Comment
Guidance for protecting species habitat has become a major barrier to sustainable forest management on Crown and private lands. The guidelines should focus on the reason for the species' status, the potential impact of activity on the population, not the individual, and the potential positive impacts of activity on the population and its habitat. Certain species provide excellent examples of the current challenges with the protection of SAR that pertain to forestry.
1) Ginseng: The species is at risk due to picking, not sustainable forest management. We have shown MNR numerous examples where tolerant hardwood stands have been tree marked and harvested following a selection system and upon return 20 to 30 years later, the population of ginseng has increased. This forest management success has now caused the loss of large areas of operable forest due to areas of concern (AOCs). In addition, the AOCs become obvious targets for pickers. Mapping the populations is taking large amounts of MNR time and causing the unnecessary loss of large volumes of timber. Selection management to a basal area of 18 m2/ ha or higher should be the only requirement to protect ginseng.
2) Black ash. The species is at risk due to EAB. There are literally billions of black ash trees and seedlings on the landscape. It is generally not a desirable commercial species, but should sometimes be marked for harvest to release a tree that can fill the space once the ash dies, or for harvest access. Harvesting some black ash trees will in no way change the outcome of the pest infestation and will allow other species to dominate the forest. A carefully managed reduction in ash species is the best way to preserve lowland hardwood forests on the landscape. On private land, forests of dying ash are prime targets for conversion to agriculture. See the attached link for guidelines for managing ash forests written by MNR staff prior to the ESA (2012).
3) Butternut. The protection of individual butternut trees is essential. However, harvest adjacent to the trees is the best possible method of securing future regeneration because of the species' low shade tolerance. Large no-cut buffers prevent successful butternut regeneration. The best known example of successful butternut regeneration on Crown land is a fully completed uniform shelterwood removal cut.
4) Bobolink and Meadowlark. Some ecologists have suggested that tree planting should not occur in areas of bobolink habitat on private land. No specific protection should be required for species that are at risk because of a reduction in cultural activity and a return to a more natural condition in the ecosystem.
Submitted October 18, 2025 6:47 AM
Comment on
Developing guidance on section 16 activities under the Species Conservation Act, 2025.
ERO number
025-0908
Comment ID
158647
Commenting on behalf of
Comment status