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Environmental Review Toolkit

Eco-Logical Webinar
Mitigation Banking, Conservation Banking, and In-Lieu Fee Programs: Mitigation Options Using the Eco-Logical Approach

Thursday, September 8, 2011
3:00 - 4:30 PM Eastern


  • Corrie Veenstra, FHWA Office of Project Development and Environmental Review
  • Mike Ruth, FHWA Office of Project Development and Environmental Review
  • Steve Martin, U.S. Army Corps of Engineers
  • Deblyn Mead, U.S. Fish and Wildlife Service
  • Brad Livingston, Oregon Department of Transportation

Moderated by Haley Peckett, Volpe National Transportation Systems Center/USDOT

PDF Version [2.4 MB]

Table of Contents

FHWA Overview of Mitigation Requirements and Activities

Mitigation Banks and In-Lieu Fee Programs

Conservation Banking: A Market-Based Incentive Program for Conserving Species & Habitat

ODOT's Mitigation and Conservation Banking Program Case Study: Whetstone Vernal Pool Mitigation and Conservation Bank

FHWA Overview of Mitigation Requirements and Activities

Slide 1: Mitigation Banking, Conservation Banking, and In-Lieu Fee Programs: Mitigation Options Using the Eco-Logical Approach

September 8, 2011

Slide 2: Purpose of today's presentation

  • Promote the Every Day Counts (EDC) initiative on the use of mitigation banking and in-lieu fee programs
  • Introduce mitigation banking, in-lieu fee programs, and conservation banking
  • Provide an example of a successful mitigation banking and conservation banking program

Slide 3: Shorten Project Delivery: Use of In-Lieu Fee (ILF) and Mitigation Banking

In projects that will impact waters of the United States (wetlands, for example), the permitting process under Section 404 of the Clean Water Act currently constitutes a major component of the project development and delivery process. This initiative proposes expanded use of in-lieu fees and mitigation banking currently allowed under existing statute, FHWA regulations, State law and court decisions in order to save time and expedite project delivery.

Slide 4: How can we meet this EDC initiative?

  • Utilize existing banks and ILF programs
  • Develop Department of Transportation (DOT) (single client) banks or ILF programs

Slide 5: DOT's purchase credits at existing banks or in-lieu fee programs

Advantages Disadvantages
  • Relinquish mitigation requirement
  • Saves time
  • Less temporal loss of resource
  • Close out construction contract
  • There may not be any banks or in-lieu fee programs where DOTs need credits.

Slide 6: DOT's setting up their own banks or in-lieu fee programs

Advantages Disadvantages
  • The DOT establishes the price of the credits
  • DOT knows where their mitigation needs are
  • States may not have up front/seed money to start bank or in-lieu fee
  • Long term management of site
  • Time to establish the bank or in-lieu fee

Slide 7: FHWA Policies

Regulations Guidance and Executive Order
  • Federal-aid Eligibility for Long-Term Management Activities in Wetland and Natural Habitat Mitigation (Oct 3, 2008)
  • Federal-aid Eligibility of Wetland and Natural Habitat Mitigation (March 10, 2005)
  • Executive Order 11990—Protection of wetlands

Slide 8: Speakers today

  • Steve Martin, USACE-IWR
    • Mitigation banking
    • In-Lieu Fee programs
  • Deblyn Mead, USFWS
    • Conservation banking
  • Brad Livingston, Oregon DOT
    • Case study on Oregon DOT's Conservation Banking program

Slide 9: FHWA Headquarters Contacts for Mitigation Banking, Conservation Banking, and In-Lieu Fee Programs

Corrie Veenstra
Mike Ruth

Slide 10: Advanced Environmental Mitigation Requirements

Environmental mitigation activities are “intended to be regional in scope, and may not necessarily address potential project-level impacts.”
- 23 CFR 450.104

Image: Photograph of a small river in a grassy valley, with tree-covered mountains in the background

Slide 11: Funding Advance Mitigation

Reimbursable Maintenance

Image: Photograph of a pond surrounded by green vegetation

Slide 12: Advance Mitigation Partnerships

Image: A topographic map of Elkhorn Slough, California, and a smaller map of California marked with the location of Elkhorn Slough

Slide 13: Advance Mitigation Successes

South Carolina DOT —
Carolina Bays Ecosystem Initiative
Image: Photograph of a small river in a grassy flatland
Mississippi DOT —
Deaton Ecological Preserve
Image: Photograph of a swamp with bare trees

Slide 14: San Diego Association of Governments (SANDAG) Multi-species Conservation Plan/Transnet Environmental Mitigation Project

  • Transnet (1/2 cent sales tax) funds transportation projects including Mitigation Project:
    • Funding to acquire and manage habitat lands.
    • Buy land early and bank for future mitigation needs.
    • Up to $200 million in savings.
Image: Photograph of a bird looking down at a pair of eggs in a scrape nest in the sand. The eggs are camouflaged by being colored like the sand.

