Archived – Evaluation of Aquatic Invasive Species
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Project Number 6B080
September 16, 2008
Table of Contents
- 1.0 Executive Summary
- 2.0 Introduction
- 3.0 Observations and Recommendations
- 3.1 Relevance
- 3.2 Program Design and Delivery
- 3.3 Success
- 3.4 Effectiveness
- 3.5 Unintended Impacts and Risk
- 4.0 Management Action Plan
List of Acronyms
1.0 Executive Summary
Aquatic Invasive Species (AIS) are harmful aquatic species whose introduction outside of their natural range threatens the environment, economy and society. Introductions of AIS can result in damage to sensitive ecosystems, as well as fisheries, aquaculture, municipal infrastructure, tourism and other important industries.
In 2005-06, Treasury Board (TB) provided $20M in funding over five years to Fisheries and Oceans Canada (DFO) to initiate the development of an aquatic invasive species program ($10M) and to increase its contribution to the Great Lakes Fishery Commission (GLFC) for the management of sea lamprey on the Great Lakes ($10M). [Cabinet Confidence]
1.2 Objectives and Scope
For both the Sea Lamprey Control Program (SLCP) and the Aquatic Invasive Species Program (AISP) component, the evaluation assessed:
- The relevance in relation to DFO’s strategic outcomes and the Government of Canada’s priorities;
- The appropriateness of the design & delivery mechanisms;
- The extent to which the programs have been successful in achieving their objectives and expected results; and,
- For the SLCP only, the evaluation assessed the effectiveness of the program.
The evaluation was conducted at DFO Headquarters and in all regions and focused on fiscal years 2005-06 to 2007-08.
With respect to the SLCP, only the portion of the program related to DFO’s $8.1M annual allocation ($2M TB approved + $6.1M from DFO A-Base) to GLFC was considered in the evaluation and not the entirety of the GLFC programs.
1.3 Summary of Observations
AIS pose a threat to Canada’s commercial fisheries and aquaculture industry. Activities carried out to combat sea lamprey and other AIS help protect these important industries. In that regard, AISP and SLCP activities are aligned with DFO’s Strategic Objective of “Sustainable Fisheries and Aquaculture
1.3.2 Program Design and Delivery
There is no AISP governance framework in DFO, nor are there clearly defined accountabilities, roles or responsibilities. Thus far, DFO’s Science Sector has taken a de facto lead on the file mainly because of the need for scientific research on AIS. The evolving nature of the AIS file and it being more than just a science issue is such that there is a need for a lead to be identified and a clear governance structure to be established.
There is evidence to support that collaboration of AIS activities is underway through a variety of committees and organisations both internationally and within the Department. Some regions have established AIS committees whose membership includes representatives from different DFO sectors, other federal departments, industry, and other levels of government.
DFO staff is utilizing opportunities with provincial governments to maximize the work that can be done with limited funding.
DFO received $2M annually for AIS activities other than sea lamprey. The funding proposal was developed with no provision for Full Time Equivalents (FTE). Consequently, some of the $2M operating funds were converted to salaries resulting in a cost of 20% of the amount converted.
The SLCP as part of the GLFC has a well defined governance structure with clear roles and responsibilities for the Sea Lamprey Control Centre (SLCC). However, the SLCP has not been integrated with other AIS activities in DFO. There are also no formal strategic consultations between SLCC and DFO sectors on broader AIS issues.
The amount allocated to the GLFC is $8.1M annually. The financial arrangements call for DFO to fund 31% of the cost of the SLCP and 50% of the research and administrative costs related to sea lamprey and the GLFC.
Complexities exist around how the funding is disbursed. There is no direct transfer of DFO funds to the GLFC. Some funds are maintained by DFO to manage the SLCC, the amount of which is approved by the GLFC. The remaining funds are paid to the GLFC based on an invoice submitted by them. It was further noted that the program delivery agreement (PDA) between DFO and GLFC is activity based and not results based.
Some aspects of the PDA with GLFC also lacked clarity, in particular a reversionary rights clause on assets purchased by DFO and utilized by the SLCC to be returned to GLFC upon conclusion or cessation of the SLCP.
There is no analysis of the relative importance of sea lamprey over other AIS to justify the contribution of $8.1M for that species and much less for the remainder of the AIS.
From a Science perspective, DFO has achieved much of what it has set out to do with the limited resources that it received for AIS such as, funding to the Canadian Aquatic Invasive Species Network (CAISN) for research on pathways of introduction and factors affecting species establishment, funding allocated for research specific to each region, establishment of a Centre of Expertise for Aquatic Risk Assessment (CEARA), and risk assessments completed or in progress for 20 priority species.
Areas for improvement include the limited sharing of the results of CAISN research, lack of national priorities related to funding DFO’s AIS research proposal process, National Framework for Rapid Response, limited resources preventing CEARA from undertaking assessments on a number of key species, and need for socio-economic assessments to be conducted in conjunction with the biological risk assessments process. In addition, there is a weakness in sharing of information and knowledge.
A number of legislative and regulatory initiatives for AIS were initiated in 2007-08; however, more work is required to finalize the development of a regulatory and supporting policy framework for AIS.
The success of the SLCP is dependent upon an overall effort on the part of the GLFC and its agents, DFO and the United States Fish and Wildlife Service (USFWS). The success or failure of the program cannot be attributed to one party.
The GLFC annual reports indicate that, although significant effort has been made and continues in order to increase the effectiveness of control treatments and assessments, the SLCP overall is not reaching the targets established by the GLFC and Lakes Committees. In response to not meeting lake targets, treatment methods and approaches are reviewed and adjusted to increase their effectiveness and achieve better results.
