An Evaluation of the Effectiveness of Mitigation Banking in Florida: Ecological Success and Compliance with Permit Criteria

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Title:
An Evaluation of the Effectiveness of Mitigation Banking in Florida: Ecological Success and Compliance with Permit Criteria
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Language:
English
Creator:
Reiss, Kelly Chinners
Hernandez, Erica
Brown, Mark T.
Publisher:
Center for Wetlands
Publication Date:

Subjects

Subjects / Keywords:
mitigation banking
mitigation
permitting
Uniform Mitigation Assessment Method (UMAM)
Florida Wetland Condition Index (FWCI)
Landscape Development Intensity Index
Wetland Rapid Assessment Procedure (WRAP)
Spatial Coverage:
United States -- Florida

Notes

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146 Pages

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University of Florida
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An Evaluation of the Effectiveness of Mitigation Banking in Florida:
Ecological Success and Compliance with Permit Criteria









An Evaluation of the Effectiveness of Mitigation Banking in Florida:
Ecological Success and Compliance with Permit Criteria




Kelly Chinners Reiss1, Erica Hernandez2, Mark T. Brown1

THoward T. Odum Center for Wetlands
University of Florida
Gainesville, Florida 32611-6350

2Department of Environmental Protection
Kissimmee Prairie Preserve
Okeechobee, Florida 34972







Final Report

Submitted to the
Florida Department of Environmental Protection
Under Contract #WM881

United States Environmental Protection Agency Region Four
Under Contract #CD 96409404-0


May 2007









ACKNOWLEDGEMENTS


This report concludes a two year study on Florida wetland mitigation banks. Suggestions and
guidance were provided by C. Bersok, R. Butgereit, J. Espy, R. Frydenborg, V. Tauxe, and N.
Wellendorf with the Florida Department of Environmental Protection; A. Bain and E. Cronyn
with the South Florida Water Management District; C. Hull with the Southwest Florida Water
Management District; M. Reiber with the St. Johns River Water Management District; R. Evans
with the United States Environmental Protection Agency; C. Noble with United States Army
Corps of Engineers; and M. McGuire with National Oceanic Atmospheric Administration.

Land managers and/or land owners for the 29 wetland mitigation banks included in this study
provided valuable assistance in granting site access, providing site tours, and/or providing
documentation including permits and monitoring reports. We would like to acknowledge the
cooperation of M. Brown with Barberville Conservation Area; J. David with Bear Point; L.
Alderman and L. Zenczak with Big Cypress; D. McIntosh and C. Olson with Bluefield Ranch; C.
Kocur with Boran Ranch; C. Chown with CGW Bank; E. Colbert with Colbert-Cameron; R.
Pavelka and Kevin Erwin with Corkscrew; T. Odom with East Central, Florida Mitigation Bank
and Reedy Creek; S. Collins, J. Lindsay, B. Maus, and G. West with Everglades Mitigation
Bank; D. Duke and M. White with Florida Wetlandsbank; S. Kaufmann with Garcon Peninsula
Mitigation Bank; S. Bradow with Graham Swamp; The National Park Service at Hole in the
Donut/Everglades National Park; A Fickett with Lake Louisa and Green Swamp; R. Fowler, P.
Henn and S. Tonjes with Lake Monroe; R. Pavelka and C. Bowman with Little Pine Island; E.
Hale with Loblolly Mitigation Bank, Sundew Mitigation Bank, and Tupelo Mitigation Bank; K.
Olsen and K. Bennett with Loxahatchee; D. Duke, J. Styer and T. Trettis and other onsite staff
with Panther Island; J. Gilio with R.G. Reserve; B. Jackson with Split Oak; J. Clark and Kathy
Hale with TM-Econ; and S. Carnival and S. Spaulding with Tosohatchee. Thank you to all the
bank owners who gave permission to allow access to their property.

We would also like to acknowledge the water management district staff who have not already
been mentioned that gave interviews regarding compliance on the mitigation banks; P. Fetterman
with the South West Florida Water Management District; S. Elfers, H. Herbst, S. McCarthy, S.
McNabb, J. Meyer, and T. Torrens with the South Florida Water Management District.

This project and the preparation of this report were funded in part by a United States
Environmental Protection Agency (USEPA) Region Four grant to the Division of Water
Resource Management of the Florida Department of Environmental Protection.

Finally, thank you to Kissimmee Prairie Preserve State Park management and staff for providing
infrastructure, resources, and support for this study.









TABLE OF CONTENTS
Page

A C K N O W L E D G E M E N T S ............................................................................................................. i

L IS T O F T A B L E S ......................................................................................................................... iv

LIST OF FIGURES ................................................................. .......................... vi

E X E C U TIV E SU M M A R Y .................................................... ............................................... viii

CHAPTER

1 INTRODUCTION ........................................................ ............ ............. .. 1

B a c k g ro u n d ................................................................................................................................. 1
M litigation B ank R regulations ........................................... ............................................. 2
Federal Coordination ................................... .. .......... .............................. 4
Florida W etland M litigation B anks.. ..................................................................... .............. 4
Definition of Success ....................................... ........... ............................ 5
P u rp o se o f S tu dy ........................................................................... .................................... 9

2 M E T H O D S .............................................................................................................................. 1 1

M litigation B ank L locations ............................................ ..................................................... 11
P erm it R review P rocedures......................................................................... ...... .............. 13
R reference Standard C condition ................................................ ............................................ 14
S ite V isits P ro c e d u re ................................................................................................................. 14
Uniform Mitigation Assessment Method (UMAM)....................................................... 18
Wetland Rapid Assessment Procedure (WRAP)............................................................ 18
Hydrogeomorphic wetland assessment (HGM).............................................................. 19
Florida Wetland Condition Index (FWCI)................................................................... 19
Landscape Development Intensity (LDI) index.............................................................. 21

3 REVIEW OF PERMIT SUCCESS CRITERIA AND CREDIT RELEASE........................... 23

M litigation G oals and Success C riteria...................................................................................... 23
C credit P potential ........................................................................................................ ........... 2 8
P re serve atio n .............................................................................................................. ........... 2 9
C credit R release ......................................................................................................... .......... 3 0
L eg al A action s ............... ... ........................ ........................................................... ........... 3 0
Construction and Management Activities....................................................................... 32
Monitoring and Interim Release Criteria..................................................................... 43
Final Success D eterm nation and R release ........................................................ .............. 45
Compliance with Permit Schedule of Activities and Success Criteria ............................... 46
S u m m ary .................................................................................................................. ........... 4 6









4 DETERMINATION OF ECOLOGICAL INTEGRITY............... ................................... 57

D definition of E cological Integrity ..................................................................... .............. 57
R results of A ssessm ent M ethods............................................................................ .............. 58
UMAM: Uniform Mitigation Assessment Method......................................................... 66
W RAP: W etland Rapid Assessment Procedure................................................ .............. 72
HGM: Hydrogeomorphic Wetland Assessment Method................................................ 77
FW C I: Florida W etland C condition Index ............................................................................. 83
LDI: Landscape D evelopm ent Intensity Index................................................. .............. 88
Com prison of A ssessm ent M ethods........................................ ......................... .............. 92
UMAM and WRAP .......................................... ............................ .. 92
U M A M W R A P and L D I.................................................. ............................................. 96
H G M an d F W C I ................................................................................................................... 9 6
Suggestions for A ssessm ent M ethods................................... ........................ .............. 109

5 PERMIT REVIEW AND ECOLOGICAL INTEGRITY: CASE STUDIES ........................ 111

C a se Stu dy : E ast C en trial ....................................................................... .. ........................... 1 12
Case Study: Florida W etlandsbank ............................................................... .............. 116
Case Study: Sundew M litigation B ank ................................... ....................... .............. 121

6 D ISC U S SIO N ...................................................................................................... ........... 127

P erm it R ev iew ......................................................................................................... ............ 12 7
Natural Communities .............................. .. .......... .................................... 128
G roundcover R restoration .................................................. ............................................ 129
Community Structure ....................................... .............................. 130
F ire M an ag em en t .................. ........................................................................................... .. 13 1
Sustainability and Landscape Position...... ............ ............ .................... 132
Credits for Achieving Success Criteria...... ............. ........... .................... 134
Coordination and Standardization among Agencies...... .... ................................... 135
Regulatory Agency Compliance Responsibilities ....... .......... .................................... 136
Ecological Integrity .......................................... ........................ ............ .. 136
Limitations to Study.................................. ............ .............................. 138
F uture R research D direction ................................................... ............................................. 138
C o n clu sio n ............................................................................................................. ........... 13 9

R E F E R E N C E S .......................................................................................................... ............ 14 1

APPENDIX
A Field Standard Operating Procedures ....................... ................................................ A -i
B Field D ata Sheets .......... ..... .. .. .... ..... ...... ... ............ ..................... B -i
C Mitigation Bank State Permit Summaries with Success Criteria and Credit Release
S c h e d u le s ................................................................................................... .................... C 1









LIST OF TABLES


Table Page

1-1 D details of the perm itted w etland m litigation banks ......................................... ...............6...

2-1 Sample size of reference database for depressional herbaceous, depressional
forested, and forested strand and floodplain wetlands............................ ................ 15
2-2 Sources of ecological information from print media used to establish the expected
reference standard w etland condition ........................................................... ................ 15
2-3 Sources of ecological information from the internet used to establish the expected
reference standard w etland condition .................................................. ........................... 16
2-4 Nonrenewable energy value assigned to land use categories used to calculate the
Landscape Developm ent Intensity (LDI) index............................................ ................ 22

3-1 Target community and reference condition information in mitigation bank permits........25
3-2 Successes criteria for native wildlife, monitoring requirements in state permits ..............27
3-3 Percent of total potential credits released for each activity or release criteria................31
3-4 Final success criteria for exotic and nuisance vegetative cover for state permits .............37
3-5 Success criteria related to native vegetation cover and survivability of planted
vegetation in state perm its .................................................................. ..... ..... .... .................. 39
3-6 Summary of regulatory compliance for 28 wetland mitigation banks...............................48

4-1 Area of wetland mitigation banks and assessment areas included in the this study ..........61
4-2 Overview of wetland assessment areas including Florida Land Use, Cover and
Forms Classification System, associated wetland community type, and wetland
assessm ent m ethods applied ............................................................................ ............... 63
4-3 Uniform Mitigation Assessment Method (UMAM) scores for 58 wetland assessment
areas at 29 w etland m litigation banks ............................................................. ................. 67
4-4 Uniform Mitigation Assessment (UMAM) scores categorized by Florida Land Use,
Cover and Forms Classification System (FLUCCS) wetland community type .............69
4-5 Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment
a r e a s ......................................... .. ..................... ................................................................ 7 3
4-6 Wetland Rapid Assessment Procedure (WRAP) scores categorized by Florida Land
Use, Cover and Forms Classification System (FLUCCS) wetland community type ........75
4-7 Hydrogeomorphic wetland assessment method (HGM) variable for flats wetlands
in th e E v erg la d e s ................. .................... ............. ... ............ .. .... .......................... 7 8
4-8 Hydrogeomorphic wetland assessment method (HGM) functional capacity index
scores (Function) for six flats wetlands in the Everglades ...........................................79
4-9 Hydrogeomorphic wetland assessment method (HGM) variable for depressional
w wetlands in peninsular F lorida .................................................. ... ............. ................. 8 1
4-10 Hydrogeomorphic wetland assessment method (HGM) functional capacity index
scores (Function) for nine depressional wetlands in peninsular Florida......................... 82
4-11 Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total FWCI
scores, and percent of reference condition for six depressional herbaceous
w etlan d s .......................................................................................................... ....... .. 84









4-12 Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total FWCI
scores, and percent of reference condition for three depressional forested wetlands........85
4-13 Macrophyte Florida Wetland Condition Index (FWCI) metric scores total FWCI
scores, and percent of reference condition for a forested strand wetland within
T M -E con M litigation B ank ............................................................. .. .... .................... 85
4-14 Macroinvertebrate Florida Wetland Condition Index (FWCI) metric scores, total
FWCI scores, and percent of reference condition for two depressional herbaceous
w etla n d s .................................... ...... ......... ...................................... .. .............................. 8 7
4-15 Macroinvertebrate Florida Wetland Condition Index (FWCI) metric scores, total
FWCI scores, and percent of reference condition for two depressional forested
w etlan d s ................... ..... .. ...................................................................... ......... ....... .. 8 7
4-16 Landscape Development Intensity (LDI) index scores.................................................89
4-17 Pair wise comparisons among scoring categories and total scores for the Uniform
Mitigation Assessment Method (UMAM), Wetland Rapid Assessment Procedures
(WRAP), wetland scale Landscape Development Intensity (LDI) index, and bank
scale L D I index ...................... ...... .... .......... .... .............................................. 97
4-18 Correlations among Uniform Mitigation Assessment Method (UMAM) and scoring
categories, Wetland Rapid Assessment Procedure (WRAP) and scoring categories,
wetland scale Landscape Development Intensity (LDI) index scores, bank scale LDI
index scores, Hydrogeomorphic wetland assessment method (HGM) functional
capacity index scores, macrophyte Florida Wetland Condition Index (FWCI) scores,
and m acroinvertebrate FW CI scores......................................................... ................. 101
4-19 Percent of reference standard conditions for Uniform Mitigation Assessment
Method (UMAM), Wetland Rapid Assessment Procedure (WRAP), macrophyte
Florida Wetland Condition Index (FWCI), and macroinvertebrate FWCI
assessment methods for 16 wetland assessment areas ................. .............................. 103
4-20 Percent of reference standard conditions for Hydrogeomorphic wetland assessment
method (HGM) functional capacity index scores for 15 wetland assessment areas........ 104

5-1 Credit release schedule for East C central .............. ......... ............................................. 114
5-2 Wetland assessment scores for two wetland assessment areas at East Central .............115
5-3 Success criteria for Florida W etlandsbank ................................................. ................ 118
5-4 Wetland assessment scores for two wetland assessment areas at Florida
W etlan d sb an k ..................................... ... .......................................................... ........ .. 1 19
5-5 State permit credit release schedule for Sundew Mitigation Bank from SJRWMD
technical report............... .......................... .... ....... .. .. ..... .............................. 123
5-6 Federal permit credit release schedule from the Mitigation Bank Instrument for
Sundew M litigation B ank ............................ .. ........................................ ............... 124
5-7 Wetland assessment scores for two wetland assessment areas at Sundew
M itig atio n B an k ............................................................................................................... 12 5









LIST OF FIGURES


Figure Page

1-1 Location of 45 Florida w etland m litigation banks........................................... ...............5...
1-2 Florida state agency responsibility for wetland mitigation banks for currently
permitted mitigation banks and land area of permitted wetland mitigation banks.............. 8

2-1 Location of 29 wetland mitigation banks included in this study .................................12
2-2 Florida wetland mitigation banks permitted by year .................................... ................ 13
3-1 Total area of permitted mitigation banks in relation to total potential credits................29
3-2 Permit requirements from Garcon Peninsula Mitigation Bank.................................... 33
3-3 Dense cover by the invasive exotic species melaleuca or punktree (Melaleuca
quinquenervia) prior to restoration activities at Little Pine Island. ..................................35
3-4 Final success criteria allowance for exotic vegetation percent cover by mitigation
bank and regulating agency ........................................................................ .................... 38
4-1 Applicable range of the Everglades flats Hydrogeomorphic wetland assessment
m ethod (H G M ) in South Florida................................................................... ................ 58
4-2 Applicable ranges (reference domain) of depressional wetlands Hydrogeomorphic
wetland assessment method (HGM) and depressional herbaceous Florida Wetland
Condition Index (FW CI) in peninsular Florida ............................................ ................ 59
4-3 Uniform Mitigation Assessment Method (UMAM) scores for the 58 assessment
areas in relation to permitted lift (credits/ac) and potential credits released (%)
at respective bank...................................... .. ............. .. .. ... .......................... 71
4-4 Wetland Rapid Assessment Procedure (WRAP) scores for the 58 assessment
areas in relation to permitted lift (credits/ac) and potential credits released (%)
at respective bank................... .. .................. ................... 76
4-5 Wetland scale and bank scale Landscape Development Intensity (LDI) index
scores for 55 w etland assessm ent areas ........................................................ ................ 91
4-6 Uniform Mitigation Assessment Method (UMAM) and Wetland Rapid
Assessment Procedure (W RAP) were positively correlated ..............................................93
4-7 The difference between Uniform Mitigation Assessment Method (UMAM)
and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland
a sse ssm en t a re a s ............... .......... ....... ..... ... ... .................................................. 9 4
4-8 Linear regression between Uniform Mitigation Assessment Method (UMAM)
and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland
a sse ssm en t a re a s ............... ....... ..... ... ... ............................................................. 9 5
4-9 Correlations among Uniform Mitigation Assessment Method (UMAM) Location
and Landscape Support scoring category with wetland scale and bank scale LDI
in d ex sco res.................. ..................... ............................................ ... ............. ........ .. 9 8
4-10 Wetland Rapid Assessment Procedure (WRAP) correlations with wetland scale
Landscape Developm ent Intensity (LDI) index............................................ ................ 99
4-11 Bank scale Landscape Development Intensity (LDI) index score correlations............ 100
4-12 Comparison among six Everglades flats wetlands of UMAM, WRAP, and HGM
fu n action al cap city in dices ............................................................................................... 106









4-13 Comparison among six depressional herbaceous wetlands of UMAM, WRAP,
HGM functional capacity indices, macrophyte FWCI, and macroinvertebrate
F W C I ............... .. ........ ......... ...................................................................... ......... 1 0 7
4-14 Comparison among four forested wetlands of UMAM, WRAP, HGM functional
capacity indices, macrophyte FWCI, and macroinvertebrate FWCI .............................108
5-1 Landscape location of East Central in northeast Orange County ..................................113
5-2 Landscape location of Florida Wetlandsbank in western Broward County and
surrounding land use ................................................. ... .... ...................... ................ 117
5-3 Landscape location of Sundew Mitigation Bank in Clay County and surrounding
la n d u se .................................................................................................. .................... 12 2









EXECUTIVE SUMMARY


AN EVALUATION OF THE EFFECTIVENESS OF MITIGATION BANKING IN FLORIDA:
ECOLOGICAL SUCCESS AND COMPLIANCE WITH PERMIT CRITERIA

The primary purpose of this study was to determine the effectiveness of mitigation banking in
Florida by determining compliance with permit success criteria, evaluating the ecological
integrity of wetlands within wetland mitigation banks, and evaluating whether permit compliance
reflects ecological integrity. Increasing the effectiveness of mitigation banking and improving
wetland assessment methodologies should increase the capacity for long term protection and
restoration of wetlands. The long term effects of this project will be to improve the ecological
performance of mitigation banks, management of mitigation banks, and stewardship of wetland
resources to better meet the goals of the Clean Water Act.

Specifically, this study used a collection of available wetland assessment methods combined
with permit and document review to determine the condition of restored, enhanced, created, and
preserved wetlands within wetland mitigation banks. Permit review involved determining stated
permit success criteria and mitigation activities. Two rapid assessment methods, Uniform
Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP),
and two field intensive assessment methods, Hydrogeomorphic approach to assessing wetland
function (HGM) and Florida Wetland Condition Index (FWCI), were applied to select wetland
assessment areas. A fifth assessment method, the Landscape Development Intensity (LDI) index
relies on geographic information systems (GIS) analysis.

Wetland assessment techniques employed varied by wetland type, but all generally relied upon a
comparison of the current wetland condition to reference standard wetland condition. Reference
standard condition was defined as the condition of wetlands surrounded by undeveloped
landscapes and without apparent human induced alterations. By designating a measure of
ecosystem condition we refer to what others have described as ecosystem integrity, defined by
Karr and Dudley (1981) as "the capability of supporting and maintaining a balanced, integrated,
adaptive community of organisms having a species composition, diversity, and functional
organization comparable to that of the natural habitat of the region" (p. 56).

As of November 2006, 45 wetland mitigation banks were permitted under Section 373.4135, F.S.
in Florida. Twenty-nine of the permitted wetland mitigation banks were visited with functional
assessments conducted at 58 wetland assessment areas within those banks between May 2005
and September 2006. The 58 wetland assessment areas were categorized based on the Florida
Land Use, Cover and Forms Classification System (FLUCCS; FDOT 1999). Both permit review
and application of functional assessment methods were used to determine the ecological integrity
of wetland assessment areas within wetland mitigation banks. Permit reviews were conducted
for all 29 wetland mitigation banks visited. In addition to permits, annual monitoring reports and
other supporting documents were used when available. Credit release schedules and success
criteria for each wetland mitigation bank were summarized.

The second part of this study involved application of five wetland assessment methods at 58
wetland assessment areas within 29 wetland mitigation banks. The wetland assessment methods









were Uniform Mitigation Assessment Method (UMAM) (Ch. 62-345, F.A.C.), Wetland Rapid
Assessment Procedure (WRAP) (Miller and Gunsalus 1999), hydrogeomorphic approach to
assessing wetland function (HGM)(Noble et al. 2002; Noble et al. 2004), Florida Wetland
Condition Index (FWCI) (Lane et al. 2003; Reiss and Brown 2005a; Reiss and Brown 2005b),
and Landscape Development Intensity (LDI) index (Brown and Vivas 2005; Vivas 2007).
UMAM, WRAP, and LDI index were completed at 58 wetland assessment areas. HGM (n=15)
and FWCI (n=10) assessments were conducted when the type of wetland within the wetland
assessment area matched the existing assessment methods.

UMAM (0.47-0.93), WRAP (0.48-0.99), and HGM (0.31-1.00) assessments showed a similar
range of scores (on a scale of 0-1.00, where 1.00 represents the highest score attainable, a
reflection of the reference standard condition). Macrophyte FWCI scores ranged from 0.21-0.88
(presented as proportion of reference standard condition). A strong positive correlation was
found between UMAM and WRAP scores (Spearman rank correlation r = 0.86, p < 0.001).
However for any given wetland, differences from -0.15 to 0.18 between UMAM and WRAP
scores were detected with only a single wetland assessment area receiving the same UMAM and
WRAP score. Across the board, neither UMAM nor WRAP provided consistently higher or
lower scores and no trends were detected specific to wetland community type.

Approximately two-thirds of the wetland assessment areas (n = 38) had wetland scale LDI index
scores less than 2.0 (where 0.0 represents no human development), with a mean wetland scale
LDI index score of 3.21 (a = 4.87), a median of 0.25, and a high score of 16.65. Wetland scale
LDI index scores were calculated such that all lands within the 100 m zone surrounding a
wetland assessment area designated as restoration, enhancement, creation, or preservation were
assigned LDI index scores reflecting natural lands. In this application, the wetland scale LDI
index score was considered a tool to predict the potential wetland condition based on the restored
support landscape. Bank scale LDI index scores, based on land use within the 100 m zone
surrounding a bank, were generally higher, with a mean bank scale LDI index score of 7.78 (C =
5.36), a median of 6.53, and a range from 0.00-18.22

Overall, wetland assessment areas in banks that had achieved final permit success criteria did not
receive the highest attainable scores for the functional assessment methods employed, suggesting
full wetland function has not been achieved. Permit review found that determination of potential
credits based on assessment methods (commonly using WRAP) generally assumed that
mitigation would result in full wetland function through assigning the highest possible scores for
with-mitigation scenarios.

Recommendations

As a result of permit review and associated assessments, eight recommendations for improving
permits and/or restoration plans were developed:
1. Define natural communities and associated reference standard conditions;
2. Emphasize groundcover restoration;
3. Monitor plant and animal community structure, not just presence or cover of exotic or
nuisance species;
4. Establish and implement fire management plans;









5. Identify sustainability of mitigation within the landscape;
6. Allocate a higher percent of credits for achieving success criteria and a lower percent of
credits for task completion;
7. Encourage better coordination and standardization among state and federal agencies and
between bank managers and agency personnel;
8. Increase compliance responsibilities of the regulatory agencies.
These suggestions are intended to facilitate improvement in the ecological condition of wetland
and upland communities within wetland mitigation banks permitted in the future.

1. Define natural communities and associated reference standard conditions. Defining the target
reference standard condition is imperative for successful restoration. In state permits, 13 bank
permits described or referred to reference conditions either as a comparison to the literature or an
actual field comparison. In contrast, 13 bank permits made no mention of reference conditions
in state permits. A few of the bank permits recognized the inability to restore natural
communities to reference condition and instead established anticipated ecological lift from pre-
bank conditions. Language commonly encountered in permits suggested that the restoration
areas would resemble a particular community type, but rarely were explanations given as to how
this resemblance would be determined. Ruiz-Jaen and Aide (2005) noted that existing laws in
the United Stated do not require restoration success as defined by comparison to reference
standard ecosystems, and that given financial concerns (e.g., increased monitoring costs for
monitoring reference sites as well as restoration sites) it is unlikely that such comparisons to
reference sites will be required for future restoration efforts. While somewhat dated, the Florida
Natural Areas Inventory (FNAI) Guide to the Natural Communities of Florida (1990) would be a
useful classification guide in permit review, as it provides a detailed description of each of
Florida's native communities.

2. Emphasize groundcover restoration. Restoration of different community types is dependent
on more than replacement of canopy structure alone. Most bank permits had some basic
requirement for percent cover of desirable, native species. Fourteen (of 29) bank permits
included planting and/or seeding as a requirement for credit release (3-20%, typically 5-10%),
though this has not been broken down by canopy or groundcover species. However, most of the
planting and credit release criteria emphasized trees rather than groundcover species. While the
canopy does influence a great deal about the community (i.e., microclimate, establishment of
shade tolerant versus intolerant species, etc.), fire management, along with planting and/or
seeding, is necessary in many community types to ensure establishment and maintenance of
groundcover.

3. Monitor plant and animal community structure. Most permits required minimal cover by a
suite of plant species, the percent cover of a desirable species to resemble that of a reference
standard community, and/or the percent cover by exotic or nuisance species to be less than some
target percentage. However, those criteria do not fully consider the target community structure
for both flora and fauna. Ten years ago Mitsch and Wilson (1996) recognized the need for
linking structural measures such as species diversity, productivity, or cover, with important
ecosystem functions such as wildlife use, nutrient cycling, or organic matter accumulation.
While many studies have noted the return of water storage or water quality functions at
restoration sites, rarely do such wetlands provide comparable community structure or wildlife









habitat functions (e.g., Brown and Veneman 2001, McKenna 2003, Zampella and Laidig 2003).
Mitigation plans should define the target natural community; recognize what physical, chemical,
and biological characteristics characterize the target natural community; identify target species
and/or community assemblages associated with the target natural community; ensure mitigation
plans and subsequent mitigation goals actively meet the life history requirements of those target
species and/or community assemblages, including needs such as connectivity, reproduction,
food, cover, etc.; and monitor for the occurrence, reproductive success, and long-term
maintenance of these target species and/or community assemblages to ensure mitigation goals
have been met.

4. Establish and implement fire management plans. Fire management is crucial to successful
maintenance of many of Florida's natural communities (for details see FNAI 1990). While 26 of
the studied banks included some fire dependent communities, only eight banks had a credit
release associated with conducting a prescribed fire, and a few more banks required prescribed
fire as part of the final release criteria. While prescribed fire was indicated for achieving
successful ecosystem restoration, many barriers arose to prevent implementation of prescribed
fire management plans. At least seven banks included in this study reported that they were
behind in accomplishing their prescribed burn plan for site specific condition, usually because
the site was either too wet or too dry. Mitigation bank permits should require successful
implementation of prescribed fire and community response to this management tool for credit
release in fire-dependent communities.


5. Identify sustainability of mitigation within the landscape. Having realistic goals as to the
potential function of a wetland mitigation bank should be a priority for assessing with mitigation
bank scenarios. The landscape location of compensatory mitigation projects continues to be an
important consideration. The landscape of Florida has been cross ditched and drained with
human settlement, and as such, an ideal landscape setting probably does not exist within the
state. Forman and Deblinger (2000) suggest that roadways and conservation areas should be
separated, and yet many of the Florida wetland mitigation banks are bordered by busy roadways
(e.g., Barberville Conservation Area bordered to the south SR-40; Everglades Mitigation
Bank/Phase I (FPL) bordered to the east by Card Sound Rd. and the west by US-1) or bisected
by busy roads (e.g., Tosohatchee bisected by the Beachline Expressway SR-528; Little Pine
Island bisected by SR-78). Consideration of potential wetland functional lift should incorporate
a landscape perspective. Wetland mitigation in general must be considered a trade-off between
temporal and spatial ecosystem function, and the bottom line comes back to having a realistic
expectation of attainable function in the calculated with mitigation bank scenario. That is, when
a bank is adjacent to developed lands, the location and landscape functional component should
never be expected to achieve a perfect score. Further, credits should reflect the landscape
condition and be realistically based on limitations to water budget, water quality, connectivity for
fauna populations, core to edge ratios for associated species, edge effects, etc. Such concerns
will vary for every bank, being based on the community types involved, the associated fauna
species, bank size, and surrounding land uses.

6. Allocate a higher percent of credits for achieving success criteria and a lower percent of
credits for task completion. Incremental credit release based on completion of activities that do









not necessarily equate to demonstrated achievement of function should be avoided. Mitsch and
Wilson (1996) argued a decade ago that efforts to determine wetland restoration or creation
success were flawed due to a lack of application of sound wetland science and the weight of
schedule-driven construction activities, and yet often credit release criteria in bank permits were
based mainly on task completion. Activity-based credit releases averaged about 50% of the total
potential credits and represented the preservation and completion of the mitigation "work" at the
bank. Although it was recognized that the actual work was sometimes equated with ecological
enhancements, mitigation success may be improved if credits releases were weighted more
toward incremental improvement and community response to these treatments and actions, rather
than simply completion of predetermined activities.

7. Encourage better coordination and standardization among the state and federal agencies and
between bank managers and agency personnel. In a study of compensatory wetland mitigation
across the United States, ELI (2002) suggested that the differences among permits and
supporting documents make comparisons difficult. This study found that was true not only
between federal and state documents, but also among documents from the four permitting
agencies in Florida. In fact, simply tracking down documentation for each wetland mitigation
bank proved difficult in many instances. Once fully on-line, the Regional Internet Bank
Information Tracking System (RIBITS), a new internet-based tracking system for United States
Army Corps of Engineer (USACE) districts to monitor wetland mitigation banks, should provide
a warehouse for wetland mitigation bank documentation at the federal level. A similar electronic
database for tracking and storing wetland mitigation bank permits at the state level would be
useful. However, suggestions for centralized databases at the state level have been made in the
past (e.g., Kentula et al. 1992) with little recent progress. All documentation leading up to
permit implementation, permits themselves, permit modifications, credit ledgers, and other
communications relating to monitoring and management should be centralized and available for
review in a digital format. Further, mitigation banks should submit digital copies of reports and
communications to be kept in a centralized file. Centralizing and tracking this documentation
will make the review process more transparent and allow for better tracking of bank histories.

8. Increase compliance responsibilities of the regulatory agencies. While time and costs are no
doubt limiting factors in the availability of agency personnel to conduct frequent and thorough
site visits, increasing agency oversight and interactions with bank managers should enhance
overall compliance and achievement of final success. Requiring frequent inspection should
provide motivation for bank managers to maintain and improve ecosystem function between site
visits. While no specific time schedule will meet the needs of all banks or regulators,
maintaining regular communication with banks, even those not requesting a credit release, is
encouraged. At a minimum, no agency should release credits without a bank inspection of
sufficient detail to confirm that monitoring reports submitted by the banker correctly document
site condition and that required release criteria were met.

Most of the wetland mitigation banks showed potential to provide increased wetland function
following restoration, assuming completion of restoration activities. However, for many wetland
banks, landscape position is the most limiting factor to attainment of full functional. Clearly
defining reference standard conditions and having realistic expectations of the potential
functional gain may lessen the potential of functional loss in wetland mitigation banks. Many of









the findings for Florida mitigation banks corroborate recent findings in Massachusetts (Brown
and Veneman 2001), California (Ambrose et al. 2006), and Ohio (Mack and Micacchion 2006),
that while most wetland mitigation banks meet permit success criteria, this does not equate to the
structure and function of natural wetland communities. Basic ecological principles can better
dictate a more sensible way to plan, implement, and manage mitigation banks, with
considerations including edge effects such as roads and towers, core to edge ratios for habitat,
fragmentation and habitat loss in the landscape, and species interaction. If these basic principles
are overlooked, then the assumption of achieving function has no validity. Mitigation banks
must be assessed realistically for credit potential.









CHAPTER 1
INTRODUCTION

Wetland mitigation banking has grown steadily in the last decade since state law and rules on
mitigation banks were adopted, with 45 wetland mitigation banks currently permitted in Florida.
Additionally federal mitigation policy is trending toward a preference for mitigation banks, such
as the 1998 Transportation Equity Act for the 21st Century "TEA-21 Restoration Act" (Public
Law 105-178) and the recent proposed rule for Compensatory Mitigation for Losses of Aquatic
Resources (2006). While there are several studies evaluating project-specific mitigation
effectiveness (e.g. FDER 1991b; FDER 1992; Brown and Veneman 2000; Campbell et al. 2002;
Morgan and Roberts 2003), few studies have been conducted on mitigation banks (though see
Brown and Lant 1999; Ambrose et al. 2006; Mack and Micacchion 2006). The Florida
Department of Environmental Protection (FDEP), in conjunction with the University of Florida's
Howard T. Odum Center for Wetlands (UF-CFW) carried out this study to evaluate the
ecological integrity of mitigation banks. This study also presents a comparison of different
wetland assessment methodologies used to evaluate the ecological integrity of 29 banks. The
study was funded through a grant from the United Stated Environmental Protection Agency
(USEPA) Region IV.

Background

For over 20 years, the federal government, through the Clean Water Act, and the state of Florida,
beginning with the Warren S. Henderson Wetlands Protection Act of 1984, have regulated
wetland impacts. Wetland permitting programs are aimed at maintaining wetland functions and
values through avoidance and minimization of wetland impacts and to compensate for
unavoidable impacts through wetland mitigation. In 1991, the state conducted an audit of
mitigation permitting operations (FDER 1991a) and a study that assessed compliance and
effectiveness of a subset of permitted mitigation projects (FDER 1991b). Like other reports
from around the country (e.g., Roberts 1993; Race and Fonseca 1996; Brown and Veneman
2000; Robb 2002; Morgan and Roberts 2003), these studies found significant problems with
permit compliance, permit success criteria, and/or the potential for long-term viability of the
mitigation area.

To address some of these issues, mitigation policies began to authorize and encourage more
consolidated mitigation projects, such as mitigation banks and regional offsite mitigation areas.
In Florida, that endorsement came with the passage of the Environmental Reorganization Act of
1993, specifically in Section 373.4135, Florida Statutes (Mitigation banks and offsite regional
mitigation), which initially authorized the use of mitigation banks and offsite regional mitigation
to offset impacts, and directed the development of mitigation bank rules. These rules were
initially promulgated in 1994 and reflected in Section 373.4136, F.S. (Establishment and
operation of mitigation banks) in 1996. Florida representatives worked closely with federal
partners and contributed to the development of the Federal Guidance for the Establishment, Use
and Operation of Mitigation Banks, published in the Federal Register in November, 1995, and
the subsequent Joint State Federal Mitigation Bank Review Team Process (the "Greenbook,"
cited as Story et al. 1998), which details how to integrate state and federal permitting for
mitigation banks in Florida.









In 2001, the National Research Council conducted a review of the federal mitigation program
(NRC 2001). Some of the common findings were:
high rates of non-compliance;
inadequate permit performance and success criteria;
limited long term monitoring and management;
sites located poorly in landscape;
inadequate agency support in compliance monitoring, tracking, training, and research.

The report also emphasized the need to avoid and minimize wetland impacts in the first place.
Only when impacts to wetlands cannot be avoided should mitigation be an option.
Recommendations for advancing the mitigation program included improvements in technical
information requirements, reference-based success criteria, long-term stewardship requirements
(including conservation easements and financial responsibility), assessment methods based on
function, and consideration for long-term viability within the watershed. It was thought that
mitigation banks would offer advantages in addressing landscape planning, financial assurance,
and long-term management and thus circumvent the problems that were plaguing compensatory
mitigation. Additionally, compliance monitoring would be facilitated. Many of the
recommendations were incorporated into the federal permitting process for mitigation banks
today.

Mitigation Bank Regulations

In Florida, mitigation banks are regulated by both federal and state agencies. Because both sets
of regulatory agencies cooperated during the development of the regulations, federal and state
regulations are similar in principle components and integrally linked in others (i.e., federal
agencies generally accept the state approved preservation and financial assurance instruments).
For the purposes of this study, mitigation banks and regulations will be discussed within the
context of state permits, with any significant federal differences noted. This state-centric
approach is taken principally because more statewide data and documents were available than
federal ones. Additionally, as will be detailed later, the state has permitted about a dozen more
banks than have been federally authorized (generally due to permitting delays rather than
fundamental differences in review).

The principle laws that regulate Florida's mitigation bank program are Florida Statute 373.4135 -
Mitigation banks and offsite regional mitigation, and Florida Statutes 373.4136 Establishment
and operation of mitigation banks. Statute 373.4135 authorizes use of mitigation banks and
recognizes the "improved likelihood of environmental success" associated with the establishment
of mitigation banks, specifically favoring "the restoration and enhancement of degraded
ecosystems and the preservation of uplands and wetlands as intact ecosystems through
restoration of ecological communities that were historically present."

The criteria for establishing mitigation banks in Section 373.4136, F.S. requires that they:
(a) improve ecological conditions of the regional watershed;
(b) provide viable and sustainable ecological and hydrological functions for the proposed
mitigation service area;
(c) be effectively managed in perpetuity;









(d) prevent destruction of areas with high ecological value;
(e) achieve mitigation success;
(f) be located adjacent to lands that will not adversely affect the perpetual viability;
(g) meet all wetland permitting criteria;
(h) have sufficient legal or equitable interest in the property to ensure perpetual
protection and management; and
(i) meet financial responsibility requirements.
Another important section in this statute defines credits as units of increased ecological value to
be determined by a functional assessment method also used to determine ecological "debits" for
wetland impacts. The statute lists factors to be considered when determining credits: the
quantity and quality of the wetland and upland enhancement/restoration expected and the
likelihood of achieving and maintaining the target condition; the degree that management
activities such as prescribed fire promote natural ecological conditions; the location in the
landscape relative to regionally significant and/or wildlife corridors; wetland and upland
ecological and hydrological connections and listed species habitat; and the degree that the
property is already protected by land use restrictions or the potential for adverse effects if the site
is not preserved.

Further, this statute indicates that permits should include a schedule for release of credits based
on the performance and criteria in the permit. Factors to be considered include the type of
mitigation activities (whether solely preservation or other types of mitigation), time required for
those activities to be successful, and ecological value associated with each mitigation activity. In
practice, most banks receive 10-25% of their total potential credits upon preservation (usually
through a recorded conservation easement) and the provision of the required financial assurance
(usually performance bonds or letter of credit payable into a standby trust) for the
implementation and long-term management of the plan. Additional credits are released for
specific mitigation activities such as physical construction (e.g., ditch filling, road removal, etc.),
exotic species removal, and/or planting. Further incremental credit release is based on regular
monitoring and documentation of trending toward success culminating in a determination of final
success.

Statute 373.4136 also establishes guidelines for the determination of the Mitigation Service Area
(MSA) based on regional watersheds. Finally, it allows for the FDEP and state Water
Management Districts (WMDs) to establish more specific rules, especially pertaining to
preservation, financial assurance, and credit assessment methods. FDEP adopted and
administers the mitigation bank rule, Chapter 62-342, Florida Administrative Code (F.A.C.), and
three of the five WMDs (South Florida Water Management District, SFWMD; Southwest
Florida Water Management District, SWFWMD; and St. Johns River Water Management
District, SJRWMD) also adopted and administer similar rules within their jurisdiction. Which
agency issues a state mitigation bank permit depends on the location and intended use of the
bank, as determined through operating agreements between the agencies.

In addition to the statutory requirements, the mitigation banking rules provide increased
guidance on intent, definitions, details on the required components of a permit, credit assessment
and release, and specifics on the instruments for preservation and for financial assurance.
However, the mitigation banking rules do not specify the functional assessment method to be









used. As a result, mitigation banks have been assessed by several function and ratio-based
methods. A standard, function-based method for debit and credit assessment for both mitigation
banks and all other forms of compensatory mitigation, called the Uniform Mitigation Assessment
Method (UMAM), went into effect in February 2004 under Rule 62-345, F.A.C. It is now used
throughout the state on all projects requiring mitigation. Mitigation banks permitted prior to
2004 were grandfathered to continue to use their original assessment method, but a few have
chosen to convert to UMAM.

Federal Coordination

The Federal Guidance for the Establishment, Use and Operation of Mitigation Banks (1995) was
issued jointly by the United States Army Corps of Engineers (Corps), the United States
Environmental Protection Agency (USEPA), the Fish and Wildlife Service (FWS), and, as
programmatically appropriate, the Natural Resource Conservation Service (NRCS) and the
National Marine Fisheries Service (NMFS). Evaluation of a proposed mitigation bank is
undertaken by an interagency Mitigation Bank Review Team (MBRT) with federal authorization
of a mitigation bank determined through a binding Mitigation Banking Instrument (MBI) that is
signed by both the MBRT members and the banker. The MBI details the establishment, use and
operational requirements of the mitigation bank, but dredge and fill operations associated with
restoration activities, such as grading, ditch filling, installation of water control structures, etc.,
may require a separate 404 permit.

An important difference between state and federal permitting review is that once a formal permit
application is received, the state is bound by statutory time clocks for review, information
requests, and approval while the federal agencies are not. While the state and federal guidelines
and goals are similar, programmatic and procedural differences can lead to disparate approvals.
The development of the Greenbook (Story et al. 1998) was an attempt to minimize duplicate
review. It provides for the state permit reviewer to co-chair the MBRT with the Corps. It
establishes a pre-application protocol that involves a preliminary prospectus and determination
of appropriateness. It stipulates a method of determining credits through ratios, Wetland Rapid
Assessment Method (WRAP), or variations thereof. Additionally, it provides guidance
indicating that the state permit application not be submitted until significant issues such as the
mitigation plan, credit assessment, and MSA, have consensus agreement. However, the
Greenbook is not binding on the state, the Corps, or the banker, so adherence to the provisions
varies. Even when there is consensus on the major components, the final development of details
and the permit under the state's time clock generally precedes that of the federal MBI.
Therefore, differences in the final authorizations are common, but typically minor. This project
has focused its review on state permits and requirements, but extends to federal requirements as
well due to the similarities in state permits and federal MBIs.

Florida Wetland Mitigation Banks

The 45 state permitted wetland mitigation banks, which are in different stages of project
development, served as the initial sample pool for this project (Figure 1-1). Table 1-1 lists the
banks by name, permitting agency, permit number, permit issue date, bank size, potential credits,
type of wetland credits available, and location (county(ies)). Two of the wetland mitigation










Sand Hill Lakes Mitigation Bank Longleaf Mitigation Bank
Northeast Florida
Loblolly Mitigation Bank
Garcon Peninsula Devils Swamp' Tupelo ".ii.j 3iion Bank
Breakfast Point Sundew Mitigation Bank
/Graham Swamp
San Pedro Bay gl,...1 Bank Barberville
Wekiva River Mitigation Bank-- F Orange
Lake Monroe Colbert-Cameron
Lake Louisa and Green Swamp- East Central
Florida Mitigation Bank "-Tosohatchee
Reedy Creek TM-Econ
Clear Springs ar Ra h Split Oak
Tampa Ba "ea CGW
Braden River Bear Point
Peace Rive Platts Creek
Boran Ranch Bluefield Ranch
Boran Ranch f h
45 Florida Wetland Mitigation Banks Little Pine Island RG- Reserve
S Included Corkscre w Loxahatchee
Panther Island Florida Wetlandsbank
Not Included Big Cypress" V
N o I n cl BE v e rg la d e s M itig a tio n B a n k
8 Digit HUC Hole in the Donut



100 0 100 200 Kilometers A


Figure 1-1. Location of 45 Florida wetland mitigation banks. Wetland mitigation banks
included in this study represented by blue circles (e); wetland mitigation banks not included in
this study represented by red squares ("). Background is 8-digit Hydrologic Cataloguing Units
(HUC) of Florida from the Florida Department of Environmental Protection (available at
http://www.fgdl.org, cover map WATERSHED).


banks have received permits for additional phases, Boran Ranch and Everglades Mitigation Bank
(FPL), and as such, each phase (permit) is listed separately. Currently, SJRWMD has issued the
most wetland mitigation bank permits with 16, followed closely by FDEP with 14 (Figure 1-2A).
The remaining 15 mitigation banks were permitted through SFWMD (n = 9) and SWFWMD (n
= 6). When considering land area covered by wetland mitigation, SJRWMD is responsible for
50% of total area in wetland mitigation banks with 23,654 ha (58,448 ac) (Figure 1-2B). FDEP
is responsible for over one-third of the area with 17,832 ha (44,061 ac) permitted. SWFWMD
(11%) and SFWMD (2%) are responsible for just 5,494 ha (13,576 ac) and 1,195 ha (2,952 ac)
of wetland mitigation banks, respectively.

Definition of Success

This research has set out to determine the success of wetland mitigation banking through a
review of permit compliance and an evaluation of the ecological integrity of wetlands using a
variety of wetland assessment techniques. Permit assessment involved determining if stated
permit success criteria and compliance with those standards would reflect ecological integrity.











Table 1-1. Details of the permitted wetland mitigation banks. Twenty-nine wetland mitigation banks were included in this
study(*). Both Boran Ranch and Everglades Mitigation Bank (FPL) were permitted in two phases and thus both are listed twice (once
for each permit).


Public State Potential Released Used Released
Mitigation Bank Land Agency MBI+ Issue Date Hectares Acreage Credits Credits Credits (%)


Barberville* Y SJRWMD No 6/1/1996 148 366
Bear Point* Y FDEP Yes 7/25/2003 128 317
Big Cypress* N SFWMD Yes 9/9/1999 518 1,280
Bluefield Ranch* N SFWMD Yes 11/15/2001 1,091 2,695
Boran Ranch, Phase I* N SWFWMD Yes 8/26/1997 96 237
Boran Ranch, Phase II N SWFWMD Yes Unknown 69 170
Braden River N SWFWMD No Unknown 141 349
Breakfast Point N FDEP Yes 10/11/2004 1,877 4,637
CGW* N SJRWMD Yes 6/10/1998 61 150
Clear Springs N SWFWMD No 10/28/2003 473 1,168
Colbert-Cameron* N SJRWMD Yes 10/28/1996 1,054 2,604
Corkscrew* N FDEP Yes 6/4/2004 257 635
Devils Swamp N FDEP Yes 10/11/2004 1,234 3,049
East Central* N SJRWMD Yes May-97 385 952
Everglades Mitigation Bank/Phase I* N FDEP Yes 10/1/1996 1,669 4,125
Everglades Mitigation Bank/Phase II* N FDEP unknown 10/16/2003 3,653 9,026
Farmton N SJRWMD Yes 4/11/2000 9,681 23,922
Florida Mitigation Bank* N FDEP Yes 5/28/1997 640 1,582
Florida Wetlandsbank* Y SFWMD Yes 2/9/1995 170 420
Garcon Peninsula* N FDEP Yes 4/12/2001 136 337
Graham Swamp* N FDEP Yes 9/5/1996 27 66
Hole in the Donut* Y FDEP ** 2/15/1995 2,529 6,250
Lake Louisa and Green Swamp* N SJRWMD Yes 10/10/1995 408 1,007
Lake Monroe* Y SJRWMD Yes 9/12/1995 244 603
Little Pine Island* Y FDEP Yes 2/6/1996 633 1,565
Loblolly Mitigation Bank* N SJRWMD Yes 9/9/2003 2,528 6,247
Longleaf Mitigation Bank N SJRWMD Yes 3/31/2004 1,223 3,021
Loxahatchee* N FDEP Yes 2/18/2000 512 1,264
Mary A Ranch N SJRWMD No 11/12/2002 837 2,069


84.30
49.80
1,001.78
1,240.00
108.59
102.53
71.69
1,051.66
63.10
438.00
718.80
351.80
586.80
286.30
424.50
1,769.53
4,585.20
847.50
370.00
172.39
32.50
6,250.00
297.90
199.90
807.00
2,034.00
813.80
641.60
1,252.80


54.20
25.00
559.20
558.14
100.78
16.99
0.00
76.29
50.50
0.00
560.30
0.00
0.00
286.30
382.00
184.60
664.50
847.50
367.37
77.40
29.25
2,111.37
245.60
130.00
279.40
508.58
105.54
320.80
302.90


35.10
3.70
246.23
135.62
98
5.20
0.00
21.36
46.20
0.00
354.60
0.00
0.00
176.70
290.69
80.64
588.40
729.80
367.37
7.27
5.50
2,111.37
212.14
110.90
161.09
315.52
20.34
221.58
154.47


64
50
56
45
92
17
0
7
80
0
78
0
0
100
90
10
14
100
99
45
90
34
82
65
35
25
13
50
24










Table 1-1. Continued.


Public State Potential Released Used Released
Mitigation Bank Land Agency MBI+ Issue Date Hectares Acreage Credits Credits Credits (%)
Myakka River N SWFWMD No 6/29/2004 154 380 224.60 38.20 9.09 17
Northeast Florida N SJRWMD Yes 9/5/1997 315 779 407.30 400.00 375.00 98
Panther Island* N SFWMD Yes 3/11/1999 1,128 2,788 934.64 799.24 588.72 86
Peace River N SWFWMD No Unknown 197 487 137.82 0.00 0.00 0
Platt's Creek N SFWMD No 4/10/2003 33 82 69.51 0.00 0.00 0
Port Orange N SJRWMD No 1/13/2004 2,314 5,719 1,176.30 237.90 73.00 20
R.G. Reserve* N SFWMD No 1/9/2003 258 638 32.48 2.55 1.20 8
Reedy Creek* N SFWMD Yes 2/13/1997 1,211 2,993 908.90 563.35 419.39 62
San Pedro Bay Mitigation Bank N FDEP Yes 2/13/2002 2,731 6,748 1,083.00 170.80 6.02 16
Sand Hill Lakes Mitigation Bank N FDEP Yes 8/5/2005 872 2,155 298.40 104.40 0.00 35
Split Oak* Y SFWMD unknown 6/13/1996 425 1,049 206.50 88.80 88.80 43
Sundew Mitigation Bank* N SJRWMD Yes 8/11/2001 853 2,107 698.30 194.20 101.54 28
Tampa Bay N SWFWMD No 9/25/2002 65 161 111.55 0.00 0.00 0
TM-Econ* N SJRWMD Yes 1/8/2003 2,104 5,199 1,568.60 227.97 150.31 15
Tosohatchee* Y SJRWMD Yes Unknown 531 1,312 185.00 185.00 152.90 100
Treasure Coast N SFWMD No 3/9/2005 1,030 2,545 1,033.43 0.00 0.00 0
Tupelo Mitigation Bank* N SJRWMD Yes 1/23/2004 617 1,525 459.70 144.85 144.52 32
Wekiva River Mitigation Bank N FDEP No 6/1/2005 665 1,643 390.12 97.53 7.06 25
*Wetland mitigation bank included in this study
+ Federal Mitigation Banking Instrument (MBI)
** Has federal approval in the form of an "in lieu fee" type agreement; state permit also more closely resembles an in-lieu-fee arrangement
Information from: Florida Department of Environmental Protection, October 2006











(A)

Di stributi on of Wetland Mitigati on Banks
by State Agency


SWFWMD, 6,
13%


SJRWMD, 16,
36%


FDEP, 14, 31%


(B)

Land Area in Wetland Mitigation Banks
by State Agency


SWFWMD,
1,195 ha, 2%
SFWMD, 5,494
ha, 11% o


FDEP, 17,832
37%


SJRWMD, 23,654
ha, 50%


Figure 1-2. Florida state agency responsibility for wetland mitigation banks for A)
currently permitted mitigation banks and B) land area of permitted wetland mitigation
banks. State agencies are St. Johns River Water Management District (SJRWMD), Florida
Department of Environmental Protection (FDEP), South Florida Water Management District
(SFWMD), and Southwest Florida Water Management District (SWFWMD).









The wetland assessment techniques employed varied by wetland type, but all generally relied
upon the comparison of the current wetland condition to wetland reference standard condition.

Because mitigation is meant to offset function lost from wetland impact activities, ideally
mitigation bank success would be measured by a direct comparison of functions lost at impact
sites to functions gained at the mitigation site. However, this was not feasible as part of this
study, as the permitted impact sites no longer exist in their pre-impact condition and therefore
could not be studied in the same way as the mitigation bank sites. Therefore, in this study,
success was evaluated using the mitigation bank permits and mitigation bank study sites alone.

Permit success is defined by demonstration of achievement of permit success criteria. Within a
given permit, achievement of specific performance standards or release criteria determines
awarding of some proportion of total potential wetland credits. For instance, an initial credit
release generally requires legal activities such as recording a conservation easement and
assertion of financial assurance. Credit release criteria can also include physical activities such
as earth moving, ditch plugging, and land grading, exotic or nuisance species removal, and
planting desirable species. Interim and final success is often defined by achieving a specified
percent cover of desired vegetation or resemblance of the mitigation wetland to a natural
community.

The definition of success based on ecological integrity can be defined by achieving specific
scores by various functional assessment methods. In this case, success is defined by the
quantitative comparison of a mitigation wetland to a reference standard wetland. Only 14% of
the banks studied included permit criteria based directly on the achievement of some functional
assessment index score (e.g., a 1.00 Wetland Rapid Assessment Procedure (WRAP) score).

Merging these two definitions of success proves challenging as each is based on different
assumptions. First, the definition of success for permitting relies on the assumption that
completion of particular activities (e.g., ditch plugging, exotic species removal, etc.) in fulfilling
permit compliance will result in functional gain and therefore provides successful mitigation.
Complicating this assessment is the fact that the release of credits is generally incremental, based
on activities such as site preservation, ditch fill, and cattle removal. On the other hand, the
definition of success for ecological integrity is based on a comparison against the reference
standard wetland condition.

Purpose of Study

The primary purpose of this study was to determine the effectiveness of mitigation banking in
Florida by determining compliance with permit success criteria, evaluating the ecological
integrity of wetlands within wetland mitigation banks, and evaluating whether permit compliance
reflects ecological integrity. Increasing the effectiveness of mitigation banking and improving
wetland assessment methodologies should increase the capacity for long term protection and
restoration of wetlands. The long term effects of this project will be to improve the ecological
performance of mitigation banks, management of mitigation banks, and stewardship of wetland
resources to better meet the goals of the Clean Water Act.









Specifically, this study used a collection of available wetland assessment methods combined
with permit and document review to determine the condition of restored, enhanced, created, and
preserved wetlands within wetland mitigation banks. Two rapid assessment methods, Uniform
Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP),
and two field intensive assessment methods, Hydrogeomorphic approach to assessing wetland
function (HGM) and Florida Wetland Condition Index (FWCI), were applied to select wetland
assessment areas. A fifth assessment method, the Landscape Development Intensity (LDI) index
relies on geographic information systems analysis.

This document is designed to present a summary of findings and synthesis of the permit and
document review and field assessments. Chapter 2 Methods provides an overview of the
location of Florida wetland mitigation banks, site visit protocol, procedures of permit and
document review, and determination of reference standard condition. A detailed description of
the field standard operating procedures can be found in Appendix A. Presentation of results
from the permit and document review and field surveys are found in Chapter 3 Review of Permit
Success Criteria and Credit Release and Chapter 4 Determination of Ecological Integrity,
respectively. A presentation of field data sheets and a summary of permit review for each
wetland mitigation bank can be found in Appendix B and Appendix C, respectively. Chapter 5
Permit Review and Ecological Integrity synthesizes findings from permit and document review
and field assessments by presenting case studies of three wetland mitigation banks. Chapter 6
Discussion reviews major findings and recommendations and addresses the effectiveness of
wetland mitigation banking in developing and maintaining wetlands with high ecological
integrity.









CHAPTER 2
METHODS

The primary goal of this project was to determine the effectiveness of mitigation banking in
Florida using permit and documentation review, field assessment, and geographic information
systems (GIS). Twenty-nine wetland mitigation banks were included in this study, with
quantitative, standardized assessment methods used to determine the ecological integrity of 58
smaller wetland assessment areas within the 29 banks. The availability of permits and other
documents associated with wetland mitigation banks varied greatly. In general, supporting
documentation gathered included permits, staff reports, monitoring reports, management plans,
and/or site visit summaries, which were summarized to include credit potential, credit release
schedules, and success criteria for each bank. Field assessments were conducted on select
wetland assessment areas within the banks, but rarely covered the entire bank area. While some
banks were relatively small in area and homogeneous in wetland community type, many covered
large areas and contained a variety of wetland community types. The number of wetland
assessment areas selected depended on a combination of site-specific conditions such as
homogeneity of wetland community types, mitigation activities completed to date and progress
towards success criteria, area of wetland, type of mitigation (i.e., restoration, creation,
enhancement, or preservation), and general site conditions. Two rapid assessment methods,
Uniform Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure
(WRAP), were used at all 58 wetland assessment areas, as was the Landscape Development
Intensity (LDI) index, a GIS based assessment tool. When the wetland assessment area matched
the communities with developed standard guidebooks for the Hydrogeomorphic wetland
classification (HGM) and/or the Florida Wetland Condition Index (FWCI), these methods were
also completed. This chapter presents background information on the assessment sites, permit
and document review procedures, reference standard condition, and field site visits procedures.

Mitigation Bank Locations

Twenty-nine of the 45 permitted mitigation banks were included in this study. Banks were
located throughout the four Florida wetland regions (Lane 2000), though only a single wetland
mitigation bank, Garcon Peninsula, was located in the panhandle wetland region (Figure 2-1).
Just over half of the study mitigation banks (n = 15) were within the central wetland region, with
10 in the south wetland region, and three in the north wetland region. Site selection criteria
included length of time since permit issue, progress towards mitigation activities, and land owner
or manager cooperation for site access. For the purposes of this study, the two phases of
Everglades Mitigation Bank were considered as separate banks, as Phase I is nearing final credit
release with 90% of credits awarded, and Phase II has limited credit release at 10%.

All of the wetland mitigation banks permitted before 2001 were visited, with the exception of
two banks where field access was denied (Figure 2-2). In addition, banks permitted as recently
at 2004 were also part of this study. The remaining mitigation banks either had no credits
released to date and/or were lacking their federal MBIs. The four oldest banks included in this
study were Florida Wetlandsbank (permit issue date February 9, 1995), Hole in the Donut
(February 15, 1995), Lake Monroe (September 12, 1995), and Lake Louisa and Green Swamp


















Garcon Peninsula Mitigati.rn


._ ..-. .Loblolly Mitigation Bank
.................................. Sundew Mitigation Bank
S /Tupelo Mitigation Bank
M. -. /.Graham Swamp
S' /Barberville
/Lake Monroe
S-- ~ C, olbert-Cameron
East Central
E : ni.,.-Tosohatchee
L3' L,,., .3 :ir,,.l *;| r, |-r ----C __'
Florida Mitigation Ban TM-Econ
Split Oak
Reedy Cree .k-- Sl:it:O.:
ii ..n Banks .:. Bear Point
Bluefield Ranch
Boran Ranc R.G. Reserve


Little Pine


- Lox ahatchee
-Florida Wetlandsbank
. Everglades 'hi ..ii ii or Bank, Phase II
-Everglades Mitigation Bank, Phase I


0 100 200 Kilometers


Figure 2-1. Location of 29 wetland mitigation banks included in this study. Wetland region
boundaries according to Lane (2000).



(October 10, 1995). The two most recently permitted banks included Tupelo Mitigation Bank
(January 23, 2004) and Corkscrew (June 4, 2004).

Mean bank size was 826 ha (2,040 ac) (a = 887 ha; 2,192 ac), ranging from 27 ha (66 ac) at
Graham Swamp to 3,653 ha (9,026 ac) at Everglades Mitigation Bank/Phase II. Twenty-seven
of the 29 banks had freshwater wetlands. Three of these mitigation banks had both freshwater
and saltwater wetlands, and the remaining two banks had salt marsh or/or mangrove wetlands.
The range in potential credits was large, from 32.5 potential credits at Graham Swamp to 6,250
potential credits at Hole in the Donut. The median was 425 potential credits. It is important to
mention that Hole in the Donut operates under a permit that more closely resembles an in-lieu-
fee agreement. Funds for restoration activities are collected at the time of impact permit issuance
until there is sufficient money to complete a portion of the required restoration. Thus, initially,
impacts occur prior to mitigation. However, while there is a potential of 2,529 ha (6,250 ac) to
restore at Hole in the Donut, work is being conducted incrementally, as financial resources
allow, and is currently "ahead" in initial restoration area relative to impact area.

Progress towards mitigation success within a bank can be measured based on potential credits
released. The wetland mitigation banks studied ranged from no credits released at Corkscrew to


S Study I1tg


Panhandle
North
11 Central
|Z South










Sl Included in Study 0 Not Included in Study


6-















Year of Permit Issue

Figure 2-2. Florida wetland mitigation banks permitted by year.


100% of the potential credits released at three wetland mitigation banks: East Central, Florida
Mitigation Bank, and Tosohatchee.

Permit Review Procedures

Permit review involved determining compliance with permit criteria. Acquisition of complete
documentation for each wetland mitigation bank proved difficult. Many of the initial permits
and technical reports were only available in draft forms, and few permit modifications were
acquired. State permits were obtained for all 29 banks, with monitoring reports available for 18
banks. Details of permit compliance were based on phone interviews with appropriate personnel
from Florida Department of Environmental Protection (FDEP), South Florida Water
Management District (SFWMD), Southwest Florida Water Management District (SWFWMD),
or St. Johns River Water Management District (SJRWMD). Differences in compliance tracking
occurs among agencies, with FDEP and SJRWMD having the same individual following the
initial permit process and implementation as well as keeping track of compliance. Conversely,
SFWMD and SWFWMD have different individuals responsible for the compliance portion of
wetland mitigation banks. If credit or permit modifications are needed, they refer back to the
individual responsible for implementing the permit.









Reference Standard Condition


In order to complete field assessments, it was necessary to determine the reference standard
condition of the wetland community type for each assessment area. Different information was
available depending on the wetland community type. We used a database of depressional
herbaceous (n=75; Lane et al. 2003), depressional forested (n= 118; Reiss and Brown 2005a), and
forested strand and floodplain wetlands (n=24; Reiss and Brown 2005b) to develop a baseline
understanding of the condition of Florida wetlands. Species lists for diatom, macrophyte, and
macroinvertebrate community assemblages, as well as physical and chemical soil and water
parameters were available (Table 2-1).

Other sources of descriptive information were consulted to determine reference conditions
(Tables 2-2, 2-3), particularly when detailed community data were not available from the studies
listed above. While internet sources were consulted (Table 2-3), site content had been
distributed by reputable sources such as the Cornell Lab of Ornithology, Florida Department of
Environmental Protection, Florida Department of Natural Resources, Florida Fish and Wildlife
Conservation Commission, Florida Natural Areas Inventory, United States Geological Survey,
and University of Florida (Institute of Food and Agricultural Sciences).

Site Visits Procedure

Prior to a site visit, recent digital orthographic quarter quads were acquired from The Land
Boundary Information System from FDEP (available at http://www.labins.org), and the
statewide data layer showing boundaries of Florida wetland mitigation banks from the Florida
Geographic Data Library (available at http://www.fgdl.org/) were overlain in ArcView GIS 3.2
(Environmental Systems Research Institute, Inc. 1999). Ecological communities within the
wetland mitigation bank boundaries were identified and potential wetland assessment areas were
documented. Background reference data were compiled for select ecological communities and
Part 1 of UMAM Qualitative Description (Ch. 62-345, F.A.C) was initiated prior to site visits.

Most site visits began with a meeting with the land manager and/or bank owner followed by an
overview tour of the site. However, each site visit was different based on the particular
circumstances regarding each bank. Some of the meetings were conducted off-site and site visits
were not always conducted with the land manager and/or owner present.

Once an overview of the wetland mitigation bank was provided, wetland assessment areas were
selected based on the amount of mitigation work completed to date, current water level
conditions, and accessibility. When practical, selection of wetland assessment areas targeted
phases that already had credits released. Digital orthographic quarter quads or other map
resources were used to determine the wetland boundary of each assessment area. The two to
three member field crew proceeded to walk a portion of the wetland boundary and interior with
sample effort regulated by homogeneity of site conditions, accessibility, and time and weather
constraints. Miller and Gunsalus (1999) suggest that a minimum of 50% of the wetland
boundary is traversed and 100% of the boundary is visually inspected when using WRAP; this
guidance was also used for field assessments using UMAM. During the site visit, notes were










Table 2-1. Sample size of reference database for depressional herbaceous, depressional
forested, and forested strand and floodplain wetlands. Data from Lane et al. (2003), Reiss
and Brown (2005a), and Reiss and Brown (2005b), respectively.


Depressional
Herbaceous


Depressional
Forested


Forested Strand
and Floodplain


Diatom Community 70 50 x
Macrophyte Community 75 118 24
Macroinvertebrate Community 75 79 x
Soil Analysis 75 118 x
Water Analysis 75 75 x


Table 2-2. Sources of ecological information from print media used to establish the
expected reference standard wetland condition.


Source
Bardi, EB, MT Brown, KC Reiss, and MJ Cohen (2005)
UMAM Training Manual: Web-based training manual for
Chapter 62-345, FAC for wetlands permitting. Available
at: hip hl .dep.state.fl.us/labs/librarv/index.htm


Mitsch, WJ and JG Gosselink. 1993. Wetlands, 2nd
edition. John Wiley and Sons, Inc. New York, New York,
USA.

Myers, RL, and JJ Ewel, editors. 1990. Ecosystems of
Florida. University of Central Florida Press, Orlando,
Florida, USA.
Noble, CV, R Evans, M McGuire, K Trott, M Davis, and
EJ Clairain, Jr. 2002. A regional guidebook for applying
the hydrogeomorphic approach to assessing wetland
functions of flats wetlands in the Everglades. Wetlands
Research Program, Engineer Research and Development
Center, US Army Corps of Engineers, Washington, D.C.
ERDC/EL TR-02-19


Noble, CV, R Evans, M McGuire, K Trott, M Davis, and
EJ Clairain, Jr. 2004. A regional guidebook for applying
the hydrogeomorphic approach to assessing wetland
functions of depressional wetlands in peninsular Florida.
Wetlands Research Program, Engineer Research and
Development Center, US Army Corps of Engineers,
Washington, D.C. ERDC/EL TR-04-3


Soil Conservation Service. 1984. 26 Ecological
Communities of Florida. United States Department of
Agriculture. Washington. D.C.. USA.


Description
Provides guidance on completing the Uniform
Mitigation Assessment Method Part I and Part II
forms, including Wetland Field Guides providing
information on predominant vegetation and wildlife,
landscape location, fire interval, hydrology, and
functions for 23 wetland communities.
Provides an overview of wetlands ecology with
sections dedicated to individual wetland types
describing wildlife, hydrology, plant composition,
and fire frequency.
Provides an overview of Florida's ecological
communities. Includes information on upland and
wetland communities.
Provides reference data for Everglades flats wetlands,
including rocky flats, marl flats, and organic flats.
Reference conditions provided for surface soil
texture, soil thickness, microtopographic features,
woody vegetation cover, periphyton cover, emergent
macrophytic vegetation cover, plant species
composition, native species richness, invasive
vegetation cover, wetland tract area, interior core
area, and habitat connections.
Provides reference data for depressional wetlands
including herbaceous marshes and cypress domes.
Reference conditions provided for wetland volume,
catchment size, upland land use, surface outlet,
cypress canopy, subsurface outlet, surface soil
texture, macrophytic vegetation cover, understory
vegetation biomass, tree basal area, herbaceous plant
species composition, number of wetland zones,
wetland proximity, and tree species composition.
Provides descriptions of 26 ecological communities
in Florida, including characteristic vegetation.










Table 2-3. Sources of ecological information from the internet used to establish the expected reference standard wetland
condition.


Source
Atlas of Florida Vascular Plants
httu %\ \ \ .plantatlas.usf.edu/default.asp
The Birds of North America Online
http://bna.birds.comell.edu/BNA/


Florida Delineation Program Field Guides
litp \ \ \ .dep.state.fl.us/water/wetlands/delineation/wetcomm/fieldguides.htm


Florida Delineation Program Vegetative Index (Plant List) from Chapter 62-340,
F.A.C. (subsection 62-340.200(17), F.A.C.)
hup \ \ \ .dep.state.fl.us/water/wetlands/delineation/vegindex/vegindex.htm
Florida Delineation Program Wetland Communities
htp "\ .dep.state.fl.us/water/wetlands/delineation/wetcomm/wetcomm.htm


End of the Road: The Adverse Ecological Impacts of Roads and Logging: A
Compilation of Independently Reviewed Research
hillm \ i\ \n nrdTc nr/linfnre/frtst/rndk/entrinY nan


Endangered Species in Florida
hlip in % .endangeredspecie.com/states/fl.htm
Environmental Resource Analysis from the FDEP
http://eraonline.dep.state.fl.us/
*NOTE* This website is scheduled to be retired be FDEP in the near future, and
replaced by Water Data Central, available at:
http://www.dep.state.fl.us/water/datacentral/


Exotic Freshwater Fishes
http://floridafisheries.com/fishes/non-native.html


Description
Scientific and common name, exotic/native status, wetland status, and
sometimes images of Florida plant species and range maps.
Information on bird species, including range maps, distinguishing
characteristics, distribution, habitat, food sources, behavior, breeding,
demography and populations, conservation and management, appearance,
and measurements.
Drawings of common species for algae and flowering plants, central Florida
floodplain forests, north Florida floodplain forests, mangroves, north and
central Florida salt marsh, and south and central Florida salt marsh.
Lists of native Florida plant species identified as facultative, facultative wet,
and obligate species.


List and brief description of common plant communities for each of seven
districts (NW, NE, central, SW, SE, S, and Florida Keys). More detailed
descriptions and photos provided for some communities as well as common
plant associates and community range.
Annotated bibliography of information pulled mainly from peer-reviewed
journals pertaining to adverse impacts of roads on North American forests.
Published by the Natural Resource Defense Council (1999).
State listed threatened and endangered plant and animal species for Florida.


Interactive mapping interface providing geographical data and information
relating to local roads, soils, Outstanding Florida Waters (aquatic preserves
and special waters), conservation lands (federal, state, local, and private
areas), city limits, and aerial photography. Also includes the ability to draw
a 1 mile buffer around a given analysis point with summary information for
permit application, jurisdictional boundaries, water resources, fish and
wildlife resources, habitats, and mitigation and restoration opportunities.
Provides a description of 32 known introduced fish species currently
reproducing in Florida waters. Includes common and scientific name,
description, range, habitat, spawning habitat, feeding habitat, age and
growth, sporting quality, edibility, state and world records, and
drawing/sketch.


hit,) %% %% %% nrdc orp,/Iand/forests/ ad-h-triny-n










Table 2-3. Continued.


Source
Florida Fish and Wildlife Conservation Commission. 2004. Florida's Imperiled
Species.
http://myfwc.com/imperiledspecies/
Florida Natural Areas Inventory and Department of Natural Resources. 1990.
Guide to Natural Communities of Florida.
hupll) % % .fnai.org/PDF/Natural Communities Guide.pdf
Florida Wetland Restoration Information Center
http \\ \ .dep.state.fl.us/water/wetlands/fwric


Frogs and Toads of Florida
http % i .wec.ufl.edu/extension/wildlife info/frogstoads/image index.php
*NOTE* This is not a permanent URL, search University of Florida
Online Guide to the Snakes of Florida
lihi \ i\ \\ .flmnh.ufl.edu/hemetoloev/FL-GUIDE/onlineLuiide.htm


Plant Species Introduced in Florida
huln % % %.flmnh.ufl.edu/herbarium/cat/imagesearch.asp?srchproiect=IN
Tables of Florida Natural Communities Descriptions available for download
hlu ".dep.state.fl.us/water/wetlands/fwric/guidance.htm


Tadpoles of the Southeastern United States Coastal Plain from the USGS
http://cars.er.usgs.gov/armi/Guide to Tadpoles/guide to tadpoles.html

U.S. Fish and Wildlife Service Species Accounts
lihiin \ \\ \.fws. ov/northflorida/Snecies-Accounts/SneciesInfo.htm


What Bird: The Ultimate Bird Guide http://www.whatbird.com/


Description
Lists Florida's imperiled species, including endangered species, threatened
species, and species of special concern.


Provides descriptions of natural ecological communities in Florida.
Includes information on characteristic plant and animal species, hydrology,
fire frequency, and associated communities.
Information on wetland and associated upland restoration; includes links to
the Florida Ecological Restoration Inventory (descriptions of current and
proposed restoration projects), restoration guidance (background on
restoration with case studies), restoration library (links and bibliographies).
List and pictorial index of the 33 frogs and toads of Florida. A description of
each species includes photos, distribution, habitat, size, reproduction, color,
and call information. Many entries include an audio clip of the call.
Key to snake identification, list of Florida snakes, color patterns, and habitat
descriptions. Provides photos, scientific name, description, sketches, range,
and habitat information for each species as well as comments on behavior,
location, food, reproduction, and a comparison with other species.
Scientific and common names for plant species as well as scanned
herbarium specimen images from the University of Florida herbarium.
Tabular information on dominant vegetative strata, ecosystem formation,
typical vegetation, typical animals, soils, hydroperiod, fire regime, typical
surrounding habitat, similar habitats, threats and importance.
Information useful for identification of tadpoles with photos of the adult and
tadpoles plus information on habitat, breeding season, similar tadpoles,
appearance, and approximate maximum size.
List of federally listed endangered, threatened, and species of special
concern by region for mammals, birds, reptiles, amphibians, fish,
crustaceans, clams, arthropods, insects, and plants. Lists are also available
by county. Links are available for further detailed information on family,
status, description, range and population level, habitat, biological
information, reason for current status, management and protection, and
references.
General species information as well as background on range and habitat
with range maps. Shows images of species and often provides audio clips of
bird calls.









taken on general site conditions including identified flora, observed wildlife (e.g., visual
sightings, calls), evidence of wildlife (e.g., tracks, nests), and occurrence of listed species.

Once notes were completed for WRAP and UMAM rapid assessment methods, transects and/or
quadrats were established for HGM and/or FWCI, depending on methods specific to those
assessment techniques. While UMAM and WRAP were completed for each of the 58 wetland
assessment areas, the more intensive sampling methods, HGM and FWCI, were only completed
for Everglades flats (Noble et al. 2002) or depressional wetlands (Noble et al. 2004) for HGM
and depressional herbaceous (Lane et al. 2003), depressional forested (Reiss and Brown 2005a),
or forested strand and floodplain (Reiss and Brown 2005b) wetlands for FWCI. After returning
from the field, a digital boundary of the wetland assessment area was drawn over the digital
orthographic quarter quad and the wetland scale LDI index was calculated for each wetland
assessment area using GIS. The bank scale LDI index value was also calculated around the
boundary of the entire bank. A brief description of each field assessment method follows.
Further details of methods for each assessment method including UMAM, WRAP, HGM, FWCI,
and LDI, are available in Appendix A.

Uniform Mitigation Assessment Method (UMAM)

UMAM is defined in Rule Chapter 62-345, F.A.C. A complete UMAM survey includes Part I
Qualitative Description and Part II Quantification of Assessment Area. Part I Qualitative
Description establishes a reference baseline for expected site functions and considers
connectivity, regional significance, and anticipated wildlife. Part II Quantification of
Assessment Area requires completion at the field site with scoring assigned in each of the three
indicators of wetland function: Location and Landscape Support, Water Environment, and
Community Structure.

Part II Quantification of Assessment Area scores are based on evidence within the wetland
community and the surrounding landscape, using reasonable scientific judgment. UMAM relies
on an adequate understanding of the functions of and species found throughout Florida
ecosystems to provide a score describing the functional capacity of a wetland. Within each of
the three indicators of wetland function, the UMAM scale ranges from 0-10, with only whole
numbers assigned. A score of 10 suggests the wetland assessment area reflects the expected
wetland function at an optimal level. Alternatively, a score of zero means that no wetland
function is being provided. Guidance is provided within the rule (Chapter 62-345, F.A.C.) for
scores of 10, 7, 4, and 0. Once each of the three categories have been scored, the values are
summed and divided by 30 to achieve a total UMAM score between 0.00-1.00, with 1.00
representing optimal wetland function. Assessments for this study were conducted as current
condition scenarios. UMAM has additional application for scenarios with- and without-
mitigation, time lag, and risk. A UMAM current condition assessment was conducted at all 58
wetland assessment areas within the 29 banks.

Wetland Rapid Assessment Procedure (WRAP)

WRAP methodologies are defined by Miller and Gunsalus (1999) for use in evaluation of
restored, created, enhanced, and preserved wetland mitigation sites. WRAP was created for use









in freshwater, non-tidal wetlands in South Florida, but is often applied statewide and has even
been applied outside of Florida. WRAP includes six scoring categories: 1) Wildlife Utilization;
2) Overstory/Shrub Canopy; 3) Vegetative Ground Cover; 4) Adjacent Upland Support/Buffer;
5) Field Indicators of Wetland Hydrology; and 6) Water Quality Input and Treatment. Scores
range from 0.0-3.0, in 0.5 increments. A score of 3.0 indicates an "intact" wetland, whereas a
score of 0.0 indicates a wetland with a reduced functional capacity (Miller and Gunsalus 1999).
Guidance is provided for scoring categories of 0.0, 1.0, 2.0, and 3.0. The final WRAP score is
calculated by summing the scores for the scoring categories and dividing by the number of
scoring categories used. For forested wetlands, six scoring categories are used; however, for
herbaceous wetlands typically only five scoring categories are used as the Overstory/Shrub
Canopy category is generally not applicable as it requires a minimum of 20% cover by woody
species. The WRAP calculation results in a score between 0.00-1.00, with 1.00 representing an
"intact" wetland. WRAP assessments were conducted at all 58 wetland assessment areas within
the 29 banks.

Hydrogeomorphic wetland assessment (HGM)

Developed through the United States Army Corps of Engineers, HGM evaluates current wetland
functions and can be used to predict prospective changes to a wetland's functions resulting from
future activities (USEPA 1998). Two HGM regional guidebooks were applicable to this study,
one for Everglades flats wetlands (Noble et al. 2002) and one for depressional wetlands in
peninsular Florida (Noble et al. 2004). The HGM approach is based on an evaluation of a
sample wetland attributes or variables compared to the reference standards provided by the
guidebook (i.e., wetlands that are relatively unaltered); the index of ecological function is
calculated from those variables. This approach focuses on five measures of wetland function: 1)
Surface Water Storage; 2) Subsurface Water Storage; 3) Cycle Nutrients; 4) Characteristic Plant
Community; and 5) Wildlife Habitat. For Everglades flats wetlands, wetland functions 1)
Surface Water Storage and 2) Subsurface Water Storage are combined into one wetland function
category called Surface and Subsurface Water Storage. Each wetland function has a calculated
value based on equations with input variables from field measurements or GIS determinations.
Each wetland function receives a score between 0.00-1.00, with 1.00 representing the reference
standard condition. Each wetland assessment area receives four or five separate HGM scores for
wetland function. HGM assessment was conducted at six Everglades flats and nine depressional
wetlands.

Florida Wetland Condition Index (FWCI)

The FWCI is a wetland bioassessment method based on three separate indices of biological
integrity: diatom, macrophyte, or macroinvertebrate community composition. The premise
behind the FWCI is to detect differences in abundance, structure, and diversity of target species
assemblages between the wetland being assessed and a reference standard wetland. Three
variations of the FWCI have been developed for herbaceous depressional wetlands (Lane et al.
2003), forested depressional wetlands (Reiss and Brown 2005a), and forested strand and
floodplain wetlands (Reiss and Brown 2005b). For a given species assemblage (i.e., diatom,
macrophyte, or macroinvertebrate), presence/absence data are used to calculate metric values,









which are then summed together to provide an overview score of wetland condition. This study
used the macrophyte and macroinvertebrate FWCIs.

The macrophyte FWCI for all wetland types contains the following metrics: 1) Tolerant Species;
2) Sensitive Species; 3) Exotic Species; 4) Floristic Quality Assessment Index or mean
Coefficient of Conservatism score; and 5) Annual or Perennial Species. The depressional
forested wetland macrophyte FWCI also includes a metric for Wetland Status (based on obligate
and facultative wetland species, as defined by Ch. 62-340.450, F.A.C. Metrics are scored from
0-10, with 10 representing the reference standard condition. Metric scores are summed and the
resulting scale is from 0-50 for depressional herbaceous and forested strand and floodplain
wetlands and 0-60 for depressional forested wetlands. The highest score represents reference
standard condition (either 50 or 60, depending on wetland type). In this study, results are the
presented as a percent of reference standard condition.

The macroinvertebrate FWCIs have different metrics for each wetland type. The depressional
herbaceous wetland macroinvertebrate FWCI includes five metrics: 1) Percent of sensitive
indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant
indicator species as determined from a reference dataset (Tolerant); 3) Percent of
macroinvertebrates in the predator functional feeding group (Predators); 4) Percent of
macroinvertebrates in the order Odonata that includes dragonflies and damselflies (Odonata);
and 5) Percent of macroinvertebrates in the subfamily Orthocladinae, a subfamily in the family
Chironomidae (Orthocladinae). Scoring for the depressional herbaceous wetland
macroinvertebrate FWCI assigns scores of 0, 3, 7, or 10 to each of the five metrics with total
FWCI scores ranging from 0-50, with 50 representing the reference standard condition. In this
study, results are presented as a percent of reference standard condition.

The depressional forested wetland macroinvertebrate FWCI includes six metrics: 1) Percent of
sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of
tolerant indicator species as determined from a reference dataset (Tolerant); 3) Calculated score
from the Florida Index (Florida Index) (see Beck 1954, Barbour et al. 1996); 4) Percent of
macroinvertebrates in the phylum Mollusca, including snails and bivalves (Mollusca); 5) Percent
of macroinvertebrates in the family Noteridae, the burrowing water beetles (Noteridae); and 6)
Percent of macroinvertebrates in the scraper functional feeding group (Scrapers). Metrics are
scored on a continuous scale from 0-10, with 10 representing the reference standard condition.
Metric scores are summed and the resulting scale is from 0-60, with 60 representing reference
standard condition. In this study, results are presented as a percent of reference standard
condition.

Macrophyte FWCI assessments were conducted at six depressional herbaceous wetlands, three
depressional forested wetlands and one forested strand and floodplain wetland.
Macroinvertebrate FWCI assessments were conducted at two depressional herbaceous wetlands
and two depressional forested wetlands. Macroinvertebrate FWCI assessments were not
conducted at the remaining five depressional wetlands, as those sites did not have the required
minimum 10 cm of standing water covering a minimum of 50% of the wetland surface area,
needed for macroinvertebrate sampling.









Landscape Development Intensity (LDI) index


The LDI index functions as an index of human activity based on a development intensity
measure derived from nonrenewable energy use (e.g., fertilizer, fuel, electricity) in the
surrounding landscape. The LDI index equation incorporates the amount of nonrenewable
energy use (Table 2-4) weighted by area of land use within a 100 m radius of the property in
question. Brown and Vivas (2005) present the basis for LDI index calculations, and Vivas
(2007) presents a modified equation, which was used in this study. The LDI index scale runs
from zero, representing high ecological integrity, to infinity, representing decreased ecological
integrity, though in practice LDI index scores appear to be limited at around 35 (Vivas 2007;
Reiss, unpublished data).

Two scales of the LDI index were calculated: wetland scale LDI index for each of the 58 wetland
assessment areas and bank scale LDI index for 26 banks. To calculate the wetland scale LDI
index, a 100 m zone was delineated around the edge of each wetland assessment area and land
uses within the zone were identified based on 2004 digital orthographic quarter quads and field
notes for current surrounding land use from site visits. Lands surrounding wetland assessment
areas within the 100 m zone that were being restored, enhanced, created, or preserved within
wetland mitigation bank boundaries were assigned the development intensity of "Natural Land,"
which suggests no use of nonrenewable energy. Clearly mitigation activities require
nonrenewable energy use (e.g., earth moving activities, exotic plant removal or herbicide
treatment). However, the calculated LDI index values for the wetland assessment areas were
considered the "potential" LDI index for a wetland assessment area given the surrounding land
uses, which should be an already restored, self-sustaining community. That is, given successful
enhancement, restoration, creation, or preservation, the calculated LDI index value reflects the
lowest potential LDI index score and in turn the highest potential ecological integrity possible for
a wetland assessment area once mitigation is complete.

To calculate the bank scale LDI index, a 100 m zone was constructed around the bank boundary
and land uses within the zone were identified using 2000 land use cover maps (LUOO), available
from the Florida Geographic Data Library (http://www.fgdl.org/). Only 26 of 29 bank scale LDI
calculations were completed, as the mitigation bank outline was not available for Boran Ranch
Phase I; Phases I and II of the Everglades Mitigation Bank were combined into one bank scale
LDI index; and year 2000 land use was not available for Garcon Peninsula.









Table 2-4. Nonrenewable energy value for land use categories used to calculate the
Landscape Development Intensity (LDI) index. The unit of nonrenewable energy (e.g.,
fertilizer, fuel, electricity) is empower density (sej/ha/yr). For a description of empower, see
Odum (1996).


Land Use Category
Natural Land / Open Water
Recreational / Open Space low intensity
Pine Plantation
Unimproved Pastureland (with livestock)
Improved Pasture (no livestock)
Low Intensity Pasture (with livestock)
High Intensity Pasture (with livestock)
Citrus
Recreational / Open Space medium intensity
Row crops
High Intensity Agriculture (dairy farm)
Single Family Residential (Low-density)
Recreational / Open Space high intensity
Single Family Residential (Med-density)
Low Intensity Transportation
Single Family Residential (High-density)
Low Intensity commercial (Comm Strip)
Institutional
Highway (4 lane)
Industrial
Multi-family residential (Low rise)
High intensity commercial (Mall)
Multi-family residential (High rise)
Central Business District (Avg 2 stories)
Central Business District (Avg 4 stories)


Non-Renewable Empower
Density (E14 sej/ha/yr)
0.0
2.8
5.1
8.3
19.5
36.9
51.5
65.4
67.3
117.1
201.0
1,077.0
1,230.0
2,461.5
3,080.0
3,729.5
3,758.0
4,042.2
5,020.0
5,210.6
7,391.5
12,661.0
12,825.0
16,150.3
29,401.3









CHAPTER 3
REVIEW OF PERMIT SUCCESS CRITERIA AND CREDIT RELEASE

This study considers two kinds of success. First, ecological success was defined by restoring
function to wetlands. Second, permit success was defined in regards to meeting criteria and
conditions set forth in the mitigation bank permit. Ideally, the two categories of success would
be integrally linked; however, in practice, permit conditions and criteria may not always equate
to ecological success. This study looked to bridge the gap in achieving both ecological and
permit success, so that improved permits result in ecologically successful wetland mitigation.

Documents reviewed for this study included state mitigation bank permits, permit modifications,
federal Mitigation Banking Instruments (MBIs), and monitoring reports. Not all documents were
obtained for all banks, but at a minimum state permits were acquired. State mitigation bank
permits, whether issued by a water management district or the Florida Department of
Environmental Protection (FDEP), generally consisted of two parts: 1) a staff review or agency
intent to issue, which summarized the salient portions of the application file and documented the
basis of the agency's authorization and 2) the legally binding permit and figures, which set forth
the conditions of the authorization. Once issued, no changes can be made to the permit
conditions without an official permit modification issued by the agency.

Appendix C lists the documents reviewed for each of the 29 banks included in this study, along
with summary notes of these documents and final success criteria. The federal MBI was not
consistently reviewed, but it was used when available. There was a great deal of variation
between and among the mitigation bank permits and additional documentation, making
generalizations difficult and statistics unrealistic. This chapter instead provides information on
the range of differences of mitigation banks pertaining to their state permits and success criteria.
Further, this chapter makes recommendations on how mitigation banks can improve permit
criteria to better ensure achievement of ecological success.

