“Excellence” is Job One

The hierarchy in the 2008 Rule, which places mitigation banks as the top priority for wetland replacement, was an important acknowledgement of the unprecedented success of banking over any previous attempts at protecting the environment. With that designation comes a responsibility for us in the banking industry to uphold the highest standards of integrity and performance in this important work.

Restoring and protecting the environment is complicated, and it takes many years in this business to learn these challenges and gain the skills needed to succeed. Bankers become experts in creating and protecting environmental values.

Those who believe banks are too expensive are usually not aware of what it takes to succeed long term. Individuals who think that putting thousands of cuttings into the ground will get their mitigation done, are not prepared when they come back and see that they have all died. The frequency of failures with other forms of mitigation has not been well-studied since the National Academy of Science report in 2001, but it is extremely high. Unfortunately, today taxpayers are often subsidizing inferior, poor-quality mitigation projects. The cost to taxpayers to try to enforce performance standards with failed projects has not been quantified, but it is substantial.

We urge our members to join us in building a reputation for unquestioned excellence in restoring and protecting the environment. Our government is looking to expand the opportunities for banking to many other areas of needed environmental restoration.  We should work to give them confidence that we take the responsibility for high standards to heart and will perform with consistent excellence.