Letter: Eco-Advocates ask EMC to take action on Double-Dip

Below is an email sent by several concerned environmental advocates to the NC EMC regarding recent policy decisions concerning Compensatory Mitigation Requirements..

Date: Wed, 13 Jan 2010 16:16:07 -0500
Subject: EMC Agenda Item 10-09, Compensatory Mitigation Requirements and EBX

Dear Environmental Management Commission Members,

Given the recent press, you are probably aware of the concerns raised by the environmental community related to the double-dipping of ecological values produced by Division of Water Quality (DWQ) crediting policies.[1]  The concept of “additionality,” as used by DWQ (the gain of additional benefit without additional work), is illusory and should not be applied to the environmental laws and policies we rely upon to protect our public trust waters.

The use of acreage that has already offset stream or wetland impacts to obtain riparian buffer or nutrient offsets re-credits the same nutrient removal function already allotted to existing credits, resulting in net degradation of water quality.  This double counting of credits results in a net loss of ecosystem function, which is contrary to DENR’s purpose of preserving and protecting North Carolina’s outstanding natural resources, including water quality.  In addition, this policy allows mitigation banks-including the Ecosystem Enhancement Program (EEP)-to charge buyers for two restorations, even though only one environmentally beneficial action is created on-the-ground.

[2]  Special Report: Department of Environment and Natural Resources Wetland Mitigation Credit Determinations.  2009 December.

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