FOPO Committee Report

We found that despite long-standing commitments, agreements, and accords, there has been a lack of practical action by the federal government to prevent alien invaders from harming Canada’s ecosystem. As a result, their numbers in Canada have grown steadily. In short, this [is] what I have called leaving the door open to invasive species that threaten our ecosystems

Johanne Gélinas, Commissioner of the Environment and Sustainable Development

Introduction

In September 2002, various ministerial councils adopted the blueprint for a national plan to address the threat of invasive alien species. The federal plan will guide the development of a national policy and management framework for action. The plan emerges eight years after the release of the Canadian Biodiversity Strategy. Ballast water regulations, expected early next year, have been 14 years in the making (since the first guidelines were issued in 1989). They should be in place 10 years after the American regulations,¹ 6 years after amendments to the Canadian Shipping Act authorizing their making, and 4 years after the new 2000 guidelines on ballast water management. They are likely to appear at the same time as an international convention on ballast water management is to be approved by member states of the International Maritime Organization (IMO).

The Committee is dismayed by the extremely slow progress that Canada has made since 1992 when world leaders recognized invasive species as one of the most serious threats to health and to ecological, social and economic well-being of the planet. It is now well accepted that (1) invasive species can have a devastating effect on species diversity, that (2) following habitat destruction, invasive species are the second-leading threat to endangered species, that (3) aquatic invasive species cause significant, negative regional, national, and international effects, that (4) the impact of several invaders is greater than the sum of their effects if they had acted alone, that (5) aquatic invasive species damage infrastructure, disrupt commerce, outcompete native species, reduce biodiversity, and threaten human health, and that (6) aquatic invasive species continue to be introduced into Canadian waters, the apparent inaction at all levels of the Canadian government is unacceptable. This is highlighted by the fact that frustration over the slow pace of action prompted both the Commissioner of the Environment and Sustainable Development and the co-chairs of the International Joint Commission to request the opportunity to appear before the Committee.

Some of the issues addressed in this report are, however, not new to this committee. In 1998 we tabled a report² in Parliament in which we made two recommendations that we find still need to be repeated in this report despite the government’s response at the time. This lack of action has motivated our decision to undertake this study.

Mandate and Timing

On November 19, 2002, the Committee agreed “that the Commissioner of the Environment and Sustainable Development be invited to appear before the Committee.” This was done at the Commissioner’s specific request. On January 30, 2003, the Committee adopted a motion to conduct a study on invasive species proposed by its subcommittee on Agenda and Procedure. The study proposed that Professor Hugh MacIsaac of the Great Lakes Institute for Environmental Research, representatives from the Ontario Federation of Anglers and Hunters (OFAH), the Commissioner of the Environment and Sustainable Development (CESD) and the Chairs of the International Joint Commission (IJC) be invited to appear before the Committee. On February 6, the Committee initiated its study by hearing witnesses from the Ontario Federation of Anglers and Hunters, the Great Lakes Fishery Commission (GLFC), and the School of Environment of McGill University. On February 11, the Committee heard both chairs of the International Joint Commission, the Right Honourable Herb Gray and Mr. Dennis Schornack, as well as the Commissioner of the Environment and Sustainable Development, Ms. Johanne Gélinas. On March 19, the Committee heard senior officials from DFO, Transport Canada and Environment Canada. The Committee concluded its hearings on March 27 by hearing representatives from the shipping industry.

This study of the Standing Committee on Fisheries and Oceans comes on the heels of several important reports on invasive alien species. In both 2001 and 2002, the Commissioner of the Environment and Sustainable Development published reports pertaining to aquatic invasive species. The second of these was tabled on October 22, 2002, the day of the release of the Invasive Species report of the U.S. General Accounting Office, the American counterpart of the Office of the Auditor General (which includes the office of the CESD). In 2002, the International Joint Commission also published a report on Alien Invasive Species in the Great Lakes.

Recent Reports Pertaining to Aquatic Invasive Species

The 2001 Report of the Commissioner of the Environment and Sustainable Development

The Commissioner devoted a major chapter of her 2001 Report to the environmental integrity of the Great Lakes and St. Lawrence River Basin, including the threat of invasive species.

In Chapter 1 — A Legacy Worth Protecting: Charting a Sustainable Course in the Great Lakes and St. Lawrence River Basin, the Commissioner found that the federal government was ill prepared to counter the threat of invasive aquatic species, despite its commitments. There was no federal policy, no recognized lead department, and no plan to coordinate federal action to counteract the environmental, economic, and social impacts of invasive species and the government was doing little to prevent the arrival of additional invasive species.

The Commissioner identified Canada’s reliance on ships’ compliance with U.S. regulations, the threat posed by foreign ships with no ballast water on board, and Canada’s lack of commitment to the Great Lakes Fishery Commission’s Sea Lamprey Control Program as the most significant problems.

The 2002 Report of the Commissioner of the Environment and Sustainable Development

In Chapter 4, Invasive Species, of her 2002 report, the Commissioner added to the conclusions in the 2001 report. In the 2002 report, the Commissioner made the following main points.

The federal government has not responded effectively to invasive species that threaten Canada’s ecosystems, habitats, and other species. It has not identified the invasive species that threaten Canada’s ecosystems or the pathways by which they arrive. Human and financial resources are spread across federal departments, agencies and outside organizations, and are not coordinated. And it has not established the capability to gauge progress on its commitments.

According to the Commissioner, there was no federal department that sees the big picture or had overarching authority to ensure that federal priorities were established and action was taken and there was a bias toward continuing dialogue and consensus building and a lack of practical action.

Because invasive species frequently travel as stowaways with people, goods, and vehicles moving between regions with different ecosystems, increases in trade and the gross national product — a key economic goal — would almost certainly lead to further invasions unless the federal government took concrete steps to prevent them.

The Commissioner acknowledged that experts and the government recognize prevention as the best defence against invasive species. Preventive measures would not be cost-free, or stop all invaders, but they are generally considered more practical than reacting to a succession of crises and repairing damage after invaders have become established.

The 11th Biennial Report of the International Joint Commission on Great Lakes Water Quality (2002)

Canada and the United States signed the Boundary Waters Treaty (1909) and the Great Lakes Water Quality Agreement (1972, 1978, 1987), and created the International Joint Commission to assist in administering both.³ The International Joint Commission assists the governments in preventing disputes related to waters along the Canada-U.S. border. Under the Agreement, the IJC assesses the adequacy and effectiveness of programs and progress to restore and maintain the health of the Great Lakes and reports its findings and makes recommendations to governments biennially. To facilitate the coordination of binational fisheries management, Canada and the United States negotiated and ratified the 1955 Convention on Great Lakes Fisheries, which created the Great Lakes Fishery Commission.

