Who gains from saving nature
Ledger 1 : 33 — For each dollar financing nature-based solutions in 2023, about $33 financed activities harmful to nature. (UNEP)
Cases / Carbon credits · United States · 1988–2026

US compensatory mitigation and conservation banking under the "no net loss" policy

Nature's voice · report
In excess of; industry-funded estimate, survey response rate under 20% 3.5 billion US dollars were earned in sales in my name. What was measured is below what was promised: The NRC reported that permits required about 1.8 acres of compensation per acre permitted, while the no-net-loss goal for wetland functions was still not met.
Did nature suffer? Not measured. Accounts differ ↓
What the record lacks: 5 none on record · 2 insufficient · 1 not measured · 6 disputed · 1 unclear See the gaps
Accounts of the harm differ
Whether compensatory mitigation achieves the national goal of no net loss
  • Researchers National Research Council (2001): "The goal of no net loss of wetlands is not being met" for wetland functions, though area losses had slowed; third-party systems such as banks "offer some advantages" over permittee-responsible mitigation. National Research Council, National Academies Press
  • Researchers Kihslinger, Environmental Law Institute (2008): Of 19 studies, 10 found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant; the programme may currently lead to a net loss in wetland acres and functions. Environmental Law Institute
  • Researchers Sonter et al. (2019): California species banks averted 62 ha of habitat loss and 1,424 ha of habitat gains in 2001–2011; equivalence with impact sites could not be determined. Sonter, Barnes, Matthews and Maron
  • Government and regulators Army Corps of Engineers and EPA (2008 rule): Compensatory mitigation is a critical tool toward no net loss; the rule says banks reduce temporal loss and uncertainty compared with in-lieu fee advance credits, and it concedes that some projects do not fully replace functions and services. Army Corps of Engineers and EPA
  • Government and regulators GAO (2026): Corps oversight frequency has generally improved since 2005, but districts are inconsistent on financial assurances, long-term management and performance standards; the sample is not generalisable. US Government Accountability Office
Net national trend in US wetlands
  • Government and regulators US Fish and Wildlife Service (2024 status report): 116.4 million acres of wetland in the conterminous US in 2019; the news page reports loss figures of 221,000 and 670,000 acres without defining either, and says vegetated-wetland loss increased by more than 50% over the previous period. US Fish and Wildlife Service
  • Press and investigations E&E News (2018, citing FWS 2009): The US recorded a slight net gain in wetlands between 1996 and 2004. E&E News by POLITICO

Since 1988 the United States has pursued a goal of no net loss of wetlands, met in part through compensatory mitigation that developers buy from banks. The market runs to billions of dollars a year by the sources' estimates; the National Research Council (2001), GAO (2005, 2026) and peer-reviewed studies report shortfalls in outcomes or oversight.

in excess of US$3.5 billion estimateDirect revenue of the US wetland and stream compensatory mitigation industry, 2019
Estimate by BenDor, Kwon and Lester (PLOS ONE, 27 September 2023), funded by an industry association with a survey response rate under 20%. Other estimates in the sources differ in year, scope and definition.

Status As of June 2026: the Corps–EPA 2008 rule is the operative framework; GAO reported improved oversight in April 2026 with remaining inconsistencies; no source measures whether credits sold offset the losses at impact sites.

