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PeerBasis
Compensation Comparability Determination

Endangered Species Protection Agency

Executive Director / CEO

EIN 811939514
UT · NTEE D30
FY ending 2024-12-31
June 9, 2026

This analysis benchmarks the total compensation of Jen Hughston-pelky, Executive Director / CEO ($12,000) against every comparable organization that fit the selection criteria — 19 in total — drawn systematically from IRS Form 990 filings, not a hand-picked subset.

Compensation sits at approximately the 21st percentile of comparable organizationsbelow the typical range for comparable organizations

Benchmarked executive: Jen Hughston-pelky — reported title “General Manager”, a direct title match to the Executive Director / CEO role.

How comparable organizations were selected

19 organizations qualified on sector, size, and geography 19 within the band form the benchmarked peer set.

Distribution of comparable compensation

$1,477 total compensation of comparable organizations → $89,322 $12,000
$8,80410th
$15,42225th
$32,980Median
$54,81975th
$74,17690th
$12,000This org · 21st
p10$8,804
p25$15,422
p50$32,980
p75$54,819
p90$74,176
$12,000

Comparable organizations

Each figure is Form 990 Part VII columns D + F (reportable pay plus other compensation and benefits; column F may include amounts from related organizations), normalized to UT cost of living (BEA RPP, 2023) and to its filing year (CPI-U); the reported amount is on each linked 990.

OrganizationStateRevenueMatched titleComp
(reported)
Comp
(adjusted)
FY
Shark Team One Corp FL$164,046 Director $18,720 $17,690 2023
A Place Called Hope Inc CT$169,929 President $36,000 $32,980 2024
Operation Game Thief Inc TX$178,259 Executive Director $71,801 $72,249 2023
Hummingbird Society AZ$116,587 Ceo $36,025 $33,851 2024
Animal Services Of Richmond Inc VA$193,278 President $60,195 $60,862 2022
Southeast Alaska Indiginous Transboundary Commissi AK$193,997 Director $50,717 $48,775 2023
Saving Our Sharks Foundation Inc PA$197,171 Treasurer - Former $13,500 $13,154 2024
Alturas Wildlife Sanctuary Inc FL$109,294 President $10,000 $9,450 2023
Marine Education Research And Rehab DE$205,183 Executive Di $84,000 $80,363 2024
Minnesota Conservation Officers Association MN$208,894 President $18,605 $17,962 2024
South Carolina Wildlife Partnership SC$210,253 Executive Director $85,116 $89,322 2023
Merritt Island Wildlife FL$214,153 Executive Di $1,609 $1,477 2024
Foundation For North American Wild MT$215,222 Executive Di $25,002 $27,110 2023
Wildlife Restoration Foundation VA$219,834 President And Board Member $41,760 $39,396 2024
Mountain Top Wildlife WA$220,300 President $22,600 $19,770 2024
Illinois Raptor Center IL$223,801 Program Dir $43,116 $42,640 2023
Harmony Wildlife Rehabilitation TN$229,761 President $6,056 $6,220 2024
Arctic Fox Daily Wildlife Rescue Inc NY$230,049 President $13,500 $11,919 2024
Amargosa Land Trust CA$230,137 Executive Director $83,615 $72,629 2023

Comp (reported) is the figure on each organization's Form 990 (columns D + F); Comp (adjusted) normalizes it to UT cost of living and 2024 dollars. Click any organization to verify the figure on ProPublica.

Methodology

Comparable organizations were drawn from electronically filed IRS Form 990 returns and matched on sector (NTEE code), budget (a size-adaptive revenue band that tightens as the organization grows), and geography (same-state first, broadening only when too few peers qualify); every organization within the band forms the peer set. To compare fairly across regions and years, peer compensation is normalized to UT cost of living (BEA Regional Price Parities, 2023) and to the subject's filing year (CPI-U). The figure benchmarked is Form 990 Part VII, Section A, columns D + F — reportable pay plus other compensation, benefits, and deferred amounts (column F may include amounts from related organizations) — with the chief executive matched by role. Related-organization amounts (column E) and institutional trustees are excluded. Full methodology: peerbasis.org/methodology.

Sample, role match & sensitivity

Sensitivity — the subject's percentile under alternative compensation definitions:

BasisSubject percentile
Total compensation (D + F), cost-of-living + inflation adjusted — the PeerBasis default21st
Total compensation (D + F), as reported (no adjustments)16th
Reportable pay only (column D), adjusted21st
All sources (D + E + F), adjusted21st

If the percentile moves materially across these definitions, the result is sensitive to methodology choices, and the board should weigh which basis best fits its facts.

Rebuttable presumption of reasonableness · 26 CFR 53.4958-6

Compensation paid by a tax-exempt organization is presumed reasonable — shifting the burden to the IRS — when three requirements are met. This report supplies the comparability data for the second. The board should record the following in its minutes concurrently with its decision:

Draft board minutes — executive compensation

  1. The compensation of the Executive Director / CEO (Jen Hughston-pelky) was approved in advance by [the Board / Compensation Committee], composed of members with no conflict of interest with respect to the arrangement.
  2. Prior to its determination, the authorized body obtained and relied upon appropriate comparability data, namely the PeerBasis Compensation Comparability Determination dated June 9, 2026, comparing compensation against 19 similarly situated organizations (Same NTEE sector (D30), nationwide + budget 0.67–1.5× revenue).
  3. The authorized body determined that total compensation of $12,000 is reasonable (approximately the 21st percentile of comparable organizations) and documented the basis for this determination concurrently, on [date], by a vote of [__ for / __ against].

Sources: IRS Form 990 e-file data (apps.irs.gov); IRS Business Master File (NTEE classification). Every figure traces to an original public filing — click any organization above to verify it on ProPublica. PeerBasis is a service of Prismind Analytics; its methodology is published, was commissioned for independent adversarial review, and discloses its own limitations. This report is comparability data to support a board's good-faith determination under IRC 4958; it is not legal or tax advice. Generated by PeerBasis on June 9, 2026.