RE: Environmental Registry…

RE: Environmental Registry of Ontario Number 019-7378
Protecting Black Ash and its Habitat under the Endangered Species Act, 2007

The Severn Sound Environmental Association (SSEA) appreciates the opportunity to comment on the Protecting Black Ash and its Habitat under the Endangered Species Act, 2007 proposal.

The Severn Sound watershed is in southeastern Georgian Bay. The SSEA is a Joint Municipal Service Board under the Municipal Act and works closely with its eight lower tier municipal partners (Midland, Penetanguishene, Tay, Tiny, Springwater, Georgian Bay, Severn and Oro-Medonte) and two upper tier municipalities (County of Simcoe and District of Muskoka) in the Severn Sound area, as well as provincial and federal government agencies and non-government organizations. The SSEA’s mission is ensuring exceptional environmental quality through exemplary stewardship of the Severn Sound area through sound science, collaboration, and partnerships. The SSEA collects environmental data and provides expertise to member municipalities, works to keep water clean so it supports healthy terrestrial and aquatic ecosystems, and has been heavily involved in municipal drinking water source protection activities, as well as in conducting wetland evaluations and identifying and documenting natural heritage features for several member municipalities for use in their Official Plan updates. The SSEA also conducts terrestrial and riparian habitat restoration projects and undertakes afforestation efforts. The SSEA is the local Source Protection Authority in the Severn Sound area.

We offer the following comments regarding the above noted ERO posting.

Black Ash typically grows in wetlands. Natural heritage features such as wetlands, woodlands and other natural areas and Species At Risk provide many benefits to the environment and to people. These features are an important component of healthy and sustainable communities and can be critical natural infrastructure and natural assets on the Ontario landscape, contributing local value to culture, the environment, and economy.

1. The Provincial Recovery Strategy for the Black Ash in Ontario (2022) recommends that the area for consideration in developing a habitat regulation for Black Ash should be “the entire wetland Ecological Land Classification ecosite type in which one or more Black Ash tree is present and all of the area within a radial distance of at least 28 m from an individual Black Ash tree, including less suitable dry or upland areas habitats”. Under the current proposal, habitat protections would only apply to a 30-metre radius around a tree that qualifies for protection, leaving valuable habitat unprotected that may be suitable for Black Ash seed dispersal and regeneration. This approach could potentially lead to habitat fragmentation and loss of suitable habitat for Black Ash growth, reproduction, regeneration, and recovery. The SSEA supports the development of a habitat regulation that is consistent with the science-based Recovery Strategy with respect to the radius/area around a qualified tree that is protected.

2. The proposed protections do not include the entire range of Black Ash in Ontario and would only apply in a portion of its range, where the Emerald Ash Borer has most severely affected the species. The Recovery Strategy for the Black Ash in Ontario states that “The protection of habitat that directly supports individual tree survival within the current presumed climatic range of Emerald Ash Borer is necessary to maximize the chances of protecting Emerald Ash Borer resistant individuals. The protection of habitat that directly supports individual tree survival beyond the current climatic range of Emerald Ash Borer aims to ensure that Black Ash subpopulations are maintained or increased”. The Recovery Strategy furthermore states that “Due to the uncertainty regarding the success of mitigation measures of Emerald Ash Borer, maintaining or increasing the population abundance and distribution in areas where it is not under threat of Emerald Ash Borer is the surest way to conserve the species in Ontario”. The SSEA supports development of a habitat regulation that is consistent with the science-based Recovery Strategy with respect to the geographic range of Black Ash that should be protected.

The SSEA supports the development of a habitat regulation that is consistent with recommended protection and recovery objectives in the Recovery Strategy - a habitat regulation that uses a precautionary approach of protecting habitat at a broad scale, to maintain a healthy abundance of Black Ash and to preserve a genetic bank for species conservation that can promote resilience and may help to mitigate other threats to the species such as climate change.

Thank you again for the opportunity to offer feedback on the Protecting Black Ash and its Habitat under the Endangered Species Act, 2007 proposal. Please continue to include the SSEA in additional consultation. The SSEA welcomes the opportunity to discuss our comments further at your convenience. If you have any questions or comments please feel free to contact the SSEA office.