Hamilton Naturalists’ Club…

Hamilton Naturalists’ Club comments on the Renewing the Ontario Invasive Species Strategic Plan

Hamilton Naturalists’ Club (HNC) is a 105-year old non-profit organization with over 300 members dedicated to the study, appreciation, and conservation of our wild plants and animals. Invasive species have been identified as a key threat to biodiversity at HNC’s 10 nature sanctuaries and invasive species management is the focus of stewardship activities for staff and volunteers. In addition to on-the-ground work, HNC is leading the development of Hamilton’s Biodiversity Action Plan in collaboration with the City of Hamilton and local conservation partners. The Biodiversity Action Plan affirms invasive species as one of the main threats to biodiversity and many Actions are dedicated to addressing this threat.

HNC is pleased to provide these comments on the Renewing the Ontario Invasive Species Strategic Plan. Additionally, HNC supports the comments submitted by the Canadian Coalition for Invasive Plant Regulation.

Question 1. What is your vision for the future of invasive species prevention and management in the province?

Hamilton Naturalists’ Club envisions a future where there are strong mechanisms in place to;
1. Prevent the spread and establishment of known invasive species to new areas.
2. Prevent the establishment of new invasive species with a robust early detection and rapid response system to eradicate, contain, or control new invasive species at their point of entry, and
3. Provide abundant support to environmental organizations and municipal, provincial, and federal governments for the management of new and known invasive species in Ontario.

In the future, areas with invasive species will be managed on both public and private lands, fostering a collaborative approach to invasive species management at the local and regional level. Community members, public and private organizations, and all levels of government will have a broad understanding of the threat invasive species pose to biodiversity, the importance of invasive species management in protecting and enhancing local biodiversity, and the cost of invasive species prevention vs management. Ontario will be considered a leader in invasive species management, protecting biodiversity through innovative approaches to the prevention, early detection and rapid response, and ongoing management of invasive species.

Legislation, Regulation and Policy
• Regulations for Prohibited and Restricted species under the Ontario Invasive Species Act (ISA) are enforced to prevent the introduction and spread of invasive species.
• Unregulated invasive species, including those sold for horticulture and aquarium use, listed in the Value-for-Money Audit: Management of Invasive Species (Office of the Auditor General of Ontario, 2022) are added to the list of regulated species under the ISA.
• Enforcement will include positive incentives for compliance and a graduated fine structure for repeated offences.

Local Communities
• The provincial government supports the work of community members, local organizations, and municipal governments to address the threat of invasive species through funding programs, resources, and tools for effective action.

Leadership and Coordination
• Ontario will be considered a leader in invasive species prevention and management, and will help to develop a provincial invasive species database which includes information about the invasive species and best management practices, along with maps of known locations to help with collaborative efforts.
• The Invasive Species Centre will be supported as a coordinator of information and central hub of information on invasive species for the public and practitioners alike.
• The Ontario Invasive Plant Council will be supported in their work to educate the public and encourage community members to take action to manage invasive plants.
• Through regulations and education the province will prevent the sale of invasive species in the horticulture industry and instead encourage the sale of native species.

Communications
• The provincial government will fund public education focused on the threats invasive species pose to the environment, economy, and human health, the importance of early detection and rapid response, and the importance of invasive species management.
• Communications and signage in horticultural sales (ex. nurseries, box stores) will inform and empower customers to avoid invasive species and instead select native or non-invasive plants.
• Communications and signage around pet sales and trades will inform and empower customers to avoid invasive species and will emphasize the prevention of spreading invasive species.
• Ontario will be involved in national and international discussions about the management of potential and emerging invasive species.

HNC’s vision aligns with best practices in invasive species management and reflects a collaborative approach to address the challenges posed by invasive species in the province. It also reflects the comments received from community members and stakeholders during the public consultation period for Hamilton’s Biodiversity Action Plan.

Question 2. What opportunities are there for the future of invasive species prevention and management in Ontario?

Globally and locally, invasive species are one of the greatest threats to biodiversity. Organizations like Hamilton Naturalists’ Club spend significant amounts of money, time, and resources each year on invasive species management. Fortunately, there are numerous opportunities to prevent invasive species from becoming established, and to manage the species that are already established. A key opportunity is to prevent the spread of invasive species through the horticulture industry. Raising awareness about these pathways for spread along with mitigating the spread is critical to invasive species management in Ontario. Additional opportunities include the following:

Strengthen Regulations and Policies
• Ontario can help develop science-based policies at the provincial and federal level to address the introduction and spread of invasive species (plants, insects, diseases, etc.) through the horticultural industry.
• Add species to the regulated species list in the Ontario Invasive Species Act (ISA).
• Coordinate the regulated species list with adjacent Canadian provinces and US states to prevent the movement of regulated invasive species across borders.
• Regular updates to the regulations regarding invasive species and the regulated species list to reflect emerging threats and new knowledge.
• Restrict or ban the sale of all invasive species in the province for any use.
• Investigate the opportunity to add or expand zones of movement for restricted materials (ex. firewood, bait fish) to strengthen the prevention of introducing invasive species to a new area.

