An Invasive Alien Species Strategy for Northern Ireland

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1 An Invasive Alien Species Strategy for Northern Ireland Comments by Northern Ireland Environment Link 30 September 2011 Northern Ireland Environment Link (NIEL) is the networking and forum body for non-statutory organisations concerned with the environment of Northern Ireland. Its 55 Full Members represent over 90,000 individuals, 262 subsidiary groups, have an annual turnover of 70 million and manage over 314,000 acres of land. Members are involved in environmental issues of all types and at all levels from the local community to the global environment. NIEL brings together a wide range of knowledge, experience and expertise which can be used to help develop policy, practice and implementation across a wide range of environmental fields. These comments are agreed by Members, but some members may be providing independent comments as well. If you would like to discuss these comments further we would be delighted to do so. Prof Sue Christie, Director Northern Ireland Environment Link 89 Loopland Drive Belfast, BT6 9DW P: E: Sue@nienvironmentlink.org W: Northern Ireland Environment Link is a Company limited by guarantee No NI and a Charity registered with Inland Revenue No XR19598

2 Q1 - The Strategy actions have been developed on the basis that tackling these issues must involve a strong and broad partnership approach. Do you, or does your organisation support this principle? We support the principle of involving a strong and broad partnership in tackling invasive species. It is important to have a cross jurisdictional framework as invasive species do not recognise political boundaries. It is important that responsibility is not lost with so many parties involved and that the required actions are taken by each party. We would add that business and industry also need to respond to the challenge of invasive plants and animals, the cost of which, both economical and environmental, has increased dramatically in recent years. We agree that the partnership of a wide array of stakeholders is necessary to tackle the issue of invasive species. Q2 Do you support the scope of the Strategy? Are there any key action areas not being addressed and how might they be addressed within current resource constraints? We support the inclusion of non-native species arriving by their own means driven by climate change and displaying invasive characteristics in the scope of measures proposed in the strategy. Detection, surveillance, mitigation and control of these species will become increasingly relevant as climate change is expected to have an increasing impact on species distributions. We recognise that actions need to be prioritised in the current economic climate. Early detection and rapid response are essential in order to minimise the extent of the invasion. Early eradication saves money in the long run as the cost of eradication significantly increases if the invasive species becomes established. In light of the current economic climate and reduced funding to some eradication projects, we would suggest that better engagement of NGOs (e.g. Ulster Wildlife Trust, CVNI, National Trust), with volunteers who can carry out invasive alien control, should be sought. Providing a small amount of funding in this sector can potentially result in large benefits, as numerous volunteers can carry out much of the manual work as part of conservation projects. To get the most out of limited funds strategic infrastructure (e.g. Invasive Species Ireland website and conferences; integrated work across sectors on mobilizing volunteers, coordinated public awareness and activity campaigns) is essential and should be prioritised as cost effective methods of both awareness raising and delivering volunteer action. Q3 Section 3 - Do you support the objective and priority actions? Do you

3 We fully support the objective to minimise the risk of invasive alien species entering and becoming established in Northern Ireland and reduce the risks associated with the movement of species outside their natural range within Northern Ireland. We also fully support the priority actions to help achieve this objective. The introduction of subordinate legislation to prohibit the sale of species which present the highest risk should be implemented in a timely manner without unnecessary delay as species introduction and establishment of the invasive species can occur quite rapidly, especially aquatic invasive species. The priority action to consider mechanisms to control the import and possession of high risk invasive alien species at all points of entry is not strong enough; we need to consider and deliver mechanisms. The control of the import and possession of high risk alien species at all points of entry requires effective practical mechanisms put in place as early as possible We agree that information must be provided for the public on the threats of invasive alien species. Practical guidelines should also be provided informing the public how they can prevent invasive alien species entering and becoming established in Northern Ireland. The public should be encouraged to take responsibility and ownership for protecting the biodiversity that surrounds them. NIEL could help with education and awareness activities aimed at various target audiences. NIEL produces documents primarily targeted at Government (local assembly and civil service) and other environmental NGOs. NIEL produces documents that are circulated widely and the NIEL website receives approximately 10,000 unique user visits per month. NIEL also distribute press and media releases. NIEL works with the Environmental Educational Forum. Also, because we bring together many environmental organisations, we can help produce a co-ordinated approach to dealing with invasive alien species. Helping to coordinate action by NGOs is one of our key roles.. Q4 Section 4 - Do you support the objective and priority actions? Do you We fully support the objective to develop an effective mechanism for detection, surveillance and responding to invasive alien species, both new and established. We agree that an early warning system and rapid response system is crucial in fulfilling this objective. We support an early an integrated early warning system with the Republic of Ireland and the GB programme. Sufficient resources and training should be provided in order to gain the maximum value from active surveillance. This will lead to early detection and a better chance at eradication, which will ultimately result in economic savings in the long run.