Mitigation Goals and Success Criteria

Florida statutes and rules present guidance on ecological goals for mitigation in general and
mitigation banks in particular. The statute establishing mitigation banking (Section 373.4135(1),
F.S.) directs agencies to emphasize restoration and enhancement of degraded ecosystems and
encourage restoration of communities that were historically present. Although state rules
identify minimum requirements for success, it is up to the reviewing agency to state the success
criteria in the permit and to ensure that specific conditions in the permit are met. Given its
reference in statute and rule, it is surprising that more permits do not emphasize or require
definitions for target natural ecological communities or reference wetlands that would include a
suite of functional parameters.

Florida Statutes Rule 62-312.350, Florida Administrative Code (F.A.C.) states, "All mitigation
bank permits include success criteria. These are indicators that long-term, self-sustaining
ecological goals of the proposed enhancement or restoration will be met." The statute goes on to
define the "minimum, necessary site characteristics to determine ecological success." These
characteristics include but are not limited to delineation of the wetlands and other surface waters









according to state rule (Ch. 62-340, F.A.C.); appropriate hydric soils; appropriate target
vegetative community or early successional stages of said target community; appropriate size,
topography, and configuration; hydrology to support target community; negligible exotic or
nuisance species present; and meeting state water quality standards.

Many of the permits reviewed for this study did not explicitly describe the target wetland
community or reference standard condition for the target wetland. When reference standard
wetland conditions were addressed within a permit, these standards were often vaguely described
and qualitative, using terms such as "based on a comparison" (TM-Econ and Colbert-Cameron),
"within the range of similarity values" (Little Pine Island) or "resemble" those of a reference
wetland (Boran Ranch, Phase I). Specific quantitative guidelines for addressing the similarity of
the mitigation wetland with the reference standard wetland condition were routinely absent.

Approximately 50% (13) of the state mitigation bank permits reviewed in this study describe or
refer to having reference conditions either as a comparison to the literature or an actual field
comparison (Table 3-1). In contrast, 13 bank permits make no mention of reference conditions
in state permits. A few bank permits recognize the inability to restore natural communities to
reference condition due to site constraints and instead measure ecological lift from pre-bank
conditions. For example, Bear Point has success criteria meant to increase function and improve
water quality and fish and wildlife habitat, but will always be managed for mosquito control. As
such, it can never represent the full function of reference conditions expected of saltwater marsh
and mangrove communities. The most obvious limitation for banks to attain reference
conditions are banks closest to urban development. Location and landscape support will always
be a limiting factor in achieving full function when banks are situated in developed landscapes.

A standard should be developed for minimal criteria to describe target natural communities for
restoration. The Florida Natural Areas Inventory Guide to the Natural Communities of Florida
(FNAI 1990) document, while dated, would be a good resource to use in the initial development
of a wetland mitigation bank. FNAI (1990) presents characteristic species, soils, hydrology, fire
regime, and limitations to natural communities in detail. At a minimum, this would be a better
starting place to frame specific restoration community goals, rather than vague references to
pinelands or sawgrass marshes that lack a full appreciation of the complexity of natural
communities.

Some banks defined target communities with the Florida Land Use, Cover and Forms
Classification System (FLUCCS), which may not be at a fine enough scale for restoration goals.
Communities defined as mixed forested wetland, wetland forested mixed, and freshwater marsh
do not provide detailed information even though some of the characteristic dominant species are
in the definitions of these categories. For example, the category of freshwater marsh (6410)
includes prairie, depression marsh, basin marsh, flatwoods pond, and ephemeral pond. These
wetlands occur throughout Florida and are composed of a variety of herbaceous species. These
freshwater marshes vary widely in size, from less than an acre (e.g., depressional marshes) to
thousands of acres (e.g., Everglades flats). In preference to FLUCCS, FNAI descriptions present
baseline conditions and an initial starting point for a literature reference, describing community
composition, structure, and ecosystem processes.













Table 3-1. Target community and reference condition information in mitigation bank
permits.



Target in success
Target communities identified? criteria? Reference provided? Reference in success criteria?
BARBERVILLE 3-4 communities named no no no
BEAR POINT 1 type named yes no no
4 communities named with literature reference for
BIG CYPRESS required acreage yes composition no
literature reference for
BLUEFIELD 16 types named yes composition yes
3 named in map with required
BORAN RANCH I acreage yes onsite reference demonstrate similarity
4 named in map with required
BORAN RANCH II acreage yes onsite reference demonstrate similarity
CGW not clear no no no
COLBERT-CAMERON preservation no no no
4 communities named with
CORKSCREW required acreage yes must meet UMAM scores must meet UMAM scores
EAST CENTRAL existing communities no no no
3 types named with required
EVERGLADES I acreage no must meet WATER scores must meet WATER scores
3 types named with required
EVERGLADES II acreage yes must meet WATER scores must meet WATER scores
FLORIDA MITIGATION 3 types named with required
BANK acreage some named no no
FLORIDA WETLANDS
BANK 3-4 types named, map no no no
3 types named with required literature reference for
GARCON PENINSULA acreage yes composition must meet WRAP scores
GRAHAM SWAMP existing communities no no no
yes onsite based on wetlands in Yes, statistical similarity
HOLE-IN-THE-DONUT 1 type named inferred Everglades National Park required
non-specific
reference to
LAKE LOUISA 4 types named composition no no
14 named and mapped with
LAKE MONROE FLUCCS no no no
yes, literature and reference
LITTLE PINE ISLAND 4 named with acreage yes wetlands yes
MBI refers to literature but is
LOBLOLLY 2-3 named communities no vague no

5 named communities with criteria based on reference at
LOXAHATCHEE required acreage yes adjacent Loxahatchee Preserve wildlife has reference targets
criteria based on reference at
3-4 communities named and adjacent preserve Corkscrew
PANTHER ISLAND mapped yes Sanctuary no
REEDY CREEK FLUCCS and mapped no no no
RG RESERVE existing communities some named no no
SPLIT OAK existing communities unknown no unknown
MBI refers to literature but is
SUNDEW not clear, upland and wetland no vague no
4-5 existing communities based on enhancements over
TM-ECON mapped no relative to onsite preservation baseline
existing communities in state
TOSOHATCHEE park no no no
MBI refers to literature but is
TUPELO not clear, upland and wetland no vague no









Not all banks lacking a description of reference conditions in their permits appear to be limited in
function or progress towards ecological improvement. Perhaps some banks that lacked
documentation for reference conditions utilized the professional experience of the land manager
to restore the natural communities. Some of the banks that were having difficulty restoring some
community types did not always have a clear goal defining the target natural community.
Simply referring to the natural community and its dominant species composition is not enough to
restore the function of the community. Measurable parameters should be clear and succinct
when referring to desirable reference conditions. Qualitative "resemblance" without quantitative
correlations is not enough to determine restored structure and function.

Perfunctory comparisons to reference wetland types based on plant descriptions can limit
determination of full wetland function if composition of flora and fauna, physical characteristics,
and structure are also not defined. Basing success only on attaining similarity of the plant
community to reference standard conditions may not restore total function and other parameters
pertaining to water chemistry, soils, macro and micro fauna, and ecological processes, all of
which are an important part of defining reference standard conditions. Nine wetland mitigation
banks make no mention of fauna in their state permits or technical reports. Ten banks make
reference to wildlife utilization in the final success criteria. Twelve banks have some form of
qualitative wildlife monitoring in their banking program, and seven banks implemented
quantitative monitoring. Of the seven banks with quantitative monitoring, two require
monitoring for listed wildlife species that occur on the bank (Table 3-2).

While application of wetland assessment methods, which are used to determine potential credits,
requires the assessor to research associated wildlife and basic life history traits, it was not
apparent that this baseline information was always being sought for fauna on the banks. Ch. 62-
345, F.A.C., is the required assessment method for calculating credits for wetland mitigation
banks, effective February 2004. UMAM 62-345.400 Part I Qualitative Characterization clearly
requires at a minimum identifying "anticipated wildlife utilization and type of use (i.e., feeding,
breeding, nesting, resting, or denning) and applicable listing classifications (i.e., threatened,
endangered, or species of special concern as defined by Rules 68A-27.003, 68A-27.004, and
68A-27.005, F.A.C.)," which should increase assessor awareness of wildlife habitat and
utilization. Basic ecological principles can be applied to determine the function of wildlife
habitat and utilization. Fauna should be considered in the planning of the mitigation bank in the
context of landscape fragmentation and habitat loss outside the bank and edge effects,
connectivity and dispersal of expected fauna, core to edge ratios regarding habitat needs for
foraging, cover and reproduction, species interaction, and monitoring should be conducted for
fauna response to management activities. If it is outside of the ability of the regulating agencies
and bank managers to apply these basic ecological principles to planning and management than
more precaution should be taken when assuming potential gain in ecological function that would
support the associated wildlife species.

Further, the scientific baseline that defines a natural community is ever evolving. It may take
years to restore a community on a wetland mitigation bank, and in the mean time available
scientific knowledge might evolve to further define appropriate fire return intervals or response
to other disturbance phenomena like hurricanes. Without an appropriate understanding of the
target natural community, and an adaptive management plan or experimental design, acceptable










Table 3-2. Successes criteria for native wildlife monitoring requirements in state permits.

Qualitative
No detail monitoring or Quantitative
on wildlife Wildlife requirements observation monitoring
Mitigation Bank needs in Success Criteria requirements requirements
Barberville V
Bear Point V
Big Cypress V" 7
Bluefield Ranch V
Boran Ranch V
CGW V
Colbert-Cameron V
Corkscrew V V
East Central V
Everglades Mitigation V (WATER
Bank requirements)
V (3 in MWRAP
Florida Mitigation wildlife V
Bank wildlife
_Bank utilization)
Florida Wetlands
Bank
Garcon Peninsula V
Graham Swamp V
Hole in the Donut V V
Lake Louisa and
Green Swamp
Lake Monroe V (FL scrub jays)
Little Pine Island V
Loblolly Mitigation
Bank
Loxahatchee V
Panther Island V V
Reedy Creek V
R.G. Reserve V
Split Oak v vt
Sundew Mitigation
Bank
TM-Econ V (red cockaded
_________woodpeckers)
Tosohatchee V
Tupelo Mitigation V
Bank









variation in community structure and function based on response to disturbance would be
unclear.

Credit Potential

Florida rules recognize that not all mitigation areas are expected to attain "reference condition."
Chapter 62.312.350, F.A.C. states that "it is not the intent of the Department to require that the
mitigation area exactly duplicate or replicate the reference water." Thus, an important concept in
evaluating mitigation success is an understanding of how a mitigation site is assessed for credit.
Mitigation projects are generally categorized along a continuum of regulatory categories
including creation of wetlands from uplands, restoration of wetlands that had historically been
converted to uplands or non-native land uses, enhancement of altered wetlands, and preservation
of intact wetlands. A mitigation bank may have several of these different mitigation types in
different locations or communities types within the bank, as well as upland preservation or
enhancement to provide buffer, protection, habitat, and recharge function to the adjacent
wetlands. Thus not all mitigation areas start at the same level of ecological function, nor do they
all have the same anticipated outcome.

It is the improvement in ecological function, or ecological lift, that provides the mitigation value
or credit to offset wetland impacts of functional loss. Potential credit and loss should be assessed
by the same method. However, when evaluating mitigation banks, the future losses through
impacts are not yet known, so a standard unit of lift or gain is needed to provide a currency for
credit and debit. In Florida, a mitigation credit is defined as a "standard unit of measure which
represents the increase in ecological value resulting from restoration, enhancement, preservation,
or creation activities" (Section 373.403(20), F.S. and Chapter 62-342.200(5), F.A.C.). Typically,
the mitigation area is divided into polygons or assessment areas of similar condition, treatment,
community type, and anticipated results. Each area is assessed for its anticipated functional lift
between its current or predicted "without bank" condition, compared to its anticipated outcome
"with bank condition" (Story et al. 1998).

In February 2004, Florida adopted Uniform Mitigation Assessment Method (UMAM) in Chapter
62-345, F.A.C, thereby providing a standard methodology for all state wetland regulatory
agencies to assess lift of mitigation and assess loss associated with impacts. Prior to that date,
mitigation banks were assessed by a variety of other functional assessments and by acre to credit
ratios. The 45 permitted mitigation banks total approximately 47,753 ha (118,000 ac) with a
total of approximately 36,500 potential credits, which means, on average, about 1.4 ha (3.5 ac) of
mitigation area is required to generate one credit (Figure 3-1).

In reviewing some of the permit files and attachments, it was clear that the "with bank" scenario
was often scored very high, anticipating full function would return to a site once mitigation
activities were completed. This was true even in cases where the surrounding landscape would
have an impact on water quality or quantity or where wildlife support or movement was
significantly curtailed. In fact, it often seemed that the assessment was focused only on the
anticipated capacity to support vegetation rather than the full suite of integrated wetland
functions of the community. This practice could lead to an over-estimation of ecological lift and
mitigation credit.











140,000

120,000
-o
o 100,000 -

c 80,000

60,000
S40,000
-c
S20,000
0 0
1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006
Year

Total Acres (2006: 118,300) 0 Total Credits (2006: 36,520)


Figure 3-1. Total area (ac) of permitted mitigation banks (blue columns) in relation to total
potential credits (red columns) (1995-2006).


Preservation

Historically, preservation of intact ecosystems through a conservation easement has been a form
of mitigation that has been used to offset impacts in limited cases. Because, technically, no
ecological function has been gained by the recording of a document, simple "preservation" was
considered of restricted value in offsetting real losses. However, because of development
pressures, relatively unregulated loss of supporting uplands, and the degradation of ecosystems
by exotic or nuisance species, establishing non-degrading conservation easements is considered
to be protection to losing function over time, and mitigation value is assessed by comparing the
anticipated condition with-preservation to that without-preservation. By rule, no mitigation
credit may be released until the mitigation bank, or phase thereof, has a recorded conservation
easement and financial assurance for its implementation and long-term management (Ch. 62-
342.470(3), F.A.C.) over the project area, regardless of its current condition. Therefore all
mitigation credits represent some degree of protection from development and ecological
degradation. However, there is wide variation among banks in the degree to which the
preservation of intact ecosystems has in generating mitigation credit.

The mitigation bank permits reviewed did not consistently separate credit awarded for
preservation in terms of preserving intact communities with a high degree of function versus
filing a conservation easement over communities in pre-restored condition. About half of the
studied banks have phases or polygons with intact wetlands or uplands where very little
enhancement was required and management in perpetuity was assumed to maintain function.









Even these banks did not specifically separate the potential credit attributed to this preservation.
It is unclear whether credits have been allocated as credits for conservation easements or as
preservation credits based on the difference between the current condition and the assumed
without mitigation scenario.

Credit Release

Florida statute recognizes that mitigation projects may take years to attain final success criteria,
and provides for an incremental release of credits with a credit release schedule in the permit.
Once the credits are released, they may be sold and used to offset impacts. Sec. 373.4136(5)(b),
F.S. states "The number of credits and schedule for release shall be determined by the
department or water management district based upon the performance criteria for the mitigation
bank and the success criteria for each mitigation activity. The release schedule for a specific
mitigation bank or phase thereof shall be related to the actions required to implement the bank,
such as site protection, site preparation, earthwork, removal of wastes, planting, removal or
control of nuisance and exotic species, installation of structures, and annual monitoring and
management requirements for success."

Credit release schedules for mitigation banks included in this study are summarized in Table 3-3.
Credit releases were separated into four broad categories: Legal Actions, Construction and
Management Activities, Monitoring of Incremental Improvement and Final Success. Each
category is discussed below in greater detail.

Legal Actions

In order to receive any credits to sell, a banker must record an agency reviewed conservation
easement over the bank, or phase thereof, with the county in which it is located. The easement
requires that the bank be maintained in its current or enhanced conditions and specifically lists
activities which are forbidden, except as stipulated or required in the permit. The conservation
easement is executed in favor of the department and/or the water management district. These
easements are also required by federal agencies, but they do not accept the easement themselves.
Prior to recording the easement, agencies review title information and required title insurance for
the easement's value.

In addition to the conservation easement, the bank sponsor must provide financial assurance for
both the implementation of the project and for its long-term management. Generally, the two
assurances are in the form of a letter of credit (LOC) or performance bond, payable into a stand-
by trust in favor of the agency. The amount of the implementation financial mechanism is based
on a cost estimate of the money required to complete the mitigation plan and manage and
monitor the land until it attains success. The banker must update the cost estimate every two
years; the LOC or bond value may decrease when work is successfully completed or may
increase to reflect higher anticipated costs. The amount for the long-term management trust is
equal to the principle that will generate in interest (at 6%) the estimated annual management
costs. When both the financial assurances and conservation easement documents are properly
executed, the banker may request the initial credit release.











Table 3-3. Percent of total potential credits released for each activity or release criteria (numbers are rounded).


.g-
I 1P


N


4Y4~ 4


N


N N


BARBERVILLE Jun-96 64% 40% 23% yes 25% 120% 100% 63%
BEAR POINT Jul-07 50% 10% 15% 15% _50% 10% 100% 40%
BIG CYPRESS Sep-99 56% 10% 20% __yes 10% _48% 12% 100% 40%
BLUEFIELD Nov-07 45% 10% 15% 10% 10% 45% 10% 100% 45%
BORAN RANCH I Aug-97 93% 25% __75% 100%0 25%
CGW Jun-98 80%" 28%~ 390% 13% ~ 6% 14% 100% 80%
COLBERT CAMERON Oct-96 78% 100% 100% 100%
CORKSCREW Jun-07 0%0 15%~ 20% 7%0 yes 3%0 30% 25% 100%' 45%
EAST CENTRAL May-97 100% 58% 30% 10% 2% 100% 100%
EVERGLADES I Oct-96 90% 10% 100% 10%0 yes 60% 10% 100% 30%
EVERGLADES II Oct-03 11%" 10%~ 20% 10% ~ 3% 3%0 34% 20% 100% 46%
FLORIDA MITIGATION
BANK May-97 100% 15% 20% yes 50% 15% 100% 35%
FLORIDA
WETLANDSBANK Feb-95 99% 15% 40%. 25% 10% 5% 5% 100% 90%
GARCON PENINSULA Apr-01 45% 15% 15% 50% yes 50% 5% 40% 15% 100% 45%
GRAHAM SWAMP Sep-96 90% 60% yes 25% 15% 100% 60%
HOLE-IN-THE-DONUT* Feb-95 NA
LAKE LOUISA Oct-95 82% 15% 10% 10% 20% 25% 20% 100% 55%
LAKE MONROE Sep-95 65% 15% 15% __yes 10% 15% 10% 35% 100% 55%
LITTLE PINE ISLAND Feb-96 35%0 100% 45%0 30% 15% 100%' 55%
LOBLOLLY Sep-03 25%" 25%~ 150% 50% 5%0 30% 20% 100% 50%
LOXAHATCHEE Feb-00 50%" 15%~ 130% 13% 50% 10%1 100% 40%
PANTHER ISLAND Mar-99 86% 25% 150% 15% 10%0 50% 20% 10% 100% 70%
REEDY CREEK Feb-97 62% 30% 20%. 5%0 3% 2% 30% 10% 100% 60%
RG RESERVE Jan-03 8% 40%o 15%' 8% 10% 20% 7% 100% 73%
SPLIT OAK** Jun-96 43% 45%0
SUNDEW Aug-01 10%" 20%~ 20% 10%0 5%0 25%. 20%. 100% 55%
TM-ECON Jan-03 15% 30% 150% 40% 15% 100% 45%
TOSOHATCHEE Oct-95 100% 300% 20%1 50% 100% 50%
TUPELO Jan-04 32%0 25%1 15%1 5%o 50%o 30% 20%1 100% 50%
*On public land; In-lieu fee bank. Credits are not released incrementally; Acres restored incrementally as needed for mitigation.
** No more credits were sought; mitigation plan carried out through alternative agency agreements.


///*^^/
/ ^ a ^ //
/ $' *fr & '?/
/ <'$' '? / -\e' ^ **> /


r









Initial credits releases are usually between 10%-25%; however there are exceptions (Table 3-3).
Some conservation easement credit releases are awarded by phase (e.g., Panther Island, Reedy
Creek Table 3-3 reflects bank-wide average) and not for the entire property. On the high end,
Colbert-Cameron, primarily a preservation bank, received 100% potential credits per phase after
removing cattle and minor hydrological fixes one year after the conservation easement was filed.
Similarly, Panther Island received 80-85% potential credit release for some of its phases in
preservation areas. Most wetland mitigation banks are not preservation-only banks. Four banks
received credit release based on conservation easements in addition to previously completed
construction activities. For example, initial credit release at Graham Swamp of 60% was based
not only on recording a conservation easement but also construction already completed and one
year of monitoring. Split Oak had a similar requirement of active management plus conservation
for their initial release. Three banks, Hole in the Donut, Little Pine Island and Tosohatchee, do
not have conservation easements and did not receive credit for preservation because they occur
on already protected public lands.

Typically, little information was provided as to how the amount of initial credit release was
determined. Ideally, the initial credits generated by recording the conservation easement should
reflect the preservation value of that property. SWFWMD has initiated a method whereby they
conduct an initial assessment of a mitigation bank to determine potential credit based only on
preservation. Assuming that the mitigation bank will be protected from future degradation,
preservation credits are awarded based on current condition. Then a second assessment based on
enhancement is completed to determine the lift associated with mitigation activities. Seemingly,
this method would make awarding credit for preservation a more transparent process.

Construction and Management Activities

Generally, once a mitigation bank permit has been issued, work begins on the ground to
commence enhancing and restoring the land as required. Some banks begin ground work in
phases or polygons, sometimes with several activities occurring simultaneously. These activities
usually include installing perimeter fencing, installing hydrologic enhancement or restoration
mechanisms, earth moving, site clearing, and planting. Although there are no rules pertaining to
monitoring and reporting requirements during the construction phase of the bank, all banks are
required to give notice prior to construction initiation. FDEP requires status reports every six
months, regardless of whether construction activities are in progress or not. Individuals at the
permitting agencies commented that some banks did not submit reports or communicate with
their regulating agency for some length of time because there was no activity on the bank during
that time period. Perhaps standardization within the permit special conditions section that a
status report is required every six months would help close the communication gap. An example
of appropriate permit language for communication with state agencies is provided for Garcon
Peninsula (Figure 3-2).

Once construction activities are complete, the bank is required to monitor. At this point, the
bank should be able to demonstrate ecological incremental improvement over time. Some banks
have interim criteria that must be met in order to demonstrate a trend towards success, while
other banks must demonstrate an improvement over baseline conditions. Banks are required to
submit a monitoring report at least annually to document the monitoring and provide the basis









30. Progress Reports. Beginning six months after permit issuance until final
success determination, the permitted shall submit semi-annual progress reports
containing the following information regarding the project:

a. Date permitted activities were begun or are anticipated to begin;
b. Brief description and extent of work completed since the previous report
or since permit was issued;
c. Copies of permit drawings indicating areas where work has been
completed;
d. A description of problems encountered and solutions undertaken;
e. A brief description of the work and/or site management the permitted
anticipates commencing, continuing or completing in the next six months;
and
f. Site management undertaken, including type of management and dates
each type was undertaken.


Figure 3-2. Permit requirements from Garcon Peninsula Mitigation Bank (permit number
017-880-001).


for requesting credit release for that monitoring period. SWFWMD does not have interim or
incremental criteria for Boran Ranch mitigation bank. At this bank, initial credit is released for
recording a conservation easement and completing construction activities; only after final
success criteria is met for a given wetland polygon is the remaining credit released. Two state
agency regulators relayed that in the past, some early banks believed they were "owed" a credit
release from the regulating agency for conducting monitoring, regardless of whether incremental
ecological improvement was documented.


Hydrology

Most of the banks in this study have some hydrologic enhancement or restoration with associated
credit releases for construction of these enhancements. Most enhancement practices have
included removing roads or increasing connectivity under roads, removing or blocking ditches,
and re-grading swales or other unnatural topographic features that inhibit the natural flow of
water. Some banks are highly engineered. A few have heavily manipulated hydrology because
of their placement in a regionally altered landscape (e.g., Floridawetlands Bank; Florida
Mitigation bank). Two banks have constructed significant berms with control structures to
increase water levels on site (i.e., Loxahatchee and Florida Mitigation Bank). Everglades Phase
II and Bear Point have existing berms required for flood control or mosquito control; these banks
have installed multiple controlled culverts through the berms to more closely mimic sheet-flow
when allowable. Eight banks are known to have permanent water control structures as described
in their state permits. In total, 19 banks describe some level of target hydrology listed in their
success criteria. Other requirements hydrology requirement include that four banks must meet
M-WRAP or other assessment criteria standards, and seven banks must meet a size requirement
of jurisdictional wetlands as defined under Section 373.421, F. S. (a bank may have more than









one of these requirements). Five banks do not specifically mention hydrology in their final
success criteria, although some credit releases are tied to installation of hydrologic enhancements
or monitoring of said enhancements.

Hydrologically based construction also occurred on the banks in terms of grading the existing
lands to achieve a lower elevation to support target communities. Hole in the Donut requires
grading all of the previously rock-plowed "soil" (approximately 0.3 m) down to the underlying
limestone to prevent re-infestation of Brazilian pepper (Schinus terebinthifolius) and to promote
the native marsh community. Likewise Florida Wetlandsbank, Panther Island, and Corkscrew
have areas dominated by exotic species or pasture permitted to be graded to support a marsh
community. Grading allowed for the appropriate target wetland species to become established
and the community to more closely resemble the desired target community. However areas that
have been rock plowed and graded lose the capacity for ground water storage in the areas that
have been lowered.

The successful completion of construction activities typically result in the release of 10-20% of
the potential credits, with a few exceptions for major construction projects: Tosohatchee and East
Central at 30% and Florida Wetlandsbank at 40% (Table 3-3). Credit release is usually based on
as-built information and/or other hydrologic data showing anticipated hydrologic enhancements
or water levels were attained. Although surface water level changes tend to occur quickly after
most hydrologic enhancement structures are in place, soil, plant, and animal community response
to the enhanced hydrology may take several years or longer.

Although one of minimum requirements of success of Rule 62-312.350, F.A.C. state that water
quality standards are met, very few banks monitor for water quality. Most banks do not
specifically propose to improve water quality through wetlands mitigation, but this might be
implied with restored function of those wetlands such as through nutrient cycling and improving
fauna habitat. The state of Florida does not have water quality standards specific to wetlands,
but general Class III water quality standards do apply (Ch. 62-302 Surface Water Quality
Standards, F.A.C.). Some of the banks have written into their state permit that they must adhere
to Best Management Practices during construction for minimizing turbidity and slope
stabilization. Eight banks are required by their state permit to monitor water quality during that
time. Only Bear Point, Florida Mitigation Bank, and Lake Louisa and Green Swamp have
mitigation activities intended to specifically improve water quality.

Exotic and inappropriate species removal

Invasive exotic and nuisance species are a tremendous ecological and financial concern for land
managers on conservation lands in Florida and elsewhere in the United States (e.g., Pimentel et
al. 2000). Many contend that these species threaten biodiversity, ecosystem functioning,
community health, or human economies (Myers et al. 2000; Diaz et al. 2003). Throughout
Florida's history, some non-native species were deliberately planted as part of previous human
land use activities like pasture, agriculture, and citrus, and as such are present on lands used for
wetland mitigation banking. While some of these species are not considered an invasion threat
(e.g., sweet orange or grapefruit, Citrus x aurantium), others can persist, reproduce, and spread









(e.g., West Indian marsh grass, Hymenachne amplexicaulis, Diaz et al. 2003) and are thought to
alter native community structure and function.

A disturbance or alteration in the landscape, often in the form of disruption of natural hydrology
or a total change in the landscape from a natural land use to agriculture or pasture often increases
the likely hood of occurrence of exotic species. Most of the banks in this study had enhancement
activities relating to the eradication and continued treatment of exotic vegetation. Banks had
varying degrees of exotic species. Little Pine Island (Figure 3-3), Hole in the Donut, and Florida
Wetlansbank receive most of their credit from the removal of 80-100% cover of melaleuca
(Melaleuca quinquenervia) or Brazilian pepper (Schinus terebinthifolius). Invasive tree species
can have a significant impact to the hydrology, structure, and function of native communities
when they invade open communities like marshes or flatwoods (EPPC 2003). Like wise, the
exotic climbing fern (Lygodium spp) can have significant impacts to function in forested
communities (EPPC 2003). These exotics pose difficulties in restoring natural communities in
several banks, including Bluefield, Corkscrew, Everglades Mitigation Bank, Garcon Peninsula,
and Loxahatchee.


Figure 3-3. Dense cover by the invasive exotic species melaleuca or punktree (Melaleuca
quinquenervia) prior to restoration activities at Little Pine Island.


Bahia grass (Paspalum notatum), while not as invasive in intact natural areas, can be persistent
and difficult to eradicate from pastures where it was introduced and is particularly difficult to
treat in historically more xeric habitats. Other problematic exotic species which are extremely
persistent and can dominate ground cover include torpedo grass (Panicum repens) and cogon
grass (Imperata cylindrical). Several earlier permits anticipated that with the restoration of
appropriate hydrology and cessation of cattle or citrus management practices, the native
vegetation would out-compete and dominate the pasture grasses or require only spot treatments









of these species. This has not been borne out on some banks, and they continue to face an uphill
battle with these invasive exotic species (e.g., Barberville, Big Cypress, Lake Louisa and Green
Swamp, and Lake Monroe). Other banks have been very effective at removing pasture grasses
and restoring back to a natural community (e.g., Reedy Creek, Bluefield) by implementing
thorough site preparation, vigilant monitoring, re-treating exotics, and re-seeding deliberately to
establish an intact native groundcover that can be more difficult for some exotics to invade.

Exotic species eradication is expensive and time consuming. Common control techniques
included herbicides and mechanical removal with some banks utilizing hand pulling in more
sensitive communities. Others experimented with manipulating hydrology and fire to remove
exotics and keep them from returning. Because of their landscape location and proximity to non-
conservation lands, many mitigation banks have a significant nearby constant exotic species seed
source from adjacent properties. Most banks will perpetually have to manage for exotic species
with the goal being to eradicate exotic species from the seed bank on site and treat new exotic
species that are recruited to the site.

There was a wide variety of percent cover allowed for exotic vegetation in permit success
criteria, ranging from 1% to 10%, and sometimes even higher for specific pasture grasses, such
as bahia grass (Paspalum notatum) (Table 3-4). While this figure may be specifically related to
individual conditions at the bank, it appeared that allowable coverage had a stronger relationship
to the permitting agency (Figure 3-4). Additionally, some mitigation banks also recognized that
a native species may be inappropriate for the target community such as woody species in an
herbaceous dominated habitat (e.g., wax myrtle, Myrica cerifera, at Garcon Peninsula).

Another category of inappropriate species is found in historic wet prairie, flatwoods or mixed
wetland forests of northern Florida that were converted to pine plantations. Several bank's
mitigation plans involve the restoration of native communities from the planted pine areas
(Barberville, Loblolly, Sundew and Tupelo, and to a lesser extreme TM-Econ and Garcon
Peninsula). Similarly, two banks involved significant acreage of citrus tree removal and re-
vegetation (Big Cypress, Lake Louisa). Eight mitigation banks have a potential credit release
tied to removing silviculture or agriculture trees (Table 3-1). Garcon Peninsula and TM-Econ
were the only banks of these eight that awarded potential credit based on the response of the
native community to pine removal as opposed to potential credit awards for the physical act of
removing the trees themselves.

Site preparation, planting, and seeding

With an emphasis on reference conditions for a target community, activities relating to site
preparation, planting, seeding, and expected survivorship of plants should have measurable,
expected densities. Most banks had some basic requirement for percent cover of desirable,
native species (Table 3-5). Fourteen banks include planting and/or seeding as a requirement for
credit release (3%-20%, typically 5%-10%) (Table 3-3). Site preparation is paramount to the
survival of the desirable species as is the timing of planting and activities used to maintain the
desired vegetation such as hydrologic regime and fire rotation. Vegetation planting may be
necessary in mitigation areas that no longer have a viable native seedbank or nearby seed source










Table 3-4. Final success criteria for exotic and nuisance vegetative cover for state permits.

Area
Mitigation Bank Credit Type County (ha) Exotic and nuisance cover
FDEP:
Bear Point Mangrove St. Lucie 128 < 2% cover per acre exotic
Corkscrew FW herb/for Lee 257 < 2% exotic cover; < 5% nuisance; < 25% combined
cover of Myrica cerifera, Baccharis halimifolia and
Salix caroliniana per acre
Everglades Mitigation Fresh/salt Dade 1,669 < 1% aerial cover
Bank, Phase I
Florida Mitigation Bank FW herb/for Osceola 640 < 1% total cover
Garcon Peninsula FW herb/for Santa Rosa 136 < 1% exotic; Sapium sebiferum < 1%; Bahiagrass <
10%, or if >10%, trend over 2+ years strongly
indicating cover will decrease to < 10%; in
cypress/hardwood swamp, nuisance species < 5%
Graham Swamp FW forest Flagler 27 < 5%
Hole in the Donut Everglades Dade 2,529 < 5% total cover
Little Pine Island Fresh/salt Lee 512 < 1%
Loxahatchee FW herb/for Palm Beach 512 EPPC Category I exotic < 1%; EPPC Category II
exotic < 3%
SFWMD:
Big Cypress FW herb/for Collier 518 0 % total cover exotic; < 3% total cover nuisance
Bluefield Ranch FW herb/for Martin & St. 1,091 < 10% exotic/nuisance cover; <15% in any 1 acre
Lucie area at any time
Florida Wetlandsbank Freshwater Broward 170 < 5%
Panther Island FW herb/for Hendry 1,128 < 0 % exotic (exotics divided by total species
rounded to nearest whole number); < 3% nuisance
R.G. Reserve FW herb/for Martin 258 <5% exotic; <10% nuisance < 15% total cover any 12
acre area
Reedy Creek FW herb/for Osceola & 1,211 < 10% exotic/nuisance; Uplands mean % cover by
Polk nuisance tree species < 1%; mean % cover by
nuisance shrub species < 5%; groundcover -
bahiagrass and other nuisance species < 20 %
SJRWMD:
Barberville FW herb/for Volusia 148 5% exotic; 10% nuisance
CGW Saltwater Indian River 61 < 1%
Colbert-Cameron Freshwater Volusia 1,054 < 10%
East Central Freshwater Orange 429 < 10%
Lake Louisa and Green Freshwater Lake 408 < 5% exotic; < 10% nuisance
Swamp
Lake Monroe FW herb/for Volusia 244 < 5% exotic
Loblolly Mitigation Bank Freshwater Duval 2,528 State permit < 10%; MBI < 5%
Sundew Mitigation Bank Freshwater Clay 853 < 10%
TM-Econ Freshwater Orange 2,104 < 10%
Tosohatchee DOT-used Orange 531 < 10%
Tupelo Mitigation Bank Freshwater St. Johns 617 < 10%
SWFWMD:
Boran Ranch Phase I Freshwater Desoto 96 < 1%
EEPC Category exotics from the Exotic Pest Plant Council (EPPC 2003).








1
.1
C


10%

0 .000
FDEP SFWMD SJRWMD SWFVWMD
Final success criteria
percent exotic cover allowed


Or.


O
O
0 o
'90
*Qn 0.


Figure 3-4. Final success criteria allowance for exotic vegetation percent cover by
mitigation bank and regulating agency. Agencies include: FDEP Florida Department of
Environmental Protection; SFWMD South Florida Water Management District; SJRWMD -
St. Johns River Water Management District; SWFWMD South West Florida Water
Management District.


I












Table 3-5. Success criteria related to native vegetation cover and survivability of planted vegetation in state permits.


Dominant Habitat Survivability of planted
Bank Name at Site Visit Final Success Criteria percent cover of native vegetation vegetation
Barberville Flatwoods Not specified 400 trees per acre
No planting in phase
Bear Point Mangrove swamp > 50% reviewed
reviewed
Herbaceous: > 80% cover native wetland spp. and > 20 wetland herbaceous
spp. The herbaceous vegetation shall cover >60 % with plant species listed
FAC or wetter and be rooted for at least 12 months and be reproducing
naturally
Big Cypress Fatwoods Forested: >70% coverage by desirable ground cover plants, with > 75% of > 80% survival of all
Big Cypress Flatwoods
spp. being listed FAC or wetter, planted trees and shrubs
Hydric pine flatwoods: diversity of > 30 herbaceous spp. shall be present.
For each 5 species over 30 a 1% credit bonus will be given for hydric pine
flatwoods.
Evidence of natural regeneration of planted species
Flatwoods graminoid vegetation in groundcover strata > 50% of total
coverage
> 70% of total groundcover strata consists of wetland vegetation hydricc survival of planted
> 80% survival of planted
Bluefield Ranch Flatwoods pine flatwoods only) trees
> 80% of total herbaceous groundcover strata FACW and/or OBL
vegetation
or OBL vegetation > upland vegetation
Boran Ranch Flatwoods, marsh 85 to 90% cover for desirable vegetation depending on community type No planting in phase I
CGW High marsh, 90% No planting
mangrove swamp
Colbert-Cameron Flatwoods, cypress Percent cover not specified, bank is primarily preservation with some No planting
domes enhancement
Mixed forest, Minimum percent cover of groundcover is 70% for hydric pines. No explicit numbers for
Corkscrew Regional cypress domes, Minimum percent cover of groundcover in cypress and mixed forest areas is survivorship in final
75% unless there is a lower percent because of open water or shading. su
___hydric flatwoods _Must show evidence of natural recruitment success criteria.
Unknown if there was a
East Central Wetland forested Bank was monitoring for vegetative cover but this study did not acquire requirement for
mixed documentation that stated what that final success criteria was. u i p
survivorship










Table 3-5. Continued.

Dominant Habitat Survivability of planted
Bank Name at Site Visit Final Success Criteria percent cover of native vegetation vegetation
Everglades Mitigation Sawgrass marsh, > 80% aerial coverage of vegetation including planted and naturally Survivorship not explicitly
Bank tree islands recruited vegetation defined.
Freshwater marsh,
Florida Mitigation Bank bottomland > 90% desirable vegetation groundcover and canopy NA
hardwood

Florida Wetlands Bank Freshwater marsh 80% planted species must have
80% cover
Groundcover> 75% 0 00
Garcon Peninsula Wet prairie n 7 > 90% survival
Planted canopy must have at least 30% cover
Graham Swamp Bottomland Vegetative cover must stay the same or increase over the baseline. No planting
hardwood forest Vegetation must demonstrate natural recruitment
The importance value, based on frequency and percent cover or density of
Hole in the Donut Freshwater marsh desirable vegetation, for each restoration area shall fall within the range of
Whittaker curves for the naturally occurring communities in this area of
Everglades National Park
Lake Louisa and Green Sandhill? Unknown if there are requirements for percent cover, none were obtained by Planted canopy 80%
Swamp this study Planted groundcover 60%
Lake Monroe Faoods Unknown whether there is a target percent cover in the final success criteria Planted longleaf and
Lake Monroe Flatwoods
but bank is tracking percent cover in the monitoring reports cypress 50%
Mangrove swamp,
Little Pine Island salt marsh, mud Demonstrate > 60% cover and increase over time NA
flats, hydric
flatwoods
Hydric flatwoods, > 80% cover groundcover 100 trees per acre in
Loblolly Mitigation Bank 2 forested wetlands
cypress domes > 25% mast forming trees 25 trees per acre in upland
25 trees per acre in upland
80 90% ground cover in marsh and willow polygons except in mudflats
with 25% woody species
Loxahatchee Forested swamp 50-90% canopy and ground cover for red maple, pond apple and cypress No planting
and open marsh polygons
10-20% open water as meandering water courses and small depressions
Permit also addresses appropriate number of species and densities










Table 3-5. Continued.

Dominant Habitat Survivability of planted
Bank Name at Site Visit Final Success Criteria percent cover of native vegetation vegetation
Flatwoods minimum 90%
Hydric flatwoods, 70% average aerial cover by native wetland flora for transitional and survival planted canopy
emergent marshes spp.; minimum 80%
Panther Island cypress s, Low pool marshes 60% cover survival of planted sub-
cypress domes
reshwater marshes Flatwoods 70% aerial cover by desirable ground cover and groundcover canopy spp.; minimum
recruitment 80% average survival of
planted ground cover spp.
Hydric flatwoods, flatwoods canopy cover < 50%, shrub cover < 20% Bank may have to do
Reedy Creek freshwater marsh, marshes 75% future plantings in marshes
if percent cover by natural
wet prairie prairie _> 80% recruitment can not be met
80% coverage of desirable wetland species
Uplands mean % cover by indigenous ground species > 75%
Bottomand Ground strata dominated with indigenous grass species at > 50% of total
Bottomland
hardwood forest, ground strata: mean % cover by indigenous ground strata species is > 5% Survivorship of planted
R.G. Reserve h rid fo fors, but < 30% vegetation not explicitly
hydric latwoods Mean density of indigenous shrubs and semi-shrubs is > 180 and < 400/ac defined
Shrub strata dominance < 75% by any 2 species
Mean % cover by indigenous tree species is > 5% and < 25%
Mean indigenous tree density is > 5 and < 50
Split Oak Documentation did not include success criteria specific to native vegetation cover or survivability of planted vegetation.

SMin Hydric flatwoods, 100 trees per acre in
Sundew Mitigation Bank Hydric flatwoods, No requirement for percent cover 100 trees per acre in
cypress domes forested wetlands
TM-Econ Hydric flatwoods, > 80 % aerial cover trees > 80%
forested slough
Mixed wetland
Tosohatchee forested, fresh > 80 % cover > 80%
water marsh
Minimum density of 100
surviving and growing
Tupelo Mitigation Bank Hydric flatwoods, No requirement for percent cover trees/ac present in
cypress domes assemblages that reflects
diversity in target
vegetative community









for recruitment. Additionally, supplemental plantings may be required to increase diversity,
provide structure, or stabilize areas where roads were removed, canals filled, or grading
occurred. A practice commonly followed by several more recently permitted banks for
flatwoods or wet prairie targets communities includes preparing large areas of bare ground by
disking and/or herbicide treatments, then mulching with seed and other plant material directly
from a harvested donor site.

Although most banks did list a desired percent cover for native vegetation, very seldom was
there a reference in the permit for how percent cover would be defined or measured.
Composition, dominance, structure, and other metrics that define a natural community say more
about restored function than percent cover or survivorship of planted species alone. In addition,
percent survivorship criteria often appeared to be based more on standard practice or previous
permits, as opposed to expected vegetation density in the reference standard community. These
arbitrary densities, especially for trees, should not be a standard, and plantings in specified target
communities should be based on reference standards in the literature or a natural community.

Prescribed fire

A majority of the mitigation banks in this study include a diverse landscape mosaic of upland
and wetland community types most of which are adapted to fire. Bear Point, CGW, and Graham
Swamp represent three mitigation banks where prescribed fire would not be appropriate given
that mangrove and hardwood wetland communities represent nearly 100% cover at these banks.
However, historically fire would have played a significant role in maintaining the natural
communities in the landscape surrounding these mangrove and bottomland hardwood swamps.

The FDEP mitigation rule requires mitigation bank permits to contain perpetual management
plans (62-342.750(1)(h) F.A.C). Most of the banks acknowledge the role of prescribed fire in
maintaining the natural communities on site. However, it was difficult to determine how detailed
long term fire management plans were. Some banks also have (or intend to) utilized prescribed
fire during enhancement and restoration activities in addition to using it for long term
management of the natural communities.

Eight bank permits had a credit release associated with conducting a prescribed fire (Table 3-3).
A few more permits required prescribed fire as part of the final release criteria. There is evidence
that some banks are not as aggressive in the application of prescribed fire as they could be. At
least two banks, Big Cypress and Barberville, cite being unable to apply prescribed fire until
planted pine trees (Pinus spp.) in flatwoods communities are established for eight to ten years.
Additionally, Barberville anticipates waiting 15 years to burn an area planted with cypress
(Taxodium spp.). Documents for both banks do not adequately describe the natural community
type, but suggest the overall reason for not applying prescribed fire is because of possible
mortality to the planted trees. As well, both banks demonstrate a lack of diversity in the
groundcover in what this study determined should be flatwoods communities. The emphasis to
protect the planted trees appears misplaced when restoring the function for this community type.
For example, in longleaf pine (Pinus palustris) communities, Kirkman and Mitchell (2006)
propose that the age and diversity of groundcover and temporal extent of fire connections across
the landscape may be more appropriate means of describing old-growth ecosystems as opposed









to the age of trees, stressing the importance of appropriate groundcover and fire regime over tree
structure. A low intensity prescribed fire during the growing season could benefit the
groundcover and enhance species diversity. Primary concern for planting the pine trees first
before restoring the groundcover may not have been the best approach to achieve success and
restoring a functioning flatwoods community.

At least seven banks included in this study reported that they were behind in accomplishing their
prescribed burn plan for site specific conditions, usually because the site was either too wet or
too dry. Other limitations for some banks include their placement in populated areas where
smoke control is more restricted (e.g., Everglades Mitigation Bank Phases I and II). In some
circumstances (e.g., Garcon Peninsula), the inability to bum has set back the restoration progress
because a primarily herbaceous ecosystem has been over taken by an overstory of shrubs and
other woody structure. In this specific case, prescribed fire was tied to credit release and the
state withheld future credit releases pending fire implementation.

As with all of the construction and management activities described in this chapter it would be
worthwhile for regulators to consider tying credit release to the natural communities response to
management decisions such as prescribed fire. Fire is an ecosystem process that can drastically
alter a landscape, if applied appropriately it can be a tool for restoration and maintenance of a
natural community. Monitoring should be conducted to determine flora and fauna response to
the application of fire. Frequency and application techniques of prescribed fire should be based
on reference documentation and literature.

Credit releases for construction and management activities described previously are based on
documentation that the required action has occurred. In total, these activity-based releases at a
typical bank averaged about 50% of the total potential credits (Table 3-3), and represent the
preservation and completion of the mitigation "work" at the bank. Although it is recognized that
the actual work does sometimes represent actual enhancements made, mitigation success may be
improved if credits releases were weighted more toward incremental improvement and
community response to these treatments and actions, rather than simply completion of
predetermined activities. The remaining credits are typically based on achieving incremental or
final performance goals.

Monitoring and Interim Release Criteria

Most mitigation banks are required to submit an annual monitoring report to document the level
of success attainment. Monitoring plans, including both qualitative and quantitative parameters,
are reviewed prior to permitting, and thus should be adequate to evaluate success criteria.
Monitoring plans are generally referenced in permit criteria or attached to the permit. Some state
permits specifically addressed what is expected in monitoring reports, others did not have
specifications. The FDEP mitigation banking rule (Chapter 62-342, F.A.C.) requires that
mitigation banks include a proposed monitoring plan to demonstrate success. Monitoring reports
acquired in this study represented varying degrees of quality of data and quantity and
completeness of information. For utility, monitoring reports should refer to success criteria, both
interim and final, and specifically demonstrate incremental change from the baseline. If a bank









is using reference wetlands for target restoration, then monitoring reports should reflect how the
restored areas compare to reference conditions.

Some monitoring reports were mere plant lists, with minimal analyses and vague descriptions. It
could be that some early permits did not specify enough detail as to what was required for
monitoring, and bank are not offering more than these minimal requirement. While agency
personnel do tend to visit banks either when new monitoring reports are submitted or following
requests for credit release and regulators should be capable of verifying what is in the report,
time and resources devoted to agency monitoring and analysis is limited. Efforts would be
improved so that monitoring reports read easily for anyone unfamiliar with site history or
permitting conditions of the bank. A monitoring report should summarize success criteria,
history of the bank, activities completed, activities planned, and discuss how the bank is
progressing in restoring and enhancing the natural target communities. Further, monitoring
reports should clearly and unambiguously state if the mitigation bank is on target with interim or
final success criteria and if the bank is trending towards success and describe the parameters it is
meeting.

Compliance regulators reported that seven banks did not report on areas that were not
demonstrating ecological improvement or did not submit a report because no activities were
taking place. Sometimes if a bank falls behind in meeting their targets, the bank will not request
additional credits release but will also not submit a monitoring report, as that would require
admitting problems with attaining interim targets or monitoring. Some permits require a status
report every six months, regardless of the degree of activity or monitoring results, which may be
a good tool to track mitigation activities and progress.

After major mitigation construction activities but prior to final credit release, interim credits are
typically awarded by year or phase of a mitigation bank. Potential credits awarded for reaching
interim criteria vary, with mean awards of 5-8% of total potential credits per year. Total interim
criteria varied around 30%-50% release of total potential credit (Table 3-3) over an average of
four to five years. While there is an expectation that releasing interim criteria should implicate a
"trending towards success," many times this was not reinforced by specific criteria that should
demonstrate incremental ecological improvement. Out of twenty three mitigation banks that
included an "interim" release, only thirteen had specific criteria tied to this annual or interim
release.

It is important that permits clearly distinguish that the interim/annual credit releases are based
upon the ecological functions gained since the last monitoring report, rather than on the submittal
of the annual monitoring report itself. Compliance regulators reported some problems with
expectations based on reports rather than success. Further, field work associated with this study
revealed cases where credits were released when it appeared that interim criteria had not been
achieved. Compliance regulators reported that monitoring reports can be misleading or report on
improving areas rather than the whole site. A few mitigation banks have few or no credits
released for interim success, either because credits are withheld until the bank or polygon attains
full success (e.g., Boran Ranch) or because the activities represent the final or near final success
(e.g., Colbert-Cameron, Florida Wetlandsbank). In addition, the number of years required for
monitoring and meeting final success varies, with most anticipating a five year release schedule,









some anticipating an accelerated schedule (e.g., Florida Wetlandsbank, Graham Swamp, Panther
Island), and other banks have or are anticipated to take 10 or more years (e.g., Everglades
Mitigation Bank, Florida Mitigation Bank, Garcon Peninsula, Hole in the Donut, Loxahatchee).
In fact, even a 10 year time span may be too short to fully attain the natural variability and
function for ecosystem development (Mitsch and Wilson 1996), even if permit success criteria
are reached.

Final Success Determination and Release

Ideally, final success criteria should reflect the mitigation project's target community goals and
anticipated functional gain, as determined by the potential credit assessment (i.e., its "with-bank"
scenario). An early guidance document for Florida mitigation banking, Joint State Federal
Mitigation Bank Review Team Process (the "Greenbook," cited as Story et al. 1998), suggests
that the risk inherent in wetland mitigation banking is managed through credit release schedules
and that because most credits are not released until the success criteria have been met, risk has
been minimized. Further, the "Greenbook" suggests that success criteria should be specific and
quantifiable based on the field assessment used to determine appropriate awarding of credits
(Story et al. 1998). Yet only five wetland mitigation banks reviewed included functional
assessment scores, such as WATER, Wetland Rapid Assessment Procedure (WRAP, Miller and
Gunsalus 1999), or Uniform Mitigation Assessment Method (UMAM, Chapter 62-345, F.A.C.),
in the final success criteria.

For over a decade, wetland scientists have recognized that permit success criteria and achieving
wetland function may not be equivalent (Mitsch and Wilson 1996), yet changes have not been
made in the permitting process to require completion of functional assessments for attaining
credit release. Functional assessment scores for WRAP or UMAM may not be included in permit
language because of concerns about the inherent subjectivity in the methods. For example, an
assessor could award a higher functional assessment score based on the incentive to attain
functional success and not necessarily based on a wetland assessment area truly achieving the
suggested function. This concern for subjectivity and evaluator bias does not speak well of the
reliability of rapid assessment methodologies or the human involvement in wetland mitigation
banking. Even in more calculation intensive methods such as the Hydrogeomorphic approach to
assessing wetland function (HGM), it has been suggested that an assessor could "visualize" a
higher percent cover of desirable species or "miss" an exotic species that occurred on a transect
to improve the final score. Perhaps development of a more objective means of measuring
ecological function is called for, and holding those involved in the process personally responsible
for such evaluations would improve the situation. Despite these limitations, achieving a
predetermined with-bank scenario score for a given functional assessment method could be used
as a back up measure to withhold final credit release if the site did meet permit success criteria,
but has been poorly monitored or is not functioning as anticipated.

Final release of potential credits for mitigation bank state permits have been organized in two
ways: one includes final release of credits as an incremental installment of available credits after
final monitoring for the entire mitigation bank, and the second separates out final credit release
based on criteria specific to each community type or polygon. The typical range of potential
credits for final credit releases is between 5-20% of total potential credits awarded (Table 3-3).









One obvious exception to the typical range is Lake Monroe, which has a potential final credit
release of 35% total potential credits. To date, all potential credits have been released for Lake
Monroe except for this final 35%, because it has not met its final success criteria. However,
success criteria for this bank do not appear to encapsulate ecological function. There are
incremental improvements, but the majority of credit is tied to the survival of a planted canopy
instead of restored groundcover for a community that should have a species rich groundcover.
There is also credit tied to the application of prescribed fire in the communities that are intact but
are in need of enhancement. At this time the bank is behind schedule in implementing
prescribed fire. Fortunately this final credit is being with held until improvements are made to
the restored and enhanced areas. It is doubtful, under the current management strategy, that the
pastures will ever be reclaimed and resemble any reference conditions, but this was never part of
the success criteria goals. The primary with holding of final credit release appears to be tied to
failures of control structures on hydrologic enhancement areas. Another exception to the average
final success release is Boran Ranch, where the permit withholds 75% of credits until final
success criteria are attained. However, this attainment is based on each polygon, rather than the
whole bank, thus it becomes "successful" in pieces, which may mimic the incremental releases
of other banks.

There are causes for concern if meeting final success criteria has a less significant credit release.
This further illustrates the importance of the regulator's ability to determine that incremental
credit releases are appropriate and determine a trending towards success. If banks are unable to
meet final success criteria because they have failed to create conditions suitable for ecological
trajectories, the final credits cannot be released.

Compliance with Permit Schedule of Activities and Success Criteria

State mitigation bank regulators were interviewed and asked to comment on the technical aspects
of compliance for their respective mitigation banks. Their responses have been compiled and are
listed in Table 3-6. In this section, success and trending towards success are defined in regards
to permit criteria only. Three mitigation banks have reached final success criteria for the entire
bank (East Central, Florida Mitigation Bank, Tosohatchee). Regulators believe that nine banks
appear to be trending towards success and should be able to reach final success. Five banks are
currently not trending towards success, at least in specific problem areas. Six banks were not far
enough along for regulators to comment on whether or not they are trending towards success yet.
Most banks are visited at least once, if not twice, a year by the regulatory agency; most visits are
timed with monitoring reports and requests for credit release. This documentation is anecdotal,
sometimes the regulator did not have all the institutional history on a bank if it was before their
involvement and others expressed that some issues were one time incidents and not a continuous
issue.

Summary

To insure that the credits released for use can indeed provide offsets to wetland functions, the
following recommendations are necessary to the highest levels:
Permits and attached or referenced documents should contain the detailed community
goals and/or reference conditions the site is anticipated to attain. FNAI descriptions









could provide a valuable starting point to ensure that more than just vegetation is
included. It is important to evaluate wildlife responses to mitigation activities.
* Final success criteria should be quantifiable reflections of these goals.
* Credit potential should be assessed with a reasonable evaluation of future condition
given the expectations for surrounding landscape and water sources.
* Implementation of fire management plan, as appropriate, should be a permit
requirement, rather than just referenced in mitigation plans.
* Regulatory agencies must endeavor to write permits that can be followed and enforced
that use the best available technology or protocol for restoration, be vigilant in
demanding accurate and representative monitoring reports, withhold credit for
underachieving sites, and ensure frequent communication and inspection of the sites.
* The permit's credit release schedule should be commensurate with actual functional
gain including the value of site preservation, with a higher focus on community
response to mitigation activities, as opposed to the activity itself, and based on specific
criteria.










Table 3-6. Summary of regulatory compliance for 28 wetland mitigation banks.


Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
Barberville Problems with planting pines, have Long ways off. No problems. Pretty good with New district staff has been out
had to replant several times but latest communication, good to the bank a couple of times,
monitoring report reports good success about district visit, and going again now because
with second planting which occurred of credit release request. If the
in 2004. Bank has not had a permit bank is not improving, then the
modification yet but has planted district will allow more time to
cypress in areas that were more wet meet criteria.
than anticipated, pine is not surviving.
Bank did not request credit release
when plantings were failing, now that
they are finding better success they
have asked for credit release.
Bear Point First release for exotic species control, Practically meeting Need reminders Needed help with process 1-2 times/yr with every credit
preservation, and financial assurance, success criteria after only when submitting but good communicating. release.
1-2 years. reports.


Big Cypress Time zero was reset because could not Permit may have to be Pretty good about Communicating pretty Generally visit Big Cypress
get ground cover to proper modified either in submitting reports well. Usually on time every time a request for credit
specifications. Recently bank number of credits or type on time although did except for what was release is submitted. Other
submitted request for credit release, of credits because they withhold a previously mentioned, than that, site visits may
but the district only gave a partial may not be able to get monitoring report for happen at the request of the
release because the herbaceous level 1 the torpedograss within a while because they permitted to address a specific
criteria could not be met because success criteria were trying to do issue (i.e., analyze methods to
torpedograss (Panicum repens) cover requirements. (this may better with the eradicate torpedograss). Site
was greater than 10%. Bank has not have ever been done torpedograss, fell a visit may be requested if there
finished all planting. before as far S.McCarthy little behind trying to are any glaring non-
knows) May experiment get it under control, compliance issues from the
with different techniques monitoring reports. District
to try and control the staff has visited the bank for
torpedograss. training and educational type
purposes for district staff in the
past. The bank has always been
very accommodating.










Table 3-6. Continued.
Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
Bluefield Credit for Phases 4 and 5 have been Have met all Reports are never Very communicative and Agency staff only gets out
Ranch released post site inspection by requirements to date, late. Usually very responsive, never late. once or twice a year. Try to
district. Percent cover exceeds success very successful to date. lengthy with lots of time inspections following
criteria goals in the permit. Bank has documentation submittal of monitoring reports
met all requirements to date. Never exceeding minimum and prior to credit releases.
denied a credit release. requirements. Typically credit release
inspections and general
inspections are conducted
together, limited staff and high
work load being the factor.
Boran Ranch There is not interim success criteria. Final success is per Annual reports are Good communicating, Site visits usually at least twice
Bank is laid out in polygons, there are polygon. A polygon very good and on bank keeps good track of a year. Visits coincide with
no partial success or trending toward might be the interior of a time. credit withdrawals, requests to release credit.
success credit releases. A polygon marsh and another Sometimes the bank might
either has reached success or not. polygon for the ecotone think they deserve credit
Credits released for Conservation or transition area. The release but the agency does not
Easement and construction and then transition zone might be believe the polygon has met
for reaching success. Phase I is mostly more difficult to achieve final criteria.
released. Phase II conservation success because of
easement and construction credits, pasture grasses and
Agency feels that the bank knows exotic species. Very cut
what the expectations are and what and dry, either successful
exactly it has to do. Myakka is set up or not. If a polygon
the same way. cannot reach success may
have to do a credit
modification and adjust
success criteria and
credits. Final success
criteria is based on
UMAM.










Table 3-6. Continued.
Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
CGW No instance when credit was not Progressing well, Sometimes needs to Not always District site visit are
released because of compliance issues. currently in monitoring be reminded to keep communicating on the performance related. Site visit
phase. on track. Asked for a ground. Lately bank is before credit is released when
credit release a year better about monitoring report is submitted
after monitoring communicating and is and also to see how bank is
report was due. straightening up ledger progressing with interim
issues. criteria.
Colbert- No problems with compliance, Looks good do not Submitting Good communication. New district staff has been to
Cameron previous regulator said things were foresee any problems. everything. the bank once, do not know
progressing well. history of previous district staff
bank visits.

Corkscrew Long delay with initiating work. Was If they had scrapped the Made a significant Not communicating at Lots of field work in
not communicating that on the ground site like original intention modification of the first what they were permitting will be onsite for
work had begun. Reevaluate different the plan had more risk permit to do less doing, doing their own initial credit release December
plan based on lack of earth work- and might have been earth work. On the thing. Better now. Work 2006.
construction changes. Permit more difficult to hit final ground less was was good. They are
modification made new plan less success. Hydrologic final done (less impact). responsive now.
intrusive but did not have big impact success may be more
on success criteria or monitoring. Will difficult to reach now
not be as wet. that they did not scrape.
East Central Unknown if there is any history of not Sold out final success Unknown. Unknown. Unknown.
meeting interim criteria, achieved.



Everglades On the ground success looks good. Phase I attained- Tardy with annual Not always on target. -1/year with credit release.
Mitigation conscientious monitoring report.
Bank management.










Table 3-6. Continued.
Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
Florida Hydrology poorly designed-ended up Do not have control of Initial monitoring Initial reporting and 1-2 times/yr with every credit
Mitigation firing manager, got new manager, and water input, but have and management modification very release.
Bank everything improved, first year annual relationship with Disney; techniques poor; misleading; good after
credit release was denied, official FDEP and good after new new consultant (-2000).
MBRT success consultant (-2000).
determination 2004.
Florida Regulator does not know previous A final more recent Very good about No problems known. Site visits every year not
Wetlandsbank compliance history but in last few phase has some time left submitting reports necessarily tied to credit
years the transfer of the bank to the in monitoring before the on time, adequate release or a set time schedule,
City of Pembroke Pines for perpetual remaining credit (2.63) is detail and just worked out between bank,
maintenance was held up because the released, information. district, county, the Corp and
buffer between housing on west side the City of Pembroke Pines.
of the bank had homeowners Early stages did annual visit
infringing into the conservation with the agencies. Towards the
easement with exotic plantings, swing final stages the only bank
sets etc. Bank managers had to go to activities were treating
the homeowners and remove all undesirable vegetation. The
infringements from the bank and then bank was well established so
the bank was required to put up a did not do as many site visits
fence on the bank boundary in that
area before the SFWMD allowed the
final transfer.
Garcon Good start-initial credit release for fire Needs a lot of work if Was out of Not good needs Frequent early on, but 2+ years
Peninsula and exotic eradication. Site got wetter they are going to try to compliance because constant agency w/ no work, no request for
than anticipated when ditches were hit final success. Back was not getting prodding. credit release and no site visit;
plugged. Changed cover type. tracked some what burning done and working to get back on track
Management fell behind, because no burning, so had aerial spraying with frequent agency
will take longer than of exotic species. inspections and notices.
planned. Hydrologic Reports not sent
success evident, because no work
done










Table 3-6. Continued.
Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
Graham Monitoring is not often enough. Did not attain final Data are sometimes Not responsive about 1+/yr earlier, now every other
Swamp success but 95% there. poor; because early keeping ledger up to year.
permit not required date.
to do long term
management reports.
Hole in the Ahead in restoration by acre. May never meet final On time, scientific Miami Dade county not No "credit release" schedule
Donut success criteria, cover is good annual good about reporting per se, but inspections -once/2
not the same as reference monitoring, but permits and updating years reveal timely/appropriate
conditions but function is deficient credits, management.
believed to be met. status/activity
reporting relative to
permit.
Lake Louisa Only SJRWMD bank that requested a Bank suffered from Have been Monitoring report New district staff visited the
and Green credit release and the district said no. neglect, problems with submitting reports misleading, not on target. bank initially to become
Swamp Having problems meeting interim bankruptcy. It is the on time but they are oriented and familiar with it.
success regarding groundcover and District's opinion that the not always accurate. Since then there has been a site
shrub layer in the planted areas, bank will have to change Reports are visit conducted because a
District asked for a plan for how bank its management strategy misleading and only monitoring report was
will address these issues. The bank is if it will ever meet final reporting on areas submitted and a credit release
in disagreement with the District's success. that are more requested.
decision because of previous successful not the
arrangements made with staff that is areas that are not in
no longer with the District. There was compliance.
never a permit modification for
success criteria. Bank is not in
compliance but believes that it is
trending towards success.










Table 3-6. Continued.
Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
Lake Monroe Problems with ground cover, some Unknown. No current Communicating pretty New District staff has been out
plantings have failed, structure for monitoring report, well. to look at the bank and has had
hydrologic improvement has had some new District staff discussions about some of the
blow outs District land managers plans on spending problems hydrologicc
may try to help with pasture grass more time with this structures and pasture grasses).
issues because it is District property, bank and addressing Bank is willing to redo that
ultimately when it is turned over then its issues, work but there is debate about
District will maintain, but they do not culvert maintenance between
want it until FDOT has found success district and FDOT land
with restoration and enhancement managers, may be an issue
measures and is up to date on discussed with previous staff
prescribed fire. no longer with the district.
Little Pine Good at hitting target. Lots of phases are done; Reporting/ Mostly good, but some 1-2 times/yr with every credit
Island no final success communication debit requests very late. release.
determination requested good.
yet.
Loblolly Request in right now for credit release, Very early stages of Had to be asked for Not communicating so Visit planned to determine
Mitigation site visit is planned. Initially credit for bank. report. well, but is getting better, credit release.
Bank conservation easement and clearing Does call a lot but has to
pines but have since done some be reminded for reports
plantings. and more administrative
type things. Bank does
get in touch but might
need more guidance and
help in the process.
Loxahatchee Not getting credit released because so Hydrology success a Good monitoring Very communicative and 1-2 times/yr with every credit
far mostly unsuccessful, may not be problem in south parcel and reporting also responsive, release.
able to reach final criteria, due to leaky underground addresses the
conduits and canal level problems
management out of responsively.
control of bank re-
evaluation of criteria and
credit likely.










Table 3-6. Continued.
Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
Panther A couple times there was a hold up on Appears all phases Bank reports are Very communicative, WMD site visits tied to credit
Island a release because WMD needed to go trending towards meeting usually on time, or if good relationship. release most of the time.
out and do a site visit, one phase okay total success. not there is a District staff has visited the
but another was not, specifically there Preservation areas doing particular reason that bank to practice plant
was an issue with the exotic species very well, creation areas they have identification and train staff in
smut grass (Sporobolus indicus) and might take longer. As far communicated to the the District. Site visits are
torpedograss (Panicum repens). Bank as meeting criteria, Phase WMD for example conducted for final releases for
was required to do a re-treatment II might be too much site was too wet to particular phases.
before full requested release. One cover- it exceeded sample vegetation,
phase had a design modified because a percent cover or time zero report
site was wetter then expected. With requirement and went was delayed because
time the Bank seems to know when to from supporting open planting issues with
wait to ask for certain releases because water fauna such as weather, lots of
they know WMD will not approve it in ducks and white pelicans planning went into
its current standing. to supporting larger and baseline and
more common egrets and monitoring before
herons, does not conflict anything was done
with success criteria, on site.
R.G. Reserve Bank has done minor enhancements, If percent cover is not Bank withheld All reports are up to date Agency staff only gets out
mostly credit for preservation. Credit achieved the bank will monitoring reports and submitted now. Very once or twice a year. Try to
might be denied sale because of have to do some because they did not little credit release, two time inspections following
withholding monitoring report vegetative planting. have Corp permit sold for owner's projects submittal of monitoring reports
(because the bank is waiting for a Corp yet, if the bank and one other private but and prior to credit releases.
permit). submits monitoring only 2/10 of a credit. Typically credit release
reports saying inspections and general
wetlands were inspections are conducted
restored, Corp would together, limited staff and high
award less credit, work load being the factor.
Corp already has
said that site is just
preservation. Bank
has modified its
monitoring schedule.










Table 3-6. Continued.

Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency
Reedy Creek No record of having with held credit Bank is fulfilling its On time or ahead of Communication Credit release and monitoring
for not meeting interim goals. requirements and schedule with exemplary, bank and the reports simultaneously with
submissions, improvements to get agency audit each other, conducting site visits.
credit release, make sure both are on the
Quality of reports is same page- verify each
exemplary. others books are straight.
Split Oak Unknown. Unknown. Unknown. Unknown. Unknown.

Sundew Bank has only had an initial release for Very early stages of Had to be asked for Not communicating so Bank has had a site visit
Mitigation the conservation easement and has had bank. report. well, but is getting better, because of request for credit
Bank some credits released for hydrologic Does call a lot but has to release. Bank is in very early
enhancements, pine removal, and be reminded for reports stages of work. Have done
some plantings. and more administrative some planting, removed
type things. Bank does planted pine, and some
get in touch but might hydrologic enhancement.
need more guidance and
help in the process.
TM-Econ No problems meeting interim criteria. No foreseen problems Always on time and Very responsive, no District site visit are
meeting final criteria, responsive, complaints from District. performance related. Site visit
before credit is released when
monitoring report is submitted
and also to see how bank is
progressing with interim
criteria.
Tosohatchee Unknown if there is any history of not All credits released, Unknown. Unknown. Previous regulator said bank
meeting interim criteria, applicant not asking for was in good shape so it is not a
anything. current priority for follow-up
to the new District staff.










Table 3-6. Continued.

Monitoring and Administrative Record
Management Keeping -Ledger; Frequency of Compliance
Bank Interim Criteria Final Success Status Reports Communication Inspections by Agency


Has had some credits released for
hydrologic enhancements, clearing of
pine, and some planting.


Very early stages of
bank.


Had to be asked for
report.


Not communicating so
well, but is getting better.
Does call a lot but has to
be reminded for reports
and more administrative
type things. Bank does
get in touch but might
need more guidance and
help in the process.


Bank has had a site visit
because of request for credit
release. Bank is in very early
stages of work. Have done
some planting, removed
planted pine, Done with
hydrologic enhancement.
Tupelo has had the most work
of the three banks including
Sundew and Loblolly.


Tupelo
Mitigation
Bank









CHAPTER 4
DETERMINATION OF ECOLOGICAL INTEGRITY

In order to assess the current ecological integrity of the wetland communities in Florida wetland
mitigation banks, five assessment methods were applied to select wetland assessment areas:
Uniform Mitigation Assessment Method (UMAM), Wetland Rapid Assessment Procedure
(WRAP), Hydrogeomorphic wetland assessment method (HGM), Florida Wetland Condition
Index (FWCI), and Landscape Development Intensity (LDI) index. This chapter defines the
term ecological integrity for the purpose of this study, followed by an overview of wetland
assessment areas and a presentation of results from the five assessment methods. Comparisons
among assessment methods are discussed.

Definition of Ecological Integrity

For this study, we adopt Karr and Dudley's (1981) definition of ecological integrity. They state
that a system with high ecological integrity has the ability "to support and maintain a balanced,
integrated, adaptive community of organisms having a species composition, diversity, and
functional organization comparable to that of the natural habitats of the region" (pg. 56). In
order to ascertain the degree of ecological integrity of the assessment sites in this study, we
compared the sites to the appropriate reference standard condition for the region.

The term "reference standard wetland condition" has been defined (Smith 2001) as "the least
altered wetlands in the least altered landscapes" (pg. 3), suggesting that those wetlands reflect the
highest level of functioning for all of the functions expected of that type of wetland. Thus, the
ecological integrity associated with these wetlands with no apparent anthropogenic alterations
and surrounded by natural landscapes would be optimal.

All of the field assessment methods used in this study were developed with reference to
minimally impacted ecological communities, and this comparison has been built into the scoring
criteria for each assessment method. For example, UMAM includes a Part I Qualitative
Description where the evaluator must determine the reference community type, hydrologic
connectivity, and the expected functions and wildlife (both common and listed species) before
the site visit and scoring occurs. Similarly, WRAP begins with an office evaluation that requires
review of aerial photography, identification of adjacent land use, and identification of wetland
area (Miller and Gunsalus 1999). Both HGM and FWCI were developed based on a comparison
of reference standard wetland community condition, and scoring criteria were standardized
against a set of reference wetlands.

Regional similarities and differences among wetland communities were considered when
defining ecological integrity. WRAP was originally designed for use in certain types of south
Florida wetlands, and has been applied state-wide to a variety of wetland types, whereas UMAM
was intended to apply to all wetland community types statewide. The FWCIs for depressional
forested wetlands and forested strands and floodplains are not limited geographically in the state.
The Everglades flats HGM assessment method is applicable only to southern portions of the state
(Figure 4-1), and both the depressional wetlands HGM assessment method and the depressional
herbaceous FWCI were limited to the Florida peninsula (Figure 4-2).





































Figure 4-1. Applicable range of the Everglades flats Hydrogeomorphic wetland assessment
method (HGM) in South Florida. Reprinted with permission from Noble et al. (2002).


Results of Assessment Methods

Site visits were completed at a total of 58 wetland assessment areas within 29 mitigation banks.
Each wetland assessment area was assigned a unique code. The first set of characters were
assigned as abbreviations of the mitigation bank name. For example, 'Barb' represents
Barberville and 'Blue' represents Bluefield Ranch. The second set of characters were assigned
as unique descriptions of a particular wetland type: BOT for Bottomland Hardwoods, FLA for
Hydric Flatwoods, FOR for Mixed Forested, HAM for Cabbage Palm Hammock, PRA for Wet
Prairie, SHR for Shrub, and SLT for Salt Marsh. When more than one wetland assessment area
at a bank was the same wetland community type, a number was added to the code.

One to four wetland assessment areas were selected within each bank for field assessment,
depending on a combination of site specific conditions such as homogeneity of the bank,
mitigation activities completed to date and progress towards success criteria, area of wetland
within the bank, types of mitigation (i.e., restoration, enhancement, creation, or preservation),
and general site conditions. Priority was given to those areas representative of the bank and
where mitigation work had been conducted.

















[I I Reference Domain


M Reference Domain


0 100 200 Kilometers


Figure 4-2. Applicable ranges (reference domain) of A) depressional wetlands
Hydrogeomorphic wetland assessment method (HGM) and B) depressional herbaceous
Florida Wetland Condition Index (FWCI) in peninsular Florida. HGM map reprinted with
permission from Noble et al. (2004).









Generalized statistics regarding the size of banks as well as the wetland assessment areas
sampled are telling of the vast differences among the banks (Table 4-1). For example, the mean
bank area was 848 ha (a = 894.5 ha) with a range from 27 ha at Graham Swamp to 3,653 ha at
Everglades Mitigation Bank/Phase II. The size of the wetland assessment areas ranged from 0.2
ha at Lake Monroe to 282.2 ha at Loxahatchee, with a mean wetland assessment area of 20.3 ha
(a = 48.3 ha). The mean wetland assessment areas was 15.8% (c = 30.8%) of the total bank
area, with a range spanning from 0.1% at Loblolly Mitigation Bank and TM-Econ to 100% at
Bear Point and Graham Swamp. Less than 1% of the bank area was included in the wetland
assessment areas at 13 banks, while over 50% of the bank area was included in the wetland
assessment areas at four banks.

Regardless of the size of the bank, which includes upland area as well as wetland area, the
assessment areas were sampled to best reflect the scope of current conditions. For example, at
Panther Island, four wetland assessment areas were selected due to the heterogeneity in wetland
community and mitigation types. However, due to the large size of the bank (1,128.3 ha) and the
small size of the wetland assessment areas (4.5 ha total); only 0.4% of the bank was included in
the wetland assessment areas. Only a single wetland assessment area was selected at each of
nine banks. At six of these banks, this was because the single wetland assessment area was
representative of the dominant type of wetland community and mitigation activities. For
example, an 8.1 ha wetland assessment area at Everglades Mitigation Bank/Phase II covered just
0.2% of the entire area of the wetland mitigation bank. In contrast, the 19.0 ha wetland
assessment area at CGW covered 31.3% of the bank area. Due to vast differences in the size of
the banks (60.7 ha at CGW and 3,652.7 ha at Everglades Mitigation Bank/Phase II), the percent
of area covered is vastly different (31.3% compared to 0.2%). However, sampling efforts based
on equal percentages of area of bank covered would not provide additional information regarding
the ecological integrity of wetland communities within these banks. Furthermore, sampling an
equal percent of wetland area at bank would have been time and resource inhibitive (e.g.,
sampling 31.3% of Everglades Mitigation Bank/Phase II would have required 1,143.3 ha of
wetland assessment areas).

At each of the 58 wetland assessment areas, UMAM, WRAP, and LDI were used to determine
ecological integrity (Table 4-2). At 16 of the wetland assessment areas, one or more additional
assessment methods were completed (HGM n= 15; macrophyte FWCI n = 10; macroinvertebrate
FWCI n = 4). HGM could only be applied to sites with a wetland community type with a
regional HGM guidebook, which were limited to flats wetlands in the Everglades (Noble et al.
2002) and depressional wetlands in peninsular Florida (Noble et al. 2004). Similarly, the
macrophyte FWCI could only be applied to depressional herbaceous wetlands in peninsular
Florida (Lane et al. 2003), depressional forested wetlands (Reiss and Brown 2005a), and forested
strand and floodplain wetlands (Reiss and Brown 2005b). Only a subset of those wetland
assessment areas sampled for the macrophyte FWCI were appropriate for additional sampling
using the macroinvertebrate FWCI (n = 4) as only four wetland assessment areas met the criteria
of 10 cm of standing water covering a minimum of 50% of the surface area. A diatom FWCI is
also available for depressional herbaceous wetlands (Lane et al. 2003) and depressional forested
wetlands (Reiss and Brown 2005a). However, due to the small sample size (n = 4) and the time
and expense associated with sample processing, a decision was made to eliminate diatom FWCI
analysis. Indeed, a greater set of HGM and FWCI appropriate wetlands would be useful for










Table 4-1. Area of wetland mitigation banks
study.


and wetland assessment areas in the this


% of Bank in
Wetland Mitigation Wetland Assessment Wetland Assessment
Bank Name & Site Code Bank (ha) Area (ha) Areas
Barberville 148.0 1.4
Barb CYP 0.6
Barb MAR 1.4
Bear Point 128.3 100
Bear MAN 128.3
Big Cypress 518.0 2.4
BigC_FLA 7.3
BigC_MAR_1 2.4
BigC MAR 2 2.6
Bluefield Ranch 1,090.6 2.9
Blue BOT 26.0
Blue FLA 5.3
Blue MAR 0.5
Boran Ranch, Phase I 95.8 23.1
Bora MAR 1 1.1
Bora MAR 2 21.0
CGW 60.7 31.3
CGW MAN 19.0
Colbert-Cameron 1,053.8 2.3
CoCa CYP 1 5.2
CoCa CYP 2 5.7
CoCa FOR 13.0
Corkscrew 257.0 2.2
Cork FLA 5.7
East Central 385.0 1.9
ECF1 FOR 0.9
ECF1 HAM 6.4
Everglades Mitigation Bank/Ph I 1,669.2 5.8
Glad MAR 1 93.0
Glad MAR 2 2.2
Glad SHR 0.9
Everglades Mitigation Bank/Ph II 3,652.7 0.2
Glad MAR 3 8.1
Florida Mitigation Bank 640.2 0.3
FLMB FOR 1.8
Florida Wetlandsbank 170.0 6.1
FLWt MAR 1 9.1
FLWt MAR 2 1.2
Garcon Peninsula 136.4 59.4
Garc FLA 81.0
Graham Swamp 26.7 100
Grhm FOR 26.7











Table 4.1. Continued.
Wetland Mitigation Wetland Assessment % of Bank in Wetland
Bank Name & Site Code Bank (ha) Area (ha) Assessment Areas
Hole in the Donut 2,529.3 7.6
HID MAR 1 21.2
HID MAR 2 171.0
Lake Louisa and Green Swamp 407.5 0.8
Loui SHR 3.2
Lake Monroe 244.0 0.3
Monr CYP 0.6
Monr MAR 0.2
Little Pine Island 511.5 7.8
LPI MAR 6.0
LPI SLT 1 10.0
LPI SLT 2 24.0
Loblolly Mitigation Bank 2,528.0 0.1
Lob CYP 1 1.1
Lob CYP 2 0.7
Loxahatchee 511.5 85.6
Lox CYP 82.0
Lox FOR 282.0
Lox SHR 74.0
Panther Island 1,128.3 0.4
Pant CYP 1 0.4
Pant CYP 2 0.7
Pant CYP 3 2.5
Pant FOR 0.9
Reedy Creek 1,211.2 0.2
Reed BOT 1.3
Reed FOR 0.7
R.G. Reserve 258.2 0.6
RG MAR 1.6
Split Oak 424.5 0.7
SplO_CYP 1.9
SplO MAR 1.2
Sundew Mitigation Bank 852.7 0.5
Sun FOR 1 3.3
Sun FOR 2 1.1
TM-Econ 2,103.9 0.1
TMEc CYP 1 1.0
TMEc CYP 2 1.5
Tosohatchee 530.9 0.3
Toso FOR 0.9
Toso MAR 0.3
Toso SHR 0.4
Tupelo Mitigation Bank 617.1 0.6
Tup_FOR 0.7
Tup PRA 2.8










Table 4-2. Overview of wetland assessment areas (n = 58) including Florida Land Use, Cover and Forms Classification System
(FLUCCS Code), associated wetland community type, and wetland assessment methods applied: Uniform Mitigation
Assessment Method (UMAM), Wetland Rapid Assessment Procedure (WRAP), Hydrogeomorphic wetland assessment method
(HGM), Florida Wetland Condition Index (FWCI) for macrophytes and macroinvertebrates, and Landscape Development Intensity
(LDI) index.

FLUCCS Wetland Community Macrophyte Macroinvertebrate
Bank Name Site Code Code Type UMAM WRAP HGM FWCI FWCI LDI
Barberville Barb_CYP 6210 Cypress
Barb MAR 6410 Freshwater Marsh //
Bear Point Bear MAN 6120 Mangrove Swamps ,/ ,/ ,/
Big Cypress BigC_FLA 6250 Hydric Pine Flatwoods/ ,/ /
BigC_MAR_ 1 6410 Freshwater Marsh ,/ ,/ ,/
BigC MAR 2 6410 Freshwater Marsh ,/ ,/ ,/
Bluefield Ranch Stream and Lake
Blue_BOT 6150 Swamps (Bottomland) ,/ / ,/
Blue_FLA 6250 Hydric Pine Flatwoods V/ V/ V/
Blue MAR 6410 Freshwater Marsh ,/ ,/ ,/ ,/ ,/
Boran Ranch, Phase I Bora MAR 1 6410 Freshwater Marsh ,/ / / V/ / ,/
Bora MAR 2 6410 Freshwater Marsh ,/ ,/ ,/
CGW CGW MAN 6120 Mangrove Swamps V/ V/ V/
Colbert-Cameron CoCa_CYP_1 6210 Cypress / V V
CoCa_CYP_2 6210 Cypress/ ,/ /
Mixed Wetland
CoCa FOR 6170 Hardwood V/ V/ V/
Corkscrew Cork_FLA 6250 Hydric Pine Flatwoods V/ V/ V/
East Central ECF1 FOR 6300 Wetland Forested Mixed / ,/ /
ECF1 HAM 6181 Cabbage Palm Hammock / ,/ ,/
Everglades Mitigation Glad_MAR 1 6410 Freshwater Marsh ,/ / V/ /
Bank/Phase I Glad MAR 2 6410 Freshwater Marsh/ ,/ /
Mixed Wetland
Glad SHR 6172 Hardwoods Shrubs ,/ ,/ ,/
Everglades Mitigation
Bank/Phase II Glad MAR 3 6410 Freshwater Marsh ,/ ,/ ,/ ,/










Table 4-2. Continued.


FLUCCS Wetland Community Macrophyte Macroinvertebrate
Bank Name Site Code Code Type UMAM WRAP HGM FWCI FWCI LDI
Wetland Forested
Florida Mitigation Bank FLMB FOR 6300 Mixed V/
Florida Wetlandsbank FLWt MAR 1 6410 Freshwater Marsh V/ V/ V/ V/
FLWt MAR 2 6410 Freshwater Marsh V/ V/ V/ V/
Garcon Peninsula Garc FLA 6250 Hydric Pine Flatwoods V/ V/ V/
Mixed Wetland
Graham Swamp Grhm FOR 6170 Hardwoods V/ V/ V/
Hole in the Donut HID MAR 1 6410 Freshwater Marsh V/ V/ V/ V/
HID MAR 2 6410 Freshwater Marsh V/ V/ V/ V/
Lake Louisa and Green Mixed Scrub Shrub
Swamp Loui SHR 6310 Wetland V/ V/ V/
Lake Monroe Monr CYP 6210 Cypress V V V V V
Monr MAR 6410 Freshwater Marsh V/ V/ V/ V/ V/
Little Pine Island LPI MAR 6410 Freshwater Marsh V/ V/ V/
LPI SLT 1 6420 Saltwater Marshes V/ V V/
LPI SLT 2 6420 Saltwater Marshes V/ V/ V/
Loblolly Mitigation Bank Lob_CYP_I 6210 Cypress V V/
Lob_CYP_2 6210 Cypress ,/ ,/ ,/
Loxahatchee Lox_CYP 6210 Cypress ,/ ,/ ,/
Mixed Wetland
Lox FOR 6170 Hardwoods / V/
Mixed Wetland
Lox SHR 6172 Hardwood- Shrubs ,/ ,/ ,/
Panther Island Pant CYP_I 6210 Cypress / / / / V/
Pant CYP_2 6210 Cypress V/ V/ V/
Pant CYP_3 6210 Cypress V/ / V/
Wetland Forested
Pant FOR 6300 Mixed ,/ ,/ ,/
Reedy Creek Stream and Lake
Reed_BOT 6150 Swamps (Bottomland) / V/
Mixed Wetland
Reed FOR 6170 Hardwood ,/ ,/ ,/ ,/ ,/ ,/










Table 4-2. Continued.


FLUCCS Wetland Community Macrophyte Macroinvertebrate
Bank Name Site Code Code Type UMAM WRAP HGM FWCI FWCI LDI
R.G. Reserve RG MAR 6410 Freshwater Marsh v v v v v
Split Oak SplO_CYP 6210 Cypress/ ,/ /
SplO MAR 6410 Freshwater Marsh ,/ ,/ ,/ ,/ ,/
Wetland Forested
Sundew Mitigation Bank Sun_FOR_1 6300 Mixed / V V
Wetland Forested
Sun FOR 2 6300 Mixed V/ V/ V/
TM-Econ TMEc_CYP_I 6210 Cypress / V V
TMEc CYP 2 6210 Cypress V/ V/ V/ V/
Mixed Wetland
Tosohatchee Toso FOR 6170 Hardwood V/ V V/
Toso MAR 6410 Freshwater Marsh / V V
Toso SHR 6460 Mixed Scrub Shrub V/ V/ V/
Wetland Forested
Tupelo Mitigation Bank Tup_FOR 6300 Mixed / V V
Tup PRA 6430 Wet Prairie ,/ ,/ VI









further consideration of ecological integrity of wetlands within banks; however, HGM and FWCI
could not be applied to wetlands that did not fit the conditions for the reference wetlands used in
developing these biological assessment tools.

Using the Florida Land Use, Cover and Forms Classification System (FLUCCS Code), 12
wetland community types were differentiated in the wetland assessment areas (Table 4-2). The
most common wetland community types were 6410: Freshwater Marsh (n = 18) and 6210:
Cypress (n = 13). In addition, 13 forested wetlands with mixed species composition were
assessed, including five 6170: Mixed Wetland Hardwood, two 6172: Mixed Wetland Hardwoods
- Shrubs, and six 6300: Wetland Forested Mixed community types.

Uniform Mitigation Assessment Method UMAM

UMAM scores for the 58 wetland assessment areas ranged from a low of 0.47 at a hydric pine
flatwoods at Big Cypress (BigC_FLA) to the high of 0.93 at five wetland assessment areas: two
freshwater marshes at Boran Ranch, Phase I (Bora_MAR 1 and Bora_MAR_2), one freshwater
marsh at Hole in the Donut (HID_MAR 1), a saltwater marsh at Little Pine Island (LPI_SLT_2),
and a cypress wetland at Split Oak (SplO_CYP) (Table 4-3). Recall that the scale of UMAM
ranges from 0.00-1.00, with 1.00 representing the optimal or reference standard condition. Half
of the wetland assessment areas had UMAM scores greater than or equal to 0.75 (n = 29),
suggesting that these wetland assessment areas provide 75% or more wetland function.

