Thank you for the…

Thank you for the opportunity to provide feedback on the proposed regulations under the Endangered Species Act to protect and recover Black Ash.

I am responding as:
• a Registered Professional Forester in Ontario with three decades of forest management and operations experience;
• an owner of a large, forested property located just outside of the City of Thunder Bay municipal boundary in Northwestern Ontario; and
• an owner of a large, forested property located in Frontenac County in Eastern Ontario.

I was pleased to see that some consideration has been given to revising the recovery plan, and I recognize the challenge of preparing a policy that is practical and suitable province-wide. However it is disconcerting that policy makers still have no good understanding on the science and silvics of black ash, which is far more abundant across the Northwestern Ontario landscape than described.

The policy makers still do not recognize that the proposed protections for black ash (not within a Forest Management Plan) are impractical and I am afraid they will likely simply be ignored. Expecting landowners to understand the varying regulations as written is unreasonable. One needs to think practically and provide direction for the common person. In discussions with friends, neighbours, colleagues, there seems to be more questions arising than clear direction in the recovery plan or supporting policy; such as:

• Can I clear my building lot if there is an ash tree?
• There is an ash sapling sprouting on my lawn or in the middle of my ATV trail – can I cut it?
• I cut and burn black ash firewood on my property for winter heating because I can’t afford other heating sources – is that restricted now?
• Where is the army of professionals that are going to assess ash trees and determine if they survived EAB? What if EAB is not even present in part of the mapped geographic scope of the regulation? Is an assessment required? Who pays for this assessment?
• Black ash trees are encroaching on my farmland and need to be cleared – can I cut them?
• Can I cultivate my farm field within 30 metres of an ash tree?
• What does a 30 metre protection zone mean? Is it no tree or shrub clearing of any species? No soil disturbance? Can I work on frozen ground?
• What if the tree is a hazard to my property?
• What is the mechanism that would change the geographic scope of the regulation and add new municipalities? A single observation of EAB?
• Why is the maximum rooting zone observed for Green Ash, a different tree species that is rarely observed in Northwestern Ontario and grows on different habitat, being used as the basis for Black Ash protection?

I do not support the inclusion of the City of Thunder Bay, which has a broad municipal boundary footprint, within the proposed geographic scope of the regulatory approach. EAB-caused mortality is not significant, and infestation is only at a few localized sites within the City.