Facilitate Improved Coordination and Information Sharing
• Help to develop invasive species database to be used by the public and professionals that includes information about the species, best management practices, and alternative species that can be used. The database could also be used to monitor for the introduction and spread of invasive species.
• Undertake comprehensive public awareness campaign that clearly describes the threats posed by invasive species, species identification, management and native or non-invasive alternatives to plant.
• Create new invasive species certification program for nurseries, garden centres, etc. to empower the public to make responsible purchases, similar to the program developed by the Carolinian Canada Coalition.
• Promote the importance of native plants and native plant nurseries to the public.
• Establish relationships with stakeholders in the horticulture industry to develop strategies that prevent or minimize the spread of invasive species.
• Support the Ontario Invasive Plant Council and their work to communicate alternatives to invasive species, along with information about native plant nurseries.

Provide Resources and Support
• The provincial government should provide federally and provincially approved sites for appropriate disposal of invasive species as outline by the best management practices or government recommendations, specifically locations for deep burial and incineration.
• Once an emerging invasive species has been identified and confirmed in the province, the provincial government should provide full funding and resources to assist the landowner(s) with rapid response to eradicate or contain the invasive species.
• Provide cleaning stations for vehicles and equipment at regular intervals along major routes to help reduce the spread of invasive species between work sites.

These opportunities will enable Ontario to develop a proactive approach to preventing and managing invasive species.

Question 3. Do you think there are barriers related to invasive species prevention and management in Ontario? How could these barriers be addressed?
There are many barriers related to invasive species prevention and management in Ontario. Addressing these barriers requires a diverse and collaborative approach. The primary barriers HNC faces related to invasive species management and suggestions for addressing these barriers are listed below.
1. Barrier: Limited Resources
Insufficient funding, staffing, and resources hinder effective invasive species prevention, early detection and rapid response, and management efforts.
Addressing the Barrier
• Provide financial support and resources to address the prevention and early detection of invasive species in addition to support for ongoing management activities.
• Explore partnerships with private sectors and NGOs to supplement resources and draw on expertise.
• Enforce fines for species regulated under the Ontario Invasive Species Act (ISA) and direct the revenue towards management of the infraction.

2. Barrier: Lack of Public Awareness
In general there is low public engagement and cooperation regarding invasive species management due to a lack of awareness about the impacts of invasive species on the environment, economy, and human health. Addressing the lack of public awareness and knowledge about invasive species is critical for effective invasive species management.
Addressing the Barrier:
• Expand existing public awareness campaigns (ex. Grow Me Instead, Buy It Where You Burn It).
• Improve education for industries and businesses about the role they play in preventing the establishment of invasive species.
• Provide funding for non-government organizations working to increase public awareness. ( ex. Best Management Practice documents, Grow Me Instead guides)
• Create user-friendly interfaces for public information systems. Ensure that these platforms are easily accessible, easy to navigate and understand, and address a diverse audience, including individuals without specialized scientific knowledge.
• Provide free training programs for industry professionals and the public on how to monitor and manage invasive species.

3. Barrier: Invasive Species Management Options
Invasive species are challenging and costly to control once established. Investing in the prevention and early detection of invasive species will save money on management - every $1 spent on prevention saves $53 on management costs (Cuthbert et al., 2022).
Addressing the barrier
• Focus monitoring programs on early detection and rapid response.
• Prioritize research into control methods for emerging invasive species as soon as possible (ex. various insecticides for Hemlock Woolly Adelgid.)
• Invest in research on effective control methods for known and emerging invasive species.
• As part of the rapid response, if an emerging invasive species in Ontario has been previously identified and managed in other Canadian provinces or territories the control methods used should be fast tracked for approval in Ontario.
• Prioritize preventive measures to reduce the possibility of introduction and establishment of new invasive species (ex. require a risk assessment before the sale of any new non-native species is permitted).
• Ban the sale of invasive species and require labels on non-native species with aggressive growth habits.
• Provide subsidies or grants for private landowners to offset invasive species management and restoration costs.

4. Barrier: Globalization and Trade
The global movement of goods and people contributes to the introduction and spread of invasive species.
Addressing the barrier
• Call upon the federal government to develop a new federal framework and establish an invasive species national committee to: coordinate biosecurity measures across Canada; strengthen regulations and policies related to the import and trade of plants, animals, and other potentially invasive organisms; improve trade practices with the aim of limiting the introduction and spread of invasive species; work with industries involved in the movement of goods to increase awareness of the risks of spreading invasive species.

By addressing these barriers through coordinated efforts and engagement with diverse stakeholders, Ontario can enhance its capacity to prevent and manage invasive species effectively. Regular and ongoing monitoring is needed to address emerging challenges.