UMAM scores were based on an average of three categories representing indicators of wetland
function: Location and Landscape Support, Water Environment, and Community Structure.
These scores ranged from 4 to 9 for Location and Landscape Support, 5 tol0 for Water
Environment, and 4 tol0 for Community Structure. While several wetland assessment areas
scored 10 for both Water Environment (n = 7) and Community Structure (n = 2), no wetland
assessment area scored 10 for the category of Location and Landscape Support.

As with the other assessment methods, UMAM was not meant to be used as a comparison among
wetland community types. As such, UMAM scores have been summarized based on specific
wetland community types using FLUCCS (Table 4-4). Averaging the UMAM scores by wetland
community type shows that mean UMAM scores ranged from 0.53-0.80, though these averages
have large standard deviations showing a great deal of variability in the function provided by the
wetland assessment areas. The highest mean UMAM score for any wetland community type was
0.80 (a = 0.18) for 6420 Saltwater Marsh. The large standard deviation is based on the wide
variability in the scores for the two saltwater marshes at Little Pine Island, as one represented the
pre-restored condition at LPI_SLT_1 (UMAM = 0.67) and one the post-restored condition at
LPI_SLT_2 (UMAM = 0.93). Perhaps in this case, the difference between the two scores is
more telling than the mean, as the numbers imply a functional lift of 0.26 may be attained by
implementing the mitigation plan for Little Pine Island salt marshes. Similarly, at Everglades
Mitigation Bank, freshwater marsh wetland assessment areas were sampled before (Phase II -
Glad_MAR 3) and after (Phase I Glad_MAR_l1) mitigation activities were implemented.
Again, the difference between the high UMAM score for the restored wetland assessment area of
0.83 and score of 0.60 at the pre-restoration wetland assessment area indicates the potential
functional lift attainable from restoration activities.










Table 4-3. Uniform Mitigation Assessment Method (UMAM) scores for 58 wetland
assessment areas at 29 wetland mitigation banks. In addition to total UMAM score, scores
are presented for each of the three UMAM scoring categories: Location and Landscape Support,
Water Environment, and Community Structure.

Location and
Landscape Water Community
Bank Name Site Code Support Environment Structure UMAM
Barberville Barb CYP 8 7 8 0.77
Barb MAR 8 8 7 0.77
Bear Point Bear MAN 8 8 9 0.83
Big Cypress BigC_FLA 5 5 4 0.47
BigC_MAR_1 7 8 6 0.70
BigC MAR 2 7 8 7 0.73
Bluefield Ranch Blue BOT 7 8 6 0.70
Blue FLA 8 9 8 0.83
Blue MAR 8 7 7 0.73
Boran Ranch, Phase I Bora MAR 1 9 10 9 0.93
Bora MAR 2 9 10 9 0.93
CGW CGW MAN 4 7 8 0.63
Colbert-Cameron CoCa CYP 1 8 7 7 0.73
CoCa CYP 2 8 9 8 0.83
CoCa FOR 8 9 7 0.80
Corkscrew Cork FLA 5 5 5 0.50
East Central ECF1 FOR 7 7 7 0.70
ECF1 HAM 9 8 6 0.77
Everglades Mitigation Bank/Phase I Glad_MAR_1 7 9 9 0.83
Glad MAR 2 8 8 9 0.83
Glad SHR 7 9 9 0.83
Everglades Mitigation Bank/Phase II Glad MAR 3 5 7 6 0.60
Florida Mitigation Bank FLMB FOR 8 7 5 0.67
Florida Wetlandsbank FLWt MAR 1 4 9 9 0.73
FLWt MAR 2 4 9 8 0.70
Garcon Peninsula Garc FLA 6 7 5 0.60
Graham Swamp Grhm FOR 4 7 7 0.60
Hole in the Donut HID MAR 1 9 9 10 0.93
HID MAR 2 8 9 8 0.83
Lake Louisa and Green Swamp Loui SHR 8 6 5 0.63
Lake Monroe Monr CYP 9 9 9 0.90
Monr MAR 7 10 7 0.80
Little Pine Island LPI MAR 8 10 8 0.87
LPI SLT 1 8 7 5 0.67
LPI SLT 2 8 10 10 0.93
Loblolly Mitigation Bank Lob_CYP_I 6 8 6 0.67
Lob CYP 2 8 9 9 0.87











Table 4-3. Continued.


Location and
Landscape Water Community
Bank Name Site Code Support Environment Structure UMAM
Loxahatchee Lox CYP 5 7 5 0.57
Lox FOR 6 9 5 0.67
Lox SHR 6 7 7 0.67
Panther Island Pant CYP 1 7 8 6 0.70
Pant CYP 2 8 9 8 0.83
Pant CYP 3 8 9 6 0.77
Pant FOR 9 10 8 0.90
Reedy Creek Reed_BOT 6 5 6 0.57
Reed FOR 7 9 7 0.77
R.G. Reserve RG MAR 7 7 6 0.67
Split Oak SplO_CYP 9 10 9 0.93
SplO MAR 8 6 7 0.70
Sundew Mitigation Bank Sun FOR_1 6 8 6 0.67
Sun FOR 2 7 9 7 0.77
TM-Econ TMEc CYP 1 9 7 6 0.73
TMEc CYP 2 9 8 9 0.87
Tosohatchee Toso FOR 8 9 9 0.87
Toso MAR 9 9 9 0.90
Toso SHR 8 9 8 0.83
Tupelo Mitigation Bank Tup_FOR 7 6 6 0.63
Tup PRA 6 5 5 0.53












Table 4-4. Uniform Mitigation Assessment (UMAM) scores categorized by Florida Land
Use, Cover and Forms Classification System (FLUCCS) wetland community type. In
addition to total UMAM score, mean (7) scores and standard deviation (a) are presented for
each of the three UMAM indicators: Location and Landscape Support, Water Environment, and
Community Structure.


UMAM Category


0
0


X;

S3
VI
^
S3
-J
*a

s-0
1
-
o C
Kl 0
^
'A s_/


If

0-




0' .


Sample size n 1 13 18 4 2 2 5 2 2 2 1 6

Location and X 9.0 7.8 7.3 6.0 6.0 8.0 6.6 6.5 8.0 6.5 6.0 7.3
Landscape Support a na 1.2 1.6 1.4 2.8 0.0 1.7 0.7 0.0 0.7 na 1.0


Water Enviromnent X 8.0 8.2 8.5 6.5 7.5 7.5 8.6 8.0 8.5 6.5 5.0 7.8
W ater Environm ent -- -- --- -- --- -- --- -- --- -- ----- --
a na 1.0 1.2 1.9 0.7 2.1 0.9 1.4 2.1 2.1 na 1.5

Community X 6.0 7.4 7.8 5.5 8.5 6.5 7.0 8.0 7.5 6.0 5.0 6.5
Structure a na 1.4 1.2 1.7 0.7 2.1 1.4 1.4 3.5 0.0 na 1.0

UMAM T 0.77 0.78 0.79 0.60 0.73 0.73 0.74 0.75 0.80 0.64 0.53 0.72
UMAM 0.16 0.14 0.14 0.11 0.11 0.18 0.09 na 0.10
ci na 0.10 0.10 0.16 0.14 0.14 0.11 0.11 0.18 0.09 na 0.10


*a
'f<









UMAM scores reflect current condition of the assessment areas and do not indicate the
beginning condition of the assessment area, nor the anticipated amount of ecological lift
attributed to the mitigation plan, nor the overall status of the bank in accordance with the
permitted plan. The degree of ecological improvement, or lift, in a bank determines the number
of potential credits awarded and integrates changes from the beginning condition and the
anticipated condition of the bank. Lift has been defined as the number of potential credits
awarded per acre. Mean lift was 0.38 (a = 0.20), with a range from 0.05 (at R.G. Reserve, which
had minor enhancement) to 0.88 (at Florida Wetlands Bank, with mostly restoration). When
Hole-in-the-Donut was included, the mean lift was slightly higher at 0.40 (a = 0.23), as Hole-in-
the-Donut more closely resembles an in-lieu-fee bank, and has been awarded 1 credit per acre of
restoration. Each data point on Figure 4-3 represents a wetland assessment area, with the
UMAM score for the wetland assessment area on the y-axis (vertical) and lift or potential credits
released for the entire mitigation bank on the x-axis (horizontal). No correlation was found
between UMAM scores, lift, or potential credits released (Figure 4-3).

















En
O A
U
0
HO
* U


Permitted Lift (credits/ac)





(B)


Potential Credit Released (%)


Percent of Potential Credits Released o <25% A >=25, <50% 0 >=50, <75% m >75%



Figure 4-3. Uniform Mitigation Assessment Method (UMAM) scores for the 58 assessment
areas in relation to A) permitted lift (credits/ac) in respective bank and B) potential credits
released (%) at respective bank.


M :


o
o



0


AA
A


1.0 -


0.8 -


0.6 -


0.4


0 0
00
0
OO


A A
A
A


U
U
U.
U
U
U


mm









WRAP: Wetland Rapid Assessment Procedure


The WRAP scale ranges from 0.00-1.00, with 1.00 representing the reference standard condition.
WRAP has six scoring categories, each with scores ranging from 0.0-3.0, in 0.5 increments, and
a score of 3.0 represents an "intact" wetland. For herbaceous wetland systems, the category of
Wetland Canopy (O/S) is generally not scored; however, if the wetland assessment area had 20%
or greater overstory and/or shrub canopy, a score was assigned (Miller and Gunsalus 1999). This
was the case at three of 18 wetland assessment areas with a wetland community type of 6410:
Freshwater Marsh.

A freshwater marsh at Boran Ranch, Phase I (Bora MAR 1) received a 0.99, the highest WRAP
score (Table 4-5). This wetland assessment area also received the highest UMAM score of 0.93.
At the other extreme, a hydric pine flatwoods at Corkscrew (Cork FLA) received the lowest
WRAP score of 0.47 (Table 4-5). No wetland assessment area received a 0.0 score in any of the
six scoring categories. However, nine scores of 0.5 were assigned for the categories of Wetland
Canopy (O/S) (n = 2), Wetland Ground Cover (GC) (n = 3), Habitat Support/Buffer (n = 3), and
Water Quality Input & Treatment (WQ) (n = 1).

Thirty-two wetland assessment areas had WRAP scores greater than or equal to 0.75.
Comparison of mean WRAP scores within FLUCCS wetland community types shows a wide
variability in scores ranging from x= 0.57 (a = 0.18) for 6250 Hydric Pine Flatwoods (n = 4) to
T= 0.82 (a = 0.13) for 6210 Cypress (n = 13) (Table 4-6). The highest variability of WRAP
scores within a wetland community type was for 6420 Saltwater Marshes for two wetland
assessment areas within Little Pine Island mitigation bank; the same wetland assessment areas
discussed earlier for UMAM. The scores ranged from 0.49 at the pre-restoration saltwater marsh
(LPI_SLT_1) to 0.92 at the restored saltwater marsh (LPI_SLT_2). At the other extreme, the
wetland community type with the smallest variability in WRAP scores was 6120 Mangrove
Swamps (x= 0.74, a = 0.02). Both of the 6120 Mangrove Swamps assessment areas at Bear
Point (Bear MAN) and CGW (CGW_MAN) scored 3.0 in the category of Wetland Canopy
(O/S). However, total WRAP scores were lower than the optimal 1.00 score at these sites due to
the influence of adjacent development, which generally provided poor habitat support and
buffers, limited wildlife utilization, and adversely influenced wetland hydrology. As noted in the
UMAM section above, assessment area scores reflect current condition at the time of site visits.
No correlation was found between WRAP scores, lift, or potential credits released (Figure 4-4).










Table 4-5. Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland
assessment areas. In addition to total WRAP score, scores are presented for each of the six
WRAP scoring categories: Wildlife Utilization, Wetland Canopy, Wetland Ground Cover,
Habitat Support/Buffer, Field Hydrology, and Water Quality Input & Treatment.








Bank Name Site Code iz S 0
Barberville Barb CYP 2.5 2.5 2.5 2.5 2.5 2.8 0.85
Barb MAR 2.5 na 2.0 2.5 2.5 2.5 0.80
Bear Point Bear MAN 2.5 3.0 na 2.5 2.0 1.3 0.75
Big Cypress BigC_FLA 1.5 1.0 0.5 1.4 2.0 2.5 0.49
BigC_MAR_1 2.0 2.0 2.0 2.4 3.0 3.0 0.80
BigC_MAR_2 2.0 2.5 2.0 2.1 2.5 3.0 0.78
Bluefield Ranch Blue BOT 2.0 1.5 2.0 2.3 2.5 1.7 0.67
Blue FLA 2.5 2.5 3.0 2.4 3.0 1.6 0.83
Blue MAR 2.0 na 2.0 2.5 2.5 3.0 0.80
Boran Ranch, Phase I Bora MAR 1 3.0 na 3.0 3.0 3.0 2.9 0.99
Bora MAR 2 3.0 na 2.5 2.5 3.0 2.9 0.93
CGW CGW MAN 2.0 3.0 3.0 1.5 2.0 1.5 0.72
Colbert-Cameron CoCa FOR 2.5 2.0 2.5 2.5 3.0 3.0 0.86
CoCa CYP 1 2.0 2.0 3.0 2.5 2.0 3.0 0.81
CoCa CYP 2 2.5 2.5 2.5 2.5 3.0 3.0 0.89
Corkscrew Cork FLA 1.5 na 0.5 1.6 2.0 1.5 0.47
East Central ECF1 FOR 2.0 2.0 0.5 2.0 2.0 3.0 0.64
ECF1 HAM 2.0 2.0 2.5 2.0 2.5 3.0 0.78
Everglades Mitigation Bank/Phase I Glad_MAR_ 1 2.5 na 3.0 1.6 2.5 2.1 0.78
Glad MAR 2 2.5 3.0 2.5 2.0 2.0 2.4 0.80
Glad SHR 3.0 2.5 3.0 2.5 2.5 3.0 0.92
Everglades Mitigation Bank/Phase II Glad_MAR_3 1.5 na 2.0 1.5 2.0 2.8 0.65
Florida Mitigation Bank FLMB_FOR 2.5 1.5 2.0 1.8 2.0 0.9 0.59
Florida Wetlandsbank FLWt MAR 1 1.5 na 2.0 0.5 2.5 1.8 0.55
FLWt MAR 2 1.5 na 1.5 0.5 2.5 1.8 0.52
Garcon Peninsula Garc FLA 1.5 0.5 1.0 1.9 2.0 1.8 0.48
Graham Swamp Grhm FOR 2.5 2.5 2.0 1.3 2.0 1.9 0.68
Hole in the Donut HID MAR 1 3.0 na 3.0 2.6 3.0 2.5 0.94
HID MAR 2 3.0 na 2.5 2.0 2.0 2.0 0.77
Lake Louisa and Green Swamp Loui_SHR 2.0 1.0 2.0 2.0 1.0 2.8 0.60
Lake Monroe Monr CYP 3.0 2.0 3.0 2.5 2.0 3.0 0.86
Monr MAR 2.0 na 2.0 2.0 3.0 2.5 0.77
Little Pine Island LPI MAR 2.5 na 2.5 3.0 3.0 3.0 0.93
LPI SLT 1 2.0 0.5 1.0 1.5 1.5 2.4 0.49
LPI SLT 2 2.5 3.0 3.0 2.5 3.0 2.5 0.92










Table 4-5. Continued.


Bank Name Site Code 0 C. ) 2
Loblolly Mitigation Bank Lob_CYP_I 2.0 2.0 2.0 2.5 2.0 1.0 0.64
Lob CYP 2 2.5 3.0 2.5 2.5 2.5 3.0 0.89
Loxahatchee Lox CYP 1.5 1.5 1.0 1.5 1.5 1.9 0.49
Lox FOR 1.5 2.0 2.0 0.5 2.0 1.3 0.52
Lox SHR 1.5 2.5 2.5 1.0 2.0 1.4 0.60
Panther Island Pant CYP 1 3.0 3.0 1.5 2.5 2.5 2.8 0.85
Pant CYP 2 2.5 3.0 2.5 2.5 3.0 3.0 0.92
Pant CYP 3 2.5 3.0 1.5 2.5 2.5 2.8 0.82
Pant FOR 3.0 3.0 2.0 2.5 3.0 2.0 0.86
Reedy Creek Reed_BOT 2.0 1.5 1.5 2.1 2.0 2.2 0.63
Reed FOR 2.0 2.0 2.0 1.5 3.0 0.5 0.61
R.G. Reserve RG MAR 2.0 na 2.0 1.8 2.0 2.8 0.71
Split Oak SplO_CYP 3.0 3.0 2.5 3.0 3.0 3.0 0.97
SplO_MAR 2.0 na 2.0 2.4 1.5 3.0 0.73
Sundew Mitigation Bank Sun_FOR_ 1 2.0 2.0 1.5 2.0 2.5 1.6 0.65
Sun FOR 2 2.0 2.0 3.0 2.0 2.5 1.6 0.73
TM-Econ TMEc CYP 1 2.5 1.5 1.5 2.8 2.0 2.7 0.72
TMEc CYP 2 3.0 3.0 2.5 3.0 2.5 2.9 0.93
Tosohatchee Toso FOR 2.5 3.0 2.0 2.5 2.5 2.8 0.85
Toso MAR 3.0 na 3.0 2.0 3.0 3.0 0.93
Toso SHR 2.5 3.0 2.0 2.5 3.0 3.0 0.89
Tupelo Mitigation Bank Tup_FOR 2.5 2.0 2.5 2.3 1.5 2.1 0.70
Tup_PRA 1.5 1.5 1.5 2.2 1.5 2.5 0.59











Table 4-6. Wetland Rapid Assessment Procedure (WRAP) scores categorized by Florida
Land Use, Cover and Forms Classification System (FLUCCS) wetland community type.
Values for each wetland community type include mean (x) and standard deviation (a).


WRAP Category


0
0


0


0a
0


I.









0


I



S3


a-.


Sample size n 1 13 18 4 2 2 5 2 2 2 1 6
Wildlife Utilization x 2.0 2.5 2.3 1.8 2.3 2.3 2.2 2.3 2.3 2.0 1.5 2.3
(WU) a na 0.5 0.5 0.5 0.4 0.4 0.4 1.1 0.4 0.0 na 0.4

Wetland Canopy X 2.0 2.5 2.5 1.3 3.0 2.0 2.3 2.5 1.8 1.5 1.5 2.1
(O/S) a na 0.6 0.5 1.0 0.0 1.4 0.4 0.0 1.8 0.0 na 0.5

Wetland Ground X 2.5 2.2 2.3 1.3 3.0 2.0 2.1 2.8 2.0 1.8 1.5 1.9
Cover (GC) G na 0.6 0.5 1.2 na 0.0 0.2 0.4 1.4 0.4 na 0.9

Habitat Y 2.0 2.5 2.1 1.8 2.0 2.3 1.7 1.8 2.0 2.2 2.2 2.1
Support/Buffer G na 0.4 0.7 0.4 0.7 0.4 0.9 1.1 0.7 0.1 na 0.3

Field Hydrology 7 2.5 2.4 2.5 2.3 2.0 2.0 2.5 2.3 2.3 2.3 1.5 2.3
(HYD) G na 0.5 0.5 0.5 0.0 1.4 0.5 0.4 1.1 0.4 na 0.5

WQ Input & X 3.0 2.7 2.6 1.9 1.4 2.9 1.9 2.2 2.5 2.0 2.5 1.9
Treatment (WQ) G na 0.6 0.4 0.5 0.1 0.1 1.0 1.1 0.1 0.4 na 0.7

W 0.78 0.82 0.79 0.57 0.74 0.75 0.70 0.76 0.71 0.65 0.59 0.70
WRAP3 0.18 0.02 0.21 0.15 0.23 0.30 0.03 na 0.09
na 0.13 0.13 0.18 0.02 0.21 0.15 0.23 0.30 0.03 na 0.09


E
fu
4I















- U
*


0 A
0


0


* 0


o 0 A


Permitted Lift (credits/ac)




(B)


A A E
A A 0



A A 0


-E
U
U
U


Potential Credit Released (%)


Percent of Potential Credits Released o <25% A >=25, <50% 0 >=50, <75% m >75%


Figure 4-4. Wetland Rapid Assessment Procedure (WRAP) scores for the 58 assessment
areas in relation to A) permitted lift (credits/ac) in respective bank and B) potential credits
released (%) at respective bank.









HGM: Hydrogeomorphic Wetland Assessment Method


The Hydrogeomorphic wetland assessment method (HGM) was conducted at six flats wetlands
in the Everglades and nine depressional wetlands in peninsular Florida.

Flats wetlands in the Everglades

HGM assessment for flats wetlands in the Everglades was divided into three subclasses of flats
wetlands: marl, organic, and rocky flats. These wetland subclasses were distinguished based on
geology, geomorphic setting, climate, soils, water source, hydrodynamics, and biota. A spatial
distribution of flats wetlands in the Everglades was presented by Noble et al. (2002, see Figure 2,
page 14). While the three subclasses were distinguished primarily on soil differences and
hydrology, they share similarities in wetland functions including unidirectional surface water
flow, poorly drained soils, flat terrain, and surficial aquifer interactions (Noble et al. 2002). An
overview of the variables used in HGM functional capacity index calculations and the functional
capacity index scores for all three subclasses of flats wetlands in the Everglades is presented in
Tables 4-7 and 4-8, respectively. Of the 12 variables described for functional capacity index
calculations in flats wetlands in the Everglades, 10, 9, and 11 variables were used for marl,
organic, and rocky flats wetlands, respectively (Table 4-7).

The two marl flats wetlands sampled were located in Everglades Mitigation Bank: Glad_MAR 1
in Phase I, where mitigation activities had been completed at the time of the site visit, and
Glad_MAR 3 in Phase II, where no mitigation activities had been completed at the time of the
site visit. For the marl flats wetlands in the restored wetland tract (Glad_MARl 1), 9 of the 10
variables achieved a perfect score of 1.00, where 1.00 reflects the reference standard condition.
The only variable not receiving a perfect 1.00 was Emergent Macrophytic Vegetation Cover
(MAC), with a score of 0.68. The marl flats wetland in the non-restored wetland tract
(Glad_MAR 3) also received high variable scores, with 8 of 10 variables receiving 1.00. This
wetland also received lower scores for MAC (0.40) and for Habitat Connections (CONNECT)
(0.85).

The two organic flats wetlands were both located within Florida Wetlandsbank. The variable
scores for these wetlands were lower, with FLWt_MAR 1 receiving 3 (of 9) scores of 1.00 and
FLWt_MAR 2 receiving 4 (of 9) scores of 1.00, where 1.00 reflects the reference standard
condition. Both wetlands received scores of 0.00 for the variable Microtopographic Features
(MICRO), as these wetlands had previously been rock plowed for farming and then were re-
graded as part of the restoration plan to match the modeled hydrology. These wetlands also
received scores less than 1.00 for Plant Species Composition (COMP), Habitat Connections
(CONNECT), Interior Core Area (CORE), and Wetland Tract Area (TRACT), as Florida
Wetlandsbank was located in urban Broward County with predominantly residential and
transportation land uses in the supporting landscape. FLWt_MAR_I also received a 0.90 score
for Cover of Woody Vegetation (WOODY).

The two rocky flats wetlands within Hole in the Donut included the wetland re-graded in 1989
(HID_MAR 1) receiving 7 (of 11) scores of 1.00 and the wetland re-graded in 2001 receiving 8
(of 11) scores of 1.00, where 1.00 reflects the reference standard condition. The younger










Table 4-7. Hydrogeomorphic wetland assessment method (HGM) variable for flats wetlands in the Everglades. Combinations
of these 12 variables were used to calculate wetland function scores in Table 4-8 according to equations from Noble et al. (2002).


MARL FLATS: ORGANIC FLATS: ROCKY FLATS:

Everglades Mitigation Bank Florida Wetlandsbank Hole in the Donut
Phase I Phase II
Variable Code Glad MAR 1 Glad MAR 3 FLWt MAR 1 FLWt MAR 2 HID MAR 1 HID MAR 2
Plant Species Composition COMP 1.00 1.00 0.76 0.55 na na
Habitat Connections CONNECT 1.00 0.85 0.10 0.10 1.00 1.00
Interior Core Area CORE 1.00 1.00 0.38 0.38 1.00 1.00
Invasive Vegetation INVASIVE 1.00 1.00 1.00 1.00 1.00 1.00
Emergent Macrophytic MAC 0.68 0.40 1.00 1.00 0.65 1.00
Vegetation Cover
Microtopographic Features MICRO 1.00 1.00 0.00 0.00 0.00 0.00
Number of Native Wetland
Number of Native Wetland NATIVE na na na na 1.00 1.00
Species
Periphyton Cover PERI 1.00 1.00 na na 0.73 1.00
Soil Thickness SOILTHICK na na na na 0.70 0.20
Surface Soil Texture SURTEX 1.00 1.00 1.00 1.00 1.00 0.70
Wetland Tract Area TRACT 1.00 1.00 0.03 0.03 1.00 1.00
Cover of Woody Vegetation WOODY 1.00 1.00 0.90 1.00 1.00 1.00










Table 4-8. Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores (Function) for six flats
wetlands in the Everglades. Variables in Table 4-7 were used to calculate functional capacity index scores according to equations
from Noble et al. (2002).

MARL FLATS: ORGANIC FLATS: ROCKY FLATS:

Everglades Mitigation Bank Florida Wetlands Bank Hole in the Donut
Phase I Phase II
Function Glad MAR 1 Glad MAR 3 FLWt MAR 1 FLWt MAR 2 HID MAR 1 HID MAR 2
Surface and Subsurface Water Storage 1.00 1.00 0.63 0.67 0.64 0.48
Cycle Nutrients 0.95 0.90 0.69 0.64 0.65 0.68
Characteristic Plant Community 0.98 0.96 0.66 0.62 0.72 0.59
Wildlife Habitat 0.96 0.90 0.56 0.53 0.81 0.81









wetland (HID_MAR 2), re-graded in 2001, received scores less than 1.00 for MICRO, Soil
Thickness (SOILTHICK), and Soil Surface Texture (SURTEX). Whereas, the older rocky flats
wetland (HID_MAR 1), re-graded in 1989, received scores less than 1.00 for MICRO, MAC,
SOILTHICK, and Periphyton Cover periI).

When the variables presented in Table 4-7 were used to calculate the functional capacity index
scores for the flats wetlands (Table 4-8), two wetlands, both at Everglades Mitigation Bank,
received the highest score of 1.00 for the Surface and Subsurface Water Storage function at
Phase I (Glad_MARl 1) and Phase II (Glad_MAR_3) wetlands. The remainder of the functional
capacity index scores between 0.48 and 0.98.

While HGM is not designed to provide one single overall score of wetland function, Story et al.
(1998) suggest several ways HGM could be used while establishing a single value of function.
For example, averaging the four functional capacity index scores would result in a range of
scores from 0.62 at Florida Wetlandsbank (FLWt MAR 2) to 0.97 at Everglades Mitigation
Bank Phase I (Glad_MAR 1).

Depressional wetlands in peninsular Florida

Nine wetlands belonging to both subclasses of depressional wetlands in peninsular Florida were
sampled (n = 6 herbaceous marsh depressional wetlands, n = 3 cypress domes). Noble et al.
(2004) described the differences in these two subclasses mainly on visual distinction based on
woody vegetation and a longer hydroperiod for cypress domes. The depressional wetlands HGM
model had 10 variables for herbaceous marsh depressional wetlands and 12 variables for cypress
domes.

All nine depressional wetlands received the maximum score of 1.00 for the variable Upland
Land Use (UPUSE) (Table 4-9). Further, eight of nine depressional wetlands received 1.00
scores for Surface Outlet (SUROUT) and Wetland Volume (WETVOL), as most of these
wetlands had little to no excavation or disturbance in their interior. The exceptions were the
herbaceous marsh depressional wetlands at Split Oak (SplO_MAR, SUROUT = 0.78) and
Barberville (Barb_MAR, WTEVOL = 0.92), respectively.

Among the herbaceous marsh depressional wetlands, the wetland assessment area at Lake
Monroe (Monr MAR) received a 1.00 score for 9 (of 10) variables and received a 0.98 score for
the tenth variable (MAC). Similarly, the cypress dome at Lake Monroe received the highest
number of 1.00 variable scores for 9 (of 12) variables. The remainder of the wetland assessment
areas received between three to seven scores of 1.00 for HGM variables. The herbaceous marsh
depressional wetland at Split Oak (SplO MAR) received the lowest number of 1.00 scores for
variables with 3 (of 10).

When the variables were used to calculate functional capacity index scores for herbaceous marsh
depressional wetland functions, scores ranged from 0.53 for Characteristic Plant Community at
Split Oak (SplO MAR) to 1.00 for Surface Water Storage at three wetland assessment areas
including Bluefield Ranch (Blue MAR), Lake Monroe (Monr MAR), and R.G. Reserve
(RG MAR), and Subsurface Water Storage at one wetland at Lake Monroe (Monr MAR) (Table
4-10). When attempting to compress HGM functional capacity indices into a single value for










Table 4-9. Hydrogeomorphic wetland assessment method (HGM) variable for depressional wetlands in peninsular Florida.
Combinations of these 14 variables were used to calculate wetland function scores in Table 4-10 according to equations from Noble et
al. (2004).

Herbaceous Marsh Depressional Wetlands Cypress Domes

Barber Bluefield Boran Ranch, Lake R.G. Split Oak Lake Panther Reedy
Ranch Phase I Monroe Reserve Monroe Island Creek
Variable Code Barb_MAR Blue_MAR Bora_MAR_1 MonrMAR RGMAR SplO_MAR Monr CYP Pant_CYP_1 Reed_FOR
Cypress Canopy CANOPY na na na na na na 1.00 1.00 0.40
Change in CATCH 0.75 1.00 0.93 1.00 1.00 0.85 0.50 0.12 1.00
Catchment Size
Herbaceous Plant
Species HCOMP 0.50 0.33 0.50 1.00 0.67 0.25 na na na
Composition
Macrophytic MAC 0.95 1.00 0.95 0.98 0.50 0.87 na na na
Vegetation Cover
Understory
Vegetation SSD na na na na na na 0.88 0.90 0.08
Biomass
Subsurface Outlet SUBOUT 1.00 1.00 1.00 1.00 0.15 0.00 1.00 1.00 1.00
Surface Outlet SUROUT 1.00 1.00 1.00 1.00 1.00 0.78 1.00 1.00 1.00
Surface Soil SURTEX 1.00 0.90 1.00 1.00 1.00 1.00 1.00 1.00 0.70
Texture
Tree Basal Area TBA na na na na na na 0.20 0.37 1.00
Tree Species TCOMP na na na na na na 1.00 0.90 0.20
Composition
Upland Land Use UPUSE 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00
Wetland
Wetland WETPROX 0.99 0.70 1.00 1.00 1.00 0.10 1.00 0.10 0.82
Proximity
Wetland Volume WETVOL 0.92 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00
Change in the
Number of ZONES 0.50 0.25 0.50 1.00 0.25 0.50 1.00 1.00 0.50
Wetland Zones











Table 4-10. Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores (Function) for nine
depressional wetlands in peninsular Florida. Variables in Table 4-9 were used to calculate functional capacity index scores
according to equations from Noble et al. (2004).

Herbaceous Marsh Depressional Wetlands Cypress Domes

Barberville Bluefield Boran Ranch, Lake R.G. Split Oak Lake Panther Reedy
Ranch Phase I Monroe Reserve Monroe Island Creek

Function Barb_MAR Blue_MAR Bora_MAR_1 MonrMAR RG_MAR SplO_MAR MonrCYP Pant_CYP_1 Reed_FOR
Surface Water
Surface Water 0.93 1.00 0.99 1.00 1.00 0.92 0.94 0.88 0.92
Storage

Subsurface
WS trae 0.94 0.98 0.98 1.00 0.79 0.71 0.88 0.78 0.93
Water Storage

Cycle Nutrients 0.96 0.97 0.98 0.99 0.83 0.92 0.79 0.78 0.75

Characteristic
Plant 0.85 0.79 0.85 0.99 0.58 0.53 0.88 0.88 0.31
Community

Wildlife Habitat 0.87 0.76 0.87 0.99 0.69 0.56 0.93 0.82 0.61









herbaceous marsh depressional wetland functions there was a large range when considering the
mean (0.73-0.99), the maximum (0.92-1.00), or the minimum (0.53-0.99). Selection of any of
these methods has strong impact on the overall assessment of wetland condition.

In general, cypress dome wetland assessment areas scored lower than the marsh assessment areas
with an overall range from 0.31 for Characteristic Plant Community at Reedy Creek
(Reed_FOR) to 0.94 for Surface Water Storage at Lake Monroe (Monr_CYP) (Table 4-10).
Scores for the functional capacity index category of Cycle Nutrients had a narrow range for all
three cypress domes, with scores of 0.75, 0.78, and 0.79, at Reedy Creek (Reed FOR), Panther
Island (Pant_CYP_I), and Lake Monroe (MONR_ CYP), respectively. Once more, for cypress
domes, selecting a single value to describe HGM would present a large range in scores for
wetland mean (x= 0.70-0.88), maximum (max = 0.88-0.94), or minimum (min = 0.31-0.79)
functional capacity index scores.

FWCI: Florida Wetland Condition Index

The Florida Wetland Condition Index (FWCI) is an index of biological integrity with similar
community-specific metrics for depressional herbaceous wetlands (Lane et al. 2003),
depressional forested wetlands (Reiss and Brown 2005a), and forested strand and floodplain
wetlands (Reiss and Brown 2005b). All three wetland classes have a FWCI developed for the
macrophyte assemblage. In addition, an FWCI for diatom and macroinvertebrate assemblages
has been developed for depressional herbaceous and depressional forested wetlands. This study
includes macrophyte FWCI assessments for six depressional herbaceous wetlands, three
depressional forested wetlands, and one forested strand wetland. As well, macroinvertebrate
FWCI assessments were completed at two depressional herbaceous wetlands and two
depressional forested wetlands. Macroinvertebrate samples were not collected at the remaining
six depressional wetlands, as these wetland assessment areas did not have a minimum of 10 cm
of standing water throughout a minimum of half the wetland area, which is the minimum
requirement for application of the macroinvertebrate FWCI.

Macrophyte FWCI

The depressional herbaceous wetland macrophyte FWCI included five metrics: 1) Percent of
sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of
tolerant indicator species as determined from a reference dataset (Tolerant); 3) Percent of species
exotic to the state of Florida (Exotic); 4) Ratio of annual to perennial species (A:P Ratio); and 5)
Mean Coefficient of Conservation score based on the Floristic Quality Assessment Index
(Average CC; Cohen et al. 2004). Each metric was assigned a score of 0, 3, 7, or 10 with total
possible FWCI scores ranging from 0-50, with 50 representing the reference standard condition.
Metric scores included two 0 scores for the Sensitive metric at Boran Ranch, Phase I
(Bora MAR 1) and for the A:P Ratio metric at Lake Monroe (Monr MAR) (Table 4-11). The
most common metric score was 3 (n = 14), followed by 7 (n = 9). Five metric scores of 10 were
assigned for Sensitive and for A:P Ratio at Barberville (Barb_MAR) and for Sensitive, Exotic,
and Average CC at R.G. Reserve (RG MAR). Total FWCI scores ranged from 12 (of 50) at
Boran Ranch, Phase I (Bora_MAR_ 1) to 41 (of 50) at Barberville (Barb MAR) with a mean of
26 (a = 12), translating into 24-82% of reference standard condition (x = 52%, a = 24%).









Table 4-11. Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total
FWCI scores, and percent of reference condition for six depressional herbaceous wetlands.
Wetland region from Lane (2000).

Bank Bluefield Boran Ranch, Lake
Name Barberville Ranch Phase I Monroe R.G. Reserve Split Oak
Name Ranch Phase I Monroe
Site Code Barb_MAR Blue_MAR Bora_MAR_1 Monr_MAR RG_MAR SplO_MAR
Region Central Central Central Central South Central
Sensitive 10 7 0 7 10 7
Tolerant 7 3 3 3 7 3
Exotic 7 3 3 3 10 7
A:P Ratio 10 7 3 0 3 3
Average
CC 7 3 3 3 10 3
FWCI 41 23 12 16 40 23
out of 50 50 50 50 50 50
% of
Reference 82% 46% 24% 32% 80% 46%
Condition


The depressional forested wetland FWCI included six metrics: 1) Percent of tolerant indicator
species as determined from a reference dataset (Tolerant); 2) Percent of sensitive indicator
species as determined from a reference dataset (Sensitive); 3) Percent of species exotic to the
state of Florida (Exotic); 4) Floristic Quality Assessment Index score (FQAI Score); 5) Percent
of species that are both native and perennial (Native Perennial); and 5) Percent of species that are
either facultative wetland or obligate species (Wetland Status). For the depressional forested
wetlands scoring for individual FWCI metrics was on a continuous scale from 0.0-10.0, with
10.0 representing the reference standard condition. FWCI metric scores had a mean of 5.5 (C =
3.2) with scores assigned at both extremes, with a 0.0 for the Sensitive metric at Panther Island
(Pant_CYP_I) and a 10.0 for the Tolerant metric at Lake Monroe (Monr_CYP) (Table 4-12).
Total FWCI scores ranged from 12.8 (of 60) at Panther Island to 48.3 (of 60) at Lake Monroe (Y
= 33.2, a = 18.3), translating into 21-81% of the reference standard condition (Y = 55%, C =
31%).

Five metrics were included in the forested strand and floodplain FWCI: 1)Proportion of tolerant
indicator species (Tolerant); 2) Proportion of sensitive indicator species (Sensitive); 3) Floristic
Quality Assessment Index score (FQAI Score); 4) Proportion of species exotic to Florida
(Exotic); and 5) Proportion of species that are both native and perennial (Native Perennial).
Scoring for each metric was based on a continuous scale from 0.0-10.0, with 10.0 representing
the reference standard condition. Only the wetland assessment area at TM-Econ
(TMEc_CYP_2) was included in the forested strand and floodplain FWCI calculations, with a
range of metric scores from 7.5 for the FQAI Score metric to 9.1 for the Sensitive metric (Y =
8.3, a = 0.7) (Table 4-13). The total FWCI for the wetland assessment area (TMEc_CYP_2) was
41.7 (of 50), translating into 83% of the reference standard condition.









Table 4-12. Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total
FWCI scores, and percent of reference condition for three depressional forested wetlands.
Wetland region from Lane (2000).

Bank Name Lake Monroe Panther Island Reedy Creek
Site Code Monr CYP Pant CYP 1 Reed FOR
Region Central South Central
Tolerant 10.0 3.5 9.8
Sensitive 6.6 0.0 1.5
Exotic 8.1 2.3 6.3
FQAI Score 8.9 0.5 4.6
Native Perennial 8.0 2.3 8.1
Wetland Status 6.7 4.3 8.2
FWCI 48.3 12.8 38.5
out of 60 60 60
% of Reference 81% 21% 64%
Condition


Table 4-13. Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total
FWCI score, and percent of reference condition for a forested strand wetland within TM-
Econ Mitigation Bank. Wetland region from Lane (2000).


Bank Name TM-Econ

Site Code TMEcCYP 1

Region Central
Tolerant 7.9
Sensitive 9.1
FQAI Score 7.5
Exotic 8.2
Native Perennial 9.0
FWCI 41.7
out of 50
% of Reference 83%
Condition




Full Text

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An Evaluation of the Effectiveness of Mitigation Banking in Florida: Ecological Success and Compli ance with Permit Criteria

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An Evaluation of the Effectiveness of Mitigation Banking in Florida: Ecological Success and Complian ce with Permit Criteria Kelly Chinners Reiss1, Erica Hernandez2, Mark T. Brown1 1Howard T. Odum Center for Wetlands University of Florida Gainesville, Florida 32611-6350 2Department of Environmental Protection Kissimmee Prairie Preserve Okeechobee, Florida 34972 Final Report Submitted to the Florida Department of E nvironmental Protection Under Contract #WM881 United States Environmental Protection Agency Region Four Under Contract #CD 96409404-0 May 2007

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i ACKNOWLEDGEMENTS This report concludes a two year study on Flor ida wetland mitigation banks. Suggestions and guidance were provided by C. Bersok, R. Butgerei t, J. Espy, R. Fryde nborg, V. Tauxe, and N. Wellendorf with the Florida Department of Envi ronmental Protection; A. Bain and E. Cronyn with the South Florida Water Management Distri ct; C. Hull with the Southwest Florida Water Management District; M. Reiber with the St. Jo hns River Water Manageme nt District; R. Evans with the United States Environmental Protectio n Agency; C. Noble with United States Army Corps of Engineers; and M. McGuire with Na tional Oceanic Atmospheric Administration. Land managers and/or land owners for the 29 wetland mitigation banks included in this study provided valuable assistance in granting site acce ss, providing site tours, and/or providing documentation including permits and monitoring reports. We would like to acknowledge the cooperation of M. Brown with Ba rberville Conservation Area; J. David with Bear Point; L. Alderman and L. Zenczak with Big Cypress; D. Mc Intosh and C. Olson with Bluefield Ranch; C. Kocur with Boran Ranch; C. Chown with CGW Bank; E. Colbert with Colbert-Cameron; R. Pavelka and Kevin Erwin with Corkscrew; T. Odom with East Central, Florida Mitigation Bank and Reedy Creek; S. Collins, J. Lindsay, B. Ma us, and G. West with Everglades Mitigation Bank; D. Duke and M. White with Florida Wetl andsbank; S. Kaufmann with Garcon Peninsula Mitigation Bank; S. Bradow with Graham Swamp; The National Park Service at Hole in the Donut/Everglades National Park; A Fickett with La ke Louisa and Green Swamp; R. Fowler, P. Henn and S. Tonjes with Lake Monroe; R. Pavelk a and C. Bowman with Little Pine Island; E. Hale with Loblolly Mitigation Bank, Sundew M itigation Bank, and Tupelo Mitigation Bank; K. Olsen and K. Bennett with Loxahatc hee; D. Duke, J. Styer and T. Trettis and other onsite staff with Panther Island; J. Gilio with R.G. Reserve; B. Jackson with Split Oak; J. Clark and Kathy Hale with TM-Econ; and S. Carnival and S. Sp aulding with Tosohatchee. Thank you to all the bank owners who gave permission to allow access to their property. We would also like to acknowle dge the water management distri ct staff who have not already been mentioned that gave interviews regarding compliance on the mitigation banks; P. Fetterman with the South West Florida Water Management Di strict; S. Elfers, H. Herbst, S. McCarthy, S. McNabb, J. Meyer, and T. Torrens with the South Florida Water Ma nagement District. This project and the preparation of this re port were funded in part by a United States Environmental Protection Agency (USEPA) Regi on Four grant to the Division of Water Resource Management of the Florida Depa rtment of Environmental Protection. Finally, thank you to Kissimmee Prai rie Preserve State Park mana gement and staff for providing infrastructure, resources, and support for this study.

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ii TABLE OF CONTENTS Page ACKNOWLEDGEMENTS.............................................................................................................i LIST OF TABLES................................................................................................................. ........iv LIST OF FIGURES................................................................................................................ .......vi EXECUTIVE SUMMARY.........................................................................................................viii CHAPTER 1 INTRODUCTION................................................................................................................. ....1 Background..................................................................................................................... ............1 Mitigation Bank Regulations.................................................................................................... ..2 Federal Coordination........................................................................................................... .......4 Florida Wetland Mitigation Banks..............................................................................................4 Definition of Success.......................................................................................................... ........5 Purpose of Study............................................................................................................... ..........9 2 METHODS...................................................................................................................... ........11 Mitigation Bank Locations...................................................................................................... .11 Permit Review Procedures....................................................................................................... .13 Reference Standard Condition..................................................................................................14 Site Visits Procedure.......................................................................................................... .......14 Uniform Mitigation Assessment Method (UMAM).............................................................18 Wetland Rapid Assessment Procedure (WRAP)..................................................................18 Hydrogeomorphic wetland assessment (HGM)....................................................................19 Florida Wetland Condition Index (FWCI)............................................................................19 Landscape Development In tensity (LDI) index....................................................................21 3 REVIEW OF PERMIT SUCCE SS CRITERIA AND CREDIT RELEASE...........................23 Mitigation Goals and Success Criteria......................................................................................23 Credit Potential............................................................................................................... ..........28 Preservation................................................................................................................... ............29 Credit Release................................................................................................................. ..........30 Legal Actions.................................................................................................................. ......30 Construction and Management Activities.............................................................................32 Monitoring and Interim Release Criteria..............................................................................43 Final Success Determination and Release............................................................................45 Compliance with Permit Schedule of Activities and Success Criteria.....................................46 Summary........................................................................................................................ ...........46

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iii4 DETERMINATION OF ECOLOGICAL INTEGRITY..........................................................57 Definition of Ecological Integrity.............................................................................................57 Results of Assessment Methods................................................................................................58 UMAM: Uniform Mitigation Assessment Method...............................................................66 WRAP: Wetland Rapid Assessment Procedure....................................................................72 HGM: Hydrogeomorphic Wetland Assessment Method......................................................77 FWCI: Florida Wetland Condition Index.............................................................................83 LDI: Landscape Development Intensity Index.....................................................................88 Comparison of Assessment Methods........................................................................................92 UMAM and WRAP..............................................................................................................92 UMAM, WRAP, and LDI.....................................................................................................96 HGM and FWCI...................................................................................................................96 Suggestions for Assessment Methods.....................................................................................109 5 PERMIT REVIEW AND ECOLOGICAL INTEGRITY: CASE STUDIES........................111 Case Study: East Central....................................................................................................... ..112 Case Study: Florida Wetlandsbank.........................................................................................116 Case Study: Sundew Mitigation Bank....................................................................................121 6 DISCUSSION................................................................................................................... .....127 Permit Review.................................................................................................................. .......127 Natural Communities..........................................................................................................128 Groundcover Restoration....................................................................................................129 Community Structure..........................................................................................................130 Fire Management................................................................................................................131 Sustainability and Landscape Position................................................................................132 Credits for Achieving Success Criteria...............................................................................134 Coordination and Standa rdization among Agencies...........................................................135 Regulatory Agency Compliance Responsibilities..............................................................136 Ecological Integrity........................................................................................................... ......136 Limitations to Study........................................................................................................... .....138 Future Research Direction......................................................................................................138 Conclusion..................................................................................................................... .........139 REFERENCES..................................................................................................................... ......141 APPENDIX A Field Standard Operating Procedures................................................................................A-1 B Field Data Sheets............................................................................................................ ....B-1 C Mitigation Bank State Permit Summaries with Success Criteria and Credit Release Schedules...................................................................................................................... ......C-1

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iv LIST OF TABLES Table Page 1-1 Details of the permitted wetland mitigation banks..............................................................6 2-1 Sample size of reference database for depr essional herbaceous, depressional forested, and forested stra nd and floodplain wetlands.......................................................15 2-2 Sources of ecological information from pr int media used to establish the expected reference standard wetland condition................................................................................15 2-3 Sources of ecological information from th e internet used to es tablish the expected reference standard wetland condition................................................................................16 2-4 Nonrenewable energy value assigned to land use categories used to calculate the Landscape Development In tensity (LDI) index.................................................................22 3-1 Target community and reference condition information in mitigation bank permits........25 3-2 Successes criteria for nati ve wildlife, monitoring requi rements in state permits..............27 3-3 Percent of total potential credits rele ased for each activity or release criteria...................31 3-4 Final success criteria for exotic and nuisance vegetative cover for state permits.............37 3-5 Success criteria related to native vegetati on cover and survivability of planted vegetation in state permits.................................................................................................39 3-6 Summary of regulatory complian ce for 28 wetland mitigation banks...............................48 4-1 Area of wetland mitigation banks and assessment areas included in the this study..........61 4-2 Overview of wetland assessment areas including Florida Land Use, Cover and Forms Classification System, associated wetland community type, and wetland assessment methods applied..............................................................................................63 4-3 Uniform Mitigation Assessment Method (U MAM) scores for 58 wetland assessment areas at 29 wetland mitigation banks.................................................................................67 4-4 Uniform Mitigation Assessment (UMAM) scores categorized by Florida Land Use, Cover and Forms Classification System (FLUCCS) wetland community type................69 4-5 Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas.......................................................................................................................... .........73 4-6 Wetland Rapid Assessment Procedure (WRAP) scores categorized by Florida Land Use, Cover and Forms Classification Sy stem (FLUCCS) wetland community type........75 4-7 Hydrogeomorphic wetland assessment method (HGM) variable for flats wetlands in the Everglades.............................................................................................................. ..78 4-8 Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores (Function) for six flats wetlands in the Everglades................................................79 4-9 Hydrogeomorphic wetland assessment me thod (HGM) variable for depressional wetlands in peninsular Florida...........................................................................................81 4-10 Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores (Function) for nine depressional wetlands in peninsular Florida............................82 4-11 Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for six depressional herbaceous wetlands....................................................................................................................... ......84

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v4-12 Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for three depressional forested wetlands........85 4-13 Macrophyte Florida Wetland Condition Index (FWCI) metric scores total FWCI scores, and percent of reference condition for a fore sted strand wetland within TM-Econ Mitigation Bank.................................................................................................85 4-14 Macroinvertebrate Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for two depressional herbaceous wetlands....................................................................................................................... ......87 4-15 Macroinvertebrate Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference conditio n for two depressional forested wetlands....................................................................................................................... ......87 4-16 Landscape Development Inte nsity (LDI) index scores......................................................89 4-17 Pair wise comparisons among scoring cat egories and total scores for the Uniform Mitigation Assessment Method (UMAM), We tland Rapid Assessment Procedures (WRAP), wetland scale Landscape Development Intensity (LDI) index, and bank scale LDI index................................................................................................................ ..97 4-18 Correlations among Uniform Mitigation Assessment Method (UMAM) and scoring categories, Wetland Rapid Assessment Pro cedure (WRAP) and scoring categories, wetland scale Landscape Development Intens ity (LDI) index scores, bank scale LDI index scores, Hydrogeomorphic wetland asse ssment method (HGM) functional capacity index scores, macrophyte Florida We tland Condition Index (FWCI) scores, and macroinvertebrate FWCI scores................................................................................101 4-19 Percent of reference standard conditions fo r Uniform Mitigation Assessment Method (UMAM), Wetland Rapid Assessmen t Procedure (WRAP), macrophyte Florida Wetland Condition Index (FWCI), and macroinvertebrate FWCI assessment methods for 16 wetland assessment areas.....................................................103 4-20 Percent of reference standard condi tions for Hydrogeomorphic wetland assessment method (HGM) functional capacity index sc ores for 15 wetland assessment areas........104 5-1 Credit release schedule for East Central..........................................................................114 5-2 Wetland assessment scores for two wetla nd assessment areas at East Central...............115 5-3 Success criteria for Florida Wetlandsbank......................................................................118 5-4 Wetland assessment scores for two wetland assessment areas at Florida Wetlandsbank................................................................................................................... 119 5-5 State permit credit release schedule for Sundew Mitigation Bank from SJRWMD technical report............................................................................................................... ..123 5-6 Federal permit credit release schedule from the Mitigation Bank Instrument for Sundew Mitigation Bank.................................................................................................124 5-7 Wetland assessment scores for two wetland assessment areas at Sundew Mitigation Bank...............................................................................................................1 25

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vi LIST OF FIGURES Figure Page 1-1 Location of 45 Florida wetland mitigation banks................................................................5 1-2 Florida state agency responsibility for wetland mitigation banks for currently permitted mitigation banks and land area of permitted wetland mitigation banks..............8 2-1 Location of 29 wetland mitigation banks included in this study.......................................12 2-2 Florida wetland mitigation banks permitted by year.........................................................13 3-1 Total area of permitted mitigation banks in relation to total potential credits...................29 3-2 Permit requirements from Ga rcon Peninsula Mitigation Bank..........................................33 3-3 Dense cover by the invasive exot ic species melaleuca or punktree ( Melaleuca quinquenervia ) prior to restoration activi ties at Little Pine Island....................................35 3-4 Final success criteria allowance for exotic vegetation percent cover by mitigation bank and regulating agency...............................................................................................38 4-1 Applicable range of the Everglades fl ats Hydrogeomorphic wetland assessment method (HGM) in South Florida........................................................................................58 4-2 Applicable ranges (reference domain) of depressional wetlands Hydrogeomorphic wetland assessment method (HGM) and depr essional herbaceous Florida Wetland Condition Index (FWCI) in peninsular Florida.................................................................59 4-3 Uniform Mitigation Assessment Method (UMAM) scores for the 58 assessment areas in relation to permitted lift (c redits/ac) and potential credits released (%) at respective bank............................................................................................................. ..71 4-4 Wetland Rapid Assessment Procedure (WRAP) scores for the 58 assessment areas in relation to permitted lift (c redits/ac) and potential credits released (%) at respective bank............................................................................................................. ..76 4-5 Wetland scale and bank scale Landscape Developmen t Intensity (LDI) index scores for 55 wetland assessment areas.............................................................................91 4-6 Uniform Mitigation Assessment Method (UMA M) and Wetland Rapid Assessment Procedure (WRAP) were positively correlated..............................................93 4-7 The difference between Uniform Mitigation Assessmen t Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas............................................................................................................... ..94 4-8 Linear regression between Unif orm Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas............................................................................................................... ..95 4-9 Correlations among Uniform Mitigation Assessm ent Method (UMAM) Location and Landscape Support scoring category with we tland scale and bank scale LDI index scores................................................................................................................... .....98 4-10 Wetland Rapid Assessment Procedure (W RAP) correlations with wetland scale Landscape Development In tensity (LDI) index.................................................................99 4-11 Bank scale Landscape Development Inte nsity (LDI) index score correlations...............100 4-12 Comparison among six Everglades fl ats wetlands of UMAM, WRAP, and HGM functional capacity indices...............................................................................................106

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vii4-13 Comparison among six depressional herbaceous wetlands of UMAM, WRAP, HGM functional capacity indices, macrophyte FWCI, and macroinvertebrate FWCI........................................................................................................................... .....107 4-14 Comparison among four forested wetlands of UMAM, WRAP, HGM functional capacity indices, macrophyte FWCI, and macroinvertebrate FWCI...............................108 5-1 Landscape location of East Cent ral in northeast Orange County....................................113 5-2 Landscape location of Florida Wetla ndsbank in western Broward County and surrounding land use........................................................................................................117 5-3 Landscape location of Sundew Mitigation Bank in Clay County and surrounding land use....................................................................................................................... .....122

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viii EXECUTIVE SUMMARY AN EVALUATION OF THE EFFECTIVENESS OF MITIGATION BANKING IN FLORIDA: ECOLOGICAL SUCCESS AND COMPLIAN CE WITH PERMIT CRITERIA The primary purpose of this study was to determ ine the effectiveness of mitigation banking in Florida by determining compliance with perm it success criteria, evaluating the ecological integrity of wetlands within wetland mitigation banks, and evaluating whether permit compliance reflects ecological integrity. Increasing the effectiveness of mitigation banking and improving wetland assessment methodologies should increase the capacity for long term protection and restoration of wetlands. The long term effects of this project wi ll be to improve the ecological performance of mitigation banks, management of mitigation banks, and stewardship of wetland resources to better meet the goals of the Clean Water Act. Specifically, this study used a co llection of available wetland assessment methods combined with permit and document review to determine the condition of re stored, enhance d, created, and preserved wetlands within wetland mitigation banks. Permit review involved determining stated permit success criteria and mitigation activities. Two rapid assessment methods, Uniform Mitigation Assessment Method (UMAM) and We tland Rapid Assessment Procedure (WRAP), and two field intensive assessment methods, H ydrogeomorphic approach to assessing wetland function (HGM) and Florida Wetland Condition Index (FWCI), were applied to select wetland assessment areas. A fifth assessment method, th e Landscape Development Intensity (LDI) index relies on geographic information systems (GIS) analysis. Wetland assessment techniques employed varied by wetland type, but all generally relied upon a comparison of the current wetland condition to reference standard wetland condition. Reference standard condition was defined as the c ondition of wetlands surrounded by undeveloped landscapes and without apparent human induced alterations. By designating a measure of ecosystem condition we refer to what others ha ve described as ecosystem integrity, defined by Karr and Dudley (1981) as the capability of s upporting and maintaining a balanced, integrated, adaptive community of organisms having a sp ecies composition, dive rsity, and functional organization comparable to that of the natural habitat of the region (p. 56). As of November 2006, 45 wetland mitigation banks were permitted under Section 373.4135, F.S. in Florida. Twenty-nine of the permitted wetla nd mitigation banks were visited with functional assessments conducted at 58 wetland assessment areas within those banks between May 2005 and September 2006. The 58 wetland assessment areas were categorized based on the Florida Land Use, Cover and Forms Classi fication System (FLUCCS; FDOT 1999). Both permit review and application of functional asse ssment methods were used to determine the ecological integrity of wetland assessment areas within wetland mitigation banks. Permit reviews were conducted for all 29 wetland mitigation banks visited. In ad dition to permits, annual monitoring reports and other supporting documents were used when ava ilable. Credit releas e schedules and success criteria for each wetland mitigation bank were summarized. The second part of this study involved applicat ion of five wetland assessment methods at 58 wetland assessment areas within 29 wetland miti gation banks. The wetland assessment methods

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ix were Uniform Mitigation Assessment Method (UMAM) (Ch. 62-345, F.A.C.), Wetland Rapid Assessment Procedure (WRAP) (Miller and G unsalus 1999), hydrogeomorphic approach to assessing wetland function ( HGM)(Noble et al. 2002; Noble et al. 2004), Florida Wetland Condition Index (FWCI) (Lane et al. 2003; Re iss and Brown 2005a; Reiss and Brown 2005b), and Landscape Development Intensity (LDI) index (Brown and Vivas 2005; Vivas 2007). UMAM, WRAP, and LDI index were completed at 58 wetland assessment areas. HGM (n=15) and FWCI (n=10) assessments were conducted wh en the type of wetland within the wetland assessment area matched the existing assessment methods. UMAM (0.47-0.93), WRAP (0.48-0.99), and HGM ( 0.31-1.00) assessments showed a similar range of scores (on a scale of 0-1.00, where 1.00 represents the highes t score attainable, a reflection of the reference standard conditio n). Macrophyte FWCI scores ranged from 0.21-0.88 (presented as proportion of reference standard condition). A strong po sitive correlation was found between UMAM and WRAP scores (Sp earman rank correlation r = 0.86, p < 0.001). However for any given wetland, differences from -0.15 to 0.18 between UMAM and WRAP scores were detected with onl y a single wetland assessment ar ea receiving the same UMAM and WRAP score. Across the board, neither UMAM nor WRAP provided consistently higher or lower scores and no trends were detect ed specific to wetland community type. Approximately two-thirds of th e wetland assessment areas (n = 38) had wetland scale LDI index scores less than 2.0 (where 0.0 represents no hu man development), with a mean wetland scale LDI index score of 3.21 ( = 4.87), a median of 0.25, and a high score of 16.65. Wetland scale LDI index scores were calcula ted such that all lands with in the 100 m zone surrounding a wetland assessment area designated as restoration, enhancement, creation, or preservation were assigned LDI index scores reflecting natural lands In this applicatio n, the wetland scale LDI index score was considered a tool to predict th e potential wetland condition based on the restored support landscape. Bank scale LDI index scor es, based on land use within the 100 m zone surrounding a bank, were generally higher, with a mean bank scale LDI index score of 7.78 ( = 5.36), a median of 6.53, and a range from 0.00-18.22 Overall, wetland assessment areas in banks that had achieved final permit success criteria did not receive the highest attainable sc ores for the functional assessme nt methods employed, suggesting full wetland function has not been achieved. Perm it review found that dete rmination of potential credits based on assessment methods (comm only using WRAP) generally assumed that mitigation would result in full wetland function through assigning the highest possible scores for with-mitigation scenarios. Recommendations As a result of permit review and associated assessments, eight recommendations for improving permits and/or restoration plans were developed: 1. Define natural communities and associated reference standard conditions; 2. Emphasize groundcover restoration; 3. Monitor plant and animal community structure, not just presence or cover of exotic or nuisance species; 4. Establish and implement fire management plans;

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x 5. Identify sustainability of m itigation within the landscape; 6. Allocate a higher percent of credits for achie ving success criteria and a lower percent of credits for task completion; 7. Encourage better coordination and standardiz ation among state and federal agencies and between bank managers and agency personnel; 8. Increase compliance responsibilit ies of the regulatory agencies. These suggestions are intended to facilitate improvement in th e ecological condition of wetland and upland communities within wetland mitigation banks permitted in the future. 1. Define natural communities and a ssociated reference standard conditions Defining the target reference standard condition is imperative for su ccessful restoration. In state permits, 13 bank permits described or referred to re ference conditions either as a comp arison to the literature or an actual field comparison. In contrast, 13 bank pe rmits made no mention of reference conditions in state permits. A few of the bank permits recognized the inability to restore natural communities to reference condition and instead established anticipat ed ecological lift from prebank conditions. Language comm only encountered in permits s uggested that the restoration areas would resemble a particular community type, but rarely were explanations given as to how this resemblance would be determined. Ruiz-Jaen and Ai de (2005) noted that existing laws in the United Stated do not require restoration success as defined by comparison to reference standard ecosystems, and that given financia l concerns (e.g., increased monitoring costs for monitoring reference sites as well as restoration sites) it is unlikely that such comparisons to reference sites will be required for future restora tion efforts. While somewhat dated, the Florida Natural Areas Inventory (FNAI) Guide to the Natu ral Communities of Flor ida (1990) would be a useful classification guide in permit review, as it provides a detailed de scription of each of Floridas native communities. 2. Emphasize groundcover restoration Restoration of different community types is dependent on more than replacement of canopy structure alone. Most bank permits had some basic requirement for percent cover of desirable, native species. Fourteen (of 29) bank permits included planting and/or seeding as a requirement for credit release (3 -20%, typically 5-10%), though this has not been broken dow n by canopy or groundcover specie s. However, most of the planting and credit release criteri a emphasized trees rather than groundcover species. While the canopy does influence a great deal about the community (i.e., microclimate, establishment of shade tolerant versus intolerant species, etc. ), fire management, al ong with planting and/or seeding, is necessary in many co mmunity types to ensure esta blishment and maintenance of groundcover. 3. Monitor plant and anim al community structure Most permits required minimal cover by a suite of plant species, the percent cover of a desi rable species to resemble that of a reference standard community, and/or the percent cover by e xotic or nuisance species to be less than some target percentage. However, those criteria do not fully consider the target community structure for both flora and fauna. Ten years ago Mits ch and Wilson (1996) recognized the need for linking structural measures such as species di versity, productivity, or cover, with important ecosystem functions such as wildlife use, nutri ent cycling, or organic matter accumulation. While many studies have noted the return of water storage or water quality functions at restoration sites, rarely do such wetlands provi de comparable community structure or wildlife

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xi habitat functions (e.g., Brown and Veneman 200 1, McKenna 2003, Zampella and Laidig 2003). Mitigation plans should define the target natu ral community; recognize what physical, chemical, and biological characteristics char acterize the target natural community; identify target species and/or community assemblages associated with the target natural community; ensure mitigation plans and subsequent mitigation goals actively meet the life history requirements of those target species and/or community assemblages, incl uding needs such as connectivity, reproduction, food, cover, etc.; and monitor for the occu rrence, reproductive success, and long-term maintenance of these target species and/or community assemblages to ensure mitigation goals have been met. 4. Establish and implement fire management plans Fire management is crucial to successful maintenance of many of Floridas natural commun ities (for details see FNAI 1990). While 26 of the studied banks included some fire dependent communities, only eight banks had a credit release associated with conducti ng a prescribed fire, and a few more banks required prescribed fire as part of the final release criteria. Wh ile prescribed fire was indicated for achieving successful ecosystem restoration, many barriers ar ose to prevent implementation of prescribed fire management plans. At least seven banks included in this study reported that they were behind in accomplishing their prescribed burn pl an for site specific condition, usually because the site was either too wet or too dry. Mitigation bank permits should require successful implementation of prescribed fire and community response to this management tool for credit release in fire-dependent communities. 5. Identify sustainability of mitigation within the landscape Having realistic goals as to the potential function of a wetland mitigation bank should be a priority for assessing with mitigation bank scenarios. The landscape location of compensatory mitigation projects continues to be an important consideration. The landscape of Fl orida has been cross ditched and drained with human settlement, and as such, an ideal landscape setting proba bly does not exist within the state. Forman and Deblinger (2000) suggest th at roadways and conservation areas should be separated, and yet many of the Florida wetland mitigation banks are bordered by busy roadways (e.g., Barberville Conservation Area bordered to the south SR-40; Ev erglades Mitigation Bank/Phase I (FPL) bordered to the east by Card Sound Rd. and the west by US-1) or bisected by busy roads (e.g., Tosohatchee bisected by the Beachline Expressway SR-528; Little Pine Island bisected by SR-78). Consideration of pot ential wetland functional lift should incorporate a landscape perspective. Wetland mitigation in ge neral must be considered a trade-off between temporal and spatial ecosystem function, and the bottom line comes back to having a realistic expectation of attainable function in the calculat ed with mitigation bank scenario. That is, when a bank is adjacent to developed lands, the lo cation and landscape functional component should never be expected to achieve a perfect score. Further, credits should reflect the landscape condition and be realistically base d on limitations to water budget, water quality, connectivity for fauna populations, core to edge ratios for associated species, edge effects, etc. Such concerns will vary for every bank, being based on the community types involved, the associated fauna species, bank size, and surrounding land uses. 6. Allocate a higher percent of credits for achi eving success criteria and a lower percent of credits for task completion Incremental credit release based on completion of activities that do

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xii not necessarily equate to demonstrated achieveme nt of function should be avoided. Mitsch and Wilson (1996) argued a decade ago that efforts to determine wetland restoration or creation success were flawed due to a lack of applica tion of sound wetland science and the weight of schedule-driven construction activi ties, and yet often credit releas e criteria in bank permits were based mainly on task completion. Activity-based credit re leases averaged about 50% of the total potential credits and represented the preservation and completion of the mitigation work at the bank. Although it was recognized th at the actual work was sometimes equated with ecological enhancements, mitigation success may be improved if credits releases were weighted more toward incremental improvement and community response to these treatments and actions, rather than simply completion of predetermined activities. 7. Encourage better coordinati on and standardization among the state and federal agencies and between bank managers and agency personnel In a study of compensatory wetland mitigation across the United States, ELI (2002) suggested that the differences among permits and supporting documents make comparisons difficult. This study found that was true not only between federal and state documents, but al so among documents from the four permitting agencies in Florida. In fact, simply track ing down documentation for each wetland mitigation bank proved difficult in many instances. Once fully on-line, the Regional Internet Bank Information Tracking System (RIBITS), a new inte rnet-based tracking system for United States Army Corps of Engineer (USACE) districts to monitor wetland mitigation banks, should provide a warehouse for wetland mitigation bank documentation at the federal level. A similar electronic database for tracking and storing wetland mitiga tion bank permits at the state level would be useful. However, suggestions for centralized data bases at the state level have been made in the past (e.g., Kentula et al. 1992) w ith little recent progress. All documentation leading up to permit implementation, permits themselves, pe rmit modifications, credit ledgers, and other communications relating to monitoring and manage ment should be centralized and available for review in a digital format. Fu rther, mitigation banks should submit digital copies of reports and communications to be kept in a centralized file Centralizing and tracking this documentation will make the review process more transparent and allow for better tracking of bank histories. 8. Increase compliance responsibilit ies of the regulatory agencies. While time and costs are no doubt limiting factors in the availability of ag ency personnel to condu ct frequent and thorough site visits, increasing agency ove rsight and interacti ons with bank manage rs should enhance overall compliance and achievement of final success. Requiring fre quent inspection should provide motivation for bank managers to maintain and improve ecosystem function between site visits. While no specific time schedule will m eet the needs of all banks or regulators, maintaining regular communication with banks, ev en those not requesting a credit release, is encouraged. At a minimum, no agency should release credits withou t a bank inspection of sufficient detail to confirm that monitoring re ports submitted by the banker correctly document site condition and that require d release criteria were met. Most of the wetland mitigation banks showed pot ential to provide increased wetland function following restoration, assuming completion of restor ation activities. However, for many wetland banks, landscape position is the most limiting factor to attainment of full functional. Clearly defining reference standard conditions and havi ng realistic expectati ons of the potential functional gain may lessen the potential of functional loss in we tland mitigation banks. Many of

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xiii the findings for Florida mitigation banks corrobor ate recent findings in Massachusetts (Brown and Veneman 2001), California (Ambrose et al. 2006), and Ohio (Mack and Micacchion 2006), that while most wetland mitigation banks meet permit success criteria, this does not equate to the structure and function of natural wetland communities. Basic ecol ogical principles can better dictate a more sensible way to plan, impl ement, and manage mitigation banks, with considerations including edge effects such as ro ads and towers, core to edge ratios for habitat, fragmentation and habitat loss in the landscape, and species interacti on. If these ba sic principles are overlooked, then the assumption of achievi ng function has no validity. Mitigation banks must be assessed realistically for credit potential.

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1 CHAPTER 1 INTRODUCTION Wetland mitigation banking has grown steadily in the last decade since state law and rules on mitigation banks were adopted, with 45 wetland m itigation banks currently permitted in Florida. Additionally federal mitigation policy is trending toward a preference for mitigation banks, such as the 1998 Transportati on Equity Act for the 21st Century TEA-21 Rest oration Act (Public Law 105-178) and the recent proposed rule for Co mpensatory Mitigation for Losses of Aquatic Resources (2006). While there are several st udies evaluating project-specific mitigation effectiveness (e.g. FDER 1991b; FDER 1992; Br own and Veneman 2000; Campbell et al. 2002; Morgan and Roberts 2003), few studies have been conducted on mitigation banks (though see Brown and Lant 1999; Ambrose et al. 2006; Mack and Micacchion 2006). The Florida Department of Environmental Protection (FDEP), in conjunction with the University of Floridas Howard T. Odum Center for Wetlands (UF-CF W) carried out this study to evaluate the ecological integrity of mitigation banks. This study also presents a co mparison of different wetland assessment methodologies used to evaluate the ecological integr ity of 29 banks. The study was funded through a grant from the Unite d Stated Environmental Protection Agency (USEPA) Region IV. Background For over 20 years, the federal government, through th e Clean Water Act, and the state of Florida, beginning with the Warren S. Henderson Wetla nds Protection Act of 1984, have regulated wetland impacts. Wetland permitting programs are aimed at maintaining wetland functions and values through avoidance and minimization of wetland impacts and to compensate for unavoidable impacts through wetland mitigation. In 1991, the state conducted an audit of mitigation permitting operations (FDER 1991a) and a study that assessed compliance and effectiveness of a subset of permitted mitigat ion projects (FDER 1991b). Like other reports from around the country (e.g., Roberts 1993; Race and Fonseca 1996; Brown and Veneman 2000; Robb 2002; Morgan and Roberts 2003), th ese studies found significant problems with permit compliance, permit success criteria, and/or the potential for long-term viability of the mitigation area. To address some of these issues, mitigation po licies began to authorize and encourage more consolidated mitigation projects, such as mitigation banks and regional offsite mitigation areas. In Florida, that endorsement came with the pa ssage of the Environmenta l Reorganization Act of 1993, specifically in Section 373.4135, Florida Statutes ( Mitigation banks and offsite regional mitigation ), which initially authorized the use of mitigation banks and offsite regional mitigation to offset impacts, and directed the development of mitigation bank rules. These rules were initially promulgated in 1994 and reflected in Section 373.4136, F.S. ( Establishment and operation of mitigation banks ) in 1996. Florida re presentatives worked closely with federal partners and contributed to the development of the Federal Guidance for the Establishment, Use and Operation of Mitigation Banks published in the Federal Register in November, 1995, and the subsequent Joint State/Federal Mitigation Bank Review Team Process (the Greenbook, cited as Story et al. 1998), which details how to integrate state and federal permitting for mitigation banks in Florida.

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2 In 2001, the National Research Council conducted a review of the federal mitigation program (NRC 2001). Some of the common findings were: high rates of non-compliance; inadequate permit performance and success criteria; limited long term monitoring and management; sites located poorly in landscape; inadequate agency support in compliance m onitoring, tracking, training, and research. The report also emphasized the need to avoid and minimize wetland impacts in the first place. Only when impacts to wetlands cannot be avoided should mitigation be an option. Recommendations for advancing the mitigation program included improvements in technical information requirements, reference-based succe ss criteria, long-term stewardship requirements (including conservation easements and financia l responsibility), assessment methods based on function, and consideration for long-term viability within the watershed. It was thought that mitigation banks would offer advantages in a ddressing landscape planning, financial assurance, and long-term management and t hus circumvent the problems th at were plaguing compensatory mitigation. Additionally, compliance monito ring would be facilitated. Many of the recommendations were incorporated into the federal permitting process for mitigation banks today. Mitigation Bank Regulations In Florida, mitigation banks are regulated by both federal and state agencies. Because both sets of regulatory agencies cooperate d during the development of the regulations, federal and state regulations are similar in principle components and integrally linked in others (i.e., federal agencies generally accept the st ate approved preservation and fina ncial assurance instruments). For the purposes of this study, mitigation banks and regulations will be discussed within the context of state permits, with any significant federal differences note d. This state-centric approach is taken principally because more stat ewide data and documents were available than federal ones. Additionally, as will be detailed later, the stat e has permitted about a dozen more banks than have been federally authorized (generally due to permitting delays rather than fundamental differences in review). The principle laws that regulate Floridas m itigation bank program are Florida Statute 373.4135 Mitigation banks and offsite regional mitigation and Florida Statutes 373.4136 Establishment and operation of mitigation banks Statute 373.4135 authorizes use of mitigation banks and recognizes the improved likelihood of environmenta l success associated w ith the establishment of mitigation banks, specifically favoring the restoration and enhancement of degraded ecosystems and the preservation of uplands and wetlands as intact ecosystems through restoration of ecological communities that were historically present. The criteria for establishing mitigation banks in Section 373.4136, F.S. requires that they: (a) improve ecological conditions of the regional watershed; (b) provide viable and sustai nable ecological and hydrological functions for the proposed mitigation service area; (c) be effectively managed in perpetuity;

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3 (d) prevent destructi on of areas with high ecological value; (e) achieve mitigation success; (f) be located adjacent to lands that will not adversely affect the perpetual viability; (g) meet all wetland permitting criteria; (h) have sufficient legal or equitable inte rest in the property to ensure perpetual protection and management; and (i) meet financial respon sibility requirements. Another important section in this statute defines credits as units of increased ecological value to be determined by a functional assessment method also used to determine ecological debits for wetland impacts. The statute list s factors to be considered when determining credits: the quantity and quality of the wetland and upland enhancement/restoration expected and the likelihood of achieving and main taining the target condition; the degree that management activities such as prescribed fire promote na tural ecological conditions ; the location in the landscape relative to regionally significant an d/or wildlife corridors; wetland and upland ecological and hydrological connect ions and listed species hab itat; and the degree that the property is already protecte d by land use restrictions or the potential for adverse effects if the site is not preserved. Further, this statute indicates that permits should include a sche dule for release of credits based on the performance and criteria in the permit. Factors to be considered include the type of mitigation activities (whether solely preservation or other types of mitigation), time required for those activities to be successful, and ecological va lue associated with each mitigation activity. In practice, most banks receive 10-2 5% of their total potential cr edits upon preservation (usually through a recorded conservation ea sement) and the provision of th e required financial assurance (usually performance bonds or letter of credit payable in to a standby trust) for the implementation and long-term management of th e plan. Additional credits are released for specific mitigation activities such as physical cons truction (e.g., ditch filling, road removal, etc.), exotic species removal, and/or planting. Furthe r incremental credit release is based on regular monitoring and documentation of trending toward su ccess culminating in a determination of final success. Statute 373.4136 also establishes guidelines for the determination of the Mitigation Service Area (MSA) based on regional watersheds. Finally, it allows for the FDEP and state Water Management Districts (WMDs) to establish mo re specific rules, especially pertaining to preservation, financial assurance, and cred it assessment methods. FDEP adopted and administers the mitigation bank rule, Chapter 62342, Florida Administrative Code (F.A.C.), and three of the five WMDs (South Florida Wa ter Management District, SFWMD; Southwest Florida Water Management District, SWFWMD ; and St. Johns River Water Management District, SJRWMD) also adopted and administer similar rules within th eir jurisdiction. Which agency issues a state mitigation bank permit depends on the location and intended use of the bank, as determined through operating agreements between the agencies. In addition to the statutory requirements, the mitigation banking rules provide increased guidance on intent, definitions, details on the required component s of a permit, credit assessment and release, and specifics on th e instruments for preservation a nd for financial assurance. However, the mitigation banking rules do not sp ecify the functional assessment method to be

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4 used. As a result, mitigation banks have been assessed by several function and ratio-based methods. A standard, function-based method for de bit and credit assessmen t for both mitigation banks and all other forms of compensatory mitig ation, called the Uniform Mitigation Assessment Method (UMAM), went into effect in February 2004 under Rule 62-345, F.A.C. It is now used throughout the state on all projec ts requiring mitigation. Mitigation banks permitted prior to 2004 were grandfathered to contin ue to use their original a ssessment method, but a few have chosen to convert to UMAM. Federal Coordination The Federal Guidance for the Establishment, Use and Operation of Mitigation Banks (1995) was issued jointly by the United States Army Corp s of Engineers (Corps), the United States Environmental Protection Agency (USEPA), th e Fish and Wildlife Service (FWS), and, as programmatically appropriate, the Natural Resource Conservation Service (NRCS) and the National Marine Fisheries Service (NMFS). Evaluation of a proposed mitigation bank is undertaken by an interage ncy Mitigation Bank Review Team (M BRT) with federa l authorization of a mitigation bank determined through a binding Mitigation Banking Instrument (MBI) that is signed by both the MBRT members and the banker. The MBI details the establishment, use and operational requirements of the mitigation bank, but dredge and fill operations associated with restoration activities, such as grading, ditch fillin g, installation of water control structures, etc., may require a separate 404 permit. An important difference between state and federa l permitting review is that once a formal permit application is received, the st ate is bound by statutory time cl ocks for review, information requests, and approval while the fe deral agencies are not. While the state and federal guidelines and goals are similar, programmatic and procedural differences can lead to disparate approvals. The development of the Greenbook (Story et al. 1998) was an attempt to minimize duplicate review. It provides for the stat e permit reviewer to co-chair th e MBRT with the Corps. It establishes a pre-application prot ocol that involves a preliminary prospectus and determination of appropriateness. It stipulates a method of determining credits through ratios, Wetland Rapid Assessment Method (WRAP), or variations th ereof. Additionally, it provides guidance indicating that the state permit application not be submitted until significant issues such as the mitigation plan, credit assessment, and MSA, have consensus agreement. However, the Greenbook is not binding on the state, the Corps, or the banker, so adhere nce to the provisions varies. Even when there is consensus on the ma jor components, the final development of details and the permit under the states time clock gene rally precedes that of the federal MBI. Therefore, differences in the final authorizations are common, but typically minor. This project has focused its review on state permits and require ments, but extends to federal requirements as well due to the similarities in state permits and federal MBIs. Florida Wetland Mitigation Banks The 45 state permitted wetland mitigation banks, which are in different stages of project development, served as the initial sample pool fo r this project (Figure 1-1). Table 1-1 lists the banks by name, permitting agency, permit number, permit issue date, bank size, potential credits, type of wetland credits available, and locatio n (county(ies)). Two of the wetland mitigation

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5 Figure 1-1. Location of 45 Flor ida wetland mitigation banks. Wetland mitigation banks included in this study represented by blue circles ( ); wetland mitigation banks not included in this study represented by red squares (). Background is 8-digit Hydrologic Cataloguing Units (HUC) of Florida from the Flor ida Department of Environmental Protection (available at http://www.fgdl.org cover map WATERSHED). banks have received permits for additional phases, Boran Ranch and Everglades Mitigation Bank (FPL), and as such, each phase (permit) is list ed separately. Currentl y, SJRWMD has issued the most wetland mitigation bank permits with 16, fo llowed closely by FDEP with 14 (Figure 1-2A). The remaining 15 mitigation banks were perm itted through SFWMD (n = 9) and SWFWMD (n = 6). When considering land area covered by wetland mitigation, SJRWMD is responsible for 50% of total area in wetland mitigation banks with 23,654 ha (58,448 ac) (Figure 1-2B). FDEP is responsible for over one-third of the area with 17,832 ha (44,061 ac) permitted. SWFWMD (11%) and SFWMD (2%) are responsible for just 5,494 ha (13,576 ac) and 1,195 ha (2,952 ac) of wetland mitigation banks, respectively. Definition of Success This research has set out to determine th e success of wetland mitigation banking through a review of permit compliance and an evaluation of the ecological integrity of wetlands using a variety of wetland assessment techniques. Perm it assessment involved determining if stated permit success criteria and compliance with those standards would reflect ecological integrity.

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Table 1-1. Details of the perm itted wetland mitigation banks. Twenty-nine wetland mitigation banks were included in this study(*). Both Boran Ranch and Everglades Mitigation Bank (FPL) were permitted in two phases and thus both are listed twice (o nce for each permit). Mitigation Bank Public Land State Agency MBI+ Issue Date Hectares Acreage Potential Credits Released Credits Used Credits Released (%) Barberville* Y SJRWMD No 6/1/1996 148 366 84.30 54.20 35.10 64 Bear Point* Y FDEP Yes 7/25/2003 128 317 49.80 25.00 3.70 50 Big Cypress* N SFWMD Yes 9/9/1999 518 1,280 1,001.78 559.20 246.23 56 Bluefield Ranch* N SFWMD Yes 11/15/2001 1,091 2,695 1,240.00 558.14 135.62 45 Boran Ranch, Phase I* N SWFWMD Yes 8/26/1997 96 237 108.59 100.78 98 92 Boran Ranch, Phase II N SWFWMD Yes Unknown 69 170 102.53 16.99 5.20 17 Braden River N SWFWMD No Unknown 141 349 71.69 0.00 0.00 0 Breakfast Point N FDEP Yes 10/11/2004 1,877 4,637 1,051.66 76.29 21.36 7 CGW* N SJRWMD Yes 6/10/1998 61 150 63.10 50.50 46.20 80 Clear Springs N SWFWMD No 10/28/2003 473 1,168 438.00 0.00 0.00 0 Colbert-Cameron* N SJRWMD Yes 10/28/1996 1,054 2,604 718.80 560.30 354.60 78 Corkscrew* N FDEP Yes 6/4/2004 257 635 351.80 0.00 0.00 0 Devils Swamp N FDEP Yes 10/11/2004 1,234 3,049 586.80 0.00 0.00 0 East Central* N SJRWMD Yes May-97 385 952 286.30 286.30 176.70 100 Everglades Mitigation Bank/Phase I* N FDEP Yes 10/1/1996 1,669 4,125 424.50 382.00 290.69 90 Everglades Mitigation Bank/Phase II* N FDEP unknown 10/16/2003 3,653 9,026 1,769.53 184.60 80.64 10 Farmton N SJRWMD Yes 4/11/2000 9,681 23,922 4,585.20 664.50 588.40 14 Florida Mitigation Bank* N FDEP Yes 5/28/1997 640 1,582 847.50 847.50 729.80 100 Florida Wetlandsbank* Y SFWMD Yes 2/9/1995 170 420 370.00 367.37 367.37 99 Garcon Peninsula* N FDEP Yes 4/12/2001 136 337 172.39 77.40 7.27 45 Graham Swamp* N FDEP Yes 9/5/1996 27 66 32.50 29.25 5.50 90 Hole in the Donut* Y FDEP ** 2/15/1995 2,529 6,250 6,250.00 2,111.37 2,111.37 34 Lake Louisa and Green Swamp* N SJRWMD Yes 10/10/1995 408 1,007 297.90 245.60 212.14 82 Lake Monroe* Y SJRWMD Yes 9/12/1995 244 603 199.90 130.00 110.90 65 Little Pine Island* Y FDEP Yes 2/6/1996 633 1,565 807.00 279.40 161.09 35 Loblolly Mitigation Bank* N SJRWMD Yes 9/9/2003 2,528 6,247 2,034.00 508.58 315.52 25 Longleaf Mitigation Bank N SJRWMD Yes 3/31/2004 1,223 3,021 813.80 105.54 20.34 13 Loxahatchee* N FDEP Yes 2/18/2000 512 1,264 641.60 320.80 221.58 50 Mary A Ranch N SJRWMD No 11/12/2002 837 2,069 1,252.80 302.90 154.47 24

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Table 1-1. Continued. Mitigation Bank Public Land State Agency MBI+ Issue Date Hectares Acreage Potential Credits Released Credits Used Credits Released (%) Myakka River N SWFWMD No 6/29/2004 154 380 224.60 38.20 9.09 17 Northeast Florida N SJRWMD Yes 9/5/1997 315 779 407.30 400.00 375.00 98 Panther Island* N SFWMD Yes 3/11/1999 1,128 2,788 934.64 799.24 588.72 86 Peace River N SWFWMD No Unknow n 197 487 137. 82 0.00 0.00 0 Platt's Creek N SFWMD No 4/10/2003 33 82 69.51 0.00 0.00 0 Port Orange N SJRWMD No 1/13/2004 2,314 5,719 1,176.30 237.90 73.00 20 R.G. Reserve* N SFWMD No 1/9/2003 258 638 32.48 2.55 1.20 8 Reedy Creek* N SFWMD Yes 2/13/1997 1,211 2,993 908.90 563.35 419.39 62 San Pedro Bay Mitigation Bank N FDEP Yes 2/13/2002 2,731 6,748 1,083.00 170.80 6.02 16 Sand Hill Lakes Mitigation Bank N FDEP Yes 8/5/2005 872 2,155 298.40 104.40 0.00 35 Split Oak* Y SFWMD unknown 6/13/1996 425 1,049 206.50 88.80 88.80 43 Sundew Mitigation Bank* N SJRWMD Yes 8/11/2001 853 2,107 698.30 194.20 101.54 28 Tampa Bay N SWFWMD No 9/25/2002 65 161 111.55 0.00 0.00 0 TM-Econ* N SJRWMD Yes 1/8/2003 2,104 5,199 1,568.60 227.97 150.31 15 Tosohatchee* Y SJRWMD Yes Unknown 531 1,312 185.00 185.00 152.90 100 Treasure Coast N SFWMD No 3/9/2005 1,030 2,545 1,033.43 0.00 0.00 0 Tupelo Mitigation Bank* N SJRWMD Yes 1/23/2004 617 1,525 459.70 144.85 144.52 32 Wekiva River Mitigation Bank N FDEP No 6/1/2005 665 1,643 390.12 97.53 7.06 25 *Wetland mitigation bank included in this study + Federal Mitigation Banking Instrument (MBI) ** Has federal approval in the form of an in lieu fee type ag reement; state permit also more closely resembles an in-lieu-fee arrangement Information from: Florida Department of Environmental Protection, October 2006

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8 (A) Distribution of Wetland Mitigation Banks by State AgencySJRWMD, 16, 36% FDEP, 14, 31% SFWMD, 9, 20% SWFWMD, 6, 13% (B) Land Area in Wetland Mitigation Banks by State Agency SFWMD, 5,494 ha, 11% FDEP, 17,832 ha, 37% SJRWMD, 23,654 ha, 50% SWFWMD, 1,195 ha, 2% Figure 1-2. Florida state agency responsib ility for wetland mitigation banks for A) currently permitted mitigation banks and B) land area of permitted wetland mitigation banks. State agencies are St. Johns River Water Management District (SJRWMD), Florida Department of Environmental Protection (FDEP) South Florida Water Management District (SFWMD), and Southwest Florida Wate r Management District (SWFWMD).

