In-Lieu Fee Credit Allocations on Public Lands in the United States: Ecosystem Prioritization and Development-Driven Impacts

Round 1

Reviewer 1 Report

Comments and Suggestions for Authors

Title: In-lieu fee credit allocations on public lands in the United States: Ecosystem prioritization and development-driven impacts

This manuscript provides a timely and comprehensive, data-driven examination of In-Lieu Fee (ILF) programs on U.S. public lands, utilizing the RIBITS database to analyze credit transactions in the post-2008 era. The study addresses a critical topic at the intersection of conservation policy and land management. However, several limitations require revision before publication. 

1. The description of the data extraction process remains overly brief and requires more detailed methodological clarification regarding the keyword selection criteria and implementation procedures. The rationale for selecting only 11 out of 106 ILF programs lacks transparency. The authors must explicitly define their exclusion criteria.
2. In the analysis of proportional differences, a Beta mixed-effects model was employed. Although the authors mention the model’s applicability, the discussion of its underlying assumptions and prerequisites remains insufficient.
3. The author has put forward some policy recommendations in the conclusion, but these suggestions are rather generic and lack specificity. It is recommended that the author conduct a more in-depth discussion based on the research findings and future policy directions, proposing more concrete and actionable policy recommendations to better guide the implementation and management of ILF programs.
4. Some abbreviations are used without full form on first mention (e.g., RIBITS).
5. The reference list is extensive but includes several incomplete entries (e.g., missing volume numbers, pages).

Author Response

Reviewer 1

Thank you very much for your thoughtful and constructive feedback. Your comments on methodological transparency, policy recommendations, and clarity of presentation were especially helpful in strengthening the manuscript, and I have addressed each point in detail in the revision. Here are the overall main points that have been changed:

The manuscript was revised to sharpen framing, improve methodological transparency, and strengthen interpretation of results. The abstract and introduction were streamlined, with ILFs on public lands foregrounded earlier and recent literature (2020–2025) incorporated. Hypotheses were reframed into three clear research questions. The methods now provide fuller detail on data selection, model choice, assumptions, and network analysis decisions. Results were clarified with added percentages, corrected ecosystem interpretation (wetlands vs. streams), simplified technical explanations, and improved figure captions. The discussion was restructured to reduce repetition and emphasize policy and ecological implications, including government-driven uses, small-scale impacts, and service-area dependencies. The conclusion was shortened and made more policy-focused, highlighting interdependencies and ecological effectiveness. References, style, and terminology were standardized, and figures/tables corrected.

 

This manuscript provides a timely and comprehensive, data-driven examination of In-Lieu Fee (ILF) programs on U.S. public lands, utilizing the RIBITS database to analyze credit transactions in the post-2008 era. The study addresses a critical topic at the intersection of conservation policy and land management. However, several limitations require revision before publication. 

1. The description of the data extraction process remains overly brief and requires more detailed methodological clarification regarding the keyword selection criteria and implementation procedures. The rationale for selecting only 11 out of 106 ILF programs lacks transparency. The authors must explicitly define their exclusion criteria.

Reply:

Absolutely, the methods section has been edited and explanations on both the data and methods added where appropriate to provide greater detail, e.g. model selection, clustering algorithm choice. In short data selection is ased on public land ILFs post 2008 approval which are currently few hence the 11 out of 106 (total number of ILFs on both private and public lands and pre-2008). Please refer to the update methods and materials section, thanks.

1. In the analysis of proportional differences, a Beta mixed-effects model was employed. Although the authors mention the model’s applicability, the discussion of its underlying assumptions and prerequisites remains insufficient.

Reply:

As mentioned before the methods have been expanded and greater detail provided regarding e.g. clustering, network analysis and models, thanks for the suggestion.

1. The author has put forward some policy recommendations in the conclusion, but these suggestions are rather generic and lack specificity. It is recommended that the author conduct a more in-depth discussion based on the research findings and future policy directions, proposing more concrete and actionable policy recommendations to better guide the implementation and management of ILF programs.

Reply:

I fully agree. Based on your suggestions and other reviewer comments I have rewritten and restructured the discussion to focus more on the implications rather than too much on the descriptive results. Please refer to the newly added discussion section under section 4, thanks.

1. Some abbreviations are used without full form on first mention (e.g., RIBITS).

Reply:

Thanks for catching that, has been checked and abbreviations are now fully explained at first mention. (e.g. RIBITS first mention is in line 162 - Regulatory In-lieu fee and Bank Information Tracking System).

1. The reference list is extensive but includes several incomplete entries (e.g., missing volume numbers, pages).

Reply:

References have been updated both in terms of completeness as well as of publication date to better capture a few newer studies that haven been released in 2025 since this paper was submitted/ written, thanks.

 

 

Reviewer 2 Report

Comments and Suggestions for Authors

Please find my comments in the attached document.

