adr-sml/docs/07-fees.md

07 — Fee research and recommended rate card

Authority: AGENTS.md §3 D8 (publish a full rate card) and D14 — a single published rate card, confirmed by Pouya 2026-08-26 (Q4/Q14/Q15-Q17 answered).

The card below is confirmed and buildable. The research that produced it is retained for context, but the figures are decisions now, not recommendations — see "Set by Pouya" below. This is business pricing information, not legal or financial advice.

Research date: 2026-08-26. All figures below are plus HST unless stated.

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The Ontario market, measured

The regulated floor

Ontario's mandatory mediation tariff (Rule 24.1) sets the roster rate. ADR Chambers publishes it as $600 to $825 depending on the number of parties, covering "one half hour of preparation time per party and up to three hours of mediation."

This is the floor of the market, and it is a floor with a signal attached: pricing at or near it reads as roster-filler work.

Published hourly bands

ADR Chambers, across its full roster:

	Range
Mediators	$150 – $750 / hour "depending on the experience of the mediator"
Arbitrators	$250 – $800 / hour

Plus, on the arbitration side: an $800 filing fee, a $800 venue fee for a hearing room and one breakout room, and $400 per additional room.

Published practitioner rate cards

Four Ontario practitioners publishing real numbers:

Practice	Half-day	Full day	Overtime	Notes
Patey — Tier 1, PI / insurance	$800 (3 h)	$1,200 (6 h)	$250 / h	Multi-party 3 h $1,200; multi-party full day $2,400; pro forma to 1.5 h $500
Patey — Tier 2, estate / employment / civil	$1,200 (3 h)	$2,400 (6 h)	$375 / h	Pre-mediation caucus $175 flat
Zuber — video	$1,800 (3 h)	$2,800 (6 h)	$500 / h	+$500 per additional party
Zuber — in person, GTA	—	$4,000 (6 h)	$500 / h	Eastern Ontario $3,500. Prep and travel included
Carroll — Ottawa	$1,750 (incl. 1.5 h prep)	$3,000 (incl. 2 h prep)	$400 / h	Arbitration day rate $3,000

What the shape of that data says

Three observations that drive the recommendation.

1. The market is already segmented by matter type, not only by seniority. Patey runs two published tiers off the same neutral. Insurance and PI work clears around $800–$1,200 a day; estate, employment, and civil work clears $2,400 for the same hours. This is the single most useful structural fact in the research.
2. Prep time is a pricing lever, disclosed differently by everyone. Carroll bundles named hours (1.5 h and 2 h). Zuber bundles prep and travel. Patey bundles neither and sells a caucus separately. Bundling explicitly reads as more confident and removes an argument later.
3. Additional parties are always priced, never absorbed. $300–$500 per party beyond two is the norm, and a four-party construction mediation is materially more work than a two-party one.

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Where this practice should sit

Not at the floor. Pouya's stack — JD, an operating role inside a litigation and ADR boutique, Q.Med and Q.Arb held, and a working engineering career — is not a junior generalist profile. Entering at roster rates would anchor him into SABS volume work and make the commercial rate very hard to raise later. Published rates are close to unrecoverable once set: raising them looks opportunistic, discounting privately never becomes public knowledge.

Not at the top either. $4,000-a-day in-person GTA rates belong to neutrals with twenty years of name recognition. Asking that without an independent track record invites a comparison he loses.

The position is the upper-middle: at or just above Patey Tier 2, just below Zuber and Carroll. That reads as credentialed and serious, priced to be taken seriously, not yet a marquee name — which is exactly true.

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The confirmed rate card

Set by Pouya on 2026-08-26 (D14). This is the card. Build /fees/ from it.

He declined the two-tier structure and set one rate for all mediation matters. All figures plus HST.

