US compensatory mitigation and conservation banking under the "no net loss" policy
- Researchers National Research Council (2001): "The goal of no net loss of wetlands is not being met" for wetland functions, though area losses had slowed; third-party systems such as banks "offer some advantages" over permittee-responsible mitigation. National Research Council, National Academies Press
- Researchers Kihslinger, Environmental Law Institute (2008): Of 19 studies, 10 found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant; the programme may currently lead to a net loss in wetland acres and functions. Environmental Law Institute
- Researchers Sonter et al. (2019): California species banks averted 62 ha of habitat loss and 1,424 ha of habitat gains in 2001–2011; equivalence with impact sites could not be determined. Sonter, Barnes, Matthews and Maron
- Government and regulators Army Corps of Engineers and EPA (2008 rule): Compensatory mitigation is a critical tool toward no net loss; the rule says banks reduce temporal loss and uncertainty compared with in-lieu fee advance credits, and it concedes that some projects do not fully replace functions and services. Army Corps of Engineers and EPA
- Government and regulators GAO (2026): Corps oversight frequency has generally improved since 2005, but districts are inconsistent on financial assurances, long-term management and performance standards; the sample is not generalisable. US Government Accountability Office
- Government and regulators US Fish and Wildlife Service (2024 status report): 116.4 million acres of wetland in the conterminous US in 2019; the news page reports loss figures of 221,000 and 670,000 acres without defining either, and says vegetated-wetland loss increased by more than 50% over the previous period. US Fish and Wildlife Service
- Press and investigations E&E News (2018, citing FWS 2009): The US recorded a slight net gain in wetlands between 1996 and 2004. E&E News by POLITICO
Since 1988 the United States has pursued a goal of no net loss of wetlands, met in part through compensatory mitigation that developers buy from banks. The market runs to billions of dollars a year by the sources' estimates; the National Research Council (2001), GAO (2005, 2026) and peer-reviewed studies report shortfalls in outcomes or oversight.
Estimate by BenDor, Kwon and Lester (PLOS ONE, 27 September 2023), funded by an industry association with a survey response rate under 20%. Other estimates in the sources differ in year, scope and definition.
Status As of June 2026: the Corps–EPA 2008 rule is the operative framework; GAO reported improved oversight in April 2026 with remaining inconsistencies; no source measures whether credits sold offset the losses at impact sites.
- Mitigation and conservation bankers — Direct revenue of the US wetland and stream compensatory mitigation industry was in excess of US$3.5 billion in 2019 according to an industry-funded estimate PLOS ONE
- Wildlands, Inc. and its investor Parthenon Capital — Parthenon announced an investment in Wildlands on 20 March 2007; the company's revenue is not on record Wildlands, Inc. and Parthenon Capital
- Wetlands and species habitat at impact sites — The NRC found functional equivalence is seldom achieved within 5 years and that fens and bogs cannot be effectively restored with present knowledge; Sonter et al. state equivalence with impact sites could not be determined National Research Council, National Academies Press
What happened
The national goal of no net loss of wetlands has a dated policy chain. In 1987, at the request of the US Environmental Protection Agency (EPA), a National Wetlands Policy Forum chaired by New Jersey Governor Thomas Kean was convened. E&E News reported that on Labor Day weekend 1988 the then vice president and candidate George H. W. Bush announced a goal of "no net loss of wetlands", citing losses of about 500,000 acres a year; the text of the speech was not found. On 15 November 1988 the Forum report recommended no net loss as the national goal. A Memorandum of Agreement between the Army and EPA dated 6 February 1990 set a mitigation sequence of avoiding, minimising and then compensating for losses; the lawyer Oliver Houck wrote that it was signed in November 1989, was delayed twice by the White House and amended, and that the amendments made the goal "less attainable than ever". On 28 November 1995 federal agencies issued guidance on mitigation banks (60 FR 58605), which said banks could contribute to the goal of no overall net loss. On 10 April 2008 the Army Corps of Engineers (Corps) and EPA published a final rule on compensatory mitigation (73 FR 19594, effective 9 June 2008) that gave bank credits preference over in-lieu fee advance credits.
