Habitat Conservation Plans provide limited insight into the cost of complying with the Endangered Species Act

Katie C. Surrey, Gwenllian Iacona, Becca Madsen, Christian Newman, Leah R. Gerber

Research output: Contribution to journalArticlepeer-review

2 Scopus citations


The Endangered Species Act (ESA) mandates protection for listed species, prohibiting intentionally adverse “take” by both public and private activities. The requirements can be perceived as a costly regulatory burden, although minimal understanding of the costs of compliance actions may exacerbate the perceived burden. This has potential consequences for ESA effectiveness and species recovery. We developed a framework to identify when compliance costs could be incurred in a project and then analyzed projected cost data from published Habitat Conservation Plans (HCPs) using this framework. We found that across HCPs, the projected costs reported were incomplete and difficult to interpret with inconsistent reporting across documents. Within the 43 HCPs that had utilizable cost data, the majority of projected costs (77%–97%) were incurred by implementation of ESA compliance activities. Of these, 46% of expected implementation costs were for monitoring efforts for project-scale HCPs, while 81% of implementation costs for large-scale projects were for compensatory mitigation actions. Our results provide a first attempt at analyzing the cost of ESA compliance actions using HCPs. However, we found that costs reported in HCPs tended to be opaque and incomplete, underscoring the need for standardization of cost reporting to better support understanding of ESA compliance costs.

Original languageEnglish (US)
JournalConservation Science and Practice
StateAccepted/In press - 2022


  • cost estimation
  • listed species
  • policy compliance costs
  • private costs
  • threatened species recovery

ASJC Scopus subject areas

  • Nature and Landscape Conservation
  • Global and Planetary Change
  • Ecology
  • Environmental Science (miscellaneous)


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