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Wetlands Mitigation Banking in New York City: Challenges and Opportunities

By Emily Walker

In New York City, tidal wetlands are a critical part of coastal resiliency and provide numerous ecological and social benefits. State and federal wetlands mitigation regulations require that development resulting in wetland impacts offset those losses through wetland creation, restoration, and enhancement – with a goal of no-net wetland loss.  

To date, wetlands mitigation has occurred in New York City predominantly on an ad-hoc basis. While the results have been largely successful, we recommend investing in a more proactive approach due to the finite locations for future mitigation. New York City has limited physical space for wetlands mitigation, while the need for mitigation has only grown due to the increased number and scale of renewable energy development, coastal development, and resiliency projects. In addition to dwindling physical space, mitigation outcomes can be negatively impacted by high costs, insufficient staffing, and a complex policy landscape. As a result of these challenges, and the compounding effects of climate change, New York City is at risk of not meeting federal, state, and local no-net loss goals for coastal wetlands.  

During the development of this report, Natural Areas Conservancy (NAC) staff interviewed over a dozen practitioners whose work intersects with the wetlands mitigation process, including professionals in the private, nonprofit, and public sectors. These individuals are key players in advancing mitigation in New York City. Their roles range from mitigation bank managers, regulators, restoration practitioners, and project managers for infrastructure projects. This report distills and synthesizes the feedback we received during the stakeholder interview process, and breaks down the challenges and barriers to the existing mitigation process, while highlighting recommendations for improvements that would help New York City better protect its wetland ecosystems.  

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