October 31, 2023 Re: ERO#…

October 31, 2023

Re: ERO# 019-7378 Protecting Black Ash and its habitat under the Endangered Species Act, 2007

The Ontario Maple Syrup Producers’ Association (OMSPA) is a member based organization representing over 600 maple producers across Ontario. The Association provides information, network services, training on various aspects of the maple production cycle and represents the maple sector at various levels of government alongside resource, private and academic partners. It also provides consumers with information on the benefits of using maple products, where to obtain locally produced maple syrup, and emphasizes the high quality of maple syrup made in Ontario. The Ontario maple industry contributes well over 70 million dollars to the economy in direct and indirect benefits annually.

Observations:

Maple syrup producers have an affinity for the land they own and manage. They must ensure a healthy ecosystem to produce maple sap, which is boiled to make maple syrup. Many have approved management plans which consider biodiversity, intermittent stream and vernal pool protection and proper silvicultural procedures that contribute to a healthy sugar maple ecosystem. It is recognized by some producers that may have black ash in their sugarbushes, that it is an important component of the health of their forest.

The Emerald Ash Borer arrival has had negative effects on many private woodlots, many of which are productive maple bushes. The loss of biomass in the forest, which has ameliorated wind and direct sunlight to the forest floor, has negatively influenced some producers’ production, let alone the aesthetic impacts. Ontario’s maple producers care very deeply about invasive species that have influenced the health and biodiversity of their sugarbushes. In this case, the EAB has caused significant threat to the ash species, hence the ESA designation; we get that.

Understanding maple infrastructure challenges:

It is important to understand the infrastructure challenges in a typical sugarbush as it relates to this initiative. Black ash thrives in low lying wet areas, much of which is under water for extended periods of time in the growing season. These low areas are usually the lowest in a sugar bush…the hard maple likes higher terrain and does not like being in very moist soils. As a result, the tubing infrastructure which is set up in a typical sugar bush is usually run in these lower areas so that subsequent “pipelines” can flow downhill to the main line and then to a collection point.

The maple sap runs into what is called “mainlines” which are supported by suspended wires and are from ¾ to 2 inches in diameter. These lines form the backbone of the collection system and are expensive to set up and tricky to repair when events occur like trees falling on them. Maple producers monitor the trees within their collection system and at times remove them from the immediate area of the pipeline to reduce the potential for damage to their pipeline from fallen trees.

Towards solutions:

We have reviewed the supporting documentation as MECP moves towards strengthening the regulations for Black Ash. It is all encompassing in principles and laudable in goals. Experience has taught us that when the overarching objectives, such as those outlined in the recovery strategy, do not work (some may work), a more prescriptive approach is adopted.

OMSPA appreciates the challenge is huge and the chance of success is uncertain. OMSPA also wants to emphasize that, as an organization, we want to be part of the solution.
We do agree and have encouraged maple producing members to be certified under the various certification programs for maple production; CFIA food regulation under the Safe Food for Canadians Regulations; Organic standards and Forest Stewardship Certification (FSC). However, we are not a regulatory agency……..we only encourage.

We also encourage members to engage in the Managed Forest Tax Incentive Program (MFTIP). Some do…. many do not. Many of the objectives outlined in the documents provided by MECP address those tools as viable paths to solving this issue. However, at present it is voluntary, depending on the marketing strategy of the individual producer. Mandating all of our members to subscribe to a written plan, approved by a Registered Professional Forester(RPF), to protect black ash would be met with significant backlash. A different approach would be more acceptable.

What would be problematic:

A prescriptive approach that disallows the maple producer from protecting the pipeline infrastructure from potential “deadfalls.”
Totally prescribing a “no cut” provision in the regulations
Mandating the maple producer to engage a registered professional as outlined in the background documentation as the only means of managing black ash on their property.
Any penalty suggested if the maple producer does not comply.
Any negative government assertions that landowners are not cooperating or engaging etc. to deal with the plight of the black ash decline.

What would be acceptable:

A training and awareness program partnered with OMSPA and government to educate members on the issue and the potential suite of solutions.
Re-evaluating the definition of qualification of “tree health” experts from the suggested professionals to landowners that are in their forest the most and can determine what a healthy tree looks like. In order for any strategy to work, the landowners need to be viewed as a partner.
Consideration of partnered funding through the Stewardship program to encourage engagement in attaining a MFTIP plan with subsequent management factors for black ash. This could be piggy backed on other ESA designated species as well.
Giving maple producers and landowners discretion on dealing with black ash issues on their property to protect their infrastructure coupled with an incentive program to protect black ash.

Why does what the maple industry suggests matter?:

The Ontario maple industry contributes over $70 million directly and indirectly to the Ontario economy. It is important to Ontarians culturally, economically, environmentally, historically and socially. It is an excellent source of 2nd and 3 rd crop income for farmers and as the industry grows maple syrup will be the primary source of farm income on more farms. It is also a driver for community stability and growth in rural Ontario. Maple producers also have a significant role in maintaining their forests and contributing to carbon sequestration.

The Future of Ontario’s Sector:

Fostering innovation, markets and talent:

The maple industry has gone through a dramatic innovative cycle in the last 10 years. Ontario producers are investing in new technology and systems. Maple equipment dealerships have more than doubled in 15 years. OMSPA commissioned a far reaching marketing strategy in 2014 that has poised Ontario to displace Quebec maple syrup in the domestic market in Ontario. Our producers are doing a better job of making quality maple syrup. They are deeply concerned about the health of their forests.

Promoting stewardship and sustainability:

OMSPA has formally endorsed third party certification for maple producers and has actively worked to educate and inform producers on mechanisms to achieve that. OMSPA has promoted the involvement in the Managed Forest Tax Incentive Program ( MFTIP) to its members as well as certification under the Forest Stewardship Council( FSC). We are a credible third party partner.

Thank you for the opportunity to comment.