In Chapter 3, Towards Biological Integrity: The Challenge of Alien Invasive Species, of its 11th Biennial Report on Great Lakes Water Quality⁴ the IJC highlighted the ecological damage and the economic costs of alien invasive species estimated, according to one study, to reach $137 billion⁵ annually in the U.S. alone.

It noted that current rules and practices for ballast water were not solving the problem despite a high level of compliance. It identified the exemption of “no ballast on board”⁶ ships from regulations as a major flaw in the system, as these ships could harbour alien invasive species in residues of previously discharged ballast water.

The report also noted that there were still substantial gaps in knowledge. For example, while the salinity of the ballast water was used to determine whether it had been exchanged, there was no accepted standard to actually evaluate the effectiveness of current ballast water exchange operations. The IJC report suggested that economic incentives could help to address the problem, pointing to “a conspicuous lack of government incentives.” It noted that the European port management community had pointed the way toward innovative incentives with its “green ship” awards, which offered reduced port fees for ships exceeding established management practices for all ship wastes, emissions, and discharges, including ballast water.

The IJC report acknowledged that governments were making some progress toward addressing the threat of alien invasive species with incremental advances in legislation, rulemaking and international agreements but that actions were focused on long-term actions and solutions and were developing at a frustratingly slow pace, despite repeated calls for immediate, urgent action from the Great Lakes community.

The Report of the U.S. General Accounting Office (2002)

In October 2002, the United States General Accounting Office (GAO) issued its report Invasive Species. The report observed that non-native plants and animals spreading through the United States had caused billions of dollars of damage to natural areas, businesses and consumers.

The GAO found that existing literature on the economic impacts of invasive species was of limited usefulness to decision makers because most economic estimates did not consider all of the relevant effects of non-native species or future risks.

The GAO also found that the U.S. National Invasive Species Management Plan, issued in 2001, did not clearly articulate specific long-term goals and that the U.S. federal government had made little progress in implementing actions called for by the plan.

The GAO recommended that the National Invasive Species Council: (a) incorporate data on the economic impacts of invasive species in developing the federal budget; (b) add performance-oriented goals and objectives to its updated plan; (c) give high priority to an oversight strategy for measuring progress against result-oriented goals; and (d) examine whether the Council was being hampered in its implementation of the Plan by the lack of specific legislation.

The Report of the Standing Committee on Fisheries and Oceans (1998)

The Standing Committee on Fisheries and Oceans tabled its Central Canada’s Freshwater Fisheries Report⁷ in November 1998. This report addressed a broad range of issues related to freshwater fisheries in Manitoba and Ontario, including invasive species.

At the time, the Committee noted an imbalance of DFO expenditures on science related, among other things, to the impact of invasive species in the Great Lakes. Even at that time, the Committee felt compelled to comment on DFO’s failure to make a long-term commitment to stable funding for the Great Lakes Fishery Commission’s sea lamprey program. The Committee recommended a guaranteed long-term minimum funding commitment for the sea lamprey program of $8 million per year. The government committed only to take the Committee’s recommendation into consideration for 1999. Since 1999, funding for the program has averaged just over $6 million and has never exceeded $7.5 million.

The Committee also commented on the need for ballast water regulations and recommended that Canada immediately adopt a mandatory ballast water exchange program. In its response, the government informed the Committee that regulations on ballast water management would be prepared following amendments to the Canada Shipping Act the previous year. However, four years have passed since the government made that commitment and regulations have yet to be issued.

The Committee called on the government to acknowledge the substantial negative effects of invasive species on the Great Lakes and that it take immediate steps to provide adequate funding to increase research into the effects of invasive species.

The Great Lakes and St. Lawrence River Basin

Sixteen million Canadians depend on the natural resources of the Great Lakes and St. Lawrence River Basin for their livelihoods. Another 25 million Americans share the basin. The Great Lakes and their connecting channels form the largest fresh surface water system on earth. Only the polar ice caps contain more fresh water. These vast inland freshwater “seas” have provided water for consumption, transportation, power, and recreation among a host of other uses.

The basin is a major economic force for Canada; Canada’s highest concentration of industry is located in the Great Lakes region. The integrated system of passable waters serves numerous commercial sectors including mining, agriculture, and industry, from the Canadian prairies to Atlantic Canada. These sectors profit by receiving or shipping to and from domestic and international destinations. Annual commerce exceeds 180 million metric tonnes at approximately 145 ports and terminals within the basin, adds an estimated $3 billion annually along with an estimated 17,000 jobs to the Canadian economy.⁸

The Great Lakes commercial fishery is one of the largest and the most valuable freshwater fisheries in the world.⁹ In Canada, it has an average annual landed value of about $45 million¹⁰ and adds over $100 million to the Canadian economy.¹¹ Recreational angling provides a further $350 million, for an overall contribution of $450 million to the Canadian economy. The combined value of both the American and the Canadian commercial and recreational fisheries in the Great Lakes has been estimated to be as much as $7 billion annually.¹²

Aquatic Invasive Species

The term “alien species” refers to a species or subspecies introduced outside its normal distribution.¹³ The term “alien invasive species” refers to an alien species whose establishment and spread threaten ecosystems, habitats or species with economic or environmental harm.¹⁴

The question has been raised as to whether Atlantic salmon on Canada’s West Coast can be considered an alien invasive species. Atlantic salmon fit the definition of an alien species in that they have been introduced in an area outside their natural distribution. Juvenile Atlantic salmon have been discovered in a small number of British Columbia streams indicating successful reproduction. In addition, there are issues related to farmed Atlantic salmon on the East Coast and farmed Pacific salmon on the West Coast. While these species are not alien in the sense that the same species also exist in the wild, the domestic stocks are genetically different and may pose a threat to the wild populations. The Committee has touched on these issues in its 2003 report The Federal Role in Aquaculture in Canada. While the Committee believes that these issues are worth studying, they are outside the scope of this study.

