What Is Wetland Mitigation Banking?

A market-based conservation tool that turns private land into protected, restored wetland habitat.

Wetland mitigation banking is a conservation practice in which a private landowner restores and preserves land to offset wetland impacts caused by development elsewhere. The landowner sells mitigation credits to developers who need to compensate for permitted wetland impacts within a defined service area.

THE PROCESS

How Mitigation Banking Works

From land identification to credit sale — four key stages

Land Identified

A private landowner identifies eligible wetland property within a defined mitigation service area

Conservation Easement Placed

A permanent conservation easement is recorded, preventing future development on the property.

Ecological Restoration Completed

The landowner implements a restoration plan to return the property to its natural hydrologic and ecological state.

Credits Issued and Sold

Regulatory agencies award mitigation credits, which are sold to developers offsetting permitted wetland impacts.

151–24,323

acres — range of bank sizes in Florida

974 acres

average Florida mitigation bank size

2–10 years

time to permit a mitigation bank

MITIGATION CREDITS

What Is a Mitigation Credit?

A mitigation credit represents the ecological value equivalent to the complete restoration of one acre of wetland. Credits are determined by the permitting agencies based on functional gains achieved through the restoration work completed at the bank site.

Landowners who impact wetlands must obtain an Environmental Resource Permit (ERP) from FDEP or a Water Management District, and in some cases a Section 404 permit from the U.S. Army Corps of Engineers.

“In 1989, President George H. W. Bush established the national policy of no net loss of wetlands.”

The functional loss caused by the impact must be offset with an equal or greater functional gain to satisfy the no net loss requirement.

REQUIREMENTS

What Wetland Mitigation Banks Must Achieve

To receive a permit and generate credits, every mitigation bank must meet the following regulatory standards.

Support Sustainable Hydrology

The site must demonstrate a natural water flow regime appropriate to the wetland type being restored.

Provide Measurable Ecological Uplift

Restoration must produce a documented functional gain over baseline conditions, assessed using UMAM.

Allow for Long-Term Management and Monitoring

The bank must have a funded management plan and meet regulatory milestones over time.

Meet Regulatory Performance Standards

Credits are only released as the site achieves standards set by FDEP, the applicable WMD, and/or USACE.

WHY BANKING WORKS BETTER

Banking vs. Permittee-Responsible Mitigation

Before mitigation banking became widespread, wetland offsets consisted of hundreds of small, scattered parcels that were difficult for agencies to monitor and frequently failed to meet restoration goals.

Mitigation Banking	Permittee-Responsible Mitigation
✓ Consolidated, large-scale restoration sites	✗ Scattered, small individual parcels
✓ Third-party managed and agency-monitored	✗ Developer-managed with inconsistent oversight
✓ Credits pre-approved before impacts occur	✗ Mitigation approved after the impact takes place
✓ Higher documented ecological success rate	✗ High historical rate of project failure
✓ Strategically positioned within watersheds	✗ Location tied to project site, not ecological need

Mitigation banking is now the preferred method of compensatory mitigation under both state and federal regulatory frameworks.

REGULATORY HISTORY

How Mitigation Banking Developed

1983

First Federal Guidance Issued

The U.S. Fish and Wildlife Service issued guidance that led to the establishment of the first wetland mitigation banks in the United States.

1989

No Net Loss Policy Established

President George H. W. Bush established the national policy of no net loss of wetlands, requiring that functional losses from development be offset through mitigation.

1993

Florida Authorizes Mitigation Banking

Florida’s Environmental Reorganization Act directed FDEP and the state’s water management districts to encourage and regulate private and public mitigation banks statewide.

WATERSHED RULES

Mitigation Must Occur Within the Same Watershed

Wetland mitigation credits must be used within the same watershed as the development impact. This requirement ensures that the ecological offset is meaningful at a landscape level and benefits the same drainage basin where the loss occurred.

If no credits are available within the impacted watershed, mitigation may occur one basin away — but a credit multiplier is applied, increasing the number of credits required to compensate for the impact.

Learn more about the ERP permitting process →

Looking for Mitigation Credits in Florida?

MBG represents mitigation banks throughout Florida and helps developers, consultants, and engineers find the right mitigation solution for their projects.

VIEW AVAILABLE CREDITS