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9 The wetland assessment techniques employed vari ed by wetland type, but all generally relied upon the comparison of the current wetland conditi on to wetland reference standard condition. Because mitigation is meant to offset functi on lost from wetland impact activities, ideally mitigation bank success would be measured by a direct comparison of functions lost at impact sites to functions gained at the mitigation site. However, this was not feasible as part of this study, as the permitted impact sites no longer exis t in their pre-impact condition and therefore could not be studied in the same way as the m itigation bank sites. Therefore, in this study, success was evaluated using the mitigation bank permits and mitigation bank study sites alone. Permit success is defined by demonstration of ac hievement of permit success criteria. Within a given permit, achievement of specific performan ce standards or release criteria determines awarding of some proportion of total potential wetland credits. For instance, an initial credit release generally requires legal activities such as recording a conservation easement and assertion of financial assurance. Credit release criteria can also include physical activities such as earth moving, ditch plugging, a nd land grading, exotic or nuis ance species removal, and planting desirable species. In terim and final success is often defined by achieving a specified percent cover of desired vegetation or resemblance of the mitigation wetland to a natural community. The definition of success based on ecological integrity can be defined by achieving specific scores by various functional assessment methods. In this case, success is defined by the quantitative comparison of a mitigation wetland to a reference standard wetland. Only 14% of the banks studied included perm it criteria based directly on the achievement of some functional assessment index score (e.g., a 1.00 Wetland Rapi d Assessment Procedure (WRAP) score). Merging these two definitions of success proves challenging as each is based on different assumptions. First, the definition of succes s for permitting relies on the assumption that completion of particular activitie s (e.g., ditch plugging, exotic specie s removal, etc.) in fulfilling permit compliance will result in functional gain and therefore provides successful mitigation. Complicating this assessment is the fact that the release of credits is generally incremental, based on activities such as site preservation, ditch fi ll, and cattle removal. On the other hand, the definition of success for ecological integrity is based on a comparison against the reference standard wetland condition. Purpose of Study The primary purpose of this study was to determ ine the effectiveness of mitigation banking in Florida by determining compliance with perm it success criteria, evaluating the ecological integrity of wetlands within wetland mitigation banks, and evaluating whether permit compliance reflects ecological integrity. Increasing the effectiveness of mitigation banking and improving wetland assessment methodologies should increase the capacity for long term protection and restoration of wetlands. The long te rm effects of this project will be to improve the ecological performance of mitigation banks, management of mitigation banks, and stewardship of wetland resources to better meet the goals of the Clean Water Act.

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10 Specifically, this study used a co llection of available wetland assessment methods combined with permit and document review to determine the condition of re stored, enhance d, created, and preserved wetlands within wetland mitigation ba nks. Two rapid assessment methods, Uniform Mitigation Assessment Method (UMAM) and We tland Rapid Assessment Procedure (WRAP), and two field intensive assessment methods, H ydrogeomorphic approach to assessing wetland function (HGM) and Florida Wetland Condition Index (FWCI), were applied to select wetland assessment areas. A fifth assessment method, th e Landscape Development Intensity (LDI) index relies on geographic information systems analysis. This document is designed to present a summar y of findings and synthesis of the permit and document review and field assessments. Ch apter 2 Methods provides an overview of the location of Florida wetland mitigation banks, s ite visit protocol, procedures of permit and document review, and determination of reference standard condition. A de tailed description of the field standard operating pro cedures can be found in Appendix A. Presentation of results from the permit and document review and field su rveys are found in Chapter 3 Review of Permit Success Criteria and Credit Release and Chap ter 4 Determination of Ecological Integrity, respectively. A presentation of field data sh eets and a summary of permit review for each wetland mitigation bank can be found in Appendi x B and Appendix C, respectively. Chapter 5 Permit Review and Ecological Integrity synthesi zes findings from permit and document review and field assessments by presenting case studies of three wetland mitigation banks. Chapter 6 Discussion reviews major findings and recommenda tions and addresses the effectiveness of wetland mitigation banking in developing and maintaining wetlands with high ecological integrity.

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11 CHAPTER 2 METHODS The primary goal of this project was to determ ine the effectiveness of mitigation banking in Florida using permit and documentation review, field assessment, and geographic information systems (GIS). Twenty-nine wetland mitigati on banks were included in this study, with quantitative, standardized assessment methods used to determine the ecological integrity of 58 smaller wetland assessment areas within the 29 ba nks. The availability of permits and other documents associated with wetland mitigation banks varied greatly. In general, supporting documentation gathered included permits, staff re ports, monitoring reports, management plans, and/or site visit summaries, which were summari zed to include credit pot ential, credit release schedules, and success criteria for each bank. Field assessments were conducted on select wetland assessment areas within the banks, but rare ly covered the entire bank area. While some banks were relatively small in area and homogene ous in wetland community type, many covered large areas and contained a variety of wetla nd community types. The number of wetland assessment areas selected depended on a combin ation of site-specific conditions such as homogeneity of wetland community types, mitigat ion activities completed to date and progress towards success criteria, area of wetland, type of mitigation (i.e., restoration, creation, enhancement, or preservation), and general si te conditions. Two rapid assessment methods, Uniform Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP), were used at all 58 wetland assessment areas, as was the Landscape Development Intensity (LDI) index, a GIS based assessment t ool. When the wetland assessment area matched the communities with developed standard guidebooks for the Hydrogeomorphic wetland classification (HGM) and/or the Florida Wetland Condition Index (FWCI), these methods were also completed. This chapter pr esents background information on the assessment sites, permit and document review procedures, reference standard condition, and field site visits procedures. Mitigation Bank Locations Twenty-nine of the 45 permitted mitigation banks were included in this study. Banks were located throughout the four Florida wetland regi ons (Lane 2000), though only a single wetland mitigation bank, Garcon Peninsula, was located in the panhandle wetland region (Figure 2-1). Just over half of the study mitigation banks (n = 15) were within the central wetland region, with 10 in the south wetland region, an d three in the north wetland regi on. Site selection criteria included length of time since permit issue, progress towards mitigation activities, and land owner or manager cooperation for site access. For the purposes of this study, the two phases of Everglades Mitigation Bank were considered as sepa rate banks, as Phase I is nearing final credit release with 90% of credits awarded, and Phase II has limite d credit release at 10%. All of the wetland mitigation banks permitted befo re 2001 were visited, with the exception of two banks where field access was denied (Figure 2-2). In addition, banks permitted as recently at 2004 were also part of this study. The re maining mitigation banks either had no credits released to date and/or were lacking their federa l MBIs. The four oldest banks included in this study were Florida Wetlandsbank (permit issue date February 9, 1995), Hole in the Donut (February 15, 1995), Lake Monroe (September 12, 1995), and Lake Louisa and Green Swamp

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12 Figure 2-1. Location of 29 wetland mitiga tion banks included in this study. Wetland region boundaries according to Lane (2000). (October 10, 1995). The two most recently perm itted banks included Tupelo Mitigation Bank (January 23, 2004) and Corkscrew (June 4, 2004). Mean bank size was 826 ha (2,040 ac) ( = 887 ha; 2,192 ac), ranging from 27 ha (66 ac) at Graham Swamp to 3,653 ha (9,026 ac) at Everglad es Mitigation Bank/Phas e II. Twenty-seven of the 29 banks had freshwater wetlands. Three of these mitigation banks had both freshwater and saltwater wetlands, and the remaining two banks had salt marsh or/or mangrove wetlands. The range in potential credits was large, from 32.5 potential credits at Graham Swamp to 6,250 potential credits at Hole in the Donut. The medi an was 425 potential credits. It is important to mention that Hole in the Donut operates under a permit that more closely resembles an in-lieufee agreement. Funds for restora tion activities are collected at th e time of impact permit issuance until there is sufficient money to complete a portion of the requi red restoration. Thus, initially, impacts occur prior to mitigation. However, wh ile there is a potential of 2,529 ha (6,250 ac) to restore at Hole in the Donut, work is being conducted incrementally, as financial resources allow, and is currently ahead in initial restoration area relative to impact area. Progress towards mitigation success within a bank can be measured based on potential credits released. The wetland mitigation banks studied ranged from no credits released at Corkscrew to

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13 0 2 4 6 81995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005Year of Permit IssueNumber of Wetland Mitigation Banks Included in Study Not Included in Study Figure 2-2. Florida wetland mitiga tion banks permitted by year. 100% of the potential credits released at three wetland mitigation banks: East Central, Florida Mitigation Bank, and Tosohatchee. Permit Review Procedures Permit review involved determining compliance with permit criteria. Acquisition of complete documentation for each wetland mitigation bank proved difficult. Many of the initial permits and technical reports were only available in dr aft forms, and few permit modifications were acquired. State permits were obtained for all 29 banks, with monitoring reports available for 18 banks. Details of permit compliance were based on phone interviews with appropriate personnel from Florida Department of Environmenta l Protection (FDEP), South Florida Water Management District (SFWMD), Southwest Fl orida Water Management District (SWFWMD), or St. Johns River Water Manage ment District (SJRWM D). Differences in compliance tracking occurs among agencies, with FDEP and SJRW MD having the same individual following the initial permit process and implementation as well as keeping track of compliance. Conversely, SFWMD and SWFWMD have different individuals responsible for the compliance portion of wetland mitigation banks. If credit or permit m odifications are needed, they refer back to the individual responsible fo r implementing the permit.

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14 Reference Standard Condition In order to complete field assessments, it was necessary to determine the reference standard condition of the wetland community type for each assessment area. Different information was available depending on the wetland community t ype. We used a database of depressional herbaceous (n=75; Lane et al. 2003), depressiona l forested (n=118; Reiss and Brown 2005a), and forested strand and floodplain wetlands (n=24; Reiss and Brown 2005b) to develop a baseline understanding of the condition of Florida wetlands Species lists for diatom, macrophyte, and macroinvertebrate community assemblages, as well as physical and chemical soil and water parameters were available (Table 2-1). Other sources of descriptive information were consulted to determine reference conditions (Tables 2-2, 2-3), particularly wh en detailed community data were not available from the studies listed above. While internet sources were c onsulted (Table 2-3), s ite content had been distributed by reputable sources such as the Cornell Lab of Orn ithology, Florida Department of Environmental Protection, Florida Department of Natural Resources, Florida Fish and Wildlife Conservation Commission, Florid a Natural Areas Inventory, Un ited States Geological Survey, and University of Florida (Institute of Food and Agricultural Sciences). Site Visits Procedure Prior to a site visit, recent digital orthographic qua rter quads were acquired from The Land Boundary Information System from FDEP (available at http://www.labins.org ), and the statewide data layer showing boundaries of Flor ida wetland mitigation banks from the Florida Geographic Data Library (available at http://www.fgdl.org/ ) were overlain in ArcView GIS 3.2 (Environmental Systems Research Institute, Inc. 1999). Ecological communities within the wetland mitigation bank boundaries we re identified and potential we tland assessment areas were documented. Background reference data were compiled for select ecological communities and Part 1 of UMAM Qualitative Description (Ch. 62345, F.A.C) was initiated prior to site visits. Most site visits began with a meeting with th e land manager and/or bank owner followed by an overview tour of the site. However, each site visit was different based on the particular circumstances regarding each bank. Some of the m eetings were conducted off-site and site visits were not always conducted with the land manager and/or owner present. Once an overview of the wetland mitigation bank was provided, wetland assessment areas were selected based on the amount of mitigation wo rk completed to date, current water level conditions, and accessibility. Wh en practical, selection of wetla nd assessment ar eas targeted phases that already had credits released. Di gital orthographic quarter quads or other map resources were used to determine the wetland boundary of each assessment area. The two to three member field crew proceeded to walk a por tion of the wetland boundary and interior with sample effort regulated by homogeneity of s ite conditions, accessibility, and time and weather constraints. Miller and Gunsalus (1999) suggest that a minimum of 50% of the wetland boundary is traversed and 100% of the boundary is visually insp ected when using WRAP; this guidance was also used for field assessments usi ng UMAM. During the site visit, notes were

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15 Table 2-1. Sample size of reference database for depressional herbaceous, depressional forested, and forested strand and floodplain wetlands Data from Lane et al. (2003), Reiss and Brown (2005a), and Reiss a nd Brown (2005b), respectively. Depressional Herbaceous Depressional Forested Forested Strand and Floodplain Diatom Community 70 50 x Macrophyte Community 75 118 24 Macroinvertebrate Community 75 79 x Soil Analysis 75 118 x Water Analysis 75 75 x Table 2-2. Sources of ecological information from print media used to establish the expected reference standa rd wetland condition. Source Description Bardi, EB, MT Brown, KC Reiss, and MJ Cohen (2005) UMAM Training Manual: Web-based training manual for Chapter 62-345, FAC for wetlands permitting. Available at: http://www.dep.state.fl.us/labs/library/index.htm Provides guidance on completing the Uniform Mitigation Assessment Method Part I and Part II forms, including Wetland Field Guides providing information on predominant vegetation and wildlife, landscape location, fire interval, hydrology, and functions for 23 wetland communities. Mitsch, WJ and JG Gosselink. 1993. Wetlands, 2nd edition. John Wiley and Sons, Inc. New York, New York, USA. Provides an overview of wetlands ecology with sections dedicated to individual wetland types describing wildlife, hydrology, plant composition, and fire frequency. Myers, RL, and JJ Ewel, editors. 1990. Ecosystems of Florida. University of Central Florida Press, Orlando, Florida, USA. Provides an overview of Floridas ecological communities. Includes information on upland and wetland communities. Noble, CV, R Evans, M McGuire, K Trott, M Davis, and EJ Clairain, Jr. 2002. A regional guidebook for applying the hydrogeomorphic appro ach to assessing wetland functions of flats wetlands in the Everglades. Wetlands Research Program, Engineer Research and Development Center, US Army Corps of Engineers, Washington, D.C. ERDC/EL TR-02-19 Provides reference data for Everglades flats wetlands, including rocky flats, marl flats, and organic flats. Reference conditions pr ovided for surface soil texture, soil thickness, microtopographic features, woody vegetation cover, periphyton cover, emergent macrophytic vegetation cover, plant species composition, native species richness, invasive vegetation cover, wetland tract area, interior core area, and habitat connections. Noble, CV, R Evans, M McGuire, K Trott, M Davis, and EJ Clairain, Jr. 2004. A regional guidebook for applying the hydrogeomorphic appro ach to assessing wetland functions of depressional wetlands in peninsular Florida. Wetlands Research Program, Engineer Research and Development Center, US Army Corps of Engineers, Washington, D.C. ERDC/EL TR-04-3 Provides reference data for depressional wetlands including herbaceous marshes and cypress domes. Reference conditions provided for wetland volume, catchment size, upland land use, surface outlet, cypress canopy, subsurface outlet, surface soil texture, macrophytic vegetation cover, understory vegetation biomass, tree basal area, herbaceous plant species composition, number of wetland zones, wetland proximity, and tree species composition. Soil Conservation Service. 1984. 26 Ecological Communities of Florida. United States Department of Agriculture, Washington, D.C., USA. Provides descriptions of 26 ecological communities in Florida, including characteristic vegetation.

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Table 2-3. Sources of ecological information from the internet used to establish the expected reference standard wetland condition. Source Description Atlas of Florida Vascular Plants http://www.plantatlas.usf.edu/default.asp Scientific and common name, exotic/native status, wetland status, and sometimes images of Florida plant species and range maps. The Birds of North America Online http://bna.birds.cornell.edu/BNA/ Information on bird species, including range maps, distinguishing characteristics, distribution, habitat, food sources, behavior, breeding, demography and populations, conservation and management, appearance, and measurements. Florida Delineation Program Field Guides http://www.dep.state.fl.us /water/wetlands/delineation/wetcomm/fieldguides.htm Drawings of common species for algae and flowering plants, central Florida floodplain forests, north Florida floodplain forests, mangroves, north and central Florida salt marsh, and south and central Florida salt marsh. Florida Delineation Program Vegetative Index (Plant List) from Chapter 62-340, F.A.C. (subsection 62-340.200(17), F.A.C.) http://www.dep.state.fl.us /water/wetlands/delineation/vegindex/vegindex.htm Lists of native Florida plant species identified as facultative, facultative wet, and obligate species. Florida Delineation Program Wetland Communities http://www.dep.state.fl.us /water/wetlands/delineation/wetcomm/wetcomm.htm List and brief description of comm on plant communities for each of seven districts (NW, NE, central, SW, SE, S, and Florida Keys). More detailed descriptions and photos provided for some communities as well as common plant associates and community range. End of the Road: The Adverse Ecological Impacts of Roads and Logging: A Compilation of Independently Reviewed Research http://www.nrdc.org/land/f orests/roads/eotrinx.asp Annotated bibliography of information pulled mainly from peer-reviewed journals pertaining to adverse impacts of roads on North American forests. Published by the Natural Resource Defense Council (1999). Endangered Species in Florida http://www.endangeredspecie.com/states/fl.htm State listed threatened and endangered pl ant and animal species for Florida. Environmental Resource Analysis from the FDEP http://eraonline.dep.state.fl.us/ *NOTE* This website is scheduled to be retired be FDEP in the near future, and replaced by Water Data Central, available at: http://www.dep.state.fl. us/water/datacentral/ Interactive mapping interface providing geographical data and information relating to local roads, soils, Outstanding Florida Waters (aquatic preserves and special waters), conservation land s (federal, state, local, and private areas), city limits, and aerial photograp hy. Also includes the ability to draw a 1 mile buffer around a given analysis point with summary information for permit application, jurisdictional bo undaries, water resources, fish and wildlife resources, habitats, and mitigation and restoration opportunities. Exotic Freshwater Fishes http://floridafisheries.com/fishes/non-native.html Provides a description of 32 known introduced fish species currently reproducing in Florida waters. Includes common and scientific name, description, range, habitat, spawning habitat, feeding habitat, age and growth, sporting quality, edibility, state and world records, and drawing/sketch.

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Table 2-3. Continued. Source Description Florida Fish and Wildlife Conservation Commission. 2004. Floridas Imperiled Species. http://myfwc.com/imperiledspecies/ Lists Floridas imperiled species, incl uding endangered species, threatened species, and species of special concern. Florida Natural Areas Inventory and Department of Natural Resources. 1990. Guide to Natural Communities of Florida. http://www.fnai.org/PDF/Natu ral_Communities_Guide.pdf Provides descriptions of natural eco logical communities in Florida. Includes information on characteristic plant and animal species, hydrology, fire frequency, and associated communities. Florida Wetland Restoration Information Center http://www.dep.state.fl. us/water/wetlands/fwric Information on wetland and associated up land restoration; includes links to the Florida Ecological Restoration Inventory (descriptions of current and proposed restoration projects), restoration guidance (background on restoration with case studies), restoratio n library (links and bibliographies). Frogs and Toads of Florida http://www.wec.ufl.edu/extension/wildlif e_info/frogstoads/image_index.php *NOTE* This is not a permanent URL, search University of Florida List and pictorial index of the 33 frogs and toads of Florida. A description of each species includes photos, distribution, habitat, size, reproduction, color, and call information. Many entries include an audio clip of the call. Online Guide to the Snakes of Florida http://www.flmnh.ufl.edu/herpetol ogy/FL-GUIDE/onlineguide.htm Key to snake identification, list of Florida snakes, color patterns, and habitat descriptions. Provides photos, scientific name, description, sketches, range, and habitat information for each species as well as comments on behavior, location, food, reproduction, and a comparison with other species. Plant Species Introduced in Florida http://www.flmnh.ufl.edu/herbarium/ cat/imagesearch.asp?srchproject=IN Scientific and common names for plant species as well as scanned herbarium specimen images from the University of Florida herbarium. Tables of Florida Natural Communities Descriptions available for download http://www.dep.state.fl.us/water /wetlands/fwric/guidance.htm Tabular information on dominant vegetative strata, ecosystem formation, typical vegetation, typical animals, soils, hydroperiod, fire regime, typical surrounding habitat, similar habitats, threats and importance. Tadpoles of the Southeastern United States Coastal Plain from the USGS http://cars.er.usgs.gov/armi/Guide_to_Tadpoles/guide_to_tadpoles.html Information useful for identification of tadpoles with photos of the adult and tadpoles plus information on habitat, breeding season, similar tadpoles, appearance, and approximate maximum size. U.S. Fish and Wildlife Service Species Accounts http://www.fws.gov/northflorida/S pecies-Accounts/SpeciesInfo.htm List of federally listed endangered, threatened, and species of special concern by region for mammals, birds, reptiles, amphibians, fish, crustaceans, clams, arthropods, insects, and plants. Lists are also available by county. Links are available for further detailed information on family, status, description, range and population level, habitat, biological information, reason for current status, management and protection, and references. What Bird: The Ultimate Bird Guide http://www.whatbird.com/ General species information as well as background on range and habitat with range maps. Shows images of species and often provides audio clips of bird calls.

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18 taken on general site conditions including iden tified flora, observed wildlife (e.g., visual sightings, calls), evidence of wildlife (e.g., tracks, nests), and occurrence of listed species. Once notes were completed for WRAP and UMAM rapid assessment met hods, transects and/or quadrats were established for HGM and/or FW CI, depending on methods specific to those assessment techniques. While UMAM and WRAP were completed for each of the 58 wetland assessment areas, the more inte nsive sampling methods, HGM and FWCI, were only completed for Everglades flats (Noble et al. 2002) or de pressional wetlands (Nobl e et al. 2004) for HGM and depressional herbaceous (Lan e et al. 2003), depressional fo rested (Reiss and Brown 2005a), or forested strand and floodplain (Reiss and Br own 2005b) wetlands for FWCI. After returning from the field, a digital boundary of the wetlan d assessment area was drawn over the digital orthographic quarter quad and the wetland scale LDI index was calculated for each wetland assessment area using GIS. The bank scale LD I index value was also calculated around the boundary of the entire bank. A brief descripti on of each field assessment method follows. Further details of methods for each assessm ent method including UMAM, WRAP, HGM, FWCI, and LDI, are available in Appendix A. Uniform Mitigation Assessment Method (UMAM) UMAM is defined in Rule Chapter 62-345, F.A.C. A complete UMAM survey includes Part I Qualitative Description and Part II Quantificati on of Assessment Area. Part I Qualitative Description establishes a reference baseline for expected site functions and considers connectivity, regional significance, and anticipated wildlife. Part II Quantification of Assessment Area requires completion at the field si te with scoring assigned in each of the three indicators of wetland function: Location a nd Landscape Support, Water Environment, and Community Structure. Part II Quantification of Assessment Area scor es are based on evidence within the wetland community and the surrounding lands cape, using reasonable scientific judgment. UMAM relies on an adequate understanding of the functio ns of and species found throughout Florida ecosystems to provide a score describing the func tional capacity of a wetland. Within each of the three indicators of wetland function, the UMAM scale range s from 0-10, with only whole numbers assigned. A score of 10 suggests the wetland assessment area reflects the expected wetland function at an optimal level. Altern atively, a score of zero means that no wetland function is being provided. Gu idance is provided within the ru le (Chapter 62-345, F.A.C.) for scores of 10, 7, 4, and 0. Once each of the three categories have been scored, the values are summed and divided by 30 to achieve a to tal UMAM score betw een 0.00-1.00, with 1.00 representing optimal wetland function. Assessmen ts for this study were conducted as current condition scenarios. UMAM has additional a pplication for scenario s withand withoutmitigation, time lag, and risk. A UMAM current condition assessment was conducted at all 58 wetland assessment areas within the 29 banks. Wetland Rapid Assessment Procedure (WRAP) WRAP methodologies are define d by Miller and Gunsalus (1999) for use in evaluation of restored, created, enhanced, and preserved wetland mitigation sites. WRAP was created for use

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19 in freshwater, non-tidal wetlands in South Florida, but is often applied statewid e and has even been applied outside of Florida. WRAP include s six scoring categories: 1) Wildlife Utilization; 2) Overstory/Shrub Canopy; 3) Vegetative Gr ound Cover; 4) Adjacent Upland Support/Buffer; 5) Field Indicators of Wetland Hydrology; and 6) Water Quality Input and Treatment. Scores range from 0.0-3.0, in 0.5 increments. A score of 3.0 indicates an intact wetland, whereas a score of 0.0 indicates a wetland with a reduced f unctional capacity (Miller and Gunsalus 1999). Guidance is provided for scoring categories of 0.0, 1.0, 2.0, and 3.0. The final WRAP score is calculated by summing the scores for the scor ing categories and dividing by the number of scoring categories used. For forested wetlands, six scoring categories are used; however, for herbaceous wetlands typically only five scoring categories are used as the Overstory/Shrub Canopy category is generally not applicable as it requires a minimum of 20% cover by woody species. The WRAP calculation results in a score between 0.00-1.00, w ith 1.00 representing an intact wetland. WRAP assessments were con ducted at all 58 wetland assessment areas within the 29 banks. Hydrogeomorphic wetland assessment (HGM) Developed through the United States Army Corps of Engineers, HGM evaluates current wetland functions and can be used to predict prospectiv e changes to a wetland's functions resulting from future activities (USEPA 1998). Two HGM regiona l guidebooks were applicable to this study, one for Everglades flats wetlands (Noble et al 2002) and one for depr essional wetlands in peninsular Florida (Noble et al. 2004). The HGM approach is based on an evaluation of a sample wetland attributes or variables compared to the reference standards provided by the guidebook (i.e., wetlands that are relatively unaltered); the inde x of ecological function is calculated from those variables. This approach focuses on five measures of wetland function: 1) Surface Water Storage; 2) Subsurface Water Storage; 3) Cycle Nutrients; 4) Characteristic Plant Community; and 5) Wildlife Habitat. For Ever glades flats wetlands, wetland functions 1) Surface Water Storage and 2) Subsurface Water St orage are combined into one wetland function category called Surface and Subsurface Water Stor age. Each wetland function has a calculated value based on equations with input variables from field measurements or GIS determinations. Each wetland function receives a score betw een 0.00-1.00, with 1.00 representing the reference standard condition. Each wetland assessment area r eceives four or five separate HGM scores for wetland function. HGM assessment was conducted at six Everglades flats a nd nine depressional wetlands. Florida Wetland Condition Index (FWCI) The FWCI is a wetland bioassessment method based on three separate indices of biological integrity: diatom, macrophyte, or macroinverteb rate community composition. The premise behind the FWCI is to detect differences in abunda nce, structure, and diversity of target species assemblages between the wetland being assessed and a reference standard wetland. Three variations of the FWCI have been developed fo r herbaceous depressional wetlands (Lane et al. 2003), forested depressional wetlands (Reiss and Brown 2005a), and forested strand and floodplain wetlands (Reiss and Brown 2005b). For a given species assemblage (i.e., diatom, macrophyte, or macroinvertebrate), presence/absen ce data are used to calculate metric values,

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20 which are then summed together to provide an overview score of wetland condition. This study used the macrophyte and macr oinvertebrate FWCIs. The macrophyte FWCI for all wetland types contains the following metrics: 1) Tolerant Species; 2) Sensitive Species; 3) Exotic Species; 4) Floristic Quality Assessment Index or mean Coefficient of Conservatism scor e; and 5) Annual or Perennial Species. The depressional forested wetland macrophyte FWCI also includes a metric for Wetland Status (based on obligate and facultative wetland species, as defined by C h. 62-340.450, F.A.C. Metrics are scored from 0-10, with 10 representing the reference standard condition. Metric scores are summed and the resulting scale is from 0-50 for depressiona l herbaceous and forested strand and floodplain wetlands and 0-60 for depressional forested wetlands. The highest score represents reference standard condition (either 50 or 60, depending on wetland type). In this study, results are the presented as a percent of re ference standard condition. The macroinvertebrate FWCIs have different me trics for each wetland type. The depressional herbaceous wetland macroinvertebrate FWCI incl udes five metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a re ference dataset (Tolerant); 3) Percent of macroinvertebrates in the pred ator functional feeding group (P redators); 4) Percent of macroinvertebrates in the orde r Odonata that includes dragonf lies and damselflies (Odonata); and 5) Percent of macroinvertebra tes in the subfamily Orthocladinae, a subfamily in the family Chironomidae (Orthocladinae). Scoring for the depressional herbaceous wetland macroinvertebrate FWCI assigns scores of 0, 3, 7, or 10 to each of the five metrics with total FWCI scores ranging from 0-50, with 50 representi ng the reference standard condition. In this study, results are presente d as a percent of refe rence standard condition. The depressional forested wetland macroinvertebrate FWCI includes six metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 3) Calculated score from the Florida Index (Florida Index) (see Beck 1954, Barbour et al. 1996); 4) Percent of macroinvertebrates in the phylum Mollusca, includi ng snails and bivalves (Mollusca); 5) Percent of macroinvertebrates in the family Noteridae, the burrowing water beetles (Noteridae); and 6) Percent of macroinvertebrates in the scraper f unctional feeding group (S crapers). Metrics are scored on a continuous scale fr om 0-10, with 10 repr esenting the reference standard condition. Metric scores are summed and the resulting sc ale is from 0-60, with 60 representing reference standard condition. In this st udy, results are presented as a percent of reference standard condition. Macrophyte FWCI assessments were conducted at six depressional herbaceous wetlands, three depressional forested wetlands and one fo rested strand and fl oodplain wetland. Macroinvertebrate FWCI assessments were cond ucted at two depressi onal herbaceous wetlands and two depressional forested wetlands. Ma croinvertebrate FWCI assessments were not conducted at the remaining five de pressional wetlands, as those si tes did not have the required minimum 10 cm of standing water covering a minimum of 50% of the wetland surface area, needed for macroinvertebrate sampling.

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21 Landscape Development Intensity (LDI) index The LDI index functions as an index of hu man activity based on a development intensity measure derived from nonrenewable energy use (e.g., fertilizer, fuel electricity) in the surrounding landscape. The LDI index equati on incorporates the amount of nonrenewable energy use (Table 2-4) weighted by area of la nd use within a 100 m radius of the property in question. Brown and Vivas (2005 ) present the basis for LDI index calculations, and Vivas (2007) presents a modified equation, which was us ed in this study. The LDI index scale runs from zero, representing high ecologi cal integrity, to infinity, representing decreased ecological integrity, though in practice LDI in dex scores appear to be li mited at around 35 (Vivas 2007; Reiss, unpublished data). Two scales of the LDI i ndex were calculated: wetla nd scale LDI index for each of the 58 wetland assessment areas and bank scale LDI index for 26 banks. To calculate the wetland scale LDI index, a 100 m zone was delin eated around the edge of each wetland asse ssment area and land uses within the zone were iden tified based on 2004 digital orthographic qua rter quads and field notes for current surrounding land use from site visits. Lands surrounding wetland assessment areas within the 100 m zone that were being re stored, enhanced, create d, or preserved within wetland mitigation bank boundaries were assigned th e development intensity of Natural Land, which suggests no use of nonrenewable ener gy. Clearly mitigation activities require nonrenewable energy use (e.g., earth moving activ ities, exotic plant removal or herbicide treatment). However, the calculated LDI index values for the wetland assessment areas were considered the potential LDI index for a wetland assessment ar ea given the surrounding land uses, which should be an already restored, self-sustaining commun ity. That is, given successful enhancement, restoration, creati on, or preservation, the calculated LDI index value reflects the lowest potential LDI index score and in turn the highest potential ecological integrity possible for a wetland assessment area once mitigation is complete. To calculate the bank scale LDI index, a 100 m zone was co nstructed around the bank boundary and land uses within the zone were identified using 2000 land us e cover maps (LU00), available from the Florida Geog raphic Data Library (http://www.fgdl.org/ ). Only 26 of 29 bank scale LDI calculations were completed, as the mitigation bank outline was not available for Boran Ranch Phase I; Phases I and II of the Everglades Mi tigation Bank were combined into one bank scale LDI index; and year 2000 land use was not available for Garcon Peninsula.

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22 Table 2-4. Nonrenewable energy value for land use categories used to calculate the Landscape Development Intensity (LDI) index. The unit of nonrenewable energy (e.g., fertilizer, fuel, electricity) is empower density (s ej/ha/yr). For a description of empower, see Odum (1996). Land Use Category Non-Renewable Empower Density (E14 sej/ha/yr) Natural Land / Open Water 0.0 Recreational / Open Space low intensity 2.8 Pine Plantation 5.1 Unimproved Pastureland (with livestock) 8.3 Improved Pasture (no livestock) 19.5 Low Intensity Pasture (with livestock) 36.9 High Intensity Pastur e (with livestock) 51.5 Citrus 65.4 Recreational / Open Space medium intensity 67.3 Row crops 117.1 High Intensity Agriculture (dairy farm) 201.0 Single Family Residential (Low-density) 1,077.0 Recreational / Open Space high intensity 1,230.0 Single Family Residential (Med-density) 2,461.5 Low Intensity Transportation 3,080.0 Single Family Residential (High-density) 3,729.5 Low Intensity commercial (Comm Strip) 3,758.0 Institutional 4,042.2 Highway (4 lane) 5,020.0 Industrial 5,210.6 Multi-family residential (Low rise) 7,391.5 High intensity commercial (Mall) 12,661.0 Multi-family residential (High rise) 12,825.0 Central Business District (Avg 2 stories) 16,150.3 Central Business District (Avg 4 stories) 29,401.3

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23 CHAPTER 3 REVIEW OF PERMIT SUCCESS CRITERIA AND CREDIT RELEASE This study considers two kinds of success. Fi rst, ecological success was defined by restoring function to wetlands. Second, permit success was de fined in regards to meeting criteria and conditions set forth in the mitigation bank permit. Ideally, the two categories of success would be integrally linked; however, in practice, pe rmit conditions and criteria may not always equate to ecological success. This study looked to bridge the gap in achieving both ecological and permit success, so that improved permits resu lt in ecologically succes sful wetland mitigation. Documents reviewed for this study included stat e mitigation bank permits, permit modifications, federal Mitigation Banking Instruments (MBIs), a nd monitoring reports. Not all documents were obtained for all banks, but at a minimum state pe rmits were acquired. State mitigation bank permits, whether issued by a water management district or the Fl orida Department of Environmental Protection (FDEP), generally consiste d of two parts: 1) a staff review or agency intent to issue, which summarized the salient portions of the application file and documented the basis of the agencys authoriza tion and 2) the legally binding pe rmit and figures, which set forth the conditions of the authori zation. Once issued, no change s can be made to the permit conditions without an official permit m odification issued by the agency. Appendix C lists the documents revi ewed for each of the 29 banks included in this study, along with summary notes of these documents and fi nal success criteria. The federal MBI was not consistently reviewed, but it was used when avai lable. There was a great deal of variation between and among the mitigation bank permits and additional documentation, making generalizations difficult and st atistics unrealistic. This chapter instead provides information on the range of differences of mitigation banks pertai ning to their state permits and success criteria. Further, this chapter makes recommendations on how mitigation banks can improve permit criteria to better ensure achiev ement of ecological success. Mitigation Goals and Success Criteria Florida statutes and rules present guidance on ecological goals for mitigation in general and mitigation banks in particular. The statute establishing mitigation banking (Section 373.4135(1), F.S.) directs agencies to emphasize restorati on and enhancement of degraded ecosystems and encourage restoration of communities that were historically present. Although state rules identify minimum requirements for success, it is up to the reviewing agency to state the success criteria in the permit and to ensure that specific conditions in the permit are met. Given its reference in statute and rule, it is surprising that more permits do not emphasize or require definitions for target natural ecological communiti es or reference wetlands that would include a suite of functional parameters. Florida Statutes Rule 62-312.350, Florida Administ rative Code (F.A.C.) states, All mitigation bank permits include success criteria. These are indicators that long-term, self-sustaining ecological goals of the proposed en hancement or restoration will be met. The statute goes on to define the minimum, necessary site characteri stics to determine ecological success. These characteristics include but are not limited to de lineation of the wetlands and other surface waters

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24 according to state rule (Ch. 62-340, F.A.C.); appropriate hydric soils; appropriate target vegetative community or early successional stages of said target community; appropriate size, topography, and configuration; hydrology to support target comm unity; negligible exotic or nuisance species present; and meeti ng state water quality standards. Many of the permits reviewed for this study di d not explicitly describe the target wetland community or reference standard condition for the target wetland. When reference standard wetland conditions were addressed within a permit, these standards were often vaguely described and qualitative, using terms such as based on a comparison (TM-Econ and Colbert-Cameron), within the range of similarity values (Little Pine Island) or resemble those of a reference wetland (Boran Ranch, Phase I). Specific quantitativ e guidelines for addressing the similarity of the mitigation wetland with the reference standard wetland condition were routinely absent. Approximately 50% (13) of the state mitigation ba nk permits reviewed in this study describe or refer to having reference conditions either as a comparison to the literature or an actual field comparison (Table 3-1). In contrast, 13 bank pe rmits make no mention of reference conditions in state permits. A few bank permits recognize th e inability to restore natural communities to reference condition due to site constraints and instead measure ecological lift from pre-bank conditions. For example, Bear Point has success criteria meant to increase function and improve water quality and fish and wildlife habitat, but w ill always be managed for mosquito control. As such, it can never represent the fu ll function of reference conditions expected of saltwater marsh and mangrove communities. The most obvious limitation for banks to attain reference conditions are banks closest to urban developmen t. Location and landscape support will always be a limiting factor in achieving full function when banks are situated in developed landscapes. A standard should be developed fo r minimal criteria to describe target natural communities for restoration. The Florida Natural Areas Inventory Guide to the Natural Communities of Florida (FNAI 1990) document, while dated, would be a good resource to use in th e initial development of a wetland mitigation bank. FNAI (1990) presents characteristic species, soils, hydrology, fire regime, and limitations to natural communities in de tail. At a minimum, this would be a better starting place to frame specific restoration comm unity goals, rather than vague references to pinelands or sawgrass marshes that lack a fu ll appreciation of the complexity of natural communities. Some banks defined target communities with the Florida Land Use, Cover and Forms Classification System (FLUCCS), which may not be at a fine enough scale for restoration goals. Communities defined as mixed forested wetland, wetland forested mixed, and freshwater marsh do not provide detailed information even though so me of the characteristic dominant species are in the definitions of these categories. For ex ample, the category of freshwater marsh (6410) includes prairie, depression marsh, basin ma rsh, flatwoods pond, and ephemeral pond. These wetlands occur throughout Florida and are composed of a variety of herbaceous species. These freshwater marshes vary widely in size, from less than an acr e (e.g., depressional marshes) to thousands of acres (e.g., Everglad es flats). In preference to FL UCCS, FNAI descriptions present baseline conditions and an initial starting point for a literature referen ce, describing community composition, structure, and ecosystem processes.

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25 Table 3-1. Target community and reference co ndition information in mitigation bank permits. Target communities identified? Target in success criteria?Reference provided?Reference in success criteria? BARBERVILLE 3-4 communities namednonono BEAR POINT 1 type namedyesnono BIG CYPRESS 4 communities named with required acreageyes literature reference for compositionno BLUEFIELD 16 types namedyes literature reference for compositionyes BORAN RANCH I 3 named in map with required acreageyesonsite referencedemonstrate similarity BORAN RANCH II 4 named in map with required acreageyesonsite referencedemonstrate similarity CGW not clearnonono COLBERT-CAMERON preservationnonono CORKSCREW 4 communities named with required acreageyesmust meet UMAM scoresmust meet UMAM scores EAST CENTRAL existing communitiesnonono EVERGLADES I 3 types named with required acreagenomust meet WATER scoresmust meet WATER scores EVERGLADES II 3 types named with required acreageyesmust meet WATER scoresmust meet WATER scores FLORIDA MITIGATION BANK 3 types named with required acreagesome namednono FLORIDA WETLANDS BANK 3-4 types named, mapnonono GARCON PENINSULA 3 types named with required acreageyes literature reference for compositionmust meet WRAP scores GRAHAM SWAMP existing communitiesnonono HOLE-IN-THE-DONUT 1 type namedinferred yes onsite based on wetlands in Everglades National Park Yes, statistical similarity required LAKE LOUISA 4 types named non-specific reference to compositionnono LAKE MONROE 14 named and mapped with FLUCCSnonono LITTLE PINE ISLAND 4 named with acreageyes yes, literature and reference wetlandsyes LOBLOLLY 2-3 named communitiesno MBI refers to literature but is vagueno LOXAHATCHEE 5 named communities with required acreageyes criteria based on reference at adjacent Loxahatchee Preserve wildlife has reference targets PANTHER ISLAND 3-4 communities named and mappedyes criteria based on reference at adjacent preserve Corkscrew Sanctuary no REEDY CREEK FLUCCS and mappednonono RG RESERVE existing communitiessome namednono SPLIT OA K existing communitiesunknownnounknown SUNDEW not clear, upland and wetlandno MBI refers to literature but is vagueno TM-ECON 4-5 existing communities mappedno relative to onsite preservation b ased on enhancements over baseline TOSOHATCHEE existing communities in state parknonono TUPELO not clear, upland and wetlandno MBI refers to literature but is vagueno

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26 Not all banks lacking a description of reference c onditions in their permits appear to be limited in function or progress towards ecological improve ment. Perhaps some banks that lacked documentation for reference conditions utilized th e professional experience of the land manager to restore the natural communities. Some of the banks that were having difficulty restoring some community types did not always have a clear goal defining the target natural community. Simply referring to the natural community and its dominant species composition is not enough to restore the function of the community. Measur able parameters should be clear and succinct when referring to desirable reference conditions. Qualitative resemblance without quantitative correlations is not enough to determ ine restored structure and function. Perfunctory comparisons to reference wetland types based on plant descriptions can limit determination of full wetland func tion if composition of flora a nd fauna, physical characteristics, and structure are also not defi ned. Basing success only on attain ing similarity of the plant community to reference standard conditions may not restore total function and other parameters pertaining to water chemistry, soils, macro and micro fauna, and ecological processes, all of which are an important part of defining reference standard conditions. Nine wetland mitigation banks make no mention of fauna in their state permits or techni cal reports. Ten banks make reference to wildlife utilization in the final suc cess criteria. Twelve ba nks have some form of qualitative wildlife monitoring in their bank ing program, and seven banks implemented quantitative monitoring. Of the seven banks with quantitative m onitoring, two require monitoring for listed wildlife species th at occur on the bank (Table 3-2). While application of wetland assessment methods, which are used to determine potential credits, requires the assessor to research associated w ildlife and basic life history traits, it was not apparent that this baseline information was al ways being sought for fauna on the banks. Ch. 62345, F.A.C., is the required assessment method for calculating credits for wetland mitigation banks, effective February 2004. UMAM 62-345.400 Pa rt I Qualitative Characterization clearly requires at a minimum identifying anticipated wild life utilization and type of use (i.e., feeding, breeding, nesting, resting, or denning) and applicab le listing classificati ons (i.e., threatened, endangered, or species of special concern as defined by Rules 68A-27.003, 68A-27.004, and 68A-27.005, F.A.C.), which should increase a ssessor awareness of wildlife habitat and utilization. Basic ecological principles can be applied to determine the function of wildlife habitat and utilization. Fauna should be considered in the planning of the mitigation bank in the context of landscape fragmentation and habita t loss outside the ba nk and edge effects, connectivity and dispersal of exp ected fauna, core to edge rati os regarding habitat needs for foraging, cover and reproduction, species intera ction, and monitoring should be conducted for fauna response to management activities. If it is outside of the ability of the regulating agencies and bank managers to apply these basic ecological principles to planning and management than more precaution should be taken when assuming poten tial gain in ecological function that would support the associated wildlife species. Further, the scientific baseline that defines a natural community is ever evolving. It may take years to restore a community on a wetland mitig ation bank, and in the mean time available scientific knowledge might evolve to further define appropriate fi re return interv als or response to other disturbance phenomena like hurricanes. Without an appropriate understanding of the target natural community, and an adaptive manageme nt plan or experimental design, acceptable

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27 Table 3-2. Successes criteria for native wildlife monitoring requirements in state permits. Mitigation Bank No detail on wildlife needs Wildlife requirements in Success Criteria Qualitative monitoring or observation requirements Quantitative monitoring requirements Barberville Bear Point Big Cypress Bluefield Ranch Boran Ranch CGW Colbert-Cameron Corkscrew East Central Everglades Mitigation Bank (WATER requirements) Florida Mitigation Bank (3 in MWRAP wildlife utilization) Florida Wetlands Bank Garcon Peninsula Graham Swamp Hole in the Donut Lake Louisa and Green Swamp Lake Monroe (FL scrub jays) Little Pine Island Loblolly Mitigation Bank Loxahatchee Panther Island Reedy Creek R.G. Reserve Split Oak Sundew Mitigation Bank TM-Econ (red cockaded woodpeckers) Tosohatchee Tupelo Mitigation Bank

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28 variation in community struct ure and function based on respons e to disturbance would be unclear. Credit Potential Florida rules recognize th at not all mitigation areas are expected to attain reference condition. Chapter 62.312.350, F.A.C. states that it is not the intent of the Department to require that the mitigation area exactly duplicate or replicate the re ference water. Thus, an important concept in evaluating mitigation success is an understanding of how a mitigation site is assessed for credit. Mitigation projects are generally categorized along a continuum of regulatory categories including creation of wetlands from uplands, restoration of wetlands that had historically been converted to uplands or non-native land uses, enhancement of altered wetlands, and preservation of intact wetlands. A mitigation bank may have several of these different mitigation types in different locations or communities types within the bank, as well as upland preservation or enhancement to provide buffer, protection, hab itat, and recharge function to the adjacent wetlands. Thus not all mitigation areas start at th e same level of ecological function, nor do they all have the same anticipated outcome. It is the improvement in ecological function, or ec ological lift, that provides the mitigation value or credit to offset wetland impacts of functional loss. Potential credit an d loss should be assessed by the same method. However, when evaluati ng mitigation banks, the future losses through impacts are not yet known, so a standard unit of lift or gain is needed to provide a currency for credit and debit. In Florida, a mitigation credit is defined as a standard unit of measure which represents the increase in ecological value resulting from re storation, enhancement, preservation, or creation activities (Section 373.403(20), F.S. and Chapter 62-342.200(5), F.A.C.). Typically, the mitigation area is divided into polygons or a ssessment areas of similar condition, treatment, community type, and anticipated results. Each area is assessed for its anticipated functional lift between its current or predicted without bank condition, compared to its anticipated outcome with bank condition (Story et al. 1998). In February 2004, Florida adopted Uniform Mitig ation Assessment Method (UMAM) in Chapter 62-345, F.A.C, thereby providing a standard methodology for all state wetland regulatory agencies to assess lift of mitigation and assess loss associated with impacts. Prior to that date, mitigation banks were assessed by a variety of other functional assessments and by acre to credit ratios. The 45 permitted mitigation banks to tal approximately 47,753 ha (118,000 ac) with a total of approximately 36,500 potenti al credits, which means, on aver age, about 1.4 ha (3.5 ac) of mitigation area is required to generate one credit (Figure 3-1). In reviewing some of the permit files and attachme nts, it was clear that the with bank scenario was often scored very high, anticipating full f unction would return to a site once mitigation activities were completed. This was true even in cases where the surrounding landscape would have an impact on water quali ty or quantity or where wild life support or movement was significantly curtailed. In fact, it often seemed that the assessment was focused only on the anticipated capacity to support vegetation rather than the full suite of integrated wetland functions of the community. This practice could l ead to an over-estimation of ecological lift and mitigation credit.

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29 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 199519961997199819992000200120022003200420052006 YearAcres (blue) or Total Credits (red) Total Acres (2006: 118,300) Total Credits (2006: 36,520) Figure 3-1. Total area (ac) of permitted mitigat ion banks (blue columns) in relation to total potential credits (red columns) (1995-2006). Preservation Historically, preservation of intact ecosystems through a conservation easement has been a form of mitigation that has been used to offset impacts in limited cases. Because, technically, no ecological function has been gain ed by the recording of a documen t, simple preservation was considered of restricted value in offsetting re al losses. However, because of development pressures, relatively unregulated loss of supporting uplands, and the degradation of ecosystems by exotic or nuisance species, establishing non-de grading conservation easements is considered to be protection to losing function over time, and mitigation value is assessed by comparing the anticipated condition with-preserv ation to that without-preservat ion. By rule, no mitigation credit may be released until the mitigation bank, or phase thereof, has a recorded conservation easement and financial assuranc e for its implementation and l ong-term management (Ch. 62342.470(3), F.A.C.) over the project area, regardle ss of its current condition. Therefore all mitigation credits represent some degree of protection from development and ecological degradation. However, there is wide vari ation among banks in the degree to which the preservation of intact ecosystems has in generating mitigation credit. The mitigation bank permits reviewed did not consistently separate credit awarded for preservation in terms of preserving intact communities with a high degree of function versus filing a conservation easement over communities in pre-restored condition. About half of the studied banks have phases or polygons with in tact wetlands or uplands where very little enhancement was required and management in perp etuity was assumed to maintain function.

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30 Even these banks did not specifically separate the potential credit attributed to this preservation. It is unclear whether credits have been allocat ed as credits for conservation easements or as preservation credits based on the difference between the current c ondition and the assumed without mitigation scenario. Credit Release Florida statute recognizes that mitigation projects may take years to attain final success criteria, and provides for an incremental release of credits with a credit release sc hedule in the permit. Once the credits are released, they may be sold and used to offset impacts. Sec. 373.4136(5)(b), F.S. states The number of credits and schedule for releas e shall be determined by the department or water management district ba sed upon the performance criteria for the mitigation bank and the success criteria for each mitigation activity. The release schedule for a specific mitigation bank or phase thereof shall be related to the actions required to implement the bank, such as site protection, site preparation, earthwork, removal of wastes, planting, removal or control of nuisance and exotic species, instal lation of structures, and annual monitoring and management requirements for success. Credit release schedules for mitigation banks incl uded in this study are summarized in Table 3-3. Credit releases were separated into four broad categories: Legal Actions, Construction and Management Activities, Monitoring of Increm ental Improvement and Final Success. Each category is discussed below in greater detail. Legal Actions In order to receive any credits to sell, a banke r must record an agency reviewed conservation easement over the bank, or phase thereof, with the county in wh ich it is locate d. The easement requires that the bank be maintained in its current or enhanced conditions and specifically lists activities which are forbidden, except as stipulated or required in the permit. The conservation easement is executed in favor of the department and/or the water manage ment district. These easements are also required by federal agencies, but they do not accept the easement themselves. Prior to recording the easement, agencies review title informati on and required title insurance for the easements value. In addition to the conservation easement, the ba nk sponsor must provide financial assurance for both the implementation of the project and for its long-term management Generally, the two assurances are in the form of a letter of cred it (LOC) or performance bond, payable into a standby trust in favor of the agency. The amount of the implementation financial mechanism is based on a cost estimate of the money required to co mplete the mitigation plan and manage and monitor the land until it attains success. The banker must update the cost estimate every two years; the LOC or bond value may decrease when work is successfully completed or may increase to reflect higher antic ipated costs. The amount for th e long-term management trust is equal to the principle that will generate in interest (at 6%) the estimated annual management costs. When both the financial assurances and conservation easement documents are properly executed, the banker may request th e initial credit release.

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Table 3-3. Percent of total potential cred its released for each activity or rel ease criteria (numbers are rounded). p e r m i t d a t e c r e d i t r e l e a s e d t o d a t e c o n s e r v a t i o n e a s e m e n t c o n s t r u c t i o n c o m p l e t i o n e x o t i c r e m o v a l t r e e r e m ov a l p l a n t i n g p r e s c r i b e d f i r e i n c r e m e n t a l f i n a l t o t a l % p o t e n t i a l c r e d i t w h i c h i s a c t i v i t y b a s e d BARBERVILLE Jun-9664%40%23%yes25%12%100%63% BEAR POINT Jul-0750%10%15%15%50%10%100%40% BIG CYPRESS Sep-9956%10%20%yes10%48%12%100%40% BLUEFIELD Nov-0745%10%15%10%10%45%10%100%45% BORAN RANCH I Aug-9793%25%75%100%25% CGW Jun-9880%28%39%13%6%14%100%80% COLBERT CAMERON Oct-9678%100%100%100% CORKSCREW Jun-070%15%20%7%yes3%30%25%100%45% EAST CENTRAL May-97100%58%30%10%2%100%100% EVERGLADES I Oct-9690%10%10%10%yes60%10%100%30% EVERGLADES II Oct-0311%10%20%10%3%3%34%20%100%46% FLORIDA MITIGATION BANK May-97100%15%20%yes50%15%100%35% FLORIDA WETLANDSBANK Feb-9599%15%40%25%10%5%5%100%90% GARCON PENINSULA Apr-0145%15%15%5%yes5%5%40%15%100%45% GRAHAM SWAMP Sep-9690%60%yes25%15%100%60% HOLE-IN-THE-DONUT* Feb-95NA LAKE LOUISA Oct-9582%15%10%10%20%25%20%100%55% LAKE MONROE Sep-9565%15%15%yes10%15%10%35%100%55% LITTLE PINE ISLAND Feb-9635%10%45%30%15%100%55% LOBLOLLY Sep-0325%25%15%5%5%30%20%100%50% LOXAHATCHEE Feb-0050%15%13%13%50%10%100%40% PANTHER ISLAND Mar-9986%25%15%15%10%5%20%10%100%70% REEDY CREEK Feb-9762%30%20%5%3%2%30%10%100%60% RG RESERVE Jan-038%40%15%8%10%20%7%100%73% SPLIT OAK** Jun-9643%45% SUNDEW Aug-0110%20%20%10%5%25%20%100%55% TM-ECON Jan-0315%30%15%40%15%100%45% TOSOHATCHEE Oct-95100%30%20%50%100%50% TUPELO Jan-0432%25%15%5%5%30%20%100%50% *On public land; In-lieu fee bank. Credits ar e not released incrementally; Acres restor ed incrementally as needed for mitigatio n. ** No more credits were sought; mitigation plan ca rried out through alternative agency agreements.

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32 Initial credits releases are usually between 10%-25%; however there are exceptions (Table 3-3). Some conservation easement credit releases are awarded by phase (e .g., Panther Island, Reedy Creek Table 3-3 reflects bank-wide average) a nd not for the entire property. On the high end, Colbert-Cameron, primarily a preservation bank, r eceived 100% potential credits per phase after removing cattle and minor hydrological fixes one y ear after the conservati on easement was filed. Similarly, Panther Island received 80-85% potentia l credit release for some of its phases in preservation areas. Most wetland mitigation bank s are not preservation-only banks. Four banks received credit release based on conservation ea sements in addition to previously completed construction activities. For exam ple, initial credit release at Graham Swamp of 60% was based not only on recording a conserva tion easement but also construction already completed and one year of monitoring. Split Oak had a similar requi rement of active management plus conservation for their initial release. Three banks, Hole in the Donut, Little Pine Island and Tosohatchee, do not have conservation easements and did not recei ve credit for preservation because they occur on already protected public lands. Typically, little information was provided as to how the amount of initial credit release was determined. Ideally, the initial credits generated by recording the conservation easement should reflect the preservation value of that property. SWFW MD has initiated a method whereby they conduct an initial assessment of a mitigation bank to determine potential credit based only on preservation. Assuming that the mitigation ba nk will be protected from future degradation, preservation credits are awarded based on curre nt condition. Then a second assessment based on enhancement is completed to determine the lift a ssociated with mitigation activities. Seemingly, this method would make awarding credit for preservation a more tr ansparent process. Construction and Management Activities Generally, once a mitigation bank permit has been issued, work begins on the ground to commence enhancing and restoring the land as required. Some banks begin ground work in phases or polygons, sometimes with several activities o ccurring simultaneously. These activities usually include installing perimeter fencing, in stalling hydrologic enhancement or restoration mechanisms, earth moving, site clearing, and plan ting. Although there are no rules pertaining to monitoring and reporting requirements during the construction phase of the bank, all banks are required to give notice prior to construction initiation. FDEP requires status reports every six months, regardless of whether construction activiti es are in progress or not Individuals at the permitting agencies commented that some banks did not submit reports or communicate with their regulating agency for some length of tim e because there was no act ivity on the bank during that time period. Perhaps standardization within the permit special conditions section that a status report is required every six months would help close the communication gap. An example of appropriate permit language for communication with state agencies is provided for Garcon Peninsula (Figure 3-2). Once construction activities are complete, the bank is required to monitor. At this point, the bank should be able to demonstrate ecological in cremental improvement over time. Some banks have interim criteria that must be met in orde r to demonstrate a trend towards success, while other banks must demonstrate an improvement over baseline conditions. Banks are required to submit a monitoring report at least annually to document the monitoring and provide the basis

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33 30. Progress Reports Beginning six months after permit issuance until final success determination, the permittee shall submit semi -annual progress reports containing the following information regarding the project: a. Date permitted activities were begun or are anticipated to begin; b. Brief description and extent of work completed since the previous report or since permit was issued; c. Copies of permit drawings indi cating areas where work has been completed; d. A description of problems encount ered and solutions undertaken; e. A brief description of the work and/or site management the permittee anticipates commencing, continuing or completing in the next six months; and f. Site management undertak en, including type of management and dates each type was undertaken. Figure 3-2. Permit requirements from Garcon Peninsula Mitigation Ba nk (permit number 017-880-001). for requesting credit release for that monitoring period. SWFWMD does not have interim or incremental criteria for Boran Ranch mitigation bank. At this bank, initial credit is released for recording a conservation easement and completi ng construction activiti es; only after final success criteria is met for a given wetland polygon is the remaining credit released. Two state agency regulators relayed that in the past, some early banks believed they were owed a credit release from the regulating agency for conducting monitoring, regardless of whether incremental ecological improvement was documented. Hydrology Most of the banks in th is study have some hydrologic enhancemen t or restoration with associated credit releases for construction of these enha ncements. Most enhancement practices have included removing roads or increa sing connectivity under roads, removing or blocking ditches, and re-grading swales or other unnatural topographi c features that inhib it the natural flow of water. Some banks are highly engineered. A few have heavily manipulated hydrology because of their placement in a regi onally altered landscape (e.g., Floridawetlands Bank; Florida Mitigation bank). Two banks have constructed si gnificant berms with control structures to increase water levels on site (i.e., Loxahatchee and Florida Mitigation Bank). Everglades Phase II and Bear Point have existing berms required fo r flood control or mosquito control; these banks have installed multiple controlled culverts thro ugh the berms to more closely mimic sheet-flow when allowable. Eight banks are known to have permanent water co ntrol structures as described in their state permits. In total, 19 banks descri be some level of target hydrology listed in their success criteria. Other requirements hydrology requi rement include that f our banks must meet M-WRAP or other assessment criteria standards, and seven banks must meet a size requirement of jurisdictional wetlands as defined under Sec tion 373.421, F. S. (a bank may have more than

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34 one of these requirements). Five banks do not specifically mention hydrology in their final success criteria, although some cred it releases are tied to installa tion of hydrologic enhancements or monitoring of said enhancements. Hydrologically based construction also occurred on the banks in terms of grading the existing lands to achieve a lower elevation to support target communiti es. Hole in the Donut requires grading all of the previously rock-plowed soil (a pproximately 0.3 m) dow n to the underlying limestone to prevent re-infestation of Brazilian pepper ( Schinus terebinthifolius ) and to promote the native marsh community. Likewise Flor ida Wetlandsbank, Panther Island, and Corkscrew have areas dominated by exotic species or pasture permitted to be graded to support a marsh community. Grading allowed for the appropriate target wetland species to become established and the community to more closely resemble th e desired target community. However areas that have been rock plowed and graded lose the cap acity for ground water storage in the areas that have been lowered. The successful completion of construction activitie s typically result in the release of 10-20% of the potential credits, with a few exceptions for ma jor construction projects: Tosohatchee and East Central at 30% and Florida Wetlandsbank at 40% (Tab le 3-3). Credit release is usually based on as-built information and/or other hydrologic data showing anticipated hydrologic enhancements or water levels were attained. Although surface water level changes tend to occur quickly after most hydrologic enhancement structures are in pl ace, soil, plant, and animal community response to the enhanced hydrology may take several years or longer. Although one of minimum requirements of succe ss of Rule 62-312.350, F.A.C. state that water quality standards are met, ve ry few banks monitor for wate r quality. Most banks do not specifically propose to improve water quality th rough wetlands mitigation, but this might be implied with restored function of those wetlands such as th rough nutrient cycling and improving fauna habitat. The state of Fl orida does not have water qualit y standards specific to wetlands, but general Class III water quality standa rds do apply (Ch. 62-302 Surface Water Quality Standards, F.A.C.). Some of the banks have writte n into their state permit that they must adhere to Best Management Practices during cons truction for minimizing turbidity and slope stabilization. Eight banks are required by their state permit to monitor water quality during that time. Only Bear Point, Florida Mitigation Bank, and Lake Louisa and Green Swamp have mitigation activities intended to specifically improve water quality. Exotic and inappropriate species removal Invasive exotic and nuisance sp ecies are a tremendous ecological and financial concern for land managers on conservation lands in Florida and el sewhere in the United States (e.g., Pimentel et al. 2000). Many contend that these species th reaten biodiversity, ecosystem functioning, community health, or human economies (Myers et al. 2000; Diaz et al. 2003). Throughout Floridas history, some non-native species were deliberately plante d as part of previous human land use activities like pasture, agriculture, and c itrus, and as such are present on lands used for wetland mitigation banking. While some of these species are not considered an invasion threat (e.g., sweet orange or grapefruit, Citrus x aurantium ), others can persist, reproduce, and spread

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35 (e.g., West Indian marsh grass, Hymenachne amplexicaulis, Diaz et al. 2003) and are thought to alter native community structure and function. A disturbance or alteration in th e landscape, often in the form of disruption of natural hydrology or a total change in the landscape from a natural land use to agriculture or pasture often increases the likely hood of occurrence of exotic species. Most of the ba nks in this study had enhancement activities relating to the eradi cation and continued treatment of exotic vegetation. Banks had varying degrees of exotic species. Little Pine Island (Figure 3-3), Hole in the Donut, and Florida Wetlansbank receive most of their credit from the removal of 80-100% cover of melaleuca ( Melaleuca quinquenervia ) or Brazilian pepper ( Schinus terebinthifolius ). Invasive tree species can have a significant impact to the hydrology, structure, and functio n of native communities when they invade open communities like marshes or flatwoods (EPPC 2003). Like wise, the exotic climbing fern ( Lygodium spp. ) can have significant impacts to function in forested communities (EPPC 2003). These exotics pose di fficulties in restoring natural communities in several banks, including Bluefield, Corkscrew, Everglades Mitigation Bank, Garcon Peninsula, and Loxahatchee. Figure 3-3. Dense cover by the invasive exotic species melaleuca or punktree ( Melaleuca quinquenervia ) prior to restoration activities at Little Pine Island. Bahia grass ( Paspalum notatum) while not as invasive in intact natural areas, can be persistent and difficult to eradicate from pastures where it was introduced and is pa rticularly difficult to treat in historically more xeric habitats. Othe r problematic exotic spec ies which are extremely persistent and can dominate groun d cover include torpedo grass ( Panicum repens) and cogon grass ( Imperata cylindrical) Several earlier permits anticipated that with the restoration of appropriate hydrology and cessation of cattle or citrus management practices, the native vegetation would out-compete and do minate the pasture grasses or require only spot treatments

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36 of these species. This has not been borne out on some banks, and they continue to face an uphill battle with these invasive exotic species (e.g., Ba rberville, Big Cypress, Lake Louisa and Green Swamp, and Lake Monroe). Other banks have b een very effective at removing pasture grasses and restoring back to a natu ral community (e.g., Reedy Cree k, Bluefield) by implementing thorough site preparation, vigilant monitoring, re-treating exotics, and re-seeding deliberately to establish an intact native groundcover that can be more difficult for some exotics to invade. Exotic species eradication is expensive an d time consuming. Common control techniques included herbicides and mechanical removal w ith some banks utilizing hand pulling in more sensitive communities. Others experimented with manipulating hydrology and fire to remove exotics and keep them from retu rning. Because of their lands cape location and proximity to nonconservation lands, many mitigation banks have a sign ificant nearby constant exotic species seed source from adjacent properties. Most banks will perpetually have to manage for exotic species with the goal being to eradicate exotic species from the seed bank on site and treat new exotic species that are recruited to the site. There was a wide variety of percent cover allowed for exo tic vegetation in permit success criteria, ranging from 1% to 10%, and sometimes ev en higher for specific pasture grasses, such as bahia grass ( Paspalum notatum ) (Table 3-4). While this figure may be specifically related to individual conditions at the bank, it appeared that allowable cove rage had a stronger relationship to the permitting agency (Figure 3-4). Additiona lly, some mitigation banks also recognized that a native species may be inappropriate for the ta rget community such as woody species in an herbaceous dominated habitat (e.g., wax myrtle, Myrica cerifera, at Garcon Peninsula). Another category of inappropriate species is found in historic we t prairie, flatwoods or mixed wetland forests of northern Florida that were converted to pine pl antations. Several banks mitigation plans involve the restoration of nati ve communities from the planted pine areas (Barberville, Loblolly, Sundew and Tupelo, and to a lesser extreme TM-Econ and Garcon Peninsula). Similarly, two banks involved significant acreage of citrus tree removal and revegetation (Big Cypress, Lake Louisa). Eight mitigation banks have a potential credit release tied to removing silviculture or agriculture trees (Table 3-1). Garcon Peninsula and TM-Econ were the only banks of these eight that awarded potential credit based on the response of the native community to pine removal as opposed to pot ential credit awards for the physical act of removing the trees themselves. Site preparation, planting, and seeding With an emphasis on reference conditions for a target community, activities relating to site preparation, planting, seeding, and expected surv ivorship of plants sh ould have measurable, expected densities. Most banks had some basi c requirement for percen t cover of desirable, native species (Table 3-5). Fourteen banks incl ude planting and/or seeding as a requirement for credit release (3%-20%, typically 5%-10%) (Table 3-3). Site preparation is paramount to the survival of the desirable species as is the timing of planting and activities used to maintain the desired vegetation such as hydrologic regime and fire rotation. Vegetation planting may be necessary in mitigation areas that no longer have a viable native seedbank or nearby seed source

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37 Table 3-4. Final success criteria for exotic and nuisance vegetative cover for state permits. Mitigation Bank Credit Type County Area (ha) Exotic and nuisance cover FDEP: Bear Point Mangrove St. Lucie 128 2% cover per acre exotic Corkscrew FW herb/for Lee 257 < 2% exo tic cover; < 5% nuisance; < 25% combined cover of Myrica cerifera, Baccharis halimifolia and Salix caroliniana per acre Everglades Mitigation Bank, Phase I Fresh/salt Dade 1,669 1% aerial cover Florida Mitigation Bank FW herb/for Osceola 640 1% total cover Garcon Peninsula FW herb/for Santa Rosa 136 < 1% exotic; Sapium sebiferum 1%; Bahiagrass 10%, or if >10%, trend over 2+ years strongly indicating cover will decrease to < 10%; in cypress/hardwood swamp, nuisance species 5% Graham Swamp FW forest Flagler 27 < 5% Hole in the Donut Everglades Dade 2,529 5% total cover Little Pine Island Fresh/salt Lee 512 < 1% Loxahatchee FW herb/for Palm Beach 512 EPPC Category I^ exotic 1%; EPPC Category II^ exotic 3% SFWMD: Big Cypress FW herb/for Collier 518 0 % total cover exotic; 3% total cover nuisance Bluefield Ranch FW herb/for Martin & St. Lucie 1,091 10% exotic/nuisance cover; 15% in any acre area at any time Florida Wetlandsbank Freshwater Broward 170 5% Panther Island FW herb/for Hendry 1,128 0 % exotic (exotics divided by total species rounded to nearest whole number); 3% nuisance R.G. Reserve FW herb/for Martin 258 5% exotic; 10% nuisance 15% total cover any acre area Reedy Creek FW herb/for Osceola & Polk 1,211 < 10% exotic/nuisance; Uplands mean % cover by nuisance tree species < 1%; mean % cover by nuisance shrub species < 5%; groundcover bahiagrass and other nuisance species < 20 % SJRWMD: Barberville FW herb/for Volusia 148 5% exotic; 10% nuisance CGW Saltwater Indian River 61 1% Colbert-Cameron Freshwater Volusia 1,054 < 10% East Central Freshwater Orange 429 10% Lake Louisa and Green Swamp Freshwater Lake 408 5% exotic; < 10% nuisance Lake Monroe FW herb/for Volusia 244 < 5% exotic Loblolly Mitigation Bank Freshwater Duva l 2,528 State permit < 10%; MBI < 5% Sundew Mitigation Bank Freshwater Clay 853 < 10% TM-Econ Freshwater Orange 2,104 < 10% Tosohatchee DOT-used Orange 531 < 10% Tupelo Mitigation Bank Freshwater St. Johns 617 < 10% SWFWMD: Boran Ranch Phase I Freshwater Desoto 96 < 1% ^ EEPC Category exotics from the Exotic Pest Plant Council (EPPC 2003).

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38 Figure 3-4. Final success criteria allowan ce for exotic vegetation percent cover by mitigation bank and regulating agency. Agencies include: FDEP Florida Department of Environmental Protection; SFWMD South Flor ida Water Management District; SJRWMD St. Johns River Water Management District; SWFWMD South West Florida Water Management District.

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Table 3-5. Success criteria related to native vegetation cov er and survivability of planted vegetation in state permits. Bank Name Dominant Habitat at Site Visit Final Success Criteria percent cover of native vegetation Survivability of planted vegetation Barberville Flatwoods Not specified 400 trees per acre Bear Point Mangrove swamp > 50% No planting in phase reviewed Big Cypress Flatwoods Herbaceous: 80% cover native wetland spp. and 20 wetland herbaceous spp. The herbaceous vegetation shall cover 60 % with plant species listed FAC or wetter and be rooted for at least 12 months and be reproducing naturally Forested: 70% coverage by desirable ground cover plants, with 75% of spp. being listed FAC or wetter. Hydric pine flatwoods: diversity of 30 herbaceous spp. shall be present. For each 5 species over 30 a 1% credit bonus will be given for hydric pine flatwoods. Evidence of natural regeneration of planted species 80% survival of all planted trees and shrubs Bluefield Ranch Flatwoods Flatwoods graminoid vegetation in groundcover strata 50% of total coverage 70% of total groundcover strata consists of wetland vegetation (hydric pine flatwoods only) 80% of total herbaceous groundcover strata FACW and/or OBL vegetation or OBL vegetation > upland vegetation 80% survival of planted trees Boran Ranch Flatwoods, marsh 85 to 90% cover for desirable vegetation depending on community type No planting in phase I CGW High marsh, mangrove swamp 90% No planting Colbert-Cameron Flatwoods, cypress domes Percent cover not specified, bank is primarily preservation with some enhancement No planting Corkscrew Regional Mixed forest, cypress domes, hydric flatwoods Minimum percent cover of groundcover is 70% for hydric pines. Minimum percent cover of groundcover in cypress and mixed forest areas is 75% unless there is a lower percent because of open water or shading. Must show evidence of natural recruitment No explicit numbers for survivorship in final success criteria. East Central Wetland forested mixed Bank was monitoring for vegetative cover but this study did not acquire documentation that stated what th at final success criteria was. Unknown if there was a requirement for survivorship

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Table 3-5. Continued. Bank Name Dominant Habitat at Site Visit Final Success Criteria percent cover of native vegetation Survivability of planted vegetation Everglades Mitigation Bank Sawgrass marsh, tree islands 80% aerial coverage of vegetation including planted and naturally recruited vegetation Survivorship not explicitly defined. Florida Mitigation Bank Freshwater marsh, bottomland hardwood > 90% desirable vegetation groundcover and canopy NA Florida Wetlands Bank Freshwater marsh 80% planted species must have 80% cover Garcon Peninsula Wet prairie Groundcover 75% Planted canopy must have at least 30% cover > 90% survival Graham Swamp Bottomland hardwood forest Vegetative cover must stay the same or increase over the baseline. Vegetation must demonstrate natural recruitment No planting Hole in the Donut Freshwater marsh The importance value, based on frequency and percent cover or density of desirable vegetation, for each restoration area shall fall within the range of Whittaker curves for the naturally occurring communities in this area of Everglades National Park No planting Lake Louisa and Green Swamp Sandhill? Unknown if there are requirements for percent cover, none were obtained by this study Planted canopy 80% Planted groundcover 60% Lake Monroe Flatwoods Unknown whether there is a target perc ent cover in the final success criteria but bank is tracking percent cover in the monitoring reports Planted longleaf and cypress 50% Little Pine Island Mangrove swamp, salt marsh, mud flats, hydric flatwoods Demonstrate > 60% cover and increase over time NA Loblolly Mitigation Bank Hydric flatwoods, cypress domes > 80% cover groundcover > 25% mast forming trees 100 trees per acre in forested wetlands 25 trees per acre in upland Loxahatchee Forested swamp and open marsh 80 90% ground cover in marsh and willow polygons except in mudflats with 25% woody species 50-90% canopy and ground cover for red maple, pond apple and cypress polygons 10-20% open water as meandering water courses and small depressions Permit also addresses appropriate number of species and densities No planting

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Table 3-5. Continued. Bank Name Dominant Habitat at Site Visit Final Success Criteria percent cover of native vegetation Survivability of planted vegetation Panther Island Hydric flatwoods, cypress strands, cypress domes, freshwater marshes 70% average aerial cover by native wetland flora for transitional and emergent marshes Low pool marshes 60% cover Flatwoods 70% aerial cover by desirable ground cover and groundcover recruitment Flatwoods minimum 90% survival planted canopy spp.; minimum 80% survival of planted subcanopy spp.; minimum 80% average survival of planted ground cover spp. Reedy Creek Hydric flatwoods, freshwater marsh, wet prairie flatwoods canopy cover 50%, shrub cover < 20% marshes 75% prairie 80% Bank may have to do future plantings in marshes if percent cover by natural recruitment can not be met R.G. Reserve Bottomland hardwood forest, hydric flatwoods, swales 80% coverage of desirable wetland species Uplands mean % cover by indigenous ground species > 75% Ground strata dominated with indigeno us grass species at > 50% of total ground strata: mean % cover by indigenous ground strata species is > 5% but < 30% Mean density of indigenous shrubs and semi-shrubs is > 180 and < 400/ac Shrub strata dominance < 75% by any 2 species Mean % cover by indigenous tree species is > 5% and < 25% Mean indigenous tree density is > 5 and < 50 Survivorship of planted vegetation not explicitly defined Split Oak Documentation did not include su ccess criteria specific to native vegetation cover or survivability of planted veget ation. Sundew Mitigation Bank Hydric flatwoods, cypress domes No requirement for percent cover 100 trees per acre in forested wetlands TM-Econ Hydric flatwoods, forested slough > 80 % aerial cover trees 80% Tosohatchee Mixed wetland forested, fresh water marsh > 80 % cover > 80% Tupelo Mitigation Bank Hydric flatwoods, cypress domes No requirement for percent cover Minimum density of 100 surviving and growing trees/ac present in assemblages that reflects diversity in target vegetative community

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42 for recruitment. Additionally, supplemental plan tings may be required to increase diversity, provide structure, or stabilize areas where ro ads were removed, canals filled, or grading occurred. A practice commonly followed by several more recently permitted banks for flatwoods or wet prairie targets communities in cludes preparing large ar eas of bare ground by disking and/or herbicide treatments, then mulchi ng with seed and other pl ant material directly from a harvested donor site. Although most banks did list a desired percent cover for native vegetation, very seldom was there a reference in the permit for how per cent cover would be defined or measured. Composition, dominance, structure, and other metric s that define a natural community say more about restored function than perc ent cover or survivorship of pl anted species alone. In addition, percent survivorship criteria often appeared to be based more on standard practice or previous permits, as opposed to expected vegetation density in the reference standard community. These arbitrary densities, especially for trees, should not be a standard, a nd plantings in specified target communities should be based on reference standard s in the literature or a natural community. Prescribed fire A majority of the mitigation banks in this study include a diverse landscape mosaic of upland and wetland community types most of which are ad apted to fire. Bear Point, CGW, and Graham Swamp represent three mitigation banks where prescribed fire would not be appropriate given that mangrove and hardwood wetland communities re present nearly 100% cover at these banks. However, historically fire would have played a significant role in maintaining the natural communities in the landscape surrounding these mangrove and bottomland hardwood swamps. The FDEP mitigation rule requires mitigation bank permits to contain perpetual management plans (62-342.750(1)(h) F.A.C). Most of the banks acknowledge the role of prescribed fire in maintaining the natural communities on site. However, it was difficult to determine how detailed long term fire management plans were. Some banks also have (or intend to) utilized prescribed fire during enhancement and restoration activ ities in addition to using it for long term management of the natural communities. Eight bank permits had a credit re lease associated with conducting a prescribed fire (Table 3-3). A few more permits required prescribed fire as part of the final release crit eria. There is evidence that some banks are not as aggressive in the applic ation of prescribed fire as they could be. At least two banks, Big Cypress and Ba rberville, cite being unable to apply prescribed fire until planted pine trees ( Pinus spp.) in flatwoods communities are established for eight to ten years. Additionally, Barberville anticipates waiting 15 years to burn an area planted with cypress ( Taxodium spp.). Documents for both banks do not ad equately describe the natural community type, but suggest the overall reason for not a pplying prescribed fire is because of possible mortality to the planted trees. As well, both banks demonstrate a lack of diversity in the groundcover in what this study determin ed should be flatwoods communities. The emphasis to protect the planted trees appears misplaced when restoring the function for this community type. For example, in longleaf pine ( Pinus palustris ) communities, Kirkman and Mitchell (2006) propose that the age and diversity of groundcover and temporal extent of fire connections across the landscape may be more approp riate means of describing ol d-growth ecosystems as opposed

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43 to the age of trees, stressing the importance of appropriate groundcover and fire regime over tree structure. A low intensity prescribed fire during the growing season could benefit the groundcover and enhance species diversity. Primar y concern for planting the pine trees first before restoring the groundcover may not have been the best approach to achieve success and restoring a functioning flatwoods community. At least seven banks included in this study reporte d that they were behind in accomplishing their prescribed burn plan for site specific conditions usually because the site was either too wet or too dry. Other limitations for some banks in clude their placement in populated areas where smoke control is more restricted (e.g., Everglad es Mitigation Bank Phases I and II). In some circumstances (e.g., Garcon Peninsula), the inability to burn has set back the restoration progress because a primarily herbaceous ecosystem has b een over taken by an overstory of shrubs and other woody structure. In this specific case, pr escribed fire was tied to credit release and the state withheld future credit rele ases pending fire implementation. As with all of the construction and management ac tivities described in this chapter it would be worthwhile for regulators to consider tying cred it release to the natural communities response to management decisions such as pres cribed fire. Fire is an ecosys tem process that can drastically alter a landscape, if applied appr opriately it can be a tool for restoration and maintenance of a natural community. Monitoring should be conduc ted to determine flora and fauna response to the application of fire. Frequenc y and application techniques of prescribed fire should be based on reference documentation and literature. Credit releases for construction and management activities described previously are based on documentation that the required action has occurred. In total, these activity-based releases at a typical bank averaged about 50% of the total po tential credits (Table 3-3), and represent the preservation and completion of the mitigation w ork at the bank. Although it is recognized that the actual work does sometimes represent actual enhancements made, mitigation success may be improved if credits releases were weighted more toward incremental improvement and community response to these treatments and actions, rather than simply completion of predetermined activities. The remaining credits are typically based on ac hieving incremental or final performance goals. Monitoring and Interim Release Criteria Most mitigation banks are required to submit an annual monitoring report to document the level of success attainment. Monitoring plans, includ ing both qualitative and quantitative parameters, are reviewed prior to permitting, and thus should be adequate to evaluate success criteria. Monitoring plans are generally refe renced in permit criteri a or attached to the permit. Some state permits specifically addressed what is expected in monitoring reports, others did not have specifications. The FDEP mitigation banking rule (Chapter 62-342, F.A.C.) requires that mitigation banks include a proposed monitoring plan to demonstrate success. Monitoring reports acquired in this study repres ented varying degrees of quali ty of data and quantity and completeness of information. For utility, monito ring reports should refer to success criteria, both interim and final, and specifically demonstrate incremental change from the baseline. If a bank

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44 is using reference wetlands for ta rget restoration, then monitoring reports should reflect how the restored areas compare to reference conditions. Some monitoring reports were mere plant lists, with minimal analyses and vague descriptions. It could be that some early perm its did not specify enough detail as to what was required for monitoring, and bank are not offering more than these minimal requirement. While agency personnel do tend to visit banks either when new monitoring reports are submitted or following requests for credit release and regulators should be capable of verifying what is in the report, time and resources devoted to agency monitori ng and analysis is limited. Efforts would be improved so that monitoring reports read easily for anyone unfamiliar with site history or permitting conditions of the bank. A monitori ng report should summarize success criteria, history of the bank, activities completed, acti vities planned, and discuss how the bank is progressing in restoring and enhancing the natural target communities. Further, monitoring reports should clearly and unambiguously state if the mitigation bank is on target with interim or final success criteria and if the bank is trending to wards success and describe the parameters it is meeting. Compliance regulators reported that seven banks did not report on areas that were not demonstrating ecological improvement or did not submit a report becau se no activities were taking place. Sometimes if a bank falls behind in meeting their targets, th e bank will not request additional credits release but will also not su bmit a monitoring report, as that would require admitting problems with attaining interim targets or monitoring. Some permits require a status report every six months, regardless of the degree of activity or monitoring results, which may be a good tool to track mitigation activities and progress. After major mitigation construction activities but pr ior to final credit release, interim credits are typically awarded by year or phase of a mitigat ion bank. Potential credits awarded for reaching interim criteria vary, with mean awards of 5-8% of total potentia l credits per year. Total interim criteria varied around 30%-50% re lease of total pot ential credit (Tab le 3-3) over an average of four to five years. While there is an expectation that releasing interim criteria should implicate a trending towards success, many times this was not reinforced by specific criteria that should demonstrate incremental ecological improvement. Out of twenty three mitigation banks that included an interim release, onl y thirteen had specific criteria tied to this annual or interim release. It is important that permits cl early distinguish that the interim/annual cred it releases are based upon the ecological functions gained since the last monitoring report, rather than on the submittal of the annual monitoring report itself. Comp liance regulators reported some problems with expectations based on reports rather than success. Further, field work associated with this study revealed cases where credits were released when it appeared that interim criteria had not been achieved. Compliance regulators re ported that monitoring reports can be misleading or report on improving areas rather than the whole site. A few mitigation banks have few or no credits released for interim success, either because cred its are withheld until the bank or polygon attains full success (e.g., Boran Ranch) or because the activ ities represent the final or near final success (e.g., Colbert-Cameron, Florida Wetlandsbank). In addition, the number of years required for monitoring and meeting final success varies, with mo st anticipating a five year release schedule,

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45 some anticipating an accelerated schedule (e .g., Florida Wetlandsbank, Graham Swamp, Panther Island), and other banks have or are anticipate d to take 10 or more years (e.g., Everglades Mitigation Bank, Florida Mitigation Bank, Garcon Peninsula, Hole in the Donut, Loxahatchee). In fact, even a 10 year time span may be too s hort to fully attain the natural variability and function for ecosystem development (Mitsch an d Wilson 1996), even if permit success criteria are reached. Final Success Determination and Release Ideally, final success criteria should reflect th e mitigation projects target community goals and anticipated functional gain, as de termined by the potential credit assessment (i.e., its with-bank scenario). An early guidance docum ent for Florida mitigation banking, Joint State/Federal Mitigation Bank Review Team Process (the Greenbook, cited as Story et al. 1998), suggests that the risk inherent in wetland mitigation bank ing is managed through credit release schedules and that because most credits are not released un til the success criteria have been met, risk has been minimized. Further, the Greenbook suggest s that success criteria s hould be specific and quantifiable based on the field assessment used to determine appropriate awarding of credits (Story et al. 1998). Yet only five wetland m itigation banks reviewed included functional assessment scores, such as WATER, Wetland Ra pid Assessment Procedure (WRAP, Miller and Gunsalus 1999), or Uniform Mitigation Assessm ent Method (UMAM, Chapter 62-345, F.A.C.), in the final success criteria. For over a decade, wetland scientists have reco gnized that permit success criteria and achieving wetland function may not be equivalent (Mitsch and Wilson 1996), yet changes have not been made in the permitting process to require completion of functional assessments for attaining credit release. Functional assessment scores for WRAP or UMAM may not be included in permit language because of concerns abou t the inherent subjectivity in the methods. For example, an assessor could award a hi gher functional assessment score base d on the incentive to attain functional success and not necessa rily based on a wetland asse ssment area truly achieving the suggested function. This concern for subjectivity and evaluator bias does not speak well of the reliability of rapid assessment methodologies or the human involvement in wetland mitigation banking. Even in more calculation intensive met hods such as the Hydrogeomorphic approach to assessing wetland function (HGM), it has been suggested that an assessor could visualize a higher percent cover of desirable species or miss an exotic species that occurred on a transect to improve the final score. Perhaps developm ent of a more objective means of measuring ecological function is called for, and holding thos e involved in the proces s personally responsible for such evaluations would improve the situ ation. Despite these limitations, achieving a predetermined with-bank scenario score for a given functional as sessment method could be used as a back up measure to withhold final credit release if the site did meet permit success criteria, but has been poorly monitored or is not functioning as anticipated. Final release of potential credits for mitigation bank state permits have been organized in two ways: one includes final re lease of credits as an incremental in stallment of available credits after final monitoring for the entire mitigation bank, a nd the second separates out final credit release based on criteria specific to each community t ype or polygon. The typical range of potential credits for final credit releases is between 5-20% of total potential credits awarded (Table 3-3).

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46 One obvious exception to the typical range is La ke Monroe, which has a potential final credit release of 35% total potential credits To date, all potential credit s have been released for Lake Monroe except for this final 35%, because it ha s not met its final success criteria. However, success criteria for this bank do not appear to encapsulate ecological function. There are incremental improvements, but the majority of cred it is tied to the survival of a planted canopy instead of restored groundcover for a community that should have a sp ecies rich groundcover. There is also credit tied to the appl ication of prescribed fire in th e communities that are intact but are in need of enhancement. At this time the bank is behind sc hedule in implementing prescribed fire. Fortunately this final credit is being with held until improvements are made to the restored and enhanced areas. It is doubtful, under the current management strategy, that the pastures will ever be reclaimed and resemble any reference conditi ons, but this was never part of the success criteria goals. The pr imary with holding of fi nal credit release appe ars to be tied to failures of control structures on hydrologic enhan cement areas. Another exception to the average final success release is Boran Ranch, where th e permit withholds 75% of credits until final success criteria are attained. However, this attainment is based on each polygon, rather than the whole bank, thus it becomes successful in piece s, which may mimic the incremental releases of other banks. There are causes for concern if meeting final suc cess criteria has a less significant credit release. This further illustrates the importance of the re gulators ability to determine that incremental credit releases are appropriate and determine a trending towards success. If banks are unable to meet final success criteria because they have failed to create conditions suitable for ecological trajectories, the final cr edits cannot be released. Compliance with Permit Schedule of Activities and Success Criteria State mitigation bank regulators were interviewed and asked to comment on the technical aspects of compliance for their respective mitigation banks. Their responses have been compiled and are listed in Table 3-6. In this section, success and trending towards success are defined in regards to permit criteria only. Three mitigation banks have reached final success criteria for the entire bank (East Central, Florida Mitigation Bank, Tosoha tchee). Regulators belie ve that nine banks appear to be trending towards success and should be able to reach final success. Five banks are currently not trending towards success, at least in specific problem areas. Six banks were not far enough along for regulators to comment on whether or not they are trending towards success yet. Most banks are visited at least once, if not twice, a year by the regulatory agency; most visits are timed with monitoring reports and requests for cred it release. This documentation is anecdotal, sometimes the regulator did not have all the inst itutional history on a bank if it was before their involvement and others expressed that some issues were one time incidents and not a continuous issue. Summary To insure that the credits released for use can indeed provide offsets to wetland functions, the following recommendations are nece ssary to the highest levels: Permits and attached or referenced docum ents should contain th e detailed community goals and/or reference conditions the site is anticipated to attain. FNAI descriptions

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47 could provide a valuable star ting point to ensure that mo re than just vegetation is included. It is important to evaluate wild life responses to mitigation activities. Final success criteria should be qua ntifiable reflections of these goals. Credit potential should be assessed with a reasonable evaluation of future condition given the expectations for surround ing landscape and water sources. Implementation of fire management pl an, as appropriate, should be a permit requirement, rather than just referenced in mitigation plans. Regulatory agencies must endeavor to write permits that can be followed and enforced that use the best available technology or protocol for re storation, be vigilant in demanding accurate and representative monitoring reports, withhold credit for underachieving sites, and ensure frequent co mmunication and inspecti on of the sites. The permits credit release schedule shoul d be commensurate with actual functional gain including the value of site preservation, with a higher focus on community response to mitigation activities, as opposed to the activity itself, and based on specific criteria.

