Mitigating Biological Impacts: On-Site vs. Off-Site

Written by Travis Jokerst.

Photo by Alyssa Burley.

Photo by Alyssa Burley.

Anyone who has ever tried to develop undisturbed land knows they will be faced with a requirement to mitigate for biological impacts caused by the development. In most cases, the project proponent (applicant) is given the option to mitigate those impacts either on-site or off-site. Off-site mitigation typically involves purchasing credits from an approved mitigation bank. The local, state, or federal agencies might even require using a bank that is in the same ecological region as the development site.

Depending on the habitat value and available credits, off-site mitigation can be very costly. For example, in San Diego County, mitigation

credits for wetland impacts cost as much as $575,000 per acre! An applicant might ask himself, why not set aside on-site habitat to offset impacts? It might be cheaper and it allows the applicant to utilize property that he may already own. Well…consider the following before jumping to this conclusion.

These are the steps necessary to preserve and manage on-site biological open space that may be used for mitigating impacts:

  1. Biological Assessment: A biologist will need to assess the on-site habitat to determine whether or not it is suitable for the type of mitigation that is required. The agencies will want to see a report and map of this assessment before accepting it as suitable mitigation for the project’s impacts.
  2. Resource Management Plan (RMP): The RMP describes the biological open space management and monitoring, includes stewardship measures, which may include fencing and signs upkeep, trespass restriction, and debris removal, as well as management and monitoring of Covered Species and their habitats. This will also require submitting annual written reports to the Wildlife Agencies.
  3. Select a Resource Manager: The applicant must select a conservation entity that would be responsible for implementing the RMP in perpetuity. This Resource Manager must be approved by the local agency and/or the Wildlife Agencies prior to commencing site development. Typically, the conservation area is eventually transferred in fee title to the Resource Manager.
  4. Property Analysis Record (PAR) and Endowment: A PAR is used to determine all necessary costs for implementing the RMP. The total management costs, combined with some annual contingencies, make up the endowment amount. In most situations, the endowment must be fully funded (bonds are acceptable) prior to commencing development. It should be noted that a variety of factors affect the PAR, such as the management area’s proximity to other development.
  5. Preserve On-site Habitat: The applicant must then dedicate and record a conservation easement with the local public agency prior to commencing development. This requires a surveyor to prepare a plat and legal description of the conservation easement boundary.

As you can see from the above list, on-site mitigation could be just as costly, if not more costly, and likely to cause more delays than off-site mitigation. However, each site presents its own complexities and should be thoroughly analyzed to determine which mitigation scenario is most appropriate.

Contact EnviroMINE at (619) 284-8515 to best determine if on-site or off-site mitigation is best for your particular project.

Travis Jokerst is a project manager and GIS specialist for EnviroMINE, Inc.