The Canadian ecosystem considered by some to be the most vulnerable to alien invasive species is the Great Lakes,¹⁵ and therefore is the primary focus of the Committee’s report. There are approximately 180 species of fish that are indigenous to the Great Lakes. Changes in the species composition of the Great Lakes basin over the last 200 years have been the result of human activities.¹⁶

Today, the Great Lakes and St. Lawrence River basin ecosystem is home to more than 160 known non-indigenous species of fish, invertebrates, plants, parasites, algae, and pathogens. Many other introduced species have likely gone unnoticed. Between 1985 and 2000, approximately 70% of the new species that invaded the Great Lakes originated from the Black and Caspian seas in Eastern Europe.¹⁷ These include the zebra mussel, its cousin the quagga mussel, the round goby and its relative the tubenose goby, the ruffe, the fisher waterflea and Echinogammarus ischnus, an invasive freshwater shrimp.

The number of recorded introductions of alien invasive species increased during the 20th century, from 40 in the first half to 76 during the latter half. Despite increasing awareness of invader risks, no discernible improvement occurred in the 1990s. During that decade, 15 additional alien species found their way into the ecosystem. The number of introductions has remained essentially unchanged from the 1980s (15), the 1970s (17), and the 1960s (15).¹⁸ Shipping accounts for more invasions than any other single vector, and its influence has grown in recent decades: 77% (36 of 47) of invasions since 1970 were likely caused by transoceanic shipping.¹⁹

The spectre of an “invasion meltdown” in the Great Lakes risks becoming a reality as alien species accumulate.²⁰ Frequent species introductions threaten the integrity of ecosystems in two ways: (1) as the cumulative number of introductions increases, populations of resident species are disrupted and the ecosystem becomes more easily invaded; and (2) once established, invaders alter habitat conditions favouring new invaders.²¹

Other Vulnerable Areas

The impacts of invasive species are not restricted to the Great Lakes and St. Lawrence basin. The Atlantic and Pacific coasts are also affected. The green crab (Carcinus maenus) is aggressively colonizing Canada’s East Coast, putting Canada’s $57 million²² clam, mussel, and oyster industries at risk. The $500 million Atlantic lobster industry is also potentially threatened by this invasive species.²³ On the West Coast, the green crab has also become established along the coast of Vancouver Island. The landed value of native clams and crab at risk in British Columbia was approximately $25 million in 2000.²⁴

Codium (Codium fragile tomentosoides), also known as oyster thief, is found on all coasts in British Columbia. It was first discovered in Nova Scotia in the late 1980s and has since expanded to the coastal waters of Prince Edward Island. Evidence suggests that codium smothers native molluscs, interferes with the reproductive cycles of the sea urchin, and displaces eelgrass that is habitat for eel. Codium also crowds out native kelp, the prime habitat for lobster and other commercially valuable species.

A third coastal invasive species is the clubbed tunicate (Styela clava). This species interferes with the settlement of oyster larvae on both coasts, and competes for space and food with young oysters and mussels. They are considered a serious pest within the aquaculture industry.

Main Route of Entry: Ballast Water

A witness categorized the major routes of entry for aquatic invasive species as coming “through the front door, the side door and the back door.” The routes of entry for invasive species include:

•	Intentional introductions;

•	Ballast water from the commercial shipping industry;

•	Recreational boating and personal watercraft;

•

Canals;

•	Horticulture (water gardening);

•	Live bait use;

•	Aquaculture;

•	Live food fish trade;

•	Aquarium trade;

•	Alien species used in research; and,

•	Unauthorized stocking of fish.

The primary pathway for invasion, the front door, is the discharge of untreated ballast water carried by foreign vessels. Ballast water exchange in sensitive areas is the leading or primary route of entry of aquatic invasive species such as zebra mussels.

Ballast water is carried by ships to ensure stability, trim and structural integrity; it is essential to the safe and efficient operation of modern shipping. When a ship discharges its cargo, it loads up with ballast water to compensate and when it loads cargo, the ballast water is discharged.

Ballast water can represent up to 30% of the loading capacity of a ship. For a typical carrier on the Great Lakes, that amounts to approximately 10,000 metric tones of water at full ballast condition. More frequently, ships transit in light ballast conditions, carrying between 300 and 500 metric tonnes.²⁵ Commercial shipping moves over 80% of the world’s commodities and transfers approximately three to five billion tonnes of ballast water each year.

The greatest threat from ballast water is when fresh or brackish water is loaded in one region of the world and carries exotic and potentially harmful invasive species to other freshwater ecosystems elsewhere, including North America. For this reason, current guidelines or regulations for the management of ballast water recommend or prescribe either exchange of ballast water at sea (as salt water kills most freshwater invasive species), retention of ballast water in sealed tanks, or treatment of ballast water on uptake or discharge.

Studies of the effectiveness of ballast water exchange indicate that actual physical exchange of greater than 85% of the water carried in the ballast tank can be achieved.²⁶ Other methods of treatment of ballast water to reduce or eliminate living organisms have been the primary focus of efforts to address the ballast water issue. Potential ballast water treatment technologies include:

•	Filtration

•	Hydrocyclone

•	Ultraviolet light irradiation

•	Ultrasound

•	Heat treatment

•	Chemical treatment

•	Deoxygenation

•	Copper ion release

•	Shore based treatment

Representatives of the maritime industry told the Committee that the industry had been actively involved in the development and testing of alternative treatment technologies for ballast water management. For example, a filtration system for ballast water was tested on the Canadian vessel, the Algonorth as part of The Ballast Water Technology Demonstration Project. The results of this project were overall very promising. The British and the Australians have respectively conducted other projects with ultraviolet treatment and the effects of heat.

Representatives of the shipping industry affirmed their high-level compliance to the American regulations on ballast water. In fact, the Shipping Federation of Canada has adopted a Code of Best Practices for Ballast Water Management in 2000 and members of the industry are involved in the consultations for the development of Canadian regulations. Nevertheless, while 95% of ships comply with the U.S. ballast water regulations, according to a 1991 Canadian study, the regulations only apply to 5% to 25% of ships. In recent years, the majority of ships entering the Great Lakes are fully loaded with cargo, and thus required no ballast water other than for adjusting the trim. Although the ballast tanks of such ships are pumped out, sludge remains at the bottom of the empty tanks. This sludge may contain not only invasive species but also pathogens causing diseases such as cholera. Foreign ships with no ballast water on board (NOBOB) pose a more significant threat than ballast water exchange, as neither the U.S. regulations nor the Canadian guidelines apply to them²⁷.