Overall, the SLCC was effective in delivering its program. In addition to having an established governance structure, there is a high level of involvement of stakeholders in the management of the SLCP. These factors enhance the effectiveness of the program.The program regularly examines ways for improving its effectiveness and recently introduced new measures to make more effective use of resources through multitasking of assessment and control staff
1.3.5 Unintended Impacts and Risk
Some unintended impacts and risks related to the SLCP were identified during the evaluation and warrant consideration by the Department.
The team noted instances where the lampricide treatments of the SLCP may have had an impact on other species:
- The use of lampricide to control the sea lamprey has reduced populations of Northern Brook Lamprey around the Great Lakes. As a result, the Northern Brook Lamprey, which is not an AIS, is being considered for listing under the Species At Risk Act (SARA); and
- In April 2008, a large number of walleye were found dead on the shores of a river in New York State following a lampricide treatment by DFO staff. The cause has yet to be identified.
It is recommended that:
- The ADM, Science in partnership with the ADMs of Policy, Oceans and Habitat Management, and Fisheries and Aquaculture Management should propose a sectoral lead for the Deputy Minister’s approval to establish an appropriate governance framework for AIS within DFO [Cabinet Confidence]. A key role of the lead would be to undertake an integrated approach that engages key sectors to develop a long term strategic direction for AIS.
- The Assistant Deputy Minister, Science, in consultation with the Regional Director General, Central and Arctic Region, should review the appropriateness of the funding and other arrangements between DFO and the GLFC.
- The sectoral lead should conduct an analysis of the relative importance of all known aquatic invasive species (including sea lamprey) with a goal of establishing a priority ranking for resources and integrating sea lamprey into an overall DFO AIS strategy.
- The Assistant Deputy Minister, Science, should ensure that national priorities are established and communicated prior to the annual call for proposals for monitoring and research funding.
- The Assistant Deputy Minister, Science, should ensure that the AIS data base is used as a tool for communicating research activities, including those of CAISN, to DFO Science staff.
- The Assistant Deputy Minister, Policy, should expedite the development of the regulatory and policy framework for AIS by March 31, 2009.
- The Assistant Deputy Minister, Policy, in collaboration with the Assistant Deputy Minister, Science, should ensure that an overall risk analysis framework is developed and includes socio-economic assessments in addition to the current biological risk assessment process.
- [Cabinet Confidence]
In 2005, Treasury Board (TB) approved funding of $85 million over five years for government departments and agencies to initiate the implementation of priority actions of an Invasive Alien Species Strategy for Canada. Of this amount, $20 million was allocated to Fisheries and Oceans Canada (DFO), including $10 million to fulfill Canada’s international obligations to the Great Lakes Fishery Commission (GLFC) for the management of the Sea Lamprey Control Program (SLCP) with the United States. The remaining $10 million was allocated to address the other aquatic invasive species (AIS) in Canada. [Cabinet Confidence].
In 2004, an “Invasive Alien Species Strategy forCanada” was developed by federal-provincial-territorial (FPT) agencies and approved by Ministers responsible for forests, fisheries and aquaculture, wildlife, and endangered species. This Strategy seeks to minimize further introductions of invasive alien species through the use of risk management analyses and science-based techniques that inform decision making and assess and mitigate risks. The Strategy includes provisions for AIS.
To implement the Strategy for AIS, the Canadian Council of Fisheries and Aquaculture Ministers’ (CCFAM) Aquatic Invasive Species Task Group (AISTG), co-chaired by DFO and the Ontario Ministry of Natural Resources, developed “A Canadian Action Plan to Address the Threat of Aquatic Invasive Species”. This Plan identifies four priority implementation activities: legislation and regulation; risk management; stewardship, education and awareness; and science.
2.1.1 Aquatic Invasive Species Program
An investment of $10 million over five years was allocated to initiate the development of a national aquatic invasive species program consistent with “A Canadian Action Plan to Address the Threat of Aquatic Invasive Species”.
The long‑term objectives of the Aquatic Invasive Species Program (AISP) are to control the pathways by which AIS enter into Canadian waters and the spread of existing AIS. Funding was to address the highest priority areas:
- Prevention - Initiatives include enhancing research capacity and risk assessment capacity for pathways of invasion to facilitate policy and regulatory-based pathway management.
- Early Detection - Activities focus on establishing a coordinated national surveillance and monitoring network for high risk locations and pathways of introduction.
- Rapid Response - Activities focus on developing legal and regulatory authorities, including the supporting policy framework, for the management of aquatic invasive species in cooperation with the provinces and territories.
2.1.2 Sea Lamprey Control Program (SLCP)
The SLCP is managed by the Great Lakes Fishery Commission (GLFC) on behalf of Canada and the United States and was created as a result of the 1954 Convention on Great Lakes Fisheries between Canada and the US. The GLFC is responsible for coordinating fisheries research and implementing a program to minimize sea lamprey populations.The SLCP’s objectives are threefold:
- Determine the distribution and abundance of sea lamprey populations in the Great Lakes;
- Implement a control program to reduce sea lamprey populations to levels that will meet the fish community objectives for lamprey abundance and fish community damage as determined by interagency Lake Committees; and
- Develop alternatives methods of reducing lamprey populations that enhance program effectiveness.
DFO, on behalf of Canada allocates $8.1 million ($2M TB approved + $6.1M DFO A-base) to the GLFC in pursuit of these objectives as well as research activities coordinated by the GLFC, and program support and management costs of the Commission. DFO delivers its portion of the program from the Sea Lamprey Control Centre (SLCC) in Sault Ste. Marie (SSM), Ontario.