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Mitigation Banks and In-Lieu Fee Programs

Most of the slides in this presentation are branded with US Army Corps of Engineers "Building Strong" logo.

Slide 15: Mitigation Banks and In-Lieu Fee Programs

Steve Martin
Environmental Scientist
Institute for Water Resources (IWR)
September 8, 2011

Image: Institute for Water Resources logo
Image: Two photographs are fit into the upper left quadrant of a circle that is situated in the lower right corner of the slide: two hikers in a lush green forest and a view across a grassy wetland.

Slide 16: Banks and ILFs are

  • 1 or more sites where resources are restored, established, enhanced, and/or preserved to offset permitted impacts
  • Governed by an instrument & overseen by an Interagency Review Team (IRT)
  • 3rd Party mitigation – Sponsor assumes responsibility for the mitigation
  • Permittees acquire mitigation credits

Slide 17: Benefits

  • Reduced risk & uncertainty
  • More efficient compliance
  • Often greater planning and scientific effort
  • May streamline permitting, by reducing effort evaluating mitigation proposal

Image: Photograph of a restoration project showing rows of plantings in a wetland

Slide 18: Drawbacks

  • Failure may result in substantial loss of aquatic resource function
  • Migration of functions and services
  • Extensive effort in instrument development & oversight

Image: Photograph of a receded river bank with lush vegetation

Slide 19: Differences Between Banks & ILFs

  • Mitigation banks:
    • Public or private sponsor
    • Site secured & project initiated in advance of debits
    • Corps has no authority over bank expenditures
  • In-lieu fee programs:
    • Government or non profit conservation organization
    • Fees often received before implementing project
    • Corps approves project funding

Slide 20: Benefits of Each

  • Banks
    • Advance site identification
    • Credit release linked to performance
    • Compensation in advance of impacts
  • ILFs
    • Mitigation when there are no banks
    • Compensation for a range of resources
    • IRT can direct site selection in a watershed approach
    • Sponsor interest in conservation

Image: Photograph of a lengthy tidal pool with areas of tall reeds

Slide 21: Drawbacks of Each

  • Mitigation Banks
    • Site selection in advance of agency review
    • Less likely to be developed in small or weak markets
  • In-lieu fee programs
    • Risk of mitigation not being provided
    • Temporal lag between permitted impacts and project implementation

Slide 22: Preference Hierarchy for Mitigation 33 CFR 332.3(b)

  1. Mitigation bank credits
  2. In-lieu fee program credits
  3. Permittee-responsible mitigation using a watershed approach
  4. On-site and/or in-kind permittee-responsible mitigation
  5. Off-site and/or out-of-kind permittee-responsible mitigation

Slide 23: Watershed Approach to Mitigation 33 CFR 332.3(c)

  • Existing watershed plans
  • Without suitable plan, use available information on condition and needs
  • Consider landscape position and sustainability
  • Provide suite of functions
  • Level of information and analysis commensurate with impacts

Slide 24: Distribution of bank sites

Image: Satellite photograph of North America, with the contiguous United States and Alaska populated with colored markers at bank site locations

Slide 25: Bank Sponsorship

Sponsor % of sites % of area
Single user 19 14
Commercial 81 86

Image: A colored 3D pie chart showing the breakdown of the 86% of the bank sponsorship area that is commercially-sponsored – Private Commercial: 63%; Public-Private: 31%; Public Commercial: 5%; and Private Non-profit: 1%.

Slide 26: Instrument Development Process

  • Draft prospectus
  • Prospectus & Public Notice
  • Draft instrument
  • Final instrument
Image: Two pages of the Gum Log Mitigation Bank Instrument: the document cover page is overlaid on top of the Table of Contents page. The cover page includes a photograph of a green field in springtime bordered by budding trees with vegetation in the foreground.