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Table 3-6. Summary of regulatory complia nce for 28 wetland mitigation banks. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Barberville Problems with planting pines, have had to replant several times but latest monitoring report reports good success with second planting which occurred in 2004. Bank has not had a permit modification yet but has planted cypress in areas that were more wet than anticipated, pine is not surviving. Bank did not request credit release when plantings were failing, now that they are finding better success they have asked for credit release. Long ways off. No problems. Pretty good with communication, good about district visit. New district staff has been out to the bank a couple of times, and going again now because of credit release request. If the bank is not improving, then the district will allow more time to meet criteria. Bear Point First release for exotic species control, preservation, and financial assurance. Practically meeting success criteria after only 1-2 years. Need reminders when submitting reports. Needed help with process but good communicating. 1-2 times/yr with every credit release. Big Cypress Time zero was reset because could not get ground cover to proper specifications. Recently bank submitted request for credit release, but the district only gave a partial release because the herbaceous level 1 criteria could not be met because torpedograss ( Panicum repens ) cover was greater than 10%. Bank has finished all planting. Permit may have to be modified either in number of credits or type of credits because they may not be able to get the torpedograss within success criteria requirements. (this may not have ever been done before as far S.McCarthy knows) May experiment with different techniques to try and control the torpedograss. Pretty good about submitting reports on time although did withhold a monitoring report for a while because they were trying to do better with the torpedograss, fell a little behind trying to get it under control. Communicating pretty well. Usually on time except for what was previously mentioned. Generally visit Big Cypress every time a request for credit release is submitted. Other than that, site visits may happen at the request of the permittee to address a specific issue (i.e., analyze methods to eradicate torpedograss). Site visit may be requested if there are any glaring noncompliance issues from the monitoring reports. District staff has visited the bank for training and educational type purposes for district staff in the past. The bank has always been very accommodating.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Bluefield Ranch Credit for Phases 4 and 5 have been released post site inspection by district. Percent cover exceeds success criteria goals in the permit. Bank has met all requirements to date. Never denied a credit release. Have met all requirements to date, very successful to date. Reports are never late. Usually very lengthy with lots of documentation exceeding minimum requirements. Very communicative and responsive, never late. Agency staff only gets out once or twice a year. Try to time inspections following submittal of monitoring reports and prior to credit releases. Typically credit release inspections and general inspections are conducted together, limited staff and high work load being the factor. Boran Ranch There is not interim success criteria. Bank is laid out in polygons, there are no partial success or trending toward success credit releases. A polygon either has reached success or not. Credits released for Conservation Easement and construction and then for reaching success. Phase I is mostly released. Phase II conservation easement and construction credits. Agency feels that the bank knows what the expectations are and what exactly it has to do. Myakka is set up the same way. Final success is per polygon. A polygon might be the interior of a marsh and another polygon for the ecotone or transition area. The transition zone might be more difficult to achieve success because of pasture grasses and exotic species. Very cut and dry, either successful or not. If a polygon cannot reach success may have to do a credit modification and adjust success criteria and credits. Final success criteria is based on UMAM. Annual reports are very good and on time. Good communicating, bank keeps good track of credit withdrawals. Site visits usually at least twice a year. Visits coincide with requests to release credit. Sometimes the bank might think they deserve credit release but the ag ency does not believe the polygon has met final criteria.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency CGW No instance when credit was not released because of compliance issues. Progressing well, currently in monitoring phase. Sometimes needs to be reminded to keep on track. Asked for a credit release a year after monitoring report was due. Not always communicating on the ground. Lately bank is better about communicating and is straightening up ledger issues. District site visit are performance related. Site visit before credit is released when monitoring report is submitted and also to see how bank is progressing with interim criteria. ColbertCameron No problems with compliance, previous regulator said things were progressing well. Looks good do not foresee any problems. Submitting everything Good communication. New district staff has been to the bank once, do not know history of previous district staff bank visits. Corkscrew Long delay with initiating work. Was not communicating that on the ground work had begun. Reevaluate different plan based on lack of earth workconstruction changes. Permit modification made new plan less intrusive but did not have big impact on success criteria or monitoring. Will not be as wet. If they had scrapped the site like original intention the plan had more risk and might have been more difficult to hit final success. Hydrologic final success may be more difficult to reach now that they did not scrape. Made a significant modification of the permit to do less earth work. On the ground less was done (less impact). Not communicating at first what they were doing, doing their own thing. Better now. Work was good. They are responsive now. Lots of field work in permitting will be onsite for initial credit release December 2006. East Central Unknown if there is any history of not meeting interim criteria. Sold out final success achieved. Unknown. Unknown. Unknown. Everglades Mitigation Bank On the ground success looks good. Phase I attainedconscientious management. Tardy with annual monitoring report. Not always on target. ~1/y ear with credit release.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Florida Mitigation Bank Hydrology poorly designed-ended up firing manager, got new manager, and everything improved, first year annual credit release was denied. Do not have control of water input, but have relationship with Disney; official FDEP and MBRT success determination 2004. Initial monitoring and management techniques poor; good after new consultant (~2000). Initial reporting and modification very misleading; good after new consultant (~2000). 1-2 times/yr with every credit release. Florida Wetlandsbank Regulator does not know previous compliance history but in last few years the transfer of the bank to the City of Pembroke Pines for perpetual maintenance was held up because the buffer between housing on west side of the bank had homeowners infringing into the conservation easement with exotic plantings, swing sets etc. Bank managers had to go to the homeowners and remove all infringements from the bank and then the bank was required to put up a fence on the bank boundary in that area before the SFWMD allowed the final transfer. A final more recent phase has some time left in monitoring before the remaining credit (2.63) is released. Very good about submitting reports on time, adequate detail and information. No problems known. Site visits every year not necessarily tied to credit release or a set time schedule, just worked out between bank, district, county, the Corp and the City of Pembroke Pines. Early stages did annual visit with the agencies. Towards the final stages the only bank activities were treating undesirable vegetation. The bank was well established so did not do as many site visits Garcon Peninsula Good start-initial credit release for fire and exotic eradication. Site got wetter than anticipated when ditches were plugged. Changed cover type. Management fell behind. Needs a lot of work if they are going to try to hit final success. Back tracked some what because no burning, so will take longer than planned. Hydrologic success evident. Was out of compliance because was not getting burning done and had aerial spraying of exotic species. Reports not sent because no work done Not good needs constant agency prodding. Frequent early on, but 2+ years w/ no work, no request for credit release and no site visit; working to get back on track with frequent agency inspections and notices.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Graham Swamp Monitoring is not often enough. Did not attain final success but 95% there. Data are sometimes poor; because early permit not required to do long term management reports. Not responsive about keeping ledger up to date. 1+/yr earlier, now every other year. Hole in the Donut Ahead in restoration by acre. May never meet final success criteria, cover is not the same as reference conditions but function is believed to be met. On time, scientific good annual monitoring, but deficient status/activity reporting relative to permit. Miami Dade county not good about reporting permits and updating credits. No "credit release" schedule per se, but inspections ~once/2 years reveal timely/appropriate management. Lake Louisa and Green Swamp Only SJRWMD bank that requested a credit release and the district said no. Having problems meeting interim success regarding groundcover and shrub layer in the planted areas. District asked for a plan for how bank will address these issues. The bank is in disagreement with the District's decision because of previous arrangements made with staff that is no longer with the District. There was never a permit modification for success criteria. Bank is not in compliance but believes that it is trending towards success. Bank suffered from neglect, problems with bankruptcy. It is the District's opinion that the bank will have to change its management strategy if it will ever meet final success. Have been submitting reports on time but they are not always accurate. Reports are misleading and only reporting on areas that are more successful not the areas that are not in compliance. Monitoring report misleading, not on target. New district staff visited the bank initially to become oriented and familiar with it. Since then there has been a site visit conducted because a monitoring report was submitted and a credit release requested.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Lake Monroe Problems with ground cover, some plantings have failed, structure for hydrologic improvement has had some blow outs District land managers may try to help with pasture grass issues because it is District property, ultimately when it is turned over then District will maintain, but they do not want it until FDOT has found success with restoration and enhancement measures and is up to date on prescribed fire. Unknown. No current monitoring report, new District staff plans on spending more time with this bank and addressing its issues. Communicating pretty well. New District staff has been out to look at the bank and has had discussions about some of the problems (hydrologic structures and pasture grasses). Bank is willing to redo that work but there is debate about culvert maintenance between district and FDOT land managers, may be an issue discussed with previous staff no longer with the district. Little Pine Island Good at hitting target. Lots of phases are done; no final success determination requested yet. Reporting/ communication good. Mostly good, but some debit requests very late. 1-2 times/yr with every credit release. Loblolly Mitigation Bank Request in right now for credit release, site visit is planned. Initially credit for conservation easement and clearing pines but have since done some plantings. Very early stages of bank. Had to be asked for report. Not communicating so well, but is getting better. Does call a lot but has to be reminded for reports and more administrative type things. Bank does get in touch but might need more guidance and help in the process. Visit planned to determine credit release. Loxahatchee Not getting credit released because so far mostly unsuccessful, may not be able to reach final criteria. Hydrology success a problem in south parcel due to leaky underground conduits and canal level management out of control of bank reevaluation of criteria and credit likely. Good monitoring and reporting also addresses the problems responsively. Very communicative and responsive. 1-2 times/yr with every credit release.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Panther Island A couple times there was a hold up on a release because WMD needed to go out and do a site visit, one phase okay but another was not, specifically there was an issue with the exotic species smut grass ( Sporobolus indicus ) and torpedograss ( Panicum repens ). Bank was required to do a re-treatment before full requested release. One phase had a design modified because a site was wetter then expected. With time the Bank seems to know when to wait to ask for certain releases because they know WMD will not approve it in its current standing. Appears all phases trending towards meeting total success. Preservation areas doing very well, creation areas might take longer. As far as meeting criteria, Phase II might be too much coverit exceeded percent cover requirement and went from supporting open water fauna such as ducks and white pelicans to supporting larger and more common egrets and herons, does not conflict with success criteria. Bank reports are usually on time, or if not there is a particular reason that they have communicated to the WMD for example site was too wet to sample vegetation, or time zero report was delayed because planting issues with weather, lots of planning went into baseline and monitoring before anything was done on site. Very communicative, good relationship. WMD site visits tied to credit release most of the time. District staff has visited the bank to practice plant identification and train staff in the District. Site visits are conducted for final releases for particular phases. R.G. Reserve Bank has done minor enhancements, mostly credit for pr eservation. Credit might be denied sale because of withholding monitoring report (because the bank is waiting for a Corp permit). If percent cover is not achieved the bank will have to do some vegetative planting. Bank withheld monitoring reports because they did not have Corp permit yet, if the bank submits monitoring reports saying wetlands were restored, Corp would award less credit, Corp already has said that site is just preservation. Bank has modified its monitoring schedule. All reports are up to date and submitted now. Very little credit release, two sold for owner's projects and one other private but only 2/10 of a credit. Agency staff only gets out once or twice a year. Try to time inspections following submittal of monitoring reports and prior to credit releases. Typically credit release inspections and general inspections are conducted together, limited staff and high work load being the factor.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Reedy Creek No record of having with held credit for not meeting interim goals. Bank is fulfilling its requirements and submissions. On time or ahead of schedule with improvements to get credit release. Quality of reports is exemplary. Communication exemplary, bank and the agency audit each other, make sure both are on the same pageverify each others books are straight. Credit release and monitoring reports simultaneously with conducting site visits. Split Oak Unknown. Unknown. Unknown. Unknown. Unknown. Sundew Mitigation Bank Bank has only had an initial release for the conservation easement and has had some credits released for hydrologic enhancements, pine removal, and some plantings. Very early stages of bank. Had to be asked for report. Not communicating so well, but is getting better. Does call a lot but has to be reminded for reports and more administrative type things. Bank does get in touch but might need more guidance and help in the process. Bank has had a site visit because of request for credit release. Bank is in very early stages of work. Have done some planting, removed planted pine, and some hydrologic enhancement. TM-Econ No problems meeting interim cr iteria. No foreseen problems meeting final criteria. Always on time and responsive. Very responsive, no complaints from District. District site visit are performance related. Site visit before credit is released when monitoring report is submitted and also to see how bank is progressing with interim criteria. Tosohatchee Unknown if there is any history of not meeting interim criteria. All credits released, applicant not asking for anything. Unknown. Unknown. Previous regulator said bank was in good shape so it is not a current priority for follow-up to the new District staff.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Tupelo Mitigation Bank Has had some credits released for hydrologic enhancements, clearing of pine, and some planting. Very early stages of bank. Had to be asked for report. Not communicating so well, but is getting better. Does call a lot but has to be reminded for reports and more administrative type things. Bank does get in touch but might need more guidance and help in the process. Bank has had a site visit because of request for credit release. Bank is in very early stages of work. Have done some planting, removed planted pine, Done with hydrologic enhancement. Tupelo has had the most work of the three banks including Sundew and Loblolly.

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57 CHAPTER 4 DETERMINATION OF ECOLOGICAL INTEGRITY In order to assess the current ecological integr ity of the wetland communities in Florida wetland mitigation banks, five assessment methods were ap plied to select wetland assessment areas: Uniform Mitigation Assessment Method (UMA M), Wetland Rapid Assessment Procedure (WRAP), Hydrogeomorphic wetland assessmen t method (HGM), Florida Wetland Condition Index (FWCI), and Landscape Development Intensity (LDI) index. This chapter defines the term ecological integrity for the purpose of this study, followed by an overview of wetland assessment areas and a presentation of results from the five assessment methods. Comparisons among assessment methods are discussed. Definition of Ecological Integrity For this study, we adopt Karr and Dudleys (1981) definition of eco logical integrity. They state that a system with high ecologi cal integrity has the ability to support and maintain a balanced, integrated, adaptive community of organism s having a species composition, diversity, and functional organization comparable to that of th e natural habitats of th e region (pg. 56). In order to ascertain the degree of ecological inte grity of the assessment sites in this study, we compared the sites to the appropriate refe rence standard condition for the region. The term reference standard wetland condition has been defined (Smith 2001) as the least altered wetlands in the least a ltered landscapes (pg. 3), suggesting that those wetlands reflect the highest level of functioning for a ll of the functions expected of that type of wetland. Thus, the ecological integrity associated w ith these wetlands with no a pparent anthropogenic alterations and surrounded by natural landscapes would be optimal. All of the field assessment methods used in this study were developed with reference to minimally impacted ecological communities, and this comparison has been built into the scoring criteria for each assessment method. For ex ample, UMAM includes a Part I Qualitative Description where the evaluator must determ ine the reference community type, hydrologic connectivity, and the expected functions and wi ldlife (both common and listed species) before the site visit and scoring occurs. Similarly, WRAP begins with an office evaluation that requires review of aerial photography, identi fication of adjacent land use, and identification of wetland area (Miller and Gunsalus 1999). Both HGM and FWCI were de veloped based on a comparison of reference standard wetland community conditi on, and scoring criteria were standardized against a set of reference wetlands. Regional similarities and differences among wetland communities were considered when defining ecological integrity. WRAP was originally designed for use in certain types of south Florida wetlands, and has been applied state-wide to a variety of wetland types, whereas UMAM was intended to apply to all wetland community types statewide. The FWCIs for depressional forested wetlands and forested strands and floodpla ins are not limited geographically in the state. The Everglades flats HGM assessment method is app licable only to southern portions of the state (Figure 4-1), and both the depre ssional wetlands HGM assessme nt method and the depressional herbaceous FWCI were limited to the Florida peninsula (Figure 4-2).

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58 Figure 4-1. Applicable range of the Evergla des flats Hydrogeomorphic wetland assessment method (HGM) in South Florida. Reprinted with permission from Noble et al. (2002). Results of Assessment Methods Site visits were completed at a total of 58 wetland assessment areas within 29 mitigation banks. Each wetland assessment area was assigned a unique code. The first set of characters were assigned as abbreviations of the mitigation bank name. For example, Barb represents Barberville and Blue represents Bluefield Ranch. The second se t of characters were assigned as unique descriptions of a pa rticular wetland type: BOT for Bottomland Hardwoods, FLA for Hydric Flatwoods, FOR for Mixed Forested, HAM for Cabbage Palm Hammock, PRA for Wet Prairie, SHR for Shrub, and SLT for Salt Marsh. When more than one wetland assessment area at a bank was the same wetland community type, a number was added to the code. One to four wetland assessment areas were select ed within each bank for field assessment, depending on a combination of site specific conditions such as homogeneity of the bank, mitigation activities completed to date and pr ogress towards success criteria, area of wetland within the bank, types of mitigation (i.e., restor ation, enhancement, creation, or preservation), and general site conditions. Prio rity was given to those areas representative of the bank and where mitigation work had been conducted.

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59 (A) (B) Figure 4-2. Applicable ranges (reference domain) of A) depressional wetlands Hydrogeomorphic wetland assessment method (HGM) and B) depressional herbaceous Florida Wetland Condition Index (F WCI) in peninsular Florida. HGM map reprinted with permission from Noble et al. (2004).

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60 Generalized statistics regarding the size of banks as well as the wetland assessment areas sampled are telling of the vast differences among the banks (Table 4-1). For example, the mean bank area was 848 ha ( = 894.5 ha) with a range from 27 ha at Graham Swamp to 3,653 ha at Everglades Mitigation Bank/Phase II. The size of the wetland assessment areas ranged from 0.2 ha at Lake Monroe to 282.2 ha at Loxahatchee, with a mean wetland assessment area of 20.3 ha ( = 48.3 ha). The mean wetland assessment areas was 15.8% ( = 30.8%) of the total bank area, with a range spanning from 0.1% at L oblolly Mitigation Bank and TM-Econ to 100% at Bear Point and Graham Swamp. Less than 1% of the bank area was included in the wetland assessment areas at 13 banks, wh ile over 50% of the bank area was included in the wetland assessment areas at four banks. Regardless of the size of the bank, which incl udes upland area as well as wetland area, the assessment areas were sampled to best reflect th e scope of current conditions. For example, at Panther Island, four wetland assessme nt areas were selected due to the heterogeneity in wetland community and mitigation types. However, due to the large size of the bank (1,128.3 ha) and the small size of the wetland assessment areas (4.5 ha total); only 0.4% of the bank was included in the wetland assessment areas. Only a single we tland assessment area was selected at each of nine banks. At six of these banks, this wa s because the single wetland assessment area was representative of the dominant type of wetland community and mitigation activities. For example, an 8.1 ha wetland assessment area at Ev erglades Mitigation Bank/Phase II covered just 0.2% of the entire area of the wetland mitigation bank. In contrast, the 19.0 ha wetland assessment area at CGW covered 31.3% of the bank area. Due to vast differences in the size of the banks (60.7 ha at CGW and 3,652.7 ha at Ever glades Mitigation Bank/Phase II), the percent of area covered is vastly differe nt (31.3% compared to 0.2%). However, sampling efforts based on equal percentages of area of ba nk covered would not provide ad ditional information regarding the ecological integrity of wetland communities w ithin these banks. Furthermore, sampling an equal percent of wetland area at bank would have been time and resource inhibitive (e.g., sampling 31.3% of Everglades Mitigation Ba nk/Phase II would have required 1,143.3 ha of wetland assessment areas). At each of the 58 wetland assessment areas, UM AM, WRAP, and LDI were used to determine ecological integrity (Table 4-2). At 16 of the wetland assessment areas, one or more additional assessment methods were completed (HGM n= 15; macrophyte FWCI n = 10; macroinvertebrate FWCI n = 4). HGM could only be applied to sites with a wetland community type with a regional HGM guidebook, which were limited to fl ats wetlands in the Everglades (Noble et al. 2002) and depressional wetlands in peninsular Florida (Noble et al. 2004). Similarly, the macrophyte FWCI could only be applied to depr essional herbaceous wetlands in peninsular Florida (Lane et al. 2003), depr essional forested wetlands (Rei ss and Brown 2005a), and forested strand and floodplain wetlands (R eiss and Brown 2005b). Only a subset of those wetland assessment areas sampled for the macrophyte FWCI were appropriate for additional sampling using the macroinvertebrate FWCI (n = 4) as onl y four wetland assessment areas met the criteria of 10 cm of standing water covering a minimum of 50% of the surface area. A diatom FWCI is also available for depressional he rbaceous wetlands (Lane et al. 2003) and depressional forested wetlands (Reiss and Brown 2005a). However, due to the small sample size (n = 4) and the time and expense associated with sample processing, a decision was made to eliminate diatom FWCI analysis. Indeed, a greater set of HGM and FW CI appropriate wetlands would be useful for

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61 Table 4-1. Area of wetland mitigation banks and wetland assessment areas in the this study. Bank Name & Site Code Wetland Mitigation Bank (ha) Wetland Assessment Area (ha) % of Bank in Wetland Assessment Areas Barberville 148.0 1.4 Barb_CYP 0.6 Barb_MAR 1.4 Bear Point 128.3 100 Bear_MAN 128.3 Big Cypress 518.0 2.4 BigC_FLA 7.3 BigC_MAR_1 2.4 BigC_MAR_2 2.6 Bluefield Ranch 1,090.6 2.9 Blue_BOT 26.0 Blue_FLA 5.3 Blue_MAR 0.5 Boran Ranch, Phase I 95.8 23.1 Bora_MAR_1 1.1 Bora_MAR_2 21.0 CGW 60.7 31.3 CGW_MAN 19.0 Colbert-Cameron 1,053.8 2.3 CoCa_CYP_1 5.2 CoCa_CYP_2 5.7 CoCa_FOR 13.0 Corkscrew 257.0 2.2 Cork_FLA 5.7 East Central 385.0 1.9 ECFl_FOR 0.9 ECFl_HAM 6.4 Everglades Mitigation Bank/Ph I 1,669.2 5.8 Glad_MAR_1 93.0 Glad_MAR_2 2.2 Glad_SHR 0.9 Everglades Mitigation Bank/Ph II 3,652.7 0.2 Glad_MAR_3 8.1 Florida Mitigation Bank 640.2 0.3 FLMB_FOR 1.8 Florida Wetlandsbank 170.0 6.1 FLWt_MAR_1 9.1 FLWt_MAR_2 1.2 Garcon Peninsula 136.4 59.4 Garc_FLA 81.0 Graham Swamp 26.7 100 Grhm_FOR 26.7

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62 Table 4.1. Continued. Bank Name & Site Code Wetland Mitigation Bank (ha) Wetland Assessment Area (ha) % of Bank in Wetland Assessment Areas Hole in the Donut 2,529.3 7.6 HID_MAR_1 21.2 HID_MAR_2 171.0 Lake Louisa and Green Swamp 407.5 0.8 Loui_SHR 3.2 Lake Monroe 244.0 0.3 Monr_CYP 0.6 Monr_MAR 0.2 Little Pine Island 511.5 7.8 LPI_MAR 6.0 LPI_SLT_1 10.0 LPI_SLT_2 24.0 Loblolly Mitigation Bank 2,528.0 0.1 Lob_CYP_1 1.1 Lob_CYP_2 0.7 Loxahatchee 511.5 85.6 Lox_CYP 82.0 Lox_FOR 282.0 Lox_SHR 74.0 Panther Island 1,128.3 0.4 Pant_CYP_1 0.4 Pant_CYP_2 0.7 Pant_CYP_3 2.5 Pant_FOR 0.9 Reedy Creek 1,211.2 0.2 Reed_BOT 1.3 Reed_FOR 0.7 R.G. Reserve 258.2 0.6 RG_MAR 1.6 Split Oak 424.5 0.7 SplO_CYP 1.9 SplO_MAR 1.2 Sundew Mitigation Bank 852.7 0.5 Sun_FOR_1 3.3 Sun_FOR_2 1.1 TM-Econ 2,103.9 0.1 TMEc_CYP_1 1.0 TMEc_CYP_2 1.5 Tosohatchee 530.9 0.3 Toso_FOR 0.9 Toso_MAR 0.3 Toso_SHR 0.4 Tupelo Mitigation Bank 617.1 0.6 Tup_FOR 0.7 Tup_PRA 2.8

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Table 4-2. Overview of wetland assessment areas (n = 58) includi ng Florida Land Use, Cover and Forms Classification System (FLUCCS Code), associated wetland community ty pe, and wetland assessme nt methods applied: Uniform Mitigation Assessment Method (UMAM), Wetland Rapid Assessment Pro cedure (WRAP), Hydrogeomorphic wetland assessment method (HGM), Florida Wetland Condition Index (FWCI) for macrophytes an d macroinvertebrates, and Landscape Development Intensity (LDI) index. Bank Name Site Code FLUCCS Code Wetland Community Type UMAM WRAP HGM Macrophyte FWCI Macroinvertebrate FWCI LDI Barberville Barb_CYP 6210 Cypress Barb_MAR 6410 Freshwater Marsh Bear Point Bear_MAN 6120 Mangrove Swamps Big Cypress BigC_FLA 6250 Hydric Pine Flatwoods BigC_MAR_1 6410 Freshwater Marsh BigC_MAR_2 6410 Freshwater Marsh Bluefield Ranch Blue_BOT 6150 Stream and Lake Swamps (Bottomland) Blue_FLA 6250 Hydric Pine Flatwoods Blue_MAR 6410 Freshwater Marsh Boran Ranch, Phase I Bora_MAR_1 6410 Freshwater Marsh Bora_MAR_2 6410 Freshwater Marsh CGW CGW_MAN 6120 Mangrove Swamps Colbert-Cameron CoCa_CYP_1 6210 Cypress CoCa_CYP_2 6210 Cypress CoCa_FOR 6170 Mixed Wetland Hardwood Corkscrew Cork_FLA 6250 Hydric Pine Flatwoods East Central ECFl_FOR 6300 Wetland Forested Mixed ECFl_HAM 6181 Cabbage Palm Hammock Everglades Mitigation Glad_MAR_1 6410 Freshwater Marsh Bank/Phase I Glad_MAR_2 6410 Freshwater Marsh Glad_SHR 6172 Mixed Wetland Hardwoods Shrubs Everglades Mitigation Bank/Phase II Glad_MAR_3 6410 Freshwater Marsh

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Table 4-2. Continued Bank Name Site Code FLUCCS Code Wetland Community Type UMAM WRAP HGM Macrophyte FWCI Macroinvertebrate FWCI LDI Florida Mitigation Bank FLMB_FOR 6300 Wetland Forested Mixed Florida Wetlandsbank FLWt_MAR_1 6410 Freshwater Marsh FLWt_MAR_2 6410 Freshwater Marsh Garcon Peninsula Garc_FLA 6250 Hydric Pine Flatwoods Graham Swamp Grhm_FOR 6170 Mixed Wetland Hardwoods Hole in the Donut HID_MAR_1 6410 Freshwater Marsh HID_MAR_2 6410 Freshwater Marsh Lake Louisa and Green Swamp Loui_SHR 6310 Mixed Scrub Shrub Wetland Lake Monroe Monr_CYP 6210 Cypress Monr_MAR 6410 Freshwater Marsh Little Pine Island LPI_MAR 6410 Freshwater Marsh LPI_SLT_1 6420 Saltwater Marshes LPI_SLT_2 6420 Saltwater Marshes Loblolly Mitigation Bank Lob_CYP_1 6210 Cypress Lob_CYP_2 6210 Cypress Loxahatchee Lox_CYP 6210 Cypress Lox_FOR 6170 Mixed Wetland Hardwoods Lox_SHR 6172 Mixed Wetland HardwoodShrubs Panther Island Pant_CYP_1 6210 Cypress Pant_CYP_2 6210 Cypress Pant_CYP_3 6210 Cypress Pant_FOR 6300 Wetland Forested Mixed Reedy Creek Reed_BOT 6150 Stream and Lake Swamps (Bottomland) Reed_FOR 6170 Mixed Wetland Hardwood

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Table 4-2. Continued. Bank Name Site Code FLUCCS Code Wetland Community Type UMAM WRAP HGM Macrophyte FWCI Macroinvertebrate FWCI LDI R.G. Reserve RG_MAR 6410 Freshwater Marsh Split Oak SplO_CYP 6210 Cypress SplO_MAR 6410 Freshwater Marsh Sundew Mitigation Bank Sun_FOR_1 6300 Wetland Forested Mixed Sun_FOR_2 6300 Wetland Forested Mixed TM-Econ TMEc_CYP_1 6210 Cypress TMEc_CYP_2 6210 Cypress Tosohatchee Toso_FOR 6170 Mixed Wetland Hardwood Toso_MAR 6410 Freshwater Marsh Toso_SHR 6460 Mixed Scrub Shrub Tupelo Mitigation Bank Tup_FOR 6300 Wetland Forested Mixed Tup_PRA 6430 Wet Prairie

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66 further consideration of ecological integrity of wetlands within banks; however, HGM and FWCI could not be applied to wetlands th at did not fit the conditions for the reference wetlands used in developing these biological assessment tools. Using the Florida Land Use, Cover and Form s Classification System (FLUCCS Code), 12 wetland community types were differentiated in the wetland assessment areas (Table 4-2). The most common wetland community types were 6410: Freshwater Marsh (n = 18) and 6210: Cypress (n = 13). In addition, 13 forested wetlands with mixed species composition were assessed, including five 6170: Mixed Wetland Hardwood, two 6172: Mixed Wetland Hardwoods Shrubs, and six 6300: Wetland Fore sted Mixed community types. Uniform Mitigation Assessment Method UMAM UMAM scores for the 58 wetland assessment areas ranged from a low of 0.47 at a hydric pine flatwoods at Big Cypress (BigC_FLA) to the hi gh of 0.93 at five wetland assessment areas: two freshwater marshes at Boran Ranch, Phase I (Bora_MAR_1 and Bora_MAR_2), one freshwater marsh at Hole in the Donut (HID_MAR_1), a salt water marsh at Little Pine Island (LPI_SLT_2), and a cypress wetland at Split Oa k (SplO_CYP) (Table 4-3). Re call that the scale of UMAM ranges from 0.00-1.00, with 1.00 representing the optimal or reference standard condition. Half of the wetland assessment areas had UMAM scores greater than or equal to 0.75 (n = 29), suggesting that these wetland assessment ar eas provide 75% or more wetland function. UMAM scores were based on an average of thr ee categories representing indicators of wetland function: Location and Landscape Support, Water Environment, and Comm unity Structure. These scores ranged from 4 to 9 for Locati on and Landscape Support, 5 to10 for Water Environment, and 4 to10 for Co mmunity Structure. While several wetland assessment areas scored 10 for both Water Environment (n = 7) and Community Structure (n = 2), no wetland assessment area scored 10 for the categor y of Location and Landscape Support. As with the other assessment methods, UMAM wa s not meant to be used as a comparison among wetland community types. As such, UMAM scor es have been summarized based on specific wetland community types using FLUCCS (Table 44). Averaging the UM AM scores by wetland community type shows that mean UMAM scor es ranged from 0.53-0.80, though these averages have large standard deviations showing a great d eal of variability in the function provided by the wetland assessment areas. The highest mean UMAM score for any wetland community type was 0.80 ( = 0.18) for 6420 Saltwater Marsh. The large standard deviation is based on the wide variability in the scores for the two saltwater marshes at Little Pi ne Island, as one represented the pre-restored condition at LPI_SLT_1 (UMAM = 0.67) and one the post-restored condition at LPI_SLT_2 (UMAM = 0.93). Perhaps in this case, the difference between the two scores is more telling than the mean, as the numbers impl y a functional lift of 0.26 may be attained by implementing the mitigation plan for Little Pine Island salt marshes. Similarly, at Everglades Mitigation Bank, freshwater marsh wetland assessm ent areas were sampled before (Phase II Glad_MAR_3) and after (Phase I Glad_MAR_1) mitigation activities were implemented. Again, the difference between the high UMAM score for the restored wetland assessment area of 0.83 and score of 0.60 at the pre-restoration wetland assessment area i ndicates the potential functional lift attainable from restoration activities.

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67 Table 4-3. Uniform Mitigation Assessmen t Method (UMAM) scores for 58 wetland assessment areas at 29 we tland mitigation banks. In addition to total UMAM score, scores are presented for each of the three UMAM scor ing categories: Location and Landscape Support, Water Environment, and Community Structure. Bank Name Site Code Location and Landscape Support Water Environment Community Structure UMAM Barberville Barb_CYP 8 7 8 0.77 Barb_MAR 8 8 7 0.77 Bear Point Bear_MAN 8 8 9 0.83 Big Cypress BigC_FLA 5 5 4 0.47 BigC_MAR_1 7 8 6 0.70 BigC_MAR_2 7 8 7 0.73 Bluefield Ranch Blue_BOT 7 8 6 0.70 Blue_FLA 8 9 8 0.83 Blue_MAR 8 7 7 0.73 Boran Ranch, Phase I Bora_MAR_1 9 10 9 0.93 Bora_MAR_2 9 10 9 0.93 CGW CGW_MAN 4 7 8 0.63 Colbert-Cameron CoCa_CYP_1 8 7 7 0.73 CoCa_CYP_2 8 9 8 0.83 CoCa_FOR 8 9 7 0.80 Corkscrew Cork_FLA 5 5 5 0.50 East Central ECFl_FOR 7 7 7 0.70 ECFl_HAM 9 8 6 0.77 Everglades Mitigation Bank/Phase I Glad_MAR_1 7 9 9 0.83 Glad_MAR_2 8 8 9 0.83 Glad_SHR 7 9 9 0.83 Everglades Mitigation Bank/Phase II Glad_MAR_3 5 7 6 0.60 Florida Mitigation Bank FLMB_FOR 8 7 5 0.67 Florida Wetlandsbank FLWt_MAR_1 4 9 9 0.73 FLWt_MAR_2 4 9 8 0.70 Garcon Peninsula Garc_FLA 6 7 5 0.60 Graham Swamp Grhm_FOR 4 7 7 0.60 Hole in the Donut HID_MAR_1 9 9 10 0.93 HID_MAR_2 8 9 8 0.83 Lake Louisa and Green Swamp Loui_SHR 8 6 5 0.63 Lake Monroe Monr_CYP 9 9 9 0.90 Monr_MAR 7 10 7 0.80 Little Pine Island LPI_MAR 8 10 8 0.87 LPI_SLT_1 8 7 5 0.67 LPI_SLT_2 8 10 10 0.93 Loblolly Mitigation Bank Lob_CYP_1 6 8 6 0.67 Lob_CYP_2 8 9 9 0.87

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68 Table 4-3. Continued. Bank Name Site Code Location and Landscape Support Water Environment Community Structure UMAM Loxahatchee Lox_CYP 5 7 5 0.57 Lox_FOR 6 9 5 0.67 Lox_SHR 6 7 7 0.67 Panther Island Pant_CYP_1 7 8 6 0.70 Pant_CYP_2 8 9 8 0.83 Pant_CYP_3 8 9 6 0.77 Pant_FOR 9 10 8 0.90 Reedy Creek Reed_BOT 6 5 6 0.57 Reed_FOR 7 9 7 0.77 R.G. Reserve RG_MAR 7 7 6 0.67 Split Oak SplO_CYP 9 10 9 0.93 SplO_MAR 8 6 7 0.70 Sundew Mitigation Bank Sun_FOR_1 6 8 6 0.67 Sun_FOR_2 7 9 7 0.77 TM-Econ TMEc_CYP_1 9 7 6 0.73 TMEc_CYP_2 9 8 9 0.87 Tosohatchee Toso_FOR 8 9 9 0.87 Toso_MAR 9 9 9 0.90 Toso_SHR 8 9 8 0.83 Tupelo Mitigation Bank Tup_FOR 7 6 6 0.63 Tup_PRA 6 5 5 0.53

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69 Table 4-4. Uniform Mitigation Assessment (U MAM) scores categorized by Florida Land Use, Cover and Forms Classification Sy stem (FLUCCS) wetland community type. In addition to total UMAM score, mean ( x ) scores and standard deviation ( ) are presented for each of the three UMAM indicators: Location a nd Landscape Support, Water Environment, and Community Structure. UMAM Category 6181: Cabbage Palm Hammock 6210: Cypress 6410: Freshwater Marsh 6250: Hydric Pine Flatwoods 6120: Mangrove Swamps 6310 & 6460: Mixed Scrub Shrub Wetland 6170: Mixed Wetland Hardwood 6172: Mixed Wetland Hardwoods Mixed Shrubs 6420: Saltwater Marshes 6150: Stream and Lake Swamps (Bottomland) 6430: Wet Prairie 6300: Wetland Forested Mixed Sample size n 1 13 18 4 2 2 5 2 2 2 1 6 x 9.0 7.8 7.3 6.0 6.0 8.0 6.6 6.5 8.0 6.5 6.0 7.3 Location and Landscape Support na 1.2 1.6 1.4 2.8 0.0 1.7 0.7 0.0 0.7 na 1.0 x 8.0 8.2 8.5 6.5 7.5 7.5 8.6 8.0 8.5 6.5 5.0 7.8 Water Environment na 1.0 1.2 1.9 0.7 2.1 0.9 1.4 2.1 2.1 na 1.5 x 6.0 7.4 7.8 5.5 8.5 6.5 7.0 8.0 7.5 6.0 5.0 6.5 Community Structure na 1.4 1.2 1.7 0.7 2.1 1.4 1.4 3.5 0.0 na 1.0 x 0.77 0.78 0.79 0.60 0.73 0.73 0.74 0.75 0.80 0.64 0.53 0.72 UMAM na 0.10 0.10 0.16 0.14 0.14 0.11 0.11 0.18 0.09 na 0.10

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70 UMAM scores reflect current condition of th e assessment areas and do not indicate the beginning condition of the assessment area, nor the anticipated amount of ecological lift attributed to the mitigation plan, nor the overall status of the bank in accordance with the permitted plan. The degree of ecological improvement, or lift, in a bank determines the number of potential credits awarded and integrates changes from the beginning condition and the anticipated condition of the bank. Lift has been defined as the number of potential credits awarded per acre. Mean lift was 0.38 ( = 0.20), with a range from 0.05 (at R.G. Reserve, which had minor enhancement) to 0.88 (at Florida Wetla nds Bank, with mostly restoration). When Hole-in-the-Donut was included, the mean lift was slightly higher at 0.40 ( = 0.23), as Hole-inthe-Donut more closely resembles an in-lieu-fee bank, and has been awarded 1 credit per acre of restoration. Each data point on Figure 4-3 represents a we tland assessment area, with the UMAM score for the wetland assessment area on the y-axis (vertical) and lift or potential credits released for the entire mitigation bank on the xaxis (horizontal). No correlation was found between UMAM scores, lift, or potentia l credits released (Figure 4-3).

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71 (A) 0.0 0.2 0.4 0.6 0.8 1.0 0.00.20.40.60.81.0 Permitted Lift (credits/ac)UMAM (B) 0.0 0.2 0.4 0.6 0.8 1.0 020406080100 Potential Credit Released (%)UMAM <25% >=25, <50% >=50, <75% >75% Percent of Potential Credits Released Figure 4-3. Uniform Mitigation Assessment Me thod (UMAM) scores for the 58 assessment areas in relation to A) permit ted lift (credits/ac) in respectiv e bank and B) potential credits released (%) at respective bank.

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72 WRAP: Wetland Rapid Assessment Procedure The WRAP scale ranges from 0.001.00, with 1.00 representing the reference standard condition. WRAP has six scoring categories, each with scores ranging fr om 0.0-3.0, in 0.5 increments, and a score of 3.0 represents an intact wetland. For herbaceous wetland systems, the category of Wetland Canopy (O/S) is generally not scored; however, if the wetland assessment area had 20% or greater overstory and/or shrub canopy, a score was assigned (Miller an d Gunsalus 1999). This was the case at three of 18 wetland assessmen t areas with a wetland community type of 6410: Freshwater Marsh. A freshwater marsh at Boran Ranch, Phase I (Bora_MAR_1) received a 0.99, the highest WRAP score (Table 4-5). This wetland assessment area also r eceived the highest UMAM score of 0.93. At the other extreme, a hydric pine flatwoods at Corkscrew (Cork_FLA) received the lowest WRAP score of 0.47 (Table 4-5). No wetland assessment area receiv ed a 0.0 score in any of the six scoring categories. However, nine scores of 0.5 were assigne d for the categories of Wetland Canopy (O/S) (n = 2), Wetland Ground Cover (GC) (n = 3), Habitat Support/Buffer (n = 3), and Water Quality Input & Treatment (WQ) (n = 1). Thirty-two wetland assessment areas had WRAP scores greater than or equal to 0.75. Comparison of mean WRAP scores within FL UCCS wetland community types shows a wide variability in scores ranging from x = 0.57 ( = 0.18) for 6250 Hydric Pine Flatwoods (n = 4) to x = 0.82 ( = 0.13) for 6210 Cypress (n = 13) (Table 4-6). The highest va riability of WRAP scores within a wetland community type wa s for 6420 Saltwater Mars hes for two wetland assessment areas within Little Pine Island mitig ation bank; the same wetland assessment areas discussed earlier for UMAM. The scores ranged from 0.49 at the pre-restoration saltwater marsh (LPI_SLT_1) to 0.92 at the restor ed saltwater marsh (LPI_SLT_2). At the other extreme, the wetland community type with the smallest va riability in WRAP scores was 6120 Mangrove Swamps ( x = 0.74, = 0.02). Both of the 6120 Mangrove Swamps assessment areas at Bear Point (Bear_MAN) and CGW (CGW_MAN) scor ed 3.0 in the category of Wetland Canopy (O/S). However, total WRAP scores were lower than the optimal 1.00 score at these sites due to the influence of adjacent development, whic h generally provided p oor habitat support and buffers, limited wildlife utiliza tion, and adversely influenced we tland hydrology. As noted in the UMAM section above, assessment area scores reflect current condition at the time of site visits. No correlation was found between WRAP scores, lift, or potential credits released (Figure 4-4).

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73 Table 4-5. Wetland Rapid Assessment Pr ocedure (WRAP) scores for 58 wetland assessment areas. In addition to total WRAP score, sc ores are presented for each of the six WRAP scoring categories: Wildlife U tilization, Wetland Canopy, Wetland Ground Cover, Habitat Support/Buffer, Field Hydrology, and Water Quality Input & Treatment. Bank Name Site Code Wildlife Utilization (WU) Wetland Canopy (O/S) Wetland Ground Cover (GC) Habitat Support/Buffer Field Hydrology (HYD) WQ Input & Treatment (WQ) WRAP Barberville Barb_CYP 2.5 2.5 2.5 2.5 2.5 2.8 0.85 Barb_MAR 2.5 na 2.0 2.5 2.5 2.5 0.80 Bear Point Bear_MAN 2.5 3.0 na 2.5 2.0 1.3 0.75 Big Cypress BigC_FLA 1.5 1.0 0.5 1.4 2.0 2.5 0.49 BigC_MAR_1 2.0 2.0 2.0 2.4 3.0 3.0 0.80 BigC_MAR_2 2.0 2.5 2.0 2.1 2.5 3.0 0.78 Bluefield Ranch Blue_BOT 2.0 1.5 2.0 2.3 2.5 1.7 0.67 Blue_FLA 2.5 2.5 3.0 2.4 3.0 1.6 0.83 Blue_MAR 2.0 na 2.0 2.5 2.5 3.0 0.80 Boran Ranch, Phase I Bora_MAR_1 3.0 na 3.0 3.0 3.0 2.9 0.99 Bora_MAR_2 3.0 na 2.5 2.5 3.0 2.9 0.93 CGW CGW_MAN 2.0 3.0 3.0 1.5 2.0 1.5 0.72 Colbert-Cameron CoCa_FOR 2.5 2.0 2.5 2.5 3.0 3.0 0.86 CoCa_CYP_1 2.0 2.0 3.0 2.5 2.0 3.0 0.81 CoCa_CYP_2 2.5 2.5 2.5 2.5 3.0 3.0 0.89 Corkscrew Cork_FLA 1.5 na 0.5 1.6 2.0 1.5 0.47 East Central ECFl_FOR 2.0 2.0 0.5 2.0 2.0 3.0 0.64 ECFl_HAM 2.0 2.0 2.5 2.0 2.5 3.0 0.78 Everglades Mitigation Bank/Phase I Glad_MAR_1 2.5 na 3.0 1.6 2.5 2.1 0.78 Glad_MAR_2 2.5 3.0 2.5 2.0 2.0 2.4 0.80 Glad_SHR 3.0 2.5 3.0 2.5 2.5 3.0 0.92 Everglades Mitigation Bank/Phase II Glad_MAR_3 1.5 na 2.0 1.5 2.0 2.8 0.65 Florida Mitigation Bank FLMB_FOR 2.5 1.5 2.0 1.8 2.0 0.9 0.59 Florida Wetlandsbank FLWt_MAR_1 1.5 na 2.0 0.5 2.5 1.8 0.55 FLWt_MAR_2 1.5 na 1.5 0.5 2.5 1.8 0.52 Garcon Peninsula Garc_FLA 1.5 0.5 1.0 1.9 2.0 1.8 0.48 Graham Swamp Grhm_FOR 2.5 2.5 2.0 1.3 2.0 1.9 0.68 Hole in the Donut HID_MAR_1 3.0 na 3.0 2.6 3.0 2.5 0.94 HID_MAR_2 3.0 na 2.5 2.0 2.0 2.0 0.77 Lake Louisa and Green Swamp Loui_SHR 2.0 1.0 2.0 2.0 1.0 2.8 0.60 Lake Monroe Monr_CYP 3.0 2.0 3.0 2.5 2.0 3.0 0.86 Monr_MAR 2.0 na 2.0 2.0 3.0 2.5 0.77 Little Pine Island LPI_MAR 2.5 na 2.5 3.0 3.0 3.0 0.93 LPI_SLT_1 2.0 0.5 1.0 1.5 1.5 2.4 0.49 LPI_SLT_2 2.5 3.0 3.0 2.5 3.0 2.5 0.92

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74 Table 4-5. Continued. Bank Name Site Code Wildlife Utilization (WU) Wetland Canopy (O/S) Wetland Ground Cover (GC) Habitat Support/Buffer Field Hydrology (HYD) WQ Input & Treatment (WQ) WRAP Loblolly Mitigation Bank Lob_CYP_1 2.0 2.0 2.0 2.5 2.0 1.0 0.64 Lob_CYP_2 2.5 3.0 2.5 2.5 2.5 3.0 0.89 Loxahatchee Lox_ CYP 1.5 1.5 1.0 1.5 1.5 1.9 0.49 Lox_ FOR 1.5 2.0 2.0 0.5 2.0 1.3 0.52 Lox_SHR 1.5 2.5 2.5 1.0 2.0 1.4 0.60 Panther Island Pant_CYP_1 3.0 3.0 1.5 2.5 2.5 2.8 0.85 Pant_CYP_2 2.5 3.0 2.5 2.5 3.0 3.0 0.92 Pant_CYP_3 2.5 3.0 1.5 2.5 2.5 2.8 0.82 Pant_FOR 3.0 3.0 2.0 2.5 3.0 2.0 0.86 Reedy Creek Reed_BOT 2.0 1.5 1.5 2.1 2.0 2.2 0.63 Reed_FOR 2.0 2.0 2.0 1.5 3.0 0.5 0.61 R.G. Reserve RG_MAR 2.0 na 2.0 1.8 2.0 2.8 0.71 Split Oak SplO_CYP 3.0 3.0 2.5 3.0 3.0 3.0 0.97 SplO_MAR 2.0 na 2.0 2.4 1.5 3.0 0.73 Sundew Mitigation Bank Sun_FOR_1 2.0 2.0 1.5 2.0 2.5 1.6 0.65 Sun_FOR_2 2.0 2.0 3.0 2.0 2.5 1.6 0.73 TM-Econ TMEc_CYP_1 2.5 1.5 1.5 2.8 2.0 2.7 0.72 TMEc_CYP_2 3.0 3.0 2.5 3.0 2.5 2.9 0.93 Tosohatchee Toso_FOR 2.5 3.0 2.0 2.5 2.5 2.8 0.85 Toso_MAR 3.0 na 3.0 2.0 3.0 3.0 0.93 Toso_SHR 2.5 3.0 2.0 2.5 3.0 3.0 0.89 Tupelo Mitigation Bank Tup_FOR 2.5 2.0 2.5 2.3 1.5 2.1 0.70 Tup_PRA 1.5 1.5 1.5 2.2 1.5 2.5 0.59

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75 Table 4-6. Wetland Rapid Assessment Proce dure (WRAP) scores categorized by Florida Land Use, Cover and Forms Classification System (FLUCCS) wetland community type. Values for each wetland comm unity type include mean ( x ) and standard deviation ( ). WRAP Category 6181: Cabbage Palm Hammock 6210: Cypress 6410: Freshwater Marsh 6250: Hydric Pine Flatwoods 6120: Mangrove Swamps 6310 & 6460: Mixed Scrub Shrub Wetland 6170: Mixed Wetland Hardwood 6172: Mixed Wetland Hardwoods Mixed Shrubs 6420: Saltwater Marshes 6150: Stream and Lake Swamps (Bottomland) 6430: Wet Prairie 6300: Wetland Forested Mixed Sample size n 1 13 18 4 2 2 5 2 2 2 1 6 2.0 2.5 2.3 1.8 2.3 2.3 2.2 2.3 2.3 2.0 1.5 2.3 Wildlife Utilization (WU) na 0.5 0.5 0.5 0.4 0.4 0.4 1.1 0.4 0.0 na 0.4 2.0 2.5 2.5 1.3 3.0 2.0 2.3 2.5 1.8 1.5 1.5 2.1 Wetland Canopy (O/S) na 0.6 0.5 1.0 0.0 1.4 0.4 0.0 1.8 0.0 na 0.5 2.5 2.2 2.3 1.3 3.0 2.0 2.1 2.8 2.0 1.8 1.5 1.9 Wetland Ground Cover (GC) na 0.6 0.5 1.2 na 0.0 0.2 0.4 1.4 0.4 na 0.9 2.0 2.5 2.1 1.8 2.0 2.3 1.7 1.8 2.0 2.2 2.2 2.1 Habitat Support/Buffer na 0.4 0.7 0.4 0.7 0.4 0.9 1.1 0.7 0.1 na 0.3 2.5 2.4 2.5 2.3 2.0 2.0 2.5 2.3 2.3 2.3 1.5 2.3 Field Hydrology (HYD) na 0.5 0.5 0.5 0.0 1.4 0.5 0.4 1.1 0.4 na 0.5 3.0 2.7 2.6 1.9 1.4 2.9 1.9 2.2 2.5 2.0 2.5 1.9 WQ Input & Treatment (WQ) na 0.6 0.4 0.5 0.1 0.1 1.0 1.1 0.1 0.4 na 0.7 0.78 0.82 0.79 0.57 0.74 0.75 0.70 0.76 0.71 0.65 0.59 0.70 WRAP na 0.13 0.13 0.18 0.02 0.21 0.15 0.23 0.30 0.03 na 0.09 x x x x x x x

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76 (A) 0.0 0.2 0.4 0.6 0.8 1.0 0.00.20.40.60.81.0 Permitted Lift (credits/ac)WRAP (B) 0.0 0.2 0.4 0.6 0.8 1.0 020406080100 Potential Credit Released (%)WRAP <25% >=25, <50% >=50, <75% >75%Percent of Potential Credits Released Figure 4-4. Wetland Rapid Assessment Proc edure (WRAP) scores for the 58 assessment areas in relation to A) permitted lift (credits/ ac) in respective bank and B) potential credits released (%) at respective bank.

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77 HGM: Hydrogeomorphic Wetland Assessment Method The Hydrogeomorphic wetland assessment method ( HGM) was conducted at six flats wetlands in the Everglades and nine depressional wetlands in peninsular Florida. Flats wetlands in the Everglades HGM assessment for flats wetlands in the Everglades was divided into three subclasses of flats wetlands: marl, organic, and roc ky flats. These wetland subclasse s were distinguished based on geology, geomorphic setting, climate, soils, water source, hydrodynamics, and biota. A spatial distribution of flats wetlands in the Everglades was presented by Noble et al. (2002, see Figure 2, page 14). While the three subclasses were di stinguished primarily on soil differences and hydrology, they share similarities in wetland f unctions including unidirectional surface water flow, poorly drained soils, flat terrain, and surficial aquifer inte ractions (Noble et al. 2002). An overview of the variables used in HGM functiona l capacity index calculati ons and the functional capacity index scores for all three subclasses of fl ats wetlands in the Everglades is presented in Tables 4-7 and 4-8, respectively. Of the 12 vari ables described for func tional capacity index calculations in flats wetlands in the Everglad es, 10, 9, and 11 variables were used for marl, organic, and rocky flats wetlands respectively (Table 4-7). The two marl flats wetlands sampled were locate d in Everglades Mitigation Bank: Glad_MAR_1 in Phase I, where mitigation activities had been completed at the time of the site visit, and Glad_MAR_3 in Phase II, where no mitigation activ ities had been completed at the time of the site visit. For the marl flats wetlands in the restored wetland tract (G lad_MAR_1), 9 of the 10 variables achieved a perfect score of 1.00, wher e 1.00 reflects the reference standard condition. The only variable not receivi ng a perfect 1.00 was Emergent Macrophytic Vegetation Cover (MAC), with a score of 0.68. The marl flat s wetland in the non -restored wetland tract (Glad_MAR_3) also received high variable scores with 8 of 10 variables receiving 1.00. This wetland also received lower scores for MAC (0.40) and for Habitat Connections (CONNECT) (0.85). The two organic flats wetlands were both located within Flor ida Wetlandsbank. The variable scores for these wetlands were lower, with FLWt_MAR_1 receiving 3 (of 9) scores of 1.00 and FLWt_MAR_2 receiving 4 (of 9) scores of 1.00, where 1.00 reflec ts the reference standard condition. Both wetlands received scores of 0.00 for the variable Mi crotopographic Features (MICRO), as these wetlands had previously been rock plowed for farming and then were regraded as part of the restor ation plan to match the modele d hydrology. These wetlands also received scores less than 1.00 for Plant Spec ies Composition (COMP), Habitat Connections (CONNECT), Interior Core Area (CORE), and Wetland Tract Area (TRACT), as Florida Wetlandsbank was located in urban Broward C ounty with predominantly residential and transportation land uses in the supporting land scape. FLWt_MAR_1 also received a 0.90 score for Cover of Woody Vegetation (WOODY). The two rocky flats wetlands within Hole in th e Donut included the we tland re-graded in 1989 (HID_MAR_1) receiving 7 (of 11) scores of 1.00 and the wetland re-grade d in 2001 receiving 8 (of 11) scores of 1.00, where 1.00 reflects the reference standard condition. The younger

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Table 4-7. Hydrogeomorphic wetland assessment method ( HGM) variable for flats wetlands in the Everglades. Combinations of these 12 variables were used to calculat e wetland function scores in Table 4-8 according to equati ons from Noble et al. (200 2). MARL FLATS: ORGANIC FLATS: ROCKY FLATS: Everglades Mitigation Bank Florid a Wetlandsbank Hole in the Donut Phase I Phase II Variable Code Glad_MAR_1 Glad_MAR_3 FLWt_MAR_1 FLWt_MAR_2 HID_MAR_1 HID_MAR_2 Plant Species Composition COMP 1.00 1.00 0.76 0.55 na na Habitat Connections CONNECT 1.00 0.85 0.10 0.10 1.00 1.00 Interior Core Area CORE 1.00 1.00 0.38 0.38 1.00 1.00 Invasive Vegetation INVASIVE 1.00 1.00 1.00 1.00 1.00 1.00 Emergent Macrophytic Vegetation Cover MAC 0.68 0.40 1.00 1.00 0.65 1.00 Microtopographic Features MICRO 1.00 1.00 0.00 0.00 0.00 0.00 Number of Native Wetland Species NATIVE na na na na 1.00 1.00 Periphyton Cover PERI 1.00 1.00 na na 0.73 1.00 Soil Thickness SOILTHICK na na na na 0.70 0.20 Surface Soil Texture SURTEX 1.00 1.00 1.00 1.00 1.00 0.70 Wetland Tract Area TRACT 1.00 1.00 0.03 0.03 1.00 1.00 Cover of Woody Vegetation WOODY 1.00 1.00 0.90 1.00 1.00 1.00

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Table 4-8. Hydrogeomorphic wetland assessment method (HGM) fu nctional capacity index sco res (Function) for six flats wetlands in the Everglades. Variables in Table 4-7 were used to calculate f unctional capacity index scores according to equations from Noble et al. (2002). MARL FLATS: ORGANIC FLATS: ROCKY FLATS: Everglades Mitigation Bank Florid a Wetlands Bank Hole in the Donut Phase I Phase II Function Glad_MAR_1 Glad_MAR_3 FLWt_MAR_1 FLWt_MAR_2 HID_MAR_1 HID_MAR_2 Surface and Subsurface Water Stor age 1.00 1.00 0. 63 0.67 0.64 0.48 Cycle Nutrients 0.95 0.90 0.69 0.64 0.65 0.68 Characteristic Plant Community 0.98 0.96 0.66 0.62 0.72 0.59 Wildlife Habitat 0.96 0.90 0.56 0.53 0.81 0.81

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80 wetland (HID_MAR_2), re-graded in 2001, receiv ed scores less than 1.00 for MICRO, Soil Thickness (SOILTHICK), and Soil Surface Texture (SURTEX). Whereas, the older rocky flats wetland (HID_MAR_1), re-graded in 1989, received scores less than 1.00 for MICRO, MAC, SOILTHICK, and Periphyton Cover (PERI). When the variables presented in Table 4-7 were used to calculate the f unctional capacity index scores for the flats wetlands (Table 4-8), tw o wetlands, both at Everglades Mitigation Bank, received the highest score of 1.00 for the Su rface and Subsurface Water Storage function at Phase I (Glad_MAR_1) and Phase II (Glad_MAR_3) wetlands. The remainder of the functional capacity index scores between 0.48 and 0.98. While HGM is not designed to provide one singl e overall score of wetland function, Story et al. (1998) suggest several ways HGM could be used while establishing a single value of function. For example, averaging the four functional capac ity index scores would result in a range of scores from 0.62 at Florida Wetlandsbank (FLWt_MAR_2) to 0.97 at Everglades Mitigation Bank Phase I (Glad_MAR_1). Depressional wetlands in peninsular Florida Nine wetlands belonging to both subclasses of de pressional wetlands in pe ninsular Florida were sampled (n = 6 herbaceous marsh depressional we tlands, n = 3 cypress domes). Noble et al. (2004) described the differences in these two su bclasses mainly on visual distinction based on woody vegetation and a longer hydroperiod for cypr ess domes. The depressional wetlands HGM model had 10 variables for herbaceous marsh de pressional wetlands and 12 variables for cypress domes. All nine depressional wetlands received the maximum score of 1.00 for the variable Upland Land Use (UPUSE) (Table 4-9). Further, eigh t of nine depressional wetlands received 1.00 scores for Surface Outlet (SUROUT) and Wetla nd Volume (WETVOL), as most of these wetlands had little to no excavation or disturba nce in their interior. The exceptions were the herbaceous marsh depressional wetlands at Split Oak (SplO_MAR, SUROUT = 0.78) and Barberville (Barb_MAR, WT EVOL = 0.92), respectively. Among the herbaceous marsh depressional we tlands, the wetland asse ssment area at Lake Monroe (Monr_MAR) received a 1.00 score for 9 (o f 10) variables and received a 0.98 score for the tenth variable (MAC). Similarly, the cypr ess dome at Lake Monroe received the highest number of 1.00 variable scores for 9 (of 12) va riables. The remainder of the wetland assessment areas received between three to seven scores of 1.00 for HGM variables. The herbaceous marsh depressional wetland at Split Oak (SplO_MAR) received the lowest number of 1.00 scores for variables with 3 (of 10). When the variables were used to calculate functi onal capacity index scores for herbaceous marsh depressional wetland functions, sc ores ranged from 0.53 for Characteristic Plant Community at Split Oak (SplO_MAR) to 1.00 for Surface Wate r Storage at three wetland assessment areas including Bluefield Ranch (Blue_MAR), Lake Monroe (Monr_MAR), and R.G. Reserve (RG_MAR), and Subsurface Water Storage at one wetland at Lake Monroe (Monr_MAR) (Table 4-10). When attempting to compress HGM functional capacity indices into a single value for

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Table 4-9. Hydrogeomorphic wetland assessment method (HGM) va riable for depressional wetl ands in peninsular Florida. Combinations of these 14 variables were used to calculate wetla nd function scores in Table 4-10 ac cording to equations from Nob le et al. (2004). Herbaceous Marsh Depressional Wetlands Cypress Domes Barberville Bluefield Ranch Boran Ranch, Phase I Lake Monroe R.G. Reserve Split Oak Lake Monroe Panther Island Reedy Creek Variable Code Barb_MAR Blue_MAR Bora_MAR_1 Monr_MAR RG_MAR SplO_MAR Monr_CYP Pant_CYP_1 Reed_FOR Cypress Canopy CANOPY na na na na na na 1.00 1.00 0.40 Change in Catchment Size CATCH 0.75 1.00 0.93 1.00 1.00 0.85 0.50 0.12 1.00 Herbaceous Plant Species Composition HCOMP 0.50 0.33 0.50 1.00 0.67 0.25 na na na Macrophytic Vegetation Cover MAC 0.95 1.00 0.95 0.98 0.50 0.87 na na na Understory Vegetation Biomass SSD na na na na na na 0.88 0.90 0.08 Subsurface Outlet SUBOUT 1.00 1.00 1.00 1.00 0.15 0.00 1.00 1.00 1.00 Surface Outlet SUROUT 1.00 1.00 1.00 1.00 1.00 0. 78 1.00 1.00 1.00 Surface Soil Texture SURTEX 1.00 0.90 1.00 1.00 1.00 1.00 1.00 1.00 0.70 Tree Basal Area TBA na na na na na na 0.20 0.37 1.00 Tree Species Composition TCOMP na na na na na na 1.00 0.90 0.20 Upland Land Use UPUSE 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 Wetland Proximity WETPROX 0.99 0.70 1.00 1.00 1.00 0.10 1.00 0.10 0.82 Wetland Volume WETVOL 0.92 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 Change in the Number of Wetland Zones ZONES 0.50 0.25 0.50 1.00 0.25 0.50 1.00 1.00 0.50

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Table 4-10. Hydrogeomorphic wetland assessment method (HGM) functional capacity index sc ores (Function) for nine depressional wetlands in peninsular Florida. Variables in Table 4-9 were used to calculate functional capacity index scores according to equations from Noble et al. (2004). Herbaceous Marsh Depressional Wetlands Cypress Domes Barberville Bluefield Ranch Boran Ranch, Phase I Lake Monroe R.G. Reserve Split Oak Lake Monroe Panther Island Reedy Creek Function Barb_MAR Blue_MAR Bora_MAR_1 Monr_MAR RG_MAR SplO_MAR Monr_CYP Pant_CYP_1 Reed_FOR Surface Water Storage 0.93 1.00 0.99 1.00 1.00 0.92 0.94 0.88 0.92 Subsurface Water Storage 0.94 0.98 0.98 1.00 0.79 0.71 0.88 0.78 0.93 Cycle Nutrients 0.96 0.97 0.98 0.99 0.83 0.92 0.79 0.78 0.75 Characteristic Plant Community 0.85 0.79 0.85 0.99 0.58 0.53 0.88 0.88 0.31 Wildlife Habitat 0.87 0.76 0.87 0.99 0.69 0.56 0.93 0.82 0.61

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83 herbaceous marsh depressional wetland functions there was a large range when considering the mean (0.73-0.99), the maximum (0.92-1.00), or the minimum (0.53-0.99). Selection of any of these methods has strong impact on the overall assessment of wetland condition. In general, cypress dome wetland assessment areas scored lower than the marsh assessment areas with an overall range from 0.31 for Characteristic Plant Community at Reedy Creek (Reed_FOR) to 0.94 for Surface Water Storage at Lake Monroe (Monr_CYP) (Table 4-10). Scores for the functional capacity index category of Cycle Nutrie nts had a narrow range for all three cypress domes, with scores of 0.75, 0.78, and 0.79, at Reedy Creek (Reed_FOR), Panther Island (Pant_CYP_1), and Lake Monroe (MONR_ CYP), respectively. Once more, for cypress domes, selecting a single valu e to describe HGM would presen t a large range in scores for wetland mean ( x = 0.70-0.88), maximum (max = 0.88-0.94) or minimum (min = 0.31-0.79) functional capacity index scores. FWCI: Florida Wetland Condition Index The Florida Wetland Condition Index (FWCI) is an index of biological integrity with similar community-specific metrics for depressional herbaceous wetlands (Lane et al. 2003), depressional forested wetlands (Reiss and Br own 2005a), and forested strand and floodplain wetlands (Reiss and Brown 2005b). All three wetland classes have a FWCI developed for the macrophyte assemblage. In addition, an FWCI fo r diatom and macroinvertebrate assemblages has been developed for depressional herbaceous a nd depressional forested wetlands. This study includes macrophyte FWCI assessments for si x depressional herbaceous wetlands, three depressional forested wetlands, and one forested strand wetland. As well, macroinvertebrate FWCI assessments were completed at two depressional herbaceous wetlands and two depressional forested wetlands. Macroinvertebrate samples were not collected at the remaining six depressional wetlands, as th ese wetland assessment areas did not have a minimum of 10 cm of standing water throughout a minimum of half the wetland area, which is the minimum requirement for application of the macroinvertebrate FWCI. Macrophyte FWCI The depressional herbaceous wetland macrophyte FW CI included five metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 3) Percent of species exotic to the state of Florida (Exotic); 4) Ratio of annual to perennial species (A:P Ratio); and 5) Mean Coefficient of Conservation score based on the Floristic Quality Assessment Index (Average CC; Cohen et al. 2004). Each metric wa s assigned a score of 0, 3, 7, or 10 with total possible FWCI scores ranging from 0-50, with 50 re presenting the reference standard condition. Metric scores included two 0 scores for the Sensitive metric at Boran Ranch, Phase I (Bora_MAR_1) and for the A:P Ratio metric at Lake Monroe (Monr_MAR) (Table 4-11). The most common metric score was 3 (n = 14), followed by 7 (n = 9). Five metric scores of 10 were assigned for Sensitive and for A: P Ratio at Barberville (Barb_MAR) and for Sensitive, Exotic, and Average CC at R.G. Reserve (RG_MAR). To tal FWCI scores ranged from 12 (of 50) at Boran Ranch, Phase I (Bora_MAR_1) to 41 (of 50) at Barberville (Barb_MAR) with a mean of 26 ( = 12), translating into 24-82% of reference standard condition ( x = 52%, = 24%).

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84 Table 4-11. Macrophyte Florida Wetland Condi tion Index (FWCI) me tric scores, total FWCI scores, and percent of reference condition for six depressional herbaceous wetlands. Wetland region from Lane (2000). Bank Name Barberville Bluefield Ranch Boran Ranch, Phase I Lake Monroe R.G. Reserve Split Oak Site Code Barb_MAR Blue_MAR Bora_MAR_1 Monr_MAR RG_MAR SplO_MAR Region Central Central Central Central South Central Sensitive 10 7 0 7 10 7 Tolerant 7 3 3 3 7 3 Exotic 7 3 3 3 10 7 A:P Ratio 10 7 3 0 3 3 Average CC 7 3 3 3 10 3 FWCI 41 23 12 16 40 23 out of 50 50 50 50 50 50 % of Reference Condition 82% 46% 24% 32% 80% 46% The depressional forested wetland FWCI included si x metrics: 1) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 2) Percent of sensitive indicator species as determined from a refe rence dataset (Sensitive ); 3) Percent of species exotic to the state of Florida (Exotic); 4) Floristic Quality Assessment Index score (FQAI Score); 5) Percent of species that are both native and perennial (Native Perennial); and 5) Percent of species that are either facultative wetland or obligate species (W etland Status). For the depressional forested wetlands scoring for individua l FWCI metrics was on a con tinuous scale from 0.0-10.0, with 10.0 representing the reference standard conditio n. FWCI metric scores had a mean of 5.5 ( = 3.2) with scores assigned at both extremes, with a 0.0 for the Sensitive me tric at Panther Island (Pant_CYP_1) and a 10.0 for the Tolerant metric at Lake Monroe (Monr_CYP) (Table 4-12). Total FWCI scores ranged from 12.8 (of 60) at Panther Island to 48.3 (of 60) at Lake Monroe ( x = 33.2, = 18.3), translating into 21-81% of the reference standard condition ( x = 55%, = 31%). Five metrics were included in the forested strand and floodplain FWCI: 1)Proportion of tolerant indicator species (Tolerant); 2) Proportion of sensitive indicator species (Sensitive); 3) Floristic Quality Assessment Index score (FQAI Score); 4) Proportion of specie s exotic to Florida (Exotic); and 5) Proporti on of species that are both native a nd perennial (Nativ e Perennial). Scoring for each metric was based on a conti nuous scale from 0.0-10.0, with 10.0 representing the reference standard condition. Only the wetland assessment area at TM-Econ (TMEc_CYP_2) was included in the forested strand and floodpl ain FWCI calculations, with a range of metric scores from 7.5 for the FQAI Score metric to 9.1 for the Sensitive metric ( x = 8.3, = 0.7) (Table 4-13). The total FWCI for the wetland asse ssment area (TMEc_CYP_2) was 41.7 (of 50), translating into 83% of the reference standard condition.

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85 Table 4-12. Macrophyte Florida Wetland Condi tion Index (FWCI) me tric scores, total FWCI scores, and percent of reference condition for three depressional forested wetlands. Wetland region from Lane (2000). Bank Name Lake Monroe Panther Island Reedy Creek Site Code Monr_CYP Pant_CYP_1 Reed_FOR Region Central South Central Tolerant 10.0 3.5 9.8 Sensitive 6.6 0.0 1.5 Exotic 8.1 2.3 6.3 FQAI Score 8.9 0.5 4.6 Native Perennial 8.0 2.3 8.1 Wetland Status 6.7 4.3 8.2 FWCI 48.3 12.8 38.5 out of 60 60 60 % of Reference Condition 81% 21% 64% Table 4-13. Macrophyte Florida Wetland Condi tion Index (FWCI) me tric scores, total FWCI score, and percent of reference condition for a forested strand wetland within TMEcon Mitigation Bank. Wetland region from Lane (2000). Bank Name TM-Econ Site Code TMEc_CYP_1 Region Central Tolerant 7.9 Sensitive 9.1 FQAI Score 7.5 Exotic 8.2 Native Perennial 9.0 FWCI 41.7 out of 50 % of Reference Condition 83%

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86 Macroinvertebrate FWCI The depressional herbaceous wetland macroinverteb rate FWCI included five metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 3) Percent of macroinvertebrates in the pred ator functional feeding group (P redators); 4) Percent of macroinvertebrates in the order Odonata, which includes dragonflies and damselflies (Odonata); and 5) Percent of macroinvertebra tes in the subfamily Orthocladinae, a subfamily in the family Chironomidae (Orthocladinae). Scoring for the depressional herbaceous wetland macroinvertebrate FWCI assigned scores of 0, 3, 7, or 10 to each of the five metrics with total possible FWCI scores ranging from 0-50, with 50 re presenting the reference standard condition. Only two wetland assessment areas were sampled, with a majority of the metric scores (6 of 10) assigned scores of 10 (Table 4-14) One metric was scored a 0 fo r the Odonata metric at Boran Ranch, Phase I (Bora_MAR_1). The remaining th ree metric scores were 7 for the Tolerant metric at Barberville (Barb_MAR) and the Sens itive and Predators metrics at Boran Ranch, Phase I (Bora_MAR_1). Total FWCI scores were 34 (of 50) at Boran Ranch, Phase I (Bora_MAR_1) and 47 (of 50) at Barberville (B arb_MAR), reflecting 68% and 94% of reference standard condition, respectively. Six metrics were included in the depressiona l forested wetland macroinvertebrate FWCI: 1) Percent of sensitive indicator species as determ ined from a reference dataset (Sensitive); 2) Percent of tolerant indicator sp ecies as determined from a reference dataset (Tolerant); 3) Calculated score from the Flor ida Index (Florida Index; see Beck 1954, Barbour et al. 1996); 4) Percent of macroinvertebrates in the phylum Mollu sca, including snails and bivalves (Mollusca) 5) Percent of macroinvertebrates in the family Noteridae, the burrowing water beetles (Noteridae); and 6) Percent of macroinvertebrates in the scraper functional feeding group (Scrapers). Each metric was sc ored between 0-10, with 10 representing th e reference standard condition. Metric scores were summed for a final index ranging from 0-60, with 60 representing the reference standard condition. Two wetland assessment areas were assessed using the depressional forested wetland macroinvertebrate FW CI (Table 4-15). The lowest metric score was 0.0 for the Scrapers metric for the wetland as sessment area at Panther Island (Pant_CYP_1). This wetland assessment area also received a scor e of 0.1 for the Florida Index metric. Four of the metrics scored above 5.0, the midpoint of the scale, including the Tole rant metric (6.1) for the wetland assessment area at Panther Island (Pant_CYP_1) and the Tolerant (7.1), Florida Index (6.5), and Mollusca (5.2) metrics for the wetland assessment area at Reedy Creek (Reed_FOR). Total FWCI scores reflected less than 50% of the reference standard condition, with a 15.3 (of 60) at Panther Island (Pan t_CYP_1) and 27.1 (of 60) at Reedy Creek.

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87 Table 4-14. Macroinvertebrate Florida Wetla nd Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference co ndition for two depressional herbaceous wetlands. Wetland region from Lane (2000). Bank Name Barberville Boran Ranch, Phase I Site Code Barb_MAR Bora_MAR_1 Region (Lane 2000) Central Central Sensitive 10 7 Tolerant 7 10 Predators 10 7 Odonata 10 0 Orthocladinae 10 10 FWCI 47 34 out of 50 50 % of Reference Condition 94% 68% Table 4-15. Macroinvertebrate Florida Wetla nd Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for two depressional forested wetlands. Wetland region from Lane (2000). Bank Name Panther Island Reedy Creek Site Code Pant_CYP_1 Reed_FOR Region South Central Sensitive 2.7 3.5 Tolerant 6.1 7.1 Florida Index 0.1 6.5 Mollusca 3.8 5.2 Noteridae 2.6 1.9 Scrapers 0.0 2.9 FWCI 15.3 27.1 out of 60 60 % of Reference Condition 26% 45%

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88 LDI: Landscape Development Intensity Index Wetland scale LDI index scores were calculated for each of th e 58 wetland assessment areas. The mean wetland scale LDI index score was 3.17 ( = 4.89) with a median of 0.26 and a range from 0.00-16.65 (Table 4-16). The distribution of LDI index scores was non-normal (ShapiroWilk W = 0.7029, p < 0.01), with 16 wetland asse ssment areas with wetland scale LDI index scores of 0.00 and an additional 19 wetland scale LDI index scores less than 1.00. Nine wetland scale LDI index scores were greater than 10.00. Recall that the wetland scale LDI index was calculated as a potential score, as the surr ounding landscapes within the wetland mitigation bank may not yet be fully enhanced, restored, or created, although it is assume d that they will as a result of the permitted mitigation activities and after final success criteria have been met, and were accordingly assigned scores for natural lands. Bank scale LDI index scores were higher, with a mean bank scale LDI index score of 7.78 ( = 5.36), a median of 6.54, and a range from 0.00-18.22 (Tab le 4-16). Only Litt le Pine Island had a bank scale LDI index score of 0.00, with two additional mitigation banks (East Central and Graham Swamp) having bank scale LDI index scor es less than 1.00. Th e wetland assessment areas at East Central (ECFl_HAM and ECFl_FOR ) had wetland scale LDI index scores of 0.00 (compared to bank scale LDI index score of 0.32) ; whereas, Graham Swamp had a difference of 11.43 between the higher wetland scale LDI inde x (11.91) and lower bank scale LDI index (0.48), an indication that the s cale of delineation of land uses within the GIS interface has important implications for LDI cal culations (i.e., bank scale LDIs were calculated based on the WMD 2000 land use cover (LU00) where land use was delineated at a scale of 1:12,000; whereas wetland scale LDIs were calculated at a much finer grain, base d on hand delineation of land uses around the wetland assessment areas digi tally drawn on the digital orthopohoto quarter quads updated during the 2005 field vi sit). Eight banks had bank s cale LDI index scores greater than 10.00, with Florida Wetlandsbank having the hi ghest bank scale LDI index score of 18.22. A weak correlation was found between wetland scal e LDI index and bank s cale LDI index scores (r = 0.27, p < 0.05) (Figure 4-5). A large number of wetland assessment areas had wetland scale LDI scores of 0.00 (n = 16). Thes e sites were typically located in the interior portion of the wetland mitigation bank, or at least 100 m from the surrounding properties and therefore were buffered from surrounding land use activities by other areas within the mitigation bank boundaries. Consideration of potential wetland functional lift should incorporate both the wetland scale and bank scale LDI index, reflecti ng both the local and broad scale landscape support.

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89 Table 4-16. Landscape Developmen t Intensity (LDI) index scores. Wetland scale LDI index scores were based on hand delinea tion of land uses around the wetla nd assessment ar eas digitally drawn on the digital orthopohoto quarter quads upda ted during the 2005 field visit. Bank scale LDI index scores were based on delineation of land use within a 100 m zone around the wetland mitigation bank boundary using 2000 land use cover maps from the WMD (LU00). The mitigation bank outline was not available for Bora n Ranch Phase I (only Boran Ranch Phase II). Everglades Mitigation Bank has one bank scale LDI index, as the outline available was combined for Phases I and II. Year 2000 land use was not available for Garcon Peninsula. Bank Name Site Code Wetland Scale LDI Index Bank Scale LDI Index Barberville Barb_ CYP 0.10 9.39 Barb_ MAR 0.04 9.39 Bear Point Bear_MAN 6.92 6.59 Big Cypress BigC_FLA 1.74 4.63 BigC_MAR_1 5.87 4.63 BigC_MAR_2 0.00 4.63 Bluefield Ranch Blue_BOT 0.29 3.74 Blue_FLA 1.55 3.74 Blue_MAR 0.00 3.74 Boran Ranch, Phase I Bora_MAR_1 0.00 NC Bora_MAR_2 4.42 NC CGW CGW_MAN 0.16 9.85 Colbert-Cameron CoCa_ CYP_1 5.18 4.81 CoCa_CYP_2 0.00 4.81 CoCa_ FOR 0.00 4.81 Corkscrew Cork_FLA 0.00 6.01 East Central ECFl_HAM 0.00 0.32 ECFl_FOR 0.00 0.32 Everglades Mitigation Bank Glad_MAR_1 13.69 11.58 Phase I Glad_MAR_2 8.30 11.58 Glad_SHR 0.00 11.58 Everglades Mitigation Bank Phase II Glad_MAR_3 6.51 11.58 Florida Mitigation Bank FLMB_FOR 0.80 10.65 Florida Wetlandsbank FLWt_MAR_1 16.65 18.22 FLWt_MAR_2 13.00 18.22 Garcon Peninsula Garc_FLA 12.55 NC Graham Swamp Grhm_FOR 11.91 0.48 Hole in the Donut HID_MAR_1 7.45 3.70 HID_MAR_2 13.10 3.70 Lake Louisa and Green Swamp Loui_SHR 0.00 2.87

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90 Table 4-16. Continued. Bank Name Site Code Wetland Scale LDI Index Bank Scale LDI Index Lake Monroe Monr_CYP 0.05 10.46 Monr_MAR 0.01 10.46 Little Pine Island LPI_MAR 0.00 0.00 LPI_SLT_1 2.01 0.00 LPI_SLT_2 10.77 0.00 Loblolly Mitigation Bank Lob_CYP_1 1.00 10.86 Lob_CYP_2 0.28 10.86 Loxahatchee Lox_ CYP 15.72 17.03 Lox_ FOR 10.93 17.03 Lox_SHR 6.51 17.03 Panther Island Pant_CYP_1 0.22 9.90 Pant_CYP_2 0.02 9.90 Pant_CYP_3 0.01 9.90 Pant_FOR 0.00 9.90 Reedy Creek Reed_BOT 2.28 8.12 Reed_FOR 0.00 8.12 R.G. Reserve RG_MAR 0.01 6.48 Split Oak SplO_CYP 0.03 1.25 SplO_MAR 0.80 1.25 Sundew Mitigation Bank Sun_FOR_1 0.59 16.04 Sun_FOR_2 0.23 16.04 TM-Econ TMEc_CYP_1 1.26 17.84 TMEc_CYP_2 0.02 17.84 Tosohatchee Toso_FOR 0.00 5.43 Toso_ MAR 0.00 5.43 Toso_ SHR 0.00 5.43 Tupelo Mitigation Bank Tup_FOR 0.52 5.91 Tup_PRA 0.14 5.91 NC none calculated

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0 2 4 6 8 10 12 14 16 18 20LPI_MAR LPI_SLT_1 LPI_SLT_2 ECFl_HAM ECFl_FOR Grhm_FOR SplO_CYP SplO_MAR Loui_SHR HID_MAR_1 HID_MAR_2 Blue_BOT Blue_FLA Blue_MAR BigC_FLA BigC_MAR_1 BigC_MAR_2 CoCa_CYP_1 CoCa_CYP_2 CoCa_FOR Toso_FOR Toso_MAR Toso_SHR Tup_FOR Tup_PRA Cork_FLA RG_MAR Bear_MAN Reed_BOT Reed_FOR Barb_CYP Barb_MAR CGW_MAN Pant_CYP_1 Pant_CYP_2 Pant_CYP_3 Pant_FOR Monr_CYP Monr_MAR FLMB_FOR Lob_CYP_1 Lob_CYP_2 Glad_MAR_1 Glad_MAR_2 Glad_SHR Glad_MAR_3 Sun_FOR_1 Sun_FOR_2 Lox_ CYP Lox_ FOR Lox_SHR TMEc_CYP_1 TMEc_CYP_2 FLWt_MAR_1 FLWt_MAR_2Wetland Assessment Area (n=55)LDI Inde x Wetland Scale LDI Index Bank Scale LDI Index Figure 4-5. Wetland scale (light blue ba rs) and bank scale (dark green bars) Land scape Development Intensity (LDI) index scores for 55 wetland assessment areas (identified by site code).

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92 Comparison of Assessment Methods Comparisons were made between the five assessment methods used (UMAM, WRAP, HGM, FWCI, and LDI). Each assessment method was based on wetland condition using field observations, field sampling and m easurements, laboratory taxonomic id entification, and/or GIS. General comparison among UMAM, WRAP, and LDI we re most robust, with a sample size of 58 wetland assessment areas, while comparisons of HGM or FWCI (macrophyte and macroinvertebrate) with other assessment meth ods were more limited due to much smaller sample sizes (15, 10, and 4, respectively). Statis tical analyses were perf ormed using Analyse-It Software, Ltd., version 1.67 (1997-2003). UMAM and WRAP Half (n = 29) of the wetland assessment areas ha d UMAM scores greater than 0.75 (Table 4-3). Results were similar for WRAP assessments, as 31 of the wetland assessment areas (53%) had scores greater than 0.75 (Table 4-5). WRAP and UMAM scores for the 58 wetland assessment areas showed a strong positive correlation (Sp earman rank correlation r = 0.87, p < 0.01) (Figure 4-6). While it is not considered appropriate to compare scores for diffe rent wetland community types, UMAM and WRAP scores for each assessm ent area should be comparable to each other as a set, due to similarity in assessment me thod design and intent. Given the similar scoring criteria and scale, a wetland assessment area may be expected to achieve equal UMAM and WRAP scores. Comparison between UMAM and WRAP scores fo r the various wetland community types shows that there was no significant difference based on community types regarding whether the UMAM or WRAP score was higher (Figure 4-6) The difference between UMAM and WRAP scores at each wetland assessmen t area ranged from -0.15 to 0.18 (Figure 4-7), with two wetland assessment areas, a hydric pine flatwoods wetland assessment area at Bluefield Ranch (Blue_FLA; UMAM, WRAP = 0.83) and a fres hwater marsh at Boran Ranch, Phase I (BORA_MAR_2; UMAM, WRAP = 0.93), having no difference between UMAM and WRAP scores. Two freshwater marsh organic flats wetland assessment areas at Florida Wetlandsbank (FLWt_MAR_1 and FLWt_MAR_2) and a saltwate r marsh wetland assessment area at Little Pine Island (LPI_SLT_1) had the largest differe nce between UMAM and WRAP scores of 0.18 (FLWt_MAR_1 UMAM = 0.73, WRAP = 0.55; FLWt_MAR_2 UMAM = 0.70, WRAP 0.52; LPI_SLT_1 UMAM = 0.67, WRAP = 0.49). However, the mean difference between UMAM and WRAP scores was 0.00 ( = 0.08), suggesting that as a group, UMAM and WRAP scores were similar. A simple linear regression analysis performe d between UMAM and WRAP scores for the 58 wetland assessment areas showed a positive correlation (R2 = 0.72, p < 0.01, fitted regression line shown), a narrow 95% confid ence interval (middle dashed lines), and a wide prediction interval band (bold outer lines), suggesting the fitted regression line wa s not a good fit and that accurate or useful prediction of future UMAM scores are not possible based on WRAP scores (Figure 4-8). Use of a linear regression was possible due to the norma l distribution of the UMAM scores dataset (Shapiro-Wilk test) and apparent constant variance over the sampling range.

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0.0 0.2 0.4 0.6 0.8 1.0 0.00.20.40.60.81.0 WRAPUMAM 6181 Cabbage Palm Hammock 6210 Cypress 6410 Freshwater Marsh 6250 Hydric Pine Flatwoods 6120 Mangrove Swamps 6460 & 6310 Mixed Scrub Shrub 6170 Mixed Wetland Hardwood 6172 Mixed Wetland HardwoodShrubs 6420 Saltwater Marshes 6150 Stream and Lake Swamps (Bottomland) 6430 Wet Prairie 6300 Wetland Forested Mixed Figure 4-6. Uniform Miti gation Assessment Method (UMAM) and Wetlan d Rapid Assessment Procedure (WRAP) were positively correlated (Spearman rank correlation r = 0.87, p < 0.01). The line shown represents the 1:1 line.

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-0.20 -0.15 -0.10 -0.05 0.00 0.05 0.10 0.15 0.20Pant_CYP_1 BigC_MAR_1 Pant_CYP_2 Glad_SHR CGW_MAN CoCa_CYP_1 Grhm_FOR Barb_CYP Blue_MAR Tup_FOR CoCa_CYP_2 TMEc_CYP_2 LPI_MAR Toso_SHR Reed_BOT Bora_MAR_1 CoCa_FOR Tup_PRA BigC_MAR_2 Glad_MAR_3 Pant_CYP_3 SplO_CYP RG_MAR SplO_MAR Barb_MAR Toso_MAR Lob_CYP_2 BigC_FLA ECFl_HAM HID_MAR_1 Bora_MAR_2 Blue_FLA TMEc_CYP_1 LPI_SLT_2 Toso_FOR Sun_FOR_1 Glad_MAR_2 Blue_BOT Lob_CYP_1 Monr_MAR Cork_FLA Loui_SHR Monr_CYP Pant_FOR Sun_FOR_2 Glad_MAR_1 HID_MAR_2 ECFl_FOR Lox_SHR Lox_CYP Bear_MAN FLMB_FOR Garc_FLA Lox_FOR Reed_FOR FLWt_MAR_1 FLWt_MAR_2 LPI_SLT_1Wetland Assessment Areas (n=58)Difference UMAM WRAP Figure 4-7. The difference between Un iform Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas. Light colored bars (n = 30) show higher WRAP scores; dark colored bars (n = 26) show higher UMAM.

