Invasive Species Plan

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Invasive species are non-native (or “alien”) plants, animals and even micro-organisms whose introduction or spread can threaten the environment, human health and the economy. They can be extremely difficult and costly to control and, if unchecked, can inflict significant and irreversible ecological impacts (see pp. 47-52 of the ECO’s 2003/2004 Annual Report). For example, in Ontario:

  • The emerald ash borer (Agrilus planipennis) has killed over one million trees in the southwest.
  • Invasive Phragmites (the European common reed) has caused significant habitat loss for several wetland-dependent species.
  • Zebra mussels (Dreissena polymorpha) have restructured nearshore ecosystems, displaced native mussels and clogged intake structures in power stations and water purification plants, costing millions of dollars in increased operating costs.

Other invasive threats, including Asian carp (several species of cyprinid fish) and chronic wasting disease (a degenerative brain disease that affects deer, elk, moose and potentially woodland caribou) also have the potential to cause major harm if they become established in Ontario.

A variety of approaches have been developed to address invasive species in Ontario. Since 1992, the Ministry of Natural Resources (MNR) has partnered with the Ontario Federation of Anglers and Hunters to deliver the province-wide Invading Species Awareness Program to educate the public about invading species, address key pathways contributing to their introduction and spread, and facilitate monitoring and tracking initiatives.

Despite some isolated successes, however, addressing invasive species remains a significant and complicated problem, involving many different species, points of entry, means of dispersal, stakeholders, industries and levels of government. Accordingly, the ECO has been calling on the government for almost a decade to develop a provincial invasive species strategy. Although Ontario’s Biodiversity Strategy (2005) included some provincial actions for implementing components of the federal government’s An Invasive Alien Species Strategy for Canada (the “National Strategy”), it failed to delegate responsibilities to different ministries, set out timelines to accomplish objectives or establish measurable targets.

In July 2012, the government finally released a dedicated invasive species strategy. The development of the Ontario Invasive Species Strategic Plan (OISSP or the “Strategic Plan”) was led by MNR, but also involved the Ministry of the Environment (MOE), Ministry of Transportation (MTO) and Ontario Ministry of Agriculture, Food and Rural Affairs (OMAFRA, as it was then known). The three objectives (or intended outcomes) of the OISSP are to: prevent new invaders from arriving and surviving in Ontario; slow and, where possible, reverse the spread of existing invaders; and reduce their harmful impacts. To meet these objectives, the OISSP is guided by four goals, which mirror those of the National Strategy:

  • Prevent harmful introductions before they occur.
  • Detect and identify invasive species before or immediately after they become established.
  • Respond rapidly to invasive species before they become established or spread.
  • Implement innovative management actions and take practical steps to protect against impacts of invasive species.

These four goals translate into 27 strategic actions and almost a hundred tactics (see examples in Table 4.2.1), grouped into six activity categories: leadership and co-ordination; legislation, regulation and policy; risk analysis; monitoring and science; management measures; and communication and education. The OISSP describes how the government intends to meet the goals of the National Strategy, as well as those of several national action plans, including A Canadian Action Plan to Address the Threat of Aquatic Invasive Species (2004), the Action Plan for Invasive Alien Terrestrial Plants and Plant Pests (2005), and Canada’s National Wildlife Disease Strategy (2004).

Table 4.2.1. Examples of Strategic Actions and Tactics Included in the Ontario Invasive Species Strategic Plan (2012).

Activity Category Strategic Action Tactic
Leadership and Co-ordination #2. Clarify roles and responsibilities of provincial ministries for invasive species issues. OMAFRA will establish a clear contact as its lead on invasive agricultural species.
Legislation, Regulation and Policy #7. Examine provincial legislative and policy framework for invasive species management. Conduct a regulatory review of federal and provincial legislation to determine regulatory gaps and inconsistencies.
Monitoring and Science #15. Improve existing invasive species monitoring programs, and develop a network of experts to identify species. Investigate new technologies to inventory native and invasive species and detect hybridization.
Communication and Education #27. Build communication networks with a wider range of interested communities and interest groups. MNR will work to broaden partnerships with Ontario’s Aboriginal communities.

Implications of the Decision

Potential to Reduce the Threats Caused by Invasive Species in Ontario

Previous efforts to address the threats caused by invasive species in Ontario were piecemeal and unco-ordinated. The province now has a comprehensive, logical and well-researched strategy dedicated to addressing this problem. Assuming that the OISSP’s strategies and tactics are fully and effectively implemented, the Strategic Plan has the potential to help reduce the introduction, spread and impacts of invasive species.

New Invasive Species Policies and Management Plans

Implementation of the Strategic Plan will require the government to develop and implement a variety of policies and plans, including best management practices, and management plans for priority invasive species. The development of these policies, plans and protocols will require public consultation via the Environmental Registry.

Fulfillment of Other Commitments and Goals

In echoing the National Strategy’s goals and strategies, implementation of the OISSP should help Ontario fulfil Canada’s invasive species goals at the provincial level. Moreover, implementing the OISSP’s actions and tactics should help Ontario meet the goals of other overarching plans and commitments, including the Ontario Government Plan to Conserve Biodiversity (2012), the Canada-Ontario Agreement Respecting the Great Lakes Basin Ecosystem (2007), Climate Ready: Ontario’s Adaptation Strategy and Action Plan (2011), and MNR’s strategic directions.

Reliance on the Canadian Government, Municipalities, and Other Stakeholders

While the majority of the tactics in the OISSP require tangible action by Ontario ministries, a few involve the government encouraging, working with and/or co-operating with the federal government, municipalities, or other players to do something (e.g., develop ballast water treatment standards, increase capacity for inspections and enforcement at Canada’s borders and key ports of entry, etc.). Although integral to the Plan’s overall success, the ultimate power for completing these tactics and meeting OISSP’s underlying goals may be in the hands of some other authority.

