OFA commented on the proposed regulations on how Black Ash and its habitat will be protected under the Endangered Species Act, 2007. OFA supported the proposed species protection regulations and conditional exemptions for Black Ash under the Act. OFA is in favour of limiting the application of species protection prohibitions only to healthy Black Ash, and only in areas of the province that have experienced significant Emerald Ash Borer-caused mortality of ash trees. OFA also supported the definition of healthy Black Ash trees in the proposal.

OFA restated its longstanding belief that recovery strategies and habitat regulations need to reflect that it is unsustainable to have a single-minded focus on species restoration that excludes all other factors.

OFA is in favour of the proposed prohibitions that relate to possession, transportation, buying, selling or offering to buy and sell do not apply to Black Ash. OFA requested that agricultural lands be exempt from habitat protection provisions, which would allow agricultural activities to continue even where healthy Black Ash is located. Furthermore, OFA recommended conducting an economic impact analysis on the effects of recovery actions on northern Ontario, especially where data gaps on Black Ash currently exist.