Slide 27: 3rd party mitigation instruments include:

  • Service area(s)
  • Accounting procedures
  • Sponsor assumption of mitigation responsibility
  • Default and closure provisions
  • Reporting protocols
  • Other information deemed necessary

Slide 28: Service areas

Geographic area served by bank or ILF

  • Based on watershed, ecoregion, physiographic province, or other suitable geographic area
  • One or more 8-digit HUCs
  • May consider economic viability
  • Basis for service area location & extent must be documented in the instrument

Slide 29: Maps

Image: Colored map of North Carolina labeled “USGS 8-Digit Cataloging Units – North Carolina”
Image: Black and white map of the counties along a portion of Nebraska's eastern border showing two Wetland Mitigation Service Areas along the Missouri River
Image: Map of Missouri with two wetland mitigation areas highlighted in color
Image: Map of a section of northwest Virginia with a mitigation area's Bank Site and Service Area outlined
Image: Black and white map of the St. Louis, Missouri, area with Madison County shaded and the Madison County Mitigation Bank pinpointed by a red dot

Slide 30: Credit Release Schedule Example

  • 20% Initial Release
  • 15% Hydrologic restoration
  • 15% 2nd incremental release
  • 15% 3rd Incremental release
  • 15% 4th Incremental Release
  • 20% Final Release (approx Year 10)
Image: Photograph of a field of tall grass and wildflowers at the edge of a forest

Slide 31: Additional requirements for In-lieu fee programs

  • Description of ILF program account
  • Compensation planning framework
  • Advance credits, by service area
  • Advance credit fee schedule, by service area
  • Method for determining fees and credits
Image: Photograph of the cover of the Mississippi Delta - In Lieu Fee Program, which includes a collage of nature photographs

Slide 32: Compensation Planning Framework includes:

  • Service area (watershed-based)
  • Analysis of historic aquatic resource loss & current condition
  • Threats to aquatic resources & how they are addressed
  • Aquatic resource goals & objectives
  • Prioritize mitigation projects
  • Use of preservation
  • Description of stakeholder involvement
  • Long-term protection and management
  • Evaluation and reporting
Image: Photograph of a field worker in a mitigation area inputting data into a handheld device

Slide 33: NC EEP Fee Schedule

Fee Category Unit Fee per Unit -
Higher Fee HU
Fee per Unit -
Lower Fee HU
Riparian Buffer Sq.ft $0.96 $0.96
Stream Lin.ft $344 $260
Non-riparian wetland Acre $45,752 $23,528
Riparian wetland Acre $63,414 $35,853
Coastal wetland Acre $155,998 $155,998

Slide 34: ILF Program Advance Credits

  • Cap on advance credits specified in instrument
  • Advance credits available once instrument approved
  • As projects produce released credits, advance credits are fulfilled & available again

Slide 35: ILF project implementation

  • Land acquisition and improvements must be initiated by 3rd growing season after first advance credit is acquired
Image: Aerial photograph of a winding stream in an open, rural field

Slide 36: More information

Steve Martin (IWR)
(757) 201-7787

Corps Regulatory Program

Regulatory In-lieu fee & Bank Information Tracking System

Image: Colored illustration of a green tree frog

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Conservation Banking: A Market-Based Incentive Program for Conserving Species & Habitat

Slide 37: Conservation Banking: A market-based incentive program for conserving species & habitat

U.S. Fish & Wildlife Service
Endangered Species Program

Image: Logo of the US Department of the Interior
Image: Logo of the US Fish and Wildlife Service
Image: Collage of four images: a photograph of the document Endangered Species Act of 1973 is layered on top of three photographs: an orange tree frog, two purple wild irises, and the head of a brown bear

Slide 38: Today's Discussion...

  • What are conservation banks?
  • How do conservation banks differ from mitigation banks?
  • Why establish conservation banks?
  • When and where to establish conservation banks?
  • How the program works –
    • Service areas
    • Credits & Debits
    • Combination conservation-mitigation banks (ESA+CWA)
  • Conservation banking considerations – FHWA and DOTs

Slide 39: What is a conservation bank?

A site or suite of sites containing natural resource values that are conserved and managed in perpetuity for specified endangered, threatened, or other at-risk species and used to offset impacts occurring elsewhere to the same type of resource (e.g., species)

Off-site and In-kind

Slide 40: Conservation banking is not...

a substitute for avoidance and on-site minimization of effects on listed species or other sensitive resources and is only for use with projects that would otherwise be permitted.

