In biodiversity conservation, mitigation means steps taken to avoid, minimize, or offset the impacts of human activities on the biodiversity world. Strong mitigation helps conserve existing natural resources and recover degraded ones, and federal agencies have wide authority to require activities which they carry out or provide permits for – such as development – properly apply mitigation. The National Oceanographic and Atmospheric Administration (NOAA) recently released a draft mitigation policy to cover its activities. Defenders appreciates NOAA’s development of such a policy, but as written it lacks sufficient rigor and fails to address certain key elements of mitigation policy. In these comments we identify shortcomings and offer recommendations to improve the policy.