A conservation bank or wetland mitigation bank is protected or restored land divided into credits; a developer who must offset habitat or wetland losses buys credits instead of restoring land itself. Market estimates vary with year and definition. Ecosystem Marketplace put species banking at about US$370 million a year and wetland mitigation at US$3.3 billion a year, about US$1 billion of it through banks (December 2008). Its 2011 update, with 2010 data, put the global market at "at least" US$2.4 billion to US$4.0 billion a year and US aquatic compensatory mitigation and conservation banking at US$2.0 billion to US$3.4 billion a year, and counted 1,044 active and sold-out US wetland, stream and conservation banks, 82 of them conservation banks in California. A 2017 report put global transactions at US$4.8 billion in 2016. BenDor and colleagues (2023) estimated the 2019 direct revenue of the US wetland and stream compensatory mitigation industry at more than US$3.5 billion, with total output of more than US$9.6 billion, more than 53,000 jobs and nearly 2,200 banks by October 2022. As of 2026 the Corps' RIBITS database listed more than 4,700 bank and in-lieu fee project sites, and an FWS-approved list cited in 2022 held 173 conservation banks covering about 260,000 acres and 57 listed species. Wildlands, Inc. described itself in 2007 as the largest mitigation banker in California; a Wildlands vice-president said in 2015 that wetland credits were worth "about half a million dollars per acre", which he called a guess.
Outcome studies of wetland mitigation report shortfalls. The National Research Council (2001) found that "the goal of no net loss of wetlands is not being met" for wetland functions, although area losses had slowed. It reported that permits required about 1.8 acres of compensation per acre permitted, that Corps data were inadequate to confirm the status of compensation wetlands, that mitigation wetlands "seldom achieve functional equivalency" with reference sites or permit requirements within 5 years, and that fens and bogs "cannot be effectively restored with present knowledge". The Government Accountability Office (GAO-05-898, 2005) reviewed 152 permit files and found monitoring reports required in 89 and evidence of receipt in 21; of 85 bank files, 60 required monitoring reports and 70% showed receipt of at least one. Kihslinger (Environmental Law Institute, 2008) reported about 47,000 acres of mitigation required per year against about 21,000 acres of permitted losses; of 19 studies reviewed, 10 found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant. She concluded the programme "may currently lead to a net loss in wetlands acres and functions". The 2008 federal rule itself states that "there are compensatory mitigation projects that do not fully succeed in replacing the functions and services".
For species conservation banks, Sonter and colleagues (Conservation Letters, 2019) studied 59 California banks covering 15,350 ha. Between 2001 and 2011 the banks averted 62 ha of habitat loss and unexpectedly averted habitat gains of 1,424 ha, 35 times greater; equivalence with the impact sites could not be determined because records of losses at impact sites covered by sold credits do not exist. A World Biodiversity Forum 2026 conference abstract by Verner-Crist, which is not a peer-reviewed article, reported 30 years of monitoring at 36 California banks: 23% never documented the target species on site, 56% failed to demonstrate successful breeding, and most were not required to show the target species present before selling credits. The Delhi Sands flower-loving fly case is one data point: FWS found in 2008 that about 10% of remaining potential fly habitat had protected status.
GAO's April 2026 follow-up (GAO-26-106827) sampled 85 files from three Corps districts, including 28 banks, and found oversight frequency generally improved since 2005 while districts remained inconsistent on financial assurances, long-term management and performance standards; GAO said the sample is not generalisable. The Department of Defense agreed with its one recommendation, on implementation guidance. FWS's 2024 wetlands status report found 116.4 million acres of wetland in the conterminous US in 2019; its news page gave loss figures of 221,000 and 670,000 acres without defining either, and said vegetated-wetland loss increased by more than 50% over the previous period. No FWS conservation-banking rule after a July 2022 advance notice of proposed rulemaking was found.