What?
The United States pursues a goal of no net loss of wetlands and acts on it through compensatory mitigation, including purchased credits from mitigation and conservation banks. Market estimates run to billions of dollars a year, and outcome studies and audits report shortfalls in results or oversight. Army Corps of Engineers and EPA
Where?
United States nationwide; California holds the largest number of conservation banks (82 active and sold-out in the 2011 Update). Ecosystem Marketplace / Forest Trends
When?
Goal announced 1988; Army–EPA agreement 1990; bank guidance 1995; Corps–EPA rule 2008; NRC 2001, GAO 2005 and 2026, Sonter 2019 and BenDor 2023 reviews. Army Corps of Engineers and EPA
Who?
Gained
  • Mitigation and conservation bankers — Direct revenue of the US wetland and stream compensatory mitigation industry was in excess of US$3.5 billion in 2019 according to an industry-funded estimate PLOS ONE
  • Wildlands, Inc. and its investor Parthenon Capital — Parthenon announced an investment in Wildlands on 20 March 2007; the company's revenue is not on record Wildlands, Inc. and Parthenon Capital
Lost
None on record
Harmed
  • Wetlands and species habitat at impact sites — The NRC found functional equivalence is seldom achieved within 5 years and that fens and bogs cannot be effectively restored with present knowledge; Sonter et al. state equivalence with impact sites could not be determined National Research Council, National Academies Press
Why?
Federal policy sets a goal of no net loss of wetland acreage and function while permitting some development; the rule and guidance present banks as a way to compensate with less temporal loss and uncertainty. Army Corps of Engineers and EPA
How?
Developers who need Clean Water Act section 404 permits or Endangered Species Act take authorisation avoid and minimise impacts and then buy credits from banks or fund other compensation; the Corps and FWS approve and oversee banks. Army Corps of Engineers, EPA, USDA NRCS, FWS and NMFS
6 of 6 questions answered from the record

What happened

The record, in order.

The national goal of no net loss of wetlands has a dated policy chain. In 1987, at the request of the US Environmental Protection Agency (EPA), a National Wetlands Policy Forum chaired by New Jersey Governor Thomas Kean was convened. E&E News reported that on Labor Day weekend 1988 the then vice president and candidate George H. W. Bush announced a goal of "no net loss of wetlands", citing losses of about 500,000 acres a year; the text of the speech was not found. On 15 November 1988 the Forum report recommended no net loss as the national goal. A Memorandum of Agreement between the Army and EPA dated 6 February 1990 set a mitigation sequence of avoiding, minimising and then compensating for losses; the lawyer Oliver Houck wrote that it was signed in November 1989, was delayed twice by the White House and amended, and that the amendments made the goal "less attainable than ever". On 28 November 1995 federal agencies issued guidance on mitigation banks (60 FR 58605), which said banks could contribute to the goal of no overall net loss. On 10 April 2008 the Army Corps of Engineers (Corps) and EPA published a final rule on compensatory mitigation (73 FR 19594, effective 9 June 2008) that gave bank credits preference over in-lieu fee advance credits.

A conservation bank or wetland mitigation bank is protected or restored land divided into credits; a developer who must offset habitat or wetland losses buys credits instead of restoring land itself. Market estimates vary with year and definition. Ecosystem Marketplace put species banking at about US$370 million a year and wetland mitigation at US$3.3 billion a year, about US$1 billion of it through banks (December 2008). Its 2011 update, with 2010 data, put the global market at "at least" US$2.4 billion to US$4.0 billion a year and US aquatic compensatory mitigation and conservation banking at US$2.0 billion to US$3.4 billion a year, and counted 1,044 active and sold-out US wetland, stream and conservation banks, 82 of them conservation banks in California. A 2017 report put global transactions at US$4.8 billion in 2016. BenDor and colleagues (2023) estimated the 2019 direct revenue of the US wetland and stream compensatory mitigation industry at more than US$3.5 billion, with total output of more than US$9.6 billion, more than 53,000 jobs and nearly 2,200 banks by October 2022. As of 2026 the Corps' RIBITS database listed more than 4,700 bank and in-lieu fee project sites, and an FWS-approved list cited in 2022 held 173 conservation banks covering about 260,000 acres and 57 listed species. Wildlands, Inc. described itself in 2007 as the largest mitigation banker in California; a Wildlands vice-president said in 2015 that wetland credits were worth "about half a million dollars per acre", which he called a guess.