Comments for author File: Comments.pdf

Author Response

Reviewer 2

I sincerely appreciate your careful review and encouraging remarks. Your suggestions on clarifying inconsistencies in the results, and improving figure presentation were invaluable, and I have incorporated these revisions throughout the manuscript. As an overview here are the main changes based on your very helpful suggestions as well as other reviewer comments:

The manuscript was revised to sharpen framing, improve methodological transparency, and strengthen interpretation of results. The abstract and introduction were streamlined, with ILFs on public lands foregrounded earlier and recent literature (2020–2025) incorporated. Hypotheses were reframed into three clear research questions. The methods now provide fuller detail on data selection, model choice, assumptions, and network analysis decisions. Results were clarified with added percentages, corrected ecosystem interpretation (wetlands vs. streams), simplified technical explanations, and improved figure captions. The discussion was restructured to reduce repetition and emphasize policy and ecological implications, including government-driven uses, small-scale impacts, and service-area dependencies. The conclusion was shortened and made more policy-focused, highlighting interdependencies and ecological effectiveness. References, style, and terminology were standardized, and figures/tables corrected.

 

In-lieu fee credit allocations on public lands in the United States: Ecosystem prioritization

and development-driven impacts

Referee Review

Summary:

This paper provides a novel analysis of In-Lieu Fee (ILF) credit transactions on public lands in the United States after the 2008 Compensatory Mitigation Rule change. Its main contributions are the identification of residential development, resource extraction, and commercial projects as the primary drivers of ILF transactions, and the use of an innovative mix of analytical methods (proportional difference analysis, network analysis, and Sankey diagram) to illustrate the flow and proportion of credits across different ecosystems and reveal the dependencies between different impact types within service areas. The study's key strength lies in its use of a comprehensive national database to explore an under-examined area of U.S. conservation policy, offering valuable insights into the practical application of ILF programs.

General Concept Comments

The manuscript addresses a relevant gap in the conservation policy literature, and you motivate both the topic, and the methods well. The use of the RIBITS database is a significant strength, and I find the application of network analysis to understand co-occurring impacts to be both creative and insightful. That said, I would recommend reframing your hypothesis in a manner that is more harmonious with your analyses and the subsequent discussions. Additionally, I noticed a few inconsistencies that, if addressed, will make the manuscript stronger. I summarize these points generally below, and provide more specific comments further in my review. I end with a small suggestions that may be a tad stylistic in nature, and you can feel free to ignore those if you choose.

Regarding my point about your hypothesis (that government activities would be the primary driver of transactions) -- the data and your analyses seem to refute that, and you find instead that it is private development and resource extraction. That is okay, since hypotheses are rejected all the time, but the burden then falls on you to shape your narrative around that setup. Additionally, you make a strong case for why evaluating government activities in this context is important (lines 89-109), but do not follow that up with an equally strong discussion about the same.

Consequently, your overall narrative feels a little incomplete. I would recommend either

discussing your findings in the context of the (rejected) hypothesis, or reformulating the overall discussion in the last paragraph of the introduction section so that your motivation and your findings are more harmonious.

The second (smaller) issue that I would bring your attention to are the inconsistencies between what is mentioned in the manuscript and what is presented in the figures and results tables. There is some confusion between what the reference ecosystem category in your proportional difference model is – the model specification and the results table suggest it is “Stream”, but the discussion in section 3.2 hints that it is “Wetlands”. You also state that certain data points (clubbed in the “Other” category) are excluded from your analyses, but you then include them in figures and tables. Please address these in future submissions.

Specific Comments

• Lines 224-225 and Table A1: The interpretation of the mixed-effects model is incorrect

(or perhaps the easier explanation is that it was a simple typo/human error). Specifically,

you mention that "Stream credits are allocated at significantly higher proportions", but on

line 163 you state that stream ecosystem is the reference category. Additionally, based on

what I see in the results in Table A1 and , “Stream” is indeed the baseline reference

ecosystem category, and it is instead the coefficient on “Wetlands” that is positive and

statistically significant. This means that wetland credits, not stream credits, are allocated

in significantly higher proportions relative to streams. Please make this correction, as it is

a major finding.

Reply:

Absolutely, that was 100% a human error as part of the editing and writing process, apologies for that. It has been corrected to ‘Wetlands’ which is also to be expected given wetlands being the main target ecosystem for compensatory mitigation, thanks! Regarding the main findings I ultimately decided to restructure and overhaul the discussion to shift the focus away from unnecessarily repeating the findings but focusing more on the actual implications.

• Line 208 and Figures/Tables: The text states that 4 transactions labeled as “'Other' ...

[were] consequently not considered in the analyses.” However, the “Other” category is

clearly included in the network diagram in Figure 3a and in the data in Table A2 and

Table A3. Please address this inconsistency by either removing the statement in the text

(easily done), or by removing the “Other” category from the analyses and visuals (may be

a heavier lift), I am indifferent to which path you choose.

Reply:

Thanks for catching that. Yes, the ‘other’ was only initially considered to be removed but given that I settled on a network approach it was used to paint the whole picture. Has been edited since it is definitely part of the analysis, thanks. 

• Figure 3a and Table A2: On line 258, you mention the “Subaqueous” ecosystem type as

being included in Figure 3a (network connectivity), but it seems to be missing in that

figure. Please update your figure to ensure that it completely represents the data you

analyze.