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95 y = 0.68x + 0.24 R2 = 0.72, p < 0.01 0.4 0.5 0.6 0.7 0.8 0.9 1.0 0.40.50.60.70.80.91.0 WRAPUMAM Figure 4-8. Linear regression between Un iform Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas (R2 = 0.72, p < 0.01, fitted regression line shown). Middle dashed lines are 95% confidence interval and bold outer lines are prediction interval band. Given the similarities in the UMAM and WRAP scoring categories and application of the methods, correlations were expected among the many scoring categories for each method. In fact, of the 55 pair wise comparisons between UMAM and its three scoring categories (Location and Landscape Support, Water Environment, and Community Structure) and WRAP and its six scoring categories (Wildlife Utilization (WU), Wetland Canopy (O/S), Wetland Ground Cover (GC), Habitat Support/Buffer, Field Hydrology ( HYD), WQ Input & Treatment (WQ)), 52 pair wise comparisons were statis tically correlated (S pearman rank correlation r > 0.25, p < 0.05; Table 4-17). The three non-si gnificant comparisons were for WRAP WQ Input & Treatment (WQ) with UMAM Water Environment, WR AP Wetland Canopy (O/S), and WRAP Wetland Ground Cover (GC).

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96 UMAM, WRAP, and LDI The distribution of scores for both wetland s cale and bank scale LD I index were non-normal (Shapiro-Wilk W = 0.69; W = 0.94, respectiv ely, p < 0.01), therefore the Spearman rank correlation was used for comparisons, as this correlation does not rely on the assumption of normal distributions and it does no t anticipate a lin ear correlation among variables. Recall that the wetland scale LDI index was calculated as the potential for a wetland assessment area. That is, given successful restoration, creation, enhancement, or preservation in the adjacent landscape, the wetland scale LDI index value re flects the lowest potential wetland scale LDI index score and in turn the highest potenti al ecological integrity possible for a wetland assessment area once mitigation is complete and successful restoration of wetland function is achieved. Overall UMAM scores were not significantly correlated with wetland scale or bank scale LDI index scores (Table 4-17). However the UMAM scoring category Location and Landscape Support was significantly correlated with both the wetland scale LDI index (Spearman rank correlation r = -0.36, p < 0.01) (Figure 4-9A) and bank scale LDI index (r = -0.30, p < 0.05) (Figure 4-9B). Bardi et al. (2005) suggested usi ng a modified form of the LDI index scaled to match UMAM scoring, as a tool to assist in scoring UMAM. As the support landscape within mitigation banks undergoes further restoration a nd/or enhancement, th e correlation between UMAM Location and Landscape Support and wetla nd scale LDI index may strengthen. UMAM Water Environment and UMAM Community Structur e scoring categories we re not statistically significant with either wetland scal e or bank scale LDI index scores. Overall WRAP scores were sign ificantly correlated with wetl and scale LDI index scores (r = -0.36, p < 0.01) (Figure 4-10A), though not with bank scale LDI index scores. In addition, wetland scale LDI index scores we re significantly correlated with WRAP Habitat Support/Buffer (r = -0.39, p < 0.01) (Figure 410B), WRAP Field Hydrology (HYD) (r = -0.27, p < 0.05) (Figure 4-10C), and WRAP WQ Input & Treatmen t (WQ) (r = -0.49, p < 0.01) (Figure 4-10D). Bank scale LDI index scores were also correlated with WRAP WQ Input & Treatment (WQ) (r = -0.37, p < 0.01) (Figure 4-11). HGM and FWCI Comparisons between HGM and FW CI with the other three met hods (UMAM, WRAP, and LDI) were limited due to the relatively small sample size of HGM assessments (n = 15), macrophyte FWCI assessments (n = 10), and macroinverte brate FWCI assessments (n = 4), though some interesting trends were apparent with even this small dataset. One statistically significant correlation was found in the comparison of to tal WRAP score with HGM Wildlife Habitat (Spearman rank correlation r = 0.55, p < 0.05) (Table 4-18). This correlation used scores for all 15 HGM assessments, which included a mixture of flats wetlands in the Everglades and depressional wetlands in peninsul ar Florida. WRAP was originally designed for compliance assessment of wetlands in South Florida, includi ng Everglades and depre ssional wetlands in the southern portion of the Florid a peninsula. Two additional si gnificant correlations were found between WRAP scoring categories and HGM func tional capacity index scores: WRAP Field Hydrology (HYD) and HGM Subsurface Water St orage (r = 0.75, p < 0.05) and WRAP WQ

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Table 4-17. Pair wise comparisons among scoring categories and total scores for the Unifor m Mitigation Assessment Method (UMAM), Wetland Rapid Assessment Procedures (WRAP), wetla nd scale Landscape Development Intensity (LDI) index, and bank scale LDI index. All reported comparisons we re significant (p < 0.05). UMAM UMAM Location and Landscape Support UMAM Water Environment UMAM Community Structure WRAP WRAP Wildlife Utilization (WU) WRAP Wetland Canopy (O/S) WRAP Wetland Ground Cover (GC) WRAP Habitat Support/Buffer WRAP Field Hydrology (HYD) WRAP WQ Input & Treatment (WQ) Wetland Scale LDI Index UMAM Location and Landscape Support 0.77 x UMAM Water Environment 0.83 0.42 x UMAM Community Structure 0.85 0.47 0.67 x WRAP 0.87 0.73 0.65 0.74 x WRAP Wildlife Utilization (WU) 0.78 0.74 0.54 0.64 0.83 x WRAP Wetland Canopy (O/S) 0.69 0.33 0.61 0.80 0.76 0.63 x WRAP Wetland Ground Cover (GC) 0.66 0.46 0.49 0.71 0.68 0.55 0.48 x WRAP Habitat Support/Buffer 0.66 0.72 0.38 0.45 0.8 0.69 0.49 0.35 x WRAP Field Hydrology (HYD) 0.72 0.40 0.80 0.55 0.71 0.47 0.54 0.41 0.46 x WRAP WQ Input & Treatment (WQ) 0.41 0.50 NS 0.27 0.63 0.35 NS NS 0.54 0.31 x Wetland Scale LDI Index NS -0.36 NS NS -0.36 NS NS NS -0.39 -0.27 -0.49 x Bank Scale LDI Index NS -0.3 NS NS NS NS NS NS NS NS -0.37 0.27 Values reflect Spearman rank co rrelation coefficient (r value) NS Not significant

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98(A) (B) 0 2 4 6 8 10 048121620 Wetland Scale LDI IndexUMAM Location and Landscape Support 0 2 4 6 8 10 048121620 Bank Scale LDI IndexUMAM Location and Landscape Support .r = -0.36, p < 0.01 r = -0.30, p < 0.05 Figure 4-9. Correlations among Unifor m Mitigation Assessmen t Method (UMAM) Location and Landscape Support scoring ca tegory with A) wetland scale Landscape Development Intensity (LDI) index scores and B) bank scale LDI index scores.

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99(A)(B) (C)(D) 0.0 0.2 0.4 0.6 0.8 1.0 048121620 Wetland Scale LDI IndexWRAP .r = -0.36, p < 0.01 0 1 2 3 048121620 Wetland Scale LDI IndexWRAP Habitat Support/Buffer 0 1 2 3 048121620 Wetland Scale LDI IndexWRAP Field Hydrology (HYD) 0 1 2 3 048121620 Wetland Scale LDI IndexWRAP WQ Input & Treatment (WQ) .r = -0.27, p < 0.05 r = -0.39, p < 0.01 r = -0.49, p < 0.01 Figure 4-10. Wetland Rapid Assessment Pr ocedure (WRAP) correlations with wetland scale Landscape Development Intensity (LDI) index: A) Overall WRAP scores ; B) WRAP Habitat Support/Buffer scores; C) WRAP Fiel d Hydrology (HYD) scores ; and D) WRAP WQ Input & Treatment (WQ) scores.

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100 0 1 2 3 048121620 Bank Scale LDI IndexWRAP WQ Input & Treatment (WQ) .r = -0.37, p < 0.01 Figure 4-11. Bank scale Landscape Developmen t Intensity (LDI) index score correlations: A) Wetland Rapid Assessment Procedure (WRAP) WQ Input & Treatment (WQ) scores; and B) wetland scale LDI index scores.

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Table 4-18. Correlations among Uniform Mitigation Assessment Method (UMAM) and scoring categories, Wetland Rapid Assessment Procedure (WRAP) and scoring categories, wetland scale Landscape Development Intensity (LDI) index scores, bank scale LDI index scores, Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores, macrophyte Florida Wetland Condition Index (FWCI) scores, and macroinvertebrate FWCI scores. Only significant correlations (p < 0.05) are shown. HGM Subsurface Water Storage HGM Surface and Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat WRAP NS NS NS NS 0.55 WRAP Field Hydrology (HYD) 0.75NS NS NS NS WRAP WQ Input & Treatment (WQ) NS NS 0.53NS NS Wetland Scale LDI Index -0.72NS -0.56NS NS HGM Cycle Nutrients 0.71NS x x x HGM Characteristic Plant Community NS 0.81 NS x x HGM Wildlife Habitat NS NS 0.560.88x Values reflect Spearman rank co rrelation coefficient (r value) NS Not significant

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102 Input & Treatment (WQ) and HGM Cycle Nutrie nts (r = 0.53, p < 0.05). These same two HGM functional capacity index scores, HGM Subs urface Water Storage and HGM Cycle Nutrients were significantly correlated with wetland scale LDI index (r = -0.72, p < 0.05; r = -0.56, p < 0.05, respectively). Comparisons among the HGM functional capacity index scores revealed four significant correlations within HGM: HGM Subsurface Water Storage and HGM Cycle Nutrients (r = 0.71, p < 0.05), HGM Surface and Subsurface Water Storage and HGM Characteristic Plant Community (r = 0.81, p < 0.05), and HGM Wildlife Habitat with both HGM Cycle Nutrients (r = 0.56, p < 0.05) and HGM Characteristic Plant Community (r = 0.88, p < 0.01). Neither the macrophyte nor macroinvertebrate FWCI scores were significan tly correlated with UMAM and UMAM scoring catego ries, WRAP and WRAP scoring categories, wetland scale or bank scale LDI scores, HGM functio nal capacity index scores, or one another. Further, UMAM, UMAM scoring categories, and bank scale LDI i ndex were not significantly correlated with HGM functional capacity index scores. Each of the five assessment methods measured wetland condition as compared to the reference standard condition. As such, co mparisons have been made by sc aling each assessment score to represent the percent of the reference standard conditi on. UMAM, WRAP, macrophyte FWCI, macroinvertebrate FWCI, and wetland scale LDI (Table 4-19) and HGM variables (Table 4-20) scores presented as percent of reference standa rd condition provide a comp lex picture of wetland assessment, as shown in three examples below. The depressional forested wetland at Reedy Creek (Reed_FOR) scored 77% for UMAM, 61% for WRAP, 64% on macrophyte FWCI, and 45% on the macroinvertebrate FWCI (Table 4-19). This same wetland assessment area scored 31% of the reference standard condition for the HGM variable Characteristic Plant Community and 93% for the HGM variable Surface Water Storage variable (Table 4-20). The wetland scale LDI index was 0.00, suggesting that this wetland assessment area has the potential to provide fu ll wetland function in the future, based on complete restoration of surroundi ng lands within the bank. However, the bank scale LDI for Reedy Creek was 8.12, as the land surrounding th e bank hosts some human activities. The depressional marsh at Barberville (Barb_M AR) reflected 85-96% of the reference wetland condition for all of the HGM fu nctional capacity index scores Scores for the remaining assessment methods were more variable, fr om 77% for UMAM, 80% for WRAP, 82% for macrophyte FWCI, and 94% for macroinvertebrate FW CI. Another interest ing case was one of the organic flats marshes in Florida Wetlands bank (FLWt_MAR_1), which received a wetland scale LDI index of 16.65, yet received higher percentages of reference standard condition according to UMAM (73%), WRAP (55%), and HGM functional capacity index scores from 5669%. The variability in scoring percentages for th is wetland assessment area was large, and it is unclear which, if any, assessment method provided a more accurate picture of current wetland condition. A simple average am ong the assessment methods ( x = 0.64, = 0.07) offers an incomplete description of the current wetland condition.

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Table 4-19. Percent of reference standard conditions for Un iform Mitigation Assessment Met hod (UMAM), Wetland Rapid Assessment Procedure (WRAP), macrophyte Florida Wetland Condition Index (FWCI), and macroinvertebrate FWCI assessment methods for 16 wetland assessment areas. Mitigation Bank Site Code Wetland Type UMAM WRAP Macrophyte FWCI Macroinvertebrate FWCI Lake Monroe Monr_CYP Cypress 90% 86% 81% na Panther Island Pant_CYP_1 Cypress 70% 85% 21% 26% Reedy Creek Reed_FOR Cypress 77% 61% 64% 45% TM-Econ TMEc_CYP_1 Forested Strand 73% 72% 83% na Barberville Barb_MAR Marsh 77% 80% 82% 94% Bluefield Ranch Blue_MAR Marsh 73% 80% 46% na Boran Ranch, Phase I Bora_MAR_1 Marsh 93% 99% 24% 68% Lake Monroe Monr_MAR Marsh 80% 77% 32% na R.G. Reserve RG_MAR Marsh 67% 71% 80% na Split Oak SplO_MAR Marsh 70% 73% 46% na Everglades Mitigation Bank Phase I Glad_MAR_1 Marl Flats 83% 78% na na Everglades Mitigation Bank Phase II Glad_MAR_3 Marl Flats 60% 65% na na Florida Wetlandsbank FLWt_MAR_1 Organic Flats 73% 55% na na Florida Wetlandsbank FLWt_MAR_2 Organic Flats 70% 52% na na Hole in the Donut HID_MAR_1 Rocky Flats 93% 94% na na Hole in the Donut HID_MAR_2 Rocky Flats 83% 77% na na

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Table 4-20. Percent of reference standard conditions for Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores for 15 wetland assessment areas. Mitigation Bank Site Code Wetland Type HGM Surface Water Storage HGM Subsurface Water Storage HGM Surface and Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat Lake Monroe Monr_CYP Cypress 94% 88% na 79% 88% 93% Panther Island Pant_CYP_1 Cypress 88% 78% na 78% 88% 82% Reedy Creek Reed_FOR Cypr ess 92% 93% na 75% 31% 61% Barberville Barb_MAR Marsh 93% 94% na 96% 85% 87% Bluefield Ranch Blue_MAR Marsh 100% 98% na 97% 79% 76% Boran Ranch, Phase I Bora_MAR_1 Marsh 99% 98% na 98% 85% 87% Lake Monroe Monr_MAR Marsh 100% 100% na 99% 99% 99% R.G. Reserve RG_MAR Marsh 100% 79% na 83% 58% 69% Split Oak SplO_MAR Marsh 92% 71% na 92% 53% 56% Everglades Mitigation Bank Phase I Glad_MAR_1 Marl Flats na na 100% 95% 98% 96% Everglades Mitigation Bank Phase II Glad_MAR_3 Marl Flats na na 100% 90% 96% 90% Florida Wetlandsbank FLWt_MAR_1 Organic Flats na na 63% 69% 66% 56% Florida Wetlandsbank FLWt_MAR_2 Organic Flats na na 67% 64% 62% 53% Hole in the Donut HID_MAR_1 Rocky Flats na na 64% 65% 72% 81% Hole in the Donut HID_MAR_2 Rocky Flats na na 48% 68% 59% 81%

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105 Further sampling and analysis with the detailed biological assessm ents methods is suggested, as this would provide for more robust comparisons among methods. However, inspection of the percentage of reference standard condition reflected in the 16 wetland assessment areas with HGM and/or FWCI assessments shows that few if any of these wetlands are providing maximum function according to the comparison to the refe rence standard condition (Figures 4-12, 4-13, 414). There was a general ( 10-20%) agreement in the range of sc ores for the majority of these assessment methods at each site, though no clear trend was apparent based on higher or lower representation of reference standard condition by assessment method or by potential credits released. For the six Everglades flats we tlands there was no clear trend between which assessment method presented the highest percent of reference condition as measured by UMAM, WRAP, or HGM (Figure 4-12). Similarly, for th e six depressional herbace ous wetlands, scores were variable, though scores for one of the HGM functional indices was often the highest assessment with the exception of the herbaceous marsh at Split Oak (SplO_MAR), where the WRAP score (0.97) was the highest measured a ssessment score (Figure 4-13). For the three forested depressional wetlands, HGM was also the highest assessment score, and for the forested strand wetland (where no HGM was conduc ted) the macrophyte FWCI was the highest assessment score (Figure 4-14).

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0% 20% 40% 60% 80% 100% Glad_MAR_3HID_MAR_1HID_MAR_2Glad_MAR_1FLWt_MAR_2FLWt_MAR_1Percent of Reference Condition UMAM WRAP HGM Surface and Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat10% 33% 33% 90% 99% 99% Potential Credits Released per Respective Bank Figure 4-12. Comparison among six Everg lades flats wetlands of UMAM (solid bars), WRAP (white bars), and HGM functional capacity indices (hatched bars).

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0% 20% 40% 60% 80% 100% RG_MARSplO_MARBlue_MARBarb_MARMonr_MARBora_MAR_1Percent of Reference Condition UMAM WRAP HGM Surface Water Storage HGM Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat Macrophyte FWCI Macroinvertebrate FWCI8% 43% 45% 64% 65% 92% Potential Credits Released per Respective Bank Figure 4-13. Comparison among six depre ssional herbaceous wetlands of UMAM (s olid bars), WRAP (white bars), HGM functional capacity indices (hatched bars), macrophyte FWCI, and macroinvertebrate FWCI (checkered bars).

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0% 20% 40% 60% 80% 100% TMEc_CYP_1Reed_FORMonr_CYPPant_CYP_1Percent of Reference Condition UMAM WRAP HGM Surface Water Storage HGM Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat Macrophyte FWCI Macroinvertebrate FWCI15% 62% 65% 86% Potential Credits Released per Respective Bank Figure 4-14. Comparison among four foreste d wetlands of UMAM (solid bars), WRAP (white bars), HGM functional capacity indices (hatched bars), macrophyte FWCI, an d macroinvertebrate FWCI (checkered bars). HGM was not completed at TMEc_CYP_1, a forested strand wetland. The remaining three wetlands were depressional forested wetlands.

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109 Suggestions for Assessment Methods Our primary goal was to determine the current ecological integrity of the wetland resources within permitted wetland mitigation banks. While this research was not specifically designed to provide suggestions to further develop and refi ne the assessment methods, some comments and concerns have arisen after implementa tion of the different assessment methods. In general, UMAM Location and Landscape Suppor t could use further guidance regarding the spatial extent that should be identified and us ed in scoring this category. Questions that commonly arose in the field centered around the a ppropriate scale or exte nt to consider for wildlife conduits, downstream connectivity, a nd surrounding land uses. Some wetland assessment areas were situated in the interior of the wetland mitigation bank, while others were located adjacent to the boundary near roadways or other anthropogenic land us es. In the case of the former, consideration had to be given to the implications of developed lands outside of the mitigation bank boundaries and how these areas affected the connectivity of the wetland assessment area to areas appropriate to suppor t expected wildlife species, provide water buffering (both quality and quantity) supply native and exotic seed sources, etc. In the case of the latter, consideration had to be given to immediately adjacent land uses as well as available habitat within the wetland mitigation bank. UMAM Location and Landscape Support scores could be highly variable dependi ng on the spatial extent used. Suggestions and concerns for WRAP have not b een provided, as UMAM must now be used by state agencies for all regulatory decisi on making involving mitigation, including the determination of potential credits in mitigation banks in Florida. Both the HGM flats wetlands in the Everglades a nd depressional wetlands of peninsular Florida guidebooks have had limited field testing and applic ation within Florida. There are some areas where clarification would be appropriate for fu ture HGM assessments as well as some minor errors that were detected within the guid ebooks. Additional HGM guidebooks for more wetland community types would be beneficial. To ease the use of the guidebook, a reference sheet that explains what specific data need to be collected for each variable would be valuable. This study created its own reference sheet so that the guidebook did not need to go in the field and to ensure that important data were not accidentally overlo oked and not collected. Field data sheets were inconsistently referred to within the text of the HGM guidebook for de pressions making cross referencing confusing at times. Field data sheets could be reworked; it appears sometimes that they reflected data collection that may have be en included earlier on in the development of the guidebook but not the final method. Specifically sometimes too much data collection was required that was not later used as part of the analysis. This was especially true for the variable of tree basal area (TBA) and macrophytic vege tation cover (MAC) in the depressional guidebook. Identification of a species and recording its species name was not part of the analysis and was unnecessary to that degr ee of detail. The field sheet could also be made more user friendly by providing more space for recording data. Often notes were taken elsewhere or in the margins and it would have been useful on the fi eld sheet itself so that there was an obvious progression of data recorded and then final asse ssment. For example it would be appropriate for the COMP variable for vegetation dominance to have a space for recording what the species actually were along with th e percent dominance.

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110 Likewise, development and application of FWCI in Florida has been limited to three wetland community types, and expansion to include add itional wetland types and regions would improve application. Clearly the diatom and macroinve rtebrate FWCIs are limited by the need for a minimum of 10 cm of standing water. As th ese species assemblages depend on standing water for their existence, little coul d be done regarding the small sa mple size. Perhaps additional FWCIs for other community assemblages such as bi rds or herps could be developed to alleviate some of the need for a minimum level of standing water. The application of LDI to mitigation sites presents many challenges. Primarily, there is concern over how to appropriately assign non -renewable empower density values to lands that in the past have been used for human activities but currently are being restored to a reference community type. As such, wetland scale LDI calculations used in this study have been considered potential LDI, suggesting th e wetland condition a ttainable based on surrounding land use within the bank. Further, the differences betw een wetland scale and bank scale LDI scores raise a question as the most important or relevant scale to consider. In the end, perhaps an integration of both scales is the best indication of landscape support. Overall each assessment method has multiple strengths and weaknesses. It was useful to use all five of the assessment methods to evaluate wetland condition within the wetland mitigation banks.

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111 CHAPTER 5 PERMIT REVIEW AND ECOLOGICAL INTEGRITY: CASE STUDIES In an attempt to understand and evaluate the effectiveness of wetland mitigation banking in Florida, a review of permits and other relevant documents, site vi sits, and field assessments were conducted. The results indicated a disconnect between the determ ination of success or interim success criteria according to th e permit and the site condition assessed according to five methods. Mitigation bank permits refer to succe ss as meeting the minimal intended ecological condition and the specific criteria listed in the Mitigation Banking Instrument (MBI) or the permit as a result of the permitted restoration a nd enhancement activities (Story et al. 1998; Ch 62-342.750, F.A.C.). Permit success is not intende d to indicate that the functional capacity of a particular area (whether wetl and or upland, or whether re stored, enhanced, created, or preserved) has been achieved. Therefore, it has b een challenging to correlated success defined by permit review with field evaluations, whic h rely on a score of wetland function. Permits may also refer to interim success, or milestones, for incremental credit releases. Permit credit release (also called interim success) crit eria were often combin ations of recording a conservation easement, removal of exotic sp ecies vegetation, earth moving and grading, hydrologic enhancement in the form of ditch plugging or canal filling, site preparation and planting, removal of undesirable tree canopy species or woody ve getation, successful completion of a prescribed burn, monitoring and accompanyi ng reports, management, and preservation. While these are all worthy activities and necessary for restoration efforts, they do not in and of themselves equate to success defined as fully functioning wetland communities. Due to the vast difference among permit success criteria, credit release requirements, and application of fields assessment methods (spe cific to particular we tland community types), across the board generalizations are difficult. Case studies for three wetland mitigation banks will be presented, highlighting differences of permit success, as measured by permit and document review and compliance interviews as presented in Chapter 3, and functional success, as measured by field assessment methods as pres ented in Chapter 4. Case studies for East Central, Florida Wetlandsbank, and Sundew Mitigation Bank provi de an overview of permit and document review juxtaposed w ith field assessment results.

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112 Case Study: East Central East Central Florida Regional Mitigation Bank (East Central) a 385 ha (952 ac) wetland mitigation bank located in the northeast corner of Orange County in central Florida along the St. Johns River (S2-6, 8-11/T22S/R33E and S35/T21S /R33E) (Figure 5-1A), abuts approximately 23,472 ha (58,000 ac) of public lands and was reported to host seven state li sted threatened or endangered plant species and six state and/or fede rally listed wildlife species. It was permitted by SJRWMD in May 1997. Approximately 75-80% of the bank consisted of hydric hammock and floodplain swamp wetland, with pine or mi xed hardwood upland communities covering the remaining 20-25%. To date, all of the 286.3 potential credits have b een released. Original credit allocation was 121.4 credits (42.4%) for forest ed upland enhancement and management, 96.2 credits (33.6%) for forested wetland restora tion and enhancement, and 68.7 credits (24%) for forested wetland preservation. As of October 2006, a total of 176.1 credits (61.5%) have been sold. The forested communities on this property were logged primarily for bald-cypress (Taxodium distichum), oak (Quercus spp.), red maple (Acer rubrum), and sweetgum (Liquidambar styraciflua) in the 1940s, with additional l ogging activities in the past 60 yrs. In areas where the canopy has not recovered, the wetland community type was described as cabbage palm hammock. Cattle grazing was also historically prevalent on the property. The majority of credits (55.4%) were released for recordi ng a conservation easement, removing cattle, and constructing a fence along the western boundary to prevent cattle ac cess from adjoining properties (Table 5-1). Filli ng an existing canal system that impacted Christmas Creek and installing vegetation for stabilization accounted fo r 95.1 credits (33.2%). A dditional ditch filling to improve the hydrology of seven impacted isol ated wetlands was awarde d 1.1 credits (0.38%). Canal filling used existing spoil berm materials onsite, with four areas of the canal filled to match the adjacent grade and others filled only to the extent possible given existing on-site material, leaving some deeper pools along the hist oric canal footprint (F igure 5-1B). Areas restored to matching grade were planted with herbaceous vegetation for stabilization. An additional 26.4 credits (9.22%) were allocated fo r a prescribed burn of designated upland area where fire suppression had led to encroachment by hardwood species in an otherwise pine (Pinus sp.) dominated area. Detailed success criteri a were not found for the remaining 5.0 credits (1.7%) that were tied into success of planted areas, defined roughly with achieving and maintaining target hydrologic regimes based upon reve rsal of existing altera tions and less than 10% cover by nuisance and e xotic species of vegetation. Potential credit determination was establishe d through mitigation ratios by SJRWMD. The 121.4 forested upland enhancement and manageme nt credits were awarded based on a 2.1:1 credit ratio. Of the 96.2 credits for forested wetland restorat ion and enhancement, 50.9 credits were allocated for hydrologic enhancement with in the primary and s econdary zones along Christmas Creek canal and the isolated wetlands with credit ratios of 2.5:1, 5:1, and 6:1, respectively; 23.5 credits were allo cated for enhancement of Christ mas Creek with a credit ratio of 2.5:1; and 21.8 credits were allocated for we tland restoration using existing berms to fill canals to grade with a 1:1 credit ratio.

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113 (A) (B) Figure 5-1. Landscape location of East Central (green line) in northeast Orange County: A) along the St. Johns River and surrounding land use in 2004 and B) close-up of wetland assessment areas for field assessment methods. Images are digital orthographic quarter quads. Green line is East Central bank boundary; blue (ECFl_HAM) and orange (ECFl_FOR) lines are wetland assessment areas for field assessment methods.

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114 Table 5-1. Credit release schedule for East Central. Activity Credits% Credits Record conservation easement, remove cattle, construct fence along west boundary 158.755.4% Complete canal filling and install plants for stabilization 95.133.2% Perform restorative burn of designated upland area 26.49.2% Meet success criteria for planted areas 5.01.7% Complete ditch filling for seven isolated wetlands 1.10.4% Total Credits 286.3100% Two wetland assessment areas were selected with in East Central, ECFl_HAM a cabbage palm hammock (FLUCCS 6181 Cabbage Palm Hammock) and ECFl_FOR a mixed species forested wetland along a black water stream (FLUCCS 6300 Wetland Forested Mixed) (Figure 5-1B). ECFl_HAM surrounds a portion of the filled canal that has been planted with marsh vegetation for stabilization but will be allowed to naturally recruit shrub and tree species in the long term. The filled canal footprint was not included in the assessment area because it is not currently a recognized wetland community type. Historically the canal imp acted the surficia l aquifer in the forested areas and downstream wetlands within two zones according to the original permit, a primary impact zone within 76.2 m (250 ft) and a secondary im pact zone within 152.4 m (500 ft). Both zones were included within the we tland assessment area of ECFl_HAM. Total UMAM (0.77) and WRAP (0.78) scores for ECFl_HAM were similar (T able 5-2). UMAM category scores ranged from 6 for Community Structure to 9 for Location and Landscape Support. The lower Community Structure score was assigned based on the altered canopy composition from logging activities and the presen ce of some exotic and nuisance species of vegetation. WRAP scoring categories ranged from 2.0 for Wildlif e Utilization (WU), We tland Canopy (O/S), and Habitat Support/Buffer to 3.0 for WQ Input & Treatment (WQ). The second wetland assessment area, ECFl_FOR wa s located along the historic Christmas Creek floodplain in the forested wetland preservation ar ea. Christmas Creek runs through the wetland mitigation bank in a southwest/northeast direction, though the creek signature is difficult to detect on the 2004 digital orthogr aphic quarter quads (Figure 51). UMAM (0.70) and WRAP (0.64) scores were lower for ECFl_FOR (Table 52) mainly due to upstream disturbances, the constant input of the invasive ex otic species comm on water-hyacinth (Eichhornia crassipes) from the connection with the St. Johns River, improper zonation in the wetland ground cover, and altered canopy. All three UMAM scoring categ ories were assigned scores of 7. WRAP scoring categories ranged from 0.5 for Wetla nd Ground Cover (GC) to 3.0 for WQ Input & Treatment (WQ), with the remaining four scoring categories assigned a 2.0. While all of the potential credit has been released for East Central, it is clear from the wetland assessments conducted that full wetland function ha s not been achieved. It is unclear if the permitting process assumed full wetland function would be restored in determining mitigation

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115 Table 5-2. Wetland assessment scores for two wetland assessment areas (ECFl_HAM and ECFl_FOR) at East Central. Assessment methods include Uniform Mitigation Assessment Method (UMAM), three UMAM scoring catego ries, Wetland Rapid Assessment Procedure (WRAP), and six WRAP sc oring categories scores. ECFl_HAM ECFl_FOR UMAM 0.77 0.70 Location and Landscape Support 9 7 Water Environment 8 7 Community Structure 6 7 WRAP 0.78 0.64 Wildlife Utilization (WU) 2.0 2.0 Wetland Canopy (O/S) 2.0 2.0 Wetland Ground Cover (GC) 2.5 0.5 Habitat Support/Buffer 2.0 2.0 Field Hydrology (HYD) 2.5 2.0 WQ Input & Treatment (WQ) 3.0 3.0 ratios. If so, while success criteria designed for this project have been met, full wetland function has not been attained at this s ite as measured by these method. Of the entire credits allocated for East Central, only 1.7% (5.0 credits) were based on reaching success criteria for planted areas. A majority of credits, 89% ( 254.9 credits) were based on recording a conservation easement or construction activities (i.e., fence construction, canal fil ling, ditch filling). The remaining 8.8% (26.4 credits) were based on completion of a pres cribed burn in the uplands and meeting success criteria. While these activities were assumed to enhance the condition of wetland and upland communities, there was little control over m odification of credit release based on wetland function achieved from these activities.

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116 Case Study: Florida Wetlandsbank As the first wetland mitigation bank permitte d in Florida in 1995 by SFWMD, Florida Wetlandsbank provided an example of a bank that has been deemed successful according to permit success criteria. Current conditions of two ar eas assessed in 2005, 10 yrs after the state permit was issued, suggested that full wetland function has not been restored to date. Florida Wetlandsbank was located in western Br oward County (S11/T51S/R39E). Current land use surrounding the bank was predominantly re sidential with some light commercial development, roads, and small parcels of old-fi eld non-restored lands (F igure 5-2A). Before becoming a mitigation bank, this 170 ha (420 ac) site was an old-field with a large population of the Florida Exotic Pest Plant Council Category I invasive exotic punktree (Melaleuca quinquenervia), a species documented as causing ecological damage through invading and disrupting native communities (EPPC 2003). The historic land use from a 1970s land use cover map (file USGSLU, available at: http://www.fgdl .org/) characterized the site as herbaceous rangeland (FLUCCS 3100). In addition, the site was hydrologically impacted by land drainage and canals, including a canal bisecting the property along a NE-SW line (Figure 5-2B). The mitigation plan involved removing exotic sp ecies, scraping the site down to the limestone bedrock to facilitate wetland establishment, and installing water control structures. The site was graded to target elevations of community types present in the greater Everglades: cypress flats, open water, sawgrass marsh, wet prairie, tree islands and other native upland communities. Water levels were manipulated and controlled to keep the site hydrated for the extended 9-12 month annual period of inundation t ypical of natural organic flats wetlands in the Everglades (Noble et al. 2002). Berms surrounding the wetla nds and dividing some of the phases were planted with native upland vegetation. The wetlands were also either planted and/or allowed to naturally recruit with native vegetation. Planting at the bank included 1,317,433 plants, and some areas had to be planted several times beca use of poor success in plan t establishment. At least 129 native species were documented as recrui ting naturally on the bank. In addition, the site has three known protected archaeological sites. Success criteria for Florida Wetlandsbank include d hydrology, exotic spec ies cover, planted vegetation, and recruited vegetatio n (Table 5-3). For hydrologic re storation, the project goal was to maintain an average water level of 4.0 ft ( 0.25 ft) National Ge odetic Vertical Datum (NGVD) to maintain the desired inundation cond itions. The second success criteria was for 5% or less cover by exotic or undesirable species of vegetatio n throughout the bank, including both planted and non-planted areas. The remaini ng two success criteria concerned minimum survivorship and cover of desi rable species throughout the bank. The credit release schedule for this bank was 90 % activity oriented credi t: credit release awarded for recording the conser vation easement (15%), punkt ree removal (25%), site grading (40%), and planting and mulching (10%). The final 10% of credits were schedul ed for release after successful monitoring after the first (5%) and second (5%) year. To date, 367.37 of the potential 370 credits have been released and the bank has b een sold out. The final 2.63 credits were being held by the SFWMD until monitoring for the last restored phase was complete.

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117 (A) (B) Figure 5-2. Landscape location of Florida We tlandsbank (green line) in western Broward County and surrounding land use in A) 2004 and B) 1995. Images are digital orthographic quarter quads. Green lines are wetland mitigat ion bank boundaries with small county in-holding in southwest corner. Blue (FLWt_MAR_1) and orange (FLW t_MAR_2) lines are wetland assessment areas for field assessment methods.

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118 Table 5-3. Success criteria for Florida Wetlandsbank. Category Criteria Hydrology Water levels demonstrate an average water elevation of 4.0 ft NGVD or within an acceptable deviation of 0.25 ft Exotic cover No more than 5% of both plan ted and unplanted areas will support exotic or undesirable plant species Desirable vegetation, planted 80% survival of each planted specie s after 2 years with persistence of another 3 years after the da te of time zero for each phase Desirable vegetation, recruited 80% cover for volunteer vegetation areas without planting after 2 years persistence for another 3 year s after the date of time zero for each phase Information from Bank Permit Staff Report Monitoring Plan E xhibit 29 and Special Conditions. Two years after the state permit was issued, Le w Lautin, Chief Executive Officer and Partner WetlandsbankTM, Inc., testified before the H ouse of Representatives, Subcommittee on Water Resources and Environment Committee on Transportation and Infrastructure, that As of December 1, 1997, our Pembroke Pines mitigation bank has completely restored almost 350 acres to fully functioning wetlands that have been monitored and approved by federal, state and local regulatory agencies. In my written report, you will find information that supports this success through the elimination of exotic plants, the reest ablishment of hydrology and the planting and growth of a variety of pl ants and trees that now thrive at th e site and provide critical habitat for diverse wildlife speci es that now make their home in this mitigation bank within a mile of the historic Florida Everglades (pg. 3). The permit and supporting documentation appear to assume full wetla nd function would be restored to this site once the success criteria have been met. However, according to the field UMAM, WRAP, and HGM assessment results from this study, this bank has achieved 52-73% of the reference wetland condition (Table 5-4) Assessment scores ranged between 0.52 (for WRAP at FLWt_MAR_2) to 0.73 (for UMAM at FLWt_MAR_1). The difference between the expected full return of wetland function following restoration and the measured level of wetland function was predominantly based on the suburban location and the effect of that location on wildlife, water, and related functions. It is not clear that the consideration of location was included in the original credit assessment. Thus there is a potential for loss of wetland function for impact projects that relied on this bank as mitigation providing full function as defined by current assessment methods. The wetland assessment area in Phase 1 (FLWt_MAR_1), which was restored approximately 3.5 yrs earlier than the wetland assessment area in Phase 29 (FLWt_MAR_2), had slightly higher scores for UMAM, WRAP, and HGM functional ca pacity index scores, except HGM Surface and Subsurface Water Storage (Table 5-4). Perh aps assessing the wetland function of similar wetland types restored over time using similar restoration techniques (i.e., a chronosequence design) would provide a reasonabl e estimate of time lag factors associated with restoration activities for specific wetland community types. However, fi nding a large enough sample size for any statistical vigor seems unlikely due to vast differences in site specific conditions.

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119 Table 5-4. Wetland assessment scores for two wetland assessment areas (FLWt_MAR_1 and FLWt_MAR_2) at Florida Wetlandsbank. Assessment methods include Uniform Mitigation Assessment Method (UMAM), three UMAM scoring categories, Wetland Rapid Assessment Procedure (WRAP), six WRAP sc oring categories, Hydrogeomorphic wetland assessment method (HGM), and four HGM functional capacity index scores. FLWt_MAR_1 FLWt_MAR_2 UMAM 0.73 0.70 Location and Landscape Support 4 4 Water Environment 9 9 Community Structure 9 8 WRAP 0.55 0.52 Wildlife Utilization (WU) 1.5 1.5 Wetland Canopy (O/S)* na na Wetland Ground Cover (GC) 2.0 1.5 Habitat Support/Buffer 0.5 0.5 Field Hydrology (HYD) 2.5 2.5 WQ Input & Treatment (WQ) 1.8 1.8 HGM Surface and Subsurface Water Storage 0.63 0.67 Cycle Nutrients 0.69 0.64 Characteristic Plant Community 0.66 0.62 Wildlife Habitat 0.56 0.53 *WRAP Wetland Canopy (O/S) was not scored for these wetland assessment areas because they did meet the minimum requirement of 20% cover by overstory /shrub canopy (Miller and Gunsalus 1999). In the case of Florida Wetland sbank and other banks located in highly develope d landscapes, the location and associated landscape support will al ways be a limiting factor in achieving full wetland function. For example, UMAM Lo cation and Landscape Support score was 4 and WRAP Habitat Support/Buffer score was 0.5 for both wetland assessment ar eas indicating that habitats outside the wetland assessment area prov ide support for generalist species, but typically fail to provide support for many wetland specialists and wildlife species that have larger home ranges than the bank can provide or that need a mosaic of habitats to complete their life cycles. Both assessment areas had the same scores fo r HGM variables that defined accessibility to wildlife for dispersal and migr ation (TRACT; 0.03 out of 1.00), interior core habitat and vulnerability to fragmentation (CORE; 0.38 out of 1.00), and habitat connectivity (CONNECT; 0.10 out of 1.00). Reasons for low landscape and connectivity scores included: substantial barriers for terrestrial species to reach the greater Everglades system to the west from roadways, canals, and urban structures (Fi gure 5-3); nearby urban areas provi ded a constant seed source for exotic species of vegetation, including the in vasive exotic punktree; and alteration of the hydrologic discharge from the property. Whereas, hi storically this area w ould have contributed to the regional water budget with sheet flow st yle drainage, now the down stream areas receive a point source outflow into a SFWMD canal, which drai ns to the east rather than into the greater Everglades system south and west. Florida We tlandsbank was thought to act as a water purifier

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120 for the SFWMD canal water, a gain of local wetland function by tr eating urban run off, but that water is no longer part of the greater Everglades system, a loss of regional wetland function. The HGM assessment also gave all organic flats wi th rock plowing a 0.00 variable score (MICRO) because of the loss of water storage capacity. Even if restoration activities (i.e., grading) can account for recreating some micr otopographic relief, the drop in elevation associated with scraping the site down to the be drock can never regain the same storage capacity (Noble et al. 2002). Lew Lautin, in his testimony before the House of Representatives, went on to state that when circumstances favor mitigation banking, it has proven to be a viable and successful alternative that ensures a true no net loss of wetland functional values (pg. 4). It is true that the wetland resources at Florida Wetlandsbank are ra re for urban Broward County and that the aesthetic and recreational resources provided are a positiv e contribution to the area. However, in regards to wetland function, ther e has been a net loss when assumptions of full functional restoration are perpetuated. For example, while local water treatment and nutrient cycling has been restored, contribution to th e regional water cycle has not. In addition, wildlife species found within the wetland boundaries that can carryout their life cycles with in narrow strips of upland or that can fly over urban developmen t can succeed within the bank; however, ground limited species and those needing larger areas will not succeed. This is not to say that the wetland function has not been enhanced at the bank, but simply that it was not restored to full function.

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121 Case Study: Sundew Mitigation Bank Located in the southeastern corner of Clay County (S26,27,34,35/T7S/R26E), Sundew Mitigation Bank encompasses 851.7 ha (2,104.6 ac) Over half of the site (57%) was characterized as wetland (488.7 ha), with just under 6% of the wetland area (or 28.6 ha) considered largely unaltered by s ilvicultural activities. Only approximately 1.5 ha, less than 1% of the uplands, of native-like forest (scrubby flatwoods) remains, according to the Individual Environmental Resource Permit Technical Sta ff Report (Staff Report) dated August 7, 2001. This property was used for turp entine production in the early 1900s By the 1940s, the entire property, including most interior wetlands, was clear cut, root raked, and bedded. A 1970s land use cover map (file USGSLU, available at: http://www.fgdl.org/ ) showed a majority of the property as FLUCCS code 4200 Upland Hardwood Forests with a strand of 6100 Wetland Hardwood Forests. The apparent shift from pine dominance (for turpentine and harvest) to hardwood species dominance was most likely a re sult of rapid hardwood re-growth following extensive pine harvest, suggestin g the site was harvested again in the late 1960s or early 1970s. Silvicultural practices were active up until the property became a bank. Digital orthographic quarter quads from 1995 show that the middle section of the property had recently been harvested (Figure 5-3A), with the remaining ar eas harvested before the 1999 digital orthographic quarter quads were flown (Figure 5-3B). The Staff Report states that a majority of the upland areas host six-year-old slash pine (Pinus elliottii) planted on 0.9-1.5 m (3-5 ft) centers in 2001. The rows of young pine can be seen in the 200 4 digital orthographic quarter quads (Figure 53C). Mitigation activities at Sundew Mitigation Bank included ending silvicultural activities, eliminating most bedding, restoring water leve ls and patterns, enha ncing native forest communities through planting, creating small herb aceous wetlands, and implementing prescribed fire. While the permit was issued August 7, 2001, lit tle had been completed four years later. The only recent activity that was noted was some clear cutting. The ground was impacted with rutting by machinery and woody debris. Hydrologic alterations draining the site were still in place. Sundew Mitigation Banks permit allowed 698.3 potential credits, as stated in Exhibit 3 of the Staff Report (Table 5-5). As of October 2006, 194.2 credits had been released, representing just under 28% of the total potential credits. Th e federal Mitigation Banking Instrument (MBI) suggested 930.9 total credits were available. It was unclear from either the MBI or the state permit why the credit determination was different fo r the state and federal agencies. The credit release schedule in the SJRWMD permit was also set up somewhat differently than the federal MBI. The federal permit had more detail and di fferent success criteria and credit release. Federal documents were not acquired for all ba nks, and the federal MB I success criteria for Sundew Mitigation Bank were included here as an example of the differences between state and federal requirements. Note that this was one example, and all state and federal permits do not share the same similarities and differences. One of the primary differences between the state credit release schedule (Table 5-5) and the federal credit release schedule (Table 5-6) was th e large difference between the percent of credits

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(A) (B) (C) Figure 5-3. Landscape location of Sundew Mitigation Bank (green line) in Clay Co unty and surrounding land use in A) 1995, B) 1999, and C) 2004. Images are digital orthographic quarter quads. Green line is wetland mitigation bank boundary; blue (Sun_FOR_1) and orange (Sun_FOR_2) lines are wetla nd assessment areas for field assessment methods.

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123 Table 5-5. State permit credit release schedule for Sundew Mi tigation Bank from SJRWMD technical report. Activity Credit Release Percent Release Conservation easement 139.66 20% Cut planted pines 69.83 10% Harrow the bedding 69.83 10% Complete hydrologic enhancement construction 69.83 10% Complete tree plantings 34.92 5% Document hydrologic enhancement (with minimum 3 years monitoring) 34.92 5% Document tree assemblage and densities met After 1 year monitoring indicates success 27.93 4% After 2 year monitoring indicates success 27.93 4% After 3 year monitoring indicates success 27.93 4% After 4 year monitoring indicates success 27.93 4% After 5 year monitoring indicates success 27.93 4% Final success achieved with mini mum 5 years monitoring* 139.66 20% Total 698.30 100% 100% of created wetland credits will be released only after a minimum of 3 years of monitoring indicates successful establishment awarded for mechanized or phys ical activities versus credits awarded for monitoring and demonstration of success. For example, 45% of the credits aw arded through the state credit release schedule came from monitoring and docum entation of meeting permit specified success criteria; whereas only 11% of th e credits awarded through the fe deral credit re lease schedule came from monitoring and documentation of success. In fact, the state credit release schedule allocated 20% of the credits for reaching final success after a minimum 5 yr monitoring period. The federal credit release schedule, however, pl aced emphasis on construction based activities on the assumption that removing undesirable species (i.e., slash pine), removing silvicultural bedding, and removing unnatural drai nage features would lead to full restoration of wetland function. The implementation of such activities resulting in restoration of full wetland function remains untested. Two wetland assessment areas (Sun_FOR_1 a nd Sun_FOR_2) were selected for field assessments within Phase 1 at Sundew Mitigatio n Bank (Figure 5-3), both characterized as 6300 Wetland Forested Mixed wetland communities (SJRWMD 2000 land use cover map). The first wetland assessment area (Sun_FOR_1) included one area with a fairly closed canopy and one area with a more open canopy due to past harves ting with extensive evidence of recent hog rooting. Because these areas did not have distinct boundaries and they clearly comprised one contiguous wetland, these areas were scored as one wetland assessment area. The second assessment area (Sun_FOR_2) was characterized as floodplain forest though the strip of remaining floodplain vegetation had been greatly re duced due to past silvicultural encroachment into the wetland. There were occasional cypress (Taxodium spp.) in the canopy with some large

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124 Table 5-6. Federal permit credit release sche dule from the Mitigation Bank Instrument for Sundew Mitigation Bank. Activity Percent Release Place conservation easement 15% Eliminate planted pines per plan 15% Eliminate and Cross-cut bedding Year one 10% Year two 5% Year three 5% Eliminate unnatural drainage structures and washouts 10% Supplemental canopy tree planting Year one 6% Year two 5% Year three 5% Year four 5% Year five 8% Demonstrate Improved Wetland Hydrology Year one 2% Year two 2% Year three 2% Demonstrate <5% exotic nuisance plant cover Year one 1% Year two 1% Year three 1% Year four 1% Year five 1% Completion and Success of Created Herbaceous Wetlands 100% loblolly bay (Gordonia lasianthus) throughout, though much of the cypress had likely been harvested in the past. No evidence of cypr ess regeneration was found. Water flowed in a distinct channel through the cen ter of this assessment area, di rectly connecting it to other wetlands throughout the bank a nd draining to the south. Assessment score ranged from 0.65 to 0.77, with Sun_FOR_1 having UMAM and WRAP scores of 0.67 and 0.65 and Sun_FOR_2 having UMAM and WRAP scores of 0.77 and 0.73, respectively (Table 5-7). State credit allocati on was based on mitigation ratios; however federal credit allocation was based on M-WRAP calculati ons with scoring worksheets available. All with-bank scenarios in the federal MBI for we tland polygons predicted a score of 3.0 for each M-WRAP scoring category and th erefore an overall 1.00 M-WR AP score after restoration, enhancement, or creation activities were comp leted. M-WRAP scores for current (pre-bank) conditions from federal documentation at th is bank ranged from 0.56-0.83, which encompassed the range of scores for the two wetland asse ssment areas in this study (Sun_FOR_1 and

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125 Table 5-7. Wetland assessment scores for two wetland assessment areas (Sun_FOR_1 and Sun_FOR_2) at Sundew Mitigation Bank. Assessment methods include Uniform Mitigation Assessment Method (UMAM) with its three scoring categorie s and Wetland Rapid Assessment Procedure (WRAP) with its six scoring categories. Sun_FOR_1 Sun_FOR_2 UMAM 0.67 0.77 Location and Landscape Support 6 7 Water Environment 8 9 Community Structure 6 7 WRAP 0.65 0.73 Wildlife Utilization (WU) 2.0 2.0 Wetland Canopy (O/S) 2.0 2.0 Wetland Ground Cover (GC) 1.5 3.0 Habitat Support/Buffer 2.0 2.0 Field Hydrology (HYD) 2.5 2.5 WQ Input & Treatment (WQ) 1.6 1.6 Sun_FOR_2). While specific condi tions within the wetlands can be expected to improve with the implementation of mitigation activities such as improved community structure and hydrologic conditions, it is uncertain that full functi on could ever be attained at this location. The disruption of neighboring lands to the southw est through mining activit ies (Figure 5-4B, C) will influence site hydrology, species exchange, a nd wildlife habitat suppor t. Additionally, the proximity of US-17, a busy highway to the northeast, acts as a wildlife barrier between the bank and Bayard Conservation Area. As well, the occurrence of residentia l areas along the eastern boundary and the abundance of silvic ultural activities in the vicin ity suggest that the landscape will never provide all of the benefits and connections necessary for full wetland function. Further, without-bank scenarios in the MBI used to calculate the delta for credit determination seemed overly depressed. For example, in one polygon (e.g., W-1) the Ve getation Overstory (an M-WRAP category analogous to WRAP Wetland Ca nopy) scored 0.0 under the assumption that all cypress would be harveste d. Also, Adjacent Upland Buffer (analogous to WRAP Habitat Support/Buffer) received a score of 0.0. While it might be possible to completely eliminate both the vegetative structure of the wetland and th e surrounding lands, current regulations regarding urban development would require some compensa tion for such loss, and these scores seem inappropriate for without-bank scenarios. Ov erall, the prospects of Sundew Mitigation Bank ever achieving full wetland function, documente d through perfect WRAP or M-WRAP scores, seems unlikely, and a net loss of wetland function likely.

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127 CHAPTER 6 DISCUSSION When this proposal was drafted in 2004, only 34 Florida wetland mitigation banks had been permitted. By October 2006, that number had increas ed to 45 permitted banks in Florida. As a result of this rapid increase in banking in Florida, this study ha d the opportunity to identify the current ecological function provided by permitted wetland mitigation banks across a broad spectrum of activity, from those sites where mitiga tion activities had not yet occurred to those banks deemed successful. The following sections describe overall conc lusions drawn from permit and documentation review and from field assessments. First, we present eight recommendations to improve permits and mitigation plans. Second, we discuss consider ations for basing success criteria on indicators of ecological integrity. Third, we present a brief discussion on project limitations and future research direction, followed by concluding remarks. Permit Review Generalizations regarding permits were difficult considering the vast di fferences in wetland community types, regional variations in exotic and nuisance species of ve getation present, varied expectations of wildlife use, di fferent anticipated fire regimes based on community type, assorted methods of potential credit determination, and differences among overseeing agencies (Florida Department of Environmental Protection, FDEP ; South Florida Water Management District, SFWMD; Southwest Florida Water Management District, SWFWMD; or St Johns Water Management District, SJRWMD). All of these factors contributed to somewhat unique permit requirements for each wetland mitigation bank. One consideration regarding wetland mitigation banks was the lack of any centralized oversight structure that followed the mitigation bank from initial permit ap plication review through final credit release, combined state and federal regulations and over sight, and warehoused important documentation such as permits, credit releas e requests, monitoring reports, and any other additional correspondence and proceedings relating to banks. The management of banks by four separate agencies within the state and the time la g between state and federal processing appeared to confuse and delay the process of permitting Florida banks. In contrast, having multiple agencies responsible for permitting did not overloa d one single agency with all permit requests, though it did increase the differences among ba nk permits within the state. Sharing all documentation in a transparent, accessible, cent ralized, digital fashion from pre-permit through final success would facilitate compliance tracking and auditing. Eight recommendations for improving permits a nd/or mitigation plans were developed from review of permits and documentation at 29 Florida mitigation banks. These included: 1. Define natural communities and associated reference standard conditions; 2. Emphasize groundcover restoration; 3. Monitor plant and animal community structure, not just presence or cover of exotic or nuisance species; 4. Establish and implement fire management plans; 5. Identify sustainability of m itigation within the landscape;

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128 6. Allocate a higher percent of credits for achievi ng success criteria a nd a lower percent of credits for task completion; 7. Encourage better coordination and standardiz ation among state and federal agencies and between bank managers and agency personnel; and, 8. Increase compliance responsibilit ies of the regulatory agencies. These suggestions are intended to facilitate improvement in th e ecological condition of wetland and upland communities within banks permitted in the future. Natural Communities Chapter 373.4135, F.S. states Mitigation banks and offsite regional mitigation should emphasize the restoration and enhancement of degraded ecosystems and the preservation of uplands and wetlands as intact ecosystems rather than alteration of landscapes to create wetlands. This is best accomplished through restoration of ecological communities that were historically present. The Society for Ecological Restor ation International (SER) defines ecological restoration as the process of assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed (SER 2004, pg. 3). Th e Environmental Resource Permitting Basis of Review defines restoration as converting back to a historic condition those wetlands, surface waters, or uplands which currently exist as a land form which differs from the historic condition (SJRWMD BOR 2.0(vv)). Both th e SER and SJRWMD defi nitions point to a need to understand the historic condition or a recove red condition of the intended comm unity. Therefore, defining the targeted ecological community or reference standa rd condition is imperative in mitigation banks. While some mitigation plans for banks clearly de fine the targeted natural community type and restoration goals, many more do not. Language commonly encountered in permits suggests that mitigation areas would resemble a particular co mmunity type, but rarely were explanations given as to how this resemblance would be dete rmined. In fact, sometimes the resemblance would be based on similar percent cover by a singl e species. While ecological statistics can be quite complicated, some simpler functional a ssessment tools are available to provide a quantitative comparison of community structure, such as indices of biotic integrity (i.e., Florida Wetland Condition Index, FWCI), or functional assessment techniques (i.e., Hydrogeomorphic approach to assessing wetland func tion, HGM). Further, in a re view of restoration projects described in the first 11 volumes of the journa l Restoration Ecology, Ruiz-Jaen and Aide (2005) mention group comparisons (i.e., ANOVA, ttest), ordination (i.e., DCA), and linear comparisons as the three common st atistical methods for evaluating restoration success. Surely some quantitative means of evaluating similarity to a reference standard community could be incorporated into permit success criteria. Ecosystems are inherently variable as they or ganize around constant change s in driving energies (i.e., sunlight, rainfall, etc.) and natural disturbances (i.e., wind storms, hurricanes, fire, etc.). Defining the target reference st andard condition and having a refe rence database and/or nearby field sites for comparison are crucial to understa nding the expected range of variability for a community type. In many instances having bot h would be ideal, as a reference database provides representative conditions across the region or state and lo cal field sites provide for an understanding of current local variation. Unfortuna tely, a state-wide reference database does not exist, though restoration planning, monitoring, an d assessment would benefit from such a tool.

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129 Florida banks are not alone in their lack of cl early defined target natu ral communities. In a nationwide study on wetland mitigation, the Environm ental Law Institute (ELI 2002) found that a clear and uniform definition of wetland type was rarely included in bank permits and documents, despite indication within the documents suggesting a standard wetland classification systems would be used, typically that of Coward in et al. (1979). Further, Ruiz-Jaen and Aide (2005) noted that existing laws in the United Stat es do not require restora tion success as defined by comparison to reference standard communities, and that given financial concerns, such as increased costs for monitoring reference sites as we ll as restoration sites, it is unlikely that such comparisons to reference sites will be required fo r future restoration efforts. While the Uniform Mitigation Assessment Method (UMAM), which is now the required assessment method for determining potential credits at wetland mitigat ion banks, does require the assessor to describe the wetland assessment area by FLUCCS code or other classification scheme, functions, and anticipated common and listed wildlife utilizat ion, it does not require field comparison to a reference standard community. Perhaps the Fl orida Natural Areas Inventory (FNAI) Guide to the Natural Communities of Florid a (1990) would be a more useful classification for managers planning restoration activities th an FLUCCS codes, as FNAI provi des a detailed description of each of Floridas native communities. In addition to defining a reference standard c ondition for a community type, baseline conditions should be established. Moore et al. (1999) state that the need fo r restoration acti vities and the evaluation of restoration success are based on diffe rences between current and reference standard condition. While some permits did establish the current condition of the environmental resources for the determination of preservation cr edit release (credits available for preservation credit release can be calculated as the differe nce between the current condition scores minus the without bank scenario, Story et al. 1998), this depended on the met hod used to calculate potential credits. The baseline condition should be calculated for all communities within banks. This is particularly important if a bank falls out of complia nce and the baseline wetland function has been diminished. Such was the case for at least one bank that stalled restoration activities, fell out of compliance, and thus had more work to attain permit success criteria due to the delayed activities and the growth of both exotic and nui sance species that expanded during an extended period of inactivity leading to a se t back in restoration progress. Groundcover Restoration Restoration of different commun ity types requires more than replacement of canopy structure alone. While the canopy no doubt influences a great deal about the community (e.g., microclimate, Breshears et al. 1998; air turbulence, Patton et al. 2003; etc.), there is more to restoring natural communities than simply planting or growing trees. However, most restoration plans rely on natural processes alone to esta blish non-canopy vegetation (Clewell 1999). In a study of Florida Everglades marsh restoration, Sm ith et al. (2002) support that active vegetation management must be used along with hydrologic re storation in order to restore the herbaceous vegetation to the target re ference standard condition. Beyond plantings, Mitsch and Wilson (1996) suggest that allowing nature to participate in the wetland community design through multiple-seeding, multiple-transplanting, and allowing genetic material to enter through hydrologically c onnected systems is an appropriate means of

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130 vegetative restoration. In a restoration site in south Florida, David (1999) suggested that colonization of a restored marsh by pickerelweed (Pontederia cordata) occurred due to the hydrologic connectivity of the restored site with a drainage ditch that hosted pickerelweed. For restoration at wetland mitigation banks, it may be important to include connectivity to off-site wetlands and uplands, not just for hydrologic rest oration but to increase the inflow of genetic vegetation material as well. In restoring flatwood ecosystems, many of the banks have success cr iteria tied to survivorship of planted pine trees, but relatively few in clude specific success criteria for groundcover composition in these areas. However, gro undcover plays an importa nt role in these communities, particularly for carrying fire and providing food and nesting materials for wildlife. When wet flatwoods have had groundcover or hydrologic disturbance, overall community recovery is poor (FNAI 1990), suggesting the im portance of actively restoring the groundcover in such communities. An important part of achieving success in groundcover restoration includes adequate site preparati on prior to planting, seeding or allowing natural regeneration to occur. Perhaps in such communities success crit eria should be more cl osely tied to groundcover composition similarity to the target reference st andard condition in add ition to or instead of survivorship of planted tree species. Community Structure An apparent oversight in many mitigation plans is the lack of consideration of target community structure for both flora and fauna. Some permits require a minimum percent cover of a desirable species or percent plant cover that resemble s a reference standard community and limit the percent cover by exotic and/or nuisance species. Ten of the 29 permits reviewed in this study had wildlife requirements for determination of success, and seven of these included qualitative wildlife monitoring. Restoration of wetland a nd upland communities should focus on the target wildlife community structure as we ll as the vegetative community structure. It is not enough to believe that if you create a sim ilar vegetative structure, the w ildlife will come back. Instead, attention should also be given to establishment a nd maintenance of desired wildlife communities. Further, it is recognized that currently many available assessment methods clearly aim to measure community structure, with the assump tion that restoring community structure will equate to returning community function. However, a simple list of speci es occurrence does not provide an adequate means of assessing ecosystem function (Mitsch and Wilson 1996). Ten years ago Mitsch and Wilson (1996) recognized the need for linking structural measures such as species diversity, productivity, or cover, with impor tant ecosystem functions such as wildlife use, nutrient cycling, or organic matter accumulation. Studi es have noted that the return of the water storage or water quality functions at restoration sites does not always equate to targeted community structure or wildlife habitat f unctions (e.g., Brown and Veneman 2003, McKenna 2003, Zampella and Laidig 2003) Further, McPherson and DeSt efano (2003) suggest that a quantitative, objective description may be required to assess the effectiveness of management activities on community structure. Establishing community structure targets through applic ation of functional a ssessment tools that provide a quantitative comparison of community structure, such as indices of biotic integrity

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131 (i.e., Florida Wetland Condition Index, FWCI), or functional assessment techniques (i.e., Hydrogeomorphic approach to a ssessing wetland function, HGM), may improve the structural component of wetland mitigation banks. The underlying support for using biological indicators is that organisms have an intricate relationship with their environment, which reflects current and cumulative ecosystem conditions (Karr 1981). Biol ogical indicators reflect chemical exposure and also integrate changes in the community compos ition of the ecosystem (from physical, chemical, and biological changes) (Adams 2002). Currently the FWCI is only available for three wetland community types (i.e., depressional herbaceous, de pressional forested, a nd forested strand and floodplain wetlands) and three community assemblages (i.e., diatoms, macrophytes, and macroinvertebrates) for Florida wetlands. Sim ilarly, indices of biotic integrity should be developed for other species assemblages, as has been the case in other states for fish (Schulz et al. 1999), birds (OConnell et al. 1998), and amphibians (Micacchion 2002). Developing bioassessment tools based on additional community assemblages (e.g., bird, amphibians, etc.) and for additional wetland types (e .g., cabbage palm hammock, Ever glades flats, etc.) for the state of Florida would help provide means to qu antitatively compare community structure. In fact, biological assessment data for multiple community assemblages will provide a more complete picture of ecosystem condition (Reiss and Brown 2005a). Application of the HGM approach is also limite d by method development and field testing, as currently guidebooks are available for a limited set of wetland community types in Florida: 1. Flats wetlands in the Ev erglades (Noble et al. 2002); 2. Wet pine flats on mineral so ils in the Atlantic and Gulf Co astal Plains (Reinhardt et al. 2002), which includes far northeastern Florid a but excludes penins ular Florida, though the authors suggest the same m odel may be applicable to peni nsular Florida with limited modification; 3. Low-gradient, blackwater riverine wetlands in peninsular Florida (Uranowski et al. 2003); 4. Depressional wetlands in peni nsular Florida (N oble et al. 2004). Increased field testing, developing guide books for other wetland community types, and expanding the geographic regions of Florida represented by HGM models would provide further tools for quantitative comparis ons of community structure. Fire Management Fire management is crucial to successful mainte nance of many of Floridas natural communities, ranging from high-frequency fires in prairies, flatwoods, and sha llow marshes, to longer fire return interval in sw amps and hardwood forests (FNAI 1990). Yet detailed fire management plans were often not included in permits and associated documenta tion. Even wh en prescribed fire was indicated for achieving successful ecosy stem restoration, many barriers arose to prevent implementation of prescribed fire management plans. Management s hould be proactive and aggressive in conducting prescribed fires. Wh ile weather conditions ar e not always ideal for conducting prescribed fires, certain ly some day within the appropria te fire season interval should become available within a reasonable time fram e to keep fire management based mitigation activities on track. Managers should be ready to act when appropriate weather and field conditions arise. Historic Florida fire regimes ha ve been altered for over a hundred years, when human activities began to fragment the Florida landscape and pr omote activities to supp ress and extinguish any

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132 natural fires that did occur. However, re storation of groundcover in many communities is dependent on frequent lightning season fires, and successful restoratio n may be unattainable without fire management that mi mics the natural regime to the extent practical. Some banks suggest prescribed fire as a management t ool only after the canopy species have become established (5-10 yrs after planting) yet prescribed fire should be c onsidered as a restoration tool sooner to help promote the groundcover that can then support and sustai n a fire. The early establishment of appropriate pyr ophytic groundcover that includes fi ne fuels capable of carrying prescribed fire is an important consideration. Successful implementation of prescribed fire and community response to this management tool sh ould be required by m itigation bank permits and linked to credit release in fire-dependent communities. Sustainability and Landscape Position The location of compensatory mitigation sites con tinues to be an important consideration. The state of Florida has been cross ditched and drained since human settlement began, and as such, an ideal landscape setting probably does not exist wi thin the state. Having realistic goals as to the potential function of a wetland mitigation ba nk should be a priority for assessing with mitigation bank scenarios. A bank surrounded by human development land uses or in areas that are likely to support human development activities in the near future s hould not receive perfect landscape scores for with mitigation scenarios. Consideration of potential wetland functional lift should incorporate a landscape perspective, whic h could include application of available tools such as both the wetland scale and bank scale LDI index, reflecting both the local and broad scale landscape support. The relatively rece ntly adopted UMAM does consider location and landscape support in its scoring. Finding a significantly large tract of land on which to locate a ba nk in Florida, or the United States, may be impossible, as Forman (2000) su ggests that approximately 20% of the land area within the United States has experienced direct ecological effects from the public road system. This 20% figure is expected to rise in the future, suggesting that roadways will continue to act as a major influence on the community structure and wildlife habitat suitabili ty for Florida wetland mitigation banks. While the Criteria for Esta blishing a Mitigation Bank (62-342.400 (1) (f), F.A.C.) states that the wetland mitigation ba nk should be adjacent to lands which will not adversely affect the perpetual viability of the Mitigation Bank due to unsuitable land uses or conditions (pg. 538), this criteria may be overlooked when deciding to approve the location of a proposed wetland mitigation bank. For example, mitigation banks adjacent to or bisected by highways is a concern, as highways act as significant barriers for wildlife. In a study on the mortality of amphibians, reptiles, and other wildlife along a two-lane pa ved causeway, Ashley and Robinson (1996) found over 32,000 individuals died in two two-year periods along the road. In another study from Boston, Massachusetts, researchers found the impacts of a major four-lane road extended at least 100 m and perhaps more than 1 km for some effects (Forman and Deblinger 2000). Further examples of the significant impacts roads play in disturbing wildlife include the mortality of herpetofauna along US-27 in Lake Jackson, Florida (Aresc o 2005), which are a co mmonly overlooked though major biotic component of freshw ater wetlands (Gibbons 2003). In addition, rarely have female Florida panthers (Felis concolor coryi) been found to cross major ro ads or use underpasses, so

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133 their habitat is still essentially fragmented by roads even where underpasses have been constructed (Maehr 1988, as cited by the Florid a Fish and Wildlife Conservation Commission at http://myfwc.com/panther). These studies sugge st that roadways and conservation areas should be well separated, and yet many of the Florid a banks are bordered by busy roadways (e.g., Barberville is bordered to the south by SR-40; Ev erglades Mitigation Bank/Phase I is bordered to the east by Card Sound Rd. a nd the west by US-1 ; etc.) or bisected by busy roads (e.g., Tosohatchee is bisected by the Beach-Line High way SR-528; Little Pine Island is bisected by SR-78; etc.). In addition, a recently permitte d bank, Wekiva River, has been targeted as a potential area to be impacted by a futu re highway serving the Orlando area. A further concern regarding landscape support is the presence of tall transmission towers on or near bank property that may occur within avian f light paths. A few banks (e.g., Panther Island) are situated adjacent to such towers, and species attracted to the mitigation site may be endangered by neighboring structur es. For example, in a study on bird mortality in central Florida, Taylor (1973) found hundreds of black-t hroated blue and Cape May warblers were killed in a six week period in September and October at the WDBO-WFTV TV Tower, in the autumns of 1969-1972. In a more recent study by Crawford and Engstrom (2001), a total of 44,007 individuals of 186 species were collected at the WCTV television to wer in north Florida, and over 94% of the total number of individuals were Neotropical migrants. The study spanned a 29-yr period, one of the longest of its kind. Th ey found that towers approximately 94 m or lower may not pose as great a threat to avian mortality as caused by towers 200 m or greater. Clearly the position of banks in urban lo cations, near highways, or adjace nt to transmission towers will have unintended consequen ces for mobile species. Further, McAllister et al. (2000) suggest that the landscape location at a regional scale that would maximize the functional gain from wetland restora tion is frequently ignored. While the primary focus of that study was the function of flood attenuati on, certainly this is true of other functions. In the end, all restoration, mitigation, and c onservation areas must contend with human development activities. Conve rsely, a recent study on the demographics of Florida banks suggested that the locati on of banks in more rural areas redistributes wetland resources and the associated ecosystem services away from urban areas and thus removes some of the services afforded by these systems (Ruhl and Salzman 2006). Locating banks within developed urban areas may improve the distribution of certain ecosystem services acro ss the landscape (e.g., flood attenuation), but it will not improve the total potential function that could be attained on a site. Wetland mitigation in general must be consider ed a trade-off between temporal and spatial ecosystem function, and th e bottom line comes back to a rea listic expectation of attainable function in the calculated with mitigation bank scenario. That is, when a bank is adjacent to developed lands, the location and landscape functi onal component should ne ver be expected to achieve a perfect score. Similarl y, when a bank is located in an area spatially distant from the impact site, some local loss of wetland function s hould be anticipated and offset as appropriate through other components of wetland regulation, such as floodplain compensation and surface water treatment and attenuation. A national study by Brown and Lant (1999) found that the spatial location of banks was ofte n in downstream or coastal locat ions, so that replacement may not be providing equal function as from the we tlands lost in the upper watershed. Significant loss in wetland function from moving mitigation wetlands towards the bottom of a watershed may be manifest in loss of flood control (O gawa and Male 1986 as cited by Brown and Lant

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134 1999) and change in water quality benefits (P eterjohn and Correll 1984), which should be taken into consideration when defining the mitigation bank service area. Credits for Achieving Success Criteria When reviewing bank permits and supporting docum entation, it became clear that much of the credit release was tied directly into completion of specific tasks such as grading, ditch plugging, or canal filling. Because the concept behind comp ensatory mitigation is to prevent no net loss of wetland function and the function attributed to ba nks is meant to be in place prior to impacts (Federal Guidance for the Establishment, Use and Operation of Mitigation Banks 1995), more credits should be tied into demonstration of ac hieving function and less into task completion. Early credit release is probably necessary to maintain the economic incentive of establishing and operating a bank, and limited initial credit re lease based on acquisitio n of a conservation easement and demonstrating financial assurance seems justified. However, continued credit release based on completion of activities that do not necessarily equate to demonstrated improvement of function should be avoided. Cr edit release criteria should be explicit and measurable, and demonstration of trending toward s success should be the most important factor in further credit release. Mits ch and Wilson (1996) argued a decade ago that efforts to determine wetland restoration or creation succe ss are flawed due to a lack of application of sound wetland science and the weight of schedule-driven cons truction activities, and yet many of the success criteria of permits were focused on task completion. Both the FDEP and WMD rules on mitigation banking state that a mitigation bank permit must include the success criteria by which the mitig ation bank will be evaluated. (12.4.9(a)3, SJRWMD Applicants Handbook; Ch. 62-342.750(1)(c), F.A.C.) The FDEP rule goes on to state that Success means when a Mitigation Bank m eets the success criteria provided in Section 62-312.350, F.A.C., and in the Mitigation Bank Permit. Section 62-312.350, F.A.C. deems mitigation successful if three conditions are met: 1. All applicable water quality standards must be met. The state of Florida does not currently have water quality standards that specifically address wetland water quality, however the general state water quality stan dards established in Chapter 62-302 Surface Water Quality Standards, F.A.C. apply. Ra rely did bank permits require water quality monitoring, and in the few permits that did mention water quality, generally it was in regard to monitoring turbidity during construction activities. 2. The mitigation project must have sufficien t hydrology to sustain it. This was sometimes identified in permits as having a specified acreage of jurisdictional wetland, pursuant to Section 373.421, F.S. It seems intuitive that success of wetland restoration, enhancement, preservation, and particular ly creation projects should be deemed successful only if they can be clearly identifie d as jurisdictional wetlands, though not all bank permits specified this condition. In a study of compensatory wetland mitigation throughout the United States, ELI (2002) found that nationwide just over half of wetland mitigation banks with explicit performance standards include hydrologic criteria. 3. For mitigation success, the project must meet permit specific success criteria. Generally this was the main condition identified to determine success for banks. As noted above, particularly in the discussions of natu ral communities, groundcover, and community

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135 structure, many permits do not state the intended target community, establish a reference standard condition, or c onsider groundcover and other community components in the determination of success. Another controversy surrounding th e awarding of potential cred its deals with the types of mitigation and the communities receiving credit s including creation and preservation of wetlands and preservation of upland areas. Genera lly the greatest amount of potential credits is awarded for wetland creation as it represents the greatest potential lift, despite the low success rate of attaining wetla nd function with such endeavors (Sto lt et al. 2000, ELI 2002) In addition, there is some loss of upland f unction in areas converted to we tland, and the redistribution of wetlands across the landscape should be consider ed. However, state rules require that no credits awarded for freshwater wetland creation shall be released until the success criteria included in the mitigation bank permit are met (12.4.5(c), SJRWMD App licants Handbook; Ch. 62-342.470(3), FAC), thereby addressing the qu estion of success rate for creation. The Federal Guidance for the Establishment, Use and Operation of Mitigation Banks (1995) states that preservation shoul d only be used under exceptional circumst ances, yet Section 373.4135, F.S. states that Mitigation banks shoul d emphasize the restoration and enhancement of degraded ecosystems and the preservation of uplands and wetlands as intact ecosystems. Preservation acreage made up a major component in some Florida banks. A similar disconnect was found regarding awarding credits to upland areas. While many studies suggest the importance of uplands in bufferi ng wetland and aquati c ecosystems, providing support habitat for valuable wildlife species, a nd protecting the functional integrity of these systems (i.e., Brown et al. 1990, JEA 1999), pres ervation or enhancement of upland ecosystems alone do not increase total acreage of wetland in the landscape. However, the state directs mitigation banks to include both uplands and wetlands in banks as intact ecosystems (Section 373.4135, F.S.). Coordination and Standardization among Agencies In a study of compensatory wetland mitigation across the United States, ELI (2002) suggested that differences among permits and supporting docum ents make comparisons difficult. This is true not only between fe deral and state documents, but also among documents from the four state agencies that permit Florida mitigation banks : FDEP, SFWMD, SWFWMD and SJRWMD. In fact, simply tracking down documentation for each bank proved difficult in many instances. A new internet-based tracking system for United States Army Corps of Engineer (Corps) to monitor banks, called the Regional Internet Bank Information Tracking System (RIBITS), should provide a warehouse for bank documentation at the federal level. The RIBITS interface will allow Corps staff and the general public to track the status of banks, track credit release and credit debits, see compliance reports, and ema il information requests. A similar electronic database for tracking and storing bank permits at the state level would be useful. However, suggestions for centralized databases have been made in the past (e.g., Ke ntula et al. 1992) with little recent progress.

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136 Similarly, having a standard format for permits i ssued by state agencies would enable quick and efficient comparison among the state banks. This would also ensure that important information has not been overlooked. While the Mitigation Bank Review Team (MBRT) established through the Joint State/Federal Mitigati on Bank Review Team Process for Florida (Story et al. 1998) provides a forum for state and federal agencies to work together on bank reviews, the MBRT and recommended procedures are not binding on any of the agencies. In a few instances, the state and federal permits diverged in important points which leaves conf usion over key issues, such as the number of potential credits. Regulatory Agency Compliance Responsibilities While time and costs are no doubt limiting factors in the availability of agency personnel to conduct frequent and thorough site visits, increasi ng agency oversight and interactions with bank managers should enhance overall compliance and achievement of final success. Frequent inspection should provide motivation for bank ma nagers to maintain and improve ecosystem function between site visits. At a minimum, no agency should release credits without a bank inspection of sufficient detail to confirm that monitoring reports correctly document site condition and that required rel ease criteria have been met. Site visits are important to help understand th e unique characteristics of each bank. In some instances, the quality and detail provided in a mo nitoring report does not re flect the quality of on the ground efforts. Wetland ecolog ical condition and progress of restoration efforts are highly dependant on the knowledge and experience of the land manager and the interaction of the bank manager with the respective regulatory agen cy. FDEP, SJRWMD, SFWMD, and SWFWMD all operate somewhat differently regarding permit and compliance for banks. It appears that typically for FDEP the same individual is re sponsible for permit review and following up with compliance. However for SFWMD different indi viduals are responsible for each stage of the bank, so that once a permit has been approved the responsibility of compliance is shifted to someone who was not involved in the initial permit pr ocess. The benefit of this procedure is the additional oversight provided by a new individual. However, the down side is that the compliance office has no permit review experien ce with the bank manager, the mitigation plan, or the property. Ecological Integrity Before compensatory wetland mitigation is consid ered, state and federal regulations propose that first wetland impacts are avoided and second that unavoidable wetland impacts are minimized. Remaining wetland impacts are then mitigated w ith the intention of replacing lost wetland function and achieving the often proclaimed no net loss of wetland function. The impetus for wetland protection comes from protecting the physic al, biological, and chemical integrity of our Nations waters, particularly in matters of human health and economic concerns (e.g., coastal fisheries, navigation). Defining ecological integrity of a delineated wetland or water body can be done in a number of different ways, each reachi ng a somewhat different conclusion depending on what was measured and how it was quantified. There is currently no single scientifically agreed upon best method to assess the ecologi cal integrity of an ecosystem. However,

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137 developing a repeatable and objective measure of eco logical integrity that is easy to implement and unambiguous would be ideal. The variability in the wetland community types w ithin the 29 banks included in this study plus the fact that anywhere from one single wetland community type to multiple different wetland community types existed at each bank made a simple calculation of ecological integrity impracticable. In fact, most assessment method s developed to measure ecological integrity are wetland community specific (e.g., HGM, FWCI) or are simply not meant to be used as a comparison against other wetland community t ypes (e.g., WRAP, UMAM), in part due to the different ecosystem services and functions prov ided by each different wetland community type (Chapter 62-345.300, F.A.C.). Even if these issu es could be overcome, one may expect many banks would achieve similar, average scores due to the dampening effect that would come into play when scores for different community types within a bank were averaged. The number of potential mitigation credits is rel ative to that [ecological value] obtained by successfully creating one acre of wetland (Ch 62-342.470(2), F.S.). Wetland assessment areas in this study located in banks that had achieved final permit success criteria and had all potential credits released did not receive the highest po ssible scores for the field assessment methods, suggesting full wetland function had not been a ttained, as measured by these methods. Some banks near busy highways, receiving polluted wa ter (e.g., receiving water from a canal that receives urban stormwater runoff), or adjacent to high intensity human development activities (e.g., high-density single family residential), were assumed to have the potential to provide full wetland function. However, the landscape of Florida has become more urban and Florida has one of the highest rates of conversion of rural to urban land use (Reynolds 2001). Realistic withmitigation scenarios should be of primary importance for determining potential credits for a bank. This draws into question whether the same wetland functions are being restored within banks as are being lost at impact sites. Unfortunately, this study was lim ited to wetland assessment areas within banks, and we cannot comment specifically on what functions have been lost due to permitted wetland impacts. We can, however, focus on our understanding of the differences between the community structure and functional a ssessment scores of wetland assessment areas within banks and reference wetlands. In a stud y of the effectiveness of compensatory wetland mitigation in Massachusetts, Brown and Veneman (2001) found that while all projects were in compliance, plant community structure at mitiga tion wetlands was not similar to the wetlands that had been impacted, leading to a loss of wildli fe habitat and utilization functions. Even when water quality and sediment control functions we re replaced, there was still a calculated net loss of wetland function (Brown and Veneman 2001). Few studies have attempted to link community structure with function, though many assessment methods are based on the idea (e.g., VIBI, Mack et al. 2000; FWCI, Lane et al. 2003, Reiss and Brown 2005a). While community structure is c onsidered relatively easy to measure, direct measures of wetland functions are either not available or are more difficult and more time intensive. Further, there is some concern th at when restoring a single wetland function or a limited number of wetland functions, dissimilarities in community structure may still occur. A study in New York by McKenna (2003) found simila r rates of production and respiration, which

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138 are wetland functions, at a restored wetland a nd reference wetland. However, the community structure was not similar between these wetlands, and McKenna ( 2000) suggested that different foodweb pathways resulted. This is an important consideration for any form of mitigation. For example, simply restoring or enhancing hydro logic connectivity or we tland volume for flood attenuation may never result in a fully func tioning wetland consider ing all other potential wetland functions. Designing miti gation to address on ly a subset of all possible wetland functions provided by a certain wetland type coul d easily translate into a net loss of some wetland function if mitigation assumed equal impr ovement or replacement of all functions was attainable. While methods are not currently available to answer the questions about how and which functions should be restored, th ere are methods available for de termining ecological integrity. Perhaps HGM best addresses the various wetlan d functions by arriving at functional capacity index scores for each function separately. From an ecological perspective, separate accounting of each lost function may be the best means of accounting. However, from a regulatory perspective, accounting separately for each lost wetland function could further complicate the process. That does not mean this is not the best approach, but perhaps not the most realistic. One of the driving principles of ecosystem re storation lies in the concept of determining a reference standard community type. This concep t is similarly applied in the determination of ecological integrity, as community structure is compared to that of a reference standard community in order to assess ecological integrity. All of the field assessment methods used in this study were developed with regard to reference standard ecological communities. Some measures of wetland function can be calculated through rapid as sessment methods and best professional judgment (e.g., WRAP, UMAM), measures of community struct ure (e.g., FWCI), or measures of community variables (e.g., HGM). Use of the more detailed assessment methods (e.g., FWCI, HGM) may provide a clearer picture of wetland function through measures of community structure and/ or abiotic variables. Limitations to Study It is important to note that we are unable to comment specifically on the advantages of mitigation banking for maintaining no net loss of wetla nd function as compared to other methods of mitigation (e.g., on-site mitigation, in-lieu fee, etc. ). In addition, we are unable to definitively suggest there is a calculated no net loss of wetland function, as we did not compare wetlands on impact sites to wetlands in banks. This is an important avenue to be explored. What we can say is that, when permits assume that the with -bank scenario attains full wetland function and success criteria are established based on assumed attainment of full wetland function, any wetland (or upland) community in a bank that falls short of full wetland function represents a potential net loss of wetland function. Future Research Direction Two primary avenues for future research have b een identified through this study. First, further development of wetland assessment methods (e .g., FWCI, HGM) for additional Florida regions and wetland community types should be a prior ity in order to further accounting of wetland

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139 function. Second, further studies should focus on what wetland functions are being lost in wetland impact sites in relation to the mitigation provided. When this project began, the FWCI was consider ed to be one of the primary detailed assessment methods that would be used to assess wetland assessment areas within banks. However, once site visits and field sampling began, it became a pparent that the applica tion of the FWCI would be limited by wetland community type, as the FWCI has only been developed for depressional herbaceous wetlands (Lane et al. 2003), depre ssional forested wetla nds (Reiss and Brown 2005a), and forested strand and floodplain wetl ands (Reiss and Brown 2005b). Further, while separate FWCIs have been developed for diatom, macrophyte, and macroinvertebrate assemblages, site conditions during the samp ling period (May 2005-September 2006) prevented collection of diatom and macroinvertebrate samples at most sites. The general lack of correlati on among the rapid field assessme nt methods (e.g., WRAP, UMAM) with the more detailed field assessment met hods (e.g., HGM, FWCI) may be attributable to the small sample size or the variability in wetland comm unity type. It is unlik ely that there was truly no correlation among these methods, as the refe rence database used to develop the FWCI showed significant correlations among LDI, WRAP, and FWCI (R eiss and Brown 2007, in press). Although HGM and FWCI methods were more time consuming and labor intensive, further development and testing of field based biological assessment met hods and application of these tools for monitoring and assessment of rest oration, creation, enhancem ent, and preservation effectiveness for wetlands within mitigation ba nks could strengthen the foundation for a basis of calculating wetland function. In addition, undertaking a detailed study that meas ures the ecological integrity of wetlands lost from impacts compared to that gained from atta inment of permit success criteria at banks should be considered. No true calcula tion of net wetland function can be considered after-the-fact at wetland impact sites. Such a st udy would require a long time fram e, addressing initial wetland condition at the bank, wetland condition at the bank at the time of incremental credit releases, wetland condition at the bank following final release of credits after meeting permit success criteria, and assessments at each wetland impact project prior to impact that purchased credits from the bank, using the same assessment method or set of a ssessment methods throughout the study. While such a study may sound massive and unfeasible, it is seemingly the only way to truly account for functional gains or losses from compensatory mitigation and to calculate net loss. Conclusion Return of full wetland function may be an im possible goal given current and future human development activities across the Florida lands cape. A more realistic outlook on mitigation outcomes would probably reduce the amount of potenti al credits allocated fo r a particular site. Some may argue that this would reduce the econom ic incentive of mitigation banking. However, economic evaluation is beyond the scope of this study and existing state wetland regulatory rules.

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140 One of the purported benefits of wetland mitigation banks is that mitigation is in place prior to wetland impacts, which is an improvement over on-site mitigation that allows for the impact of one wetland resource prior to the enhancement or creation of another. However, for mitigation banks, it is unclear how much wetland function is act ually provided at the time of credit releases. Initial credit releases are based on recording of conservation easement, often with no additional mitigation activities or site improvements, such that there may be a temporary loss associated with this practice. Overall, most of the wetland mitigation banks showed potential to provided increased wetland function following restoration. However, many wetland mitigation banks were limited by their position in the landscape, managed hydrologic re gimes and altered benefits to downstream systems, water quality concerns, or other barrie rs to attaining full function. Having realistic expectations of the potential f unctional gain and clearly defini ng reference standard conditions may lessen the potential of net loss in wetland mitigation banks. As noted in compensatory mitigation studies in Massachusetts (Brown a nd Veneman 2001), California (Ambrose et al. 2006), and Ohio (Mack and Micacchion 2006), while most wetland mitigation banks may have the potential to meet permit success criteria, this does not necessarily equate to their achieving full wetland function. Basic ecological principles can better dictate a more sensible way to plan, implement, and manage mitigation banks, with c onsiderations including edge effects such as roads and towers, core to edge ratios for habita t, fragmentation and habi tat loss in the landscape, and species interaction. If these basic principles are over looked, then the assumption of achieving function has no validity. Mitigation banks must be assessed realistically for credit potential.

