November 2nd, 2023 Re: ERO#…

November 2nd, 2023

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

The Ontario Woodlot Association (OWA) applauds the Draft Government Response Statement for Black Ash. As an organization where we help each other be the best possible stewards of our woodlots, we are invested in maintaining the health and diversity of wooded areas. The three focus areas identified in the response statement: 1) management and protection, 2) research and monitoring and 3) awareness, provide good potential to enact and apply the recommendations of the SAR Recovery strategy for black ash.

The OWA through its membership and programming, which includes on-going production of private lands forest inventory derived from LiDAR, Forest Stewardship Council (FSC) and Sustainable Forestry Initiative (SFI) group certification, and in-person and online workshops, is well-positioned to collaborate on the proposed policy and actions to maintain this keystone species on the landscape. The OWA supports the proposed species-specific policy, but does have several comments and suggestions to avoid unnecessary burdens on the health, safety, and forest management (including commercial operations) of private landowners.

OWA response to the proposed regulations related to Black Ash under the Endangered Species Act, 2007:

The OWA is supportive of the intent of the proposed regulations that will set out how black ash and its habitat will be protected under the Endangered Species Act of 2007. Protecting healthy and lingering stems (8cm diameter at breast height and greater), during and following Emerald Ash Borer infestation provides opportunities for the proposed actions under the SAR Recovery Strategy and the Draft Government Response Statement. We are also supportive of good forestry practices that include written prescriptions by Registered Professional Foresters describing how forestry operations will minimize adverse effects to black ash and/or contribute to the renewal and maintenance of black ash.

We are, however, concerned about a potentially unnecessary burden that will be placed on private landowners if the determination of tree health is required by qualified professionals and with written documentation. As you can imagine, EAB infestations do not kill all trees at the same time, and private landowners may need to clear dead and dying trees to maintain the safety of their woodlots and the viability of any ongoing (commercial) operations such as maple syrup production. We do not want to see the financial and time burden placed on private landowners to determine if a dead and dying tree requires removal, whatever might be the cause (i.e., including factors other than EAB that can cause a tree to decline or die).

As we understand the proposed regulations, this determination of health by a qualified professional with supporting written documentation is limited to healthy trees, and would not apply to dead and dying trees. Is our interpretation of the proposed regulations correct?

We see opportunities through collaboration to further educate woodlot owners on black ash identification, EAB identification, understanding SAR regulations, and opportunities to contribute to high priority actions included in the SAR Recovery Strategy. This would help to ensure that healthy stems are retained, and also provide information on the signs of dead and dying trees. Beyond identifying healthy lingering black ash over 8 cm diameter at breast height, this can also create informed landowners. These individuals can report on stunted stems that are capable of producing seed on nutrient poor or lower productivity sites, potential cultural uses of black ash, as well as contributing to knowledge on the presence of regeneration and in which conditions this takes place.

We thank the Ministry of the Environment, Conservation and Parks for their work at protecting black ash and look forward to collaborating on its recovery through our programming and membership base. Please reach out to us at your convenience to discuss how we can positively contribute to the protection and conservation of black ash in privately owned forests.

Yours truly,

Matt DeMille
President
Ontario Woodlot Association

John Pineau
Executive Director
Ontario Woodlot Association
705-358-4261
John.pineau@ontariowoodlot.com