Currently, Canada does not prohibit the discharge of ballast water within its 200-mile exclusive economic zone. The CESD reported in 2002 that Transport Canada neither regulates ballast water discharges, nor monitors or reports on compliance with its guidelines on ballast water exchange. In fact, because Great Lakes-bound ships transit American waters at Massena, they are subject to U.S. regulations. Canada therefore relies on U.S. inspection and enforcement to ensure ships’ compliance with ballast water management rules. U.S. Coast Guard officers based in Massena perform inspections at the entrance to the St. Lawrence Seaway in St. Lambert, QC, a few miles upriver from the Port of Montreal. There are no inspections done downriver, in the St. Lawrence estuary, or in the Gulf of St. Lawrence. This reliance on American regulations has been used to justify the lack of urgency in developing Canadian regulations.²⁸ The Committee rejects any such justification.

Canada took early leadership on ballast water management in 1989 by establishing voluntary guidelines to protect the Great Lakes. These guidelines were based on the assumption that exchange of ballast water at sea would kill alien freshwater organisms. In 1993, the U.S. followed suit with ballast water exchange regulations made pursuant to the 1990 Nonindigenous Aquatic Nuisance Prevention and Control Act. These regulations were based on the 1989 Canadian guidelines. The American Act has been re-authorized once with the 1996 National Aquatic Invasive Species Act, and is about to be re-authorized and reinforced with a new bill. The new National Aquatic Invasive Species Act (NAISA) was introduced in both the U.S. House of Representatives and the Senate in March 2003. With NAISA (2003), the U.S. will make ballast water regulations mandatory everywhere in the country by 2004. It also sets the year 2011 as the deadline for the implementation and enforcement of final standards for operational performance and biological effectiveness of ballast water exchange and treatment. NAISA (2003) has been praised by both chairmen of the IJC as representing “major progress toward closing the doors to biological invaders while keeping the doors open for maritime commerce.” The Canadian Section Chair, the Right Honourable Herb Gray, added that the IJC was “encouraged by the attention given to Aquatic Invasive Species by the U.S. Congress and was [looking] forward to similar legislative initiatives in Canada.”²⁹

This committee recommended in its 1998 Central Canada’s Freshwater Fisheries Report “that the Government of Canada immediately adopt measures to ensure that a mandatory ballast water exchange program be instituted and effectively enforced for vessels entering Canadian waters.” The government responded that the statutory authority for a mandatory program, which had not existed previously, had been included in the recent amendments to the Canada Shipping Act (CSA). The amendments to the Canada Shipping Act received Royal Assent on June 11, 1998, and the authority to regulate the control and management of ballast water came into force on October 31, 1998.³⁰

A consultation process under the auspices of Canada’s Marine Advisory Council (CMAC), involving representation from federal departments, the transportation industry, labour associations, recreational boaters, environmental groups and other interested marine stakeholders, was undertaken. However, it would appear that the end result of this process was not mandatory regulations but rather the 2000 Guidelines for the Control of Ballast Water Discharge from Ships in Waters under Canadian Jurisdiction. These guidelines apply to all vessels entering Canada’s exclusive economic zone, including those arriving from U.S. ports. The Committee welcomes the broadening of the application of Canadian guidelines to continental seaboard traffic as it is well established that invasions of non-indigenous species may also significantly disturb marine and estuarine biological communities. One example of such a community is the Digby Neck area in Nova Scotia, one of the richest fishing areas of the world, currently threatened by marine traffic from the U.S. eastern seaboard that would service a proposed quarry in the area.³¹

Canadian Ballast Water regulations for the Great Lakes and St. Lawrence River under the CSA are being drafted and are to be harmonized with U.S. requirements. Promulgation may be as early as 2004. The Committee welcomes the regulations but it is appalled that it will have taken 6 years since the CSA was amended and 15 years since the first guidelines were established, for the government to implement such regulations.

In its response to our 1998 report, the government also noted that untreated ballast water meets the definition of a pollutant under Canadian law.³² False declarations made regarding the exchange of ballast water are an offence and have been successfully prosecuted under the Canada Shipping Act.

In the meantime, there have been negotiations on the international arena on ballast water management. In response to the threats posed by aquatic invasive species, the 1992 Rio Conference on Environment and Development called on the International Maritime Organization (IMO) and other international bodies to take action to address the transfer of harmful organisms by ships. Negotiations on ballast water management at the IMO resulted on a draft Convention for the Control and Management of Ships’ Ballast Water and Sediments. Regulations for ballast water management accompany this convention and would replace the current IMO guidelines set forth by the 1997 Assembly resolution A.868(20). A diplomatic conference is scheduled to be held at the beginning of 2004 to consider and adopt the draft text of the new convention. The current draft document does not yet specify conditions for the entry into force of the new convention; generally it requires 25 member states totalling 50-65% of the world tonnage to ratify the treaty. While the average delay for the entry into force of IMO conventions and related regulations upon signature of the treaty by member states is 5 years, some IMO conventions have been activated within as little as 90 days. Government officials assured the Committee that Canada will implement international regulations for all Canadian waters when the IMO regulations come into force.

Other Routes of Entry: Tributaries and Waterways

Shipping has historically relied on a network of canals connecting most major basins in Eastern Canada and United States: e.g. the Rideau, Erie, Champlain, and Welland canals, and the Chicago Sanitary and Shipping Canal which links the Great Lakes and the Mississippi River basins. These networks of canals, locks and dams provide artificial connections between watersheds and make shipping and recreational boating possible. One witness has described this as the “side door entrance” to aquatic invasive species, particularly fish. At least 12 species have invaded the Great Lakes in part through these canal systems³³. Many invasive species have taken advantage of these networks to extend their range. Zebra mussels spread from the Great Lakes to many inland lakes and streams in Ontario through the Rideau Canal, and to the Mississippi River basin through the Chicago sanitary and shipping canal.

At this time, Asian carp (there are several species) constitute one of the most serious threats to the ecology of the Great Lakes. One witness described the Asian carp as the “piscatorial poster child for invasive species.” The only obstacle stopping Asian carp from invading the Great Lakes from the Mississippi River system is an electrical barrier across the Chicago Sanitary and Shipping Canal. The same barrier can prevent invasive species (such as the round goby, tubenose goby and ruffe) from advancing in the opposite direction into the Mississippi River basin from the Great Lakes.

Four species of large Asian carp (grass, bighead, silver and black) have been imported into the Southern U.S. for use in the freshwater aquaculture industry to control vegetation and algal blooms. Two species, the silver and the bighead escaped into the Mississippi River basin from fish farms during floods in the early 1990s. Biologists are increasingly raising concerns about their effect on native fish and shellfish when these species of carp are released into the wild. These species are all native to areas of northern China and Siberia and thus will likely find the cool waters of the Great Lakes suitable for habitation. The Asian carp are large (30-40 kg), have voracious appetites, are very prolific and have no predators. Thus, they pose a very real threat to aquatic life in the Great Lakes. Asian carp feed at very low trophic levels (zooplankton, phytoplankton and aquatic macrophytes) which form the basis of North American aquatic food chains. The four species of Asian carp are:

•	Grass carp (Ctenopharyngodon idella) was imported in 1963 to aquaculture facilities in Alabama and Arkansas for research in the control of vegetation. The U.S. Fish and Wildlife Service estimates that immediate action is needed to limit access to the Great Lakes.