Reply:

Figure has been updated, thanks! That got cut-off due to its low degree centrality wit having only a single connection but has been added back in the updated figure.

• Figure 2: There is a minor typo in the legend: “Residentialdevelopment” should be

corrected to “Residential development”.

Reply:

Thanks, has been corrected and also the fonts/ spacing increased a bit for readability.

• [Stylistic choice]: it is common practice to represent statistical significance in tables

using asterisks. Typically, researchers use a single asterisk (*) to represent significance at

the 10% level, double asterisks (**) for significance at the 5% level, and triple asterisks

(***) for significance at the 1% level. In such cases, the results are also discussed in

terms of the strength of the findings, which adds an additional layer of nuance to the

analysis. While I believe adopting this approach could strengthen your manuscript, I

recognize that it is ultimately a matter of style and leave the decision to you.

Reply:

I fully agree, thanks. I have changed asterisks accordingly. In regard to fully utilizing all stats I have also moved some of the percentages and CIs for the model and network analyses into the text to provide a bit more nuance and greater depth without having to go into the individual tables.

Reviewer 3 Report

Comments and Suggestions for Authors

Title: In-lieu fee credit allocations on public lands in the United States: Ecosystem prioritization and development-driven impacts
Manuscript ID: Conservation-3854243

General Overview

The manuscript addresses the use of in-lieu fee (ILF) programs as compensatory mitigation mechanisms in the U.S., with a particular focus on their application to public lands since the 2008 Mitigation Rule. This is a relevant and timely contribution, as ILFs remain under-studied relative to mitigation banks despite their significant policy implications. The work is well-grounded in regulatory context and makes use of the RIBITS database to provide quantitative insights into credit transactions.

The significance lies in highlighting how development, resource extraction, and government projects drive ILF transactions, and how ecosystems—especially wetlands and streams—are prioritized. The originality is evident in the public lands focus, which is often neglected in offsetting literature.

Shortcomings, however, include:

The abstract (lines 8–26) overstates contributions without adequately clarifying the methodological depth.

The introduction (lines 28–109) is lengthy and could be more sharply framed.

The methods section (lines 110–197) is technically sound but needs clearer justification for model choices and more details on assumptions.

The results (lines 198–281) are solid but somewhat descriptive; more emphasis on implications is needed.

The discussion (lines 288–397) sometimes repeats results rather than critically interpreting them.

The conclusion (lines 403–426) is appropriate but could be more concise and policy-oriented.

Overall, the manuscript is suitable for publication after major revisions focusing on clarity, framing, and critical interpretation.

Section-wise Comments

Abstract (Lines 8–26)

Line 9–11: The phrase “important mechanism for compensatory mitigation” is vague; specify why ILFs are especially important on public lands.

Line 13–16: Clarify the time frame (post-2008 approvals) earlier for context.

Line 18–22: The description of dependencies and scaling analysis is overly technical for an abstract. Recommend simplifying for accessibility.

Line 23–25: The claim about “complementary role to mitigation banks” should be softened—currently overstated without sufficient comparative evidence.

Introduction (Lines 28–109)

Line 30–34: The overview of threats to freshwater systems is comprehensive, but the link to ILFs on public lands is not made until much later. Suggest tightening background to foreground the policy question.

Line 40–49: The explanation of mitigation hierarchy is clear, but consider citing more recent policy reviews beyond 2018.

Line 64–71: The criticism that “at the time of credit sale, no physical offsets exist” could be expanded with recent empirical critiques (e.g., program delays, underperformance).

Line 72–77: The statement that ILFs make up “18% of sites and 6% of programs” is useful but should be tied more explicitly to the rationale for this study.

Line 83–88: The research objective is well stated, but the scope (“situated on public land”) should be made explicit earlier.

Line 89–109: The hypothesis section is strong, though somewhat speculative. Consider framing as research questions rather than a single hypothesis.

Methods (Lines 110–197)

Line 113–115: Clarify how “public lands” were operationalized in RIBITS (federal vs. state vs. local jurisdiction).

Line 121–129: Table 1 is informative, but abbreviations (RB, RD, etc.) are introduced abruptly—remind readers that full terms are explained later.

Line 146–156: The transformation of proportions for Beta regression is appropriate, but explain why this model is preferable over alternatives (e.g., logit-transformed linear models).

Line 157–163: Clarify the choice of reference categories (stream ecosystem, CD impact). Why these specifically?

Line 174–179: The bipartite network description is clear, but justify the cutoff of p(Z)<0.5. Why not a more stringent threshold?

Line 187–195: The Leiden algorithm choice is well motivated, but briefly mention why Louvain or other methods were not suitable.

Results (Lines 198–281)

Line 200–211: The reporting of credit transactions is clear, but it would benefit from a relative percentage breakdown, not just raw counts.

Line 217–229: The interpretation of model results (seagrass, tidal significance) should include confidence intervals in-text rather than only in the appendix.

Line 230–238: The negative association with residential development is interesting; highlight implications earlier instead of waiting for the discussion.