4 We are in support of the development and implementation of a rapid response mechanism in the form of initiating eradication and containment measures before the species has spread beyond a limit that is eradicable. This is highly important as a lot of invasive species can spread very quickly. For example the invasive freshwater invasive bivalve Asian clam has r-strategy lifecycle traits such as high fecundity, early sexual maturation, short generation time and wide dispersal of offspring that allows it to invade and establish itself in new areas very quickly. Rapid response is critical in tackling invasive species that spread rapidly. We support the development and implementation of contingency and eradication plans for high risk species to aid a rapid response. We welcome the provision of clarity to organisations on roles and responsibilities and where support is available as this will make the process a lot more efficient. Northern Ireland Environment Link is involved in various activities relating to invasive species. NIEL analyses, critiques and advocates for improved policy and programmes, for example through involvement on Government working groups or through consultation response. NIEL sits on the Invasive Species Ireland group, services the Northern Ireland Biodiversity group and is represented on many of the Advisory Committees, for example, Strangford and Lough Neagh Lower Bann. NIEL is also secretariat to or is represented on the Freshwater and Marine Task forces. NIEL has profiled the Invasive Species website in their News section and links to the website appear on the NIEL website. This helps in creating more awareness of invasive species and could help increase the number of people reporting invasive alien species through passive surveillance. Q5 Section 5 - Do you support the objective and priority actions? Do you We support the objective of developing mechanisms to record, report and monitor invasive species. Knowing where these species are is essential for their control. This can most effectively be done through systems that allow easy, convenient and quick reporting of sightings of these species, and a tool kit as identified here would needed for aiding this. Maximum benefit can be achieved through using local groups, and they should be properly trained and equipped to monitor invasive species. NIEL can help support these actions by circulating information about monitoring schemes to our member Q6 Section 6 - Do you support the objective and priority actions? Do you have any suggestions or ideas for maximising the benefits to be gained from these actions? How can you or your organisation help through your specific

5 NIEL supports the objective and priority actions. Northern Ireland has suffered from a lack of proper management of invasive species (with the exception of nature reserves or other managed areas), and this should be a priority to prevent further spread and damage caused by these. Knowledge of management has already been gained in other countries, so we are in a position to use this experience to our benefit. Development of protocols for management should be completed as soon as possible, to begin to tackle constantly spreading invasive species. Much of the information needed for developing control protocols will be gained from organisations directly involved in invasive species control. As such NIEL can have a limited role here. However, we would welcome any enquiries that we could relay to our members who are more directly involved in invasive control. Q7. Section 7 - Do you support the objective and priority actions? Do you NIEL fully supports this objective and the priority actions identified. We welcome the fact that the management will involve work with key stakeholders. We recommend that this should include all relevant public bodies (e.g. NIEA) and environmental NGOs (e.g. Ulster Wildlife Trust and National Trust), and local community groups. We support the concept of local management area plans, which would allow local groups to have more control over invasive control. Materials such as the proposed online toolkit are likely to be of great use, but need to be properly communicated to the stakeholders. NIEL can help this by providing resources for the dissemination of such materials and other information, through our website, newsletters and other material. Q8. Section 8 - Do you support the objective and priority actions? Do you We support the proposed actions and offer assistance in coordination of voluntary sector input. Q9. Section 9. We support the proposals and priority actions. The importance of building partnerships especially around communication cannot be overestimated; clear, consistent messages which encourage appropriate action are required. Involvement of NGOs and community groups are vital for success.

6 Q10. Section 10. We support the need for an all-island approach supplemented by garnering best practice from elsewhere and harmonising relevant legislation across the UK and EU to try to halt invasions. The conflicts between free trade and biosecurity need to be addressed at the highest governmental levels to ensure that errors are not made in the interests of free trade that can be immensely costly to the environment and the economy. Intergovernmental work is required to address these issues. Legislation and development of guidance should proceed simultaneously to allow the most rapid introduction of effective changes. Q The review cycles and reporting proposals are acceptable for the Strategy itself. Much more frequent reporting on the individual species or issues may certainly be required within each period.. The need for research is vital to demonstrate the requirement for and cost effectiveness of action to control invasives.