March 4, 2019 Dear Public…

March 4, 2019

Dear Public Input Coordinator,

The Council of Tay Valley Township, in Eastern Ontario, passed a motion February 14, 2019 directing staff to comment on Area of Focus 4 – Authorization Process of the 10th Year Review of Ontario’s Endangered Species Act: Discussion Paper.

Tay Valley Township is part of two unique ecoregions in the province: the Frontenac Arch in the southeast of the Township and The Land Between in the northwest of the Township. Council is aware of the high level of biodiversity found in the Township as a result of its position as the northern limit of many southern species and the southern limit of many northern species.

Much of the Township is still rural and it is on these rural lands, that contain species at risk habitat, that the Township wishes to focus its comment. In Area of Focus 4, the Discussion Paper poses the question, “What new authorization tools could help business achieve benefits for species at risk? (e.g., in lieu of activity based requirements enable paying into a conservation fund dedicated to species at risk conservation, or allow conservation banking to enable addressing requirements for species at risk prior to activities).

Tay Valley Township supports the establishment of conservation banks similar to those established in 16 states, managed by the US Fish and Wildlife Service. Tay Valley Township sees an economic opportunity for its rural residents to be financially compensated for maintaining endangered species habitat through conservation banks.

Finally, Tay Valley Township has a process related comment from working with development proponents and seeing how the permit process works. When a proponent submits information it goes through many layers within the Ministry– information gathering form, authorization form, conservation permit form and goes up the hierarchy of approval within the Ministry. Instead of coming back down the layers of approval and sitting on someone's desk while they are on vacation, etc., the permit could be sent directly from the Minister to the proponent.

If you are interested, more information on conservation banks, as described by the US Fish and Wildlife Service, is provided below.

“Conservation banks are permanently protected lands that contain natural resource values. These lands are conserved and permanently managed for species that are endangered, threatened, candidates for listing as endangered or threatened, or are otherwise species-at-risk.

Conservation banks function to offset adverse impacts to these species that occurred elsewhere, sometimes referred to as off-site mitigation. In exchange for permanently protecting the land and managing it for these species, the U.S. Fish and Wildlife Service (FWS) approves a specified number of habitat or species credits that bank owners may sell. Developers or other project proponents who need to compensate for the unavoidable adverse impacts their projects have on species may purchase the credits from conservation bank owners to mitigate their impacts.

Lands used for ranching, farming, and timber operations or similar agricultural purposes can function as conservation banks if they are managed as habitat for species. Degraded habitat, such as retired croplands or orchards, may be restored. Linear areas or corridors, such as stretches of streams and their associated riparian habitat that link populations of species, may also qualify as conservation banks.

A conservation bank is a market enterprise that offers landowners incentives to protect species and their habitat. Landowners can profit from selling habitat or species credits to parties who need to compensate for adverse impacts to these species. Landowners can generate income, keep large parcels of land intact, and possibly reduce their taxes.

Conservation banking benefits species by establishing large reserves (200-300 acres or more) that function as compensatory mitigation areas for multiple projects. It costs less per acre to manage a conservation bank than the equivalent acreage divided among many small isolated mitigation sites. Larger reserves are more likely to ensure ecosystem functions, foster biodiversity, and provide opportunities for linking existing habitat.

Conservation banking also benefits the public by protecting open space and contributing environmental services such as nutrient recycling, pollination services, and climate regulation.
Conservation banks have existed in the US since 1995.

Conservation banking is not a substitute for avoiding and minimizing effects on listed species on-site. The purpose of conservation banking is not to encourage development of listed species’ habitats, but rather to provide an ecologically effective alternative to small on-site preserves which are not defensible or sustainable.”

Thank you for the opportunity to comment.