Commercial Mitigation Banking

Banks offering compensatory mitigation credits for general use, whether sponsored by public entities or private firms, have been referred to as "commercial banks" or "credit supply ventures." Privately sponsored commercial banks are known as "entrepreneurial banks." Since 1992, numerous privately-sponsored ventures have been proposed and several implemented.

The first entrepreneurial bank was the Millhaven bank (also known as WET, Inc.) which was permitted by the Corps' Savannah District, December 1992.

In July 1993, the Florida Wetlandsbank in Pembroke Pines became the second entrepreneurial bank to be permitted. Florida Wetlandsbank has since been permitted by the South Florida Water Management District, the Broward County Department of Natural Resources Protection, and the South Broward Drainage District, in addition to the Corps.

Among the earliest publicly sponsored banks were Bracut Marsh and Astoria Airport. The Bracut March Bank, sponsored by the California Coastal Conservancy, was constructed in 1981. The Astoria Airport Bank was sponsored by the Oregon Division of State Lands and was constructed in 1987.

IWR canvassed the Corps Districts in late summer 1995 to get an update on the nature and number of commercial ventures now in operation or under planning. More than 25 commercial ventures were in operation and at least 50 more were in some stage of planning.

A variation of the commercial banking theme is the fee-based credit supply venture (also referred to as in-lieu fee programs). Fees are collected from permit applicants for unavoidable wetland losses. The fees accumulate in a dedicated fund typically with no clear timetable for replacement of wetlands. Although this program is especially criticized by some in the environmental community, its infrequent implementation to date has typically been for compensation for small wetland losses, e.g., a few acres to fractions of an acre, that might otherwise have been permitted without compensation if no such credit supply program were available.

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