Line 255–263: The description of degree centrality (e.g., RB, GV nodes) is somewhat technical. Consider simplifying or moving details to the appendix.

Figures 2–3: Well-designed, but captions should better explain their relevance (policy or ecological implications).

Discussion (Lines 288–397)

Line 290–297: The emphasis on wetlands reflects known ILF trends; stress more strongly why this is significant for public lands specifically.

Line 298–315: The argument about smaller-scale impacts (e.g., docks, private property) is a useful insight; expand with citations to private landowner challenges.

Line 316–327: The explanation of government-driven uses is accurate but overly descriptive; critically assess whether current ILF design adequately addresses these.

Line 329–341: The scaled proportion discussion is valuable but repeats earlier results. Focus instead on policy implications.

Line 349–397: The discussion of dependencies within service areas is one of the strongest parts. However, it could benefit from connecting to broader land-use planning debates (e.g., cumulative impacts).

Conclusions (Lines 403–426)

Line 409–412: The statement that “findings align with policy shifts” is sound, but add a brief reflection on whether ILFs are achieving ecological effectiveness, not just policy compliance.

Line 420–425: The comment about interdependencies is important; suggest highlighting it earlier in the abstract as a key finding.

The conclusion could be shortened by ~25% to make it sharper and policy-oriented.

Minor and Technical Comments

References (Lines 463–607): Several citations are outdated (e.g., [28], [29]); recommend incorporating post-2020 literature on ILFs and compensatory mitigation.

Figures: Ensure all sources of icons/graphics are properly credited with permission.

Grammar/Style: Occasional long sentences (e.g., lines 90–106, 288–296) should be split for clarity.

Consistency: Use either “ILF” or “in-lieu fee program” consistently; sometimes both appear interchangeably.

Major Suggestions for Improvement

Sharpen the framing: More clearly position the study within debates on ILFs versus mitigation banks, and highlight novelty of the public lands angle.

Balance description vs. critique: The results are detailed but under-interpreted. Strengthen policy and ecological implications in the discussion.

Tighten sections: Shorten introduction and conclusion by ~20%, making them more focused.

Update references: Add recent offsetting/ILF research post-2020 for currency.

Author Response

Reviewer 3

Thank you for your thorough and insightful review. Your guidance on tightening the abstract and introduction, enhancing the methods justifications, and focusing the discussion on implications rather than repetition significantly improved the clarity and overall contribution of the paper. All the best and thanks again for taking the time!

General Overview

The manuscript addresses the use of in-lieu fee (ILF) programs as compensatory mitigation mechanisms in the U.S., with a particular focus on their application to public lands since the 2008 Mitigation Rule. This is a relevant and timely contribution, as ILFs remain under-studied relative to mitigation banks despite their significant policy implications. The work is well-grounded in regulatory context and makes use of the RIBITS database to provide quantitative insights into credit transactions.

The significance lies in highlighting how development, resource extraction, and government projects drive ILF transactions, and how ecosystems—especially wetlands and streams—are prioritized. The originality is evident in the public lands focus, which is often neglected in offsetting literature.

Shortcomings, however, include:

The abstract (lines 8–26) overstates contributions without adequately clarifying the methodological depth.

The introduction (lines 28–109) is lengthy and could be more sharply framed.

The methods section (lines 110–197) is technically sound but needs clearer justification for model choices and more details on assumptions.

The results (lines 198–281) are solid but somewhat descriptive; more emphasis on implications is needed.

The discussion (lines 288–397) sometimes repeats results rather than critically interpreting them.

The conclusion (lines 403–426) is appropriate but could be more concise and policy-oriented.

Overall, the manuscript is suitable for publication after major revisions focusing on clarity, framing, and critical interpretation.

As a general overview here are the main changes based on your excellent suggestions as well as other reviewer comments:

The manuscript was revised to sharpen framing, improve methodological transparency, and strengthen interpretation of results. The abstract and introduction were streamlined, with ILFs on public lands foregrounded earlier and recent literature (2020–2025) incorporated. Hypotheses were reframed into three clear research questions. The methods now provide fuller detail on data selection, model choice, assumptions, and network analysis decisions. Results were clarified with added percentages, corrected ecosystem interpretation (wetlands vs. streams), simplified technical explanations, and improved figure captions. The discussion was restructured to reduce repetition and emphasize policy and ecological implications, including government-driven uses, small-scale impacts, and service-area dependencies. The conclusion was shortened and made more policy-focused, highlighting interdependencies and ecological effectiveness. References, style, and terminology were standardized, and figures/tables corrected.

Section-wise Comments

Abstract (Lines 8–26)

Line 9–11: The phrase “important mechanism for compensatory mitigation” is vague; specify why ILFs are especially important on public lands.

Reply:

I fully agree, thanks for pointing that out. Has been clarified and their role re-emphasized (lines 10-12).

Line 13–16: Clarify the time frame (post-2008 approvals) earlier for context.

Reply:

Has been edited, thanks.

Line 18–22: The description of dependencies and scaling analysis is overly technical for an abstract. Recommend simplifying for accessibility.

Reply:

Very true. Has been simplified as part of the reworked key findings in lines 25-30.