No Implementation Plan or Funding Strategy

The OISSP provides a good, clear description of the issues related to invasive species and a comprehensive analysis of what is needed to address them. However, the ECO has identified a number of structural deficiencies in the actions and tactics outlined in the Plan. Namely, they: are not species- or region-specific; generally do not identify the ministry or branch responsible; lack timelines for completion; fail to specify targets and indicators for measuring progress; and contain no public reporting requirements. The draft OISSP, posted on the Environmental Registry in 2011, included a commitment by MNR to co-ordinate the development of an annual implementation plan to identify and articulate priorities for implementation. Unfortunately, references to annual implementation plans are noticeably absent in the final Strategic Plan. What still need to be articulated, then, are the details that likely would have appeared in an implementation plan: species-specific actions; responsible branches/actors within ministries; deadlines for completion; and targets and indicators to measure progress. The OISSP also lacks a clear timeframe and an indication as to when it will be reviewed, as well as any strategic actions to ensure funding for its implementation.

ECO Comment

The ECO applauds MNR, OMAFRA, MOE and MTO for collaborating to develop a comprehensive invasive species strategy for the province. The Strategic Plan provides a logical and thoughtful framework for preventing, responding to and managing invasive species in Ontario.

Nevertheless, the Strategic Plan lacks the specifics necessary to instil confidence that all of the responsible players will do what is required to ensure success. While the ECO agrees with MNR that the OISSP provides a “conceptual framework for tackling Ontario’s invasive species problem,” the ECO does not believe that it includes a “detailed action plan designed to ensure progress toward specific outcomes.” The ECO is disappointed that the government decided to remove from the Strategic Plan the commitment to develop annual implementation plans. The ministry’s explanation as to why this commitment was removed reads as follows:

[MNR] recognized that a more efficient model was for planning to occur through regularized annual work planning and priority setting exercises. MNR will help to facilitate these discussions in collaboration with the other ministries. This will enable ministries to use business systems already in place to establish implementation priorities, reflective of needs, resources, partnership opportunities and respond to ever-emerging invasive species issues.

The ECO is not convinced by this argument and urges the government to revisit its original intention. Committing to the development of a detailed and publicly available annual implementation plan will increase the likelihood that the goals, actions and tactics outlined in the OISSP are promptly implemented and consistently employed. Furthermore, it is important that the Strategic Plan include a commitment to, and a mechanism for, evaluating whether the implemented tactics are actually achieving the OISSP’s intended goals and objectives (for more discussion about the evaluation of environmental programs, see Part 6.4 of the ECO’s 2011/2012 Annual Report, Part 2).

Given the nature of some of the OISSP’s tactics, the ECO is disappointed that the Strategic Plan seems to assign no responsibilities to the Ministry of Municipal Affairs and Housing (MMAH). For example, one tactic is to “encourage municipalities to include invasive species prevention measures within their official plans.” Others relate to working with municipalities, for example, on policies and practices to reduce disturbance in natural areas and natural corridors, and to develop and implement invasive species best management practices for municipal planning documents and zoning. Because these tactics relate to municipal land use planning – something clearly within the mandate of MMAH – the ministry should have been involved in developing the OISSP and should be jointly responsible for implementing it.

Finally, the ECO is concerned that the laudable goals of the Strategic Plan will go unfulfilled without adequate funding. The ECO has reported several times that MNR and MOE have limited finances, staff and expertise to effectively meet their mandates (see Part 2.3 of this Annual Report). MNR is moving forward with a plan to “modernize its business and operate on a more cost efficient basis” that involves cutting its budget, staff, partnership funding and facility locations over three years (for more information, see Part 2.1 of this Annual Report). There is clearly a need to secure funding to ensure the effective implementation of the OISSP. Equally important, funding is needed for other partners (e.g., conservation authorities, municipalities, etc.) to fulfil some of the OISSP’s strategic actions. Dedicating adequate dollars to preventing the introduction and spread of invasive species would be a wise investment, potentially averting the risks and financial costs associated with invasive species that we have seen with previous introductions.

Other jurisdictions have made funding provisions an integral part of their invasive species strategies. For example, one of the five key actions of the Invasive Species Strategy for British Columbia (BC) is to “develop a long-term funding strategy for invasive species management in BC that includes baseline funding targets and possible funding mechanisms.” The BC strategy also suggests that “new funding mechanisms should include approaches that are both universal (applicable to all British Columbians) and targeted (linked to special interests, such as key pathways of introduction and spread).” The ECO is disappointed that no comparable actions are included in Ontario’s Strategic Plan. If the plan is to be more than a well-meaning but empty gesture, it is incumbent on the government to develop and implement the means to finance the long-term prevention, detection, and management of invasive species threats.

The OISSP itself may be a comprehensive, logical and thoughtful strategy. However, it provides no details as to how, when and by whom species-specific tactics will be implemented, no articulation of how progress and efficacy will be evaluated, and no indication how funding for implementation will be secured. As a result, the government’s commitment to addressing this complex and significant issue may be sincere, but ultimately unachievable.

This is an article from the 2012/13 Annual Report to the Legislature from the Environmental Commissioner of Ontario.

Citing This Article:
Environmental Commissioner of Ontario. 2013. "Stopping the Spread: Invasive Species Plan." Serving the Public, ECO Annual Report, 2012/13. Toronto: The Queen's Printer for Ontario. 99-103.