Invasive Species ...Input requested

[glen]

Lake Superior Binational Program's
Complete Prevention Plan for aquatic invasive species is available for review on the GLIN website -
http://www.epa.gov/glnpo/lakesuperior/l ... _draft.pdf

Comments on the Complete Prevention Plan for Aquatic Invasive Species can be made on this site. If you haven't already done so, register to post on this site by clicking "Register" (towards top right of page). Registering only takes a moment. The Binational Forum co-ordinator will automatically receive an email to "activate" your account. You will then be able to post articles of interest or "Reply" or comment on posts already made, such as the posting about the Complete Prevention Plan for Aqautic Invasive Species.

Once registered, (allow one day for account activation) simply click "post reply" below to comment on the Complete Prevention Plan for Aquatic Invasive Species. All comments about the Complete Prevention Plan made on this site will be forwarded to the Aquatic Invasives Team, comprised of representatives of goernment agencies around Lake Superior.

[admin]

Comments from Lake Superior Binational Forum member Klaas Oswald of Sault Ste. Marie, ON:

Comments on the proposed Complete Protection Plan respecting Alien Invasive Species in Lake Superior.

Overall, the CPP is very impressive. I think it covers most of the bases. It is well organized and makes sense.
One criticism: I only heard about the CPP and the opportunity to comment by way of my being a member of the Lake Superior Binational Forum. I suspect that most people who have an interest in the ecology and/or economy of Lake Superior, either as a shoreline cottager, or angler or commercial fisher, municipal leader, marina operator, etc., have not heard of this initiative and thus have no opportunity to provide input.

I really like the recognition and recommended actions respecting the Items in Trade, on page 59. It is still easily possible to buy Purple Loosestrife, Himalayan Helmet Plant, and other invasive "flower garden plants". I strongly support the idea of creating lists of prohibited plants and other organisms. But, the trade in garden plants also involves hitchhiker organisms. In two successive years I had some kind of minnow or carp fish in my backyard flower pool, as the result of buying aquatic plants at a garden retailer. I suspect that eggs were attached to the roots of Water Hyacinth that I purchased. As many aquatic ornamentals have to be kept wet in order to be transported, I think this is another problem pathway of distribution. I would therefore suggest something in line with the concept of transport and sale only of "Certified Pathogen-Free through raising from seed" category for ALL non-native and native plants sold through garden centres and nurseries. Otherwise, hitch-hiker species will continue to move with cuttings and runners, which is a common method of propagation at this time.

Shoreline Habitat and Restoration, on page 59. I agree with the CPP on this. But, the Canadian Federal government is currently developing regulations under the Navigable Waters Protection Act that would remove the need for permits for shoreline work on what is being classed as "minor works", or on "minor waters". This is contrary to the recommendations in the CPP, where permits to work on shorelines are the means of education and conveyor of conditions to prevent AIS from being established. I am also opposed to the lack of permits under the new NWPA regulations due to other other aquatic habitat concerns, such as enabling the converting natural shore to artificial shore. Good luck in changing the regulatory climate in Ottawa at this time.

On page 59 is listed "Illegal Activities" particularly unauthorized introductions of fish and illegal import of baitfish. Everything written in these sections of the CPP is correct except for one thing: it does not address the root issue. As long as it is lawful to possess live aquatic bait (baitfish, leeches, crayfish, mayfly larvae), both those species, their attached (internal and external) pathogens, and hitch-hiker species in the carrying water will continue to be transported from one body of water to another and then released either on purpose or inadvertently. It is not a question of "import", as this is a concept that is based only on dotted lines on a map. It is really a question of movement into and within the Lake Superior basin. The root issue is the possession and transport of aquatic bait. When I was an Ontario conservation officer I retired recently after 37 years on the job) I observed that laws continued to be violated despite well-written regulations and a decent enforcement effort. It is my considered belief that regulations throughout the Lake Superior basin that permit the possession of live aquatic bait for personal use, will be used as a cover for import of them into the basin, and the transport of them within the basin. For instance, the current prohibition on movement of live baitfish out of part of southern Ontario to prevent the spread of VHS, is in my opinion only a minor holding tactic that will not work. Anglers will simply continue to baitfish in the affected area and transport them to their fishing areas farther north. The only solution is the prohibition on possession, sale, and transport of live aquatic bait, in every province and state that fronts on Lake Superior (and the other Great Lakes). There are many viable alternatives to live bait nowadays, the sport fishing industry has a whole range of artificial baits available to anglers.

Page 60, Sale and Distribution of Live Bait, is largely addressed in my paragraph above. The CPP calls for education, but I don't think that is good enough. Tradition always trumps change, therefore live-bait anglers will simply continue to use it and the new rules and regulations be damned. Also, commercial fishers including bait fishers and dealers are far more interested in making money in the short term, over following regulations and "best practices" suggestions that may cost them time and money. I am not impressed with the way the Ontario government obviously gave in to the Baitfish lobby in the VHS regulations. I believe that costs to the economy of Ontario, if VHS moved into the huge recreational/tourist fishery in northern Ontario would far outweigh the value of the baitfish industry in southern Ontario.

On page 61, the Chicago Ship Canal is discussed. In my considered opinion, the only way to prevent the spread of Asian carps through that canal is to bulldoze a permanent berm of 100 metres or longer in the canal. I have little faith in electrical barriers, there are too many "moving parts" to break. Despite the so-called fail-safe built into the electrical barrier, it will fail due to mechanical breakdown or human error at some point. Filling the canal for 100 metres, once it is done, provides no opportunity for misfunction or human error. I realize that this will prove costly in terms of the barge traffic between Lake Michigan and the Mississippi River system, but the costs to the Great Lakes, if carp breach the electrical barrier, would be much higher in the long run. Goods going through the canal will just have to be offloaded, trucked, and reloaded, but that would have to be the cost of doing business. Other sectors of the North American industry and economy also have to pay a price to be environmentally responsible.

Thank you for the opportunity to comment.

Klaas Oswald
Sault Ste. Marie, ON

[glen]

Re:

It is still easily possible to buy Purple Loosestrife, Himalayan Helmet Plant, and other invasive "flower garden plants". I strongly support the idea of creating lists of prohibited plants and other organisms. But, the trade in garden plants also involves hitchhiker organisms. In two successive years I had some kind of minnow or carp fish in my backyard flower pool, as the result of buying aquatic plants at a garden retailer. I suspect that eggs were attached to the roots of Water Hyacinth that I purchased.

We've observed the same in nursuries and had similar incident concerning pond plants when residing in Southern Ontario.
Thanks, Klaas, for sharing a thoughtful and constructive comment, including your thought (near end of your comment)of a possible solution to the urgent issue on invasive carp.
Glen

[glen]

Chicago area locks plan called inadequate Feb 9/10
http://www.twincities.com/outdoors/ci_1 ... source=rss

[bflind08]

The current thinking is that ecological separation of the Lake Superior and Mississippi River basin at the Chicago Sanitary and Shipping Canal should be a high priority for the United States Army Corp of Engineers. USACE will likely be the lead agency charged with development of a plan for this separation. Comments in Washingtron DC during Great Lakes Day (Feb 24th) discussion and lobbying recognized that this planning will present huge challenges including an ability to prepare for potential flooding that could impact the downtown area of Chicago.