Subject: ERO #019-1163 –…

Subject: ERO #019-1163 – Developing Prevention and Response Plans for European water chestnut and water soldier under the 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. We have reviewed the proposal “Developing Prevention and Response Plans for European water chestnut and water soldier under the Invasive Species Act, 2015” and offer the following comments for consideration.

The OFAH is supportive of the development and use of Prevention and Response Plans to enable management and eradication activities which would otherwise be prohibited by regulation under the Invasive Species Act, 2015 (ISA). These plans will allow for a more rapid response as agencies that fall under “Authorized Persons” will not have to wait for permitting under the ISA. The OFAH suggests that the Ministry of Natural Resources and Forestry (MNRF) create similar response plans for current and future prohibited species in order to facilitate management actions. For over 10 years, OFAH has been working closely with the inter-agency Water Soldier Working Group to eradicate water soldier from Ontario. We feel using an integrated management approach that enables residents, property owners, not-for-profit corporations, municipalities, and/or conservation authorities to engage in activities to help control, eradicate, and prevent the spread of water soldier will be beneficial for Ontario’s environment, economy, and society. Given our knowledge and support for the efforts to control European water chestnut in Ontario, we feel this approach will be beneficial in controlling, eradicating, and preventing its spread as well.

These two plans, as well as any subsequent plans for additional species, must be communicated to the people and/or groups that qualify as “Authorized Persons” to ensure the effectiveness of this tool. It is critically important that government works with all “Authorized Persons” from the outset of any management action to ensure that the Prevention and Response Plans are being followed. Improper management of both water soldier and European water chestnut has the potential to spread the plants and make the infestation worse. We suggest identifying and working with key partners (e.g., OFAH, Ducks Unlimited Canada) to implement community-based workshops to inform potential “Authorized Persons” of the requirements in the Prevention and Response Plans, as well as train “Authorized Persons” on the best management practices with respect to removal, containment, decontamination, and disposal. Not only will these workshops ensure water soldier and European water chestnut are not incidentally spread/introduced to new areas, but they will also be an excellent tool to engage people and facilitate early detection.

In the Prevention and Response Plan for Water Soldier, the section titled “Conditions” states the plan “does not apply to the use of mechanical harvesters” (page 6). We would like to clarify this condition is only applicable to activities that fall under the Prevention and Response Plan for water soldier, and not to the efforts of the inter-agency Water Soldier Working Group. Currently there is a management method (diver assisted suction harvesting) outlined in the Water Soldier Integrated Management Plan that is considered “mechanical harvesting” which we hope to pilot in the future to determine its efficacy. We are hopeful this condition will not prevent novel control methods, such as this one, from being used in Ontario. Since this plan does not apply to mechanical harvesters, would management activities that use mechanical harvesters need to obtain additional permits or authorizations under the ISA? What would the permitting process be for “Authorized Persons” to utilize a new management action not currently included in the Prevention and Response Plan?

The Prevention and Response Plans are vague about who is considered an “Authorized Person” and therefore who has the authority to manage water soldier and European water chestnut. How does the MNRF intend to monitor the use of these plans? We feel it will be important to have a mechanism in place for “Authorized Persons” to verify the species identification and report on their actions to help control, eradicate, and prevent the spread of water soldier and European water chestnut in Ontario. This will not only ensure the proper species is being removed, but will also track where management for water soldier and European water chestnut is occurring and by whom. There are existing tools in place to support the reporting of occurrences of these two species (e.g., EDDMapS Ontario), and we encourage MNRF to consider using these tools to enhance the level of communication between MNRF and those groups/individuals operating under the Prevention and Response Plans. Having a mechanism in place will ensure that new detections do not go unreported, and that the MNRF (and its partners) remain up-to-date on occurrences and efforts to eradicate and/or manage these species in Ontario.

Having worked in partnership with the MNRF for over 28 years delivering the Invading Species Awareness Program, as well as supporting the efforts of the Water Soldier Working Group for more than 10 years, the OFAH is pleased to see the MNRF taking additional actions to help control, eradicate, and prevent the spread of water soldier and European water chestnut through the development of Prevention and Response Plans. These plans align with the objectives of the OFAH/MNRF Invading Species Awareness Program and will increase provincial capacity to address the critical threat that water soldier and European water chestnut pose to Ontario.

Additionally, in combination with the work that multiple agencies are undertaking to manage and remove water soldier and European water chestnut, the government needs to invest more resources into outreach, education, and enforcement in order to have the best chance at eradication. Management of populations can only go so far if new introductions continue to occur; continued outreach regarding the legality and negative impacts of possessing and releasing these two species is required. There must also be enforcement of the ISA when individuals are found to be in possession of restricted species. Without consistent and active enforcement, the ISA will not function as intended and Ontario will continue to face the environmental, social, and economic impacts of invasive species.

The OFAH looks forward to continuing to be a partner in educating the public on invasive species and managing water soldier in Ontario. Thank you for considering these comments.

Yours in Conservation,

Manager, Conservation Programs