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?
The National Environmental Banking Association (NEBA) is a professional organization focused on integrity, transparency, and accountability, promoting the highest standards in the environmental banking industry. Its members include mitigation banking professionals, industry vendors, and government officials, ensuring cost-effective outreach and support. Joining NEBA benefits you and your business, helping to grow the industry and improve
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According to US Army Corps of Engineers (USACE) data, there are more than 8 million Advance Mitigation Credits sitting on the ledgers of the many dozens of In-Lieu Fee (ILF) Programs across the United States today, nearly all of which are exempt from any financial assurance that the mitigation projects will actually be performed.
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