

My other concern is with the requirement to render watercraft equipment “free of all aquatic organisms before being placed into any body of water”. The controlling regulation must require the removal of all aquatic organisms before the watercraft equipment is transported to a launch site – to allow the cleaning of a boat (trailer, etc.) at the a new launch site would defeat the intended protection and to create an offence provision that is not complete until the contaminated watercraft equipment is launched will be ineffective and unenforceable.