A method to investigate wetland mitigation banking for Saipan, Commonwealth of the Northern Mariana Islands
Abstract The Commonwealth of the Northern Mariana Islands (CNMI) government is considering developing a wetlands mitigation bank on the island of Saipan. The goals of developing the bank are to maximize cost effectiveness of compensatory wetland mitigation, streamline the wetland regulatory framework, and minimize environmental impacts from compensatory wetland mitigation. This article describes the method being employed by the Joint Federal/CNMI Environmental Working Group (Group) to make a recommendation to Governor Froilan C. Tenorio concerning whether the CNMI should establish a Saipan wetland mitigation bank. The Group's method has three components: (1) considering alternative methods to streamline the wetland regulatory framework and enhance the protection of wetlands that may be more suitable to the Saipan context than a wetland mitigation bank; (2) conducting a cost-benefit analysis of potential environmental, economic, and regulatory outcomes of using a mitigation bank; and, (3) analysing regulatory, economic, and ecological risks associated with establishing and using a Saipan bank. A description of the CNMI's wetland resources and the wetland regulatory framework justifies the method being employed by the Group. Federal and CNMI regulators of Saipan's wetlands currently do not possess the technical ability to ensure that there is no net loss of all wetland functions, but are managing Saipan's wetlands solely based on concerns with impacts to bird habitat. Thus, the siting and design of a Saipan bank would currently only be based on managing wetlands according to habitat concerns, and use of the bank would not necessarily prevent a net loss of wetland quality. The Group recognizes the need for a wetland assessment method that can account for the full suite of CNMI wetland functions in order for a Saipan bank to fulfill the Federal mandate for no net loss of wetland quality or quantity. The CNMI's tropical freshwater wetland ecology and level of technical expertise in wetland science require a specific bank design, monitoring and maintenance activities, and enabling instrument in order to be successful in the CNMI context. Fortunately, Federal guidance on the establishment, use, and administration of wetland mitigation banks is flexible enough to enable the CNMI to establish a Saipan bank that fits their unique environmental and social context. Federal guidance appears to unconditionally encourage the establishment and use of banks. However, a wetland mitigation bank may not be appropriate for the local environmental, regulatory, and economic context of a specific city or island. Banking is not a definite panacea to streamline the wetland regulatory framework and enhance wetland protection, and can just as likely worsen problems as remedy them depending on the local context. It is therefore important to investigate economic, regulatory, and environmental risks, costs, and benefits, and to consider all available methods to improve wetlands management as described in this article. This article is a working paper of the Joint Federal/CNMI Environmental Working Group.