- 1987National Wetlands Policy Forum convened at EPA's request, chaired by Governor Thomas Kean
- 1988Labor Day weekend: George H. W. Bush announces a goal of no net loss of wetlands (E&E News); 15 November: Forum report recommends no net loss as the national goal
- 1990Army–EPA Memorandum of Agreement on mitigation dated 6 February (Houck dates its signing to November 1989)
- 1995Federal guidance on mitigation banks issued (60 FR 58605, 28 November)
- 2001National Research Council report finds the no-net-loss goal for wetland functions is not being met (June)
- 2005GAO-05-898 finds the Corps lacks an effective oversight approach for compensatory mitigation (8 September)
- 2008Corps–EPA compensatory mitigation rule published (73 FR 19594, 10 April; effective 9 June); Ecosystem Marketplace sizes species banking at about US$370 million a year (December)
- 2011Ecosystem Marketplace 2011 Update counts 1,044 US wetland, stream and conservation banks (2010 data)
- 2017Forest Trends reports US$4.8 billion in global biodiversity-mitigation transactions in 2016 (December)
- 2019Sonter et al. publish a study of 59 California species conservation banks
- 2022FWS advance notice of proposed rulemaking on conservation banking (July); 173 FWS-approved conservation banks cited
- 2023BenDor et al. estimate 2019 industry direct revenue above US$3.5 billion (27 September)
- 2026GAO-26-106827 reports improved Corps oversight with remaining inconsistencies (30 April); World Biodiversity Forum abstract on California banks (June)
What was said
“no net loss of wetlands”
“a unifying standard”
“less attainable than ever”
“the goal of no net loss of wetlands is not being met”
“seldom achieve functional equivalency with reference sites or comply with permit requirements within 5 years”
“there are compensatory mitigation projects that do not fully succeed in replacing the functions and services”
“may currently lead to a net loss in wetlands acres and functions”
“about half a million dollars per acre”
Where accounts differ
Each party's account, side by side, with its source. The record does not settle these points; it shows them.
"The goal of no net loss of wetlands is not being met" for wetland functions, though area losses had slowed; third-party systems such as banks "offer some advantages" over permittee-responsible mitigation.
National Research Council, National Academies PressOf 19 studies, 10 found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant; the programme may currently lead to a net loss in wetland acres and functions.
Environmental Law InstituteCalifornia species banks averted 62 ha of habitat loss and 1,424 ha of habitat gains in 2001–2011; equivalence with impact sites could not be determined.
Sonter, Barnes, Matthews and MaronCompensatory mitigation is a critical tool toward no net loss; the rule says banks reduce temporal loss and uncertainty compared with in-lieu fee advance credits, and it concedes that some projects do not fully replace functions and services.
Army Corps of Engineers and EPACorps oversight frequency has generally improved since 2005, but districts are inconsistent on financial assurances, long-term management and performance standards; the sample is not generalisable.
US Government Accountability OfficeSpecies banking about US$370 million a year; wetland mitigation US$3.3 billion a year, about US$1 billion of it through banks.
Ecosystem MarketplaceUS aquatic compensatory mitigation and conservation banking US$2.0 billion to US$3.4 billion a year; the global market at least US$2.4 billion to US$4.0 billion.
Ecosystem Marketplace / Forest Trends2019 direct revenue of the US wetland and stream compensatory mitigation industry in excess of US$3.5 billion. The study lists earlier estimates of US$2.9 billion (ELI, fiscal 2003), US$1.3 billion to US$2.2 billion (2010), US$1.8 billion to US$3.2 billion (2011) and US$1.45 billion to US$5.7 billion (2017).
PLOS ONENearly US$5 billion globally in 2016, of which mitigation banks US$3.6 billion (press release); the presentation deck gives US$4.8 billion and an estimated US$3.8 billion a year for US wetland banking.
Forest TrendsThe 2023 study was funded by the Ecological Restoration Business Association, an industry group, and had a survey response rate under 20%.
PLOS ONE116.4 million acres of wetland in the conterminous US in 2019; the news page reports loss figures of 221,000 and 670,000 acres without defining either, and says vegetated-wetland loss increased by more than 50% over the previous period.
US Fish and Wildlife ServiceThe US recorded a slight net gain in wetlands between 1996 and 2004.
E&E News by POLITICOThe agreement was signed in November 1989, delayed twice by the White House and then amended.
Environmental Law ReporterThe operative agreement is dated 6 February 1990.
