Public Comment on Minimizing Transaction Costs for Mitigation Banking

A public comment submitted to the U.S. Fish and Wildlife Service regarding the advanced notice of proposed rulemaking on compensatory mitigation mechanism.

Main Points:
  • Conservation banking is a market solution that can lower the cost of conservation and proactively recover species.
  • But costs matter. Any proposed regulation should limit transaction costs for bankers and credit buyers to encourage the establishment of and competition between conservation banks.
  • Any rule should also embrace opportunities for markets to promote voluntary conservation on public lands.
  • Finally, the Service should consider opportunities to further reward conservation banking through positive incentives.
Introduction:

Conservation banking is a powerful and important tool for recovering species and conserving habitats through markets. Regulation could help facilitate the use of this tool—or hold it back. That’s why it is critical that any rule minimizes transaction costs for bankers and credit buyers and encourages competition among bankers. The agency should also embrace opportunities for conservation banking on public lands. And, ultimately, the Service should consider how additional positive incentives can expand the work of conservation banks and grow the restoration economy.

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