Guest commentary by Becca Madsen, director of the Restoration Economy Center at the Environmental Policy Innovation Center (EPIC)
California’s water delivery projects are in desperate need of large-scale, shovel-ready mitigation solutions. Projects like the $4.4 billion Sites Reservoir exemplify the massive infrastructure investments requiring extensive environmental offsets. Meanwhile, water utilities are getting creative and venturing into nature-based solutions—like San Bernardino Valley Municipal Water District’s $51.3 million Enhanced Recharge Project that integrates groundwater recharge with habitat restoration. Yet even as state legislators discuss permitting reforms to address the state’s housing crisis and ambitious renewable energy goals, they’ve overlooked the crisis in approving the environmental restoration required to mitigate these developments. The faster California can permit restoration projects, the faster the state will progress without adding a biodiversity debt to its balance sheet.
Under the California Endangered Species Act, development projects must avoid, minimize, and then offset any harm to protected species. Conservation banks restore and protect expanses of habitat that serve as offsets after meeting ecological success criteria. Because restoration is established before impacts occur, conservation bank credits are preferred over piecemeal offsets in both state and federal policies. Even so, they still take between 761-1,740 days for state review–nearly triple the statutory 270-day timeline– creating a growing bottleneck in supply and thousands of unrestored acres.
The consequences of delays are becoming evident. Without readily available conservation banks, developers must promise future offsets while seeking suitable restoration opportunities – a process that can stretch for years to decades. For example, CalMatters reported on the delayed restoration tied to the LA-area Playa Vista – 20 years overdue. Initial research shows 40% of promised offsets for state endangered species are still pending.
California is making progress on its 30×30 goal of conserving 30% of its land by 2030, and leadership recognizes the challenges ahead. Since the mid-2000s, Sustainable Conservation and other state stakeholders championed paths to Cutting Green Tape for restoration projects, and the initiative gained significant momentum when Natural Resources Secretary Wade Crowfoot made streamlining restoration a key priority. This program has shown remarkable results – saving millions and cutting restoration permit processing times to 45 days.
In fact, out of the dozens of efforts we’ve researched across the country to streamline permitting, California’s Cutting Green Tape initiative stands among the best. Despite this success, there’s still work to be done: of the 200+ restoration projects that benefited from streamlined processes, we found few for compliance purposes. Some voices in the environmental community eschew offsets, but the fish don’t care who restored the river so long as the outcomes are verified (a requirement for conservation banks). Delaying the review process for restoration used for offsets doesn’t prevent development – it only enables impacts to outpace the required restoration, and the affected resources ultimately bear the cost of delays. Sustainable Conservation’s 2024 report recommends agencies convene to streamline permitting for offsets projects, including for conservation banks. That’s a great idea to implement, but California shouldn’t stop there.
For example, CDFW could follow the U.S. Army Corps of Engineers’ recent approach for offsets from wetland mitigation banks (a swampy sibling of conservation banks). In September 2024, Corps leadership issued directives prioritizing review deadlines and expediting project approvals for these banks. Given the similarities between the Corps’ and California’s review processes for offset projects, CDFW could adopt similar measures while maintaining standards for high value environmental outcomes.
After multiple hearings last fall, the Assembly Select Committee on Permitting Reform has now released its final report, highlighting best practices for permit efficiencies to meet target housing, renewable energy, and disaster recovery goals. Yet to balance progress with 30×30 goals, they must ensure that environmental offsets keep pace with anticipated development. This means embracing Cutting Green Tape as a philosophy for program management and extending these streamlined processes to restoration projects used for offsets. By addressing regulatory processes for conservation banks with the same urgency as development, California can build the infrastructure it needs for tomorrow while paying down—rather than compounding—its biodiversity debt today.
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Becca Madsen is the director of the Restoration Economy Center at the Environmental Policy Innovation Center (EPIC).
Disclosure: EPIC has received funding from the California Restoration Business Association. EPIC maintains independence in analysis and reporting of research findings, as it has in similar work conducted at the state and national level.
Biography: Becca Madsen has over 15 years of experience analyzing issues at the intersection of natural resources and economics. She has analyzed and written on topics ranging from data science applications to environmental issues, to global biodiversity offset policies, to feasibility of water quality trading in the Chesapeake Bay. Prior to joining EPIC, she spent nine years managing and conducting research on a wide range of topics related to natural resources at the Electric Power Research Institute (EPRI). Prior to EPRI, Ms. Madsen worked for Ecosystem Marketplace, the US Forest Service, local government in North Texas, and the Peace Corps. Ms. Madsen holds a B.A in business administration from the University of South Carolina Honors College and a Master of Environmental Management from Duke University. Ms. Madsen was a Doris Duke Conservation Fellow, a Presidential Management Fellow, and a PERC Enviropreneur Fellow.
Note: The views and opinions expressed in this commentary are those of the author and do not necessarily reflect the official policy or position of Maven’s Notebook.

