Trading wetlands no longer a deal with the devil"
This Biological Conservation journal article includes criticism and reccommendations for the current US wetland mitigation system from ecologists at University of Illinois.
Criticism 1: The emphasis on larger-scale restoration could lead to spatial arrangements that may not be optimal for society - aka, city folks might miss the wetlands they used to have, as restoration focuses on cheaper land, further away in the watershed.
Criticism 2: Time lags of replacing destroyed wetlands with wetlands created at the time of impact (aka "permittee-responsible mitigation"). Mitigation bankers agree with this criticism, which is why they lobbied to have a preference for mitigation from already-restored wetlands, and that's what gets preference in the 2008 Rules (that, and ILFs with already-restored wetlands). Link to 2008 Rule: http://water.epa.gov/lawsregs/guidance/wetlands/upload/2008_04_10_wetlands_wetlands_mitigation_final_rule_4_10_08.pdf
Criticism 3: Non-equivalence of the sites that are impacted and the sites that are restored. ""The deeper you look into complex ecosystems, the more nonequivalence you find," [author] Matthews said. "You could look at two forests and say they're the same. But as you look closer, you might find that species composition is different. Nutrient cycling processes, for example, may be very different in those two forests. And so as you look in finer and finer detail, you find layers and layers of nonequivalence. Where we place the value becomes critically important. The scale at which we consider two sites to be equivalent or nonequivalent and how we place value on certain uniqueness in sites becomes critical in what we accept as a truly successful restoration."
Recommendations: Scientists are pushing for restoration that is closer to cities to maintain value to communities; more finer-scale like-for-like requirements; more monitoring and research; and adaptive management.
Reality Check: The recommendations would translate to more costly restoration. And do you know who would have to pay for this? Anyone who impacts wetlands: DOTs (everyone's taxes), oil and gas developers (who have lobbyists), builders (who have lobbyists)... see what I'm getting at here? In order to change the system, you'd have to have enormous political will and evidence that the increased value to society would be offset by the increased cost to permitees.