Regarding proposal 019-4278,…

Regarding proposal 019-4278, a 2 year delay in the implementation of protections for Black Ash:

I support the Ministry’s proposal to delay province-wide protection measures to get them right, because the Endangered Species Act was designed for fish & wildlife, not for trees, and not for a predicted, as opposed to current, population decline.

Many ESA provisions (e.g. 'harm & harass') don't make sense when applied to a tree species. For example, black ash sprouts a new tree when cut down, unlike wildlife. Also, trees can be identified from aerial imagery and don't move once detected, and can be regenerated where desired, unlike wildlife. Because trees can be protected and regenerated with much more confidence than fish & wildlife, the protection provisions designed for fish & wildlife can be completely unnecessary and even counterproductive for trees.

Protection/ management provisions for Black Ash pose an even greater challenge than for most Species at Risk, since Black Ash were listed At Risk in anticipation of a predicted future (as opposed to current) population decline which now only exists in certain ecological zones of Ontario; black ash populations are thriving throughout almost all of in Northern Ontario.

If protection of trees which are under no threat whatsoever came at no consequence to anyone, then one could consider it. However, as I and many others have pointed out, protection measures would incur a very significant cost to a very significant number of people - for no benefit.

My suggestion is to put the 2-year delay on, and then immediately impose targetted, effective protection and silviculture strategies in areas where black ash is under threat. I think everyone shares the desire to ensure that black ash continue to exist in those places where they are under attack. There is no reason why measures cannot differ as appropriate across Ontario's vast geography while the 2-year delay is On.

The management of Black Ash, as with other tree species imperilled by insect and disease, is not simple, and is a task for professional foresters. NDMNRF professionals are capable of developing effective strategies that include assessment of local risk, protection where needed, and silvicultural practices. Thank you for the opportunity to contribute.