Comment
There is insufficient justification provided here for the delay in protections for black ash. The species has already been left unprotected for a full year since assessment, and an additional two years will only leave it more vulnerable. The justification here is primarily based around the supposed potential negative "economic impacts" of protecting the tree. Is the worry here that industry won't be able to freely harvest the tree at the same rates as before? If so, then that's the whole point of the ESA: this species is at risk, it needs protection, and industries using black ash for products will just have to adapt. The alternative is to create a perverse incentive to plunder the species stocks before they are damaged by ash borer, which will have a greater impact on the species and industries that benefit from it in the long run. Damage to black ash habitat and elimination of resistant individuals jeopardizes the species population. We need to be preserving as much black ash as possible to preserve a decent genetic stock when only resistant individuals remain after EAB. Additionally, the justification that somehow time is needed to study the impact of protections is misguided. Any restrictions to use of black ash caused by policy will be small compared to the destruction caused by EAB and habitat loss. A long term view is needed here. I urge to the Minister to not delay protections for this species, and instead implement protections as soon as possible.
Submitted November 7, 2021 8:09 PM
Comment on
Minister’s Order for temporary suspension of protection upon the listing of Black Ash under the Endangered Species Act
ERO number
019-4278
Comment ID
58680
Commenting on behalf of
Comment status