Layering Multiple Credit Types in Mitigation Banks

Conservation banking, or banking credits to offset impacts to species listed as threatened or endangered under the federal Endangered Species Act (ESA), has developed on a parallel path with mitigation banking, or banking credits to offset impacts to wetlands under the Clean Water Act (CWA). Although developed separately and under different federal jurisdictions, these two types of resource credits (ESA and CWA) can be compatible within the same bank and even on the same acreage, and it makes ecological sense for a project that is going to impact multiple resources to compensate for those impacts in one place.