In respect of Proposal…

In respect of Proposal Notice 019-7378 Protecting Black Ash and its habitat under the Endangered Species Act, 2007 the Forest Gene Conservation Association (FGCA) has the following comments:

Supporting protection and recovery of this species is critical before the populations are decimated by EAB. US Forest service research indicates that aside from treated black ash, all are susceptible to EAB and have essentially 100% dieback. Recovery efforts for this species shouldn’t be looking for only surviving black ash but also black ash that are declining more slowly that others. It will only decrease the genetic diversity of the species if only the lingering ash are considered in the recovery efforts. Documenting habitat, locations as well as sampling and seed collection of both lingering black ash and black ash that are more slowly declining, should be require before removals.

Black ash trees of all ages are important in recovery. For seed collection it has been found through USDA research that trees as young as 5 cm dbh produce seed. Also the EAB can impact black ash that is 2.5 cm or larger. The 8 cm or greater focus is erroneous. Seed can be collected earlier and vegetative propagation and grafting can be done on black ash as young as seedlings. Maintaining seed production and species diversity is crucial within the species otherwise there is a risk of inbreeding depression.

Genetics need to be preserved/archived over the whole range of black ash in Ontario (Zone, A, B and C) – we don’t know how fast EAB will spread, if it’s already in all of these locations just not discovered yet, and it is our understanding that this geographic boundary is up to 5 years out of date. (COSEWIC 2018 – per recovery strategy map).

FGCA has many partnerships with the forestry industry, and in order to ensure that their interests are protected, we understand that there will be flexibility tools or authorizations for *all* forestry activities. The CFSA provides exemptions under the ESA for the forestry activities in the area of the undertaking (AOU) but we want to ensure that other private and commercial and municipal (etc) forestry activities can continue under these protections. So we support/advocate for exemptions or flexibility tools in order to ensure that this happens.

How are indigenous uses of black ash being considered here? FGCA knows how important Black ash is to the indigenous communities and knows that it will be used with reverence and respect. We support exemptions for indigenous uses of black ash.