2.2 Objectives and Scope
There are two distinct components to the AIS approach in DFO, the SLCP and the remainder of the AIS activities under AISP. The evaluation approach undertaken took into consideration the different levels of maturity of the two components, so as to provide a fair and equitable assessment of the SLCP and AISP. The evaluation assessed:
- The relevance of both components in relation to DFO’s strategic outcomes and the Government of Canada’s priorities;
- The appropriateness of the design & delivery mechanisms for the two components;
- The extent to which both components have been successful in achieving their objectives and expected results; and,
- For the SLCP only, the evaluation assessed the effectiveness of the program
The evaluation was conducted at DFO Headquarters and in all regions (through on-site visits and/or electronically and focused on fiscal years 2005-06 (time of TB funding) to 2007-08. However, the evaluation also examined activities prior to 2005-06 to determine a base from which to assess the progress being made with the new funding.
This evaluation was limited to AIS activities carried out by DFO. Other departments/agencies who received funding for AIS initiatives are responsible for conducting their own evaluation and independently reporting back to Treasury Board Secretariat.
In regard to the SLCP, the scope of the evaluation was limited to the results of DFO activities related to the $8.1 million annual allocation by DFO to the GLFC and not the entirety of GLFC programs.
A framework was developed to guide the evaluation and addressed the objectives outlined in Section 2.2 of this report.
An evidenced-based approach to the evaluation was undertaken, whereby conclusions and recommendations are based on objective, quantitative and documented evidence to the fullest extent possible.
A multiple lines of evidence approach was used for the evaluation and included:
- Review of departmental files and program documentation;
- Interviews with DFO’s headquarters and regional staff;
- Interviews with representatives of provincial governments;
- Interviews with representatives of the GLFC;
- Interviews with research partners (e.g., University of Windsor);
- Review of relevant national and regional databases (e.g., performance measurement information); and
- Review and analysis of information collected.
Limitations in Methodology
An AISP performance measurement strategy was developed in 2005 as part of a Results-Based Management and Accountability Framework (RMAF) but was never formally implemented. As a result, there is no formalized performance measurement strategy in place to track and report on the effectiveness of the activities undertaken.
The evaluation did not examine the activities of other federal departments as their activities are subject to their own evaluations.
Another limitation in the methodology stems from the fact that DFO activities represent only one component of the Sea Lamprey Control Program. The evaluation had no authority or mandate to explore matters beyond what was related to the allocation of $8.1 million that DFO makes to the GLFC. Identifying the DFO component of joint DFO/United States Fish and Wildlife Service (USFWS)/GLFC activities was a significant challenge to the evaluation team.
3.0 Observations and Recommendations
The evaluation assessed the relevance of both components in relation to DFO’s strategic outcomes and the Government of Canada’s priorities.
3.1.1 Linkage to Strategic Priorities
Significant evidence exists to support the linkage of AIS to DFO’s mandate and strategic priorities. AIS are formally identified as a sub-activity of Science within DFO’s Program Activity Architecture (PAA) structure, linked to the strategic outcome of “Sustainable Fisheries and Aquaculture”.AIS is one of ten research priorities identified in DFO’s five year research agenda for 2007-2012 recognizing that Aquatic Invasive Species (AIS) are one of the leading threats to aquatic biodiversity and ecosystem health.
3.1.2 Federal Role
The federal government has been involved with AIS since 1955 when the GLFC was established in the Great Lakes area. Canada officially recognized AIS as a priority in the 1995 Canadian Biodiversity Strategy. In 2004, the “Invasive Alien Species Strategy for Canada” restated the government's primary goal of preventing the introduction of aquatic invasive species.
Federally, DFO is the lead for aquatic invasive species and is responsible for the conservation and protection of fish and their habitat. DFO also has the responsibility of performing scientific research and providing scientific advice to Transport Canada in connection with ballast water regulations and standards. The provision of such advice is critical given that ballast water has been identified as one of the main vector or pathway in which AIS are entering Canada.
Within the federal government, primary responsibility and authority for AIS rests with DFO, but, depending on the species and its pathway into Canadian waters, management actions can also involve other government departments such as Environment Canada (EC) and Transport Canada (TC).
3.1.3 Public Interest
AIS are a significant public interest issue to Canadians given the potential destructive impact on habitat and native biodiversity. The fact that Canada is home to 20 per cent of the world's fresh water and has one of the world's longest coastlines means it is at significant risk for AIS.
Provincial and territorial governments share the responsibility for AIS, as do organizations such as the International Joint Commission and the GLFC. Industry, a variety of Non-governmental organizations (NGOs), Aboriginal peoples and the general public are also involved.
3.2 Program Design and Delivery
The evaluation examined the appropriateness of the program design and the delivery mechanisms in place for the AISP and the SLCP.
When DFO initiated the AISP in 2005-06, a formal governance framework was not established. The RMAF developed for AISP when funding was being requested indicated that accountability for program delivery would be shared between the DFO Science and Policy Sectors. The evaluation found that, with the exception of some regional involvement, the Policy Sector has not taken on a formal governance role with respect to AIS. Rather, due to the large focus on science, the Science Sector assumed the lead on the AIS file, with the research and monitoring aspects of the program being governed via existing science management structures within the department. The absence of an AIS governance framework has impacted areas such as:
- defining clear roles/responsibilities and accountabilities;
- performance measurement and reporting;
- strategic direction/oversight;
- priority setting;
- overarching regulatory/policy development; and
- effective coordinating/sharing of information among sectors/regions.