Mediation — all matters, one rate

Item	Fee
Half day — up to 3 hours of session. Fee includes up to 2 hours of preparation	$2,000
Full day — up to 6 hours of session. Fee includes up to 3 hours of preparation	$4,000
Each party beyond two	$500
Overtime, per hour	$500

⚠️ THE TWO ROWS ABOVE WERE AMBIGUOUS UNTIL 2026-08-31, AND THE AMBIGUITY WAS IN THIS DOCUMENT RATHER THAN IN ANY COPY — Q58, ruled by Pouya. They read "Half day — up to 3.5 h, including 2 h preparation" and "Full day — up to 7 h, including 3 h preparation". Read literally that makes 3.5 the whole billed envelope and the time in the room 1.5 h. Pouya's ruling: "3.5 was meant as the TOTAL time committed, of which 2 is preparation — leaving 1.5 hours in the room… The intended reading is the market's, and my wording obscured it."

What found it was arithmetic, not reading: 3.5 and 7 are exactly 2×, which they would not be if preparation sat inside them, because preparation does not scale with session length. Under the literal reading the room time was 1.5 h and 4 h, which is not 2× anything.

The corrected numbers are corroborated by this file's own research table, one section up — which is the reason they are 3 and 6 rather than a round guess:

• Patey publishes 3 h half-day and 6 h full-day in both tiers.
• Zuber publishes 3 h video half-day and 6 h full day.
• ADR Chambers' roster rate covers "one half hour of preparation time per party and up to three hours of mediation" — preparation counted separately from a three-hour session, which is the shape this card now has.

Pouya: "Selling 1.5 hours of room time as a half day would be an outlier nobody would recognise." ⚠️ One provenance note, because this file is the authority on money: he recalled Patey and Zuber as publishing "all or part of 3 hours". The extract above records their hours but not that phrase, so the hours are what this file relies on — do not quote the phrase as theirs.

THE PREPARATION ALLOWANCE IS CAPPED, AND MUST BE PUBLISHED AS CAPPED. "Including up to 2 hours of preparation." Never "including 2 hours", which reads as a flat entitlement, and never "preparation included", which sells an uncapped one. See §All parameters confirmed below.

Consequences, applied 2026-08-31: FEES.mediation.*.hours in src/data/site.ts means the session and is corrected 3.5 → 3 and 7 → 6, and /fees/ is unblocked for build step 9 on the question Q58 asked.

✅ WHERE OVERTIME BEGINS — RULED. Q59, Pouya, 2026-08-31. IT RUNS FROM THE SESSION CAP: the fourth hour of a half day, the seventh of a full day. Not the billed envelope. The two candidates were the session cap (3 h / 6 h) and the envelope (5 h / 9 h), and this file could not choose between them — a fee term is a fact we do not have, not an inference. A first pass at this paragraph asserted the session cap as applied fact and adversarial-reviewer struck it in the same change set that wrote it; the strike was right, and the ruling has now supplied the value the strike was waiting for.

⚠️ AND THE RULING'S SECOND HALF IS THE PART THAT MATTERS MOST, BECAUSE IT ANSWERS THE ARITHMETIC ANOMALY BELOW RATHER THAN RESTATING IT. His words:

"a full day reserves the day; half-day overtime is subject to availability"

The full-day fee buys the DAY, not six hours of it. That is what a reader doing the arithmetic in the table below is missing: 2000 + 500 × 3 = 3500 against 4000 looks like a $500 penalty for booking properly, and it is not — the two are different products. Half-day overtime depends on the time after the session still being free, and on a booked day it is not.

So the reservation sentence is published ADJACENT TO THE OVERTIME ROW on /fees/, not in a footnote, and it is rendered from FEES.mediation.reservation rather than retyped. Structurally the same rule as PROCESS_FRAMING beside the five timings under Q43: a reader who takes the number and skips the framing has read a different offer.

⚠️ THE ANOMALY IS NOT CLOSED BY THIS. The gap is still in D14's own figures — the half-to-full step is $2,000 and three hours of overtime is $1,500 — and the reservation point explains what the gap buys without removing it. It stays on §12 R5's 12-month review, and §Recorded dissent below carries the table for that review to test against.

