Timeliness of Processing Mitigation Banking Instruments (MBI’s)

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).

1. Strict Application of the Timeline to improve timeliness of processing Mitigation Banking Instruments (MBI’s)
2. Transparent Reporting of the MBI Process with RIBITS and/or ORM2 to improve transparency
3. Use of Common Project Management Tools (i.e.; agreed-to Gantt timeline with known milestones/deadlines) to enable better coordination
4. Improved leadership by USACE Project Managers within the Inter-Agency Review (IRT) Process in application of their position as LEAD to the IRT
5. Use of Templates and Standard Operating Procedures for MBI’s and other documents required by the process to improve transparency, timeliness and coordination

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.

Download Full Letter

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