New Rules – overview of major themes (see New Corps/EPA wetland mitigation regulations).
National Mitigation Banking Association Session – discussion about ensuring that new Rules are implemented & consistently. NMBA will watchdog. NMBA interest in expanding conservation banking beyond CA. NMBA interest in informing other potential legislation affecting the miti industry (conservation banking, WQT, Nat Resources Damage, C issues, stacking).
Highlights from Q & A’s during the Day
Q: Concern voiced over ACOE’s (lack of) motivation to efficiently administer WL miti banking review b/c of lack of OMB performance measures.
A: ACOE has proposed new perf measures to OMB.
Q: Concern voiced that ACOE/EPA staff stretched thin.
A: Acknowledged, trying to make more info avail online (RIBITS) that will increase public info & ensure continuity of records with staff turnover. Also more Interagency Review Team training so members can review efficiently, having the info they need.
Q: Questions regarding stream miti.
A: ACOE *already* requires miti for impacts to streams, Rule doesn’t make this a new thing. Next big step is to develop guidance on quantifying debits for impacts & credits for restoration.
Q: Several questions/discussions regarding stacking
A: ACOE, EPA clear there should be no double-dipping. Comment from audience: USDA Secretary previously announced that farmers who receive $ from Farm Bill programs (CRP, etc.) can also receive payments for ecosystem services. Basic argument for stacking: if an impact is required to mitigate for several diff types of impacts (WL, habitat) on one piece of land, a mitigation site should be able to mitigate for several diff types of impacts. Basic argument against: if it’s acre per acre-type mitigation, you just can’t sell the same acre twice. Concession: if mitigating based on function, and can show/document “uplift”, maybe could stack. Stacking WL and WQ – probably not. If bank were “double-dipping”, ACOE would stop the bank from selling any more credits.
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