Outcome studies of wetland mitigation report shortfalls. The National Research Council (2001) found that "the goal of no net loss of wetlands is not being met" for wetland functions, although area losses had slowed. It reported that permits required about 1.8 acres of compensation per acre permitted, that Corps data were inadequate to confirm the status of compensation wetlands, that mitigation wetlands "seldom achieve functional equivalency" with reference sites or permit requirements within 5 years, and that fens and bogs "cannot be effectively restored with present knowledge". The Government Accountability Office (GAO-05-898, 2005) reviewed 152 permit files and found monitoring reports required in 89 and evidence of receipt in 21; of 85 bank files, 60 required monitoring reports and 70% showed receipt of at least one. Kihslinger (Environmental Law Institute, 2008) reported about 47,000 acres of mitigation required per year against about 21,000 acres of permitted losses; of 19 studies reviewed, 10 found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant. She concluded the programme "may currently lead to a net loss in wetlands acres and functions". The 2008 federal rule itself states that "there are compensatory mitigation projects that do not fully succeed in replacing the functions and services".

For species conservation banks, Sonter and colleagues (Conservation Letters, 2019) studied 59 California banks covering 15,350 ha. Between 2001 and 2011 the banks averted 62 ha of habitat loss and unexpectedly averted habitat gains of 1,424 ha, 35 times greater; equivalence with the impact sites could not be determined because records of losses at impact sites covered by sold credits do not exist. A World Biodiversity Forum 2026 conference abstract by Verner-Crist, which is not a peer-reviewed article, reported 30 years of monitoring at 36 California banks: 23% never documented the target species on site, 56% failed to demonstrate successful breeding, and most were not required to show the target species present before selling credits. The Delhi Sands flower-loving fly case is one data point: FWS found in 2008 that about 10% of remaining potential fly habitat had protected status.

GAO's April 2026 follow-up (GAO-26-106827) sampled 85 files from three Corps districts, including 28 banks, and found oversight frequency generally improved since 2005 while districts remained inconsistent on financial assurances, long-term management and performance standards; GAO said the sample is not generalisable. The Department of Defense agreed with its one recommendation, on implementation guidance. FWS's 2024 wetlands status report found 116.4 million acres of wetland in the conterminous US in 2019; its news page gave loss figures of 221,000 and 670,000 acres without defining either, and said vegetated-wetland loss increased by more than 50% over the previous period. No FWS conservation-banking rule after a July 2022 advance notice of proposed rulemaking was found.

  1. 1987National Wetlands Policy Forum convened at EPA's request, chaired by Governor Thomas Kean
  2. 1988Labor Day weekend: George H. W. Bush announces a goal of no net loss of wetlands (E&E News); 15 November: Forum report recommends no net loss as the national goal
  3. 1990Army–EPA Memorandum of Agreement on mitigation dated 6 February (Houck dates its signing to November 1989)
  4. 1995Federal guidance on mitigation banks issued (60 FR 58605, 28 November)
  5. 2001National Research Council report finds the no-net-loss goal for wetland functions is not being met (June)
  6. 2005GAO-05-898 finds the Corps lacks an effective oversight approach for compensatory mitigation (8 September)
  7. 2008Corps–EPA compensatory mitigation rule published (73 FR 19594, 10 April; effective 9 June); Ecosystem Marketplace sizes species banking at about US$370 million a year (December)
  8. 2011Ecosystem Marketplace 2011 Update counts 1,044 US wetland, stream and conservation banks (2010 data)
  9. 2017Forest Trends reports US$4.8 billion in global biodiversity-mitigation transactions in 2016 (December)
  10. 2019Sonter et al. publish a study of 59 California species conservation banks
  11. 2022FWS advance notice of proposed rulemaking on conservation banking (July); 173 FWS-approved conservation banks cited
  12. 2023BenDor et al. estimate 2019 industry direct revenue above US$3.5 billion (27 September)
  13. 2026GAO-26-106827 reports improved Corps oversight with remaining inconsistencies (30 April); World Biodiversity Forum abstract on California banks (June)

What was said

Claims, in the words of those who made them.