AIS issues are generally addressed through the national meetings of Regional Directors, Science, as there is currently no DFO specific AIS committee in place to discuss issues on a national scale.
Now that scientific research on AIS has been conducted, the information should be used to develop policy and support management action. It is imperative that ongoing leadership be established to ensure an integrated approach and strategic direction that engages all key sectors and continues to build on the knowledge acquired thus far. Science, Policy, Oceans and Habitat Management and Fisheries and Aquaculture Management sectors all have a role to play in the development of a long term strategy for AIS. However, future action and leadership should reside within a sector responsible for managing issues impacted by AIS.
There was no consensus among those interviewed as to what sector should be the lead for AIS. Some suggested that because of the intersectoral requirements of AIS, the Policy Sector might be the best place for it to reside. Others indicated that Oceans and Habitat Management Sector might be appropriate given the integrated approach to oceans management as well as the potential habitat implications of some AIS.
From a program delivery perspective, a management decision is required to determine which sector is in the best position to assume the lead and undertake an integrated collaborative approach to AIS.
The SLCP is managed by the GLFC, an organization established as a result of the 1954 Convention on Great Lakes Fisheries between Canada and the United States. A governance structure is well defined for DFO’s role with the SLCP.
The GLFC is comprised of eight Commissioners, four from Canada and four from the US. Two of the Canadian Commissioners are from DFO. Canada and the United States each have one vote and all decisions must be unanimous. The Great Lake Fisheries Commissioners make decisions based on advice received from a variety of GLFC committees and working groups, such as the Sea Lamprey Integration Committee and the Program Integration Working Group. DFO is represented on each of these committees and groups tasked with managing the SLCP.The roles and responsibilities for the SLCP stem from the mandate of the GLFC and DFO’s roles and responsibilities in regards to the SLCP are clear. Staff of the SLCC in SSM report functionally to the GLFC and have a line relationship within DFO through the Regional Director of Science in DFO’s Central and Arctic Region.
Despite the lack of a formalized program structure, collaboration on AIS activities is underway through a variety of mechanisms. For example, DFO represents Canada internationally as a member of the North Pacific Marine Science Organization (PICES) and the International Council for the Exploration of the Sea (ICES) which are scientific organizations established to promote and coordinate marine research amongst member countries.
The AISTG that was initially established to develop the Canada Action Plan for AIS was intended to terminate in 2007. In 2007, CCFAM decided to establish it as a permanent sub-committee of CCFAM called the National Aquatic Invasive Species Committee (NAISC). It is an inter-jurisdictional committee co-chaired by DFO’s Science Sector and the Ontario Ministry of Natural Resources and includes representatives from federal/provincial/ territorial governments. Terms of Reference (ToR) have been developed outlining the mandate of this committee, however, the committee is more of an information sharing forum than a decision making body.
In an attempt to increase collaboration on AIS issues at a regional level, Newfoundland and Labrador, Gulf, and Pacific regions have established regional AIS committees where membership includes representatives from different sectors within DFO, other federal government departments, provincial governments, industry, educational institutions, and other stakeholders who have a vested interest in AIS. These committees provide a forum for exchanging information and best practices related to AIS.
The focus on AIS science research has meant that until now, there has been a limited need to collaborate among sectors in DFO. While collaboration does occur as required, the Department is now becoming involved in activities that go beyond scientific research and there is an increased need for integration and involvement of other DFO sectors. The degree of involvement or the associated roles and responsibilities have yet to be defined.
AIS issues are extremely complex and involve a wide variety of stakeholders, including governments industry sectors, and NGOs. Effective leadership and coordination are imperative for success, as they serve to reduce overlap and duplication and focus efforts on the most important tasks. Within each DFO region, there is strong evidence to support collaboration with provincial and industry counterparts; however a gap continues to exist on a broader national level as there is no coordinating lead identified within DFO for AIS.
While formal interactions with the SLCP and other sectors are not in place, ad hoc collaboration occurs in a manner similar to other programs. SLCC staff consults Habitat Management Branch regarding permits and construction of barriers for sea lamprey control, however, collaboration between SLCC and other DFO sectors was not readily evident. There is little interaction between the SLCC and DFO HQ on issues related to AIS and the activities of the SLCC are not part of an integrated AIS strategy within the Department.
The SLCC operates independently with little interaction outside of the GLFC or Science Sector. The division manager responsible for the SLCC sits on the C&A Region’s Science management committee and has a line reporting relationship to the Regional Director, Science. It is through this committee that the SLCC manager interacts with his colleagues from other parts of Science. In June 2007, a C&A Regional AIS Strategic Workshop was held to identify current AIS activities, look for gaps, rank priority activities and develop a work plan for undertaking these activities. The Division Manager of the SLCC, under the direction of the Regional Director, Science, was the project leader for this event.
Given the nature of the activities carried out by the SLCC, in particular the treatments and their potential impacts on other species and habitat, it would be prudent to maintain close working arrangements with other sectors in the Department. In addition, as the SLCC has been dealing with an AIS (sea lamprey) since the 1950s, lessons learned (both good and bad) could be shared with sectors as well as contribute to the development of the AIS program.
3.2.3 Financial Arrangements
The financial arrangements for the AISP and the SLCP are managed as two distinct allocations of funds by HQ and the C&A region and therefore, the two components are discussed separately in this section.
Beginning in 2005-06, DFO received $2M annually in operating funds to implement a national aquatic invasive species program consistent with “A Canadian Action Plan to Address the Threat of Aquatic Invasive Species”.The funding was directed to scientific research and monitoring of AIS activities, as well as the development of risk and regulatory frameworks. Prior to 2005-06, DFO had been allocating approximately $1.9M annually in resources towards AIS. The evaluation team was unable to validate the source or nature of this funding.