Line 23–25: The claim about “complementary role to mitigation banks” should be softened—currently overstated without sufficient comparative evidence.

Reply:

Thanks for pointing that out. I agree fee programs tend to fill a niche rather than being complementary. Has been edited. Lines 28-30.

Introduction (Lines 28–109)

Line 30–34: The overview of threats to freshwater systems is comprehensive, but the link to ILFs on public lands is not made until much later. Suggest tightening background to foreground the policy question.

Reply:

I agree, has been edited to shorten said section and tie into ILFs earlier.

Line 40–49: The explanation of mitigation hierarchy is clear, but consider citing more recent policy reviews beyond 2018.

Reply:

Absolutely, especially given recent and anticipated policy changes and new studies that have come out in 2025 after the manuscript was submitted. I have revised and added more recent references at this point as well as on ILFs in general, thanks.

Especially Peterson and BenDor have an interesting recent one on ILFs as funding sources for development and infrastructure as well as Schelsky et al. on ILFs and endangered species which is interesting considering that those are normally covered through conservation banks and the ESA.

Mitigation hierarchy-wise there is an excellent new study on moving beyond the hierarchy and strengthening the different steps prior to offsetting, e.g., by Kornov et al.

References have been revised and expanded throughout the introduction, thanks!

Line 64–71: The criticism that “at the time of credit sale, no physical offsets exist” could be expanded with recent empirical critiques (e.g., program delays, underperformance).

Reply:

Absolutely, it goes hand in hand with most criticism on advance credits for offsets in general. Point has been expanded in lines 73-77.

Line 72–77: The statement that ILFs make up “18% of sites and 6% of programs” is useful but should be tied more explicitly to the rationale for this study.

Reply:

Thanks for this excellent suggestion. I have tied these two numbers stronger to the objectives and rationale.

Line 83–88: The research objective is well stated, but the scope (“situated on public land”) should be made explicit earlier.

Reply:

I fully agree. I thought it fits best after introducing base concepts like NNL etc. so I have added the introduction to public lands along lines 57-60, as well as an early mention in line 47 now as well.

Line 89–109: The hypothesis section is strong, though somewhat speculative. Consider framing as research questions rather than a single hypothesis.

Reply:

Thanks for the suggestion. I have edited the hypotheses and their objectives towards three key research questions that directly relate to the three presented research justifications to be more tangible and less speculative, thanks! Lines 125-151.

Methods (Lines 110–197)

Line 113–115: Clarify how “public lands” were operationalized in RIBITS (federal vs. state vs. local jurisdiction).

Reply:

I fully agree, that is important formation for the reader. The public land criteria have been clarified, thanks. Lines 133 and following.

Line 121–129: Table 1 is informative, but abbreviations (RB, RD, etc.) are introduced abruptly—remind readers that full terms are explained later.

Reply:

Very true, that is a bit of an unfortunate placement for the table given that the full definitions follow later. Disclaimer has been added in the table caption, thanks! (Table 1)

Line 146–156: The transformation of proportions for Beta regression is appropriate, but explain why this model is preferable over alternatives (e.g., logit-transformed linear models).

Reply:

Thanks for this excellent suggestion. I have added a small section under 2.2.2 to cover model alternatives and reasoning for going with a beta mixed-effects model.

Line 157–163: Clarify the choice of reference categories (stream ecosystem, CD impact). Why these specifically?

Reply:

Absolutely. Has been added in 2.2.2 as well.

Line 174–179: The bipartite network description is clear, but justify the cutoff of p(Z)<0.5. Why not a more stringent threshold?

Reply:

That is a very good point. There are different thresholds suggested in the literature, especially the accompanying R documentation and github documents. Overall, the goal of the network analysis is to show meaningful connections in an exploratory sense, hence 0.5 is an already reduced constrained network before adding statistical layers e.g., like clustering. In the end the network should show as many connections as possible and as few as necessary to explore interconnectedness. Generally speaking, 0.5 is good for exploratory aspects since it covers probable coincidence, between two events when their conditional probability is greater than 50%. However, you are absolutely correct that depending on what you are interested in you could move that threshold in either direction increasing or decreasing the network constraints. Has been clarified in 2.2.3, thanks again.

Line 187–195: The Leiden algorithm choice is well motivated, but briefly mention why Louvain or other methods were not suitable.

Reply:

Again, very helpful to include those justifications. Has been clarified in 2.2.3 now. In short Leiden is tends to fare better than e.g., Louvain by retaining within cluster connections while being well suited for smaller or complex datasets, which is the case here not necessarily based on the transaction sample size but the limited program number and large amount of subset categories e.g., RD, RE etc.

Results (Lines 198–281)

Line 200–211: The reporting of credit transactions is clear, but it would benefit from a relative percentage breakdown, not just raw counts.

Reply:

Thanks for this helpful suggestion. I agree, percentages do add to clarity and the have been added throughout.

Line 217–229: The interpretation of model results (seagrass, tidal significance) should include confidence intervals in-text rather than only in the appendix.

Reply:

I fully agree, CIs have been moved from the appendix to the text for 3.2, thanks.

