Commentaire
This species can be added first while you work out a strategy. This is the process used under the Act for years and not following it is not acceptable. The rationale for delay is unfounded and risks loss of species and habitat. Also, there would be no guarantee the listing would happen. It would not be the first time a deadline has been missed. There is no question this species is at risk. In October 2020, the Committee on the Status of Species at Risk in Ontario (COSSARO) determined that black ash was endangered in Ontario.
Threats to the species are already well understood and documented by COSSARO and the Committee on the Status of Endangered Wildlife in Canada (COSEWIC).
That more time is needed to consider listing is also unfounded. Overall benefit permits, agreements and regulatory exemptions already provide ample flexibility. Forestry operations in managed Crown forests are entirely exempt from ESA requirements.
Black ash should benefit from the full protection of the law, without further delay. Here’s why:
• Globally, black ash is critically endangered. Since at least 25 percent of the species’ global range is in Ontario, we have a significant conservation responsibility (COSSARO, p.3).
• Black ash is a culturally significant species for many Indigenous Peoples.
• Delay would create a perverse incentive for destruction: development proponents wishing to avoid meeting ESA requirements would have two more years to cut down trees and destroy habitats (primarily in wetlands) with impunity.
• Continued and likely accelerated removal of black ash risks the loss of genetic diversity that could provide resistance to emerald ash borer, the primary cause of black ash decline.
• Habitat loss “may have significant regional effects” on remaining black ash in areas heavily converted to agriculture and urban development (COSEWIC, p. 45).
Soumis le 27 octobre 2021 7:41 PM
Commentaire sur
Arrêté du ministre pour la suspension temporaire de la protection du frêne noir après son inscription à la Liste des espèces en péril en Ontario en vertu de la Loi de 2007 sur les espèces en voie de disparition
Numéro du REO
019-4278
Identifiant (ID) du commentaire
58625
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Statut du commentaire