When the funding proposal was developed for 2005-06 and beyond, a management decision was taken not to request Full Time Equivalent (FTE) positions in order to increase the amount of operating dollars available for the program. This decision was based on the assumption that existing staff would be able to take on the added workload for AIS. The lack of FTEs and salaries, has led to the inefficient practice of converting operating funding to salaries resulting in a cost of approximately 20% of funding for employee benefits, ultimately resulting in less funding to undertake AIS activities.
Given the limited capacity to deal with AIS, DFO staff is utilizing opportunities to work with provincial governments in order to maximize the results that can be achieved. For example, in the BC interior, DFO staff is working with the province to develop a strategic approach to dealing with spiny ray fish. In addition, on Prince Edward Island, DFO and its provincial counterparts work closely in the battle against tunicates.
DFO is required to fund 31% of the SLCP (equivalent to cost of operation of the SLCC in SSM) and 50% of related research, and administrative functions of the GLFC. This percentage was established by the GLFC in the early years of the program and is based on the historical value of the Canadian commercial fisheries and the geographic area in Canada of the Great Lakes.
The amount of funding that DFO provides to the GLFC is not specified in the Great Lakes Fisheries Convention Act but is based on the cost of the program as determined by the GLFC. We understand that the size of the program is based on the funding that the United States and Canada provide and presumably if less funding was available then the level of effort of the program would be reduced accordingly.
Since 2005-06, the amount of DFO funding to the SLCP and GLFC has been $8.1M annually. The funding arrangement between DFO and the GLFC is based on an annual Program Delivery Agreement (PDA) that specifies which activities DFO will carry out and how much they will cost.
Complexities exist as a result of the funding arrangement with the GLFC. The arrangement is such that DFO retains funds to cover SLCP expenses (control and assessment activities for $5.2M in 2007) at the SLCC in SSM and is invoiced for the balance ($2.9M in 2007 for research and administration) of $8.1M by the GLFC. Any funds not spent for control and assessment activities revert to the GLFC for research and administration.
In the United States, their portion of the funding is submitted directly to the GLFC who contracts with the USFWS to carry out the SLCP under its jurisdiction. DFO could utilize an instrument such as a Contribution Agreement (CA) with the GLFC. The CA could clearly lay out the method of transferring funds to the GLFC and also identify the expected results from the $8.1M contribution. The CA would allow DFO to transfer the funds relating to research and administrative activities directly to the GLFC and retain the remainder of the $8.1M to pay for the operation of the SLCC in SSM. The operation of the SLCC would be considered an in-kind contribution to the GLFC and be specified in the CA.
In 1989, the “Report of the Evaluation of the Great Lakes Fishery Commission” by a Canada-US evaluation team raised the funding issue and recommended that:
“… All funds appropriated by Parliament to cover the Canadian contribution for GLFC should go directly to GLFC who may then contract with whomever to carry out the control.”
A direct contribution arrangement would simplify accounting and management of funds and would provide an opportunity to identify expected results from the funding that DFO provides to the GLFC.
The terms of conditions of the PDA with the GLFC also includes a clause that states that “…GLFC will retain a reversionary interest in property and equipment obtained under this agreement”. It is not clear what property and equipment this refers to or what may have to be turned over to the GLFC should the clause in the agreement be enforced. This issue was raised with the C&A Regional Finance staff who was also uncertain of the implications of this clause.
DFO spends substantially more on managing sea lamprey than on all of the other AIS combined. Sea lampreys are subject to an international agreement to combat them, while the others are managed on an ad hoc basis at the regional level.
The evaluation team found no evidence of any overarching analysis of the relative importance of one AIS compared to others, yet the Government of Canada has been contributing to the GLFC for over 50 years for the management of the sea lamprey. Given the growing number of aquatic invasive species being identified and the limited resources to manage them, funding should be allocated to those species being of the highest risk and having the greatest impact on Canadians. (Any reallocation of funds would have to take into consideration the implications of Canada’s obligations under the Great Lakes Fisheries Convention Act with respect to its commitment to sea lamprey management. The TB decision of allocating $2M annually to the SLCP and $2M to the rest of the AIS must also be respected.
3.2.4 Opportunities for Partnership
The complex inter-jurisdictional nature of AIS would make it difficult to transfer, in whole or in part, responsibilities to the private/voluntary sector. However, there is evidence to support that both the federal and provincial governments are already collaborating and partnering with various organizations to fight AIS. For example, the Ontario Federation of Anglers and Hunters (OFAH) has been partnering with the Ontario Ministry of Natural Resources since 1992 on an “Invading Species Awareness Program”. These organizations do a great deal of work, independent of DFO, on the Great Lakes.
For the SLCP, the Great Lakes Fisheries Commission and the Sea Lamprey Control Centre operate in concert with Provincial and State governments, academic institutions, private sector and NGOs. Ontario Ministry of Natural Resource and Ministry of Environment, OFAH, Fisheries Associations, Universities and First Nations are consulted regularly and provide input through participation on various GLFC committees.
GLFC and SLCC have investigated having some activities performed by private sector such as barrier construction and assessments. Time and effort was required by staff to ensure compliance with procedures and quality of work. The approach did not yield the anticipated cost savings and was not pursued over the long term.
