We understand the need to…

We understand the need to gather the evidence on socioeconomic implications of the proposed changes but are concerned that the Black Ash will continue to decline in number because of this postponement. Are there any protections and/or measures that could be afforded to provide some protection (i.e., require an ESA permit for removal) during the creation of the recovery strategy?

We also believe that protection of this species is crucial for the species recovery. According to the 2020 Evaluation Report for Black Ash from COSSARO 25% of the global range is in Ontario. Postponing the protection of the species under the ESA will negatively impact the species because there will be no limitations for removal of the species during the suspension.

Additionally, development of a Recovery Strategy while the protections are suspended does not
prevent the species from being affected. We are concerned that not having the species protected will result in further loss and make for a more difficult recovery period.

Finally, with regards to the proposed amendment to the General Regulations under the ESA, we
believe that each species should be individually assessed based on their COSSARO status. All species are variable and individual exemptions will vary based on each individual status. We fear that blanket approval of the existing conditional examples does not afford the species the necessary protection as determined by COSSARO.

We strongly oppose this proposal for the reasons listed above. We believe that protection of species such as the Black Ash is of utmost importance and will be in jeopardy if this proposal is enacted.