"The proposed changes would…

"The proposed changes would authorize the creation of a regulatory charge that could be paid by persons who are permitted to carry out otherwise prohibited activities under certain permits, agreements, and regulations. The charge would be paid in lieu of fulfilling certain potential conditions that could otherwise have been imposed under the permit, agreement, or regulation. The proposed charges would only be available in respect of species prescribed by regulation. The price for the payment-in-lieu (i.e. regulatory charge) will be within the range of costs that a client would have otherwise incurred through meeting the species-based conditions of an authorization. Clients would still need to fulfill some on-the-ground requirements, including considering reasonable alternatives for their activity and taking steps to minimize the adverse effects of the activity on the species at risk."

This is not acceptable and is too broad. What steps would need to be taken? What requirements? What alternatives? Paying a 'fee' with this kind of broad generalization of the restrictions is essentially open ending into nothing.

As annoying as it may seem there are some species that are so endangered and do not easily repopulate that paying a 'fee' shouldn't be an option at all. Look at the Hwy 7 expansion delays from Kitchener to Guelph due to a Newt(s). It might be annoying but everyone in this region has accepted it for as long as it has gone on and we will continue to do so until it as migrated.

Without mentions of scenarios where a fee is not possible at all due to how endangered something may be all you're doing is implementing a scale of the fee which is absolving a developer completely and generating a 'pay to play' scenario.