Line 230–238: The negative association with residential development is interesting; highlight implications earlier instead of waiting for the discussion.

Reply:

That is true. It can be a bit tricky to separate implications and results sufficiently but in this case I do agree. Has been edited at this point and for other results in 3.2 to summarize important findings prior to the discussion, thanks for the suggestion.

Line 255–263: The description of degree centrality (e.g., RB, GV nodes) is somewhat technical. Consider simplifying or moving details to the appendix.

Reply:

I agree. Has been simplified to improve clarity in 3.3. Basically, degree centrality = number of direct connections a node has, which tells us how immediately important or connected that node is in the network, I think this explanation and consequent use in the text will make it more intuitive, thanks for the suggestion.

Figures 2–3: Well-designed, but captions should better explain their relevance (policy or ecological implications).

I agree. Captions have been improved to make them more stand-alone in terms of content and level of detail.

Discussion (Lines 288–397)

Line 290–297: The emphasis on wetlands reflects known ILF trends; stress more strongly why this is significant for public lands specifically.

Line 298–315: The argument about smaller-scale impacts (e.g., docks, private property) is a useful insight; expand with citations to private landowner challenges.

Line 316–327: The explanation of government-driven uses is accurate but overly descriptive; critically assess whether current ILF design adequately addresses these.

Line 329–341: The scaled proportion discussion is valuable but repeats earlier results. Focus instead on policy implications.

Line 349–397: The discussion of dependencies within service areas is one of the strongest parts. However, it could benefit from connecting to broader land-use planning debates (e.g., cumulative impacts).

Conclusions (Lines 403–426)

Line 409–412: The statement that “findings align with policy shifts” is sound, but add a brief reflection on whether ILFs are achieving ecological effectiveness, not just policy compliance.

Line 420–425: The comment about interdependencies is important; suggest highlighting it earlier in the abstract as a key finding.

The conclusion could be shortened by ~25% to make it sharper and policy-oriented.

Reply:

Thank you kindly for the detailed and constructive suggestions for the discussion and conclusions. As mentioned before, based on the comments and other reviewer suggestions I decided to rework the discussion completely to shift the focus away from being too results heavy and more towards the actual implications and management recommendations. Please refer to the revised discussion section.

Round 2

Reviewer 1 Report

Comments and Suggestions for Authors

I have reviewed the authors' response to the previous round of comments and the revised version of the manuscript. All my previous concerns have been adequately addressed. Therefore, I  recommend acceptance of the manuscript for publication.

Author Response

Thank you once again for taking the time during the review process. All the best and thanks again.

Reviewer 3 Report

Comments and Suggestions for Authors

Title: In-Lieu Fee credit allocations on public lands in the United States: Ecosystem prioritization and development-driven impacts
Manuscript Number: Conservation-3854243

Overview of Manuscript

This manuscript examines how In-Lieu Fee (ILF) programs operate on U.S. public lands, analyzing credit allocations, drivers of impacts, and ecosystem targets post-2008 Compensatory Mitigation Rule. The study uses data from RIBITS and applies statistical and network-based methods to highlight the role of private versus government-driven development pressures.

Significance:
The topic is timely and relevant to conservation policy, especially as ILF programs continue to evolve under regulatory scrutiny. The analysis provides quantitative evidence of how residential, commercial, and resource extraction projects shape mitigation outcomes.

Shortcomings:

Some sections remain overly descriptive and could benefit from clearer framing of hypotheses and implications.

Figures and tables are informative but need stronger integration into the narrative.

Methodological details are thorough, but a few require clarification for reproducibility.

The discussion could expand further on policy and ecological trade-offs beyond U.S. contexts.

Extent of Revision:
Compared with the earlier version, the manuscript shows substantial revision (approx. 30–35% expanded content). The Introduction has been significantly lengthened with more citations (lines 29–93), Methods are more detailed (lines 122–228), and Results have additional quantitative depth (lines 229–328). Figures and network analysis (lines 299–338) are new or enhanced. The Discussion has been reframed around policy implications (lines 339–446). These changes improve rigor but still leave room for refinement.

Section-by-Section Comments

Abstract (lines 8–27)

Line 17–22: The description of interdependency between development types is strong, but it could briefly specify why this matters for policy planning. Suggest rephrasing to emphasize management implications.

Line 23–26: The contrast between ILFs and mitigation banks is valuable. Consider briefly mentioning limitations of ILFs here for balance.

Introduction (lines 29–120)

Line 40–49: Strengthen linkage between mitigation hierarchy and ILFs. Currently, the narrative jumps from theory to offsets; clarify how ILFs operationalize the hierarchy.

Line 66–70: This critique of ILFs is accurate but feels repetitive. Suggest condensing.

Line 93–104: The research questions are clear, but add a statement connecting them to broader conservation policy relevance (e.g., federal land management).

Methods (lines 122–228)

Line 124–129: The definition of “public lands” is precise, but please add justification for excluding mixed-ownership programs. Could this exclusion bias the results?

Line 170–179: The proportion transformation method is sound, but specify why a beta model was chosen over alternatives beyond just boundedness.