“no net loss of wetlands”

George H. W. Bush, then vice president, announcing a national goal (as reported by E&E News) · Labor Day weekend 1988 · E&E News by POLITICO

“a unifying standard”

“less attainable than ever”

“the goal of no net loss of wetlands is not being met”

“seldom achieve functional equivalency with reference sites or comply with permit requirements within 5 years”

“there are compensatory mitigation projects that do not fully succeed in replacing the functions and services”

“may currently lead to a net loss in wetlands acres and functions”

“about half a million dollars per acre”

A Wildlands, Inc. vice-president, on the price of wetland credits, which he called a guess · 12 February 2015 · KPBS

Where accounts differ

Each party's account, side by side, with its source. The record does not settle these points; it shows them.

Whether compensatory mitigation achieves the national goal of no net loss
Researchers
National Research Council (2001)

"The goal of no net loss of wetlands is not being met" for wetland functions, though area losses had slowed; third-party systems such as banks "offer some advantages" over permittee-responsible mitigation.

National Research Council, National Academies Press
Researchers
Kihslinger, Environmental Law Institute (2008)

Of 19 studies, 10 found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant; the programme may currently lead to a net loss in wetland acres and functions.

Environmental Law Institute
Researchers
Sonter et al. (2019)

California species banks averted 62 ha of habitat loss and 1,424 ha of habitat gains in 2001–2011; equivalence with impact sites could not be determined.

Sonter, Barnes, Matthews and Maron
Government and regulators
Army Corps of Engineers and EPA (2008 rule)

Compensatory mitigation is a critical tool toward no net loss; the rule says banks reduce temporal loss and uncertainty compared with in-lieu fee advance credits, and it concedes that some projects do not fully replace functions and services.

Army Corps of Engineers and EPA
Government and regulators
GAO (2026)

Corps oversight frequency has generally improved since 2005, but districts are inconsistent on financial assurances, long-term management and performance standards; the sample is not generalisable.

US Government Accountability Office
Size of the US mitigation market
Researchers
Ecosystem Marketplace (2008)

Species banking about US$370 million a year; wetland mitigation US$3.3 billion a year, about US$1 billion of it through banks.

Ecosystem Marketplace
Researchers
Ecosystem Marketplace 2011 Update (2010 data)

US aquatic compensatory mitigation and conservation banking US$2.0 billion to US$3.4 billion a year; the global market at least US$2.4 billion to US$4.0 billion.

Ecosystem Marketplace / Forest Trends
Researchers
BenDor, Kwon and Lester (2023)

2019 direct revenue of the US wetland and stream compensatory mitigation industry in excess of US$3.5 billion. The study lists earlier estimates of US$2.9 billion (ELI, fiscal 2003), US$1.3 billion to US$2.2 billion (2010), US$1.8 billion to US$3.2 billion (2011) and US$1.45 billion to US$5.7 billion (2017).

PLOS ONE
Standard-setters and registries
Forest Trends (2017)

Nearly US$5 billion globally in 2016, of which mitigation banks US$3.6 billion (press release); the presentation deck gives US$4.8 billion and an estimated US$3.8 billion a year for US wetland banking.

Forest Trends
Researchers
Study funders and method

The 2023 study was funded by the Ecological Restoration Business Association, an industry group, and had a survey response rate under 20%.

PLOS ONE
Net national trend in US wetlands
Government and regulators
US Fish and Wildlife Service (2024 status report)

116.4 million acres of wetland in the conterminous US in 2019; the news page reports loss figures of 221,000 and 670,000 acres without defining either, and says vegetated-wetland loss increased by more than 50% over the previous period.

US Fish and Wildlife Service
Press and investigations
E&E News (2018, citing FWS 2009)

The US recorded a slight net gain in wetlands between 1996 and 2004.

E&E News by POLITICO
When the Army–EPA mitigation agreement was signed
Researchers
Oliver Houck (1990)

The agreement was signed in November 1989, delayed twice by the White House and then amended.

Environmental Law Reporter
Government and regulators
Federal Register (1995, 2008)

The operative agreement is dated 6 February 1990.

Army Corps of Engineers and EPA

How it looked

What was shown, beside what was recorded.

