I Fisheries and Oceans P?ches et Oceans Canada Canada Daniel Callej a Crespo Director General DG Environment European Commission B-1049 Brussels Belgium Dear Mr. Crespo: This letter is to inform European Union (EU) authorities of the serious concerns the United States and Canada have with the risk assessment used to support Sweden?s proposal, dated January 18, 2016, to include the Species Homarus amerz?canus on the EU list of invasive alien species (IAS). With our huge freshwater resources and extensive coastlines, the United States and Canada are especially vulnerable to the threat of aquatic IAS. With this understanding, we share Sweden?s, and the as a whole, concern on the introduction and spread of IAS. We also trust there is a shared acknowledgement of the need for supporting scienti?c evidence to guide govemments? efforts to address this threat. We wish to stress the need for any measure intended to curb the introduction and spread of IAS to be based on robust, peer-reviewed science, and to be no more restrictive on trade than necessary to achieve these objectives, as outlined in the WTO Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement). The Swedish risk assessment has undergone a preliminary analysis by a number of scientists from Canada and the United States, including from the United States? National Marine Fisheries Service (NMFS) and Canada?s Department of Fisheries and Oceans (DFO). These preliminary analyses from NOAA and DFO, as well as an independent white paper response (April 12, 2016) by Dr. Robert S. Steneck, Professor of Marine Biology at the University of Maine are included with this correspondence. Among other claims, the Swedish risk assessment ?nds that there is a high risk of Homams americanus successfully reproducing and overpowering the native Homarus gammarus in EU waters, with a major/massive ecological and economic impact. Our initial ?ndings suggest that these conclusions are not supported by the best available science. There is no evidence of success?il life cycle completion or establishment of Homarus americanus populations, or of negative impacts to biodiversity or related ecosystems, when introduced (deliberately or otherwise) outside of its native range in western North Atlantic waters. It is the collective position of Canada and the United States that, for the Swedish risk assessment to be fully evaluated, complete information about the risk assessment model and methodology used, including supporting documentation is required. We respectfully request any supporting documentation about the model and methodology used to develop the risk assessment document, including any records of how individual risk Canad'a'. ~12 -2- and uncertainty scores were assigned and then combined to arrive at the ?nal overall levels of risk and uncertainty, so that we may perform a more thorough scienti?c evaluation of the risk assessment. In addition to these scienti?c issues, the potential socio-economic impact of the proposed measure, including impacts on international trade and trading partners has not been properly assessed in the risk assessment. We share the spirit of Regulation 1143/2014 that any decision to include a Species into the EU list of IAS should be balanced and should take the costs and bene?ts of such decisions into consideration. Paragraph (13) of Regulation 1143/2014 says: ?To ensure compliance with the rules under the relevant Agreements of the WTO and the coherent application of this Regulation, common criteria should be established to carry out the risk assessment. Where appropriate, those criteria should be based on existing national and international standards and should encompass different aspects of the characteristics of the species, the risk and modes of introduction into the Union, the adverse social, economic and biodiversity impact of the species, the potential bene?ts ofuses and the costs of mitigation to weigh them against the adverse impact, as well as on an assessment of the potential costs of environmental, social and economic damage demonstrating the signi?cance for the Union, so as to furtherjusti?i action. The socio-economic impact of adding Homarus americanas to the EU IAS list is signi?cant, not only for Canada and the United States, but also for Europe. Collectively, Canada and the United States export over US $200 million worth of live lobster to the EU. This represents a signi?cant economic driver for numerous coastal communities involved directly and indirectly in the lobster ?shery all along the northern Canadian and American coasts. From a European peISpective, live lobster from North America generates investments, employment and economic returns for the EU, and the entire supply chain, ?om storage, handling, importing, freight forwarding, processing, and distribution, to the retail sector and the catering and restaurant industries. All would be severely impacted by the inclusion of Homarus americanns on the list of invasive alien Species. Based on the initial reviews undertaken by Canada and the United States of the Swedish risk assessment, both countries conclude that it does not provide suf?cient basis for the European Union to place Homarus americanns on its list of invasive alien species, and we believe that Sweden?s request should not be considered on these grounds. Thank you for your consideration. 4? abs/\- Tom Rosser Eileen Sobeck Senior Assistant Deputy Minister Assistant Administrator Fisheries and Oceans Canada National Marine Fisheries Services cc: ean?Luc Demarty, Director General- DG Trade 050 Aguiar Machado, Director General- DG Marine Affairs and Fisheries