•	Bighead carp (Hypophthalmichthys nobilis) was first brought to this continent in 1972 by an Arkansas fish farmer to improve water quality. The likelihood of its transfer to the Great Lakes is high and immediate action is needed to prevent access to the Great Lakes.

•	Silver carp (Hypophthalmichthys molitrix) was first introduced in 1973 by an Arkansas fish farmer for use as phytoplankton control in ponds and as a food fish. Its transfer to the Great Lakes is as likely as for the bighead carp and similar action is required.

•

Black carp (Mylopharyngodon piceus) was brought to the U.S. in the early 1970s as a contaminant in imported grass carp stocks. Black carp are still presently held in captivity so the effects on native ecosystems are not documented. However, if released, the species could pose a serious threat to mussel and snail populations.

The invasive species electrical dispersal barrier across the Chicago Sanitary and Shipping Canal began operation in April 2002. In an effort to improve and operate this barrier, secure funding had to be obtained from the U.S. Congress. The International Joint Commission, the U.S. Environmental Protection Agency and the Great Lakes Fisheries Commission also contributed financially. However, there is a clear need for a second barrier, the construction of which started recently. Again the IJC and the GLFC, in partnership with the State of Illinois and the U.S. Army Corps of Engineers (the original proponent of the first electrical barrier), are involved. The estimated cost of the project is $10 million U.S.³⁴ Canada clearly benefits from these projects, but its specific role, except for that as partner in the IJC and the GLFC, remains undefined. The Committee believes that Canada should be more proactive in assisting the U.S. with preventative measures to protect Canadian ecosystems.

Hidden Routes of Entry

Some pathways for the introduction of invasive species are, at first glance, less obvious. They are nevertheless significant and the so-called “backdoor” to the Great Lakes remains widely open. These pathways include the live food fish trade, the aquarium trade and live bait use:

•	Several alien species including Asian carp are imported live into Canada in large numbers from aquaculture facilities in Southern U.S.35 This is a growing industry in Canada. Concern centres around the possibility that customers will buy and release live fish into the open.

•

The problem of deliberate aquarium releases or escape of aquarium fish from breeding facilities is particularly important in the Southern U.S. However as many as 12 species may have been introduced into the Great Lakes as a result of aquarium trade. This includes such well-known species as goldfish. This industry remains largely unregulated in Canada, particularly with respect to the importation of aquarium and pond organisms. Awareness programs directed at hobbyists are probably our best option.

•

Use of live bait is recognized as a potential pathway. Several species of fish and one species of mollusc have been introduced through this pathway, but more importantly it allows species to extend their natural range within the Great Lakes basin and has the potential to spread the microscopic stages of alien species that may contaminate the bait (e.g. zebra mussels).

The live fish food trade represents a potential source of introduction of the Asian carp. According to one witness, more than 400 000 kg of Asian carp are trucked annually across the Ambassador Bridge for markets in Ontario.³⁶ Fish markets across the country sell live Asian carp. One witness even displayed a 6 kg bighead carp bought alive the day before in a market in Ottawa. The Great Lakes Fishery Commission has been working with federal, state, provincial and tribal law enforcement officials to stop the trade in live fish. Partly as a result of these efforts, the states of Ohio, Michigan, Indiana and Illinois have already banned the possession of live Asian carp.

Under Canadian law, it is legal to import live Asian carp into Canada. It is however illegal under the Fisheries Act to release live Asian carp into Canadian waters (section 55 of the Fisheries (General) Regulations). Enforcement would present obvious practical challenges. There are, however, two more practical legal tools that the Committee believes could be employed with little delay to counter this threat: banning the importation of potentially harmful live fish or other aquatic species for the food or the aquarium trades, and banning the sale and trade of these species. Time is of the essence and immediate action is required in the case of the Asian carp. There is absolutely no reasonable excuse for delay in banning the importation of live Asian carp.

The Wild Animal and Plant Protection and Regulation of International and Interprovincial Trade Act (WAPPRIITA) and the Wild Animal and Plant Trade Regulations are meant (1) to conserve Canadian wild animals and plants by preventing their illegal trade, (2) to enable Canada to do its part to prevent the illegal international trade of wild specimens, and (3) to protect Canadian ecosystems from the introduction of listed harmful wild species. Species whose introduction into Canadian ecosystems would be harmful to indigenous species are listed in Schedule II of the Regulations. Listed species may not be imported into the country. It is recognized that WAPPRIITA is best suited to regulating the planned importation or interprovincial transport of potentially harmful, mostly alien macro-organisms. In fact, WAPPRIITA was “designed expressly for the purpose of enabling the designation of species that we think could be invasive if they were to establish themselves in Canada and therefore control the importation.”³⁷ The Committee believes that Asian carp and any potentially harmful alien species should be added to Schedule II of the Wild Animal and Plant Trade Regulations without delay to prevent the importation and trade in such species.

During the Committee’s hearings, the question was asked which level of government would have the jurisdiction to prohibit the sale of live Asian carp. The Committee has examined this issue and has concluded that the federal government has the authority to regulate the sale of potentially invasive aquatic species for the purpose of protecting fisheries resources.

Section 27 of the Marine Mammal Regulations prohibits the sale, trade or barter of young harp and hooded seals, known respectively as whitecoats and bluebacks. In the case of Ward vs. Canada (Attorney General),³⁸ the Supreme Court of Canada found that the objective of this regulation was not to control commerce or property per se but to curtail a hunt that was damaging the economic viability of the sealing industry and the fisheries resource in general. The Court found that s. 27 was “in pith and substance” (in other words the essence of s. 27) concerned with the management of the Canadian fishery and that it therefore fell within the federal fisheries power. The Court noted that the federal power over fisheries is not confined to conserving fish stocks, but extends more broadly to maintenance and preservation of the fishery as a whole, including its economic value.

By analogy, the Committee believes that the federal government has the jurisdiction and the legislative authority under section 43 of the Fisheries Act to ban the sale of live Asian carp and any other potentially invasive species of fish as this would be more directly concerned with the preservation of the fishery than a prohibition on the sale of young seals.

