NEBA Comments on Proposed Rulemaking – 2008 Mitigation Rule

Comments were respectfully submitted by the Board of Directors of the National Environmental Banking Association (NEBA) to the U.S. Army Corps of Engineers and U.S. Environmental Protection Agency in early August at request of the Agencies and in response to changes being considered for the 2008 Mitigation Rule.

The 2008 Mitigation Rule represented a huge leap in creating a framework to support privately funded mitigation banks. Since that time, banks have proven that the environmental banking program is the most successful effort in history to permanently restore degraded environments. It is extremely rare for a bank to fail, and mechanisms are built in to help ensure success. Banks are not subsidized by taxpayers and add to overall tax receipts across the country.

There is a growing volume of acreage, as a result of this program, that is restored to high quality performance standards, well managed and permanently protected with no burden or impact to taxpayers. Banking is the only solution to environmental impacts that does not in some way involve increased cost to taxpayers.

Since the 2008 Rule, many lessons have been learned, and NEBA’s Board is on the receiving end of countless comments about how it could be improved. We firmly believe that, with a few adjustments, environmental banking could become the long-awaited resolution to the alarming continuation of environmental destruction. A solid set of rules that investors can rely on will vastly increase the amount of private funds pouring into environmental banks and the environment.

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