legal status of credit stacking

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Phone: 877-789-2085 Attendee PIN: 7712 What is Environmental Credit Stacking?


Phone: 877-789-2085 Attendee PIN: 7712 The Crux of Stacking

Can you get paid twice for the same conservation action?

• Drive to maximize Economic Returns • Concern over Ecological Validation • Development of Policy


Phone: 877-789-2085 Attendee PIN: 7712

• Agencies: Regulatory agencies need to ensure that the credits appropriately offset impacts. This can be challenging even in one market type. When credits are stacked the question of “additionality” becomes even more prominent.

• Landowners: Shouldn’t credit producers expect to be

compensated for the range of environmental benefits they support?

• Project Managers: Even in the absence of clear direction from agencies and standard protocols, pilot projects are proceeding to test the possibilities of credit stacking.

• Ecosystems: Credits represent mitigation. When credits are stacked, so are the risks to the ecosystem if credits fail.

Perspectives and Responsibilities



• Van Vleck Ranch Mitigation Bank (CA) – Wetland and vernal pool fairy shrimp credits

Stacking scenarios: Wetlands and endangered species

Source: Westervelt Ecological Services

http://www.wesmitigation.com/mitigation-conservation-projects/van-vleck-ranch-mitigation-bank.cfm#page=photos



• Neu-Con Umbrella Wetland Mitigation and Stream Restoration Bank (NC) – Wetland and nutrient offset credits

Stacking scenarios: Wetlands and water quality

Source: North Carolina State University

http://www4.ncsu.edu/~grhess/PhotoOfTheMonth/archive/



• Spellbottom Mitigation Bank (TX) – Temporary Storage of Surface

Water (TSSW) – Maintenance of Plant and Animal

Communities (MPAC) – Removal and Sequestration of

Elements and Compounds (RSEC)

Stacking scenarios: Wetland functions

Source: Mitigation Solutions USA

http://www.msusa.com/banks/texas/SpellbottomMitigationBank_Map.html


Phone: 877-789-2085 Attendee PIN: 7712 Stacking scenarios:

Multiple species (federal)



• Lyonia Preserve (FL)

Stacking scenarios: Multiple species (federal and state)

Source: Volusia County Florida

www.volusia.org



• Florida Panther Conservation Bank – Panther credits and

reservation of right to seek carbon credits in the future

Stacking scenarios: Endangered species and carbon

Source: The Florida Panther Conservation

http://pantherconservation.com/



• Maryland’s (nascent) water quality trading program

Stacking scenarios: Water Quality Phosphorous and Nitrogen

Chesapeake Bay

Source: Fairfax County

http://www.fairfaxcounty.gov/dpwes/environmental/cbay/


Accounting Units & Defensible Stacking Scenarios

• Species • Wetlands • Carbon • Water Quality

Bundles of Ecosystem Values (Acres)

Defined Accounting Units (tons, pounds)

Based on our analysis, the most appropriate credit stacking scenario is when the accounting units are pollutant-specific, such as pounds of nitrogen in water quality trading, and tons of CO2 equivalents in carbon markets.


Phone: 877-789-2085 Attendee PIN: 7712 Discussion …



Consideration 1: Ecosystem credits that consist of a suite of functions should not be stacked and unbundled.

Consideration 2: Stacking and unbundling credits should not result in habitat loss.

Consideration 3: Managing the site for one credit type should not denigrate the ecological values represented by other credit types.

Considerations for a Credit Stacking Protocol

“Credit stacking could provide great economic incentives for effective conservation, but only after the fundamental considerations

described here are addressed.”



Consideration 4: Regulatory agencies need the resources and capacity to confirm the ecological validity of the transactions.

Consideration 5: Any stacking and unbundling of credits should be transparent.

Consideration 6: Tests for additionality should be applied.

Considerations for a Credit Stacking Protocol



• While environmental markets can be flexible to accommodate social and economic elements such as price, infrastructure, and mechanics, they need to maintain basic scientific integrity and defensibility.

• While the perspectives of the buyer, seller, and regulator are important in these markets, the quality of the credits needs to be ensured.

• The validity of credit stacking boils down to appropriate mitigation: do the credits appropriately mitigate the impacts that they are intended to offset?

The Bottom Line on Credit Stacking

legal status of credit stacking

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