Martin Doyle reporting in the Duke University Nicholas Institute for Environmental Policy Solutions, analyzes the incentives created by the In Lieu Fee (ILF) Program model, summarizing ‘there are financial and environmental risks that are unique to ILF Programs.’
The 2019 report, highlights common and systemic shortcomings or flaws in ILF programs and notes necessary safeguards to protect the Clean Water Act (CWA) ILF Programs and the Endangered Species Act (ESA) Programs.