Prevention is Vital

The Convention on Biological Diversity states that Contracting Parties, as far as possible and as appropriate, shall “prevent the introduction of, control or eradicate those alien species which threaten ecosystems, habitats or species.”³⁹ Once an alien species has become established, eradication may be impossible and control programs are costly especially in large, open aquatic systems such as the St. Lawrence and Great Lakes Basin. It is widely accepted that preventing the introduction of invasive species is the most environmentally sound and cost-effective management approach as stated by the Commissioner of the Environment and Sustainable Development:

Prevention is recognized by experts and the government as the best response to invasive species. Preventive measures would not be cost-free, or stop all invaders, but they are generally considered more practical than reacting to a succession of crises and repairing damage after invaders have become established.⁴⁰

In addition, waiting to react until after an alien species has invaded, risks the possibility of adverse synergistic reactions between invading species further compounding the extent of environmental damage and the difficulty of controlling the invasion:

We will stand to benefit disproportionately if we can slow the rate of invasion. This is a rebuttal to anybody who says that you shouldn’t bother expending costly controls if you can’t control everything. We don’t have to control everything. The more we shut down the tap, the more we’re going to benefit. That’s what this implies.

Anthony Ricciardi, McGill University School of Environment

Thus, a proactive approach that prevents introductions of invasive species can potentially save millions of dollars in impacts and control costs, eliminate harmful ecological side effects from control programs, and avoid the ecosystem problems and management uncertainty that are created when invasive species become established.⁴¹

Control of Aquatic Invasive Species

Several control programs have been implemented to mitigate the harmful impacts of specific invasive species in the Great Lakes. Although they are often costly and can have undesirable impacts on wildlife, some of these programs are successful. Control however seldom leads to complete eradication, and such programs need a stable and long-term commitment of resources and funding.

The Sea Lamprey Program

The sea lamprey (Petromyzon marinus) is a primitive fish native to the Atlantic Ocean. It was introduced to the Great Lakes in the early part of the 20th century as a result of the construction of the canal system that linked the Great Lakes with the Atlantic.

The lamprey is a parasite that attaches itself to other fish by means of a sucking disk in order to feed on their body fluids. In its adult phase, each lamprey can kill 18 kg or more of fish.

As it spread through the Great Lakes, the sea lamprey caused enormous destruction to native fish populations, which had no defences against the invader, and in turn devastated thriving Great Lakes fisheries.

The Great Lakes Fishery Commission was formed in 1955, in part to control the sea lamprey. The Commission cooperates with Fisheries and Oceans Canada, the U.S. Fish and Wildlife Service and the U.S. Army Corps of Engineers to control sea lampreys in the Great Lakes. Both the United States and Canadian federal governments fund the Great Lakes Fishery Commission. Under the Convention on Great Lakes Fisheries and supporting legislation, the United States and Canada respectively contribute 69% and 31% of the Commission’s budget for the Integrated Sea Lamprey Management Program.

The Sea Lamprey Control Program has been a great success. Sea lamprey populations have been reduced by 90% and native fish stocks are rebounding. The program employs a variety of methods including a chemical “lampricide,” barriers to prevent lampreys from accessing suitable spawning areas, trapping, and the release of sterile males.

Despite the success of the program, it is impossible to eradicate the sea lamprey entirely and efforts to control it cannot be relaxed.

The program currently costs $21 million annually. In the past two years, Canada’s contribution to the Great Lakes Fishery Commission has fallen short of its commitment of 31%. Despite the fact that the Sea Lamprey Control Program is one of the most cost-effective programs supported by the federal government, it has suffered from a lack of commitment to long-term, stable funding.

Since the combined Great Lakes commercial and recreational fisheries contribute almost a half billion dollars to the Canadian economy, the Sea Lamprey Control Program is a remarkably small investment to protect this resource.

Zebra Mussel Control

Zebra mussels (Dreissena polymorpha) are small mollusks about the size of a fingernail. Originally from the Black and Caspian seas area, they spread through Eastern Europe in the late 18th century via canals built for commercial navigation. They were first observed in the mid-1980s in Lake St. Clair and they are believed to have been introduced in ballast water discharged from an ocean going vessel. The zebra mussel is a prolific breeder. Carried by boat traffic and the normal flows of water, the zebra mussel has spread rapidly through the Great Lakes and beyond. The zebra mussel is now firmly established, not only in the Great Lakes, but also through the Mississippi River and its tributaries. A related species, the quagga mussel, is also spreading through the Great Lakes.

The mussels attach to virtually any available surface such as docks, boat hulls, commercial fishing nets and even native mollusks. Infestations foul water intake pipes, and disrupt municipal water supplies, industrial processing and cooling water, and agricultural irrigation water. Zebra mussel invasions to inland lakes in Ontario have caused habitat alterations and disrupted fish communities and have had severe economic impacts to shoreline residents, power generators, and municipalities by clogging intake pipes.⁴²

 

The mussel also causes problems for marine traffic by attaching itself to the hulls of boats, increasing drag and fuel consumption. They can also clog cooling water intakes causing overheating and engine damage.

Scientists do not believe that zebra mussels can be eradicated and there is currently no way of controlling them on a Great Lakes-wide basis. In fact, there is little that can be done at present because they are so firmly established.⁴³ The major objective of research is to find ways to control them and minimize the damage they cause. Chlorination is the most common treatment in use, but the use of chlorine is generally contrary to other environmental objectives.

The one area in which the zebra mussel population is currently being controlled is in “closed systems” such as cooling water intakes at electrical generating plants around the Great Lakes. At certain times of the year the water has to be treated with chemical compounds to prevent the zebra mussels from establishing colonies inside the pipes, clogging them up and shutting the system down. In open systems, such as the Great Lakes themselves, there is little that can be done as the use of chemicals or biological controls risks creating even more damage.

The control of the spread of zebra mussels through education and awareness campaigns appears to be the most effective way to deal with this invasive species at this time.

Education and Awareness

Public awareness programs, partnerships and cooperation between diverse agencies and stakeholders have been critical to the success of invasive species management efforts in the Great Lakes region. Numerous government agencies, industry partners and non-governmental organizations (NGOs) are involved in the management of zebra mussels alone.

Various NGOs, most notably the Ontario Federation of Anglers and Hunters (OFAH), have provided invasive species education campaigns where the federal government and its agencies should have been more proactive. The Committee wishes to acknowledge the tremendous efforts of the OFAH, a volunteer organization.