And the reason it cannot be quietly chosen is that the choice is visible in the arithmetic. Take the trigger as the session cap. The half-day route costs 2000 + 500 × max(0, n − 3); the full-day route is flat $4,000 until hour 6 and 4000 + 500 × (n − 6) after it:

Session run to	Book a half day + overtime	Book a full day	Gap
3 h	$2,000	$4,000	$2,000
4 h	$2,000 + 1 × $500 = $2,500	$4,000	$1,500
5 h	$2,000 + 2 × $500 = $3,000	$4,000	$1,000
6 h	$2,000 + 3 × $500 = $3,500	$4,000	$500
7 h	$2,000 + 4 × $500 = $4,000	$4,000 + 1 × $500 = $4,500	$500

Booking a half day and paying overtime is cheaper at every length — by $2,000 at three hours, narrowing to $500 from six hours on — and the full-day rate is never the cheaper choice. The gap is in D14's figures rather than in the trigger: the half-to-full step is $2,000 and three hours of overtime is $1,500.

⚠️ A FIRST PASS AT THIS PARAGRAPH GOT THE ARITHMETIC WRONG, AND WRONG IN THE DIRECTION THAT MATTERED. It generalised the full-day route as 500n + 1000 for all n ≥ 3, which is only valid from hour 6 — the route is flat until then — and concluded "$500 cheaper at every length". The real spread is up to four times larger and is largest at three to five hours, which is the band a half-day booking actually overruns into. The document's own table contradicted the formula three lines above it. Found by adversarial-reviewer on round 2, in the change set that wrote it. A measurement is a claim about your instrument, and a formula is an instrument.

Moving the trigger out to the 5 h / 9 h billed envelope does not fix it and is not uniformly better either — the gap stays at $2,000 through five hours and is $1,500 at six, worse than the session-cap trigger there, but it closes to zero from nine hours on, where the session-cap trigger holds a permanent $500. So the two triggers trade one band against another and neither removes the anomaly. It was never a defect this file could fix by picking a trigger — which is why the trigger went to Pouya and the step went to R5.

Both halves came back. He ruled the session cap AND supplied the reservation point, which is the answer the arithmetic alone cannot give: the table compares prices for two things that are not the same product. Read the table as a price comparison and the full-day rate looks strictly worse; read it knowing a full day reserves the day and half-day overtime is subject to availability, and the $2,000-to-$500 spread is the price of certainty rather than a mistake. The anomaly stays on R5 because the size of that spread is still a judgement about D14's figures, and it is largest at three to five hours — the band a half-day booking actually overruns into.

Arbitration

Sole, party-appointed and co-arbitration appointments in commercial matters are all accepted now — AGENTS.md §4 Offerings carries a row for each [verified 2026-08-26 — Pouya]. ("in commercial matters" added 2026-08-28: the line was unscoped, and every §4 arbitration row is scoped commercial with family arbitration separately NOT OFFERED — Q39's struck universal.) (This line previously read "sole appointments follow the Q.Arb designation", which understated the offering, and carried a caveat against a since-closed Q36.)

⚠️ /fees/ HAS NO CREDENTIALING DISCLOSURE TO MAKE (amended 2026-08-29). This paragraph required that whatever the page says about arbitration "must state the Q.Arb stage plainly alongside it — §4 Offerings, 'neither half may be dropped'". Q.Arb is held and that condition is dissolved. /fees/ is unbuilt (step 9), so this is the one place the amendment lands before the page exists rather than after — do not build the page against the struck form. 03-content-spec.md's model sentence is now the scope half only — the stage half was struck with the paragraph this one used to point at.

Item	Fee
Hourly	$500
Hearing day	$4,000
Documents-only / expedited, flat — simple	$6,500
Documents-only / expedited, flat — complex	$9,500

No tribunal-secretary rate. Removed by Pouya. Do not reinstate it, and do not offer tribunal-secretary work on the site.