- The ADM, Science in partnership with the ADM of Policy, Oceans and Habitat Management, and Fisheries and Aquaculture Management should propose a sectoral lead for the Deputy Minister’s approval to establish an appropriate governance framework for AIS within DFO [Cabinet Confidence]. A key role of the lead would be to undertake an integrated approach that engages key sectors to develop a long term strategic direction for AIS. The following are some areas that should be considered for the sectoral lead:
- defining clear roles/responsibilities and accountabilities;
- developing and implementing performance measurement and reporting;
- providing strategic direction/oversight;
- setting priorities;
- initiating overarching regulatory/policy development; and
- providing effective coordinating/sharing of information among sectors/regions.
- The Assistant Deputy Minister, Science, in consultation with the Regional Director General, Central and Arctic Region, should review the appropriateness of the funding and other arrangements with the GLFC. The following should be considered:
- the mechanism for transferring the funds to the GLFC;
- incorporation of clear and measurable results as part of a funding agreement;
- clarification of the reversionary rights clause in the PDA regarding property and equipment obtained under the agreement; and
- the suitability and related risk of DFO staff conducting treatment and assessment activities in the United States (see section 3.5).
- The sectoral lead should conduct an analysis of the relative importance of all known aquatic invasive species (including sea lamprey) with a view to establishing a priority ranking for resources and integrating sea lamprey into an overall DFO AIS strategy.
Success is based on the extent to which progress has been made in implementing the program and achieving the expected results. A performance measurement strategy was developed in 2005 as part of the RMAF for AIS but was never formally implemented. As a result, there is no formalized performance measurement strategy in place to track and report on the success of activities undertaken for AIS.
In accordance with the funding provided, DFO has undertaken research related to pathways of introduction, factors affecting species’ establishment, ecosystem impacts and mitigation methods. These research activities are being undertaken through a contribution agreement with the Canadian Aquatic Invasive Species Network (CAISN). CAISN is made up of specialists from academia, government, industry, and non-government organizations.
Starting in 2006/07, DFO is contributing $1M over five years to assist CAISN undertake AIS research. This research is directed at the identification and quantification of vectors and pathways that spread AIS to and within Canada as well as the assessment of factors that affect the establishment of AIS. In addition, CAISN is also undertaking aspects of risk assessment modeling of AIS. Most DFO staff interviewed was unaware of the research work being undertaken by CAISN, an indication that effective communication mechanisms are not in place. While DFO staff directly involved with CAISN have in-depth knowledge of its activities, the information is not filtering down to all DFO staff involved in AIS activities. As AIS research activities are also carried out within DFO, there is a risk of duplication of effort not only between DFO and CAISN but among DFO regions themselves.
Each year, funds are allocated to DFO regions to conduct research on AIS issues specific to each region, based on proposals received. As part of the annual funding process for research projects, priorities are identified after proposals for funding have been submitted. The identification of research priorities prior to the call for proposals would be a more effective practice allowing for a more targeted approach to proposal development.
There are a number of research projects underway in a number of regions on ballast water exchange management which is a priority research area due to ballast water being one of the main vectors responsible for the introduction of AIS into Canadian waters. The AIS database, which is not yet operational, is one tool which may help communicate research findings among program staff and raise awareness of the types of research that is underway to reduce risk of research duplication.
In accordance with funding provided, DFO was to establish an early detection monitoring program for high risk pathways, species, and geographic locations. DFO regions are working together on a zonal basis (Atlantic, C&A, and Pacific) to implement monitoring protocols which involve the use of collector based surveillance/monitoring programs in high risk areas. In some regions however, AIS is an emerging issue with no baseline data available on which to base a monitoring program. As a result, monitoring processes are more survey based and geared to gathering baseline data which will be used for future decision making.
In addition to surveying and sampling, DFO regions have also initiated monitoring programs involving community groups and stakeholders. These activities help raise awareness of AIS and allow community groups and stakeholders to play an important role in detecting and tracking the spread of AIS.
Rapid Response is the capacity to quickly respond to an invasion in cases where prevention (of the invasion) fails. Normally, eradication is the primary goal. Other management options include containment of the population, suppression to keep its numbers below an economic or ecological threshold or slow its spread, or living with the effects of the species. It is important that every stage of a rapid response include clear lines of authority and responsibility for funding, as well as a communication strategy which is a critical step in the process.
To date, little work has been undertaken with respect to rapid response activities, mainly due to this activity not being funded in DFO. DFO has piloted a proposed National Framework for Rapid Response to Aquatic Invasive Species for Tunicates in Prince Edward Island however the framework has yet to be formalized. There continues to be uncertainty surrounding where responsibility lies for this activity.
[Cabinet Confidence] risk assessment activities to be undertaken included the development of a science-based risk assessment model and the completion of risk assessments for priority pathways and species.
In response to the TB requirements, DFO established the Centre of Expertise for Aquatic Risk Assessment (CEARA) in 2006. The mandate of CEARA is to develop national standards for, and to provide guidance on, scientifically defensible biological risk assessments for AIS. CEARA is also responsible for identifying risk assessment priorities and tracking national risk assessments to provide science advice related to healthy and productive aquatic ecosystems and sustainable fisheries and aquaculture.
Since its inception, CEARA has accomplished a number of activities that are consistent with its mandate, including:
- establishing national guidelines for evaluating the risk to biodiversity of introducing aquatic non-indigenous organisms into a new environment;
- completing risk assessments and biological synopses on 11 species with 9 more in progress;
- establishing a framework to identify priority pathways and species for funding purposes; and,
- identifying six Risk Assessment Priorities 2007/08 which could not be undertaken due to limited funding.
CEARA is currently in the process of developing a rapid assessment protocol to identify highest risk pathways and species for advice or screening purposes. This rapid assessment protocol is targeted for completion in 2008-09.
