I would start by saying that the concept of habitat banking isn't very well developed at this stage. I think it needs a lot of work.
What we're doing right now in the city is really an uncomplicated, low-level form of habitat banking. We're looking at specific quantities being destroyed for a construction project and that construction project being charged to do replacement. It's as simple as this: if they have to destroy a turf area, they would have to replace it with turf, and if they destroy a natural area, they'd replace it with a natural area.
If habitat banking were put together well, I think urban areas could benefit, depending on how the formulas are all put together, because there are a lot of things that need to be taken into account.