With the recent Final Compensatory Mitigation Rule by the US Army Corps of Engineers and US Environmental Protection Agency, wetland mitigation banking has been designated as the preferred means of compensatory mitigation after avoidance and minimization of wetland impacts. Permits and supporting documents were reviewed and site visits conducted at 29 Florida wetland mitigation banks to assess their permit-based success. Just over half of the banks included three or more ecological criteria in permit success requirements. Release of a majority of potential credits (60–75%) was strongly based on completion of activities (e.g. conservation easement, financial assurance, ditch filling). A review of bank compliance suggested that over 40% of banks had reached final success criteria or were clearly trending towards success, but that 17% of the banks were not trending towards success. Most banks were deemed successful according to permit criteria and compliance considerations, although permit criteria were not explicitly tied to ecological considerations. While permit success criteria may have been met, it was unclear what level of functional performance wetland mitigation banks provided.
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Vol. 29 • No. 3