
There has been much recent discussion around proposed changes to the 2008 Mitigation Rule (Rule). There have even been some claiming to represent our industry who are proposing to re-elevate Permittee-Responsible Mitigation in the hierarchy of mitigation forms under the Rule. Some are proposing to do away with Inter-Agency Review Teams (IRTs) and still others are trying to propose that cash be the only approved mechanism for mitigation bank financial assurances.
NEBA’s simple question is this: Do you think substantive changes in the 2008 Mitigation Rule need to be made?
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