I feel that the proposed…

I feel that the proposed approach is short-sighted by neglecting any protection for Black Ash outside of its already-impacted range. Emerald Ash Borer is expected to continue marching northward, so it is not a question of if but when those unprotected trees are subject to impact from the pest (barring any sudden and miraculous discovery of a 'cure', of course). And given that there's no way to tell ahead of time which trees are going to be tolerant of EAB and survive infestation, the unprotected tree that gets cut down today may be the one you need in the future to ensure continuance of the species.

Further, this approach is likely to lead unscrupulous developers or landowners to preemptively remove Black Ash from their properties in unprotected areas, out of some perceived threat of future regulatory restrictions.

The proposed separation of Black Ash range based on an arbitrary line on a map is an irresponsible approach until we better understand what the long-term range and effect of EAB is going to be. The proposed approach does not serve the long-term conservation of this Endangered species and should be reconsidered.

With regard to the protection of "healthy" ash trees, the province should provide clear, measurable, and scientifically-supportable criteria for the determination of what constitutes a "healthy" tree, in a similar vein as was done previously for Butternut. Leaving this judgment to the interpretation of individuals will only lead to wildly different standards for what is considered "healthy", and will undoubtedly result in the removal of some trees which should have been retained.

As a final note, I take exception to the closing statement of the proposal: "Regulatory impact statement: This proposal is expected to reduce burden that would otherwise arise if these regulations were not put in place. The proposed regulations are expected to result in cost and time savings for individuals, businesses and government". When it comes to the preservation of at-risk species, the primary concern cannot and should not be saving time and money for those attempting to further impact those species. The proper and responsible approach is to always first consider what is best for the species, even if it is inconvenient.