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?
[poll id="6"]The mitigation banking industry is at a pivotal moment. Regulatory shifts, evolving interpretations of the 2008 Mitigation Rule, and increasing pressure from alternative mitigation programs are reshaping the landscape. In this environment, a unified voice is not just beneficial—it’s essential. That’s where membership in the National Environmental Banking Association (NEBA) makes a difference.
Read MoreAccording 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.
Read More