NMBA Comment Letter

NMBA Comment Letter on USFWS Revisions to Mitigation Policy

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Comments Sought on U.S. Fish & Wildlife Service Mitigation Policy

As an NMBA member, you may be aware that two years ago NMBA submitted comments to the US Fish & Wildlife Service regarding its mitigation policy. We are pleased to announce that FWS has followed NMBA’s recommendations and has released proposed revisions to its mitigation policy.

NMBA is drafting suggestions to make the policy better and seeks comment from NMBA members.

All NMBA members are encouraged to provide the following:

  1. General comments on the policy (what should the tone be, how do you feel about it, etc.)
  2. Specific language you would like to have changed (please provide the new language you are proposing)

Timeline for comments

4.13     Deadline for comments from the membership

4.18     Draft letter complete and sent to the membership

4.22     Deadline for final comments from the membership

4.26     Final draft letter sent to NMBA Board of Directors

4.28     NMBA Board of Directors Meeting

5.9       Comment period closes

To assist you in developing comments, please find the following documents on the NMBA website:

Proposed Revisions to the U.S. Fish and Wildlife Service Mitigation Policy; Notice

2014 NMBA Recommendations for U.S. Fish and Wildlife Service Mitigation Policy

– U.S. Fish and Wildlife Service FAQ on mitigation banking

– 3/7/16 White House press release covering several conservation initiatives

There are two ways to submit comments:

  1. Use this Google form
  2. Email them directly to info@mitigationbanking.org

Please be sure to have your comments to us by close of business Wednesday, April 13.

Thank you in advance for continuing to shape this very important mitigation policy.



James Parker and Will McDow

Emerging Markets Committee Co-Chairs

National Mitigation Banking Association

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FWS Policy Fed Reg 8 Mar 2016

FWS Policy Fed Reg 8 Mar 2016

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FINAL USFWS Mitigation Policy NMBA White Paper

FINAL USFWS Mitigation Policy NMBA White Paper

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2016 Mitigation Banking Conference – Register Now for Savings

A “Must Attend” for those in environmental restoration, ecosystem markets & environmental banking — the National Mitigation & Ecosystem Banking Conference® offers an expanded program May 10-13, 2016 in Fort Worth, Texas.  BIG savings when you register by Early Bird Deadline January 25Click here for more info

At NMEBC 2016, you’ll get the latest on the new Presidential Memos, initiatives and programs, emerging markets, science, practice & policy.  Plus — More education and training included! Connect with leaders and experts from private companies, environmental organizations, state, local & federal agencies  including CEQ, DOI, USACE, EPA, FWS, NOAA, NRCS, FS, FHWA, BLM and others

  • For those new to this industry, start with the Basics of Banking
  • Those who want more in depth, choose to attend one of the Advanced courses on Stream or Conservation Banking
  • Learn how to use NMBA’s Mitigation Analyst (includes a trial subscription) and RIBITS
  • Field Trips are offered Tuesday and Friday
  • Exhibits and posters are held throughout the event starting on Wednesday

>Read More on NMBA’s Associate Member Discount Voucher

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Restoration Industry Announces Support for New Natural Resource Investment Center

WASHINGTON, D.C. – December 15, 2015 – U.S. Secretary of the Interior Sally Jewell today announced that the Department of Interior (DOI) will establish a Natural Resource Investment Center to spur partnerships with the private sector to develop creative financing opportunities that support economic development goals while advancing the Department’s resource stewardship mission.

Jewell outlined that the Center will use market-based tools and innovative public-private collaborations to increase investment in water conservation and critical water infrastructure, as well as promote investments that conserve important habitat in a manner that advances efficient permitting and meaningful landscape-level conservation.

As long-time advocates of viable, high-quality environmental markets, the National Mitigation Banking Association (NMBA) is grateful for the ongoing work of the Department and for the Secretary’s commitment to enjoining private investment to protect, and restore America’s critical natural resources. “Our business members across the U.S. continue to express strong support for the work of the federal family in recognizing the importance of leveraging public-private partnerships to balance our nation’s use of natural resources while ensuring that future generations will have access to the same resources,” said Wayne White, president of NMBA.

Today, privately funded resource restoration and preservation activities employ Americans in all 50 states who do everything from planting vegetation into beach dunes to establishing natural grasslands in disturbed areas. “This latest announcement from the Department means that there will be even greater opportunities to increase private sector participation in restoration of our lands and water,” White said.

Wayne White, President
National Mitigation Banking Association


National Mitigation Banking Association is a national association brings together leaders who are committed to a unique concept for restoring and conserving America’s wetlands, streams, and other habitat resources through sound economic and environmental practices. Established in 1998 NMBA promotes federal legislation and regulatory policy that encourages mitigation banking as a means of compensating for adverse impacts to our nation’s environment.

