Yes, there's certainly concern about such models in the environmental community. There are worries that “pay to slay” models may not be appropriate when the amount of habitat being destroyed is large and can be restored or replaced in an equivalent or improved way. Our interest in that sort of model is for those small projects for which an individual offset wouldn't make sense. You couldn't do an offset the size of this table here to build something that's going to be beneficial to fish.
In that situation, what's happening right now and why there aren't good outcomes of this lengthy review process for small projects is that the harm is allowed: This amount of habitat can be destroyed, but nothing is done to compensate for it or to gradually build some sort of restoration fund to address it.
Some way of collecting fees, pooling them and dedicating them to restoration would help to ensure that there's a bit of a trade-off between allowing that project to proceed and being able to restore habitat in a meaningful way that's beneficial to fish and fish habitat.