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141 REFERENCES Adams, S.M. 2002. Biological indicators of aqua tic ecosystem stress: in troduction and overview. Pages 1-11 in S.M. Adams, editor. Biologica l indicators of aquatic ecosystem stress. American Fisheries Society. Bethesda, Maryland, USA. Ambrose, R.F., J.C. Callaway, and F.F. Lee. 2006. An evaluation of compensatory mitigation projects permitted under Clean Water Act Sect ion 401 by the California State Water Quality Control Board, 1991-2002. Final Report to the California Environmental Protection Agency, California State Water Resources Control Board, Los Angeles, California, USA. Contract number: 03-259-250-0. Analyse-it Software, Ltd. 1997-2003. vers ion 1.67. Leeds, England, United Kingdom. Arcview GIS 3.2 Environmental Systems Research Institute, Inc. 1999. Neuron Data, Inc. 19911996. Portions copyright 1991-1995 Arthur D. Applegate. Redlands, California, USA. Aresco, M.J. 2005. Mitigation measures to re duce highway mortality of turtles and other herpetofauna at a north Fl orida lake. Journal of W ildlife Management 69(2):549. Ashley, E.P., and J.T. Robinson. 1996. Road mortality of amphibians, reptiles and other wildlife on the Long Point Causeway, Lake Erie, Ontario. Canadian Field Naturalist 110(3): 403-412. Barbour, M.T., J. Gerritsen, and J.S. White. 1996. Development of the stream condition index (SCI) for Florida. A Report to the Florid a Department of Envi ronmental Protection, Stormwater and Nonpoint Source Management Section. Tetra Tech, Inc. Owing Mills, Maryland, USA. Bardi, EB, MT Brown, KC Reiss, MJ Cohe n (2005) UMAM Training manual: Web-based training manual for Chapter 62-345, FAC fo r wetlands permitting. Available at: http://www.dep.state.fl. us/labs/library/index.htm Beck, W.M. 1954. Studies in stream pollution biol ogy I: a simplified ecologi cal classification of organisms. Quarterly Journal of the Fl orida Academy of Science 17(4): 211-227. Breshears, D.D., J.W. Nyhan, C.E. Heil, and B.P. Wilcox. 1998. Effects of woody plants on microclimate in a semiarid woodland: soil temperature and evaporation in canopy and intercanopy patches. Internati onal Journal of Plant Sciences 159: 1010. Brown, M.T., J. Schaefer, and K. Brandt. 1990. Buffer zones for water, wetlands, and wildlife in East Central Florida. CFW Publication #89 -07, Florida Agricultura l Experiment Stations Journal Series No. T-00061. Brown, M.T. and M.B. Vivas. 2005. A landscape development intensity index. Environmental Monitoring and Assessment 101: 289-309. Brown, P., and Lant. 1999. The effect of we tland mitigation banking on the achievement of nonet-loss. Environmenta l Management 23(3): 333-345. Brown, S.C. and P.L.M. Veneman. 2000. Effectiv eness of compensatory wetland mitigation in Massachusetts, USA. Wetlands 21(4): 508-518. Campbell, D.A., C.A. Cole, and R.P. Brooks. 2002. A comparison of created and natural wetlands in Pennsylvania, USA. We tlands Ecology and Management 10: 41. Clewell, A. 1999. Restorati on of riverine forest at Ha ll Branch on phosphate-mined land, Florida. Restoration Ecology 7(1): 1-14. Cohen, M.J., S.M. Carstenn, and C.R. Lane. 2004. Fl oristic quality indices for biotic assessment of depressional marsh condition in Florid a. Ecological Applications 14(3): 784-794.

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An Evaluation of the Effectiveness of Mitigation Banking in Florida: Ecological Success and Compli ance with Permit Criteria

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An Evaluation of the Effectiveness of Mitigation Banking in Florida: Ecological Success and Complian ce with Permit Criteria Kelly Chinners Reiss1, Erica Hernandez2, Mark T. Brown1 1Howard T. Odum Center for Wetlands University of Florida Gainesville, Florida 32611-6350 2Department of Environmental Protection Kissimmee Prairie Preserve Okeechobee, Florida 34972 Final Report Submitted to the Florida Department of E nvironmental Protection Under Contract #WM881 United States Environmental Protection Agency Region Four Under Contract #CD 96409404-0 May 2007

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i ACKNOWLEDGEMENTS This report concludes a two year study on Flor ida wetland mitigation banks. Suggestions and guidance were provided by C. Bersok, R. Butgerei t, J. Espy, R. Fryde nborg, V. Tauxe, and N. Wellendorf with the Florida Department of Envi ronmental Protection; A. Bain and E. Cronyn with the South Florida Water Management Distri ct; C. Hull with the Southwest Florida Water Management District; M. Reiber with the St. Jo hns River Water Manageme nt District; R. Evans with the United States Environmental Protectio n Agency; C. Noble with United States Army Corps of Engineers; and M. McGuire with Na tional Oceanic Atmospheric Administration. Land managers and/or land owners for the 29 wetland mitigation banks included in this study provided valuable assistance in granting site acce ss, providing site tours, and/or providing documentation including permits and monitoring reports. We would like to acknowledge the cooperation of M. Brown with Ba rberville Conservation Area; J. David with Bear Point; L. Alderman and L. Zenczak with Big Cypress; D. Mc Intosh and C. Olson with Bluefield Ranch; C. Kocur with Boran Ranch; C. Chown with CGW Bank; E. Colbert with Colbert-Cameron; R. Pavelka and Kevin Erwin with Corkscrew; T. Odom with East Central, Florida Mitigation Bank and Reedy Creek; S. Collins, J. Lindsay, B. Ma us, and G. West with Everglades Mitigation Bank; D. Duke and M. White with Florida Wetl andsbank; S. Kaufmann with Garcon Peninsula Mitigation Bank; S. Bradow with Graham Swamp; The National Park Service at Hole in the Donut/Everglades National Park; A Fickett with La ke Louisa and Green Swamp; R. Fowler, P. Henn and S. Tonjes with Lake Monroe; R. Pavelk a and C. Bowman with Little Pine Island; E. Hale with Loblolly Mitigation Bank, Sundew M itigation Bank, and Tupelo Mitigation Bank; K. Olsen and K. Bennett with Loxahatc hee; D. Duke, J. Styer and T. Trettis and other onsite staff with Panther Island; J. Gilio with R.G. Reserve; B. Jackson with Split Oak; J. Clark and Kathy Hale with TM-Econ; and S. Carnival and S. Sp aulding with Tosohatchee. Thank you to all the bank owners who gave permission to allow access to their property. We would also like to acknowle dge the water management distri ct staff who have not already been mentioned that gave interviews regarding compliance on the mitigation banks; P. Fetterman with the South West Florida Water Management Di strict; S. Elfers, H. Herbst, S. McCarthy, S. McNabb, J. Meyer, and T. Torrens with the South Florida Water Ma nagement District. This project and the preparation of this re port were funded in part by a United States Environmental Protection Agency (USEPA) Regi on Four grant to the Division of Water Resource Management of the Florida Depa rtment of Environmental Protection. Finally, thank you to Kissimmee Prai rie Preserve State Park mana gement and staff for providing infrastructure, resources, and support for this study.

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ii TABLE OF CONTENTS Page ACKNOWLEDGEMENTS.............................................................................................................i LIST OF TABLES................................................................................................................. ........iv LIST OF FIGURES................................................................................................................ .......vi EXECUTIVE SUMMARY.........................................................................................................viii CHAPTER 1 INTRODUCTION................................................................................................................. ....1 Background..................................................................................................................... ............1 Mitigation Bank Regulations.................................................................................................... ..2 Federal Coordination........................................................................................................... .......4 Florida Wetland Mitigation Banks..............................................................................................4 Definition of Success.......................................................................................................... ........5 Purpose of Study............................................................................................................... ..........9 2 METHODS...................................................................................................................... ........11 Mitigation Bank Locations...................................................................................................... .11 Permit Review Procedures....................................................................................................... .13 Reference Standard Condition..................................................................................................14 Site Visits Procedure.......................................................................................................... .......14 Uniform Mitigation Assessment Method (UMAM).............................................................18 Wetland Rapid Assessment Procedure (WRAP)..................................................................18 Hydrogeomorphic wetland assessment (HGM)....................................................................19 Florida Wetland Condition Index (FWCI)............................................................................19 Landscape Development In tensity (LDI) index....................................................................21 3 REVIEW OF PERMIT SUCCE SS CRITERIA AND CREDIT RELEASE...........................23 Mitigation Goals and Success Criteria......................................................................................23 Credit Potential............................................................................................................... ..........28 Preservation................................................................................................................... ............29 Credit Release................................................................................................................. ..........30 Legal Actions.................................................................................................................. ......30 Construction and Management Activities.............................................................................32 Monitoring and Interim Release Criteria..............................................................................43 Final Success Determination and Release............................................................................45 Compliance with Permit Schedule of Activities and Success Criteria.....................................46 Summary........................................................................................................................ ...........46

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iii4 DETERMINATION OF ECOLOGICAL INTEGRITY..........................................................57 Definition of Ecological Integrity.............................................................................................57 Results of Assessment Methods................................................................................................58 UMAM: Uniform Mitigation Assessment Method...............................................................66 WRAP: Wetland Rapid Assessment Procedure....................................................................72 HGM: Hydrogeomorphic Wetland Assessment Method......................................................77 FWCI: Florida Wetland Condition Index.............................................................................83 LDI: Landscape Development Intensity Index.....................................................................88 Comparison of Assessment Methods........................................................................................92 UMAM and WRAP..............................................................................................................92 UMAM, WRAP, and LDI.....................................................................................................96 HGM and FWCI...................................................................................................................96 Suggestions for Assessment Methods.....................................................................................109 5 PERMIT REVIEW AND ECOLOGICAL INTEGRITY: CASE STUDIES........................111 Case Study: East Central....................................................................................................... ..112 Case Study: Florida Wetlandsbank.........................................................................................116 Case Study: Sundew Mitigation Bank....................................................................................121 6 DISCUSSION................................................................................................................... .....127 Permit Review.................................................................................................................. .......127 Natural Communities..........................................................................................................128 Groundcover Restoration....................................................................................................129 Community Structure..........................................................................................................130 Fire Management................................................................................................................131 Sustainability and Landscape Position................................................................................132 Credits for Achieving Success Criteria...............................................................................134 Coordination and Standa rdization among Agencies...........................................................135 Regulatory Agency Compliance Responsibilities..............................................................136 Ecological Integrity........................................................................................................... ......136 Limitations to Study........................................................................................................... .....138 Future Research Direction......................................................................................................138 Conclusion..................................................................................................................... .........139 REFERENCES..................................................................................................................... ......141 APPENDIX A Field Standard Operating Procedures................................................................................A-1 B Field Data Sheets............................................................................................................ ....B-1 C Mitigation Bank State Permit Summaries with Success Criteria and Credit Release Schedules...................................................................................................................... ......C-1

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iv LIST OF TABLES Table Page 1-1 Details of the permitted wetland mitigation banks..............................................................6 2-1 Sample size of reference database for depr essional herbaceous, depressional forested, and forested stra nd and floodplain wetlands.......................................................15 2-2 Sources of ecological information from pr int media used to establish the expected reference standard wetland condition................................................................................15 2-3 Sources of ecological information from th e internet used to es tablish the expected reference standard wetland condition................................................................................16 2-4 Nonrenewable energy value assigned to land use categories used to calculate the Landscape Development In tensity (LDI) index.................................................................22 3-1 Target community and reference condition information in mitigation bank permits........25 3-2 Successes criteria for nati ve wildlife, monitoring requi rements in state permits..............27 3-3 Percent of total potential credits rele ased for each activity or release criteria...................31 3-4 Final success criteria for exotic and nuisance vegetative cover for state permits.............37 3-5 Success criteria related to native vegetati on cover and survivability of planted vegetation in state permits.................................................................................................39 3-6 Summary of regulatory complian ce for 28 wetland mitigation banks...............................48 4-1 Area of wetland mitigation banks and assessment areas included in the this study..........61 4-2 Overview of wetland assessment areas including Florida Land Use, Cover and Forms Classification System, associated wetland community type, and wetland assessment methods applied..............................................................................................63 4-3 Uniform Mitigation Assessment Method (U MAM) scores for 58 wetland assessment areas at 29 wetland mitigation banks.................................................................................67 4-4 Uniform Mitigation Assessment (UMAM) scores categorized by Florida Land Use, Cover and Forms Classification System (FLUCCS) wetland community type................69 4-5 Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas.......................................................................................................................... .........73 4-6 Wetland Rapid Assessment Procedure (WRAP) scores categorized by Florida Land Use, Cover and Forms Classification Sy stem (FLUCCS) wetland community type........75 4-7 Hydrogeomorphic wetland assessment method (HGM) variable for flats wetlands in the Everglades.............................................................................................................. ..78 4-8 Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores (Function) for six flats wetlands in the Everglades................................................79 4-9 Hydrogeomorphic wetland assessment me thod (HGM) variable for depressional wetlands in peninsular Florida...........................................................................................81 4-10 Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores (Function) for nine depressional wetlands in peninsular Florida............................82 4-11 Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for six depressional herbaceous wetlands....................................................................................................................... ......84

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v4-12 Macrophyte Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for three depressional forested wetlands........85 4-13 Macrophyte Florida Wetland Condition Index (FWCI) metric scores total FWCI scores, and percent of reference condition for a fore sted strand wetland within TM-Econ Mitigation Bank.................................................................................................85 4-14 Macroinvertebrate Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for two depressional herbaceous wetlands....................................................................................................................... ......87 4-15 Macroinvertebrate Florida Wetland Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference conditio n for two depressional forested wetlands....................................................................................................................... ......87 4-16 Landscape Development Inte nsity (LDI) index scores......................................................89 4-17 Pair wise comparisons among scoring cat egories and total scores for the Uniform Mitigation Assessment Method (UMAM), We tland Rapid Assessment Procedures (WRAP), wetland scale Landscape Development Intensity (LDI) index, and bank scale LDI index................................................................................................................ ..97 4-18 Correlations among Uniform Mitigation Assessment Method (UMAM) and scoring categories, Wetland Rapid Assessment Pro cedure (WRAP) and scoring categories, wetland scale Landscape Development Intens ity (LDI) index scores, bank scale LDI index scores, Hydrogeomorphic wetland asse ssment method (HGM) functional capacity index scores, macrophyte Florida We tland Condition Index (FWCI) scores, and macroinvertebrate FWCI scores................................................................................101 4-19 Percent of reference standard conditions fo r Uniform Mitigation Assessment Method (UMAM), Wetland Rapid Assessmen t Procedure (WRAP), macrophyte Florida Wetland Condition Index (FWCI), and macroinvertebrate FWCI assessment methods for 16 wetland assessment areas.....................................................103 4-20 Percent of reference standard condi tions for Hydrogeomorphic wetland assessment method (HGM) functional capacity index sc ores for 15 wetland assessment areas........104 5-1 Credit release schedule for East Central..........................................................................114 5-2 Wetland assessment scores for two wetla nd assessment areas at East Central...............115 5-3 Success criteria for Florida Wetlandsbank......................................................................118 5-4 Wetland assessment scores for two wetland assessment areas at Florida Wetlandsbank................................................................................................................... 119 5-5 State permit credit release schedule for Sundew Mitigation Bank from SJRWMD technical report............................................................................................................... ..123 5-6 Federal permit credit release schedule from the Mitigation Bank Instrument for Sundew Mitigation Bank.................................................................................................124 5-7 Wetland assessment scores for two wetland assessment areas at Sundew Mitigation Bank...............................................................................................................1 25

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vi LIST OF FIGURES Figure Page 1-1 Location of 45 Florida wetland mitigation banks................................................................5 1-2 Florida state agency responsibility for wetland mitigation banks for currently permitted mitigation banks and land area of permitted wetland mitigation banks..............8 2-1 Location of 29 wetland mitigation banks included in this study.......................................12 2-2 Florida wetland mitigation banks permitted by year.........................................................13 3-1 Total area of permitted mitigation banks in relation to total potential credits...................29 3-2 Permit requirements from Ga rcon Peninsula Mitigation Bank..........................................33 3-3 Dense cover by the invasive exot ic species melaleuca or punktree ( Melaleuca quinquenervia ) prior to restoration activi ties at Little Pine Island....................................35 3-4 Final success criteria allowance for exotic vegetation percent cover by mitigation bank and regulating agency...............................................................................................38 4-1 Applicable range of the Everglades fl ats Hydrogeomorphic wetland assessment method (HGM) in South Florida........................................................................................58 4-2 Applicable ranges (reference domain) of depressional wetlands Hydrogeomorphic wetland assessment method (HGM) and depr essional herbaceous Florida Wetland Condition Index (FWCI) in peninsular Florida.................................................................59 4-3 Uniform Mitigation Assessment Method (UMAM) scores for the 58 assessment areas in relation to permitted lift (c redits/ac) and potential credits released (%) at respective bank............................................................................................................. ..71 4-4 Wetland Rapid Assessment Procedure (WRAP) scores for the 58 assessment areas in relation to permitted lift (c redits/ac) and potential credits released (%) at respective bank............................................................................................................. ..76 4-5 Wetland scale and bank scale Landscape Developmen t Intensity (LDI) index scores for 55 wetland assessment areas.............................................................................91 4-6 Uniform Mitigation Assessment Method (UMA M) and Wetland Rapid Assessment Procedure (WRAP) were positively correlated..............................................93 4-7 The difference between Uniform Mitigation Assessmen t Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas............................................................................................................... ..94 4-8 Linear regression between Unif orm Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas............................................................................................................... ..95 4-9 Correlations among Uniform Mitigation Assessm ent Method (UMAM) Location and Landscape Support scoring category with we tland scale and bank scale LDI index scores................................................................................................................... .....98 4-10 Wetland Rapid Assessment Procedure (W RAP) correlations with wetland scale Landscape Development In tensity (LDI) index.................................................................99 4-11 Bank scale Landscape Development Inte nsity (LDI) index score correlations...............100 4-12 Comparison among six Everglades fl ats wetlands of UMAM, WRAP, and HGM functional capacity indices...............................................................................................106

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vii4-13 Comparison among six depressional herbaceous wetlands of UMAM, WRAP, HGM functional capacity indices, macrophyte FWCI, and macroinvertebrate FWCI........................................................................................................................... .....107 4-14 Comparison among four forested wetlands of UMAM, WRAP, HGM functional capacity indices, macrophyte FWCI, and macroinvertebrate FWCI...............................108 5-1 Landscape location of East Cent ral in northeast Orange County....................................113 5-2 Landscape location of Florida Wetla ndsbank in western Broward County and surrounding land use........................................................................................................117 5-3 Landscape location of Sundew Mitigation Bank in Clay County and surrounding land use....................................................................................................................... .....122

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viii EXECUTIVE SUMMARY AN EVALUATION OF THE EFFECTIVENESS OF MITIGATION BANKING IN FLORIDA: ECOLOGICAL SUCCESS AND COMPLIAN CE WITH PERMIT CRITERIA The primary purpose of this study was to determ ine the effectiveness of mitigation banking in Florida by determining compliance with perm it success criteria, evaluating the ecological integrity of wetlands within wetland mitigation banks, and evaluating whether permit compliance reflects ecological integrity. Increasing the effectiveness of mitigation banking and improving wetland assessment methodologies should increase the capacity for long term protection and restoration of wetlands. The long term effects of this project wi ll be to improve the ecological performance of mitigation banks, management of mitigation banks, and stewardship of wetland resources to better meet the goals of the Clean Water Act. Specifically, this study used a co llection of available wetland assessment methods combined with permit and document review to determine the condition of re stored, enhance d, created, and preserved wetlands within wetland mitigation banks. Permit review involved determining stated permit success criteria and mitigation activities. Two rapid assessment methods, Uniform Mitigation Assessment Method (UMAM) and We tland Rapid Assessment Procedure (WRAP), and two field intensive assessment methods, H ydrogeomorphic approach to assessing wetland function (HGM) and Florida Wetland Condition Index (FWCI), were applied to select wetland assessment areas. A fifth assessment method, th e Landscape Development Intensity (LDI) index relies on geographic information systems (GIS) analysis. Wetland assessment techniques employed varied by wetland type, but all generally relied upon a comparison of the current wetland condition to reference standard wetland condition. Reference standard condition was defined as the c ondition of wetlands surrounded by undeveloped landscapes and without apparent human induced alterations. By designating a measure of ecosystem condition we refer to what others ha ve described as ecosystem integrity, defined by Karr and Dudley (1981) as the capability of s upporting and maintaining a balanced, integrated, adaptive community of organisms having a sp ecies composition, dive rsity, and functional organization comparable to that of the natural habitat of the region (p. 56). As of November 2006, 45 wetland mitigation banks were permitted under Section 373.4135, F.S. in Florida. Twenty-nine of the permitted wetla nd mitigation banks were visited with functional assessments conducted at 58 wetland assessment areas within those banks between May 2005 and September 2006. The 58 wetland assessment areas were categorized based on the Florida Land Use, Cover and Forms Classi fication System (FLUCCS; FDOT 1999). Both permit review and application of functional asse ssment methods were used to determine the ecological integrity of wetland assessment areas within wetland mitigation banks. Permit reviews were conducted for all 29 wetland mitigation banks visited. In ad dition to permits, annual monitoring reports and other supporting documents were used when ava ilable. Credit releas e schedules and success criteria for each wetland mitigation bank were summarized. The second part of this study involved applicat ion of five wetland assessment methods at 58 wetland assessment areas within 29 wetland miti gation banks. The wetland assessment methods

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ix were Uniform Mitigation Assessment Method (UMAM) (Ch. 62-345, F.A.C.), Wetland Rapid Assessment Procedure (WRAP) (Miller and G unsalus 1999), hydrogeomorphic approach to assessing wetland function ( HGM)(Noble et al. 2002; Noble et al. 2004), Florida Wetland Condition Index (FWCI) (Lane et al. 2003; Re iss and Brown 2005a; Reiss and Brown 2005b), and Landscape Development Intensity (LDI) index (Brown and Vivas 2005; Vivas 2007). UMAM, WRAP, and LDI index were completed at 58 wetland assessment areas. HGM (n=15) and FWCI (n=10) assessments were conducted wh en the type of wetland within the wetland assessment area matched the existing assessment methods. UMAM (0.47-0.93), WRAP (0.48-0.99), and HGM ( 0.31-1.00) assessments showed a similar range of scores (on a scale of 0-1.00, where 1.00 represents the highes t score attainable, a reflection of the reference standard conditio n). Macrophyte FWCI scores ranged from 0.21-0.88 (presented as proportion of reference standard condition). A strong po sitive correlation was found between UMAM and WRAP scores (Sp earman rank correlation r = 0.86, p < 0.001). However for any given wetland, differences from -0.15 to 0.18 between UMAM and WRAP scores were detected with onl y a single wetland assessment ar ea receiving the same UMAM and WRAP score. Across the board, neither UMAM nor WRAP provided consistently higher or lower scores and no trends were detect ed specific to wetland community type. Approximately two-thirds of th e wetland assessment areas (n = 38) had wetland scale LDI index scores less than 2.0 (where 0.0 represents no hu man development), with a mean wetland scale LDI index score of 3.21 ( = 4.87), a median of 0.25, and a high score of 16.65. Wetland scale LDI index scores were calcula ted such that all lands with in the 100 m zone surrounding a wetland assessment area designated as restoration, enhancement, creation, or preservation were assigned LDI index scores reflecting natural lands In this applicatio n, the wetland scale LDI index score was considered a tool to predict th e potential wetland condition based on the restored support landscape. Bank scale LDI index scor es, based on land use within the 100 m zone surrounding a bank, were generally higher, with a mean bank scale LDI index score of 7.78 ( = 5.36), a median of 6.53, and a range from 0.00-18.22 Overall, wetland assessment areas in banks that had achieved final permit success criteria did not receive the highest attainable sc ores for the functional assessme nt methods employed, suggesting full wetland function has not been achieved. Perm it review found that dete rmination of potential credits based on assessment methods (comm only using WRAP) generally assumed that mitigation would result in full wetland function through assigning the highest possible scores for with-mitigation scenarios. Recommendations As a result of permit review and associated assessments, eight recommendations for improving permits and/or restoration plans were developed: 1. Define natural communities and associated reference standard conditions; 2. Emphasize groundcover restoration; 3. Monitor plant and animal community structure, not just presence or cover of exotic or nuisance species; 4. Establish and implement fire management plans;

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x 5. Identify sustainability of m itigation within the landscape; 6. Allocate a higher percent of credits for achie ving success criteria and a lower percent of credits for task completion; 7. Encourage better coordination and standardiz ation among state and federal agencies and between bank managers and agency personnel; 8. Increase compliance responsibilit ies of the regulatory agencies. These suggestions are intended to facilitate improvement in th e ecological condition of wetland and upland communities within wetland mitigation banks permitted in the future. 1. Define natural communities and a ssociated reference standard conditions Defining the target reference standard condition is imperative for su ccessful restoration. In state permits, 13 bank permits described or referred to re ference conditions either as a comp arison to the literature or an actual field comparison. In contrast, 13 bank pe rmits made no mention of reference conditions in state permits. A few of the bank permits recognized the inability to restore natural communities to reference condition and instead established anticipat ed ecological lift from prebank conditions. Language comm only encountered in permits s uggested that the restoration areas would resemble a particular community type, but rarely were explanations given as to how this resemblance would be determined. Ruiz-Jaen and Ai de (2005) noted that existing laws in the United Stated do not require restoration success as defined by comparison to reference standard ecosystems, and that given financia l concerns (e.g., increased monitoring costs for monitoring reference sites as well as restoration sites) it is unlikely that such comparisons to reference sites will be required for future restora tion efforts. While somewhat dated, the Florida Natural Areas Inventory (FNAI) Guide to the Natu ral Communities of Flor ida (1990) would be a useful classification guide in permit review, as it provides a detailed de scription of each of Floridas native communities. 2. Emphasize groundcover restoration Restoration of different community types is dependent on more than replacement of canopy structure alone. Most bank permits had some basic requirement for percent cover of desirable, native species. Fourteen (of 29) bank permits included planting and/or seeding as a requirement for credit release (3 -20%, typically 5-10%), though this has not been broken dow n by canopy or groundcover specie s. However, most of the planting and credit release criteri a emphasized trees rather than groundcover species. While the canopy does influence a great deal about the community (i.e., microclimate, establishment of shade tolerant versus intolerant species, etc. ), fire management, al ong with planting and/or seeding, is necessary in many co mmunity types to ensure esta blishment and maintenance of groundcover. 3. Monitor plant and anim al community structure Most permits required minimal cover by a suite of plant species, the percent cover of a desi rable species to resemble that of a reference standard community, and/or the percent cover by e xotic or nuisance species to be less than some target percentage. However, those criteria do not fully consider the target community structure for both flora and fauna. Ten years ago Mits ch and Wilson (1996) recognized the need for linking structural measures such as species di versity, productivity, or cover, with important ecosystem functions such as wildlife use, nutri ent cycling, or organic matter accumulation. While many studies have noted the return of water storage or water quality functions at restoration sites, rarely do such wetlands provi de comparable community structure or wildlife

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xi habitat functions (e.g., Brown and Veneman 200 1, McKenna 2003, Zampella and Laidig 2003). Mitigation plans should define the target natu ral community; recognize what physical, chemical, and biological characteristics char acterize the target natural community; identify target species and/or community assemblages associated with the target natural community; ensure mitigation plans and subsequent mitigation goals actively meet the life history requirements of those target species and/or community assemblages, incl uding needs such as connectivity, reproduction, food, cover, etc.; and monitor for the occu rrence, reproductive success, and long-term maintenance of these target species and/or community assemblages to ensure mitigation goals have been met. 4. Establish and implement fire management plans Fire management is crucial to successful maintenance of many of Floridas natural commun ities (for details see FNAI 1990). While 26 of the studied banks included some fire dependent communities, only eight banks had a credit release associated with conducti ng a prescribed fire, and a few more banks required prescribed fire as part of the final release criteria. Wh ile prescribed fire was indicated for achieving successful ecosystem restoration, many barriers ar ose to prevent implementation of prescribed fire management plans. At least seven banks included in this study reported that they were behind in accomplishing their prescribed burn pl an for site specific condition, usually because the site was either too wet or too dry. Mitigation bank permits should require successful implementation of prescribed fire and community response to this management tool for credit release in fire-dependent communities. 5. Identify sustainability of mitigation within the landscape Having realistic goals as to the potential function of a wetland mitigation bank should be a priority for assessing with mitigation bank scenarios. The landscape location of compensatory mitigation projects continues to be an important consideration. The landscape of Fl orida has been cross ditched and drained with human settlement, and as such, an ideal landscape setting proba bly does not exist within the state. Forman and Deblinger (2000) suggest th at roadways and conservation areas should be separated, and yet many of the Florida wetland mitigation banks are bordered by busy roadways (e.g., Barberville Conservation Area bordered to the south SR-40; Ev erglades Mitigation Bank/Phase I (FPL) bordered to the east by Card Sound Rd. and the west by US-1) or bisected by busy roads (e.g., Tosohatchee bisected by the Beachline Expressway SR-528; Little Pine Island bisected by SR-78). Consideration of pot ential wetland functional lift should incorporate a landscape perspective. Wetland mitigation in ge neral must be considered a trade-off between temporal and spatial ecosystem function, and the bottom line comes back to having a realistic expectation of attainable function in the calculat ed with mitigation bank scenario. That is, when a bank is adjacent to developed lands, the lo cation and landscape functional component should never be expected to achieve a perfect score. Further, credits should reflect the landscape condition and be realistically base d on limitations to water budget, water quality, connectivity for fauna populations, core to edge ratios for associated species, edge effects, etc. Such concerns will vary for every bank, being based on the community types involved, the associated fauna species, bank size, and surrounding land uses. 6. Allocate a higher percent of credits for achi eving success criteria and a lower percent of credits for task completion Incremental credit release based on completion of activities that do

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xii not necessarily equate to demonstrated achieveme nt of function should be avoided. Mitsch and Wilson (1996) argued a decade ago that efforts to determine wetland restoration or creation success were flawed due to a lack of applica tion of sound wetland science and the weight of schedule-driven construction activi ties, and yet often credit releas e criteria in bank permits were based mainly on task completion. Activity-based credit re leases averaged about 50% of the total potential credits and represented the preservation and completion of the mitigation work at the bank. Although it was recognized th at the actual work was sometimes equated with ecological enhancements, mitigation success may be improved if credits releases were weighted more toward incremental improvement and community response to these treatments and actions, rather than simply completion of predetermined activities. 7. Encourage better coordinati on and standardization among the state and federal agencies and between bank managers and agency personnel In a study of compensatory wetland mitigation across the United States, ELI (2002) suggested that the differences among permits and supporting documents make comparisons difficult. This study found that was true not only between federal and state documents, but al so among documents from the four permitting agencies in Florida. In fact, simply track ing down documentation for each wetland mitigation bank proved difficult in many instances. Once fully on-line, the Regional Internet Bank Information Tracking System (RIBITS), a new inte rnet-based tracking system for United States Army Corps of Engineer (USACE) districts to monitor wetland mitigation banks, should provide a warehouse for wetland mitigation bank documentation at the federal level. A similar electronic database for tracking and storing wetland mitiga tion bank permits at the state level would be useful. However, suggestions for centralized data bases at the state level have been made in the past (e.g., Kentula et al. 1992) w ith little recent progress. All documentation leading up to permit implementation, permits themselves, pe rmit modifications, credit ledgers, and other communications relating to monitoring and manage ment should be centralized and available for review in a digital format. Fu rther, mitigation banks should submit digital copies of reports and communications to be kept in a centralized file Centralizing and tracking this documentation will make the review process more transparent and allow for better tracking of bank histories. 8. Increase compliance responsibilit ies of the regulatory agencies. While time and costs are no doubt limiting factors in the availability of ag ency personnel to condu ct frequent and thorough site visits, increasing agency ove rsight and interacti ons with bank manage rs should enhance overall compliance and achievement of final success. Requiring fre quent inspection should provide motivation for bank managers to maintain and improve ecosystem function between site visits. While no specific time schedule will m eet the needs of all banks or regulators, maintaining regular communication with banks, ev en those not requesting a credit release, is encouraged. At a minimum, no agency should release credits withou t a bank inspection of sufficient detail to confirm that monitoring re ports submitted by the banker correctly document site condition and that require d release criteria were met. Most of the wetland mitigation banks showed pot ential to provide increased wetland function following restoration, assuming completion of restor ation activities. However, for many wetland banks, landscape position is the most limiting factor to attainment of full functional. Clearly defining reference standard conditions and havi ng realistic expectati ons of the potential functional gain may lessen the potential of functional loss in we tland mitigation banks. Many of

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xiii the findings for Florida mitigation banks corrobor ate recent findings in Massachusetts (Brown and Veneman 2001), California (Ambrose et al. 2006), and Ohio (Mack and Micacchion 2006), that while most wetland mitigation banks meet permit success criteria, this does not equate to the structure and function of natural wetland communities. Basic ecol ogical principles can better dictate a more sensible way to plan, impl ement, and manage mitigation banks, with considerations including edge effects such as ro ads and towers, core to edge ratios for habitat, fragmentation and habitat loss in the landscape, and species interacti on. If these ba sic principles are overlooked, then the assumption of achievi ng function has no validity. Mitigation banks must be assessed realistically for credit potential.

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1 CHAPTER 1 INTRODUCTION Wetland mitigation banking has grown steadily in the last decade since state law and rules on mitigation banks were adopted, with 45 wetland m itigation banks currently permitted in Florida. Additionally federal mitigation policy is trending toward a preference for mitigation banks, such as the 1998 Transportati on Equity Act for the 21st Century TEA-21 Rest oration Act (Public Law 105-178) and the recent proposed rule for Co mpensatory Mitigation for Losses of Aquatic Resources (2006). While there are several st udies evaluating project-specific mitigation effectiveness (e.g. FDER 1991b; FDER 1992; Br own and Veneman 2000; Campbell et al. 2002; Morgan and Roberts 2003), few studies have been conducted on mitigation banks (though see Brown and Lant 1999; Ambrose et al. 2006; Mack and Micacchion 2006). The Florida Department of Environmental Protection (FDEP), in conjunction with the University of Floridas Howard T. Odum Center for Wetlands (UF-CF W) carried out this study to evaluate the ecological integrity of mitigation banks. This study also presents a co mparison of different wetland assessment methodologies used to evaluate the ecological integr ity of 29 banks. The study was funded through a grant from the Unite d Stated Environmental Protection Agency (USEPA) Region IV. Background For over 20 years, the federal government, through th e Clean Water Act, and the state of Florida, beginning with the Warren S. Henderson Wetla nds Protection Act of 1984, have regulated wetland impacts. Wetland permitting programs are aimed at maintaining wetland functions and values through avoidance and minimization of wetland impacts and to compensate for unavoidable impacts through wetland mitigation. In 1991, the state conducted an audit of mitigation permitting operations (FDER 1991a) and a study that assessed compliance and effectiveness of a subset of permitted mitigat ion projects (FDER 1991b). Like other reports from around the country (e.g., Roberts 1993; Race and Fonseca 1996; Brown and Veneman 2000; Robb 2002; Morgan and Roberts 2003), th ese studies found significant problems with permit compliance, permit success criteria, and/or the potential for long-term viability of the mitigation area. To address some of these issues, mitigation po licies began to authorize and encourage more consolidated mitigation projects, such as mitigation banks and regional offsite mitigation areas. In Florida, that endorsement came with the pa ssage of the Environmenta l Reorganization Act of 1993, specifically in Section 373.4135, Florida Statutes ( Mitigation banks and offsite regional mitigation ), which initially authorized the use of mitigation banks and offsite regional mitigation to offset impacts, and directed the development of mitigation bank rules. These rules were initially promulgated in 1994 and reflected in Section 373.4136, F.S. ( Establishment and operation of mitigation banks ) in 1996. Florida re presentatives worked closely with federal partners and contributed to the development of the Federal Guidance for the Establishment, Use and Operation of Mitigation Banks published in the Federal Register in November, 1995, and the subsequent Joint State/Federal Mitigation Bank Review Team Process (the Greenbook, cited as Story et al. 1998), which details how to integrate state and federal permitting for mitigation banks in Florida.

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2 In 2001, the National Research Council conducted a review of the federal mitigation program (NRC 2001). Some of the common findings were: high rates of non-compliance; inadequate permit performance and success criteria; limited long term monitoring and management; sites located poorly in landscape; inadequate agency support in compliance m onitoring, tracking, training, and research. The report also emphasized the need to avoid and minimize wetland impacts in the first place. Only when impacts to wetlands cannot be avoided should mitigation be an option. Recommendations for advancing the mitigation program included improvements in technical information requirements, reference-based succe ss criteria, long-term stewardship requirements (including conservation easements and financia l responsibility), assessment methods based on function, and consideration for long-term viability within the watershed. It was thought that mitigation banks would offer advantages in a ddressing landscape planning, financial assurance, and long-term management and t hus circumvent the problems th at were plaguing compensatory mitigation. Additionally, compliance monito ring would be facilitated. Many of the recommendations were incorporated into the federal permitting process for mitigation banks today. Mitigation Bank Regulations In Florida, mitigation banks are regulated by both federal and state agencies. Because both sets of regulatory agencies cooperate d during the development of the regulations, federal and state regulations are similar in principle components and integrally linked in others (i.e., federal agencies generally accept the st ate approved preservation and fina ncial assurance instruments). For the purposes of this study, mitigation banks and regulations will be discussed within the context of state permits, with any significant federal differences note d. This state-centric approach is taken principally because more stat ewide data and documents were available than federal ones. Additionally, as will be detailed later, the stat e has permitted about a dozen more banks than have been federally authorized (generally due to permitting delays rather than fundamental differences in review). The principle laws that regulate Floridas m itigation bank program are Florida Statute 373.4135 Mitigation banks and offsite regional mitigation and Florida Statutes 373.4136 Establishment and operation of mitigation banks Statute 373.4135 authorizes use of mitigation banks and recognizes the improved likelihood of environmenta l success associated w ith the establishment of mitigation banks, specifically favoring the restoration and enhancement of degraded ecosystems and the preservation of uplands and wetlands as intact ecosystems through restoration of ecological communities that were historically present. The criteria for establishing mitigation banks in Section 373.4136, F.S. requires that they: (a) improve ecological conditions of the regional watershed; (b) provide viable and sustai nable ecological and hydrological functions for the proposed mitigation service area; (c) be effectively managed in perpetuity;

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3 (d) prevent destructi on of areas with high ecological value; (e) achieve mitigation success; (f) be located adjacent to lands that will not adversely affect the perpetual viability; (g) meet all wetland permitting criteria; (h) have sufficient legal or equitable inte rest in the property to ensure perpetual protection and management; and (i) meet financial respon sibility requirements. Another important section in this statute defines credits as units of increased ecological value to be determined by a functional assessment method also used to determine ecological debits for wetland impacts. The statute list s factors to be considered when determining credits: the quantity and quality of the wetland and upland enhancement/restoration expected and the likelihood of achieving and main taining the target condition; the degree that management activities such as prescribed fire promote na tural ecological conditions ; the location in the landscape relative to regionally significant an d/or wildlife corridors; wetland and upland ecological and hydrological connect ions and listed species hab itat; and the degree that the property is already protecte d by land use restrictions or the potential for adverse effects if the site is not preserved. Further, this statute indicates that permits should include a sche dule for release of credits based on the performance and criteria in the permit. Factors to be considered include the type of mitigation activities (whether solely preservation or other types of mitigation), time required for those activities to be successful, and ecological va lue associated with each mitigation activity. In practice, most banks receive 10-2 5% of their total potential cr edits upon preservation (usually through a recorded conservation ea sement) and the provision of th e required financial assurance (usually performance bonds or letter of credit payable in to a standby trust) for the implementation and long-term management of th e plan. Additional credits are released for specific mitigation activities such as physical cons truction (e.g., ditch filling, road removal, etc.), exotic species removal, and/or planting. Furthe r incremental credit release is based on regular monitoring and documentation of trending toward su ccess culminating in a determination of final success. Statute 373.4136 also establishes guidelines for the determination of the Mitigation Service Area (MSA) based on regional watersheds. Finally, it allows for the FDEP and state Water Management Districts (WMDs) to establish mo re specific rules, especially pertaining to preservation, financial assurance, and cred it assessment methods. FDEP adopted and administers the mitigation bank rule, Chapter 62342, Florida Administrative Code (F.A.C.), and three of the five WMDs (South Florida Wa ter Management District, SFWMD; Southwest Florida Water Management District, SWFWMD ; and St. Johns River Water Management District, SJRWMD) also adopted and administer similar rules within th eir jurisdiction. Which agency issues a state mitigation bank permit depends on the location and intended use of the bank, as determined through operating agreements between the agencies. In addition to the statutory requirements, the mitigation banking rules provide increased guidance on intent, definitions, details on the required component s of a permit, credit assessment and release, and specifics on th e instruments for preservation a nd for financial assurance. However, the mitigation banking rules do not sp ecify the functional assessment method to be

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4 used. As a result, mitigation banks have been assessed by several function and ratio-based methods. A standard, function-based method for de bit and credit assessmen t for both mitigation banks and all other forms of compensatory mitig ation, called the Uniform Mitigation Assessment Method (UMAM), went into effect in February 2004 under Rule 62-345, F.A.C. It is now used throughout the state on all projec ts requiring mitigation. Mitigation banks permitted prior to 2004 were grandfathered to contin ue to use their original a ssessment method, but a few have chosen to convert to UMAM. Federal Coordination The Federal Guidance for the Establishment, Use and Operation of Mitigation Banks (1995) was issued jointly by the United States Army Corp s of Engineers (Corps), the United States Environmental Protection Agency (USEPA), th e Fish and Wildlife Service (FWS), and, as programmatically appropriate, the Natural Resource Conservation Service (NRCS) and the National Marine Fisheries Service (NMFS). Evaluation of a proposed mitigation bank is undertaken by an interage ncy Mitigation Bank Review Team (M BRT) with federa l authorization of a mitigation bank determined through a binding Mitigation Banking Instrument (MBI) that is signed by both the MBRT members and the banker. The MBI details the establishment, use and operational requirements of the mitigation bank, but dredge and fill operations associated with restoration activities, such as grading, ditch fillin g, installation of water control structures, etc., may require a separate 404 permit. An important difference between state and federa l permitting review is that once a formal permit application is received, the st ate is bound by statutory time cl ocks for review, information requests, and approval while the fe deral agencies are not. While the state and federal guidelines and goals are similar, programmatic and procedural differences can lead to disparate approvals. The development of the Greenbook (Story et al. 1998) was an attempt to minimize duplicate review. It provides for the stat e permit reviewer to co-chair th e MBRT with the Corps. It establishes a pre-application prot ocol that involves a preliminary prospectus and determination of appropriateness. It stipulates a method of determining credits through ratios, Wetland Rapid Assessment Method (WRAP), or variations th ereof. Additionally, it provides guidance indicating that the state permit application not be submitted until significant issues such as the mitigation plan, credit assessment, and MSA, have consensus agreement. However, the Greenbook is not binding on the state, the Corps, or the banker, so adhere nce to the provisions varies. Even when there is consensus on the ma jor components, the final development of details and the permit under the states time clock gene rally precedes that of the federal MBI. Therefore, differences in the final authorizations are common, but typically minor. This project has focused its review on state permits and require ments, but extends to federal requirements as well due to the similarities in state permits and federal MBIs. Florida Wetland Mitigation Banks The 45 state permitted wetland mitigation banks, which are in different stages of project development, served as the initial sample pool fo r this project (Figure 1-1). Table 1-1 lists the banks by name, permitting agency, permit number, permit issue date, bank size, potential credits, type of wetland credits available, and locatio n (county(ies)). Two of the wetland mitigation

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5 Figure 1-1. Location of 45 Flor ida wetland mitigation banks. Wetland mitigation banks included in this study represented by blue circles ( ); wetland mitigation banks not included in this study represented by red squares (). Background is 8-digit Hydrologic Cataloguing Units (HUC) of Florida from the Flor ida Department of Environmental Protection (available at http://www.fgdl.org cover map WATERSHED). banks have received permits for additional phases, Boran Ranch and Everglades Mitigation Bank (FPL), and as such, each phase (permit) is list ed separately. Currentl y, SJRWMD has issued the most wetland mitigation bank permits with 16, fo llowed closely by FDEP with 14 (Figure 1-2A). The remaining 15 mitigation banks were perm itted through SFWMD (n = 9) and SWFWMD (n = 6). When considering land area covered by wetland mitigation, SJRWMD is responsible for 50% of total area in wetland mitigation banks with 23,654 ha (58,448 ac) (Figure 1-2B). FDEP is responsible for over one-third of the area with 17,832 ha (44,061 ac) permitted. SWFWMD (11%) and SFWMD (2%) are responsible for just 5,494 ha (13,576 ac) and 1,195 ha (2,952 ac) of wetland mitigation banks, respectively. Definition of Success This research has set out to determine th e success of wetland mitigation banking through a review of permit compliance and an evaluation of the ecological integrity of wetlands using a variety of wetland assessment techniques. Perm it assessment involved determining if stated permit success criteria and compliance with those standards would reflect ecological integrity.

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Table 1-1. Details of the perm itted wetland mitigation banks. Twenty-nine wetland mitigation banks were included in this study(*). Both Boran Ranch and Everglades Mitigation Bank (FPL) were permitted in two phases and thus both are listed twice (o nce for each permit). Mitigation Bank Public Land State Agency MBI+ Issue Date Hectares Acreage Potential Credits Released Credits Used Credits Released (%) Barberville* Y SJRWMD No 6/1/1996 148 366 84.30 54.20 35.10 64 Bear Point* Y FDEP Yes 7/25/2003 128 317 49.80 25.00 3.70 50 Big Cypress* N SFWMD Yes 9/9/1999 518 1,280 1,001.78 559.20 246.23 56 Bluefield Ranch* N SFWMD Yes 11/15/2001 1,091 2,695 1,240.00 558.14 135.62 45 Boran Ranch, Phase I* N SWFWMD Yes 8/26/1997 96 237 108.59 100.78 98 92 Boran Ranch, Phase II N SWFWMD Yes Unknown 69 170 102.53 16.99 5.20 17 Braden River N SWFWMD No Unknown 141 349 71.69 0.00 0.00 0 Breakfast Point N FDEP Yes 10/11/2004 1,877 4,637 1,051.66 76.29 21.36 7 CGW* N SJRWMD Yes 6/10/1998 61 150 63.10 50.50 46.20 80 Clear Springs N SWFWMD No 10/28/2003 473 1,168 438.00 0.00 0.00 0 Colbert-Cameron* N SJRWMD Yes 10/28/1996 1,054 2,604 718.80 560.30 354.60 78 Corkscrew* N FDEP Yes 6/4/2004 257 635 351.80 0.00 0.00 0 Devils Swamp N FDEP Yes 10/11/2004 1,234 3,049 586.80 0.00 0.00 0 East Central* N SJRWMD Yes May-97 385 952 286.30 286.30 176.70 100 Everglades Mitigation Bank/Phase I* N FDEP Yes 10/1/1996 1,669 4,125 424.50 382.00 290.69 90 Everglades Mitigation Bank/Phase II* N FDEP unknown 10/16/2003 3,653 9,026 1,769.53 184.60 80.64 10 Farmton N SJRWMD Yes 4/11/2000 9,681 23,922 4,585.20 664.50 588.40 14 Florida Mitigation Bank* N FDEP Yes 5/28/1997 640 1,582 847.50 847.50 729.80 100 Florida Wetlandsbank* Y SFWMD Yes 2/9/1995 170 420 370.00 367.37 367.37 99 Garcon Peninsula* N FDEP Yes 4/12/2001 136 337 172.39 77.40 7.27 45 Graham Swamp* N FDEP Yes 9/5/1996 27 66 32.50 29.25 5.50 90 Hole in the Donut* Y FDEP ** 2/15/1995 2,529 6,250 6,250.00 2,111.37 2,111.37 34 Lake Louisa and Green Swamp* N SJRWMD Yes 10/10/1995 408 1,007 297.90 245.60 212.14 82 Lake Monroe* Y SJRWMD Yes 9/12/1995 244 603 199.90 130.00 110.90 65 Little Pine Island* Y FDEP Yes 2/6/1996 633 1,565 807.00 279.40 161.09 35 Loblolly Mitigation Bank* N SJRWMD Yes 9/9/2003 2,528 6,247 2,034.00 508.58 315.52 25 Longleaf Mitigation Bank N SJRWMD Yes 3/31/2004 1,223 3,021 813.80 105.54 20.34 13 Loxahatchee* N FDEP Yes 2/18/2000 512 1,264 641.60 320.80 221.58 50 Mary A Ranch N SJRWMD No 11/12/2002 837 2,069 1,252.80 302.90 154.47 24

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Table 1-1. Continued. Mitigation Bank Public Land State Agency MBI+ Issue Date Hectares Acreage Potential Credits Released Credits Used Credits Released (%) Myakka River N SWFWMD No 6/29/2004 154 380 224.60 38.20 9.09 17 Northeast Florida N SJRWMD Yes 9/5/1997 315 779 407.30 400.00 375.00 98 Panther Island* N SFWMD Yes 3/11/1999 1,128 2,788 934.64 799.24 588.72 86 Peace River N SWFWMD No Unknow n 197 487 137. 82 0.00 0.00 0 Platt's Creek N SFWMD No 4/10/2003 33 82 69.51 0.00 0.00 0 Port Orange N SJRWMD No 1/13/2004 2,314 5,719 1,176.30 237.90 73.00 20 R.G. Reserve* N SFWMD No 1/9/2003 258 638 32.48 2.55 1.20 8 Reedy Creek* N SFWMD Yes 2/13/1997 1,211 2,993 908.90 563.35 419.39 62 San Pedro Bay Mitigation Bank N FDEP Yes 2/13/2002 2,731 6,748 1,083.00 170.80 6.02 16 Sand Hill Lakes Mitigation Bank N FDEP Yes 8/5/2005 872 2,155 298.40 104.40 0.00 35 Split Oak* Y SFWMD unknown 6/13/1996 425 1,049 206.50 88.80 88.80 43 Sundew Mitigation Bank* N SJRWMD Yes 8/11/2001 853 2,107 698.30 194.20 101.54 28 Tampa Bay N SWFWMD No 9/25/2002 65 161 111.55 0.00 0.00 0 TM-Econ* N SJRWMD Yes 1/8/2003 2,104 5,199 1,568.60 227.97 150.31 15 Tosohatchee* Y SJRWMD Yes Unknown 531 1,312 185.00 185.00 152.90 100 Treasure Coast N SFWMD No 3/9/2005 1,030 2,545 1,033.43 0.00 0.00 0 Tupelo Mitigation Bank* N SJRWMD Yes 1/23/2004 617 1,525 459.70 144.85 144.52 32 Wekiva River Mitigation Bank N FDEP No 6/1/2005 665 1,643 390.12 97.53 7.06 25 *Wetland mitigation bank included in this study + Federal Mitigation Banking Instrument (MBI) ** Has federal approval in the form of an in lieu fee type ag reement; state permit also more closely resembles an in-lieu-fee arrangement Information from: Florida Department of Environmental Protection, October 2006

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8 (A) Distribution of Wetland Mitigation Banks by State AgencySJRWMD, 16, 36% FDEP, 14, 31% SFWMD, 9, 20% SWFWMD, 6, 13% (B) Land Area in Wetland Mitigation Banks by State Agency SFWMD, 5,494 ha, 11% FDEP, 17,832 ha, 37% SJRWMD, 23,654 ha, 50% SWFWMD, 1,195 ha, 2% Figure 1-2. Florida state agency responsib ility for wetland mitigation banks for A) currently permitted mitigation banks and B) land area of permitted wetland mitigation banks. State agencies are St. Johns River Water Management District (SJRWMD), Florida Department of Environmental Protection (FDEP) South Florida Water Management District (SFWMD), and Southwest Florida Wate r Management District (SWFWMD).

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9 The wetland assessment techniques employed vari ed by wetland type, but all generally relied upon the comparison of the current wetland conditi on to wetland reference standard condition. Because mitigation is meant to offset functi on lost from wetland impact activities, ideally mitigation bank success would be measured by a direct comparison of functions lost at impact sites to functions gained at the mitigation site. However, this was not feasible as part of this study, as the permitted impact sites no longer exis t in their pre-impact condition and therefore could not be studied in the same way as the m itigation bank sites. Therefore, in this study, success was evaluated using the mitigation bank permits and mitigation bank study sites alone. Permit success is defined by demonstration of ac hievement of permit success criteria. Within a given permit, achievement of specific performan ce standards or release criteria determines awarding of some proportion of total potential wetland credits. For instance, an initial credit release generally requires legal activities such as recording a conservation easement and assertion of financial assurance. Credit release criteria can also include physical activities such as earth moving, ditch plugging, a nd land grading, exotic or nuis ance species removal, and planting desirable species. In terim and final success is often defined by achieving a specified percent cover of desired vegetation or resemblance of the mitigation wetland to a natural community. The definition of success based on ecological integrity can be defined by achieving specific scores by various functional assessment methods. In this case, success is defined by the quantitative comparison of a mitigation wetland to a reference standard wetland. Only 14% of the banks studied included perm it criteria based directly on the achievement of some functional assessment index score (e.g., a 1.00 Wetland Rapi d Assessment Procedure (WRAP) score). Merging these two definitions of success proves challenging as each is based on different assumptions. First, the definition of succes s for permitting relies on the assumption that completion of particular activitie s (e.g., ditch plugging, exotic specie s removal, etc.) in fulfilling permit compliance will result in functional gain and therefore provides successful mitigation. Complicating this assessment is the fact that the release of credits is generally incremental, based on activities such as site preservation, ditch fi ll, and cattle removal. On the other hand, the definition of success for ecological integrity is based on a comparison against the reference standard wetland condition. Purpose of Study The primary purpose of this study was to determ ine the effectiveness of mitigation banking in Florida by determining compliance with perm it success criteria, evaluating the ecological integrity of wetlands within wetland mitigation banks, and evaluating whether permit compliance reflects ecological integrity. Increasing the effectiveness of mitigation banking and improving wetland assessment methodologies should increase the capacity for long term protection and restoration of wetlands. The long te rm effects of this project will be to improve the ecological performance of mitigation banks, management of mitigation banks, and stewardship of wetland resources to better meet the goals of the Clean Water Act.

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10 Specifically, this study used a co llection of available wetland assessment methods combined with permit and document review to determine the condition of re stored, enhance d, created, and preserved wetlands within wetland mitigation ba nks. Two rapid assessment methods, Uniform Mitigation Assessment Method (UMAM) and We tland Rapid Assessment Procedure (WRAP), and two field intensive assessment methods, H ydrogeomorphic approach to assessing wetland function (HGM) and Florida Wetland Condition Index (FWCI), were applied to select wetland assessment areas. A fifth assessment method, th e Landscape Development Intensity (LDI) index relies on geographic information systems analysis. This document is designed to present a summar y of findings and synthesis of the permit and document review and field assessments. Ch apter 2 Methods provides an overview of the location of Florida wetland mitigation banks, s ite visit protocol, procedures of permit and document review, and determination of reference standard condition. A de tailed description of the field standard operating pro cedures can be found in Appendix A. Presentation of results from the permit and document review and field su rveys are found in Chapter 3 Review of Permit Success Criteria and Credit Release and Chap ter 4 Determination of Ecological Integrity, respectively. A presentation of field data sh eets and a summary of permit review for each wetland mitigation bank can be found in Appendi x B and Appendix C, respectively. Chapter 5 Permit Review and Ecological Integrity synthesi zes findings from permit and document review and field assessments by presenting case studies of three wetland mitigation banks. Chapter 6 Discussion reviews major findings and recommenda tions and addresses the effectiveness of wetland mitigation banking in developing and maintaining wetlands with high ecological integrity.

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11 CHAPTER 2 METHODS The primary goal of this project was to determ ine the effectiveness of mitigation banking in Florida using permit and documentation review, field assessment, and geographic information systems (GIS). Twenty-nine wetland mitigati on banks were included in this study, with quantitative, standardized assessment methods used to determine the ecological integrity of 58 smaller wetland assessment areas within the 29 ba nks. The availability of permits and other documents associated with wetland mitigation banks varied greatly. In general, supporting documentation gathered included permits, staff re ports, monitoring reports, management plans, and/or site visit summaries, which were summari zed to include credit pot ential, credit release schedules, and success criteria for each bank. Field assessments were conducted on select wetland assessment areas within the banks, but rare ly covered the entire bank area. While some banks were relatively small in area and homogene ous in wetland community type, many covered large areas and contained a variety of wetla nd community types. The number of wetland assessment areas selected depended on a combin ation of site-specific conditions such as homogeneity of wetland community types, mitigat ion activities completed to date and progress towards success criteria, area of wetland, type of mitigation (i.e., restoration, creation, enhancement, or preservation), and general si te conditions. Two rapid assessment methods, Uniform Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP), were used at all 58 wetland assessment areas, as was the Landscape Development Intensity (LDI) index, a GIS based assessment t ool. When the wetland assessment area matched the communities with developed standard guidebooks for the Hydrogeomorphic wetland classification (HGM) and/or the Florida Wetland Condition Index (FWCI), these methods were also completed. This chapter pr esents background information on the assessment sites, permit and document review procedures, reference standard condition, and field site visits procedures. Mitigation Bank Locations Twenty-nine of the 45 permitted mitigation banks were included in this study. Banks were located throughout the four Florida wetland regi ons (Lane 2000), though only a single wetland mitigation bank, Garcon Peninsula, was located in the panhandle wetland region (Figure 2-1). Just over half of the study mitigation banks (n = 15) were within the central wetland region, with 10 in the south wetland region, an d three in the north wetland regi on. Site selection criteria included length of time since permit issue, progress towards mitigation activities, and land owner or manager cooperation for site access. For the purposes of this study, the two phases of Everglades Mitigation Bank were considered as sepa rate banks, as Phase I is nearing final credit release with 90% of credits awarded, and Phase II has limite d credit release at 10%. All of the wetland mitigation banks permitted befo re 2001 were visited, with the exception of two banks where field access was denied (Figure 2-2). In addition, banks permitted as recently at 2004 were also part of this study. The re maining mitigation banks either had no credits released to date and/or were lacking their federa l MBIs. The four oldest banks included in this study were Florida Wetlandsbank (permit issue date February 9, 1995), Hole in the Donut (February 15, 1995), Lake Monroe (September 12, 1995), and Lake Louisa and Green Swamp

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12 Figure 2-1. Location of 29 wetland mitiga tion banks included in this study. Wetland region boundaries according to Lane (2000). (October 10, 1995). The two most recently perm itted banks included Tupelo Mitigation Bank (January 23, 2004) and Corkscrew (June 4, 2004). Mean bank size was 826 ha (2,040 ac) ( = 887 ha; 2,192 ac), ranging from 27 ha (66 ac) at Graham Swamp to 3,653 ha (9,026 ac) at Everglad es Mitigation Bank/Phas e II. Twenty-seven of the 29 banks had freshwater wetlands. Three of these mitigation banks had both freshwater and saltwater wetlands, and the remaining two banks had salt marsh or/or mangrove wetlands. The range in potential credits was large, from 32.5 potential credits at Graham Swamp to 6,250 potential credits at Hole in the Donut. The medi an was 425 potential credits. It is important to mention that Hole in the Donut operates under a permit that more closely resembles an in-lieufee agreement. Funds for restora tion activities are collected at th e time of impact permit issuance until there is sufficient money to complete a portion of the requi red restoration. Thus, initially, impacts occur prior to mitigation. However, wh ile there is a potential of 2,529 ha (6,250 ac) to restore at Hole in the Donut, work is being conducted incrementally, as financial resources allow, and is currently ahead in initial restoration area relative to impact area. Progress towards mitigation success within a bank can be measured based on potential credits released. The wetland mitigation banks studied ranged from no credits released at Corkscrew to

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13 0 2 4 6 81995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005Year of Permit IssueNumber of Wetland Mitigation Banks Included in Study Not Included in Study Figure 2-2. Florida wetland mitiga tion banks permitted by year. 100% of the potential credits released at three wetland mitigation banks: East Central, Florida Mitigation Bank, and Tosohatchee. Permit Review Procedures Permit review involved determining compliance with permit criteria. Acquisition of complete documentation for each wetland mitigation bank proved difficult. Many of the initial permits and technical reports were only available in dr aft forms, and few permit modifications were acquired. State permits were obtained for all 29 banks, with monitoring reports available for 18 banks. Details of permit compliance were based on phone interviews with appropriate personnel from Florida Department of Environmenta l Protection (FDEP), South Florida Water Management District (SFWMD), Southwest Fl orida Water Management District (SWFWMD), or St. Johns River Water Manage ment District (SJRWM D). Differences in compliance tracking occurs among agencies, with FDEP and SJRW MD having the same individual following the initial permit process and implementation as well as keeping track of compliance. Conversely, SFWMD and SWFWMD have different individuals responsible for the compliance portion of wetland mitigation banks. If credit or permit m odifications are needed, they refer back to the individual responsible fo r implementing the permit.

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14 Reference Standard Condition In order to complete field assessments, it was necessary to determine the reference standard condition of the wetland community type for each assessment area. Different information was available depending on the wetland community t ype. We used a database of depressional herbaceous (n=75; Lane et al. 2003), depressiona l forested (n=118; Reiss and Brown 2005a), and forested strand and floodplain wetlands (n=24; Reiss and Brown 2005b) to develop a baseline understanding of the condition of Florida wetlands Species lists for diatom, macrophyte, and macroinvertebrate community assemblages, as well as physical and chemical soil and water parameters were available (Table 2-1). Other sources of descriptive information were consulted to determine reference conditions (Tables 2-2, 2-3), particularly wh en detailed community data were not available from the studies listed above. While internet sources were c onsulted (Table 2-3), s ite content had been distributed by reputable sources such as the Cornell Lab of Orn ithology, Florida Department of Environmental Protection, Florida Department of Natural Resources, Florida Fish and Wildlife Conservation Commission, Florid a Natural Areas Inventory, Un ited States Geological Survey, and University of Florida (Institute of Food and Agricultural Sciences). Site Visits Procedure Prior to a site visit, recent digital orthographic qua rter quads were acquired from The Land Boundary Information System from FDEP (available at http://www.labins.org ), and the statewide data layer showing boundaries of Flor ida wetland mitigation banks from the Florida Geographic Data Library (available at http://www.fgdl.org/ ) were overlain in ArcView GIS 3.2 (Environmental Systems Research Institute, Inc. 1999). Ecological communities within the wetland mitigation bank boundaries we re identified and potential we tland assessment areas were documented. Background reference data were compiled for select ecological communities and Part 1 of UMAM Qualitative Description (Ch. 62345, F.A.C) was initiated prior to site visits. Most site visits began with a meeting with th e land manager and/or bank owner followed by an overview tour of the site. However, each site visit was different based on the particular circumstances regarding each bank. Some of the m eetings were conducted off-site and site visits were not always conducted with the land manager and/or owner present. Once an overview of the wetland mitigation bank was provided, wetland assessment areas were selected based on the amount of mitigation wo rk completed to date, current water level conditions, and accessibility. Wh en practical, selection of wetla nd assessment ar eas targeted phases that already had credits released. Di gital orthographic quarter quads or other map resources were used to determine the wetland boundary of each assessment area. The two to three member field crew proceeded to walk a por tion of the wetland boundary and interior with sample effort regulated by homogeneity of s ite conditions, accessibility, and time and weather constraints. Miller and Gunsalus (1999) suggest that a minimum of 50% of the wetland boundary is traversed and 100% of the boundary is visually insp ected when using WRAP; this guidance was also used for field assessments usi ng UMAM. During the site visit, notes were

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15 Table 2-1. Sample size of reference database for depressional herbaceous, depressional forested, and forested strand and floodplain wetlands Data from Lane et al. (2003), Reiss and Brown (2005a), and Reiss a nd Brown (2005b), respectively. Depressional Herbaceous Depressional Forested Forested Strand and Floodplain Diatom Community 70 50 x Macrophyte Community 75 118 24 Macroinvertebrate Community 75 79 x Soil Analysis 75 118 x Water Analysis 75 75 x Table 2-2. Sources of ecological information from print media used to establish the expected reference standa rd wetland condition. Source Description Bardi, EB, MT Brown, KC Reiss, and MJ Cohen (2005) UMAM Training Manual: Web-based training manual for Chapter 62-345, FAC for wetlands permitting. Available at: http://www.dep.state.fl.us/labs/library/index.htm Provides guidance on completing the Uniform Mitigation Assessment Method Part I and Part II forms, including Wetland Field Guides providing information on predominant vegetation and wildlife, landscape location, fire interval, hydrology, and functions for 23 wetland communities. Mitsch, WJ and JG Gosselink. 1993. Wetlands, 2nd edition. John Wiley and Sons, Inc. New York, New York, USA. Provides an overview of wetlands ecology with sections dedicated to individual wetland types describing wildlife, hydrology, plant composition, and fire frequency. Myers, RL, and JJ Ewel, editors. 1990. Ecosystems of Florida. University of Central Florida Press, Orlando, Florida, USA. Provides an overview of Floridas ecological communities. Includes information on upland and wetland communities. Noble, CV, R Evans, M McGuire, K Trott, M Davis, and EJ Clairain, Jr. 2002. A regional guidebook for applying the hydrogeomorphic appro ach to assessing wetland functions of flats wetlands in the Everglades. Wetlands Research Program, Engineer Research and Development Center, US Army Corps of Engineers, Washington, D.C. ERDC/EL TR-02-19 Provides reference data for Everglades flats wetlands, including rocky flats, marl flats, and organic flats. Reference conditions pr ovided for surface soil texture, soil thickness, microtopographic features, woody vegetation cover, periphyton cover, emergent macrophytic vegetation cover, plant species composition, native species richness, invasive vegetation cover, wetland tract area, interior core area, and habitat connections. Noble, CV, R Evans, M McGuire, K Trott, M Davis, and EJ Clairain, Jr. 2004. A regional guidebook for applying the hydrogeomorphic appro ach to assessing wetland functions of depressional wetlands in peninsular Florida. Wetlands Research Program, Engineer Research and Development Center, US Army Corps of Engineers, Washington, D.C. ERDC/EL TR-04-3 Provides reference data for depressional wetlands including herbaceous marshes and cypress domes. Reference conditions provided for wetland volume, catchment size, upland land use, surface outlet, cypress canopy, subsurface outlet, surface soil texture, macrophytic vegetation cover, understory vegetation biomass, tree basal area, herbaceous plant species composition, number of wetland zones, wetland proximity, and tree species composition. Soil Conservation Service. 1984. 26 Ecological Communities of Florida. United States Department of Agriculture, Washington, D.C., USA. Provides descriptions of 26 ecological communities in Florida, including characteristic vegetation.

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Table 2-3. Sources of ecological information from the internet used to establish the expected reference standard wetland condition. Source Description Atlas of Florida Vascular Plants http://www.plantatlas.usf.edu/default.asp Scientific and common name, exotic/native status, wetland status, and sometimes images of Florida plant species and range maps. The Birds of North America Online http://bna.birds.cornell.edu/BNA/ Information on bird species, including range maps, distinguishing characteristics, distribution, habitat, food sources, behavior, breeding, demography and populations, conservation and management, appearance, and measurements. Florida Delineation Program Field Guides http://www.dep.state.fl.us /water/wetlands/delineation/wetcomm/fieldguides.htm Drawings of common species for algae and flowering plants, central Florida floodplain forests, north Florida floodplain forests, mangroves, north and central Florida salt marsh, and south and central Florida salt marsh. Florida Delineation Program Vegetative Index (Plant List) from Chapter 62-340, F.A.C. (subsection 62-340.200(17), F.A.C.) http://www.dep.state.fl.us /water/wetlands/delineation/vegindex/vegindex.htm Lists of native Florida plant species identified as facultative, facultative wet, and obligate species. Florida Delineation Program Wetland Communities http://www.dep.state.fl.us /water/wetlands/delineation/wetcomm/wetcomm.htm List and brief description of comm on plant communities for each of seven districts (NW, NE, central, SW, SE, S, and Florida Keys). More detailed descriptions and photos provided for some communities as well as common plant associates and community range. End of the Road: The Adverse Ecological Impacts of Roads and Logging: A Compilation of Independently Reviewed Research http://www.nrdc.org/land/f orests/roads/eotrinx.asp Annotated bibliography of information pulled mainly from peer-reviewed journals pertaining to adverse impacts of roads on North American forests. Published by the Natural Resource Defense Council (1999). Endangered Species in Florida http://www.endangeredspecie.com/states/fl.htm State listed threatened and endangered pl ant and animal species for Florida. Environmental Resource Analysis from the FDEP http://eraonline.dep.state.fl.us/ *NOTE* This website is scheduled to be retired be FDEP in the near future, and replaced by Water Data Central, available at: http://www.dep.state.fl. us/water/datacentral/ Interactive mapping interface providing geographical data and information relating to local roads, soils, Outstanding Florida Waters (aquatic preserves and special waters), conservation land s (federal, state, local, and private areas), city limits, and aerial photograp hy. Also includes the ability to draw a 1 mile buffer around a given analysis point with summary information for permit application, jurisdictional bo undaries, water resources, fish and wildlife resources, habitats, and mitigation and restoration opportunities. Exotic Freshwater Fishes http://floridafisheries.com/fishes/non-native.html Provides a description of 32 known introduced fish species currently reproducing in Florida waters. Includes common and scientific name, description, range, habitat, spawning habitat, feeding habitat, age and growth, sporting quality, edibility, state and world records, and drawing/sketch.

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Table 2-3. Continued. Source Description Florida Fish and Wildlife Conservation Commission. 2004. Floridas Imperiled Species. http://myfwc.com/imperiledspecies/ Lists Floridas imperiled species, incl uding endangered species, threatened species, and species of special concern. Florida Natural Areas Inventory and Department of Natural Resources. 1990. Guide to Natural Communities of Florida. http://www.fnai.org/PDF/Natu ral_Communities_Guide.pdf Provides descriptions of natural eco logical communities in Florida. Includes information on characteristic plant and animal species, hydrology, fire frequency, and associated communities. Florida Wetland Restoration Information Center http://www.dep.state.fl. us/water/wetlands/fwric Information on wetland and associated up land restoration; includes links to the Florida Ecological Restoration Inventory (descriptions of current and proposed restoration projects), restoration guidance (background on restoration with case studies), restoratio n library (links and bibliographies). Frogs and Toads of Florida http://www.wec.ufl.edu/extension/wildlif e_info/frogstoads/image_index.php *NOTE* This is not a permanent URL, search University of Florida List and pictorial index of the 33 frogs and toads of Florida. A description of each species includes photos, distribution, habitat, size, reproduction, color, and call information. Many entries include an audio clip of the call. Online Guide to the Snakes of Florida http://www.flmnh.ufl.edu/herpetol ogy/FL-GUIDE/onlineguide.htm Key to snake identification, list of Florida snakes, color patterns, and habitat descriptions. Provides photos, scientific name, description, sketches, range, and habitat information for each species as well as comments on behavior, location, food, reproduction, and a comparison with other species. Plant Species Introduced in Florida http://www.flmnh.ufl.edu/herbarium/ cat/imagesearch.asp?srchproject=IN Scientific and common names for plant species as well as scanned herbarium specimen images from the University of Florida herbarium. Tables of Florida Natural Communities Descriptions available for download http://www.dep.state.fl.us/water /wetlands/fwric/guidance.htm Tabular information on dominant vegetative strata, ecosystem formation, typical vegetation, typical animals, soils, hydroperiod, fire regime, typical surrounding habitat, similar habitats, threats and importance. Tadpoles of the Southeastern United States Coastal Plain from the USGS http://cars.er.usgs.gov/armi/Guide_to_Tadpoles/guide_to_tadpoles.html Information useful for identification of tadpoles with photos of the adult and tadpoles plus information on habitat, breeding season, similar tadpoles, appearance, and approximate maximum size. U.S. Fish and Wildlife Service Species Accounts http://www.fws.gov/northflorida/S pecies-Accounts/SpeciesInfo.htm List of federally listed endangered, threatened, and species of special concern by region for mammals, birds, reptiles, amphibians, fish, crustaceans, clams, arthropods, insects, and plants. Lists are also available by county. Links are available for further detailed information on family, status, description, range and population level, habitat, biological information, reason for current status, management and protection, and references. What Bird: The Ultimate Bird Guide http://www.whatbird.com/ General species information as well as background on range and habitat with range maps. Shows images of species and often provides audio clips of bird calls.

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18 taken on general site conditions including iden tified flora, observed wildlife (e.g., visual sightings, calls), evidence of wildlife (e.g., tracks, nests), and occurrence of listed species. Once notes were completed for WRAP and UMAM rapid assessment met hods, transects and/or quadrats were established for HGM and/or FW CI, depending on methods specific to those assessment techniques. While UMAM and WRAP were completed for each of the 58 wetland assessment areas, the more inte nsive sampling methods, HGM and FWCI, were only completed for Everglades flats (Noble et al. 2002) or de pressional wetlands (Nobl e et al. 2004) for HGM and depressional herbaceous (Lan e et al. 2003), depressional fo rested (Reiss and Brown 2005a), or forested strand and floodplain (Reiss and Br own 2005b) wetlands for FWCI. After returning from the field, a digital boundary of the wetlan d assessment area was drawn over the digital orthographic quarter quad and the wetland scale LDI index was calculated for each wetland assessment area using GIS. The bank scale LD I index value was also calculated around the boundary of the entire bank. A brief descripti on of each field assessment method follows. Further details of methods for each assessm ent method including UMAM, WRAP, HGM, FWCI, and LDI, are available in Appendix A. Uniform Mitigation Assessment Method (UMAM) UMAM is defined in Rule Chapter 62-345, F.A.C. A complete UMAM survey includes Part I Qualitative Description and Part II Quantificati on of Assessment Area. Part I Qualitative Description establishes a reference baseline for expected site functions and considers connectivity, regional significance, and anticipated wildlife. Part II Quantification of Assessment Area requires completion at the field si te with scoring assigned in each of the three indicators of wetland function: Location a nd Landscape Support, Water Environment, and Community Structure. Part II Quantification of Assessment Area scor es are based on evidence within the wetland community and the surrounding lands cape, using reasonable scientific judgment. UMAM relies on an adequate understanding of the functio ns of and species found throughout Florida ecosystems to provide a score describing the func tional capacity of a wetland. Within each of the three indicators of wetland function, the UMAM scale range s from 0-10, with only whole numbers assigned. A score of 10 suggests the wetland assessment area reflects the expected wetland function at an optimal level. Altern atively, a score of zero means that no wetland function is being provided. Gu idance is provided within the ru le (Chapter 62-345, F.A.C.) for scores of 10, 7, 4, and 0. Once each of the three categories have been scored, the values are summed and divided by 30 to achieve a to tal UMAM score betw een 0.00-1.00, with 1.00 representing optimal wetland function. Assessmen ts for this study were conducted as current condition scenarios. UMAM has additional a pplication for scenario s withand withoutmitigation, time lag, and risk. A UMAM current condition assessment was conducted at all 58 wetland assessment areas within the 29 banks. Wetland Rapid Assessment Procedure (WRAP) WRAP methodologies are define d by Miller and Gunsalus (1999) for use in evaluation of restored, created, enhanced, and preserved wetland mitigation sites. WRAP was created for use

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19 in freshwater, non-tidal wetlands in South Florida, but is often applied statewid e and has even been applied outside of Florida. WRAP include s six scoring categories: 1) Wildlife Utilization; 2) Overstory/Shrub Canopy; 3) Vegetative Gr ound Cover; 4) Adjacent Upland Support/Buffer; 5) Field Indicators of Wetland Hydrology; and 6) Water Quality Input and Treatment. Scores range from 0.0-3.0, in 0.5 increments. A score of 3.0 indicates an intact wetland, whereas a score of 0.0 indicates a wetland with a reduced f unctional capacity (Miller and Gunsalus 1999). Guidance is provided for scoring categories of 0.0, 1.0, 2.0, and 3.0. The final WRAP score is calculated by summing the scores for the scor ing categories and dividing by the number of scoring categories used. For forested wetlands, six scoring categories are used; however, for herbaceous wetlands typically only five scoring categories are used as the Overstory/Shrub Canopy category is generally not applicable as it requires a minimum of 20% cover by woody species. The WRAP calculation results in a score between 0.00-1.00, w ith 1.00 representing an intact wetland. WRAP assessments were con ducted at all 58 wetland assessment areas within the 29 banks. Hydrogeomorphic wetland assessment (HGM) Developed through the United States Army Corps of Engineers, HGM evaluates current wetland functions and can be used to predict prospectiv e changes to a wetland's functions resulting from future activities (USEPA 1998). Two HGM regiona l guidebooks were applicable to this study, one for Everglades flats wetlands (Noble et al 2002) and one for depr essional wetlands in peninsular Florida (Noble et al. 2004). The HGM approach is based on an evaluation of a sample wetland attributes or variables compared to the reference standards provided by the guidebook (i.e., wetlands that are relatively unaltered); the inde x of ecological function is calculated from those variables. This approach focuses on five measures of wetland function: 1) Surface Water Storage; 2) Subsurface Water Storage; 3) Cycle Nutrients; 4) Characteristic Plant Community; and 5) Wildlife Habitat. For Ever glades flats wetlands, wetland functions 1) Surface Water Storage and 2) Subsurface Water St orage are combined into one wetland function category called Surface and Subsurface Water Stor age. Each wetland function has a calculated value based on equations with input variables from field measurements or GIS determinations. Each wetland function receives a score betw een 0.00-1.00, with 1.00 representing the reference standard condition. Each wetland assessment area r eceives four or five separate HGM scores for wetland function. HGM assessment was conducted at six Everglades flats a nd nine depressional wetlands. Florida Wetland Condition Index (FWCI) The FWCI is a wetland bioassessment method based on three separate indices of biological integrity: diatom, macrophyte, or macroinverteb rate community composition. The premise behind the FWCI is to detect differences in abunda nce, structure, and diversity of target species assemblages between the wetland being assessed and a reference standard wetland. Three variations of the FWCI have been developed fo r herbaceous depressional wetlands (Lane et al. 2003), forested depressional wetlands (Reiss and Brown 2005a), and forested strand and floodplain wetlands (Reiss and Brown 2005b). For a given species assemblage (i.e., diatom, macrophyte, or macroinvertebrate), presence/absen ce data are used to calculate metric values,

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20 which are then summed together to provide an overview score of wetland condition. This study used the macrophyte and macr oinvertebrate FWCIs. The macrophyte FWCI for all wetland types contains the following metrics: 1) Tolerant Species; 2) Sensitive Species; 3) Exotic Species; 4) Floristic Quality Assessment Index or mean Coefficient of Conservatism scor e; and 5) Annual or Perennial Species. The depressional forested wetland macrophyte FWCI also includes a metric for Wetland Status (based on obligate and facultative wetland species, as defined by C h. 62-340.450, F.A.C. Metrics are scored from 0-10, with 10 representing the reference standard condition. Metric scores are summed and the resulting scale is from 0-50 for depressiona l herbaceous and forested strand and floodplain wetlands and 0-60 for depressional forested wetlands. The highest score represents reference standard condition (either 50 or 60, depending on wetland type). In this study, results are the presented as a percent of re ference standard condition. The macroinvertebrate FWCIs have different me trics for each wetland type. The depressional herbaceous wetland macroinvertebrate FWCI incl udes five metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a re ference dataset (Tolerant); 3) Percent of macroinvertebrates in the pred ator functional feeding group (P redators); 4) Percent of macroinvertebrates in the orde r Odonata that includes dragonf lies and damselflies (Odonata); and 5) Percent of macroinvertebra tes in the subfamily Orthocladinae, a subfamily in the family Chironomidae (Orthocladinae). Scoring for the depressional herbaceous wetland macroinvertebrate FWCI assigns scores of 0, 3, 7, or 10 to each of the five metrics with total FWCI scores ranging from 0-50, with 50 representi ng the reference standard condition. In this study, results are presente d as a percent of refe rence standard condition. The depressional forested wetland macroinvertebrate FWCI includes six metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 3) Calculated score from the Florida Index (Florida Index) (see Beck 1954, Barbour et al. 1996); 4) Percent of macroinvertebrates in the phylum Mollusca, includi ng snails and bivalves (Mollusca); 5) Percent of macroinvertebrates in the family Noteridae, the burrowing water beetles (Noteridae); and 6) Percent of macroinvertebrates in the scraper f unctional feeding group (S crapers). Metrics are scored on a continuous scale fr om 0-10, with 10 repr esenting the reference standard condition. Metric scores are summed and the resulting sc ale is from 0-60, with 60 representing reference standard condition. In this st udy, results are presented as a percent of reference standard condition. Macrophyte FWCI assessments were conducted at six depressional herbaceous wetlands, three depressional forested wetlands and one fo rested strand and fl oodplain wetland. Macroinvertebrate FWCI assessments were cond ucted at two depressi onal herbaceous wetlands and two depressional forested wetlands. Ma croinvertebrate FWCI assessments were not conducted at the remaining five de pressional wetlands, as those si tes did not have the required minimum 10 cm of standing water covering a minimum of 50% of the wetland surface area, needed for macroinvertebrate sampling.

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21 Landscape Development Intensity (LDI) index The LDI index functions as an index of hu man activity based on a development intensity measure derived from nonrenewable energy use (e.g., fertilizer, fuel electricity) in the surrounding landscape. The LDI index equati on incorporates the amount of nonrenewable energy use (Table 2-4) weighted by area of la nd use within a 100 m radius of the property in question. Brown and Vivas (2005 ) present the basis for LDI index calculations, and Vivas (2007) presents a modified equation, which was us ed in this study. The LDI index scale runs from zero, representing high ecologi cal integrity, to infinity, representing decreased ecological integrity, though in practice LDI in dex scores appear to be li mited at around 35 (Vivas 2007; Reiss, unpublished data). Two scales of the LDI i ndex were calculated: wetla nd scale LDI index for each of the 58 wetland assessment areas and bank scale LDI index for 26 banks. To calculate the wetland scale LDI index, a 100 m zone was delin eated around the edge of each wetland asse ssment area and land uses within the zone were iden tified based on 2004 digital orthographic qua rter quads and field notes for current surrounding land use from site visits. Lands surrounding wetland assessment areas within the 100 m zone that were being re stored, enhanced, create d, or preserved within wetland mitigation bank boundaries were assigned th e development intensity of Natural Land, which suggests no use of nonrenewable ener gy. Clearly mitigation activities require nonrenewable energy use (e.g., earth moving activ ities, exotic plant removal or herbicide treatment). However, the calculated LDI index values for the wetland assessment areas were considered the potential LDI index for a wetland assessment ar ea given the surrounding land uses, which should be an already restored, self-sustaining commun ity. That is, given successful enhancement, restoration, creati on, or preservation, the calculated LDI index value reflects the lowest potential LDI index score and in turn the highest potential ecological integrity possible for a wetland assessment area once mitigation is complete. To calculate the bank scale LDI index, a 100 m zone was co nstructed around the bank boundary and land uses within the zone were identified using 2000 land us e cover maps (LU00), available from the Florida Geog raphic Data Library (http://www.fgdl.org/ ). Only 26 of 29 bank scale LDI calculations were completed, as the mitigation bank outline was not available for Boran Ranch Phase I; Phases I and II of the Everglades Mi tigation Bank were combined into one bank scale LDI index; and year 2000 land use was not available for Garcon Peninsula.

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22 Table 2-4. Nonrenewable energy value for land use categories used to calculate the Landscape Development Intensity (LDI) index. The unit of nonrenewable energy (e.g., fertilizer, fuel, electricity) is empower density (s ej/ha/yr). For a description of empower, see Odum (1996). Land Use Category Non-Renewable Empower Density (E14 sej/ha/yr) Natural Land / Open Water 0.0 Recreational / Open Space low intensity 2.8 Pine Plantation 5.1 Unimproved Pastureland (with livestock) 8.3 Improved Pasture (no livestock) 19.5 Low Intensity Pasture (with livestock) 36.9 High Intensity Pastur e (with livestock) 51.5 Citrus 65.4 Recreational / Open Space medium intensity 67.3 Row crops 117.1 High Intensity Agriculture (dairy farm) 201.0 Single Family Residential (Low-density) 1,077.0 Recreational / Open Space high intensity 1,230.0 Single Family Residential (Med-density) 2,461.5 Low Intensity Transportation 3,080.0 Single Family Residential (High-density) 3,729.5 Low Intensity commercial (Comm Strip) 3,758.0 Institutional 4,042.2 Highway (4 lane) 5,020.0 Industrial 5,210.6 Multi-family residential (Low rise) 7,391.5 High intensity commercial (Mall) 12,661.0 Multi-family residential (High rise) 12,825.0 Central Business District (Avg 2 stories) 16,150.3 Central Business District (Avg 4 stories) 29,401.3

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23 CHAPTER 3 REVIEW OF PERMIT SUCCESS CRITERIA AND CREDIT RELEASE This study considers two kinds of success. Fi rst, ecological success was defined by restoring function to wetlands. Second, permit success was de fined in regards to meeting criteria and conditions set forth in the mitigation bank permit. Ideally, the two categories of success would be integrally linked; however, in practice, pe rmit conditions and criteria may not always equate to ecological success. This study looked to bridge the gap in achieving both ecological and permit success, so that improved permits resu lt in ecologically succes sful wetland mitigation. Documents reviewed for this study included stat e mitigation bank permits, permit modifications, federal Mitigation Banking Instruments (MBIs), a nd monitoring reports. Not all documents were obtained for all banks, but at a minimum state pe rmits were acquired. State mitigation bank permits, whether issued by a water management district or the Fl orida Department of Environmental Protection (FDEP), generally consiste d of two parts: 1) a staff review or agency intent to issue, which summarized the salient portions of the application file and documented the basis of the agencys authoriza tion and 2) the legally binding pe rmit and figures, which set forth the conditions of the authori zation. Once issued, no change s can be made to the permit conditions without an official permit m odification issued by the agency. Appendix C lists the documents revi ewed for each of the 29 banks included in this study, along with summary notes of these documents and fi nal success criteria. The federal MBI was not consistently reviewed, but it was used when avai lable. There was a great deal of variation between and among the mitigation bank permits and additional documentation, making generalizations difficult and st atistics unrealistic. This chapter instead provides information on the range of differences of mitigation banks pertai ning to their state permits and success criteria. Further, this chapter makes recommendations on how mitigation banks can improve permit criteria to better ensure achiev ement of ecological success. Mitigation Goals and Success Criteria Florida statutes and rules present guidance on ecological goals for mitigation in general and mitigation banks in particular. The statute establishing mitigation banking (Section 373.4135(1), F.S.) directs agencies to emphasize restorati on and enhancement of degraded ecosystems and encourage restoration of communities that were historically present. Although state rules identify minimum requirements for success, it is up to the reviewing agency to state the success criteria in the permit and to ensure that specific conditions in the permit are met. Given its reference in statute and rule, it is surprising that more permits do not emphasize or require definitions for target natural ecological communiti es or reference wetlands that would include a suite of functional parameters. Florida Statutes Rule 62-312.350, Florida Administ rative Code (F.A.C.) states, All mitigation bank permits include success criteria. These are indicators that long-term, self-sustaining ecological goals of the proposed en hancement or restoration will be met. The statute goes on to define the minimum, necessary site characteri stics to determine ecological success. These characteristics include but are not limited to de lineation of the wetlands and other surface waters

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24 according to state rule (Ch. 62-340, F.A.C.); appropriate hydric soils; appropriate target vegetative community or early successional stages of said target community; appropriate size, topography, and configuration; hydrology to support target comm unity; negligible exotic or nuisance species present; and meeti ng state water quality standards. Many of the permits reviewed for this study di d not explicitly describe the target wetland community or reference standard condition for the target wetland. When reference standard wetland conditions were addressed within a permit, these standards were often vaguely described and qualitative, using terms such as based on a comparison (TM-Econ and Colbert-Cameron), within the range of similarity values (Little Pine Island) or resemble those of a reference wetland (Boran Ranch, Phase I). Specific quantitativ e guidelines for addressing the similarity of the mitigation wetland with the reference standard wetland condition were routinely absent. Approximately 50% (13) of the state mitigation ba nk permits reviewed in this study describe or refer to having reference conditions either as a comparison to the literature or an actual field comparison (Table 3-1). In contrast, 13 bank pe rmits make no mention of reference conditions in state permits. A few bank permits recognize th e inability to restore natural communities to reference condition due to site constraints and instead measure ecological lift from pre-bank conditions. For example, Bear Point has success criteria meant to increase function and improve water quality and fish and wildlife habitat, but w ill always be managed for mosquito control. As such, it can never represent the fu ll function of reference conditions expected of saltwater marsh and mangrove communities. The most obvious limitation for banks to attain reference conditions are banks closest to urban developmen t. Location and landscape support will always be a limiting factor in achieving full function when banks are situated in developed landscapes. A standard should be developed fo r minimal criteria to describe target natural communities for restoration. The Florida Natural Areas Inventory Guide to the Natural Communities of Florida (FNAI 1990) document, while dated, would be a good resource to use in th e initial development of a wetland mitigation bank. FNAI (1990) presents characteristic species, soils, hydrology, fire regime, and limitations to natural communities in de tail. At a minimum, this would be a better starting place to frame specific restoration comm unity goals, rather than vague references to pinelands or sawgrass marshes that lack a fu ll appreciation of the complexity of natural communities. Some banks defined target communities with the Florida Land Use, Cover and Forms Classification System (FLUCCS), which may not be at a fine enough scale for restoration goals. Communities defined as mixed forested wetland, wetland forested mixed, and freshwater marsh do not provide detailed information even though so me of the characteristic dominant species are in the definitions of these categories. For ex ample, the category of freshwater marsh (6410) includes prairie, depression marsh, basin ma rsh, flatwoods pond, and ephemeral pond. These wetlands occur throughout Florida and are composed of a variety of herbaceous species. These freshwater marshes vary widely in size, from less than an acr e (e.g., depressional marshes) to thousands of acres (e.g., Everglad es flats). In preference to FL UCCS, FNAI descriptions present baseline conditions and an initial starting point for a literature referen ce, describing community composition, structure, and ecosystem processes.