Shown

  • Compensatory mitigation described as "a critical tool in helping the federal government to meet the longstanding national goal of `no net loss' of wetland acreage and function".
    Army Corps of Engineers and EPA, 2008 final rule · Army Corps of Engineers and EPA
  • Mitigation banks described as able to "contribute towards attainment of the goal for no overall net loss of the Nation's wetlands".
  • Wildlands, Inc. described as "the largest mitigation banker in California".
    Wildlands' founder and chief executive, in a 20 March 2007 release on Parthenon Capital's investment · Wildlands, Inc. and Parthenon Capital

Recorded

  • NRC 2001: the no-net-loss goal for wetland functions was not being met; about 1.8 acres of compensation were required per acre permitted; Corps data could not confirm the status of compensation wetlands.
  • GAO-05-898 (2005): of 152 permit files, monitoring reports were required in 89 and evidence of receipt appeared in 21; evidence of a compliance inspection appeared in 15%. Of 85 bank files, 60 required reports and 70% showed receipt of at least one; 36% showed an inspection. Two of three recommendations are recorded as closed, not implemented.
  • GAO-26-106827 (30 April 2026): oversight frequency generally improved since 2005 in a sample of 85 files, with inconsistencies on financial assurances, long-term management and performance standards; the sample is not generalisable.
  • Kihslinger (2008): about 47,000 acres of mitigation required per year against about 21,000 acres of permitted losses; 10 of 19 studies found most projects compliant with permit conditions and 9 found only 4% to 49% fully compliant.
  • Sonter et al. (2019): 59 California species conservation banks averted 62 ha of habitat loss and 1,424 ha of habitat gains between 2001 and 2011; equivalence with impact sites could not be determined.
  • World Biodiversity Forum 2026 abstract: at 36 California banks, 23% never documented the target species and 56% failed to demonstrate successful breeding; the abstract is not a peer-reviewed article.

In nature's name

What was promised in nature's name, the money that moved, and what was measured.

Promised

  • “a critical tool in helping the federal government to meet the longstanding national goal of `no net loss' of wetland acreage and function” — Army Corps of Engineers and EPA, final rule on compensatory mitigation (10 April 2008) Army Corps of Engineers and EPA
  • “contribute towards attainment of the goal for no overall net loss of the Nation's wetlands” — Federal agencies, guidance on mitigation banks (on what banks can do) (28 November 1995) Army Corps of Engineers, EPA, USDA NRCS, FWS and NMFS

Money moved in nature's name

WhatKindAmountPeriod
Direct revenue of the US wetland and stream compensatory mitigation industry
US wetland and stream compensatory mitigation industry
PLOS ONE
Sales$3.5bn estimate2019
US species banking, annual market
US species banks
Ecosystem Marketplace
Sales$370m estimate2008 report
US wetland mitigation, annual market
US wetland mitigation
Ecosystem Marketplace
Sales$3.3bn estimate2008 report
Banking segment of US wetland mitigation
US wetland mitigation banks
Ecosystem Marketplace
Sales$1bn estimate2008 report
US aquatic compensatory mitigation and conservation banking
US aquatic compensatory mitigation and conservation banking programmes
Ecosystem Marketplace / Forest Trends
Sales$2bn estimate2010 data
Global biodiversity-mitigation transactions
Global biodiversity-offset and compensation programmes
Forest Trends
Sales$4.8bn estimate2016
US wetland banking sector, estimated annual transactions
US wetland banking sector
Forest Trends
Sales$3.8bn estimate2016
Wetland credit price estimated by a Wildlands vice-president
Wildlands, Inc.
KPBS
Sales$0.5m estimate2015

What was measured

Measured below the promise

Independent reviews (NRC 2001, GAO 2005 and 2026) and peer-reviewed studies (Sonter et al. 2019) report that the no-net-loss goal for wetland functions was not being met, that oversight evidence was lacking or inconsistent, and that equivalence with impact sites could not be determined for species banks. Market-size figures come from industry-linked estimates; they measure money, not benefit to nature.