Army Corps of Engineers and EPAHow it looked
Shown
- Compensatory mitigation described as "a critical tool in helping the federal government to meet the longstanding national goal of `no net loss' of wetland acreage and function".Army Corps of Engineers and EPA, 2008 final rule · Army Corps of Engineers and EPA
- Mitigation banks described as able to "contribute towards attainment of the goal for no overall net loss of the Nation's wetlands".Federal agencies, 1995 guidance · Army Corps of Engineers, EPA, USDA NRCS, FWS and NMFS
- Wildlands, Inc. described as "the largest mitigation banker in California".Wildlands' founder and chief executive, in a 20 March 2007 release on Parthenon Capital's investment · Wildlands, Inc. and Parthenon Capital
Recorded
- NRC 2001: the no-net-loss goal for wetland functions was not being met; about 1.8 acres of compensation were required per acre permitted; Corps data could not confirm the status of compensation wetlands.
- GAO-05-898 (2005): of 152 permit files, monitoring reports were required in 89 and evidence of receipt appeared in 21; evidence of a compliance inspection appeared in 15%. Of 85 bank files, 60 required reports and 70% showed receipt of at least one; 36% showed an inspection. Two of three recommendations are recorded as closed, not implemented.
- GAO-26-106827 (30 April 2026): oversight frequency generally improved since 2005 in a sample of 85 files, with inconsistencies on financial assurances, long-term management and performance standards; the sample is not generalisable.
- Kihslinger (2008): about 47,000 acres of mitigation required per year against about 21,000 acres of permitted losses; 10 of 19 studies found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant.
- Sonter et al. (2019): 59 California species conservation banks averted 62 ha of habitat loss and 1,424 ha of habitat gains between 2001 and 2011; equivalence with impact sites could not be determined.
- World Biodiversity Forum 2026 abstract: at 36 California banks, 23% never documented the target species and 56% failed to demonstrate successful breeding; the abstract is not a peer-reviewed article.
In nature's name
Promised
- “a critical tool in helping the federal government to meet the longstanding national goal of `no net loss' of wetland acreage and function” — Army Corps of Engineers and EPA, final rule on compensatory mitigation (10 April 2008) Army Corps of Engineers and EPA
- “contribute towards attainment of the goal for no overall net loss of the Nation's wetlands” — Federal agencies, guidance on mitigation banks (on what banks can do) (28 November 1995) Army Corps of Engineers, EPA, USDA NRCS, FWS and NMFS
Money moved in nature's name
| What | Kind | Amount | Period |
|---|---|---|---|
| Direct revenue of the US wetland and stream compensatory mitigation industry US wetland and stream compensatory mitigation industry PLOS ONE | Sales | $3.5bn estimate | 2019 |
| US species banking, annual market US species banks Ecosystem Marketplace | Sales | $370m estimate | 2008 report |
| US wetland mitigation, annual market US wetland mitigation Ecosystem Marketplace | Sales | $3.3bn estimate | 2008 report |
| Banking segment of US wetland mitigation US wetland mitigation banks Ecosystem Marketplace | Sales | $1bn estimate | 2008 report |
| US aquatic compensatory mitigation and conservation banking US aquatic compensatory mitigation and conservation banking programmes Ecosystem Marketplace / Forest Trends | Sales | $2bn estimate | 2010 data |
| Global biodiversity-mitigation transactions Global biodiversity-offset and compensation programmes Forest Trends | Sales | $4.8bn estimate | 2016 |
| US wetland banking sector, estimated annual transactions US wetland banking sector Forest Trends | Sales | $3.8bn estimate | 2016 |
| Wetland credit price estimated by a Wildlands vice-president Wildlands, Inc. KPBS | Sales | $0.5m estimate | 2015 |
What was measured
Independent reviews (NRC 2001, GAO 2005 and 2026) and peer-reviewed studies (Sonter et al. 2019) report that the no-net-loss goal for wetland functions was not being met, that oversight evidence was lacking or inconsistent, and that equivalence with impact sites could not be determined for species banks. Market-size figures come from industry-linked estimates; they measure money, not benefit to nature.
