Banking Bad Science?

I was just on a conference call of the National Mitigation Banking Association when someone referenced this very significant policy statement from the Society of Wetland Scientists.

It was issued a couple of years ago (a pleasant surprise to our industry) and I had just about forgotten about it.

Then I kicked myself in the pants!

Why had I not remembered to send the policy statement to reporter Amos Esty before he wrote this cynical piece about mitigation banking for American Scientist?

Its not my job to do his research but I should have. (A simple Google search for the terms Wetland Scientists Mitigation Banking would have turned up the position paper of as the first hit!)

In his article Esty leaves the clear impression that mitigation banking, at best, is a two-sided issue with respect to science, or, at worst, a case of business objectives in conflict with sound science. It’s neither. It might fit a sceptical working narrative but it doesn’t reflect the truth.

The truth is that mitigation banks are on sound scientific and policy ground. The truth is that all mitigation can fail if improperly designed – like anything. And also true, if you do not suggest an alternative to what you view as bad policy — you have no credibility and shouldn’t get ink.

This is particularly true of Esty’s other source. Esty chose as his representative wetland scientist, Joy Zedler. Among other silliness, Dr. Zedler offers a typically romantic and unproductive question: “How do you re-create something that took nature a thousand years to develop?”

My answers:

First, how does a beaver? I have seen many a fine highly functioning wetland built by beaver without waiting a “thousand years.”

Second, who says we are trying to “replicate” anything? The federal policies realistically demand the system mitigate damage done by development – not “re-create” anything. The last time I looked “mitigate” meant lessen the severity, not make perfect again. RS believes this is done by restoring wetlands that no longer serve any function — but sure can in the future.

Third, losing wetlands to development, and our imperfect way of mitigating that sad fact, may indeed disappoint Dr. Zedler. But until I hear her prescription for reform she has zero credibility with me as a critic.

Fourth, asking such question simply isn’t helping meet the challenge at hand. If such a question were asked in the medical field, we would tell people with failing livers they may be better off on dialysis, than dare attempt to “replicate” the integrity of the original with a transplant.

Finally, why is it not reported that Zedler is on The Nature Conservancy’s Governing Board? The Nature Conservancy, a $4 billion organization, has tremendous financial interest in the continued use of preservation based mitigation – a mitigation method described as follows by the Sierra Club:

“the preservation of existing wetlands is under no circumstances an acceptable form of compensatory mitigation for wetland losses because it will result in a net loss of wetland acreage and functions.”

Why is it not a story that an oft-quoted wetland scientist like Zedler governs an organization that supports policies that are in “no circumstances acceptable” to one of the world’s largest environmental groups?

Here’s why: Its not about wetlands – its about politics. Dr. Zedler, TNC, the Sierra Club, even in disagreement over fundamental policy points – are fellow travelers. To investigate their differences and intellectual conflicts would undermine the comfortable feeling that they know best, shared by most of the press.

The bias here is not based on science, but based on a skeptical elitist attitude toward anyone not motivated by “grants and goodwill” to restore wetlands, but rather a desire to get the job done in a competitive free-market fashion. Like RS.

Given this pervasive cynicism toward private-sector efforts, we should not expect to see Dr. Zedler brought to account soon for her unhelpful statements.

Society of Wetland Scientists

TITLE Wetland Mitigation Banking


The Society of Wetland Scientists supports wetland mitigation banking to improve mitigation success and contribute to the goal of no net loss of wetlands. Banked wetlands are systems that have been restored or created for compensatory mitigation in advance of those unavoidable impacts to wetlands permitted by regulatory authorities. The banked wetlands should be managed, protected in perpetuity, functionally similar to the altered systems and within defined geographical areas.

Endorsement and citations here