 Common mitigation banking misconceptions MISCONCEPTION: Wetland mitigation banking will facilitate more wetland destruction. FACT: It is now commonly accepted by the resource agencies responsible for protection of the environment that wetland mitigation banks are more environmentally beneficial than the previous piecemeal mitigation policies. Permittees must still follow the CWA Section 404(b)(1) guidelines that require avoidance and minimization to the greatest extent practicable. If anything, the use of mitigation banks may increase the amount of functional wetland acreage due to greater than 1 to 1 mitigation requirements. MISCONCEPTION: The cost of using a mitigation bank can be prohibitive. FACT: In all cases, using a wetland mitigation bank will be more cost-effective than on-site or off-site mitigation. This is because mitigation banks include many hidden costs of conventional wetland mitigation. These include wetland design, permitting, conservation easements, construction, land value, follow-up maintenance to ensure mitigation success and ongoing monitoring for up to 10 years. Use of a mitigation bank can provide a known cost and allow for accurate assessment of the project's bottom line. MISCONCEPTION: Agencies don't really like to allow the use of wetland mitigation banks. FACT: The state of New Jersey is in the forefront of wetland mitigation banking and the NJDEP has a mitigation council which approves and promotes the concept of mitigation banking. An interagency federal guidance document states that the use of mitigation banks is the preferable method in many cases. Several proposed wetlands legislation bills include specific language on the use of mitigation banks. Finally, mitigation banking is not only accepted it is now preferred by the Hackensack Meadowlands Development Commission.
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