Findings on record
- Official audit National Research Council (2001-06) · Compensating for Wetland Losses Under the Clean Water Act: “the goal of no net loss of wetlands is not being met” National Research Council, National Academies Press
- Official audit US Government Accountability Office (2005-09-08) · GAO-05-898: “Does Not Have an Effective Oversight Approach to Ensure That Compensatory Mitigation Is Occurring” US Government Accountability Office
- Own admission Army Corps of Engineers and EPA (2008-04-10) · Compensatory Mitigation for Losses of Aquatic Resources, 73 FR 19594: “there are compensatory mitigation projects that do not fully succeed in replacing the functions and services” Army Corps of Engineers and EPA
- Peer-reviewed study Sonter, Barnes, Matthews and Maron, Conservation Letters (2019) · Quantifying habitat losses and gains made by U.S. Species Conservation Banks Sonter, Barnes, Matthews and Maron
- Peer-reviewed study BenDor, Kwon and Lester, PLOS ONE (2023-09-27) · Assessing the size and growth of the US wetland and stream compensatory mitigation industry PLOS ONE
- Official audit US Government Accountability Office (2026-04-30) · GAO-26-106827: “Has Improved Oversight of Compensatory Mitigation, but Needs Implementation Guidance” US Government Accountability Office
Who gained
Reached nature or the ground
Gained elsewhere
Responses on record
- US Army Corps of Engineers and EPA (10 April 2008): The 2008 final rule states that compensatory mitigation is "a critical tool" toward the national goal of no net loss, that some projects "do not fully succeed in replacing the functions and services", and that it incorporated recommendations of the 2001 NRC report and the 2001 and 2005 GAO reports. · Army Corps of Engineers and EPA
- US Army Corps of Engineers (2005 report, status as of 2026): GAO recorded two of three recommendations of its 2005 report as closed, not implemented. · US Government Accountability Office
- US Department of Defense (April 2026): Agreed with GAO's one recommendation, on implementation guidance, in GAO-26-106827. · US Government Accountability Office
- Wildlands, Inc. (20 March 2007; 12 February 2015): Described itself in 2007 as "the largest mitigation banker in California" and in 2015 estimated wetland credits at "about half a million dollars per acre", which its vice-president called a guess. · Wildlands, Inc. and Parthenon Capital
In court and with insurers
Lawsuits and rulings
Insurers
What nature saw
Nature's report opens this page. Below: further outcomes measured on the ground.
What we don't know
Nature
- Not measured Harm to nature: The record holds no measurement of harm to nature.
- Disputed Whether compensatory mitigation achieves the national goal of no net loss
- Disputed Net national trend in US wetlands
Accounts
Record
- None on record None on record: a measurement of whether the habitat or wetland lost at the sites covered by sold credits was equivalent to what the credits protect; Sonter et al. state that records of losses at impact sites covered by sold credits do not exist.
- None on record None on record: the number and names of listed species with no conservation bank, and California's current share of conservation banks.
- None on record None on record: an FWS conservation-banking rule after the July 2022 advance notice of proposed rulemaking.
- None on record None on record: a direct annual market estimate for 2022 to 2025; the latest figure in the sources reviewed is for 2019.
- None on record None on record: annual revenue of Wildlands, Inc. or an independent ranking of it; the company's releases and the press reviewed give no revenue figure, and its current owner is not stated on the company site.
- Insufficient Insufficient: the FWS 2024 wetlands status page gives loss figures of 221,000 and 670,000 acres without defining either, so the net national trend is unresolved.
- Disputed Disputed: the 2017 report is cited as nearly US$5 billion and US$4.8 billion, and mitigation banks as US$3.6 billion in the press release and an estimated US$3.8 billion a year for US wetland banking in the presentation deck.
- Disputed Disputed: the 2011 Update text gives US$2.0 billion to US$3.4 billion for US aquatic compensatory mitigation and conservation banking, while an Ecosystem Marketplace article on the same data gives US$2 billion to US$3.6 billion for wetland and stream banking.
- Unclear Unclear: the date of the Army–EPA agreement. Houck dates its signing to November 1989; federal documents date the operative agreement to 6 February 1990.
- Insufficient Unconfirmed: a search summary cited an FWS fact sheet saying 105 conservation banks had been approved as of October 2011, and another summarised an archived January 2021 speciesbanking.com page linking a dataset of 832 US wetland and stream banks.
