Thank you for the…

Thank you for the opportunity to provide my comments. These comments come from the perspective of an environmental consultant who as has worked with many different clients in the implementation of numerous ESA authorizations.

We understand the Species Conservation Charge Formulas and Costing is intended to based on costs proponents may have otherwise incurred in fulfilling permit conditions. However, the formula provides costs that seem to be considerable higher (more than double) what many proponents pay to implement overall benefit measures. We are supportive of the Species at Risk Conservation Fund as it has the potential to benefit species at risk in Ontario. However, if the costs to opt into the fund are not reasonable, it is likely to be underused. Some areas where the formula appears to be overestimate include:
- Land costs:
 For ESA authorizations for activities in an urban areas or other municipalities with high land costs, overall benefit typically occurs in nearby municipalities with lower land costs. As such, basing the cost on the municipality of the activity overestimates the cost.
 Overall benefit is often on lands that are otherwise constrained from development and therefore have lower land value.
 Outright purchase of lands for overall benefit measures is rare. Lands are typically leased at lower costs.
- Beneficial Action
 The cost to implement overall benefit actions appear to be higher than industry standard.
 There are typically efficiencies in maintenance and monitoring for larger benefit projects. For example, there is little difference in cost in planting, maintaining and monitoring 5 or 20 butternut, s the time for logistics, mobilizing to site and reporting are the same. Consider adding efficiencies to the formula.
- Benefit Ratio
 There is an overall benefit already built into the formula (i.e. 20:1 replacement ratio for each butternut over 15cm DBH). As such, an overall benefit is achieved without this multiplier.
 We understand that opting into the fund should cost more than a proponent fulfilling permit conditions themselves. However, the 1.5 multiplier on top of the exaggerated land and beneficial action cost results in a calculation that is considerable higher than what it would cost to fulfilling permit conditions.

Consideration of the level of impact
- In an ESA authorization, the level of impact is the benchmark for which overall benefit measures are developed. The higher the level of impact, the more action is needed to achieve an overall benefit to the species, contributing to its conservation and recovery in the province. The level of impact could be considered in the formula, including:
- Category of habitat could be considered. For example, impacts to Blanding’s Turtle Category 1 habitat (nesting or hibernation) could required more overall benefit compensation than impacts to Category 3 (movement).
- Temporary vs permanent impacts to habitat.