Banking does not facilitate development of habitat.

Slide 41: Purpose and Goals

  • Provide an economically effective process that provides project proponents with options to offset unavoidable adverse impacts to listed and other at-risk species
  • Aid in recovery of listed species
  • Aid in preventing future listing of other at-risk species
  • Reduce the Service's ESA sections 7(a)(2) and 10(a)(1)(B) workload

Slide 42: Purpose and Goals

  • Conservation banking should result in a net species conservation benefit
  • Conservation banking should contribute to Service and partners regional conservation planning efforts including:
    • Landscape/ecosystem scale plans (take advantage of/get involved with Landscape Conservation Cooperatives)
    • Consider climate change model projections when selecting bank sites
    • Consider both green and grey infrastructure

Slide 43: Legal Authorities

  • Endangered Species Act
    • Section 7 – Interagency Cooperation
      • 7(a)(1) – carry out programs for the conservation of listed species
      • 7(a)(2) – consult on listed species
      • 7(a)(4) – conference on proposed species
    • Section 10(a)(1)(B) – Habitat Conservation Plan
    • Section 2 – provide a means whereby the ecosystems upon which endangered and threatened species depend may be conserved...

Slide 44: Legal Authorities

  • Fish and Wildlife Coordination Act
  • National Environmental Policy Act
  • USFWS Conservation Banking Guidance
  • other statutes, regulations and policies

Slide 45: Why establish conservation banks?

Image: Photograph of a San Joaquin Kit Fox
- Courtesy of Heather Bell

Slide 46: Conservation banks vs. individual, on-site mitigation

  • Avoid piecemeal mitigation and small indefensible “avoidance areas”
  • Contribute to existing and planned community conservation strategies (e.g., Habitat Conservation Plans, State Wildlife Action Plans)
  • Streamline the permit process for all

Slide 47: Conservation banks vs. individual, on-site mitigation

  • Better Assurances
    • Real Estate (perpetual conservation easement)
    • Management & Monitoring (long-term management plan, with measurable monitoring criteria and thresholds for action, remediation process)
    • Financial (non-wasting endowment to fund implementation of the management plan, operation & maintenance at the bank)
  • Greatly reduces agency time spent tracking compliance and monitoring mitigation sites
  • Reduces the need for enforcement actions

Slide 48: How the program works—

Conservation banking is optional & used in conjunction with:

  • Individual consultations
  • Programmatic consultations
  • Conferences
  • HCPs
Image: Photograph of a Gopher Tortoise
- Courtesy of Randy Browning

Slide 49: Service Areas

  • A service area is the geographic area within which credit trading occurs for a particular conservation bank
    • service areas are determined by USFWS
    • service areas are biologically justifiable areas based on species recovery units, watersheds, species population structures, or other ecological considerations
  • A bank may have more than one service area when multiple credit types are available

Slide 50: Credit Determination Methodology

  • Should be based on species conservation strategy/framework; focus on species recovery
  • Methodology should work in conjunction with adverse effects determinations at impact sites
  • Ranges from simple to complex—keep it as simple as possible at the bank user-end
  • Credit methodologies can be used to encourage landowner participation in targeted areas

Slide 51: Credit Determination Methodologies

  • X acres = 1 credit
  • 1 mating pair of individuals = 1 credit
  • 1 relocated individual = 1 credit
  • Specific methodology in which the credit score is based on multiple criteria; some of which may be weighted
  • Multiple habitats with species overlaps that generate different credit values per acre for different species
  • Existing/restored/enhanced habitat with different credit values
  • Combination of CWA and ESA credits

Slide 52: Combination ESA-CWA Banks


  • Better serve regulated public where aquatic resources and endangered species overlap
  • More holistic approach to stewardship
  • Typically larger sites with multiple habitat types
  • Better use of agency resources
  • Potential to reduce agency efforts tracking compliance and monitoring mitigation sites


  • Generally a longer approval time
  • Crediting metrics can be complicated

Slide 53: Bank Establishment Process

Mitigation Banking
  • Prospectus
  • Public review & comment
  • Mitigation Bank Instrument (MBI, BEI)
    • Development Plan
    • Management Plan
    • Conservation Easement
    • Bank Closure Plan
  • IRT review
  • Agency approval
Conservation Banking
  • Proposal (Prospectus)
  • Conservation Bank Agreement (CBA, CBEI)
    • Development/Restoration Plan (if needed)
    • Management Plan
    • Conservation Easement
    • Bank Closure Plan
  • CBRT review
  • Agency approval

Slide 54: How long does it take to establish a conservation bank?