Did the harm stop?
The sources reviewed do not report that wetland or habitat loss under the programme has stopped. FWS's 2024 wetlands report says vegetated-wetland loss increased by more than 50% compared with the previous study, though its loss figures are not defined on the page reviewed.
Who paid?
Developers and permit holders buy credits from banks. The industry estimates range from US$370 million a year for species banking (2008) to direct revenue of more than US$3.5 billion for wetland and stream compensatory mitigation (2019). The sources reviewed give no total paid for credits whose impact sites were measured.
Sources
Company or project
- Wildlands, Inc. Announces Investment by Parthenon CapitalWildlands, Inc. and Parthenon Capital · 2007-03-20
- Who we areWildlands, Inc. · 2026
Government and regulators
- Wetlands Protection: Corps of Engineers Does Not Have an Effective Oversight Approach to Ensure That Compensatory Mitigation Is Occurring (GAO-05-898)US Government Accountability Office · 2005-09-08
- Clean Water Act: Corps of Engineers Has Improved Oversight of Compensatory Mitigation, but Needs Implementation Guidance (GAO-26-106827)US Government Accountability Office · 2026-04-30
- Federal Guidance for the Establishment, Use and Operation of Mitigation Banks, 60 FR 58605Army Corps of Engineers, EPA, USDA NRCS, FWS and NMFS · 1995-11-28
- Compensatory Mitigation for Losses of Aquatic Resources, final rule, 73 FR 19594Army Corps of Engineers and EPA · 2008-04-10
- RIBITS (Regulatory In-lieu Fee and Bank Information Tracking System) pageARA, contractor for the Corps' RIBITS · 2026
- Status and Trends of Wetlands (2009 to 2019)US Fish and Wildlife Service · 2024-03
Press and investigations
- Wetland loss still outweighs gain despite 20 years of progress (press release)Ohio State University · 2001-06-25
- How George H.W. Bush (eventually) rescued U.S. wetlands (Ariel Wittenberg)E&E News by POLITICO · 2018-12-03
- Forum calls for wetlands protection. EPA-sponsored coalition sets `no net loss' as a national priorityChristian Science Monitor · 1988-11-18
- speciesbanking.com for all your species needs (Steve Zwick)Ecosystem Marketplace · 2008-12-10
- 173 FWS-approved conservation banks (repost of the FWS advance notice of proposed rulemaking announcement, 87 FR 45076)Mitigation Banking Inc. · 2022-07-27
- Mitigation bankers see profit in converting developed landKPBS · 2015-02-12
- Biodiversity Market Tops $3 Billion in 2010Ecosystem Marketplace · 2011-06-27
Communities and civil society
- 2011 Update - State of Biodiversity Markets: Offset and Compensation Programs WorldwideEcosystem Marketplace / Forest Trends · 2011
- State of Biodiversity Mitigation 2017 webinar deckForest Trends · 2018
Researchers
- Compensating for Wetland Losses Under the Clean Water Act (executive summary)National Research Council, National Academies Press · 2001
- Success of Wetland Mitigation Projects (Kihslinger), National Wetlands Newsletter 30(2)Environmental Law Institute · 2008
- Inconsistencies and Underperformance in US Biodiversity Offsets Policy (conference abstract, not peer-reviewed)Verner-Crist, World Biodiversity Forum 2026 · 2026-05-23
Connected cases
- Delhi Sands flower-loving fly and the Colton Dunes Conservation Bank, California United States · 1993–2026 Related matter
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews
- Beach nourishment and armoring on Florida's loggerhead nesting beaches United States · 2011–2025
- US Army Corps of Engineers (Government) — here: Issues section 404 permits, oversees compensatory mitigation and banks; co-author of the 1995 guidance and the 2008 rule; there: Sand placement covered by the 2015 opinion
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Issued the Statewide Programmatic Biological Opinion of 13 March 2015
- Starbase launch site, Boca Chica, Texas: environmental review, penalties and Starship debris United States · 2022–2025
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Federal environmental regulator; found Clean Water Act violations
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Federal wildlife agency; reported the fire after the first flight
- US bans DDT in 1972; bald eagle breeding pairs rebound United States · 1972–2019
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: issued the 1972 DDT ban
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: published bald eagle population data
- 1,4-dioxane in Tide: Prop 65 settlement and New York limit United States · 2011–2024
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; revised risk determination
- 3M PFOS: internal evidence, EPA penalty and Minnesota settlement United States · 1979–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; TSCA charge closed 2006
- ADM Decatur carbon storage site leaks about 8,000 tons, EPA finds United States · 2023–2024
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: regulator that found a violation
