We at TULLOCH Environmental…

We at TULLOCH Environmental are pleased to see the proposal of an informed and reasonable approach to Black Ash management. As Ecologists and Environmental Professionals, we work with landowners, municipalities, and industry at sites across Ontario. We can attest to the stark contrast between Black Ash health declines in Southern Ontario, and the apparent abundance and good health of the species in the north. This year, our group found Black Ash on 18 of 26 (70%) of our northern sites – where it is often a dominant and healthy canopy tree in low-lying areas. Black Ash also appears to be an effective reproducer in the north, with canopy dominance sustained by robust and multi-layered understories of seedling and sapling regeneration.

Our group has been apprehensive about the approaching implementation of Black Ash protections in January 2024. We were concerned that so many northern homeowners and businesses would see their land needlessly sanitized of any feasible use. We were also concerned it would exasperate the housing crisis experienced by some northern communities. We are now relieved to see that this may not be the case.

We expect that some portion of the population will be disappointed by anything other than full protections for Black Ash in all areas of the province. But as your Ministry has correctly observed, province-wide protections, while attractively simple, would overlook the root cause of Ash’s decline and impose a potentially catastrophic constraint on northern landowners and economy. Please proceed with this two-tiered approach to Black Ash protections with confidence that it is indeed reasonable, science-based, and defensible. Thank you for this opportunity to comment.