Line 202–212: In coincidence analysis, clarify why a threshold of p(Z)<0.5 was chosen. This is unusually high and may raise reviewer questions.

Results (lines 229–328)

Line 235–242: The prevalence of residential development is an important finding. Recommend adding comparative percentages against government-driven activities for clarity.

Line 253–266: The variability in credit proportions is well-analyzed. Suggest adding ecological interpretation—why wetlands show more variability than streams.

Line 299–310: Strong use of network analysis, but more explanation in the text would help readers not familiar with network metrics.

Discussion (lines 339–446)

Line 351–368: The finding that private development dominates is important. Suggest connecting this with existing land-use policy debates (e.g., zoning, suburban sprawl).

Line 393–412: Excellent integration of watershed approach; however, highlight challenges in implementing watershed-scale planning (jurisdictional fragmentation, funding).

Line 429–445: The call for advanced credit pricing is strong. Recommend discussing feasibility—are agencies equipped for such complex valuation models?

Conclusions (lines 447–468)

Line 452–459: Emphasize again the shift from government to private pressures. This is the main contribution and should be clearly stated.

Line 463–466: The suggested refinements are appropriate, but consider reframing as “actionable recommendations” for policymakers.

Figures & Tables

Figures are clear, but captions are overly descriptive (e.g., Figure 3, lines 331–338). Condense text and move some explanation to the Results section.

Table 1 (lines 161–168) is helpful, but a summary table comparing government vs. non-government contributions would strengthen the Results.

Comments (Summary)

Clarify methodological thresholds and assumptions (e.g., p(Z)<0.5, exclusion of mixed ownership).

Strengthen policy framing by linking findings more explicitly to land management strategies.

Streamline overly descriptive text in Introduction and Discussion to improve focus.

Expand cross-comparison with mitigation banks and other offset mechanisms for context.

Provide more ecological interpretation of quantitative results to appeal to conservation readers.

 

Author Response

Overview of Manuscript

This manuscript examines how In-Lieu Fee (ILF) programs operate on U.S. public lands, analyzing credit allocations, drivers of impacts, and ecosystem targets post-2008 Compensatory Mitigation Rule. The study uses data from RIBITS and applies statistical and network-based methods to highlight the role of private versus government-driven development pressures.

Significance:
The topic is timely and relevant to conservation policy, especially as ILF programs continue to evolve under regulatory scrutiny. The analysis provides quantitative evidence of how residential, commercial, and resource extraction projects shape mitigation outcomes.

Shortcomings:

Some sections remain overly descriptive and could benefit from clearer framing of hypotheses and implications.

Figures and tables are informative but need stronger integration into the narrative.

Methodological details are thorough, but a few require clarification for reproducibility.

The discussion could expand further on policy and ecological trade-offs beyond U.S. contexts.

Extent of Revision:
Compared with the earlier version, the manuscript shows substantial revision (approx. 30–35% expanded content). The Introduction has been significantly lengthened with more citations (lines 29–93), Methods are more detailed (lines 122–228), and Results have additional quantitative depth (lines 229–328). Figures and network analysis (lines 299–338) are new or enhanced. The Discussion has been reframed around policy implications (lines 339–446). These changes improve rigor but still leave room for refinement.

Comments (Summary)

Clarify methodological thresholds and assumptions (e.g., p(Z)<0.5, exclusion of mixed ownership).

Strengthen policy framing by linking findings more explicitly to land management strategies.

Streamline overly descriptive text in Introduction and Discussion to improve focus.

Expand cross-comparison with mitigation banks and other offset mechanisms for context.

Provide more ecological interpretation of quantitative results to appeal to conservation readers.

Reply:

Thanks again for the helpful and constructive follow-up feedback. I appreciate the time you have taken to go through the revised version of the manuscript. Please see the section-by-section replies to the main points addressed.

 

Section-by-Section Comments

Abstract (lines 8–27)

Line 17–22: The description of interdependency between development types is strong, but it could briefly specify why this matters for policy planning. Suggest rephrasing to emphasize management implications.

Reply:

Thanks, that makes sense. Has been added to the abstract. Lines 17-22.

The main advantages here are that co-occurrence of different impact types can help with anticipatory planning. E.g. if impact A occurs in an area then there is a high chance for impact B to also occur simultaneously or in the future as well as the associated credit demand for it.

 

Line 23–26: The contrast between ILFs and mitigation banks is valuable. Consider briefly mentioning limitations of ILFs here for balance.

Reply:

Absolutely, limitations have been added. Overall, the main one is naturally advance credits which can be highlighted here given the word restriction in an abstract.

 

Introduction (lines 29–120)

Line 40–49: Strengthen linkage between mitigation hierarchy and ILFs. Currently, the narrative jumps from theory to offsets; clarify how ILFs operationalize the hierarchy.

Reply:

Thanks for the suggestion, the link has been strengthened as ILFs are offsets, hence follow the mitigation hierarchy as the final step for residual impacts.

 

Line 66–70: This critique of ILFs is accurate but feels repetitive. Suggest condensing.