- AES coal ash sold as road fill in Guayama, Puerto Rico; arsenic above standard United States · 2021
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Federal regulator promising action
- African Parks Odzala-Kokoua abuses (Republic of Congo) Republic of Congo · 2010–2025
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Funder (2024)
- After Sackett ruling, NRDC says at least 60% of individual wetlands are unprotected United States · 2023
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Defendant in Sackett; named in reported 2025 and 2026 proposals to narrow the test (unconfirmed)
- Asbestos 524(g) bankruptcy trusts and J&J talc two-step United States · 1988
- US Government Accountability Office (GAO) (Public authority) — here: Audited Corps oversight of compensatory mitigation in 2005 and 2026; there: Source of the 2011 asbestos trust data
- Black-footed ferret cloning (Antonia) and wild plague United States · 1988–2024
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Federal agency; project partner
- BP Deepwater Horizon: the spill, the court cases and the recovery claims United States · 2010–2031
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Suspended BP from new federal contracts, 2012–2014
- California v. ExxonMobil: plastics recycling claims and the Baytown plant United States · 2021–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Rejected the mass balance method for its Safer Choice label, per ProPublica
- CAMPFIRE and elephant trophy hunting Zimbabwe · 2010–2015
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Trophy-import regulator
- Chemours spin-off liabilities United States · 2015–2025
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator in the December 2005 PFOA case
- Colossal Biosciences: de-extinction ventures, funding and the Burgum remark United States · 2022–2026
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Signed a memorandum of understanding with Colossal; co-author of the July 2026 harm-definition rule
- Court reverses $60 million punitive award in dicamba case United States · 2015–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Approved over-the-top dicamba use for 2026 and 2027
- Diamond Shamrock Lister Avenue dioxin, Passaic River United States · 1984–1993
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Selected the 2016 lower Passaic remedy
- Dicamba drift (Bader Farms) and EPA re-registration United States · 2015–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; re-registered dicamba in February 2026
- DuPont PFOA (C8) at Washington Works, Parkersburg, and the Tennant farm United States · 1981–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; 2005 penalty
- EPA repeals 2009 greenhouse gas endangerment finding on legal grounds United States · 2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Issued the repeal
- Exxon Valdez: the spill, insurance and court cases United States · 1989–2015
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Federal regulator in the 1991 settlement
- Fieldwood bankruptcy and US offshore decommissioning United States · 2024
- US Government Accountability Office (GAO) (Public authority) — here: Audited Corps oversight of compensatory mitigation in 2005 and 2026; there: Auditor; estimated liabilities
- Former EPA chief Lisa Jackson named interim chair of Conservation International United States · 2012–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Withdrew the Range Resources emergency order in 2012
- GE ran a 'Let Nature Clean Up the Hudson' campaign against EPA dredging United States · 2009–2015
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator that ordered and certified the dredging
- GenX chemical found in Cape Fear River, a DuPont and Chemours replacement for PFOA United States · 2009
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Found in 2021 that GenX was more toxic than previously thought
- Greens report: parts of German glyphosate assessment copied Monsanto file Germany · 2015–2025
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: US regulator; former staff moved to Monsanto; Rowland remark reported
- Gulf of Mexico dead zone (Mississippi nutrient runoff) United States · 1985–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Clean Water Act regulator
- Hawaii shallow-set longline swordfish fishery: loggerhead interaction limits, Ninth Circuit ruling and 2018 closure United States · 2004–2020
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Defendant agency (Interior)
- Holcim Geocycle and brand-cement plastic co-processing Global · 2021–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; found no meaningful climate benefit from burning plastic instead of coal in kilns (as reported)
- Kivalina village in Alaska still awaits relocation after 2008 suit against ExxonMobil United States · 1992–2026
- US Army Corps of Engineers (Government) — here: Issues section 404 permits, oversees compensatory mitigation and banks; co-author of the 1995 guidance and the 2008 rule; there: Federal engineers who estimated erosion timelines and relocation costs
