In respect of Proposal…

In respect of Proposal Notice 019-6990 Developing the government response statement for Black Ash under the endangered species Act, 2007, the Forest Gene Conservation Association (FGCA) has the following comments:

- 37-44 & 92-106- In either or both of these sections, the GRS needs to mention the state of black ash in the US. The research that is being done in the US is fundamental to our learning, partnerships and our recovery success for black ash. Also the genetic sources for climate change adaptation in black ash populations could depend on the sources from the US.
- 65-75- Black ash is a dioecious tree (has female and male trees), this is absolutely critical to understand for recovery as you may preserve a male tree, but without a female you will never have fruit. (aka seeds)
-65-66 – Black ash can produce seed at much younger than 30-40 years of age. There have been studies done that indicate that it can produce seed when it is as young as 5 cm dbh
- 228 Using the Ontario Tree Seed Genetic Archive is only a small subset of what is required for a species of this scale. The National Tree Seed Centre in Fredericton NB, is also a critical partner in recovery and preserving seed. Recovery partners like the FGCA are an important link in both the collection of seed as well as the vegetative propagation or grafting efforts to understand the best methods to preserve the genetic diversity of this species.
-233 How are populations being monitored now? Can you ensure trees removed are documented for long term understanding of the native range of the species before a significant portion of the trees are lost.
-244 FGCA has robust programs in both species recovery and a climate change adaptation as well as a broad network of partners from multiple levels of government and that can be utilized in both recovery and would be well positioned to be involved in a program of this scale.
-252 This is critical as so much can change in this time period. This needs to be prioritized so we can learn from the actions taken in that time and improve upon them for greater success.
-270 Genetics need to be preserved/archived over the whole range of black ash in Ontario (Zone, A, B and C). It may take years to accurately archive the current or imminent threat populations in southern Ontario. Although we are looking for genetic resistance, those trees that do not exhibit that resistance may still have a significant role if the pest populations drop or are significantly reduced. Therefore archiving the population based on its historical range should be the priority. 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).

440-449 These performance measures will take a significant amount of effort and time, and may not be attainable for all of the ecodistricts. This would be a great goal, but given the state of ash in the southern ecodistricts, this might have to include more than just the healthiest ash over 8 cm dbh. For butternut archiving the FGCA has been working at this endeavour for over 15 years with a good deal of funding and still have yet to reach our goal of 10 archived parent trees per ecodistict. There will need to be a good amount of funding allocated to this recovery effort in order to achieve this performance measure by 2033. Including the genetic archiving of the populations in the ‘areas not affected by EAB’ is also important – genetics need to be preserved and maintained through the whole range of ash. And 15 might not be enough in the grand scheme of it all. Especially as the trees die off, the more genetic representation the better!

Will the area “not affected by EAB” be fluid as monitoring reports come in? This is not a static thing.

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.