Invasive species education campaigns have successfully raised public awareness and influenced behaviours by targeting key interest groups such as anglers, boaters, cottage owners, and aquarium hobbyists. The Invading Species Hotline, the Invading Species Watch, and the Zebra Mussel Mania Travelling Trunk are examples of campaigns and programs offered by the OFAH. These directed campaigns, however, are limited by both the financial and human capital that is available to them. Provided with adequate resources, public education and awareness programs have the potential to be among the most economical and cost-effective solutions to preventing the spread of invasive species. The Committee believes that the federal government should support these worthwhile initiatives in a concrete financial manner.

Science and Research

Scientific information is crucial to making well-informed policy decisions. The Committee wants to reiterate that the federal government has yet to identify the invasive species that threaten Canada’s ecosystems or the pathways by which they arrive. Several witnesses stressed the importance of, and need for, a central information repository where all aquatic invasive species science can be kept and accessed equally by researchers and policy advisors among other stakeholder groups.

Central information repositories that provide coordination regionally, nationally, and internationally would be beneficial for several reasons. The coordination of the collection and exchange of information is needed as is a means for the rapid exchange of information. Research underlies every aspect of detecting, preventing, controlling, and eradicating invasive species, educating citizens and stakeholders, and restoring ecosystems.

Governmental Actions to Date

At the 1992 United Nations Convention on Biological Diversity, world leaders recognized invasive species as one of the most serious threats to health and to ecological, social and economic well-being. Canada and 167 other countries signed the Convention. The previous year, in preparation for the Convention, Canada had designated Environment Canada to coordinate our commitments made through the Convention.

In 1995, the Biodiversity Convention Office at Environment Canada released the Canadian Biodiversity Strategy, Canada’s Response to the Convention on Biological Diversity. In this document, under the heading “Strategic Directions,” the government made commitments to:

•	Take all necessary steps to prevent the introduction of harmful alien organisms and eliminate or reduce their adverse effects by:

•	Developing and implementing effective means to identify and monitor alien organisms;

•	Determining priorities for allocating resources for the control of harmful alien organisms based on their impact on native biodiversity and economic resources, and implementing effective control or, where possible, eradication measures;

•	Identifying and eliminating common sources of unintentional introductions;

•	Developing national and international databases that support the identification and anticipation of the introduction of potentially harmful alien organisms in order to develop control and prevention measures;

•	Ensuring that there is adequate legislation and enforcement to control introductions or escapes of harmful alien organisms, and improving preventative mechanisms such as screening standards and risk assessment procedures; and

•	Enhancing public education and awareness of the impacts of harmful alien organisms and the steps that can be taken to prevent their introduction.

•	Promote research into methods and approaches that improve our ability to assess whether or not alien organisms will have an adverse impact on biodiversity.

An important characteristic of the Canadian Biodiversity Strategy is that many agencies, federally and provincially, are involved in implementing the recommendations and strategies that it contains. Along with Environment Canada, the lead department for the Canadian Biodiversity Strategy, two other federal departments play key roles in managing the problem of aquatic invasive species. Transport Canada is responsible for regulating and controlling the management of ballast water on ships and preventing or reducing the release of foreign aquatic organisms or pathogens by ships entering Canadian waters. DFO is responsible for the conservation and protection of fish and their habitat. DFO has also the responsibility of performing scientific research and providing scientific advice in connection with ballast water regulations and standards.

In recent years, Environment Canada has concentrated its efforts in the context of the Biodiversity Strategy on the Species at Risk Act, which received royal assent last December. In fact, it appears that all of the Department’s energy and resources were mobilized by this initiative, and that other priorities, including invasive alien species, advancing stewardship, biological information systems, biodiversity status and trend reporting, have been neglected. This happened despite the fact that invasive species had been recognized as a most serious threat worldwide. The Committee was told that after the strenuous decade-long process of developing the Species at Risk Act, the government of Canada was only now paying attention to the other priorities within the Canadian Biodiversity Strategy.

It is therefore not surprising that in 2002, the Commissioner of the Environment and Sustainable Development reported that the government still needed to know three basic things to begin managing invasive species:

•	Which species and pathways pose the greatest risks;

•	Who will take what action to respond to those risks; and

•	How effectively those actions have mitigated the risks so that further actions may be taken as required.

Finally, in September 2002, the Canadian Council of Fisheries and Aquaculture Ministers, the Canadian Council of Forest Ministers, and the Wildlife Ministers Council of Canada adopted the blueprint for a national plan to address the threat of invasive alien species.⁴⁴ Four thematic working groups were also established: an aquatics invasive group, a terrestrial animals group, a terrestrial plants group and a leadership and coordination of thematic working group. The aquatics invasive species workgroup is co-chaired by DFO and the Ontario Deputy Minister of Natural Resources.

The blueprint identifies three strategic goals to guide the development of a national policy and management framework:

•	Integrating environmental considerations into decision-making, in this case the implications of invasive species;

•	Coordinating responses to new invasions and pathways; and,

•	Strengthening programs to protect natural resources better under pressure because of increased global trade and transport.

Achieving these goals should improve the prevention, the early detection and rapid response as well as the eradication, containment and control programs. To do so, Canada will need to improve its coordination, refine its legislation and policy tools, work closely with its trading partners, focus on risk assessment and support research, monitor ecosystems and inform the public. In terms of coordination, the national plan to address the threat of invasive alien species confirms the role of Environment Canada as leader and coordinator of the federal response to invasive alien species. The development of a national plan will span three phases.

The first phase is supposed to include Cabinet level discussions. During that time, the federal action should focus on prevention since it is widely acknowledged that it is more cost effective than managing established invaders. Other action will include a policy framework for the National Strategy and action plans, and immediate action on ballast water management. As mentioned above, new regulations prepared by Transport Canada with the contribution of DFO could come as early as 2004. The second phase of the national plan pertains to the eradication, the containment and the control of some established invaders, the third phase relates to innovation and technology.

Specific actions on aquatic invasive species are under the purview of one of the thematic working groups set forth by the ministerial councils last fall. This task force will formulate an action plan whose goals are to:

•	Prevent unintentional or accidental introductions of new species;

•	Slow down the spread of aquatic species that have already become established; and,

•	Eliminate or at least to reduce the unacceptable impacts of aquatic invasive species.

