NEBA has been receiving increasing notice from members across the U.S. of proposed and in-process ill-formed and non-compliant 'mitigation banking projects'. These efforts would seem to seek new precedents and to discard long-held basic concepts underpinning "mitigation" and "mitigation banking."
Uniformly, these projects enable environmental damage without truly offsetting the known environmental impacts using 'cheap and fast' 404 credits.
'Mitigation' in this basic context must involve the replacement of lost/damaged resources and their associated environmental functions. Such mitigation is attained by creating ecological 'lift' and 'additionality' on project sites (called mitigation banks), then preserving and protecting in-perpetuity those restored resources. There are many thousands of established, successful mitigation banks across the U.S. today with a history of having done just that.
There are thousands of mitigation banks across the United States
A new 'Race to the Bottom' appears to be underway, supported by some in government and industry who want fast access to cheap offsets for permitted unavoidable impacts to the Nation's waters. This pursuit despite the fact that the costs to our shared environment of 'fast and cheap' are obvious. It means reduced investments in environmental restoration, less site monitoring, fewer site protections, reduced project maintenance - ultimately increased project failures. AND, with this new race to the bottom, the mitigation banking industry itself stands to damage its standing. One need only look as far as voluntary carbon credits to understand the risk and see the cautionary tale of good ideas turned by greed into greenwashing.
In the coming year, the National Environmental Banking Association will address head-on these new challenges being brought on our environment and our industry. In upcoming posts, we'll take a careful look at how the voluntary carbon market helped to destroy itself, we'll profile several unusual 'mitigation banking projects', and we'll continue to advocate for high-quality environmental mitigation in Congress and beyond- as the Trusted Voice of the Mitigation Banking Industry.
If you work in mitigation banking, ecological restoration, or ecosystem markets, there’s one event you can’t afford to miss this fall: 2026 NEBA Annual DC Fly-InSeptember 15–17 in Washington, DC Hosted by the National Environmental Banking Association (NEBA), this annual event brings industry leaders face-to-face with federal policymakers to influence environmental legislation and regulation that directly impact
Read MoreThe National Environmental Banking Association (NEBA) is pleased to announce the proposed Board of Directors slate that will be presented to members for election during the Annual Membership Meeting on September 16, 2026, as part of the NEBA Annual DC Fly-In in Washington, D.C.The proposed slate is:JEFF OYEN, ChairKEVIN MORAN, Vice-ChairKENNETH JESENSKY, Secretary/TreasurerROBERT SPOTH, Board
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