Today and tomorrow, the Environment Law Institute is hosting an “ILF Workshop”, furthering BWSR’s agenda to establish this unnecessary program in Minnesota. Only a couple of hours into the program, there are some interesting facts we feel need to be pointed out.
The Corps of Engineers tracks wetland banks nationally on their RIBITS website, and categorizes them depending upon who established the bank. Wetland banks like the majority established by Minnesota private bankers are listed as “Private Commercial”.
As we’ve pointed out, Minnesota has one of the most diverse, thriving private banking markets in the country. Representatives of three states; Oregon, Wisconsin and New Hampshire have made presentations on their state’s existing In-Lieu Fee (ILF) program already this morning.
What’s interesting is the number of “Private Commercial” banks in these states vs. Minnesota. According to RIBITS, Oregon has a total of 16, Wisconsin has 9, and New Hampshire has just 1. On the other hand, Minnesota has a total of 100 approved “Private Commercial” banks, nearly 4 times as many as these 3 states combined, with many projects pending.
Unfortunately, when your regulators tell you that ILF can work hand-in-hand with the private market, this data seems quite contrary, and leads us once again to question the need and benefit of an ILF program in Minnesota.
How can an ILF program provide more diverse, targeted mitigation than a thriving private market with 100 banks to choose from? And if the ILF program is implemented in Minnesota, will this be the beginning of the end of the diversity our private banking market offers?
If you are interested, you can listen in to the webinar free of charge at the following link: