The Tampa Bay Mitigation Bank and Mitigation Banking

cole asset management

In 1996, the Tampa Bay National Estuary Program (TBNEP) published cole asset management Charting the Course: The Comprehensive Conservation and Management Plan for Tampa Bay. Significant loss of mangroves, salt marsh, and wading bird habitats were documented along Tampa Bay’s southeastern shore. Long-term health and sustainability of this area were jeopardized by intensive alteration of the adjacent upland areas. Bird populations, including protected species, such as the white ibis, have been declining regionally due to the loss of freshwater marshes and ponds. Goals were identified to restore estuarine and freshwater wetlands habitat and small freshwater ponds which are critical foraging habitat.

Tampa Bay Mitigation Bank Around the same time as the publication of “Charting the Course”, Tampa Bay Mitigation, LLC realized the unique opportunity to develop a mitigation bank, Tampa Bay Mitigation Bank (TBMB), on a site adjacent to the Cockroach Bay Aquatic Preserve. This site was identified by TBNEP as a priority for wetlands and wildlife habitat restoration, enhancement, and protection.

The TBMB site consists of 161 acres of land surrounding the headwaters of Andrews Creek, on the southeast portion of the peninsula between Little Cockroach Bay and Cockroach Bay, in the Southshore area of Hillsborough County. TBMB initiated site plan design for the restoration and enhancement of the mitigation bank site to address the goals of the TBNEP and to mirror the successes of the adjacent Cockroach Bay Habitat Restoration Project, a joint project between Hillsborough County and Southwest Florida Water Management District.

Historic habitats at the TBMB site included an expansive mosaic of hydric hammock, swamp, pine flatwoods (hydric and upland), and upland hammocks, which offered an abundant variety of ecological benefits to the area. Approximately forty years ago, however, the TBMB site was converted into irrigated row crops and improved pasture. The headwaters of Andrews Creek were channelized for agricultural irrigation and ditches were cut throughout the property to drain and lower surface and groundwater levels, significantly altering site hydrology. A concrete weir was constructed across Andrews Creek, altering the hydrology of this tidal creek system.

Through creation, restoration, and enhancement, the TBMB was designed to provide a diverse variety of ecologically productive habitat types including mangrove forest, salt marsh, freshwater marsh and shallow ponds, and coastal and upland hammock. The concrete weir was removed, restoring the hydrology of Andrews Creek. A tiered system of wetlands was established beginning with the upper freshwater wetlands which flow into the lower oligohaline and then saltwater marshes and mangrove forests. These varying depths provide seasonal and permanent habitats and create freshwater pond foraging habitat for protected species. Significant natural recruitment of red, white, and black mangroves and other native estuarine species has occurred in the tidally influenced areas, closer to Andrews Creek. Additionally, this area has been planted with native estuarine species to supplement the recruited species. Oligihaline areas were then planted and lastly the Freshwater portions of the site.

The site was permitted by SWFWMD and the US Army Corps of Engineers as a mitigation bank through an extensive review process, and approved by the Hillsborough County Environmental Protection Commission. The TBMB is the first and only permitted mitigation bank in the Tampa Bay Basin. A mitigation bank provides greater ecological benefits and long term sustainability unlike many smaller mitigation projects. The bank site is protected in perpetuity, and future management and maintenance are funded through an established trust fund. Various habitat types have been released by regulating agencies for sale as wetland mitigation credits.

Regional Quality of Life Benefit

The creation, enhancement, and protection of the TBMB site have significant regional benefits that improve the quality of life in the Tampa Bay region. First and foremost are the water quality and ecological benefits to Tampa Bay and the Cockroach Bay Aquatic Preserve which provide significant recreational and commercial opportunities. Numerous economic and community benefits associated with improved water quality and ecological conditions in Tampa Bay are now evident.

Tampa Bay Mitigation BankThe availability of a mitigation bank in the Tampa Bay Basin also provides a viable and effective mitigation opportunity in a region currently known for the lack of mitigation options due to the predominately urban nature of the region. The paucity of mitigation opportunities in the region affects not only private economic development, but also affects local government and state sponsored projects proposed to enhance the quality of life including schools, parks, roadways, utilities and other critical infrastructure projects. Lack of mitigation in this region often delays such projects or significantly increases the cost to the public of implementing these community projects. As the economy rebounds, it is important to have cost-effective mitigation available for both private and public projects.

Regional economic growth and changes render development inevitable. With the growing demand for limited resources, sustainability as a way of life has become essential. As defined by the United States Green Building Council, sustainable living is “providing for the needs of the present without detracting from the ability to fulfill the needs of the future.” In terms of growth management planning, wetland mitigation banking is a unique tool that contributes sustainable practices uniting the natural and built environments so they can grow together responsibly. Mitigation banks also allow for an investment in the local environment, both for bank owners and users.

The TBMB serves the entire Region, providing sustainable wetlands mitigation options that will allow needed development and infrastructure improvements for the Tampa Bay area as it grows and changes. Essentially, the TBMB provides the ability and motivations for regional development to fund environmental restoration, which appeals to both ecological and economic interests. Additionally, the TBMB property had development potential and otherwise may have been built-out as commercial and/or residential property.

Benefit to the Environment

By virtue of its approval as a mitigation bank, the state and federal agencies have acknowledged the regional nature of the ecological and water quality benefits of the TBMB site plan as this is a criterion for establishment of a mitigation bank. The primary design goal of the TBMB was to provide regional environmental benefits. Estuarine, Oligohaline and freshwater wetlands are created, enhanced, and protected in perpetuity. Listed species habitat, for example shallow freshwater ponds for white ibis and other wading bird habitat, has been created on the site.

Habitat Types Created

Habitat Type


High Marsh/Tidal Marsh 31.96
Tidal Forest 10.2
Freshwater Marsh 81.26
Freshwater Pond 3.80
Upland/Wetland Hammock 7.76
Upland Hammock 26.25
Total 111.55

The TBMB directly influences the regional quality of water and ecology in the Cockroach Bay Aquatic Preserve and Tampa Bay Estuary, and aids in the protection and preservation of vast amounts of diverse flora and fauna. The TBMB also contributes to the preservation of protected resources such as Threatened, Endangered and Species of Special Concern, wading and migratory birds, Essential Fish Habitat, nursery habitat, mangrove forests, sea grasses, oyster beds, manatees, sea turtles and countless others. These species and habitats are vital to the health and continuation of the rich freshwater, transitional and saltwater ecosystems that comprise the Tampa Bay region. More specifically, some of the ecologically and economically valuable benefits provided by wetlands include (Mitsch and Gosselink (2000a)):

  • Habitat for threatened and endangered plant and wildlife species
  • Flood mitigation by reducing flood damage and storing floodwaters
  • Storm abatement, through salt marshes and mangroves that provide buffers against coastal storms
  • Water quality improvement through processes such as the removal of organic and inorganic nutrients} the removal of toxic substances, sediment trapping, dentrification and chemical precipitation
  • Aesthetics such as wetlands visited by birdwatchers or others who enjoy wetland environments
  • Habitat for fish and shellfish which supports the fisheries industry
  • Habitat for both migratory and non-migratory waterfowl

A former Director of the Environmental Resource Permitting Program at the Southwest Florida Water Management District was quoted on the project in the January 2009 edition of the Florida Specifier:

“This bank is right next to Tampa Bay and provides some estuarine habitat and nursery habitat. This bank is larger than your typical on-site mitigation project so you get some better ecological benefit. The location is also favorable in terms of being close to Tampa Bay which provides more ecological benefits for the habitat,” he said. “The district encourages mitigation banking.”

