Please see attached letter…

Please see attached letter.

We strongly supports this proposal and encourage the Ministry of Environment, Conservation and Parks (MECP) to move forward with this temporary suspension.

We continue to have concerns about this listing as a whole and encourage MECP to work with municipalities and the forest sector to evaluate the true status of black ash across the Province, and determine if listing the species will actually protect the species, or simply lead to economic and social consequences.

Protecting Black Ash from being harmed, killed or harassed during forestry, roads or development will not protect the trees from EAB. On the contrary, listing Black Ash as endangered will inevitably lead to its pre-emptive removal on private land to avoid future persecution, reduce the ability to manage forests for resilience against EAB and other invasive species, and will lead to increased human safety hazards because of hesitancy or inability to meet ESA requirements for removal of EAB affected ash. Putting an “assessor”-type system in place similar to Butternut would be unachievable on the scale that ash exists.

Our advice would be to not list Black Ash as an endangered species, as it is unclear how this designation will help the species recover, whereas it is known that the impact to many sectors and industries would be great in areas where EAB is not yet fully established and Black Ash is common. A better use of resources that would be necessary for policing, evaluating and permitting for inevitable Black Ash removal would be the expedition of parasitic wasp trials for biocontrol of EAB.

The proposed temporary suspension of protection of black ash is necessary to allow all those affected by the listing, including the Ministry of Northern Development Mines, Natural Resources, and Forestry (MNDMNRF) to develop appropriate and comprehensive management actions should the listing stand. It is imperative that government use this time to plan for the future of black ash in Ontario, beyond simply listing the species. How protections will be implemented, what protections will be implemented, and what the measures will be determining the success of these protections all need to be considered and shared with municipalities, the public and the forest sector well in advance of the end of the two-year temporary suspension, to ensure unintended consequences are avoided.

It is critical that this proposed Minister’s Order be implemented, but it is even more important that this time be used to seriously evaluate the impacts of Black Ash being listed as Endangered – will there be a positive outcome for the species, or only negative impacts on forestry, infrastructure and development?