No-net-loss goal for wetland functions
Not being met (2001)
Permit files with monitoring reports received
21 of 89 files requiring them
GAO-05-898, 152 permit files US Government Accountability Office
Habitat loss averted by 59 California species banks, 2001–2011
62 ha
Sonter et al. 2019; 1,424 ha of habitat gains also averted Sonter, Barnes, Matthews and Maron
Banks that never documented the target species
23% of 36
World Biodiversity Forum 2026 abstract, not peer-reviewed Verner-Crist, World Biodiversity Forum 2026
The NRC reported that permits required about 1.8 acres of compensation per acre permitted, while the no-net-loss goal for wetland functions was still not met. National Research Council, National Academies Press

Findings on record

  • Official audit National Research Council (2001-06) · Compensating for Wetland Losses Under the Clean Water Act: “the goal of no net loss of wetlands is not being met” National Research Council, National Academies Press
  • Official audit US Government Accountability Office (2005-09-08) · GAO-05-898: “Does Not Have an Effective Oversight Approach to Ensure That Compensatory Mitigation Is Occurring” US Government Accountability Office
  • Own admission Army Corps of Engineers and EPA (2008-04-10) · Compensatory Mitigation for Losses of Aquatic Resources, 73 FR 19594: “there are compensatory mitigation projects that do not fully succeed in replacing the functions and services” Army Corps of Engineers and EPA
  • Peer-reviewed study Sonter, Barnes, Matthews and Maron, Conservation Letters (2019) · Quantifying habitat losses and gains made by U.S. Species Conservation Banks Sonter, Barnes, Matthews and Maron
  • Peer-reviewed study BenDor, Kwon and Lester, PLOS ONE (2023-09-27) · Assessing the size and growth of the US wetland and stream compensatory mitigation industry PLOS ONE
  • Official audit US Government Accountability Office (2026-04-30) · GAO-26-106827: “Has Improved Oversight of Compensatory Mitigation, but Needs Implementation Guidance” US Government Accountability Office

Who gained

Money that reached nature, beside money that stayed elsewhere.

Reached nature or the ground

Not published
No figure published.

Gained elsewhere

Not totalled
Currency: USD · Window: Mixed — see each line. Figures cover different periods and are not compared as a ratio. * Estimate built from cited figures.

Responses on record

  • US Army Corps of Engineers and EPA (10 April 2008): The 2008 final rule states that compensatory mitigation is "a critical tool" toward the national goal of no net loss, that some projects "do not fully succeed in replacing the functions and services", and that it incorporated recommendations of the 2001 NRC report and the 2001 and 2005 GAO reports. · Army Corps of Engineers and EPA
  • US Army Corps of Engineers (2005 report, status as of 2026): GAO recorded two of three recommendations of its 2005 report as closed, not implemented. · US Government Accountability Office
  • US Department of Defense (April 2026): Agreed with GAO's one recommendation, on implementation guidance, in GAO-26-106827. · US Government Accountability Office
  • Wildlands, Inc. (20 March 2007; 12 February 2015): Described itself in 2007 as "the largest mitigation banker in California" and in 2015 estimated wetland credits at "about half a million dollars per acre", which its vice-president called a guess. · Wildlands, Inc. and Parthenon Capital

In court and with insurers

Every proceeding and every insurer decision on record.

Lawsuits and rulings

No court case on record. No court has ruled on this case.

Insurers

No insurer decision on record.

What nature saw

Outcomes measured on the ground, and nature's note.

Nature's report opens this page. Below: further outcomes measured on the ground.

No-net-loss goal for wetland functions
Not being met (NRC, 2001)
Area losses had slowed; about 1.8 acres of compensation were required per acre permitted
Permit files with evidence of monitoring reports received
21 of 89 required
GAO-05-898 (2005), 152 permit files reviewed
Habitat loss averted by 59 California species banks, 2001–2011
62 ha
Sonter et al. (2019); equivalence with impact sites could not be determined
California banks that never documented the target species
23% of 36
World Biodiversity Forum 2026 abstract, not peer-reviewed

What we don't know

Undisclosed, unproven, untried: recorded as data.