  • It depends on a number of things, including:
    • Experience of bank sponsor and previous history with banking
    • Completeness of prospectus
    • Complexity of bank
    • Level of adherence to FWS banking templates and guidance
    • FWS workload
    • DOI Solicitor workload
  • The range: 3 months to 7 years

Slide 55: What about establishing single client banks for DOT use only?

Image: Photograph of a Valley Elderberry Longhorn Beetle straddling the edge of a leaf
- Courtesy of Theresa Sinicrope Talley

Slide 56: Single client banks vs. use of private banks — advantages of each...

Establish own DOT-use only banks
  • Credits readily available once bank is established and fully funded
  • Control credit cost
Use private banks
  • Transfer of liability for success of mitigation
  • DOT has no responsibility for success of bank site
  • Greater service area opportunities (generally)
  • More credit types available (generally)
  • No bank start-up costs for DOT

Slide 57: Questions?

  • Deblyn Mead
  • U.S. Fish and Wildlife Service
  • National Conservation Banking Coordinator
  • 703-358-1898

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ODOT's Mitigation and Conservation Banking Program Case Study: Whetstone Vernal Pool Mitigation and Conservation Bank

The slides in this presentation are bordered on the left with a blue-tinted photograph of a whitewater stream in the woods

Slide 58: ODOT's Mitigation and Conservation Banking Program Case Study: Whetstone Vernal Pool Mitigation and Conservation Bank

Presented by Brad Livingston, Wetlands Program Coordinator
Eco-Logical Webinar, September 8, 2011

Image: A section of the State of Oregon seal showing an etching of a covered wagon
Image: Logo of the Oregon Department of Transportation

Slide 59: Bank Development Fundamentals:

  1. Eco-Logical-integrated transportation and conservation planning
  2. Needs Assessment/Market Analysis
  3. Scope and Scale: Watershed or Ecoregion
  4. Site selection consistent with Stewards goals

Slide 60: Planning Horizon

  • 20 years ideally, FHWA
    • Population and transportation growth projections
    • Development trends
  • ODOT constraints:
    • Uncertainty with projects beyond STIP planning
    • Uncertainty with project $ allocation
    • Limited to highway needs, not a broker

Slide 61: Needs Assessment

  • Retrospective data and long term projections
  • ODOT Project Delivery Structure
  • Stakeholder Involvement
  • Geographic extent
    • Klamath Mountains Ecoregion (KME)
    • I-5 CORRIDOR

Slide 62: Map

Image: A map of Oregon's Region 3 Mitigation Needs Assessment with color-coded circles showing the locations of Current Projects, Future Projects, and projects Already Debited From VPMB. There are also color-coded lines to delineate the VPMB Service Area, County borders, City Limits, and Highways.

Slide 63: Service Area Rationale

  • Sliver impact to roadside resources over broad geographic area
  • On-site within Right of Way may not be appropriate, generally
    • Perpetual disturbance
    • Future improvements
    • Conflicts with maintenance requirements
  • Stormwater facilities on-site

Slide 64: Klamath Mountains Ecoregion (KME)

  • Geographically Distinct
  • Recognized Ecological Boundary with Diverse Geology and Climates
  • Botanical Treasures, Floristic Crossroads
    • Approx. 4,000 Plant Species in OR
    • Approx. 2,000 Plant Species in KME*
    • Approx. 500 Endemic Species* (*ODF 2001)
Image: Photograph of a field of unique vegetation on the edge of a forest

Slide 65: “Vernal Pool Complex (VPC) Preservation is essential to preserve biological integrity on a landscape scale”*

  • Ecoregion priority
  • Rarity and support of endemics
  • Development pressure
  • Regulatory issues
  • Difficulty replacing
  • Biocomplexity


Image: Photograph of a field of various grasses with a grove of trees in the background

Slide 66: A testament to VPC biocomplexity: Dumontia oregonensis

“three ephemeral ponds near Medford, Ore., have yielded a once-in-a-century taxonomic surprise: a new species of water flea that represents an entirely new family - a missing link of sorts - of water fleas”
- Devitt 2004

