We at the Canadian Chestnut…

We at the Canadian Chestnut Council, recognize that expeditious economic development in Ontario is critical. However, we also believe it can be achieved while minimizing the cost to Ontario’s at-risk tree species – specifically the American chestnut. The proposed policy changes can be amended to minimize their effect on the vulnerable ecosystems the tree represents, while maintaining or enhancing their protection. The preservation of the few remaining American Chestnut trees, representing the three (3) subgroups unique to Ontario, is vital in our collective efforts to enhance or economy, combat climate change, maintain clean water supplies and support biodiversity. The American Chestnut tree represents cultural value to both indigenous and non-indigenous communities and will provide recreational opportunities to all. The recovery of the American Chestnut tree will ultimately provide the economic value of the timber and nuts it historically had. The recovery will also allow the American Chestnut tree to regain its ecological role as a keystone species within the forests of Ontario.

Accordingly, the Canadian Chestnut Council suggests that the Minister, who desires to develop regulations in consultation with the public, incorporate the following into the proposed changes:

1) That the proposed registration system emulate the current “Environmental Registry of Ontario”. This would allow for notice to the public of proposed actions and their related mitigation plans – time for the public to react – allow for notice to the Minister of potentially sensitive situations both to the uniqueness of the American Chestnut tree effected (i.e. extreme scientific importance, recruitment issues, last of its kind in a geographic area, matters cultural in nature), and potential political concerns while providing an opportunity for intervention by the Ministry. Perhaps a permit might be required. The time restraints would expedite this process while allowing for transparency. Critique by stakeholders would be stakeholder initiated rather than Ministry driven.

2) To assist the proponent in developing their mitigation plan, and in an effort of establishing a clear framework for setting expectations and rules for them to follow, we suggest the American Chestnut tree be added to Regulation 830/21 in a manner similar to the representation of the Butternut tree. We would also petition that the Canadian Chestnut Council be engaged in the establishment of these species-specific regulations in order that we may contribute our unique knowledge of the species and its’ place in the Ontario environment.

3) We would encourage the Minister to retain the Recovery Strategies and Government Response statements for the American Chestnut tree. We would also ask that the Canadian Chestnut Council be encouraged to maintain its’ Stewardship Agreement with the Minister and as part of the agreement continuously update the suggested proposals regarding the preservation and restoration of the American Chestnut tree.

4) Where there is a proposed enhancement toward “habitat restoration”, we feel “species restoration” should not be overlooked. In many cases, due to various causes, i.e. invasive insects, fungus, deforestation, or others; the species has been decimated. However, American Chestnut supportive habitat still exists.

5) Regarding the addition or removal of a species from the endangered species list, we feel it should be done for scientific reasons. If the Minister executes his discretion to remove a species, then in the spirit of transparency, the Minister be compelled to explain the reasoning for his action.

6) Regarding the New Species Conservation Program we are very concerned that in the administration of this funding that grass-root volunteer organizations that are not highly structured nor multi species orientated will continue to have a role and the support of the Minister in their efforts. The Canadian Chestnut Council was established in 1988 and has a good record of supporting the Government Response Statement for American chestnut. In addition, it enjoys a Stewardship Agreement with the Minister. It would be a shame to see our past and continuing efforts not be respected in the name of efficiency.

As a general comment – the funding of major purchases such as land should be discouraged, as they are expensive. The funding of more projects with the same resources, especially to grass-root volunteer groups, should be encouraged. The result will be to provide for more “bang-for-the-buck”, so to speak, from the funding. An additional benefit will be many more good will photo opportunities from the same expenditure.

The Canadian Chestnut Council looks forward to your response, and awaits our opportunity to engage in the development of regulations specific to the American Chestnut tree.

As a final statement, the more a species is endangered, the more protection it should have, and the more accommodation there should be for its continuance.

Yours in the preservation and restoration of the American Chestnut;

The Canadian Chestnut Council