Mitigation banks offer a more ecologically sound mitigation option than most on-site mitigation. Grouping wetlands habitat together in a contiguous manner offers significant environmental benefits over the typical piecemeal approach of creating small, less productive wetlands on individual private properties in the more urban areas. The mitigation bank is a larger area under one owner with extensive monitoring and reporting requirements. This approach provides the synergistic effects of a larger ecological system and facilitates in compliance reviews by local governments and regulatory agencies. Mitigation banking allows for the establishment of functional wetlands systems well in advance of any project impacts.


The TBMB is the first and only mitigation bank in the Tampa Bay Basin. It serves the entire Tampa Bay Basin including portions of Hillsborough, Manatee, Pasco, and Pinellas counties, by providing an economical and sustainable mitigation option for manageable growth and environmental sustainability. TBMB provides regionally significant coastal wildlife habitat, funded as development occurs as an alternative to expensive and often ineffective on-site wetland mitigation.

Mitigation banking itself is still a relatively new practice which is gaining momentum as state and federal environmental regulatory agencies acknowledge the benefits of the concept. Recently, the federal agencies have directed that mitigation banks should be considered before any other form of mitigation for a permittable project. Mitigation banking in the Tampa Bay region has lagged behind other areas of the state primarily due to limited, suitable and available land.

Additionally, the TBMB was designed and implemented via unconventional means even for a mitigation bank. Partners in the bank each contributed “sweat equity” from their respective fields of expertise including engineering, environmental restoration design and permitting, land excavation and management, land owner negotiations and financial considerations. Perhaps the most innovative aspect of the bank implementation was the use of shell rock mining to affect the majority of land excavation and assist in funding other aspects of the mitigation bank development. During construction, the overburden was removed and set aside. Shell rock was mined from the site and sold and the site re-contoured to meet the design specifications for the wetlands creation and restoration plan. The overburden was redistributed and the site was prepared for planting. Although this approach took more time than is typical for mitigation bank development, it allowed the partners to proceed without outside investors.

Cost Effectiveness

The cost effectiveness of the TBMB can be discussed on several fronts. Mitigation bank credit purchases offer a cost effective approach to achieve environmental protection and preservation goals. Credit purchases are motivated by the fact that landowners (public and private entities) in the Tampa Bay Region potentially face high costs to offset wetland impacts from site development. Mitigating off-site at the TBMB allows them to offset unavoidable impacts and maximize development potential of their site. The TBMB allows regional facilities facing high mitigation costs to meet their regulatory obligations by purchasing environmentally equivalent mitigation credits from the bank to achieve the same (or greater) environmental preservation at a lower overall cost.

The cost of a “credit” often seems high at first look (initially listed at $100K-$150K per credit); however, the cost is often significantly lower than the cost of designing and permitting on-site mitigation projects taking into consideration land costs, consulting and engineering fees, and delays in project implementation. Highly disturbed lands or property in dense urban areas may be more suited to development than wetlands mitigation. Costs for utilizing such lands can be very high due to loss of development potential. There is also no long term liability or monitoring associated with purchasing credits from a mitigation bank. The mitigation banker bears all responsibility for wetlands mitigation success and compliance. Local and state governments have significantly less effort in managing compliance at a bank site versus many small mitigation projects throughout the region. Additionally, in areas such as Tampa Bay where even small mitigation sites are essentially unavailable to many projects, the TBMB offers a much needed source of highly productive wetlands mitigation.

The diverse selection of habitats that now exist at the TBMB provides the aforementioned environmental benefits throughout the Tampa Bay Basin. The development of the mitigation bank by private parties alleviates tax payers and governmental entities from funding the cost of the restoration efforts achieved by the TBMB. The development of the TBMB helps government agencies achieve their environmental objectives without investment of public funds. Because the credits purchased at the TBMB are maintained in perpetuity, the corresponding habitat acreage will remain as an undeveloped, ecologically productive area that will serve as a conservation area.


In summary, the TBMB provides an overwhelming contribution to the Tampa Bay Region in the categories of Regional Quality of Life, Benefit to the Environment, Innovation and Cost-Effectiveness. The project is secured in perpetuity and its ecological and economic benefits will support the Tampa Bay Region for generations to come.