Nature

  • Not measured Harm to nature: The record holds no measurement of harm to nature.
  • Disputed Whether compensatory mitigation achieves the national goal of no net loss
  • Disputed Net national trend in US wetlands

Accounts

  • Disputed Size of the US mitigation market
  • Disputed When the Army–EPA mitigation agreement was signed

Record

  • None on record None on record: a measurement of whether the habitat or wetland lost at the sites covered by sold credits was equivalent to what the credits protect; Sonter et al. state that records of losses at impact sites covered by sold credits do not exist.
  • None on record None on record: the number and names of listed species with no conservation bank, and California's current share of conservation banks.
  • None on record None on record: an FWS conservation-banking rule after the July 2022 advance notice of proposed rulemaking.
  • None on record None on record: a direct annual market estimate for 2022 to 2025; the latest figure in the sources reviewed is for 2019.
  • None on record None on record: annual revenue of Wildlands, Inc. or an independent ranking of it; the company's releases and the press reviewed give no revenue figure, and its current owner is not stated on the company site.
  • Insufficient Insufficient: the FWS 2024 wetlands status page gives loss figures of 221,000 and 670,000 acres without defining either, so the net national trend is unresolved.
  • Disputed Disputed: the 2017 report is cited as nearly US$5 billion and US$4.8 billion, and mitigation banks as US$3.6 billion in the press release and an estimated US$3.8 billion a year for US wetland banking in the presentation deck.
  • Disputed Disputed: the 2011 Update text gives US$2.0 billion to US$3.4 billion for US aquatic compensatory mitigation and conservation banking, while an Ecosystem Marketplace article on the same data gives US$2 billion to US$3.6 billion for wetland and stream banking.
  • Unclear Unclear: the date of the Army–EPA agreement. Houck dates its signing to November 1989; federal documents date the operative agreement to 6 February 1990.
  • Insufficient Unconfirmed: a search summary cited an FWS fact sheet saying 105 conservation banks had been approved as of October 2011, and another summarised an archived January 2021 speciesbanking.com page linking a dataset of 832 US wetland and stream banks.

Did the harm stop?

The sources reviewed do not report that wetland or habitat loss under the programme has stopped. FWS's 2024 wetlands report says vegetated-wetland loss increased by more than 50% compared with the previous study, though its loss figures are not defined on the page reviewed.

Who paid?

Developers and permit holders buy credits from banks. The industry estimates range from US$370 million a year for species banking (2008) to direct revenue of more than US$3.5 billion for wetland and stream compensatory mitigation (2019). The sources reviewed give no total paid for credits whose impact sites were measured.

Sources

Voices on record: ✓ Company or project✓ Government and regulators— Courts✓ Press and investigations✓ Communities and civil society✓ Researchers

Company or project

  1. Wildlands, Inc. Announces Investment by Parthenon Capital
    Wildlands, Inc. and Parthenon Capital · 2007-03-20
  2. Who we are
    Wildlands, Inc. · 2026

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Related matters, and cases linked to this one through the same organisations, with the role each played in both.

Science and environment

Hectare (ha)
A unit of area equal to 10,000 square metres, about 2.5 acres. 100 hectares make one square kilometre.
PFOA (C8) and PFAS
PFAS are a large family of human-made chemicals that persist in the environment and the body; PFOA, also called C8, is one of them and was used to make Teflon.
Wetland
Land that is saturated or covered with water for long periods, such as marshes, swamps and peat bogs.

Institutions

EPA
The US Environmental Protection Agency.

Carbon and conservation finance

Offset
Using carbon credits to balance emissions released elsewhere, so that a buyer can claim lower or zero net emissions.
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Dutch nitrogen crisis and farm buyouts
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Posidonia oceanica meadows (Balearics, Mediterranean)
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Sengwer evictions from Embobut forest and the EU Water Towers programme (Kenya)
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