The role of CEARA in risk is limited to biological risk assessments. There is little evidence to indicate that progress is being made from a socio-economic assessment perspective. When funding for AIS was approved in 2005-06, no funds were allocated for the completion of economic impact analyses. As a result, only limited activities have been undertaken to date, and a risk analysis model which takes into consideration both biological and socio-economic factors has not been developed.
The authorities for AIS activities are not clear. The need for a national regulatory framework for AIS was first identified as a requirement in the Canada Action Plan for AIS.
DFO initiated work on the development of a national Regulatory Framework for AIS in 2007-08. (Funding was provided for 2005-06 and 2006-07 but it is not clear what activities were undertaken). Once completed, it is expected that the framework will identify the most effective legislation, regulations, and policies to control AIS in Canada in the context of different regional requirements and AIS pathways.
As a first step, DFO initiated a review of federal, provincial, and territorial legislation, regulations and policies that currently exist to control AIS in Canada. This initial work also included the identification of gaps and duplication in the existing tools for dealing with AIS. The results of this review are currently being finalized.
The next steps will include an intergovernmental workshop to be held during 2008/09 to discuss the findings of the review and to recommend options for addressing the current gaps and duplications. Following the workshop, the regulatory framework will be mapped by identifying the best tools for each AIS pathway and region in Canada. These recommendations will be based on the unique regional needs across Canada, and will also incorporate the best approaches taken by other countries. Final recommendations should be available in 2009.
It is expected that DFO’s authority for all AIS will be further enhanced with the enactment of a new Fisheries Act.
The success of the SLCP is dependent upon an overall effort on the part of the GLFC and its agents, DFO and the USFWS. The success or failure of the program cannot be attributed to one party. This evaluation examined only the contribution of $8.1M that DFO made to the GLFC and not the entire SLCP. Any attempt to provide an assessment on the success of the overall SLCP would be outside the scope of this evaluation. Nevertheless, there are some areas that the evaluation can comment on and provide the status of progress made in achieving the expected outcomes for the program.
Activities for the SLCP, including lampricide applications to eradicate sea lampreys is undertaken under the assumed authority of the Great Lakes Fishery Convention Act which authorizes the GLFC to “formulate and implement a comprehensive program for the purpose of eradicating or minimizing the sea lamprey populations” in the Great Lakes. As stated previously, DFO's authorities for sea lamprey (and other AIS) will be further enhanced with the enactment of a new Fisheries Act.
As a result of additional funding provided by DFO, control and assessment activities have increased and resources are now being utilized more efficiently. Furthermore, alternative control techniques, such as the Sterile Male Release Program in St.Mary's River have been established, and implementation of a pheromones treatment approach is expected in the next few years. These two new approaches would allow the SLCP to use alternatives to pesticide for control and eradication of the sea lamprey. The additional funding has permitted the GLFC to invest in research on these approaches leading to their implementation sooner than would otherwise have been possible.
The SLCP has demonstrated successful collaboration among governments, stakeholders and academia since its inception in 1955 and a noted decrease in sea lamprey populations has occurred. Interviewees and documentation reviews indicate that the abundance of sea lamprey has decreased by 90% to about four hundred thousand today throughout the five Great Lakes. Most of the reduction took place in the early days of the SLCP and the challenge in recent years has been to maintain and further decrease the sea lamprey population levels.
The GLFC, in consultation with scientists and technical experts, and upon advice of individual Lake Committees has established measures and targets for the SLCP. Measures for success include targets for desirable or maximum number of sea lamprey in each Great Lake, acceptable lamprey wounding rates on host species and rehabilitation of lake trout populations.
Review of GLFC annual reports indicate that although significant effort has been made and continues in order to increase the effectiveness of control treatments and assessments, sea lamprey populations and wounding rates remain above targets in all lakes. The SLCP overall is not reaching the targets established by the GLFC and Lake Committees.
Lake Ontario is the only lake where sea lamprey are fairly stable, hovering near the established targets. In response to not meeting lake targets, treatment methods and approaches have been reviewed and adjusted to increase their effectiveness and achieve better results. Because the SLCP is a joint undertaking between DFO and USFWS, failure to achieve targets can not be solely attributed to DFO.
Effectiveness is defined as the extent to which a program is achieving its desired outcomes. This section discusses the effectiveness of the SLCP. It was considered pre-mature to include the overall AISP as dedicated funding has not been in place for a sufficient amount of time to allow for an appropriate assessment of the achievement of desired outcomes.
GLFC, SLCC staff, and DFO management are continuously reviewing operations to increase productivity and to better achieve expected results. Recent changes to operations have been instituted as a result of an Evaluation and Efficiency exercise requested by GLFC and have resulted in changes addressing inefficiencies and leading to overall cost savings for the SLCP allowing the program to achieve a greater number of activities.
One key improvement that has taken place in the DFO component of the SLCP operations is the multi-tasking of the assessments and control crews at the SSM location. In the past, these activities were very distinct and the crews were specialized in each area. During the past year, crews were cross-trained and can now participate in each others’ activities while optimizing the use of their time.
DFO as an agent of the GLFC contributes significantly to the delivery of the SLCP which ultimately leads to the achievement of the GLFC’s objectives. DFO’s objective is primarily to deliver an assessment and control program on behalf of the GLFC. While there are some issues around how the financing of DFO’s operations is handled (discussed in section 3.2.3 of this report), how DFO delivers its component of the overall program is considered to operate in an effective manner.