Med-arb — billed by phase

⚠️ INTERIM. Set by Pouya 2026-09-03; reviewed at the twelve-month fee review, AGENTS.md §12 R5. It is stamped interim because it is the only rule on this page set after the card was published rather than with it, and because it prices an offering by reference to two other rows — if either moves at R5, this moves with them and nobody will be reminded by a figure changing.

The rule, and it carries no figure of its own:

• Med-arb is billed by phase. The mediation phase is charged at the mediation rates above. If the matter proceeds to arbitration, that phase is charged at the arbitration rates above.
• There is no separate med-arb fee.
• The additional-party and cancellation terms apply to each phase as they apply to that process on its own.

Why this rule exists at all, because a fee page does not usually need one. /fees/ opens "Every figure is on this page", and AGENTS.md §4 Offerings carries a Med-Arb row that this document priced nowhere. The promise was therefore wider than the card — the D20 cutover claims pass, finding 10. Pouya closed it by pricing the offering rather than narrowing the promise, which is the more expensive of the two fixes and the one that leaves the page saying the stronger thing.

⚠️ DO NOT GIVE MED-ARB A RATE ROW. A med-arb figure would be a fourth price for a process that is already priced twice, and the first thing it would do is disagree with one of them. The rule is expressed as a pointer to the two cards above on purpose; that is what keeps the count of published figures the same as the count of published rates.

⚠️ "AS THEY APPLY TO THAT PROCESS ON ITS OWN" IS NOT "TO BOTH PHASES". The additional-party fee is a mediation row; the arbitration card has no equivalent. The wording above invents nothing. "The additional-party term applies throughout" would invent an additional-party charge in the arbitral phase, which no ruling has set.

FEES.medArb in src/data/site.ts holds the three sentences and /fees/ renders them, so the rule is not retyped into the template.

Other services — hourly

Early neutral evaluation, dispute-system design, and pre-dispute technical advisory: $500 / hour.

✅ PUBLISHABLE — Q46(a) closed 2026-08-28. All three §4 Offerings rows read PUBLISHABLE on Pouya's second ruling, so the line item may go on /fees/. Read the §4 ENE row first: gate 1 is closed as [Pouya's stated basis 2026-08-28], not [verified] — there is still no source in docs/reference/ — and the framing constraints in docs/01 §/practice/ travel with the offering onto this page. In particular, ENE is priced as an assessment delivered to both parties, and nothing on /fees/ may read as a rate for advising one of them.

THREE services, not four. settlement counsel is struck and must not be priced — AGENTS.md Q42, Pouya 2026-08-27, correcting his own entry in docs/01:

"Settlement counsel acts FOR a party in negotiation. That is a partisan role, and putting it on a site that (a) sells neutrality and (b) asserts no licensure under D13 is wrong twice over: it undercuts the brand's central claim and it edges into acting for a client."

A struck row exists in §4 Offerings so the decision is findable. Same treatment as the tribunal-secretary rate above, and for a related reason: a rate on a fee page is an offer.

Cancellation — adopted as recommended

When	Fee
More than 30 days before	No fee. Disbursements only
15 – 30 days before	50% of the booked fee
Fewer than 15 days before	100% of the booked fee
Rescheduled with a new date fixed at the same time	No charge
Reserved time filled by another matter of equal or greater value	Waived

Terms to state on the page

• All fees plus HST.
• Shared equally between the parties unless they agree otherwise in writing.
• Payable on rendering; interest on overdue accounts at 5% per annum.
• Video and in-person at the same rate. Do not discount remote sessions — the preparation is identical, and discounting teaches the market that the session is the product.
• Travel outside the GTA billed separately or bundled at a stated day rate.

All parameters confirmed

Q15, Q16, and Q17 were closed on 2026-08-26. Preparation time is bundled and must be stated on the page, IN HOURS AND AS A CAP — "including up to 2 hours of preparation", "including up to 3 hours of preparation". Do not quietly fold it into the session figure, and do not drop the "up to": the allowance is capped, so the unqualified form sells an uncapped one. At these rates, saying preparation is included is the selling point, not a footnote.