Media Contacts:
Wayne White
(202) 457-8409

Michael Sprague
(202) 457-8409


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Another Benefit of Your Membership in NMBA

Members, please remember that the Association completed form-style letters on the topics of the ‘Mitigation Hierarchy’ and the ‘Use of Preservation for Mitigation’ early in 2015 and the Board of Directors adopted a streamlined process for executing these in response to requests from membership.  Thanks to the hard work of the Rules and Legislative Committee of NMBA, these letters have begun to be deployed in response to specific member concerns across the U.S.  If you are wrestling with one of these issues in your region, district, or state, we encourage you to contact the association info@mitigationbanking.org to learn more.   Members – Review NMBA’s processing strategy HERE.

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NMBA Associate Member registration voucher offered this year! 

All 2016 Associate Memberships include one $300 voucher from NMBA toward your employees’ 2016 MEBC conference registration.  To qualify you must become an Associate Member of NMBA before registering for the conference.  For details, visit www.mitigationbanking.org or www.mitigationbankingconference.com

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Open Letter to Media and Membership

Open Letter to Media and Membership following on the November 3, 2015 U.S. Presidential Memorandum

On August 31, 1910, Theodore Roosevelt spoke these words to an audience in Kansas. “I recognize the right and duty of this generation to develop and use the natural resources of our land but I do not recognize the right to waste them, or to rob, by wasteful use, the generations that come after us…”

Over 100 years later, the United States continues to try and find a balance between current use of the natural resources of our land and ensuring that future generations have access to the same resources. Today, land restoration and preservation activities employ Americans in all 50 states who do everything from planting beach dunes to establishing natural grasslands in disturbed areas. However, much of this activity takes place due to direct government spending on the local, state and federal levels. There is great opportunity to increase private sector involvement and investment in land restoration.

Recently, a Presidential Memorandum was released that encourages private investors to restore public land and natural resources through mitigation banks, where investors can perform compensatory mitigation for credits that can be used to offset development impacts. The National Mitigation Banking Association is an association of entrepreneurial companies that purchase land and waters to restore them and create these mitigation banks. More than 100 conservation banks and more than 1300 wetland and stream mitigation banks have been approved, restoring and protecting over a million acres of private land. NMBA members have raised more than a billion private dollars that can be put to work, in cooperation with federal agencies, for conservation. By creating a marketplace for land restoration credits, the economic uses of public resources can be balanced with their long-term stewardship. The land can be productively used, but not used up.

Wayne White, President
National Mitigation Banking Association

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Presidential Directive on Mitigation Celebrated

WASHINGTON, D.C. – The National Mitigation Banking Association (NMBA) applauds this week’s Presidential Memorandum encouraging private investments in America’s natural resources. This policy directive will ensure equivalent standards for all forms of mitigation and a preference for mitigation performed in advance of impacts, creating greater market certainty and environmental outcomes. “This Presidential Memorandum strikes the right balance between economic development and restoring the nation’s natural resource endowment,” NMBA President Wayne White said. “With implementation of this directive, NMBA members look forward to increased private capital investment in green infrastructure under an invigorated public private partnership. Full implementation will cut permitting times for development projects, reduce government cost, and increase predictability in the building and replacement of critical infrastructure.”

NMBA represents the private investment sector of the $25B natural restoration industry supporting 220,000 jobs across the country – jobs ranging from Ph.D. scientists and engineers to nurserymen and forestry workers. Our members provide the highest quality mitigation available for wetland, stream and other impacts by relying on Universal Principles of Mitigation. NMBA advocates for viable, high-quality environmental markets to protect and restore important, scarce, and sensitive natural resources as offsets to unavoidable impacts associated with economic development.

We believe that when properly framed by sound government policy, private investment in restoration and conservation is a powerful tool to meet today’s growing environmental challenges. These include offsets for impacts to endangered species habitat, natural resource damages from oil and chemical spills, diminished water quality, and the need for green infrastructure protection to combat extreme weather events including storms, floods, and drought. Additionally, strengthened compensatory mitigation policies applied to public lands will create net gain of publicly-owned natural resources. With this new policy we expect to double the pace of private investment from the 2014 rate of 85,000 acres per year to 200,000 acres per year within the next five years.

Restoration and conservation investments require predictability to attract the innovation and capital of third-party providers, as well as to provide certainty to consumers of compensatory mitigation credits. NMBA endorses today’s Presidential Memorandum and will continue to work diligently with federal agencies to maintain and repair our nation’s precious natural resources.
Media Contact:
Wayne White, President
(202) 457-8909

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