3.5 Unintended Impacts and Risk
In putting in place most initiatives or programs, there are inevitably events or situations (positive or negative) that occur that were not anticipated. Following are a number of unintended impacts that were identified during this evaluation:
- Although staff at the SLCC and the GLFC consider the impacts of sea lamprey treatments on other fish species as negligible, the evaluation team noted some examples where the lampricide treatments did have an impact on other species.
- The Northern Brook lamprey, a native species and not an AIS, is currently being considered for listing under the Species At Risk Act (SARA). The lampricide used to control sea lamprey has reduced the Northern Brook lamprey populations in habitat areas where the two species co-exists.
- At the beginning of the treatment season in April 2008, an incident occurred following a treatment in Sandy Creek in New York State. Between 1,000 and 1,500 Walleye were found dead on the shores of the creek. It has not been determined whether the deaths occurred as a result of the lampricide treatment or if there were other contributing factors.
- Since 1972, DFO, on behalf of the GLFC, have been conducting pesticide treatments on lakes and streams in New York State. The practice began as a way of addressing staffing shortfalls at the USFWS and continues to this day. The evaluation team was not able to ascertain whether a risk assessment of this activity has been done to address possible liabilities to the Department. It should be noted that the USFWS does not conduct pesticide treatment in Canada.
4.0 Management Action Plan
|Recommendations||Management Action Plan||Status Report Update|
|Actions Completed||Actions Outstanding||Target Date|
1. The ADM, Science in partnership with the ADM of Policy, Oceans and Habitat Management, and Fisheries and Aquaculture Management should propose a sectoral lead for the Deputy Minister’s approval to establish an appropriate governance framework for AIS within DFO [Cabinet Confidence]. A key role of the lead would be to undertake an integrated approach that engages key sectors to develop a long term strategic direction for AIS. The following are some areas that should be considered for the sectoral lead:
Science Sector to make a presentation to the departmental senior management Policy Integration Committee (PIC) on program management.
Science Sector to distribute a memo to DMC to establish a management committee.
Science Sector to chair and organize AIS program management committee first meetings.
AIS program management committee to develop an option paper and make recommendation to the DMC on program lead.
DFO AIS sector lead to develop program governance framework to provide strategic direction, program priorities and to initiate regulatory and policy development.
Presentation made to PIC.
2. The ADM, Science, in consultation with the Regional Director General, Central and Arctic Region, should review the appropriateness of the funding and other arrangements with the GLFC. The following should be considered:
Science Sector to organize a meeting with SLCC and Departmental Finance Directorate to look at DFO’s funding options.
ADM Science to organize a conference call with C&A RDG to explore funding mechanisms for collaboration with GLFC.
Science Sector, in collaboration with SLCC to discuss the incorporation of a more specific set of results in future funding agreements.
Science Sector, in collaboration with departmental program lead and C&A region to develop a revised program funding agreement to clarify the reversionary rights clause and to confirm the departmental position related to the ability of DFO staff to conduct activities in the United States.
3. The sectoral lead should conduct an analysis of the relative importance of all known aquatic invasive species (including sea lamprey) with a goal of establishing a priority ranking for resources and integrating sea lamprey into an overall DFO AIS strategy.
To be addressed once sectoral lead is identified.
4. The ADM, Science, should ensure that national priorities are established and communicated prior to the annual call for proposals for monitoring and research funding.
Science Sector, in collaboration with the departmental AIS management committee and if possible the program lead will develop a clear set of priorities prior to the annual call for funding proposals.
5. The Assistant Deputy Minister, Science, should ensure that the AIS data base is used as a tool for communicating research activities, including those of CAISN, to DFO Science staff.
Science Sector, in collaboration with program lead analyse and develop a formal training program for HQ & regional staff involved in AIS program on how to operate the existing database.
Science Sector to consider the possibility of hiring students or contractor to update the national AIS database and set up an updated version.
Science Sector to ensure that AIS existing database is updated.
6. The ADM, Policy, should expedite the development of the regulatory and policy framework for AIS by March 31, 2009.
The requirement for intergovernmental and interdepartmental cooperation will be key in determining whether we can achieve an agreed-upon, integrated solution in this timeframe. Policy Sector is committed to delivering on the draft regulatory framework, and will attempt to expedite the framework to March 31, 2009.
The supporting policy work will need to be coordinated across sectors in DFO, inter-departmentally and inter-governmentally.
In 2007-8, LRA contracted for: a review of existing and proposed authorities for managing AIS; process mapping for dealing with AIS (including rapid response); a gap analysis of legislative and regulatory mechanisms for AIS management; and, proposed measures to address those gaps.
Completion of a federal legislative and regulatory framework for AIS.
Initial: March 2010
7. The Assistant Deputy Minister, Policy, in collaboration with the Assistant Deputy Minister, Science, should ensure that an overall risk analysis framework is developed and includes socio-economic assessments in addition to the current biological risk assessment process.
Policy Sector will develop a business case, in consultation with Science Sector and the AIS Sectoral Lead that will identify priority areas of AIS economic research such as risk assessment, in line with the Departmental Science Program and with overarching DFO priorities.
The business case will identify the highest priority, maximum value-added analyses to support the Department’s Aquatic Invasive Species Program. This business case will be key to addressing this gap in the next Memorandum to Cabinet.
A draft literature review on socio-economic risk assessment models has been completed.
An ad hoc working group (Policy Sector representatives from Pacific, Central&Arctic, Gulf, and Quebec Regions) has been operating for more than a year.
Liaison has been established with the Province of Alberta regarding its integrated AIS risk assessment framework.
The following tasks can be identified for completion this year:
8. [Cabinet Confidence]
To be addressed once sectoral lead is identified.
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