- Lumber Liquidators Lacey Act guilty plea over Russian Far East oak flooring Russia · 2010–2024
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Co-investigator; recipient of community service payment
- Make Sunsets stratospheric balloon launches (Mexico) Mexico · 2022–2025
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator that requested information
- Monsanto/Bayer PCB and Roundup insurance suit v AIG United States · 1967–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; reported to have told Bayer it would not accept a cancer warning
- Mosaic settles US hazardous-waste case over phosphogypsum handling United States · 2015
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator that inspected the sites and signed the settlement
- Nonylphenol ethoxylates: Swiss ban and EU restriction Switzerland · 1984–2014
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Published the nonylphenol ethoxylate action plan
- Paraquat bans, UK production for export and Chinese exports United Kingdom · 1989–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; interim decision of 2021 and January 2025 announcement
- Paraquat litigation (Syngenta/Chevron) and the Paraquat Papers United States · 1958–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; 2021 interim decision and 2025 withdrawal
- Peabody, Patriot Coal and coal self-bonding United States · 2007–2020
- US Government Accountability Office (GAO) (Public authority) — here: Audited Corps oversight of compensatory mitigation in 2005 and 2026; there: US government auditor that recommended ending self-bonding
- PFAS water utility settlements by 3M, DuPont, Chemours and Corteva United States · 2023–2036
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; drinking-water limits for PFOA and PFOS
- PG&E wildfire settlement, tax deduction and Fire Victim Trust United States · 2018–2025
- US Government Accountability Office (GAO) (Public authority) — here: Audited Corps oversight of compensatory mitigation in 2005 and 2026; there: Reviewer of tax treatment of settlements (2005)
- Portland Harbor Superfund cleanup plan (Willamette River, Oregon) United States · 2016–2017
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator; issued the draft plan and the final Superfund decision
- Removal of the Endangered Species Act 'harm' definition United States · 2025–2026
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Agency that removed the definition from its regulations
- Roundup litigation, settlements and legal shield (Bayer/Monsanto) United States · 2009–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Approved the Roundup label; said it would not accept a cancer warning
- Stockholm Convention agrees chlorpyrifos phase-out with 22 uses exempted United States · 2021–2025
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: regulator
- Trump's EPA keeps Biden-era veto on Alaska's Pebble mine United States · 2023–2025
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Issued and reaffirmed the veto
- US coal ash ponds, groundwater contamination and EPA delay United States · 2015–2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Regulator
- US Defense Department PFAS costs top USD 9.3 billion at 718 installations United States · 2022–2025
- US Government Accountability Office (GAO) (Public authority) — here: Audited Corps oversight of compensatory mitigation in 2005 and 2026; there: Published the PFAS cost report
- US power-plant sulfur emissions fell over 95%, EPA says United States · 1990–2022
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: published the programme results
- US Superfund tax and funding shortfall United States · 1980–2025
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Administers Superfund; reports responsible-party commitments
- US Supreme Court blocks state cancer-warning suits against pesticide makers United States · 2026
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Approved the labels; announced the paraquat review
- US tax deductibility of environmental settlements (IRC 162(f)) United States · 2017
- US Government Accountability Office (GAO) (Public authority) — here: Audited Corps oversight of compensatory mitigation in 2005 and 2026; there: Auditor of the settlement sample (GAO-05-747)
- Volusia County, Florida: beach driving and lighting, Endangered Species Act suit with sea turtles as named plaintiffs United States · 1995–1998
- US Fish and Wildlife Service (Government agency) — here: Approves conservation banks under the Endangered Species Act; there: Named among the parties; role not described in the sources reviewed
- Washakie Renewable Energy, the Kingston family and Dermen: biodiesel tax credits and RINs (United States, 2010–2018) United States · 2010–2023
- US Environmental Protection Agency (Public authority) — here: Co-author of the 1990 agreement, 1995 guidance and 2008 rule; there: Recorded RINs sold for about $65m; FY2023 enforcement summary