If the municipality is delegated the authority to be the local program administator by the state.  Does this authority to review and approve projects also apply to state and federal projects or only to projects proposed by the private developers?

Can a municpality or private individual create a wetland bank or mitigation site and also sell credits as a nutrient mitigation bank?  Enabling these banks to have overlapping functions woukld make the creation of these banks (especially in urbanized areas with higher land costs) much more feasible.  Can existing wetland mitigation banks apply to sell credits?

These regulatory changes appear to have the unattended effect of pushing more development to greenfields since brownfield development is alreadly more difficult and costly.  New stormwater requirments will require larger or multiple parcels in order to achieve the required storm water improvments.  Has this been taken into account during the drafting of these changes?  What is being done to deter the development of greenfields and sprawl.  More should be done to encourage the sustainable development of urban infill sites and the redevelopment of brownfield sites where existing infrastructure is already in place.  Maybe a sliding scale for stormwater improvements should be utilized for urbanized areas versus suburban/exurban areas to reduce sprawl and encourage development with existing state and local infrastructure and services are already in place.