The National Environmental Banking Association (NEBA) shares the interest of the U.S. Army Corps of Engineers (USACE) in creating permitting efficiency for all those regulated by Section 404 of the Clean Water Act while allowing the necessary development and energy exploration our country requires. We support President Trump’s August 15, 2017 Presidential Executive Order on Establishing Discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure which calls for a more transparent, timely, and coordinated process for environmental review and permitting for energy, transportation, and other infrastructure projects.
Accordingly, NEBA respectfully submits the following suggestions intended to help specifically with the timely processing of Mitigation Banking Instruments (MBI's).
This letter follows on NEBA's meeting with senior USACE representatives in March of 2018 and in response to the agency's request. Read Full Letter to USACE.
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.
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