Reply:

For sure, the section has been condensed and incorporated in the previous sentences on advance credits to keep the criticism together. Overall lines 53-59 now should cover the basic setup of third-party offsetting and lines 64-72 should focus more on the critique to reduce repetition.

 

Line 93–104: The research questions are clear, but add a statement connecting them to broader conservation policy relevance (e.g., federal land management).

Reply:

Thanks for the suggestion. I added a statement to connect the questions to broader conservation policies – rephrased the previous closing sentence. Lines 124-130.

 

Methods (lines 122–228)

Line 124–129: The definition of “public lands” is precise, but please add justification for excluding mixed-ownership programs. Could this exclusion bias the results?

Reply:

Has been removed as the official definition splits ILFs strictly into public or private lands and the very few exceptions refer to ownership which then can be public/ private.

 

Line 170–179: The proportion transformation method is sound, but specify why a beta model was chosen over alternatives beyond just boundedness.

Reply:

Thanks for the suggestion. I have expanded the justification for model use at this point. In short (aside from boundedness) it allows to include a random effect over a classic beta regression as well as accounts for heterogeneity among statistical units (already mentioned in the text) and finally deals better with uneven observations or missing data.

 

Line 202–212: In coincidence analysis, clarify why a threshold of p(Z)<0.5 was chosen. This is unusually high and may raise reviewer questions.

Reply:

This was clarified last time through “… <0.5 (n = 305 transactions), which is appropriate for exploratory analysis of a sparse dataset, suggesting probable coincidence, between two categories when their conditional probability is greater than 50%.” It really is not about significance values but probabilities of co-occurrence hence 0.5 is a common approach as also reference by the accompanying literature to construct a comprehensive yet still not overly complex network.

 

Results (lines 229–328)

Line 235–242: The prevalence of residential development is an important finding. Recommend adding comparative percentages against government-driven activities for clarity.

Reply:

Thanks, has been shifted to pair GV results more with e.g. RD to better show the contrast.

 

Line 253–266: The variability in credit proportions is well-analyzed. Suggest adding ecological interpretation—why wetlands show more variability than streams.

Reply:

That makes sense, has been added, Lines 268-270. It mainly comes down to the increased human-wetland interface (e.g. often more likely to be impacted by human development based on distribution and human sprawl) as well as wetlands covering a lot of different subtypes.

 

Line 299–310: Strong use of network analysis, but more explanation in the text would help readers not familiar with network metrics.

Reply:

Thanks for this suggestion. I have added a sentence at the beginning to reiterate and summarize the main concepts of network analysis and what they mean in this specific context before going into the detailed results. Lines 316-318.

 

Discussion (lines 339–446)

Line 351–368: The finding that private development dominates is important. Suggest connecting this with existing land-use policy debates (e.g., zoning, suburban sprawl).

Reply:

Thanks for the suggestion, has been added at lines 388-394.

 

Line 393–412: Excellent integration of watershed approach; however, highlight challenges in implementing watershed-scale planning (jurisdictional fragmentation, funding).

Reply:

That makes sense, thanks. Has been added after the strengths of using a watershed approach. Overall, the main and most common constraint is resource limitations both in manpower and actual funds to properly coordinate and maintain watershed or larger scale efforts. David Poulton did write an excellent summary of ILF/ ILP experiences covering many of those issues.

 

Line 429–445: The call for advanced credit pricing is strong. Recommend discussing feasibility—are agencies equipped for such complex valuation models?

Reply:

That is interesting point which goes back to the previous funding limitations. The push is for faster turnaround times (in most countries) for permits to under an ‘economic’ framing addressing resource independent and housing. So overall advance credits and expedited approvals will not go away I the future so ultimately the only way to improve their use and reduce risks of net loss is in better models that account for mor ecosystem services and help reduce risks. There are excellent efforts e.g. EESV and other approaches to better valuate and capture ecosystem services. Currently agencies are not well equipped to make use of these newer approaches but ideally in the future, especially when they become more robust and easier to use. There are some robust Rapid Assessment methodologies for offsets/ credits so expanding those could be a first step and then slowly build on the further required modelling capacity and expertise. Even just going through the different standards and metrics (e.g. for mitigation banks) used across districts can pose an issue when introducing new assessment requirements. Has been added at this point, thanks.

Conclusions (lines 447–468)

Line 452–459: Emphasize again the shift from government to private pressures. This is the main contribution and should be clearly stated.

Reply:

I fully agree, private pressures have been emphasized more I the conclusions.

 

Line 463–466: The suggested refinements are appropriate, but consider reframing as “actionable recommendations” for policymakers.

Reply:

Thanks for the suggestion, has been changed to ‘actionable recommendations’.

 

Figures & Tables

Figures are clear, but captions are overly descriptive (e.g., Figure 3, lines 331–338). Condense text and move some explanation to the Results section.

Reply:

Thanks, has been condensed.

 

Table 1 (lines 161–168) is helpful, but a summary table comparing government vs. non-government contributions would strengthen the Results.

Reply:

I agree, however government vs non-government contributions are covered in the figures as well as all Appendix tables. Table 1 is merely meant for descriptive/ definition purposes for the methods.