(The "up to" was added 2026-08-31 with Q58's ruling. This paragraph previously prescribed the flat form, and /for-parties/ shipped it — the one page written for a reader with no counsel to catch it.)

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Recorded dissent — for the 12-month review (R5)

⚠️ SECOND ITEM FOR R5, ADDED 2026-09-04 — MED-ARB, AND IT IS NOT A DISSENT. It is here because R5 names this section as where its items live, and the med-arb rule was stamped INTERIM against R5 in §Med-arb above and written into no list the review actually reads. The rule is derived — each phase at the rates for that process, no figure of its own — so moving any mediation or arbitration number at R5 moves the med-arb price with it, silently, with no diff on the med-arb rule. Nothing else on this page has that property. Check it against whatever the review does to the two cards above.

Claude recommended a two-tier card; Pouya set a single rate. The reasoning is recorded here so the 12-month review has something to test against, not to re-open a settled decision.

Where the single rate lands relative to the measured market:

Segment	Published market, full day	This card
Insurance / SABS / LAT	~$1,200 – $2,400	$4,000
Commercial / civil / estate	~$2,400 – $3,000	$4,000
Established GTA in person	~$3,500 – $4,000	$4,000

$4,000 is at the ceiling of the published Ontario market — level with Zuber's in-person GTA rate, and roughly three times the going rate for the insurance and SABS segment.

The consequence worth watching. The strategy brief (§IV.7) identifies accident-benefits and LAT mediation as the highest realistic near-term volume, flowing directly from the firm's existing practice. At $4,000 a day that segment is priced out. This is a coherent choice — a premium specialist position that forgoes volume — provided the volume was not being counted on. If early appointment flow is slower than expected, the SABS tier is the first place to look, and reintroducing a second tier is a cleaner fix than cutting the headline rate.

What makes the rate defensible. $4,000 for a neutral who reads the contract, the code, and the System Impact Assessment is a fair price. $4,000 for a generalist is not. The rate and /practice/technology/ are load-bearing for each other, which is an argument for shipping them in the same release — and for the Insights section carrying real technical depth rather than process explainers alone.

One thing the single rate gets right. Published rates are close to unrecoverable, and it is far easier to add a lower tier later than to raise a headline rate. Setting the ceiling first and discounting privately preserves more optionality than the reverse.

And a fourth item, added 2026-08-31: the half-day-plus-overtime route is strictly cheaper than the full-day rate, at every session length. This is the one item in this section that is arithmetic rather than judgement, so it is the one the review can settle without new market data.

Session run to	Half day + overtime	Full day	Gap
3 h	$2,000	$4,000	$2,000
4 h	$2,500	$4,000	$1,500
5 h	$3,000	$4,000	$1,000
6 h	$3,500	$4,000	$500
7 h	$4,000	$4,500	$500

(Session-cap trigger; the trigger itself is AGENTS.md Q59, ruled and closed 2026-08-31 — this line said "open" for a day after line 144 of this same file recorded the ruling.) The cause is the relationship between two of D14's own numbers rather than anything about the trigger: the half-to-full step is $2,000 and three hours of overtime is $1,500. Any trigger leaves a gap; the envelope trigger closes it only from nine hours on.

What the review has to decide is whether that is a choice. It is defensible as one — a full-day booking buys certainty and a reserved diary, and a client who knows they need six hours may prefer to pay $500 for not having to watch the clock. It is also exactly the kind of thing counsel comparing published cards finds in under a minute, and this practice's whole pricing argument is that the card is published in full and means what it says. The lever, if it is not a choice: either raise the overtime rate so the routes converge, or narrow the half-to-full step. Both are rate moves, which is why they belong here and not in a footnote to the card.

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Sources

• ADR Chambers — Mediation Fees
• ADR Chambers — Roster Rate / Mandatory Mediations
• ADR Chambers — Arbitration Fees
• Patey Mediations — Rates & Cancellation
• Zuber Mediation — Fees
• Carroll Mediation — Rates & Cancellation
• O. Reg. 451/98 — Mediators' Fees (Rule 24.1)