Image: Illustration of an enlarged Dumontia oregonensis
Courtesy of Kandis Elliot

Slide 67: Site Selection Due Diligence

  • Focus on rare habitats &/or watershed priorities
  • Research wildlife action plans, rare species habitats, wildlife connectivity and adjoining land uses
  • Collaborate with resource agencies early
  • Collaborate with potential stewards early

Slide 68: ODOT Bank Site Attributes

Image: Map of Medford, Oregon, area showing the ODOT Mitigation Site

Map created by Cara Conroy, TNC AmeriCorps volunteer

Slide 69: Map

Image: Satellite image of the ODOT Mitigation Site labeled “ODOT Vernal Pool Bank” with vernal pool areas outlined in green

Slide 70: Figure 6: Vernal Pool Distribution and Assessment

Image: Grayscale topographic map of the ODOT Mitigation Site

Slide 71: Map

Image: Page taken directly from The Oregon Conservation Strategy, prepared by ODFW, February 2006. It shows a map of the Klamath Mountains Ecoregion in southwest Oregon with Conservation Opportunity Areas shaded and numbered KM1-KM13. Map sections are colored by land ownership type: Federal, State, and Private.

Slide 72: The Nature Conservancy's (Steward) Role

Ecological Assessment:

  • Habitat condition past and present
  • Performance standard baseline
  • Impact of historic disturbances
  • Status of current threats
  • Status of key management species
  • Long Term Steward
Image: Photograph of a grassy field dotted with wildflowers

Slide 73: Performance Standards: Vernal pool habitat

TARGET Standard Condition (90% CI) Performance
absolute cover of exposed substrate < 75% 4.35% (+1.81) Meets
key native vernal pool species ≥ 15 24 species Meets
relative invasive cover ≤ 15% 18.13% (+6.12) Probably Not
relative native cover > 70% 50.10% (+9.35) No

Image: Collage of five photographs:
A vernal pool edged with green vegetation
The same vernal pool, later in the season: dried out, with plants growing where there once was water
A Lomatium cookii (Cook's desert parsley) plant, with yellow flowers, growing out from a pile of rocks
A plant whose flowers are all purple, yellow and white
A Limnanthes floccosa ssp grandiflora (woolly meadowfoam) plant with white flowers
Image: Photograph of a vernal pool
Courtesy of Lyndia Hammer

Slide 74: Performance Standards: Endangered species

TARGET Standard Condition (90% CI) Performance
LIFLGR plants > 200 289 LIFLGR counted Meets
LOCO plants ≥ 200 No LOCO found at site Not present
BRLY pool occupancy > 40% 12.08% occupancy No
BRLY shrimp relative to baseline ≥ 95% No baseline In process...

Image: Photograph of two Dumontia oregonensis (water fleas)
© George Turner 2000
Image: Photograph of Limnanthes floccosa ssp grandiflora (woolly meadowfoam) plant with white flowers
Courtesy of Belinda Lo

Slide 75: Vegetation Sampling

Vegetation sampling for performance standards:

  • ¼ meter2 quadrats
  • 20 vernal pool
  • 20 upland
Image: Map of the Vegetation Sampling Quadrat Locations shaded to show Habitat Areas: Prairie, Swale, and Woodland. The map is overlaid with a grid whose rectangles are labeled 0-19, each having two small squares: red for the Upland location and blue for the Vernal Pool location.

Slide 76: Accounting

  • State revolving fund reimbursed by projects
  • Credit receipts submitted with permits
  • Credit ledger maintained
  • Annual reporting

Slide 77: Challenges

  • Scope, Scale and Priorities
  • Regulatory Flexibility
  • Service Areas
  • Project Schedule and timelines
  • Conservation Banking

Slide 78: Lessons Learned

  • Engage Steward, Agencies early
  • Define milestones
  • Document decisions
  • Acknowledge risk
  • Keep credit/debit procedures simple
  • Select sustainable site

Slide 79: –FIN–   QUESTIONS?

Brad Livingston, Wetlands Program Coordinator

Image: Photograph of a vernal pool in the middle of summer: dried out in a field lush with grasses, shrubs, and trees

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For questions or feedback on this subject, please contact Mike Ruth at 202-366-9509.