The fund and agency proposed…

The fund and agency proposed in the regulation are reasonable on their own, but what seems questionable is offering the choice between beneficial actions to protect species, and paying into the fund, because these are not equivalent actions when it comes to species protection.

In the first choice (beneficial actions), the goal is to directly preserve the individuals of the species and habitat as best as possible. This action is immediate and reactive. In the second choice (paying into the fund), the goal is to provide a benefit to the broader species over a longer timescale. It is longer term, and indirect. You cannot trade off immediate action for some hypothetical future action to protect the species, which may or may not have the equivalent conservation value. Long term, large scale approaches are important, but they are not a equivalent substitute for preserving/restoring individuals and habitats at a given location.

There may be some situations where paying into the fund may be more effective than beneficial actions, such as if actions are likely to have a low chance of success. In these situations, offering the fund as a choice could be useful since it may be more beneficial to the species than action at a given site.

In reality, both strategies must be employed for successful conservation, and it would be welcome to see the proposed mandate of the fund/agency taken on by the MECP regardless. But as it is proposed, the fund does not seem like a viable alternative to beneficial actions, because the two choices are not equivalent types of actions, and the option should only be available for cases where the success of beneficial actions are demonstrably low.

Other comments
- Butternut Category 3 trees: number allowed to be impacted should remain at 0