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Performance-Driven Conservation Embraced by New Federal Policies

Two draft policies recently released by the US Fish & Wildlife Service, the draft Mitigation Policy and the draft Compensatory Mitigation Policy, elevate performance-driven conservation by endorsing programmatic mitigation that use credits and debits to ensure offsets achieve net benefit. Environmental Incentives and our partners are pleased to see the Department of Interior using our innovative work on Habitat Exchanges and Credit Systems to raise the standard for mitigation and conservation.

Here are the top 5 exciting performance driven conservation concepts endorsed by the new draft policies:

  • Net Benefit – After following the mitigation hierarchy of avoiding, minimizing and then mitigating for the unavoidable residual impacts, the draft policies require compensatory mitigation offsets to achieve a net gain, or at least a no net loss for species, when doing so is allowed by statutory authority. This requirement defines a quantified and performance-based standard for mitigation that is central to performance driven conservation, but was lacking in past mitigation policies, and facilitates equivalency across mitigation mechanisms.
  • Consistent Metrics for Credits and Debits – Achieving net gain requires understanding the functions and services lost from the adverse effects of development and those enhanced through mitigation projects. The new policy states that the same metrics should be used to assess the debits produced from development impacts and the credits generated from mitigation projects. Our Habitat Quantification Tools establish scientifically-sound, transparent and consistent metrics that assess both debits and credits. The policies advance landscape-scale mitigation, which we integrate into our Habitat Quantification Tools to create incentives to avoid and minimize adverse effects to, and conserve, the highest value habitat in the most critical locations.
  • Programmatic Mitigation Habitat Credit Exchanges are officially endorsed by the new policies. Programmatic mitigation is recognized for reducing the cost of conservation, enabling private investment and reducing risks through innovative mechanisms pioneered by Environmental Incentives including credit reserve pools.
  • Equivalent Standards – Not only must all mitigation for a species within a region meet consistent standards of quality for habitat (see metrics above), equivalent standards for additionality and durability must also be met. This clarity ensures that the standards established by conservation banks and habitat credit exchanges will not be undercut through project-by-project negotiations. The mitigation programs that we design define a set of standards that not only ensures high-quality and equivalent mitigation supplied by the program, but also can be used by permittee-responsible mitigation to produce high-quality, equivalent and cost effective.
  • Adaptive Management – The only thing that is constant is change,” said the philosopher, Heraclitus. The draft policies encourage adaptive management of mitigation programs, which is absolutely critical to meet changing conservation priorities. This also allows programs to incorporate new science and operational learning, thereby ensuring mitigation programs effectively achieve their goals. Periodic, transparent adaptive management is a key aspect of our mitigation programs, such as the Nevada Conservation Credit System.


Follow these links to read the policies, as well as our comments on how they can be further improved:

USFWS Draft Mitigation Policy and EI’s comments

USFWS Draft Compensatory Mitigation Policy and EI’s comments

Please contact Eoin Doherty or Jeremy Sokulsky if you would like to know how these policies may affect you, or how to create private capital investment opportunities for conservation.


Written by Kristen Boysen and Eoin Doherty 

Photo by Kimberly Fraser, US Fish and Wildlife Service. The Black Footed Ferret is listed by the US Fish and Wildlife Service as endangered or threatened in North America. 


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