Environmental Review Toolkit
Accelerating Project Delivery

Step 6: Develop crediting strategy
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The goals of Step 6 are:

  1. Identify practical habitat measurements that can be used to set mitigation goals.
  2. Establish habitat measurements on which to base tools such as advanced mitigation banks, programmatic permitting, and ESA Section 7 consultation.
  3. Create agreements on the use of offsite mitigation and out-of-kind mitigation where necessary.
  4. Informed adaptive management and updates of the cumulative effects analyses.
  5. Enable measurement of gains and losses of ecological functions, and benefits and values associated with categories of transportation improvements or specific project-related impacts.
  6. Characterize project mitigation benefits related to currently unregulated services, such as carbon storage or late season water provision.
  7. Provide a means to track progress toward regional ecosystem goals and objectives.

Mitigation Credit Precedents. This step is perhaps the most challenging in that it requires a clear understanding of the habitat needs of affected species and definition of measures of the functions and values of the habitats to be mitigated.

Begin by gathering existing mitigation crediting protocols, such as for wetlands or stream mitigation where the mitigation ratios are specified based on functions and values according to state law (for example, wetland rapid assessment methods). Also, collect precedent mitigation approaches/ratios for as many of the priority habitats identified in Steps 2 through 4 as possible, such as from NEPA documents and Section 7 ESA taking permits. Preferably these precedents originate within the state or planning region, but also search adjacent areas if none are available. (Depending on the variability of the ecosystem, the applicability of the protocols borrowed from other regions may need to be tested for applicability to local conditions.) The resource agencies ought to be able to provide these precedents and policies within their jurisdiction. The point is to identify measurement criteria for each affected resource on which to base the mitigation credit system. For example, wetlands may be categorized using a rapid assessment method, and mitigation ratios established based on the categories. Also, the density of suitable habitat trees may determine the value of a habitat for a particular rare species and define mitigation ratios.

Establishing a Mitigation Credit Agreement. Next, confirm that the resource agencies have the authority and the will to establish rules for mitigation crediting for each priority resource and willingness to enter into memorandums of agreement. This will require the authority of high-level managers to ensure enforcement.

Ecological knowledge will evolve, and the doubt of resource agencies about habitat requirements will make them reluctant to set hard and fast mitigation ratios for particular species in perpetuity. The ratios may slanted to the conservative side; that is, more mitigation may be specified to compensate for lack of knowledge, and may have expiration dates, much like CWA Section 404 Nationwide Permit conditions. Even mandated mitigation ratios, such as for wetlands according to state law, can change. So, even though not all of the future unpredictability can be removed from the process, it is reasonable to assume that agreements can be reached with the resource agencies, provided the mitigation plan can meet regulatory requirements and conservation priorities, at least for foreseeable short-term mitigation requirements, such as for projects in the state transportation improvements program or transportation improvement plan.

Documentation. Document regulatory assurances to grant credits and long-term agreements.


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Step 1 -
Build and strengthen collaborative partnerships and vision
Step 2 -
Characterize resource status and integrate natural environment plans
Step 3 -
Create a regional ecosystem framework (conservation strategy + transportation plan)
Step 4 -
Assess effects on conservation objectives
Step 5 -
Establish and prioritize ecological actions
Step 6 -
Develop crediting strategy
Step 7 -
Develop programmatic consultation, biological opinion or permits
Step 8 -
Implement agreements, adaptive management, and delivery projects
Step 9 -
Update regional ecosystem framework and plan
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