Components of this plan would include:

•	Conducting a comprehensive review of federal, provincial and territorial current legislative tools;

•	Assessing significant environmental risks;

•	Identifying actions to address the most important pathways (such as ballast water);

•	Monitoring inspection reporting and enforcement activities where they are most effective;

•	Extending bilateral and international collaborations to enhance prevention actions;

•	Supporting successful control programs such as the sea lamprey program;

•	Conducting scientific research and providing scientific advice to assist Transport Canada in designing and implementing ballast water management plans; and,

•

Supporting public awareness campaigns such as the Ontario Federation of Anglers and Hunters campaign, the Shorekeepers and Reefkeepers Species Watch Program, the Canadian Coast Guard Notice to Mariners, and other public education programs instituted by various municipalities and port authorities in Canada.

Conclusion

The Committee believes that while very well intentioned, the federal initiative presented at our hearings comes too late, is focused on process and proposes very little in the way of immediate actions. The Committee favours an approach in which immediate actions will be taken on the following urgent matters:

•	Adoption of ballast water management regulation and development of treatment standards;

•	Inclusion of species of Asian carp in Schedule II of the regulations related to the Wild Animal and Plant Protection and Regulation of International and Interprovincial Trade Act ;

•	Prohibition of the sale and trade of Asian carp under section 43 of the Fisheries Act; and,

•	Contribution to the full extent of our commitment to the budget of the Sea Lamprey Control Program;

Furthermore, we believe that in the longer term, only the introduction of a comprehensive legislative package harmonized with American legislative initiatives, policies and enforcement practices, will ensure that Canada successfully closes the door to aquatic invasive species. This federal coordinated effort should be accompanied by consultation with the provinces and territories, and by a reference to the International Joint Commission to coordinate and harmonize Canada-U.S. efforts for action to counter the threat of aquatic invasive species in the Great Lakes basin.

Recommendations

RECOMMENDATION 1

That the federal government designate the Minister of Fisheries and Oceans as the minister responsible for coordinating federal actions relating to aquatic invasive species. These actions should include:

•	Creating a working committee of relevant ministers to work with the coordinating minister;

•	Consolidating and streamlining regulations applicable to aquatic invasive species within a comprehensive set of federal regulations;

•	Reducing invasive species introductions from ships by:

•	Establishing a national mandatory ballast water management program;

•	Requiring ships to have an invasive species management plan that outlines ways to minimize transfers;

•	Creating a tracking system for ships in transit to monitor compliance with the ballast water management program; and,

•	Including incentives for ship owners to install experimental ballast treatment technology.

•	Establishing emergency response centres to react to the threat of invasive species;

•	Preventing invasive species introductions from other pathways by:

•	Inventorying all invasive species that constitute the greatest risk for Canadian aquatic ecosystems and economy; and,

•	Identifying and managing pathways that pose the highest risk of introducing aquatic invasive species.

•	Supporting development and implementation of provincial and territorial aquatic invasive species management plans, including early detection, screening and rapid response activities;

•	Conducting ecological surveys for early detection of aquatic invasive species and analysis of invasion rates and patterns;

•	Ensuring that prevention and control measures do not further harm the environment and that they comply with the Fisheries Act, the Canadian Environmental Protection Act and the Canadian Environmental Assessment Act;

•	Supporting education and outreach programs to inform the public on preventing transfers of invasive species by proper cleaning of recreational boats, and proper disposal of non-native organisms from home aquaria;

•	Conducting research on high-risk invasion pathways and alternative prevention and control technologies; and,

•	Allocating the necessary funding and resources for rapid response to introductions of aquatic invasive species, and for aquatic invasive species prevention, control, and research.

RECOMMENDATION 2

That Canada seek a permanent reference to the International Joint Commission to coordinate and harmonize binational efforts for action to counter the threat of aquatic invasive species in the Great Lakes basin.

RECOMMENDATION 3

That in order to evaluate the federal government’s progress towards its commitment on aquatic invasive species issues, the Minister of Fisheries and Oceans submit an interim report to Parliament within six months of being designated, and that this report be referred to the Standing Committee on Fisheries and Oceans for scrutiny and report to Parliament by the Committee; and,

That the Minister of Fisheries and Oceans thereafter submit a report once a year to Parliament, and that this report be referred to the Standing Committee on Fisheries and Oceans for scrutiny and report to Parliament by the Committee.

RECOMMENDATION 4

That the the Minister of Fisheries and Oceans as the minister responsible for coordinating federal actions relating to aquatic invasive species, expedite the development and implementation under the Canadian Shipping Act of ballast water management regulations providing for mandatory exchange of ballast water.

RECOMMENDATION 5

That Canada and the United States under the auspices of the International Joint Commission, harmonize their ballast water treatment and exchange programs.

RECOMMENDATION 6

That as a matter of priority, standards for the treatment of ballast water be developed, implemented and fully enforced.

RECOMMENDATION 7

That the federal government support research into ship design, risk assessment and ballast water treatment technologies.

RECOMMENDATION 8

That in order to expedite the entry into force of the International Convention for the Control and Management of Ship’s Ballast Water and Sediments, Canada press for minimum ratification requirements, in terms of the number of signatures needed.

RECOMMENDATION 9

That the Government of Canada, through the Department of Fisheries and Oceans, guarantee stable, long-term funding of the Canadian portion of the Sea Lamprey Control Program. This funding should fully meet Canada’s obligation under the Convention on Great Lakes Fisheries to contribute 31% of the Great Lakes Fishery Commission annual budget for the Integrated Management of Sea Lamprey program.

RECOMMENDATION 10

That grass, bighead, silver and black carp and any other aquatic alien species deemed harmful to Canadian wildlife or ecosystems be immediately listed in Schedule II of the Wild Animal and Plant Trade Regulations, under the Wild Animal and Plant Protection and Regulation of International and Interprovincial Trade Act in order to prohibit their importation into Canada in a live state.

RECOMMENDATION 11

That the Minister of Fisheries and Oceans use his or her authority to conserve and protect fish and their habitat under section 43 of the Fisheries Act to issue regulations prohibiting the sale and trade of live grass, bighead, silver and black carp in Canada.

RECOMMENDATION 12

That a central repository of aquatic invasive species research be established to provide easy and effective access to scientific data. Such a repository could be modelled after the Great Lakes fishery database.

RECOMMENDATION 13

That the federal government through the Department of Fisheries and Oceans provide financial support to the Ontario Federation of Anglers and Hunters to help fund its aquatic invasive species education initiatives in the province of Ontario.

RECOMMENDATION 14

That the federal government through Environment Canada fund the Ontario Federation of Anglers and Hunters’ proposal for $1.4 million over five years for a national aquatic invasive species awareness program.