COMMENTARY: California’s restoration bottleneck deepens biodiversity debt
Guest commentary by Becca Madsen, director of the Restoration Economy Center at the Environmental Policy Innovation Center (EPIC)
California’s water delivery projects are in desperate need of large-scale, shovel-ready mitigation solutions. Projects like the $4.4 billion Sites Reservoir exemplify the massive infrastructure investments requiring extensive environmental offsets. Meanwhile, water utilities are getting creative and venturing into nature-based solutions—like San Bernardino Valley Municipal Water District’s $51.3 million Enhanced Recharge Project that integrates groundwater recharge with habitat restoration. Yet even as state legislators discuss permitting reforms to address the state’s housing crisis and ambitious renewable energy goals, they’ve overlooked the crisis in approving the environmental restoration required to mitigate these developments. The faster California can permit restoration projects, the faster the state will progress without adding a biodiversity debt to its balance sheet.
Under the California Endangered Species Act, development projects must avoid, minimize, and then offset any harm to protected species. Conservation banks restore and protect expanses of habitat that serve as offsets after meeting ecological success criteria. Because restoration is established before impacts occur, conservation bank credits are preferred over piecemeal offsets in both state and federal policies. Even so, they still take between 761-1,740 days for state review–nearly triple the statutory 270-day timeline– creating a growing bottleneck in supply and thousands of unrestored acres.
The consequences of delays are becoming evident. Without readily available conservation banks, developers must promise future offsets while seeking suitable restoration opportunities – a process that can stretch for years to decades. For example, CalMatters reported on the delayed restoration tied to the LA-area Playa Vista – 20 years overdue. Initial research shows 40% of promised offsets for state endangered species are still pending.
California is making progress on its 30×30 goal of conserving 30% of its land by 2030, and leadership recognizes the challenges ahead. Since the mid-2000s, Sustainable Conservation and other state stakeholders championed paths to Cutting Green Tape for restoration projects, and the initiative gained significant momentum when Natural Resources Secretary Wade Crowfoot made streamlining restoration a key priority. This program has shown remarkable results – saving millions and cutting restoration permit processing times to 45 days.
In fact, out of the dozens of efforts we’ve researched across the country to streamline permitting, California’s Cutting Green Tape initiative stands among the best. Despite this success, there’s still work to be done: of the 200+ restoration projects that benefited from streamlined processes, we found few for compliance purposes. Some voices in the environmental community eschew offsets, but the fish don’t care who restored the river so long as the outcomes are verified (a requirement for conservation banks). Delaying the review process for restoration used for offsets doesn’t prevent development – it only enables impacts to outpace the required restoration, and the affected resources ultimately bear the cost of delays. Sustainable Conservation’s 2024 report recommends agencies convene to streamline permitting for offsets projects, including for conservation banks. That’s a great idea to implement, but California shouldn’t stop there.
For example, CDFW could follow the U.S. Army Corps of Engineers’ recent approach for offsets from wetland mitigation banks (a swampy sibling of conservation banks). In September 2024, Corps leadership issued directives prioritizing review deadlines and expediting project approvals for these banks. Given the similarities between the Corps’ and California’s review processes for offset projects, CDFW could adopt similar measures while maintaining standards for high value environmental outcomes.
After multiple hearings last fall, the Assembly Select Committee on Permitting Reform has now released its final report, highlighting best practices for permit efficiencies to meet target housing, renewable energy, and disaster recovery goals. Yet to balance progress with 30×30 goals, they must ensure that environmental offsets keep pace with anticipated development. This means embracing Cutting Green Tape as a philosophy for program management and extending these streamlined processes to restoration projects used for offsets. By addressing regulatory processes for conservation banks with the same urgency as development, California can build the infrastructure it needs for tomorrow while paying down—rather than compounding—its biodiversity debt today.
–
Becca Madsen is the director of the Restoration Economy Center at the Environmental Policy Innovation Center (EPIC).
Disclosure: EPIC has received funding from the California Restoration Business Association. EPIC maintains independence in analysis and reporting of research findings, as it has in similar work conducted at the state and national level.
Biography: Becca Madsen has over 15 years of experience analyzing issues at the intersection of natural resources and economics. She has analyzed and written on topics ranging from data science applications to environmental issues, to global biodiversity offset policies, to feasibility of water quality trading in the Chesapeake Bay. Prior to joining EPIC, she spent nine years managing and conducting research on a wide range of topics related to natural resources at the Electric Power Research Institute (EPRI). Prior to EPRI, Ms. Madsen worked for Ecosystem Marketplace, the US Forest Service, local government in North Texas, and the Peace Corps. Ms. Madsen holds a B.A in business administration from the University of South Carolina Honors College and a Master of Environmental Management from Duke University. Ms. Madsen was a Doris Duke Conservation Fellow, a Presidential Management Fellow, and a PERC Enviropreneur Fellow.
Note: The views and opinions expressed in this commentary are those of the author and do not necessarily reflect the official policy or position of Maven’s Notebook.
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