Should We Be Wary of Mitigation Banking? Evidence Regarding the Risks Associated with this Wetland Offset Arrangement in Florida

This paper describes and analyzes the risks associated with using mitigation banking for the conservation of wetlands in Florida in the United States. First, we attempt to identify and summarize the main ecological and socio-economic risks regarding mitigation banking that have been discussed in previous studies. Then we analyze the institutional responses adopted by US regulators to limit these risks. We have used empirical evidence including interviews and data analysis to assess the effectiveness of these responses. Our main findings are that the recent regulatory responses adopted to face risks associated with mitigation banking seem to be more effective than what is often assumed. These responses are underpinned by the emergence of a hybrid mode of governance that combines market characteristics and regulatory constraints, and which contributes to enforcing wetland compensation in Florida. However, we also observed some risks inherent in this system, in particular the redistribution of ecosystem services, as the distance between impact sites and compensation sites seems to have increased in Florida in the last several years. In addition, the question is still pending regarding whether or not No Net Loss of wetlands is really achieved through mitigation banking.