Summary The Endangered…

Summary
The Endangered Species Act (2007) was an Ontario creation recognized as the best in the world. “Pay to slay” seriously weakens species protection. Nevertheless, a conservation fund must have the independence and the wherewithal to do its job, and the permit fees must cover the full cost of the fund’s operations. The current proposal does not meet that standard.

We are proposing to create a new provincial agency (the Agency), with expertise to invest in strategic, large-scale, and coordinated actions that would support more positive outcomes for select species at risk.

If the Agency is to fulfill its functions, it must have the capacity to do so. It must have the expertise to develop the strategy and the wherewithal to implement it. It must have the independence to create and execute its strategy. It must have staff with the appropriate skills, including potentially investment management.

Since the best means of protecting species at risk is to protect their habitat, the Agency’s first task should be to identify all existing and potential habitat of the eligible species. Then the numbers each can support and the land use designations should be determined. Potential habitat should be restored. The amount of land, current and potential, should be adequate to protect the species, and the land use protections covering a sufficiency of land must be robust. The cost to do this work should be calculated. This is initial funding the Agency will require.

The scheme anticipates that an individual wishing to destroy habitat will pay once into the fund, but conservation activities must continue if the Agency’s objective is to be met. Basic financial literacy notes that the up-front cost is the annual expenditure divided by the current interest rate, now 1%. For every dollar of the Agency’s expected annual operating costs, costs which necessarily include maintaining staff expertise and updating the strategy as required, the permit holders collectively must contribute $100.

Allocating this cost to an individual who wishes to destroy habitat is beyond the expertise of the Ministry. But it is not beyond the expertise of the insurance industry. The Agency should consult the industry to determine the price of a permit. The price should ensure the Agency has sufficient funds to do its job and remain solvent. The Agency may need the skills of underwriters and actuaries. Since the work of an actuary is highly specialized, peer reviews are common.

There is no inherent reason why the price to the landowner of “pay to slay” should be lower than the cost of protecting the existing habitat. A proper cost analysis often confirms that preservation is the more economical action. The landowner, not the public, should pay the full cost, and no permit should be issued until that value is established.

The Agency should report to the public annually, and those reports should include the management plan for each of the eligible species (plans which the Province should have developed), how the strategy implements the management plans, and how the actions taken by the Agency further the strategy. The report should include the work yet to be done and its estimated cost. A report on solvency could be included. Presumably the Auditor-General can always report on value for money, so “efficiency” measures that hamstring the Agency are undesirable.

Conclusion
The best way to protect species at risk is to protect their habitat, not “pay to slay.” But if there is to be a conservation fund, it must have the independence to do its job and it must be adequately funded. Permit fees must be as high as necessary to keep the fund solvent without compromising its ability to protect species.