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25 Table 3-1. Target community and reference co ndition information in mitigation bank permits. Target communities identified? Target in success criteria?Reference provided?Reference in success criteria? BARBERVILLE 3-4 communities namednonono BEAR POINT 1 type namedyesnono BIG CYPRESS 4 communities named with required acreageyes literature reference for compositionno BLUEFIELD 16 types namedyes literature reference for compositionyes BORAN RANCH I 3 named in map with required acreageyesonsite referencedemonstrate similarity BORAN RANCH II 4 named in map with required acreageyesonsite referencedemonstrate similarity CGW not clearnonono COLBERT-CAMERON preservationnonono CORKSCREW 4 communities named with required acreageyesmust meet UMAM scoresmust meet UMAM scores EAST CENTRAL existing communitiesnonono EVERGLADES I 3 types named with required acreagenomust meet WATER scoresmust meet WATER scores EVERGLADES II 3 types named with required acreageyesmust meet WATER scoresmust meet WATER scores FLORIDA MITIGATION BANK 3 types named with required acreagesome namednono FLORIDA WETLANDS BANK 3-4 types named, mapnonono GARCON PENINSULA 3 types named with required acreageyes literature reference for compositionmust meet WRAP scores GRAHAM SWAMP existing communitiesnonono HOLE-IN-THE-DONUT 1 type namedinferred yes onsite based on wetlands in Everglades National Park Yes, statistical similarity required LAKE LOUISA 4 types named non-specific reference to compositionnono LAKE MONROE 14 named and mapped with FLUCCSnonono LITTLE PINE ISLAND 4 named with acreageyes yes, literature and reference wetlandsyes LOBLOLLY 2-3 named communitiesno MBI refers to literature but is vagueno LOXAHATCHEE 5 named communities with required acreageyes criteria based on reference at adjacent Loxahatchee Preserve wildlife has reference targets PANTHER ISLAND 3-4 communities named and mappedyes criteria based on reference at adjacent preserve Corkscrew Sanctuary no REEDY CREEK FLUCCS and mappednonono RG RESERVE existing communitiessome namednono SPLIT OA K existing communitiesunknownnounknown SUNDEW not clear, upland and wetlandno MBI refers to literature but is vagueno TM-ECON 4-5 existing communities mappedno relative to onsite preservation b ased on enhancements over baseline TOSOHATCHEE existing communities in state parknonono TUPELO not clear, upland and wetlandno MBI refers to literature but is vagueno

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26 Not all banks lacking a description of reference c onditions in their permits appear to be limited in function or progress towards ecological improve ment. Perhaps some banks that lacked documentation for reference conditions utilized th e professional experience of the land manager to restore the natural communities. Some of the banks that were having difficulty restoring some community types did not always have a clear goal defining the target natural community. Simply referring to the natural community and its dominant species composition is not enough to restore the function of the community. Measur able parameters should be clear and succinct when referring to desirable reference conditions. Qualitative resemblance without quantitative correlations is not enough to determ ine restored structure and function. Perfunctory comparisons to reference wetland types based on plant descriptions can limit determination of full wetland func tion if composition of flora a nd fauna, physical characteristics, and structure are also not defi ned. Basing success only on attain ing similarity of the plant community to reference standard conditions may not restore total function and other parameters pertaining to water chemistry, soils, macro and micro fauna, and ecological processes, all of which are an important part of defining reference standard conditions. Nine wetland mitigation banks make no mention of fauna in their state permits or techni cal reports. Ten banks make reference to wildlife utilization in the final suc cess criteria. Twelve ba nks have some form of qualitative wildlife monitoring in their bank ing program, and seven banks implemented quantitative monitoring. Of the seven banks with quantitative m onitoring, two require monitoring for listed wildlife species th at occur on the bank (Table 3-2). While application of wetland assessment methods, which are used to determine potential credits, requires the assessor to research associated w ildlife and basic life history traits, it was not apparent that this baseline information was al ways being sought for fauna on the banks. Ch. 62345, F.A.C., is the required assessment method for calculating credits for wetland mitigation banks, effective February 2004. UMAM 62-345.400 Pa rt I Qualitative Characterization clearly requires at a minimum identifying anticipated wild life utilization and type of use (i.e., feeding, breeding, nesting, resting, or denning) and applicab le listing classificati ons (i.e., threatened, endangered, or species of special concern as defined by Rules 68A-27.003, 68A-27.004, and 68A-27.005, F.A.C.), which should increase a ssessor awareness of wildlife habitat and utilization. Basic ecological principles can be applied to determine the function of wildlife habitat and utilization. Fauna should be considered in the planning of the mitigation bank in the context of landscape fragmentation and habita t loss outside the ba nk and edge effects, connectivity and dispersal of exp ected fauna, core to edge rati os regarding habitat needs for foraging, cover and reproduction, species intera ction, and monitoring should be conducted for fauna response to management activities. If it is outside of the ability of the regulating agencies and bank managers to apply these basic ecological principles to planning and management than more precaution should be taken when assuming poten tial gain in ecological function that would support the associated wildlife species. Further, the scientific baseline that defines a natural community is ever evolving. It may take years to restore a community on a wetland mitig ation bank, and in the mean time available scientific knowledge might evolve to further define appropriate fi re return interv als or response to other disturbance phenomena like hurricanes. Without an appropriate understanding of the target natural community, and an adaptive manageme nt plan or experimental design, acceptable

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27 Table 3-2. Successes criteria for native wildlife monitoring requirements in state permits. Mitigation Bank No detail on wildlife needs Wildlife requirements in Success Criteria Qualitative monitoring or observation requirements Quantitative monitoring requirements Barberville Bear Point Big Cypress Bluefield Ranch Boran Ranch CGW Colbert-Cameron Corkscrew East Central Everglades Mitigation Bank (WATER requirements) Florida Mitigation Bank (3 in MWRAP wildlife utilization) Florida Wetlands Bank Garcon Peninsula Graham Swamp Hole in the Donut Lake Louisa and Green Swamp Lake Monroe (FL scrub jays) Little Pine Island Loblolly Mitigation Bank Loxahatchee Panther Island Reedy Creek R.G. Reserve Split Oak Sundew Mitigation Bank TM-Econ (red cockaded woodpeckers) Tosohatchee Tupelo Mitigation Bank

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28 variation in community struct ure and function based on respons e to disturbance would be unclear. Credit Potential Florida rules recognize th at not all mitigation areas are expected to attain reference condition. Chapter 62.312.350, F.A.C. states that it is not the intent of the Department to require that the mitigation area exactly duplicate or replicate the re ference water. Thus, an important concept in evaluating mitigation success is an understanding of how a mitigation site is assessed for credit. Mitigation projects are generally categorized along a continuum of regulatory categories including creation of wetlands from uplands, restoration of wetlands that had historically been converted to uplands or non-native land uses, enhancement of altered wetlands, and preservation of intact wetlands. A mitigation bank may have several of these different mitigation types in different locations or communities types within the bank, as well as upland preservation or enhancement to provide buffer, protection, hab itat, and recharge function to the adjacent wetlands. Thus not all mitigation areas start at th e same level of ecological function, nor do they all have the same anticipated outcome. It is the improvement in ecological function, or ec ological lift, that provides the mitigation value or credit to offset wetland impacts of functional loss. Potential credit an d loss should be assessed by the same method. However, when evaluati ng mitigation banks, the future losses through impacts are not yet known, so a standard unit of lift or gain is needed to provide a currency for credit and debit. In Florida, a mitigation credit is defined as a standard unit of measure which represents the increase in ecological value resulting from re storation, enhancement, preservation, or creation activities (Section 373.403(20), F.S. and Chapter 62-342.200(5), F.A.C.). Typically, the mitigation area is divided into polygons or a ssessment areas of similar condition, treatment, community type, and anticipated results. Each area is assessed for its anticipated functional lift between its current or predicted without bank condition, compared to its anticipated outcome with bank condition (Story et al. 1998). In February 2004, Florida adopted Uniform Mitig ation Assessment Method (UMAM) in Chapter 62-345, F.A.C, thereby providing a standard methodology for all state wetland regulatory agencies to assess lift of mitigation and assess loss associated with impacts. Prior to that date, mitigation banks were assessed by a variety of other functional assessments and by acre to credit ratios. The 45 permitted mitigation banks to tal approximately 47,753 ha (118,000 ac) with a total of approximately 36,500 potenti al credits, which means, on aver age, about 1.4 ha (3.5 ac) of mitigation area is required to generate one credit (Figure 3-1). In reviewing some of the permit files and attachme nts, it was clear that the with bank scenario was often scored very high, anticipating full f unction would return to a site once mitigation activities were completed. This was true even in cases where the surrounding landscape would have an impact on water quali ty or quantity or where wild life support or movement was significantly curtailed. In fact, it often seemed that the assessment was focused only on the anticipated capacity to support vegetation rather than the full suite of integrated wetland functions of the community. This practice could l ead to an over-estimation of ecological lift and mitigation credit.

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29 0 20,000 40,000 60,000 80,000 100,000 120,000 140,000 199519961997199819992000200120022003200420052006 YearAcres (blue) or Total Credits (red) Total Acres (2006: 118,300) Total Credits (2006: 36,520) Figure 3-1. Total area (ac) of permitted mitigat ion banks (blue columns) in relation to total potential credits (red columns) (1995-2006). Preservation Historically, preservation of intact ecosystems through a conservation easement has been a form of mitigation that has been used to offset impacts in limited cases. Because, technically, no ecological function has been gain ed by the recording of a documen t, simple preservation was considered of restricted value in offsetting re al losses. However, because of development pressures, relatively unregulated loss of supporting uplands, and the degradation of ecosystems by exotic or nuisance species, establishing non-de grading conservation easements is considered to be protection to losing function over time, and mitigation value is assessed by comparing the anticipated condition with-preserv ation to that without-preservat ion. By rule, no mitigation credit may be released until the mitigation bank, or phase thereof, has a recorded conservation easement and financial assuranc e for its implementation and l ong-term management (Ch. 62342.470(3), F.A.C.) over the project area, regardle ss of its current condition. Therefore all mitigation credits represent some degree of protection from development and ecological degradation. However, there is wide vari ation among banks in the degree to which the preservation of intact ecosystems has in generating mitigation credit. The mitigation bank permits reviewed did not consistently separate credit awarded for preservation in terms of preserving intact communities with a high degree of function versus filing a conservation easement over communities in pre-restored condition. About half of the studied banks have phases or polygons with in tact wetlands or uplands where very little enhancement was required and management in perp etuity was assumed to maintain function.

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30 Even these banks did not specifically separate the potential credit attributed to this preservation. It is unclear whether credits have been allocat ed as credits for conservation easements or as preservation credits based on the difference between the current c ondition and the assumed without mitigation scenario. Credit Release Florida statute recognizes that mitigation projects may take years to attain final success criteria, and provides for an incremental release of credits with a credit release sc hedule in the permit. Once the credits are released, they may be sold and used to offset impacts. Sec. 373.4136(5)(b), F.S. states The number of credits and schedule for releas e shall be determined by the department or water management district ba sed upon the performance criteria for the mitigation bank and the success criteria for each mitigation activity. The release schedule for a specific mitigation bank or phase thereof shall be related to the actions required to implement the bank, such as site protection, site preparation, earthwork, removal of wastes, planting, removal or control of nuisance and exotic species, instal lation of structures, and annual monitoring and management requirements for success. Credit release schedules for mitigation banks incl uded in this study are summarized in Table 3-3. Credit releases were separated into four broad categories: Legal Actions, Construction and Management Activities, Monitoring of Increm ental Improvement and Final Success. Each category is discussed below in greater detail. Legal Actions In order to receive any credits to sell, a banke r must record an agency reviewed conservation easement over the bank, or phase thereof, with the county in wh ich it is locate d. The easement requires that the bank be maintained in its current or enhanced conditions and specifically lists activities which are forbidden, except as stipulated or required in the permit. The conservation easement is executed in favor of the department and/or the water manage ment district. These easements are also required by federal agencies, but they do not accept the easement themselves. Prior to recording the easement, agencies review title informati on and required title insurance for the easements value. In addition to the conservation easement, the ba nk sponsor must provide financial assurance for both the implementation of the project and for its long-term management Generally, the two assurances are in the form of a letter of cred it (LOC) or performance bond, payable into a standby trust in favor of the agency. The amount of the implementation financial mechanism is based on a cost estimate of the money required to co mplete the mitigation plan and manage and monitor the land until it attains success. The banker must update the cost estimate every two years; the LOC or bond value may decrease when work is successfully completed or may increase to reflect higher antic ipated costs. The amount for th e long-term management trust is equal to the principle that will generate in interest (at 6%) the estimated annual management costs. When both the financial assurances and conservation easement documents are properly executed, the banker may request th e initial credit release.

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Table 3-3. Percent of total potential cred its released for each activity or rel ease criteria (numbers are rounded). p e r m i t d a t e c r e d i t r e l e a s e d t o d a t e c o n s e r v a t i o n e a s e m e n t c o n s t r u c t i o n c o m p l e t i o n e x o t i c r e m o v a l t r e e r e m ov a l p l a n t i n g p r e s c r i b e d f i r e i n c r e m e n t a l f i n a l t o t a l % p o t e n t i a l c r e d i t w h i c h i s a c t i v i t y b a s e d BARBERVILLE Jun-9664%40%23%yes25%12%100%63% BEAR POINT Jul-0750%10%15%15%50%10%100%40% BIG CYPRESS Sep-9956%10%20%yes10%48%12%100%40% BLUEFIELD Nov-0745%10%15%10%10%45%10%100%45% BORAN RANCH I Aug-9793%25%75%100%25% CGW Jun-9880%28%39%13%6%14%100%80% COLBERT CAMERON Oct-9678%100%100%100% CORKSCREW Jun-070%15%20%7%yes3%30%25%100%45% EAST CENTRAL May-97100%58%30%10%2%100%100% EVERGLADES I Oct-9690%10%10%10%yes60%10%100%30% EVERGLADES II Oct-0311%10%20%10%3%3%34%20%100%46% FLORIDA MITIGATION BANK May-97100%15%20%yes50%15%100%35% FLORIDA WETLANDSBANK Feb-9599%15%40%25%10%5%5%100%90% GARCON PENINSULA Apr-0145%15%15%5%yes5%5%40%15%100%45% GRAHAM SWAMP Sep-9690%60%yes25%15%100%60% HOLE-IN-THE-DONUT* Feb-95NA LAKE LOUISA Oct-9582%15%10%10%20%25%20%100%55% LAKE MONROE Sep-9565%15%15%yes10%15%10%35%100%55% LITTLE PINE ISLAND Feb-9635%10%45%30%15%100%55% LOBLOLLY Sep-0325%25%15%5%5%30%20%100%50% LOXAHATCHEE Feb-0050%15%13%13%50%10%100%40% PANTHER ISLAND Mar-9986%25%15%15%10%5%20%10%100%70% REEDY CREEK Feb-9762%30%20%5%3%2%30%10%100%60% RG RESERVE Jan-038%40%15%8%10%20%7%100%73% SPLIT OAK** Jun-9643%45% SUNDEW Aug-0110%20%20%10%5%25%20%100%55% TM-ECON Jan-0315%30%15%40%15%100%45% TOSOHATCHEE Oct-95100%30%20%50%100%50% TUPELO Jan-0432%25%15%5%5%30%20%100%50% *On public land; In-lieu fee bank. Credits ar e not released incrementally; Acres restor ed incrementally as needed for mitigatio n. ** No more credits were sought; mitigation plan ca rried out through alternative agency agreements.

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32 Initial credits releases are usually between 10%-25%; however there are exceptions (Table 3-3). Some conservation easement credit releases are awarded by phase (e .g., Panther Island, Reedy Creek Table 3-3 reflects bank-wide average) a nd not for the entire property. On the high end, Colbert-Cameron, primarily a preservation bank, r eceived 100% potential credits per phase after removing cattle and minor hydrological fixes one y ear after the conservati on easement was filed. Similarly, Panther Island received 80-85% potentia l credit release for some of its phases in preservation areas. Most wetland mitigation bank s are not preservation-only banks. Four banks received credit release based on conservation ea sements in addition to previously completed construction activities. For exam ple, initial credit release at Graham Swamp of 60% was based not only on recording a conserva tion easement but also construction already completed and one year of monitoring. Split Oak had a similar requi rement of active management plus conservation for their initial release. Three banks, Hole in the Donut, Little Pine Island and Tosohatchee, do not have conservation easements and did not recei ve credit for preservation because they occur on already protected public lands. Typically, little information was provided as to how the amount of initial credit release was determined. Ideally, the initial credits generated by recording the conservation easement should reflect the preservation value of that property. SWFW MD has initiated a method whereby they conduct an initial assessment of a mitigation bank to determine potential credit based only on preservation. Assuming that the mitigation ba nk will be protected from future degradation, preservation credits are awarded based on curre nt condition. Then a second assessment based on enhancement is completed to determine the lift a ssociated with mitigation activities. Seemingly, this method would make awarding credit for preservation a more tr ansparent process. Construction and Management Activities Generally, once a mitigation bank permit has been issued, work begins on the ground to commence enhancing and restoring the land as required. Some banks begin ground work in phases or polygons, sometimes with several activities o ccurring simultaneously. These activities usually include installing perimeter fencing, in stalling hydrologic enhancement or restoration mechanisms, earth moving, site clearing, and plan ting. Although there are no rules pertaining to monitoring and reporting requirements during the construction phase of the bank, all banks are required to give notice prior to construction initiation. FDEP requires status reports every six months, regardless of whether construction activiti es are in progress or not Individuals at the permitting agencies commented that some banks did not submit reports or communicate with their regulating agency for some length of tim e because there was no act ivity on the bank during that time period. Perhaps standardization within the permit special conditions section that a status report is required every six months would help close the communication gap. An example of appropriate permit language for communication with state agencies is provided for Garcon Peninsula (Figure 3-2). Once construction activities are complete, the bank is required to monitor. At this point, the bank should be able to demonstrate ecological in cremental improvement over time. Some banks have interim criteria that must be met in orde r to demonstrate a trend towards success, while other banks must demonstrate an improvement over baseline conditions. Banks are required to submit a monitoring report at least annually to document the monitoring and provide the basis

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33 30. Progress Reports Beginning six months after permit issuance until final success determination, the permittee shall submit semi -annual progress reports containing the following information regarding the project: a. Date permitted activities were begun or are anticipated to begin; b. Brief description and extent of work completed since the previous report or since permit was issued; c. Copies of permit drawings indi cating areas where work has been completed; d. A description of problems encount ered and solutions undertaken; e. A brief description of the work and/or site management the permittee anticipates commencing, continuing or completing in the next six months; and f. Site management undertak en, including type of management and dates each type was undertaken. Figure 3-2. Permit requirements from Garcon Peninsula Mitigation Ba nk (permit number 017-880-001). for requesting credit release for that monitoring period. SWFWMD does not have interim or incremental criteria for Boran Ranch mitigation bank. At this bank, initial credit is released for recording a conservation easement and completi ng construction activiti es; only after final success criteria is met for a given wetland polygon is the remaining credit released. Two state agency regulators relayed that in the past, some early banks believed they were owed a credit release from the regulating agency for conducting monitoring, regardless of whether incremental ecological improvement was documented. Hydrology Most of the banks in th is study have some hydrologic enhancemen t or restoration with associated credit releases for construction of these enha ncements. Most enhancement practices have included removing roads or increa sing connectivity under roads, removing or blocking ditches, and re-grading swales or other unnatural topographi c features that inhib it the natural flow of water. Some banks are highly engineered. A few have heavily manipulated hydrology because of their placement in a regi onally altered landscape (e.g., Floridawetlands Bank; Florida Mitigation bank). Two banks have constructed si gnificant berms with control structures to increase water levels on site (i.e., Loxahatchee and Florida Mitigation Bank). Everglades Phase II and Bear Point have existing berms required fo r flood control or mosquito control; these banks have installed multiple controlled culverts thro ugh the berms to more closely mimic sheet-flow when allowable. Eight banks are known to have permanent water co ntrol structures as described in their state permits. In total, 19 banks descri be some level of target hydrology listed in their success criteria. Other requirements hydrology requi rement include that f our banks must meet M-WRAP or other assessment criteria standards, and seven banks must meet a size requirement of jurisdictional wetlands as defined under Sec tion 373.421, F. S. (a bank may have more than

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34 one of these requirements). Five banks do not specifically mention hydrology in their final success criteria, although some cred it releases are tied to installa tion of hydrologic enhancements or monitoring of said enhancements. Hydrologically based construction also occurred on the banks in terms of grading the existing lands to achieve a lower elevation to support target communiti es. Hole in the Donut requires grading all of the previously rock-plowed soil (a pproximately 0.3 m) dow n to the underlying limestone to prevent re-infestation of Brazilian pepper ( Schinus terebinthifolius ) and to promote the native marsh community. Likewise Flor ida Wetlandsbank, Panther Island, and Corkscrew have areas dominated by exotic species or pasture permitted to be graded to support a marsh community. Grading allowed for the appropriate target wetland species to become established and the community to more closely resemble th e desired target community. However areas that have been rock plowed and graded lose the cap acity for ground water storage in the areas that have been lowered. The successful completion of construction activitie s typically result in the release of 10-20% of the potential credits, with a few exceptions for ma jor construction projects: Tosohatchee and East Central at 30% and Florida Wetlandsbank at 40% (Tab le 3-3). Credit release is usually based on as-built information and/or other hydrologic data showing anticipated hydrologic enhancements or water levels were attained. Although surface water level changes tend to occur quickly after most hydrologic enhancement structures are in pl ace, soil, plant, and animal community response to the enhanced hydrology may take several years or longer. Although one of minimum requirements of succe ss of Rule 62-312.350, F.A.C. state that water quality standards are met, ve ry few banks monitor for wate r quality. Most banks do not specifically propose to improve water quality th rough wetlands mitigation, but this might be implied with restored function of those wetlands such as th rough nutrient cycling and improving fauna habitat. The state of Fl orida does not have water qualit y standards specific to wetlands, but general Class III water quality standa rds do apply (Ch. 62-302 Surface Water Quality Standards, F.A.C.). Some of the banks have writte n into their state permit that they must adhere to Best Management Practices during cons truction for minimizing turbidity and slope stabilization. Eight banks are required by their state permit to monitor water quality during that time. Only Bear Point, Florida Mitigation Bank, and Lake Louisa and Green Swamp have mitigation activities intended to specifically improve water quality. Exotic and inappropriate species removal Invasive exotic and nuisance sp ecies are a tremendous ecological and financial concern for land managers on conservation lands in Florida and el sewhere in the United States (e.g., Pimentel et al. 2000). Many contend that these species th reaten biodiversity, ecosystem functioning, community health, or human economies (Myers et al. 2000; Diaz et al. 2003). Throughout Floridas history, some non-native species were deliberately plante d as part of previous human land use activities like pasture, agriculture, and c itrus, and as such are present on lands used for wetland mitigation banking. While some of these species are not considered an invasion threat (e.g., sweet orange or grapefruit, Citrus x aurantium ), others can persist, reproduce, and spread

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35 (e.g., West Indian marsh grass, Hymenachne amplexicaulis, Diaz et al. 2003) and are thought to alter native community structure and function. A disturbance or alteration in th e landscape, often in the form of disruption of natural hydrology or a total change in the landscape from a natural land use to agriculture or pasture often increases the likely hood of occurrence of exotic species. Most of the ba nks in this study had enhancement activities relating to the eradi cation and continued treatment of exotic vegetation. Banks had varying degrees of exotic species. Little Pine Island (Figure 3-3), Hole in the Donut, and Florida Wetlansbank receive most of their credit from the removal of 80-100% cover of melaleuca ( Melaleuca quinquenervia ) or Brazilian pepper ( Schinus terebinthifolius ). Invasive tree species can have a significant impact to the hydrology, structure, and functio n of native communities when they invade open communities like marshes or flatwoods (EPPC 2003). Like wise, the exotic climbing fern ( Lygodium spp. ) can have significant impacts to function in forested communities (EPPC 2003). These exotics pose di fficulties in restoring natural communities in several banks, including Bluefield, Corkscrew, Everglades Mitigation Bank, Garcon Peninsula, and Loxahatchee. Figure 3-3. Dense cover by the invasive exotic species melaleuca or punktree ( Melaleuca quinquenervia ) prior to restoration activities at Little Pine Island. Bahia grass ( Paspalum notatum) while not as invasive in intact natural areas, can be persistent and difficult to eradicate from pastures where it was introduced and is pa rticularly difficult to treat in historically more xeric habitats. Othe r problematic exotic spec ies which are extremely persistent and can dominate groun d cover include torpedo grass ( Panicum repens) and cogon grass ( Imperata cylindrical) Several earlier permits anticipated that with the restoration of appropriate hydrology and cessation of cattle or citrus management practices, the native vegetation would out-compete and do minate the pasture grasses or require only spot treatments

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36 of these species. This has not been borne out on some banks, and they continue to face an uphill battle with these invasive exotic species (e.g., Ba rberville, Big Cypress, Lake Louisa and Green Swamp, and Lake Monroe). Other banks have b een very effective at removing pasture grasses and restoring back to a natu ral community (e.g., Reedy Cree k, Bluefield) by implementing thorough site preparation, vigilant monitoring, re-treating exotics, and re-seeding deliberately to establish an intact native groundcover that can be more difficult for some exotics to invade. Exotic species eradication is expensive an d time consuming. Common control techniques included herbicides and mechanical removal w ith some banks utilizing hand pulling in more sensitive communities. Others experimented with manipulating hydrology and fire to remove exotics and keep them from retu rning. Because of their lands cape location and proximity to nonconservation lands, many mitigation banks have a sign ificant nearby constant exotic species seed source from adjacent properties. Most banks will perpetually have to manage for exotic species with the goal being to eradicate exotic species from the seed bank on site and treat new exotic species that are recruited to the site. There was a wide variety of percent cover allowed for exo tic vegetation in permit success criteria, ranging from 1% to 10%, and sometimes ev en higher for specific pasture grasses, such as bahia grass ( Paspalum notatum ) (Table 3-4). While this figure may be specifically related to individual conditions at the bank, it appeared that allowable cove rage had a stronger relationship to the permitting agency (Figure 3-4). Additiona lly, some mitigation banks also recognized that a native species may be inappropriate for the ta rget community such as woody species in an herbaceous dominated habitat (e.g., wax myrtle, Myrica cerifera, at Garcon Peninsula). Another category of inappropriate species is found in historic we t prairie, flatwoods or mixed wetland forests of northern Florida that were converted to pine pl antations. Several banks mitigation plans involve the restoration of nati ve communities from the planted pine areas (Barberville, Loblolly, Sundew and Tupelo, and to a lesser extreme TM-Econ and Garcon Peninsula). Similarly, two banks involved significant acreage of citrus tree removal and revegetation (Big Cypress, Lake Louisa). Eight mitigation banks have a potential credit release tied to removing silviculture or agriculture trees (Table 3-1). Garcon Peninsula and TM-Econ were the only banks of these eight that awarded potential credit based on the response of the native community to pine removal as opposed to pot ential credit awards for the physical act of removing the trees themselves. Site preparation, planting, and seeding With an emphasis on reference conditions for a target community, activities relating to site preparation, planting, seeding, and expected surv ivorship of plants sh ould have measurable, expected densities. Most banks had some basi c requirement for percen t cover of desirable, native species (Table 3-5). Fourteen banks incl ude planting and/or seeding as a requirement for credit release (3%-20%, typically 5%-10%) (Table 3-3). Site preparation is paramount to the survival of the desirable species as is the timing of planting and activities used to maintain the desired vegetation such as hydrologic regime and fire rotation. Vegetation planting may be necessary in mitigation areas that no longer have a viable native seedbank or nearby seed source

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37 Table 3-4. Final success criteria for exotic and nuisance vegetative cover for state permits. Mitigation Bank Credit Type County Area (ha) Exotic and nuisance cover FDEP: Bear Point Mangrove St. Lucie 128 2% cover per acre exotic Corkscrew FW herb/for Lee 257 < 2% exo tic cover; < 5% nuisance; < 25% combined cover of Myrica cerifera, Baccharis halimifolia and Salix caroliniana per acre Everglades Mitigation Bank, Phase I Fresh/salt Dade 1,669 1% aerial cover Florida Mitigation Bank FW herb/for Osceola 640 1% total cover Garcon Peninsula FW herb/for Santa Rosa 136 < 1% exotic; Sapium sebiferum 1%; Bahiagrass 10%, or if >10%, trend over 2+ years strongly indicating cover will decrease to < 10%; in cypress/hardwood swamp, nuisance species 5% Graham Swamp FW forest Flagler 27 < 5% Hole in the Donut Everglades Dade 2,529 5% total cover Little Pine Island Fresh/salt Lee 512 < 1% Loxahatchee FW herb/for Palm Beach 512 EPPC Category I^ exotic 1%; EPPC Category II^ exotic 3% SFWMD: Big Cypress FW herb/for Collier 518 0 % total cover exotic; 3% total cover nuisance Bluefield Ranch FW herb/for Martin & St. Lucie 1,091 10% exotic/nuisance cover; 15% in any acre area at any time Florida Wetlandsbank Freshwater Broward 170 5% Panther Island FW herb/for Hendry 1,128 0 % exotic (exotics divided by total species rounded to nearest whole number); 3% nuisance R.G. Reserve FW herb/for Martin 258 5% exotic; 10% nuisance 15% total cover any acre area Reedy Creek FW herb/for Osceola & Polk 1,211 < 10% exotic/nuisance; Uplands mean % cover by nuisance tree species < 1%; mean % cover by nuisance shrub species < 5%; groundcover bahiagrass and other nuisance species < 20 % SJRWMD: Barberville FW herb/for Volusia 148 5% exotic; 10% nuisance CGW Saltwater Indian River 61 1% Colbert-Cameron Freshwater Volusia 1,054 < 10% East Central Freshwater Orange 429 10% Lake Louisa and Green Swamp Freshwater Lake 408 5% exotic; < 10% nuisance Lake Monroe FW herb/for Volusia 244 < 5% exotic Loblolly Mitigation Bank Freshwater Duva l 2,528 State permit < 10%; MBI < 5% Sundew Mitigation Bank Freshwater Clay 853 < 10% TM-Econ Freshwater Orange 2,104 < 10% Tosohatchee DOT-used Orange 531 < 10% Tupelo Mitigation Bank Freshwater St. Johns 617 < 10% SWFWMD: Boran Ranch Phase I Freshwater Desoto 96 < 1% ^ EEPC Category exotics from the Exotic Pest Plant Council (EPPC 2003).

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38 Figure 3-4. Final success criteria allowan ce for exotic vegetation percent cover by mitigation bank and regulating agency. Agencies include: FDEP Florida Department of Environmental Protection; SFWMD South Flor ida Water Management District; SJRWMD St. Johns River Water Management District; SWFWMD South West Florida Water Management District.

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Table 3-5. Success criteria related to native vegetation cov er and survivability of planted vegetation in state permits. Bank Name Dominant Habitat at Site Visit Final Success Criteria percent cover of native vegetation Survivability of planted vegetation Barberville Flatwoods Not specified 400 trees per acre Bear Point Mangrove swamp > 50% No planting in phase reviewed Big Cypress Flatwoods Herbaceous: 80% cover native wetland spp. and 20 wetland herbaceous spp. The herbaceous vegetation shall cover 60 % with plant species listed FAC or wetter and be rooted for at least 12 months and be reproducing naturally Forested: 70% coverage by desirable ground cover plants, with 75% of spp. being listed FAC or wetter. Hydric pine flatwoods: diversity of 30 herbaceous spp. shall be present. For each 5 species over 30 a 1% credit bonus will be given for hydric pine flatwoods. Evidence of natural regeneration of planted species 80% survival of all planted trees and shrubs Bluefield Ranch Flatwoods Flatwoods graminoid vegetation in groundcover strata 50% of total coverage 70% of total groundcover strata consists of wetland vegetation (hydric pine flatwoods only) 80% of total herbaceous groundcover strata FACW and/or OBL vegetation or OBL vegetation > upland vegetation 80% survival of planted trees Boran Ranch Flatwoods, marsh 85 to 90% cover for desirable vegetation depending on community type No planting in phase I CGW High marsh, mangrove swamp 90% No planting Colbert-Cameron Flatwoods, cypress domes Percent cover not specified, bank is primarily preservation with some enhancement No planting Corkscrew Regional Mixed forest, cypress domes, hydric flatwoods Minimum percent cover of groundcover is 70% for hydric pines. Minimum percent cover of groundcover in cypress and mixed forest areas is 75% unless there is a lower percent because of open water or shading. Must show evidence of natural recruitment No explicit numbers for survivorship in final success criteria. East Central Wetland forested mixed Bank was monitoring for vegetative cover but this study did not acquire documentation that stated what th at final success criteria was. Unknown if there was a requirement for survivorship

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Table 3-5. Continued. Bank Name Dominant Habitat at Site Visit Final Success Criteria percent cover of native vegetation Survivability of planted vegetation Everglades Mitigation Bank Sawgrass marsh, tree islands 80% aerial coverage of vegetation including planted and naturally recruited vegetation Survivorship not explicitly defined. Florida Mitigation Bank Freshwater marsh, bottomland hardwood > 90% desirable vegetation groundcover and canopy NA Florida Wetlands Bank Freshwater marsh 80% planted species must have 80% cover Garcon Peninsula Wet prairie Groundcover 75% Planted canopy must have at least 30% cover > 90% survival Graham Swamp Bottomland hardwood forest Vegetative cover must stay the same or increase over the baseline. Vegetation must demonstrate natural recruitment No planting Hole in the Donut Freshwater marsh The importance value, based on frequency and percent cover or density of desirable vegetation, for each restoration area shall fall within the range of Whittaker curves for the naturally occurring communities in this area of Everglades National Park No planting Lake Louisa and Green Swamp Sandhill? Unknown if there are requirements for percent cover, none were obtained by this study Planted canopy 80% Planted groundcover 60% Lake Monroe Flatwoods Unknown whether there is a target perc ent cover in the final success criteria but bank is tracking percent cover in the monitoring reports Planted longleaf and cypress 50% Little Pine Island Mangrove swamp, salt marsh, mud flats, hydric flatwoods Demonstrate > 60% cover and increase over time NA Loblolly Mitigation Bank Hydric flatwoods, cypress domes > 80% cover groundcover > 25% mast forming trees 100 trees per acre in forested wetlands 25 trees per acre in upland Loxahatchee Forested swamp and open marsh 80 90% ground cover in marsh and willow polygons except in mudflats with 25% woody species 50-90% canopy and ground cover for red maple, pond apple and cypress polygons 10-20% open water as meandering water courses and small depressions Permit also addresses appropriate number of species and densities No planting

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Table 3-5. Continued. Bank Name Dominant Habitat at Site Visit Final Success Criteria percent cover of native vegetation Survivability of planted vegetation Panther Island Hydric flatwoods, cypress strands, cypress domes, freshwater marshes 70% average aerial cover by native wetland flora for transitional and emergent marshes Low pool marshes 60% cover Flatwoods 70% aerial cover by desirable ground cover and groundcover recruitment Flatwoods minimum 90% survival planted canopy spp.; minimum 80% survival of planted subcanopy spp.; minimum 80% average survival of planted ground cover spp. Reedy Creek Hydric flatwoods, freshwater marsh, wet prairie flatwoods canopy cover 50%, shrub cover < 20% marshes 75% prairie 80% Bank may have to do future plantings in marshes if percent cover by natural recruitment can not be met R.G. Reserve Bottomland hardwood forest, hydric flatwoods, swales 80% coverage of desirable wetland species Uplands mean % cover by indigenous ground species > 75% Ground strata dominated with indigeno us grass species at > 50% of total ground strata: mean % cover by indigenous ground strata species is > 5% but < 30% Mean density of indigenous shrubs and semi-shrubs is > 180 and < 400/ac Shrub strata dominance < 75% by any 2 species Mean % cover by indigenous tree species is > 5% and < 25% Mean indigenous tree density is > 5 and < 50 Survivorship of planted vegetation not explicitly defined Split Oak Documentation did not include su ccess criteria specific to native vegetation cover or survivability of planted veget ation. Sundew Mitigation Bank Hydric flatwoods, cypress domes No requirement for percent cover 100 trees per acre in forested wetlands TM-Econ Hydric flatwoods, forested slough > 80 % aerial cover trees 80% Tosohatchee Mixed wetland forested, fresh water marsh > 80 % cover > 80% Tupelo Mitigation Bank Hydric flatwoods, cypress domes No requirement for percent cover Minimum density of 100 surviving and growing trees/ac present in assemblages that reflects diversity in target vegetative community

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42 for recruitment. Additionally, supplemental plan tings may be required to increase diversity, provide structure, or stabilize areas where ro ads were removed, canals filled, or grading occurred. A practice commonly followed by several more recently permitted banks for flatwoods or wet prairie targets communities in cludes preparing large ar eas of bare ground by disking and/or herbicide treatments, then mulchi ng with seed and other pl ant material directly from a harvested donor site. Although most banks did list a desired percent cover for native vegetation, very seldom was there a reference in the permit for how per cent cover would be defined or measured. Composition, dominance, structure, and other metric s that define a natural community say more about restored function than perc ent cover or survivorship of pl anted species alone. In addition, percent survivorship criteria often appeared to be based more on standard practice or previous permits, as opposed to expected vegetation density in the reference standard community. These arbitrary densities, especially for trees, should not be a standard, a nd plantings in specified target communities should be based on reference standard s in the literature or a natural community. Prescribed fire A majority of the mitigation banks in this study include a diverse landscape mosaic of upland and wetland community types most of which are ad apted to fire. Bear Point, CGW, and Graham Swamp represent three mitigation banks where prescribed fire would not be appropriate given that mangrove and hardwood wetland communities re present nearly 100% cover at these banks. However, historically fire would have played a significant role in maintaining the natural communities in the landscape surrounding these mangrove and bottomland hardwood swamps. The FDEP mitigation rule requires mitigation bank permits to contain perpetual management plans (62-342.750(1)(h) F.A.C). Most of the banks acknowledge the role of prescribed fire in maintaining the natural communities on site. However, it was difficult to determine how detailed long term fire management plans were. Some banks also have (or intend to) utilized prescribed fire during enhancement and restoration activ ities in addition to using it for long term management of the natural communities. Eight bank permits had a credit re lease associated with conducting a prescribed fire (Table 3-3). A few more permits required prescribed fire as part of the final release crit eria. There is evidence that some banks are not as aggressive in the applic ation of prescribed fire as they could be. At least two banks, Big Cypress and Ba rberville, cite being unable to apply prescribed fire until planted pine trees ( Pinus spp.) in flatwoods communities are established for eight to ten years. Additionally, Barberville anticipates waiting 15 years to burn an area planted with cypress ( Taxodium spp.). Documents for both banks do not ad equately describe the natural community type, but suggest the overall reason for not a pplying prescribed fire is because of possible mortality to the planted trees. As well, both banks demonstrate a lack of diversity in the groundcover in what this study determin ed should be flatwoods communities. The emphasis to protect the planted trees appears misplaced when restoring the function for this community type. For example, in longleaf pine ( Pinus palustris ) communities, Kirkman and Mitchell (2006) propose that the age and diversity of groundcover and temporal extent of fire connections across the landscape may be more approp riate means of describing ol d-growth ecosystems as opposed

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43 to the age of trees, stressing the importance of appropriate groundcover and fire regime over tree structure. A low intensity prescribed fire during the growing season could benefit the groundcover and enhance species diversity. Primar y concern for planting the pine trees first before restoring the groundcover may not have been the best approach to achieve success and restoring a functioning flatwoods community. At least seven banks included in this study reporte d that they were behind in accomplishing their prescribed burn plan for site specific conditions usually because the site was either too wet or too dry. Other limitations for some banks in clude their placement in populated areas where smoke control is more restricted (e.g., Everglad es Mitigation Bank Phases I and II). In some circumstances (e.g., Garcon Peninsula), the inability to burn has set back the restoration progress because a primarily herbaceous ecosystem has b een over taken by an overstory of shrubs and other woody structure. In this specific case, pr escribed fire was tied to credit release and the state withheld future credit rele ases pending fire implementation. As with all of the construction and management ac tivities described in this chapter it would be worthwhile for regulators to consider tying cred it release to the natural communities response to management decisions such as pres cribed fire. Fire is an ecosys tem process that can drastically alter a landscape, if applied appr opriately it can be a tool for restoration and maintenance of a natural community. Monitoring should be conduc ted to determine flora and fauna response to the application of fire. Frequenc y and application techniques of prescribed fire should be based on reference documentation and literature. Credit releases for construction and management activities described previously are based on documentation that the required action has occurred. In total, these activity-based releases at a typical bank averaged about 50% of the total po tential credits (Table 3-3), and represent the preservation and completion of the mitigation w ork at the bank. Although it is recognized that the actual work does sometimes represent actual enhancements made, mitigation success may be improved if credits releases were weighted more toward incremental improvement and community response to these treatments and actions, rather than simply completion of predetermined activities. The remaining credits are typically based on ac hieving incremental or final performance goals. Monitoring and Interim Release Criteria Most mitigation banks are required to submit an annual monitoring report to document the level of success attainment. Monitoring plans, includ ing both qualitative and quantitative parameters, are reviewed prior to permitting, and thus should be adequate to evaluate success criteria. Monitoring plans are generally refe renced in permit criteri a or attached to the permit. Some state permits specifically addressed what is expected in monitoring reports, others did not have specifications. The FDEP mitigation banking rule (Chapter 62-342, F.A.C.) requires that mitigation banks include a proposed monitoring plan to demonstrate success. Monitoring reports acquired in this study repres ented varying degrees of quali ty of data and quantity and completeness of information. For utility, monito ring reports should refer to success criteria, both interim and final, and specifically demonstrate incremental change from the baseline. If a bank

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44 is using reference wetlands for ta rget restoration, then monitoring reports should reflect how the restored areas compare to reference conditions. Some monitoring reports were mere plant lists, with minimal analyses and vague descriptions. It could be that some early perm its did not specify enough detail as to what was required for monitoring, and bank are not offering more than these minimal requirement. While agency personnel do tend to visit banks either when new monitoring reports are submitted or following requests for credit release and regulators should be capable of verifying what is in the report, time and resources devoted to agency monitori ng and analysis is limited. Efforts would be improved so that monitoring reports read easily for anyone unfamiliar with site history or permitting conditions of the bank. A monitori ng report should summarize success criteria, history of the bank, activities completed, acti vities planned, and discuss how the bank is progressing in restoring and enhancing the natural target communities. Further, monitoring reports should clearly and unambiguously state if the mitigation bank is on target with interim or final success criteria and if the bank is trending to wards success and describe the parameters it is meeting. Compliance regulators reported that seven banks did not report on areas that were not demonstrating ecological improvement or did not submit a report becau se no activities were taking place. Sometimes if a bank falls behind in meeting their targets, th e bank will not request additional credits release but will also not su bmit a monitoring report, as that would require admitting problems with attaining interim targets or monitoring. Some permits require a status report every six months, regardless of the degree of activity or monitoring results, which may be a good tool to track mitigation activities and progress. After major mitigation construction activities but pr ior to final credit release, interim credits are typically awarded by year or phase of a mitigat ion bank. Potential credits awarded for reaching interim criteria vary, with mean awards of 5-8% of total potentia l credits per year. Total interim criteria varied around 30%-50% re lease of total pot ential credit (Tab le 3-3) over an average of four to five years. While there is an expectation that releasing interim criteria should implicate a trending towards success, many times this was not reinforced by specific criteria that should demonstrate incremental ecological improvement. Out of twenty three mitigation banks that included an interim release, onl y thirteen had specific criteria tied to this annual or interim release. It is important that permits cl early distinguish that the interim/annual cred it releases are based upon the ecological functions gained since the last monitoring report, rather than on the submittal of the annual monitoring report itself. Comp liance regulators reported some problems with expectations based on reports rather than success. Further, field work associated with this study revealed cases where credits were released when it appeared that interim criteria had not been achieved. Compliance regulators re ported that monitoring reports can be misleading or report on improving areas rather than the whole site. A few mitigation banks have few or no credits released for interim success, either because cred its are withheld until the bank or polygon attains full success (e.g., Boran Ranch) or because the activ ities represent the final or near final success (e.g., Colbert-Cameron, Florida Wetlandsbank). In addition, the number of years required for monitoring and meeting final success varies, with mo st anticipating a five year release schedule,

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45 some anticipating an accelerated schedule (e .g., Florida Wetlandsbank, Graham Swamp, Panther Island), and other banks have or are anticipate d to take 10 or more years (e.g., Everglades Mitigation Bank, Florida Mitigation Bank, Garcon Peninsula, Hole in the Donut, Loxahatchee). In fact, even a 10 year time span may be too s hort to fully attain the natural variability and function for ecosystem development (Mitsch an d Wilson 1996), even if permit success criteria are reached. Final Success Determination and Release Ideally, final success criteria should reflect th e mitigation projects target community goals and anticipated functional gain, as de termined by the potential credit assessment (i.e., its with-bank scenario). An early guidance docum ent for Florida mitigation banking, Joint State/Federal Mitigation Bank Review Team Process (the Greenbook, cited as Story et al. 1998), suggests that the risk inherent in wetland mitigation bank ing is managed through credit release schedules and that because most credits are not released un til the success criteria have been met, risk has been minimized. Further, the Greenbook suggest s that success criteria s hould be specific and quantifiable based on the field assessment used to determine appropriate awarding of credits (Story et al. 1998). Yet only five wetland m itigation banks reviewed included functional assessment scores, such as WATER, Wetland Ra pid Assessment Procedure (WRAP, Miller and Gunsalus 1999), or Uniform Mitigation Assessm ent Method (UMAM, Chapter 62-345, F.A.C.), in the final success criteria. For over a decade, wetland scientists have reco gnized that permit success criteria and achieving wetland function may not be equivalent (Mitsch and Wilson 1996), yet changes have not been made in the permitting process to require completion of functional assessments for attaining credit release. Functional assessment scores for WRAP or UMAM may not be included in permit language because of concerns abou t the inherent subjectivity in the methods. For example, an assessor could award a hi gher functional assessment score base d on the incentive to attain functional success and not necessa rily based on a wetland asse ssment area truly achieving the suggested function. This concern for subjectivity and evaluator bias does not speak well of the reliability of rapid assessment methodologies or the human involvement in wetland mitigation banking. Even in more calculation intensive met hods such as the Hydrogeomorphic approach to assessing wetland function (HGM), it has been suggested that an assessor could visualize a higher percent cover of desirable species or miss an exotic species that occurred on a transect to improve the final score. Perhaps developm ent of a more objective means of measuring ecological function is called for, and holding thos e involved in the proces s personally responsible for such evaluations would improve the situ ation. Despite these limitations, achieving a predetermined with-bank scenario score for a given functional as sessment method could be used as a back up measure to withhold final credit release if the site did meet permit success criteria, but has been poorly monitored or is not functioning as anticipated. Final release of potential credits for mitigation bank state permits have been organized in two ways: one includes final re lease of credits as an incremental in stallment of available credits after final monitoring for the entire mitigation bank, a nd the second separates out final credit release based on criteria specific to each community t ype or polygon. The typical range of potential credits for final credit releases is between 5-20% of total potential credits awarded (Table 3-3).

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46 One obvious exception to the typical range is La ke Monroe, which has a potential final credit release of 35% total potential credits To date, all potential credit s have been released for Lake Monroe except for this final 35%, because it ha s not met its final success criteria. However, success criteria for this bank do not appear to encapsulate ecological function. There are incremental improvements, but the majority of cred it is tied to the survival of a planted canopy instead of restored groundcover for a community that should have a sp ecies rich groundcover. There is also credit tied to the appl ication of prescribed fire in th e communities that are intact but are in need of enhancement. At this time the bank is behind sc hedule in implementing prescribed fire. Fortunately this final credit is being with held until improvements are made to the restored and enhanced areas. It is doubtful, under the current management strategy, that the pastures will ever be reclaimed and resemble any reference conditi ons, but this was never part of the success criteria goals. The pr imary with holding of fi nal credit release appe ars to be tied to failures of control structures on hydrologic enhan cement areas. Another exception to the average final success release is Boran Ranch, where th e permit withholds 75% of credits until final success criteria are attained. However, this attainment is based on each polygon, rather than the whole bank, thus it becomes successful in piece s, which may mimic the incremental releases of other banks. There are causes for concern if meeting final suc cess criteria has a less significant credit release. This further illustrates the importance of the re gulators ability to determine that incremental credit releases are appropriate and determine a trending towards success. If banks are unable to meet final success criteria because they have failed to create conditions suitable for ecological trajectories, the final cr edits cannot be released. Compliance with Permit Schedule of Activities and Success Criteria State mitigation bank regulators were interviewed and asked to comment on the technical aspects of compliance for their respective mitigation banks. Their responses have been compiled and are listed in Table 3-6. In this section, success and trending towards success are defined in regards to permit criteria only. Three mitigation banks have reached final success criteria for the entire bank (East Central, Florida Mitigation Bank, Tosoha tchee). Regulators belie ve that nine banks appear to be trending towards success and should be able to reach final success. Five banks are currently not trending towards success, at least in specific problem areas. Six banks were not far enough along for regulators to comment on whether or not they are trending towards success yet. Most banks are visited at least once, if not twice, a year by the regulatory agency; most visits are timed with monitoring reports and requests for cred it release. This documentation is anecdotal, sometimes the regulator did not have all the inst itutional history on a bank if it was before their involvement and others expressed that some issues were one time incidents and not a continuous issue. Summary To insure that the credits released for use can indeed provide offsets to wetland functions, the following recommendations are nece ssary to the highest levels: Permits and attached or referenced docum ents should contain th e detailed community goals and/or reference conditions the site is anticipated to attain. FNAI descriptions

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47 could provide a valuable star ting point to ensure that mo re than just vegetation is included. It is important to evaluate wild life responses to mitigation activities. Final success criteria should be qua ntifiable reflections of these goals. Credit potential should be assessed with a reasonable evaluation of future condition given the expectations for surround ing landscape and water sources. Implementation of fire management pl an, as appropriate, should be a permit requirement, rather than just referenced in mitigation plans. Regulatory agencies must endeavor to write permits that can be followed and enforced that use the best available technology or protocol for re storation, be vigilant in demanding accurate and representative monitoring reports, withhold credit for underachieving sites, and ensure frequent co mmunication and inspecti on of the sites. The permits credit release schedule shoul d be commensurate with actual functional gain including the value of site preservation, with a higher focus on community response to mitigation activities, as opposed to the activity itself, and based on specific criteria.

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Table 3-6. Summary of regulatory complia nce for 28 wetland mitigation banks. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Barberville Problems with planting pines, have had to replant several times but latest monitoring report reports good success with second planting which occurred in 2004. Bank has not had a permit modification yet but has planted cypress in areas that were more wet than anticipated, pine is not surviving. Bank did not request credit release when plantings were failing, now that they are finding better success they have asked for credit release. Long ways off. No problems. Pretty good with communication, good about district visit. New district staff has been out to the bank a couple of times, and going again now because of credit release request. If the bank is not improving, then the district will allow more time to meet criteria. Bear Point First release for exotic species control, preservation, and financial assurance. Practically meeting success criteria after only 1-2 years. Need reminders when submitting reports. Needed help with process but good communicating. 1-2 times/yr with every credit release. Big Cypress Time zero was reset because could not get ground cover to proper specifications. Recently bank submitted request for credit release, but the district only gave a partial release because the herbaceous level 1 criteria could not be met because torpedograss ( Panicum repens ) cover was greater than 10%. Bank has finished all planting. Permit may have to be modified either in number of credits or type of credits because they may not be able to get the torpedograss within success criteria requirements. (this may not have ever been done before as far S.McCarthy knows) May experiment with different techniques to try and control the torpedograss. Pretty good about submitting reports on time although did withhold a monitoring report for a while because they were trying to do better with the torpedograss, fell a little behind trying to get it under control. Communicating pretty well. Usually on time except for what was previously mentioned. Generally visit Big Cypress every time a request for credit release is submitted. Other than that, site visits may happen at the request of the permittee to address a specific issue (i.e., analyze methods to eradicate torpedograss). Site visit may be requested if there are any glaring noncompliance issues from the monitoring reports. District staff has visited the bank for training and educational type purposes for district staff in the past. The bank has always been very accommodating.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Bluefield Ranch Credit for Phases 4 and 5 have been released post site inspection by district. Percent cover exceeds success criteria goals in the permit. Bank has met all requirements to date. Never denied a credit release. Have met all requirements to date, very successful to date. Reports are never late. Usually very lengthy with lots of documentation exceeding minimum requirements. Very communicative and responsive, never late. Agency staff only gets out once or twice a year. Try to time inspections following submittal of monitoring reports and prior to credit releases. Typically credit release inspections and general inspections are conducted together, limited staff and high work load being the factor. Boran Ranch There is not interim success criteria. Bank is laid out in polygons, there are no partial success or trending toward success credit releases. A polygon either has reached success or not. Credits released for Conservation Easement and construction and then for reaching success. Phase I is mostly released. Phase II conservation easement and construction credits. Agency feels that the bank knows what the expectations are and what exactly it has to do. Myakka is set up the same way. Final success is per polygon. A polygon might be the interior of a marsh and another polygon for the ecotone or transition area. The transition zone might be more difficult to achieve success because of pasture grasses and exotic species. Very cut and dry, either successful or not. If a polygon cannot reach success may have to do a credit modification and adjust success criteria and credits. Final success criteria is based on UMAM. Annual reports are very good and on time. Good communicating, bank keeps good track of credit withdrawals. Site visits usually at least twice a year. Visits coincide with requests to release credit. Sometimes the bank might think they deserve credit release but the ag ency does not believe the polygon has met final criteria.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency CGW No instance when credit was not released because of compliance issues. Progressing well, currently in monitoring phase. Sometimes needs to be reminded to keep on track. Asked for a credit release a year after monitoring report was due. Not always communicating on the ground. Lately bank is better about communicating and is straightening up ledger issues. District site visit are performance related. Site visit before credit is released when monitoring report is submitted and also to see how bank is progressing with interim criteria. ColbertCameron No problems with compliance, previous regulator said things were progressing well. Looks good do not foresee any problems. Submitting everything Good communication. New district staff has been to the bank once, do not know history of previous district staff bank visits. Corkscrew Long delay with initiating work. Was not communicating that on the ground work had begun. Reevaluate different plan based on lack of earth workconstruction changes. Permit modification made new plan less intrusive but did not have big impact on success criteria or monitoring. Will not be as wet. If they had scrapped the site like original intention the plan had more risk and might have been more difficult to hit final success. Hydrologic final success may be more difficult to reach now that they did not scrape. Made a significant modification of the permit to do less earth work. On the ground less was done (less impact). Not communicating at first what they were doing, doing their own thing. Better now. Work was good. They are responsive now. Lots of field work in permitting will be onsite for initial credit release December 2006. East Central Unknown if there is any history of not meeting interim criteria. Sold out final success achieved. Unknown. Unknown. Unknown. Everglades Mitigation Bank On the ground success looks good. Phase I attainedconscientious management. Tardy with annual monitoring report. Not always on target. ~1/y ear with credit release.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Florida Mitigation Bank Hydrology poorly designed-ended up firing manager, got new manager, and everything improved, first year annual credit release was denied. Do not have control of water input, but have relationship with Disney; official FDEP and MBRT success determination 2004. Initial monitoring and management techniques poor; good after new consultant (~2000). Initial reporting and modification very misleading; good after new consultant (~2000). 1-2 times/yr with every credit release. Florida Wetlandsbank Regulator does not know previous compliance history but in last few years the transfer of the bank to the City of Pembroke Pines for perpetual maintenance was held up because the buffer between housing on west side of the bank had homeowners infringing into the conservation easement with exotic plantings, swing sets etc. Bank managers had to go to the homeowners and remove all infringements from the bank and then the bank was required to put up a fence on the bank boundary in that area before the SFWMD allowed the final transfer. A final more recent phase has some time left in monitoring before the remaining credit (2.63) is released. Very good about submitting reports on time, adequate detail and information. No problems known. Site visits every year not necessarily tied to credit release or a set time schedule, just worked out between bank, district, county, the Corp and the City of Pembroke Pines. Early stages did annual visit with the agencies. Towards the final stages the only bank activities were treating undesirable vegetation. The bank was well established so did not do as many site visits Garcon Peninsula Good start-initial credit release for fire and exotic eradication. Site got wetter than anticipated when ditches were plugged. Changed cover type. Management fell behind. Needs a lot of work if they are going to try to hit final success. Back tracked some what because no burning, so will take longer than planned. Hydrologic success evident. Was out of compliance because was not getting burning done and had aerial spraying of exotic species. Reports not sent because no work done Not good needs constant agency prodding. Frequent early on, but 2+ years w/ no work, no request for credit release and no site visit; working to get back on track with frequent agency inspections and notices.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Graham Swamp Monitoring is not often enough. Did not attain final success but 95% there. Data are sometimes poor; because early permit not required to do long term management reports. Not responsive about keeping ledger up to date. 1+/yr earlier, now every other year. Hole in the Donut Ahead in restoration by acre. May never meet final success criteria, cover is not the same as reference conditions but function is believed to be met. On time, scientific good annual monitoring, but deficient status/activity reporting relative to permit. Miami Dade county not good about reporting permits and updating credits. No "credit release" schedule per se, but inspections ~once/2 years reveal timely/appropriate management. Lake Louisa and Green Swamp Only SJRWMD bank that requested a credit release and the district said no. Having problems meeting interim success regarding groundcover and shrub layer in the planted areas. District asked for a plan for how bank will address these issues. The bank is in disagreement with the District's decision because of previous arrangements made with staff that is no longer with the District. There was never a permit modification for success criteria. Bank is not in compliance but believes that it is trending towards success. Bank suffered from neglect, problems with bankruptcy. It is the District's opinion that the bank will have to change its management strategy if it will ever meet final success. Have been submitting reports on time but they are not always accurate. Reports are misleading and only reporting on areas that are more successful not the areas that are not in compliance. Monitoring report misleading, not on target. New district staff visited the bank initially to become oriented and familiar with it. Since then there has been a site visit conducted because a monitoring report was submitted and a credit release requested.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Lake Monroe Problems with ground cover, some plantings have failed, structure for hydrologic improvement has had some blow outs District land managers may try to help with pasture grass issues because it is District property, ultimately when it is turned over then District will maintain, but they do not want it until FDOT has found success with restoration and enhancement measures and is up to date on prescribed fire. Unknown. No current monitoring report, new District staff plans on spending more time with this bank and addressing its issues. Communicating pretty well. New District staff has been out to look at the bank and has had discussions about some of the problems (hydrologic structures and pasture grasses). Bank is willing to redo that work but there is debate about culvert maintenance between district and FDOT land managers, may be an issue discussed with previous staff no longer with the district. Little Pine Island Good at hitting target. Lots of phases are done; no final success determination requested yet. Reporting/ communication good. Mostly good, but some debit requests very late. 1-2 times/yr with every credit release. Loblolly Mitigation Bank Request in right now for credit release, site visit is planned. Initially credit for conservation easement and clearing pines but have since done some plantings. Very early stages of bank. Had to be asked for report. Not communicating so well, but is getting better. Does call a lot but has to be reminded for reports and more administrative type things. Bank does get in touch but might need more guidance and help in the process. Visit planned to determine credit release. Loxahatchee Not getting credit released because so far mostly unsuccessful, may not be able to reach final criteria. Hydrology success a problem in south parcel due to leaky underground conduits and canal level management out of control of bank reevaluation of criteria and credit likely. Good monitoring and reporting also addresses the problems responsively. Very communicative and responsive. 1-2 times/yr with every credit release.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Panther Island A couple times there was a hold up on a release because WMD needed to go out and do a site visit, one phase okay but another was not, specifically there was an issue with the exotic species smut grass ( Sporobolus indicus ) and torpedograss ( Panicum repens ). Bank was required to do a re-treatment before full requested release. One phase had a design modified because a site was wetter then expected. With time the Bank seems to know when to wait to ask for certain releases because they know WMD will not approve it in its current standing. Appears all phases trending towards meeting total success. Preservation areas doing very well, creation areas might take longer. As far as meeting criteria, Phase II might be too much coverit exceeded percent cover requirement and went from supporting open water fauna such as ducks and white pelicans to supporting larger and more common egrets and herons, does not conflict with success criteria. Bank reports are usually on time, or if not there is a particular reason that they have communicated to the WMD for example site was too wet to sample vegetation, or time zero report was delayed because planting issues with weather, lots of planning went into baseline and monitoring before anything was done on site. Very communicative, good relationship. WMD site visits tied to credit release most of the time. District staff has visited the bank to practice plant identification and train staff in the District. Site visits are conducted for final releases for particular phases. R.G. Reserve Bank has done minor enhancements, mostly credit for pr eservation. Credit might be denied sale because of withholding monitoring report (because the bank is waiting for a Corp permit). If percent cover is not achieved the bank will have to do some vegetative planting. Bank withheld monitoring reports because they did not have Corp permit yet, if the bank submits monitoring reports saying wetlands were restored, Corp would award less credit, Corp already has said that site is just preservation. Bank has modified its monitoring schedule. All reports are up to date and submitted now. Very little credit release, two sold for owner's projects and one other private but only 2/10 of a credit. Agency staff only gets out once or twice a year. Try to time inspections following submittal of monitoring reports and prior to credit releases. Typically credit release inspections and general inspections are conducted together, limited staff and high work load being the factor.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Reedy Creek No record of having with held credit for not meeting interim goals. Bank is fulfilling its requirements and submissions. On time or ahead of schedule with improvements to get credit release. Quality of reports is exemplary. Communication exemplary, bank and the agency audit each other, make sure both are on the same pageverify each others books are straight. Credit release and monitoring reports simultaneously with conducting site visits. Split Oak Unknown. Unknown. Unknown. Unknown. Unknown. Sundew Mitigation Bank Bank has only had an initial release for the conservation easement and has had some credits released for hydrologic enhancements, pine removal, and some plantings. Very early stages of bank. Had to be asked for report. Not communicating so well, but is getting better. Does call a lot but has to be reminded for reports and more administrative type things. Bank does get in touch but might need more guidance and help in the process. Bank has had a site visit because of request for credit release. Bank is in very early stages of work. Have done some planting, removed planted pine, and some hydrologic enhancement. TM-Econ No problems meeting interim cr iteria. No foreseen problems meeting final criteria. Always on time and responsive. Very responsive, no complaints from District. District site visit are performance related. Site visit before credit is released when monitoring report is submitted and also to see how bank is progressing with interim criteria. Tosohatchee Unknown if there is any history of not meeting interim criteria. All credits released, applicant not asking for anything. Unknown. Unknown. Previous regulator said bank was in good shape so it is not a current priority for follow-up to the new District staff.

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Table 3-6. Continued. Bank Interim Criteria Final Success Monitoring and Management Status Reports Administrative Record Keeping -Ledger; Communication Frequency of Compliance Inspections by Agency Tupelo Mitigation Bank Has had some credits released for hydrologic enhancements, clearing of pine, and some planting. Very early stages of bank. Had to be asked for report. Not communicating so well, but is getting better. Does call a lot but has to be reminded for reports and more administrative type things. Bank does get in touch but might need more guidance and help in the process. Bank has had a site visit because of request for credit release. Bank is in very early stages of work. Have done some planting, removed planted pine, Done with hydrologic enhancement. Tupelo has had the most work of the three banks including Sundew and Loblolly.

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57 CHAPTER 4 DETERMINATION OF ECOLOGICAL INTEGRITY In order to assess the current ecological integr ity of the wetland communities in Florida wetland mitigation banks, five assessment methods were ap plied to select wetland assessment areas: Uniform Mitigation Assessment Method (UMA M), Wetland Rapid Assessment Procedure (WRAP), Hydrogeomorphic wetland assessmen t method (HGM), Florida Wetland Condition Index (FWCI), and Landscape Development Intensity (LDI) index. This chapter defines the term ecological integrity for the purpose of this study, followed by an overview of wetland assessment areas and a presentation of results from the five assessment methods. Comparisons among assessment methods are discussed. Definition of Ecological Integrity For this study, we adopt Karr and Dudleys (1981) definition of eco logical integrity. They state that a system with high ecologi cal integrity has the ability to support and maintain a balanced, integrated, adaptive community of organism s having a species composition, diversity, and functional organization comparable to that of th e natural habitats of th e region (pg. 56). In order to ascertain the degree of ecological inte grity of the assessment sites in this study, we compared the sites to the appropriate refe rence standard condition for the region. The term reference standard wetland condition has been defined (Smith 2001) as the least altered wetlands in the least a ltered landscapes (pg. 3), suggesting that those wetlands reflect the highest level of functioning for a ll of the functions expected of that type of wetland. Thus, the ecological integrity associated w ith these wetlands with no a pparent anthropogenic alterations and surrounded by natural landscapes would be optimal. All of the field assessment methods used in this study were developed with reference to minimally impacted ecological communities, and this comparison has been built into the scoring criteria for each assessment method. For ex ample, UMAM includes a Part I Qualitative Description where the evaluator must determ ine the reference community type, hydrologic connectivity, and the expected functions and wi ldlife (both common and listed species) before the site visit and scoring occurs. Similarly, WRAP begins with an office evaluation that requires review of aerial photography, identi fication of adjacent land use, and identification of wetland area (Miller and Gunsalus 1999). Both HGM and FWCI were de veloped based on a comparison of reference standard wetland community conditi on, and scoring criteria were standardized against a set of reference wetlands. Regional similarities and differences among wetland communities were considered when defining ecological integrity. WRAP was originally designed for use in certain types of south Florida wetlands, and has been applied state-wide to a variety of wetland types, whereas UMAM was intended to apply to all wetland community types statewide. The FWCIs for depressional forested wetlands and forested strands and floodpla ins are not limited geographically in the state. The Everglades flats HGM assessment method is app licable only to southern portions of the state (Figure 4-1), and both the depre ssional wetlands HGM assessme nt method and the depressional herbaceous FWCI were limited to the Florida peninsula (Figure 4-2).

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58 Figure 4-1. Applicable range of the Evergla des flats Hydrogeomorphic wetland assessment method (HGM) in South Florida. Reprinted with permission from Noble et al. (2002). Results of Assessment Methods Site visits were completed at a total of 58 wetland assessment areas within 29 mitigation banks. Each wetland assessment area was assigned a unique code. The first set of characters were assigned as abbreviations of the mitigation bank name. For example, Barb represents Barberville and Blue represents Bluefield Ranch. The second se t of characters were assigned as unique descriptions of a pa rticular wetland type: BOT for Bottomland Hardwoods, FLA for Hydric Flatwoods, FOR for Mixed Forested, HAM for Cabbage Palm Hammock, PRA for Wet Prairie, SHR for Shrub, and SLT for Salt Marsh. When more than one wetland assessment area at a bank was the same wetland community type, a number was added to the code. One to four wetland assessment areas were select ed within each bank for field assessment, depending on a combination of site specific conditions such as homogeneity of the bank, mitigation activities completed to date and pr ogress towards success criteria, area of wetland within the bank, types of mitigation (i.e., restor ation, enhancement, creation, or preservation), and general site conditions. Prio rity was given to those areas representative of the bank and where mitigation work had been conducted.

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59 (A) (B) Figure 4-2. Applicable ranges (reference domain) of A) depressional wetlands Hydrogeomorphic wetland assessment method (HGM) and B) depressional herbaceous Florida Wetland Condition Index (F WCI) in peninsular Florida. HGM map reprinted with permission from Noble et al. (2004).

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60 Generalized statistics regarding the size of banks as well as the wetland assessment areas sampled are telling of the vast differences among the banks (Table 4-1). For example, the mean bank area was 848 ha ( = 894.5 ha) with a range from 27 ha at Graham Swamp to 3,653 ha at Everglades Mitigation Bank/Phase II. The size of the wetland assessment areas ranged from 0.2 ha at Lake Monroe to 282.2 ha at Loxahatchee, with a mean wetland assessment area of 20.3 ha ( = 48.3 ha). The mean wetland assessment areas was 15.8% ( = 30.8%) of the total bank area, with a range spanning from 0.1% at L oblolly Mitigation Bank and TM-Econ to 100% at Bear Point and Graham Swamp. Less than 1% of the bank area was included in the wetland assessment areas at 13 banks, wh ile over 50% of the bank area was included in the wetland assessment areas at four banks. Regardless of the size of the bank, which incl udes upland area as well as wetland area, the assessment areas were sampled to best reflect th e scope of current conditions. For example, at Panther Island, four wetland assessme nt areas were selected due to the heterogeneity in wetland community and mitigation types. However, due to the large size of the bank (1,128.3 ha) and the small size of the wetland assessment areas (4.5 ha total); only 0.4% of the bank was included in the wetland assessment areas. Only a single we tland assessment area was selected at each of nine banks. At six of these banks, this wa s because the single wetland assessment area was representative of the dominant type of wetland community and mitigation activities. For example, an 8.1 ha wetland assessment area at Ev erglades Mitigation Bank/Phase II covered just 0.2% of the entire area of the wetland mitigation bank. In contrast, the 19.0 ha wetland assessment area at CGW covered 31.3% of the bank area. Due to vast differences in the size of the banks (60.7 ha at CGW and 3,652.7 ha at Ever glades Mitigation Bank/Phase II), the percent of area covered is vastly differe nt (31.3% compared to 0.2%). However, sampling efforts based on equal percentages of area of ba nk covered would not provide ad ditional information regarding the ecological integrity of wetland communities w ithin these banks. Furthermore, sampling an equal percent of wetland area at bank would have been time and resource inhibitive (e.g., sampling 31.3% of Everglades Mitigation Ba nk/Phase II would have required 1,143.3 ha of wetland assessment areas). At each of the 58 wetland assessment areas, UM AM, WRAP, and LDI were used to determine ecological integrity (Table 4-2). At 16 of the wetland assessment areas, one or more additional assessment methods were completed (HGM n= 15; macrophyte FWCI n = 10; macroinvertebrate FWCI n = 4). HGM could only be applied to sites with a wetland community type with a regional HGM guidebook, which were limited to fl ats wetlands in the Everglades (Noble et al. 2002) and depressional wetlands in peninsular Florida (Noble et al. 2004). Similarly, the macrophyte FWCI could only be applied to depr essional herbaceous wetlands in peninsular Florida (Lane et al. 2003), depr essional forested wetlands (Rei ss and Brown 2005a), and forested strand and floodplain wetlands (R eiss and Brown 2005b). Only a subset of those wetland assessment areas sampled for the macrophyte FWCI were appropriate for additional sampling using the macroinvertebrate FWCI (n = 4) as onl y four wetland assessment areas met the criteria of 10 cm of standing water covering a minimum of 50% of the surface area. A diatom FWCI is also available for depressional he rbaceous wetlands (Lane et al. 2003) and depressional forested wetlands (Reiss and Brown 2005a). However, due to the small sample size (n = 4) and the time and expense associated with sample processing, a decision was made to eliminate diatom FWCI analysis. Indeed, a greater set of HGM and FW CI appropriate wetlands would be useful for

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61 Table 4-1. Area of wetland mitigation banks and wetland assessment areas in the this study. Bank Name & Site Code Wetland Mitigation Bank (ha) Wetland Assessment Area (ha) % of Bank in Wetland Assessment Areas Barberville 148.0 1.4 Barb_CYP 0.6 Barb_MAR 1.4 Bear Point 128.3 100 Bear_MAN 128.3 Big Cypress 518.0 2.4 BigC_FLA 7.3 BigC_MAR_1 2.4 BigC_MAR_2 2.6 Bluefield Ranch 1,090.6 2.9 Blue_BOT 26.0 Blue_FLA 5.3 Blue_MAR 0.5 Boran Ranch, Phase I 95.8 23.1 Bora_MAR_1 1.1 Bora_MAR_2 21.0 CGW 60.7 31.3 CGW_MAN 19.0 Colbert-Cameron 1,053.8 2.3 CoCa_CYP_1 5.2 CoCa_CYP_2 5.7 CoCa_FOR 13.0 Corkscrew 257.0 2.2 Cork_FLA 5.7 East Central 385.0 1.9 ECFl_FOR 0.9 ECFl_HAM 6.4 Everglades Mitigation Bank/Ph I 1,669.2 5.8 Glad_MAR_1 93.0 Glad_MAR_2 2.2 Glad_SHR 0.9 Everglades Mitigation Bank/Ph II 3,652.7 0.2 Glad_MAR_3 8.1 Florida Mitigation Bank 640.2 0.3 FLMB_FOR 1.8 Florida Wetlandsbank 170.0 6.1 FLWt_MAR_1 9.1 FLWt_MAR_2 1.2 Garcon Peninsula 136.4 59.4 Garc_FLA 81.0 Graham Swamp 26.7 100 Grhm_FOR 26.7

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62 Table 4.1. Continued. Bank Name & Site Code Wetland Mitigation Bank (ha) Wetland Assessment Area (ha) % of Bank in Wetland Assessment Areas Hole in the Donut 2,529.3 7.6 HID_MAR_1 21.2 HID_MAR_2 171.0 Lake Louisa and Green Swamp 407.5 0.8 Loui_SHR 3.2 Lake Monroe 244.0 0.3 Monr_CYP 0.6 Monr_MAR 0.2 Little Pine Island 511.5 7.8 LPI_MAR 6.0 LPI_SLT_1 10.0 LPI_SLT_2 24.0 Loblolly Mitigation Bank 2,528.0 0.1 Lob_CYP_1 1.1 Lob_CYP_2 0.7 Loxahatchee 511.5 85.6 Lox_CYP 82.0 Lox_FOR 282.0 Lox_SHR 74.0 Panther Island 1,128.3 0.4 Pant_CYP_1 0.4 Pant_CYP_2 0.7 Pant_CYP_3 2.5 Pant_FOR 0.9 Reedy Creek 1,211.2 0.2 Reed_BOT 1.3 Reed_FOR 0.7 R.G. Reserve 258.2 0.6 RG_MAR 1.6 Split Oak 424.5 0.7 SplO_CYP 1.9 SplO_MAR 1.2 Sundew Mitigation Bank 852.7 0.5 Sun_FOR_1 3.3 Sun_FOR_2 1.1 TM-Econ 2,103.9 0.1 TMEc_CYP_1 1.0 TMEc_CYP_2 1.5 Tosohatchee 530.9 0.3 Toso_FOR 0.9 Toso_MAR 0.3 Toso_SHR 0.4 Tupelo Mitigation Bank 617.1 0.6 Tup_FOR 0.7 Tup_PRA 2.8

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Table 4-2. Overview of wetland assessment areas (n = 58) includi ng Florida Land Use, Cover and Forms Classification System (FLUCCS Code), associated wetland community ty pe, and wetland assessme nt methods applied: Uniform Mitigation Assessment Method (UMAM), Wetland Rapid Assessment Pro cedure (WRAP), Hydrogeomorphic wetland assessment method (HGM), Florida Wetland Condition Index (FWCI) for macrophytes an d macroinvertebrates, and Landscape Development Intensity (LDI) index. Bank Name Site Code FLUCCS Code Wetland Community Type UMAM WRAP HGM Macrophyte FWCI Macroinvertebrate FWCI LDI Barberville Barb_CYP 6210 Cypress Barb_MAR 6410 Freshwater Marsh Bear Point Bear_MAN 6120 Mangrove Swamps Big Cypress BigC_FLA 6250 Hydric Pine Flatwoods BigC_MAR_1 6410 Freshwater Marsh BigC_MAR_2 6410 Freshwater Marsh Bluefield Ranch Blue_BOT 6150 Stream and Lake Swamps (Bottomland) Blue_FLA 6250 Hydric Pine Flatwoods Blue_MAR 6410 Freshwater Marsh Boran Ranch, Phase I Bora_MAR_1 6410 Freshwater Marsh Bora_MAR_2 6410 Freshwater Marsh CGW CGW_MAN 6120 Mangrove Swamps Colbert-Cameron CoCa_CYP_1 6210 Cypress CoCa_CYP_2 6210 Cypress CoCa_FOR 6170 Mixed Wetland Hardwood Corkscrew Cork_FLA 6250 Hydric Pine Flatwoods East Central ECFl_FOR 6300 Wetland Forested Mixed ECFl_HAM 6181 Cabbage Palm Hammock Everglades Mitigation Glad_MAR_1 6410 Freshwater Marsh Bank/Phase I Glad_MAR_2 6410 Freshwater Marsh Glad_SHR 6172 Mixed Wetland Hardwoods Shrubs Everglades Mitigation Bank/Phase II Glad_MAR_3 6410 Freshwater Marsh

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Table 4-2. Continued Bank Name Site Code FLUCCS Code Wetland Community Type UMAM WRAP HGM Macrophyte FWCI Macroinvertebrate FWCI LDI Florida Mitigation Bank FLMB_FOR 6300 Wetland Forested Mixed Florida Wetlandsbank FLWt_MAR_1 6410 Freshwater Marsh FLWt_MAR_2 6410 Freshwater Marsh Garcon Peninsula Garc_FLA 6250 Hydric Pine Flatwoods Graham Swamp Grhm_FOR 6170 Mixed Wetland Hardwoods Hole in the Donut HID_MAR_1 6410 Freshwater Marsh HID_MAR_2 6410 Freshwater Marsh Lake Louisa and Green Swamp Loui_SHR 6310 Mixed Scrub Shrub Wetland Lake Monroe Monr_CYP 6210 Cypress Monr_MAR 6410 Freshwater Marsh Little Pine Island LPI_MAR 6410 Freshwater Marsh LPI_SLT_1 6420 Saltwater Marshes LPI_SLT_2 6420 Saltwater Marshes Loblolly Mitigation Bank Lob_CYP_1 6210 Cypress Lob_CYP_2 6210 Cypress Loxahatchee Lox_CYP 6210 Cypress Lox_FOR 6170 Mixed Wetland Hardwoods Lox_SHR 6172 Mixed Wetland HardwoodShrubs Panther Island Pant_CYP_1 6210 Cypress Pant_CYP_2 6210 Cypress Pant_CYP_3 6210 Cypress Pant_FOR 6300 Wetland Forested Mixed Reedy Creek Reed_BOT 6150 Stream and Lake Swamps (Bottomland) Reed_FOR 6170 Mixed Wetland Hardwood

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Table 4-2. Continued. Bank Name Site Code FLUCCS Code Wetland Community Type UMAM WRAP HGM Macrophyte FWCI Macroinvertebrate FWCI LDI R.G. Reserve RG_MAR 6410 Freshwater Marsh Split Oak SplO_CYP 6210 Cypress SplO_MAR 6410 Freshwater Marsh Sundew Mitigation Bank Sun_FOR_1 6300 Wetland Forested Mixed Sun_FOR_2 6300 Wetland Forested Mixed TM-Econ TMEc_CYP_1 6210 Cypress TMEc_CYP_2 6210 Cypress Tosohatchee Toso_FOR 6170 Mixed Wetland Hardwood Toso_MAR 6410 Freshwater Marsh Toso_SHR 6460 Mixed Scrub Shrub Tupelo Mitigation Bank Tup_FOR 6300 Wetland Forested Mixed Tup_PRA 6430 Wet Prairie

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66 further consideration of ecological integrity of wetlands within banks; however, HGM and FWCI could not be applied to wetlands th at did not fit the conditions for the reference wetlands used in developing these biological assessment tools. Using the Florida Land Use, Cover and Form s Classification System (FLUCCS Code), 12 wetland community types were differentiated in the wetland assessment areas (Table 4-2). The most common wetland community types were 6410: Freshwater Marsh (n = 18) and 6210: Cypress (n = 13). In addition, 13 forested wetlands with mixed species composition were assessed, including five 6170: Mixed Wetland Hardwood, two 6172: Mixed Wetland Hardwoods Shrubs, and six 6300: Wetland Fore sted Mixed community types. Uniform Mitigation Assessment Method UMAM UMAM scores for the 58 wetland assessment areas ranged from a low of 0.47 at a hydric pine flatwoods at Big Cypress (BigC_FLA) to the hi gh of 0.93 at five wetland assessment areas: two freshwater marshes at Boran Ranch, Phase I (Bora_MAR_1 and Bora_MAR_2), one freshwater marsh at Hole in the Donut (HID_MAR_1), a salt water marsh at Little Pine Island (LPI_SLT_2), and a cypress wetland at Split Oa k (SplO_CYP) (Table 4-3). Re call that the scale of UMAM ranges from 0.00-1.00, with 1.00 representing the optimal or reference standard condition. Half of the wetland assessment areas had UMAM scores greater than or equal to 0.75 (n = 29), suggesting that these wetland assessment ar eas provide 75% or more wetland function. UMAM scores were based on an average of thr ee categories representing indicators of wetland function: Location and Landscape Support, Water Environment, and Comm unity Structure. These scores ranged from 4 to 9 for Locati on and Landscape Support, 5 to10 for Water Environment, and 4 to10 for Co mmunity Structure. While several wetland assessment areas scored 10 for both Water Environment (n = 7) and Community Structure (n = 2), no wetland assessment area scored 10 for the categor y of Location and Landscape Support. As with the other assessment methods, UMAM wa s not meant to be used as a comparison among wetland community types. As such, UMAM scor es have been summarized based on specific wetland community types using FLUCCS (Table 44). Averaging the UM AM scores by wetland community type shows that mean UMAM scor es ranged from 0.53-0.80, though these averages have large standard deviations showing a great d eal of variability in the function provided by the wetland assessment areas. The highest mean UMAM score for any wetland community type was 0.80 ( = 0.18) for 6420 Saltwater Marsh. The large standard deviation is based on the wide variability in the scores for the two saltwater marshes at Little Pi ne Island, as one represented the pre-restored condition at LPI_SLT_1 (UMAM = 0.67) and one the post-restored condition at LPI_SLT_2 (UMAM = 0.93). Perhaps in this case, the difference between the two scores is more telling than the mean, as the numbers impl y a functional lift of 0.26 may be attained by implementing the mitigation plan for Little Pine Island salt marshes. Similarly, at Everglades Mitigation Bank, freshwater marsh wetland assessm ent areas were sampled before (Phase II Glad_MAR_3) and after (Phase I Glad_MAR_1) mitigation activities were implemented. Again, the difference between the high UMAM score for the restored wetland assessment area of 0.83 and score of 0.60 at the pre-restoration wetland assessment area i ndicates the potential functional lift attainable from restoration activities.

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67 Table 4-3. Uniform Mitigation Assessmen t Method (UMAM) scores for 58 wetland assessment areas at 29 we tland mitigation banks. In addition to total UMAM score, scores are presented for each of the three UMAM scor ing categories: Location and Landscape Support, Water Environment, and Community Structure. Bank Name Site Code Location and Landscape Support Water Environment Community Structure UMAM Barberville Barb_CYP 8 7 8 0.77 Barb_MAR 8 8 7 0.77 Bear Point Bear_MAN 8 8 9 0.83 Big Cypress BigC_FLA 5 5 4 0.47 BigC_MAR_1 7 8 6 0.70 BigC_MAR_2 7 8 7 0.73 Bluefield Ranch Blue_BOT 7 8 6 0.70 Blue_FLA 8 9 8 0.83 Blue_MAR 8 7 7 0.73 Boran Ranch, Phase I Bora_MAR_1 9 10 9 0.93 Bora_MAR_2 9 10 9 0.93 CGW CGW_MAN 4 7 8 0.63 Colbert-Cameron CoCa_CYP_1 8 7 7 0.73 CoCa_CYP_2 8 9 8 0.83 CoCa_FOR 8 9 7 0.80 Corkscrew Cork_FLA 5 5 5 0.50 East Central ECFl_FOR 7 7 7 0.70 ECFl_HAM 9 8 6 0.77 Everglades Mitigation Bank/Phase I Glad_MAR_1 7 9 9 0.83 Glad_MAR_2 8 8 9 0.83 Glad_SHR 7 9 9 0.83 Everglades Mitigation Bank/Phase II Glad_MAR_3 5 7 6 0.60 Florida Mitigation Bank FLMB_FOR 8 7 5 0.67 Florida Wetlandsbank FLWt_MAR_1 4 9 9 0.73 FLWt_MAR_2 4 9 8 0.70 Garcon Peninsula Garc_FLA 6 7 5 0.60 Graham Swamp Grhm_FOR 4 7 7 0.60 Hole in the Donut HID_MAR_1 9 9 10 0.93 HID_MAR_2 8 9 8 0.83 Lake Louisa and Green Swamp Loui_SHR 8 6 5 0.63 Lake Monroe Monr_CYP 9 9 9 0.90 Monr_MAR 7 10 7 0.80 Little Pine Island LPI_MAR 8 10 8 0.87 LPI_SLT_1 8 7 5 0.67 LPI_SLT_2 8 10 10 0.93 Loblolly Mitigation Bank Lob_CYP_1 6 8 6 0.67 Lob_CYP_2 8 9 9 0.87

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68 Table 4-3. Continued. Bank Name Site Code Location and Landscape Support Water Environment Community Structure UMAM Loxahatchee Lox_CYP 5 7 5 0.57 Lox_FOR 6 9 5 0.67 Lox_SHR 6 7 7 0.67 Panther Island Pant_CYP_1 7 8 6 0.70 Pant_CYP_2 8 9 8 0.83 Pant_CYP_3 8 9 6 0.77 Pant_FOR 9 10 8 0.90 Reedy Creek Reed_BOT 6 5 6 0.57 Reed_FOR 7 9 7 0.77 R.G. Reserve RG_MAR 7 7 6 0.67 Split Oak SplO_CYP 9 10 9 0.93 SplO_MAR 8 6 7 0.70 Sundew Mitigation Bank Sun_FOR_1 6 8 6 0.67 Sun_FOR_2 7 9 7 0.77 TM-Econ TMEc_CYP_1 9 7 6 0.73 TMEc_CYP_2 9 8 9 0.87 Tosohatchee Toso_FOR 8 9 9 0.87 Toso_MAR 9 9 9 0.90 Toso_SHR 8 9 8 0.83 Tupelo Mitigation Bank Tup_FOR 7 6 6 0.63 Tup_PRA 6 5 5 0.53

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69 Table 4-4. Uniform Mitigation Assessment (U MAM) scores categorized by Florida Land Use, Cover and Forms Classification Sy stem (FLUCCS) wetland community type. In addition to total UMAM score, mean ( x ) scores and standard deviation ( ) are presented for each of the three UMAM indicators: Location a nd Landscape Support, Water Environment, and Community Structure. UMAM Category 6181: Cabbage Palm Hammock 6210: Cypress 6410: Freshwater Marsh 6250: Hydric Pine Flatwoods 6120: Mangrove Swamps 6310 & 6460: Mixed Scrub Shrub Wetland 6170: Mixed Wetland Hardwood 6172: Mixed Wetland Hardwoods Mixed Shrubs 6420: Saltwater Marshes 6150: Stream and Lake Swamps (Bottomland) 6430: Wet Prairie 6300: Wetland Forested Mixed Sample size n 1 13 18 4 2 2 5 2 2 2 1 6 x 9.0 7.8 7.3 6.0 6.0 8.0 6.6 6.5 8.0 6.5 6.0 7.3 Location and Landscape Support na 1.2 1.6 1.4 2.8 0.0 1.7 0.7 0.0 0.7 na 1.0 x 8.0 8.2 8.5 6.5 7.5 7.5 8.6 8.0 8.5 6.5 5.0 7.8 Water Environment na 1.0 1.2 1.9 0.7 2.1 0.9 1.4 2.1 2.1 na 1.5 x 6.0 7.4 7.8 5.5 8.5 6.5 7.0 8.0 7.5 6.0 5.0 6.5 Community Structure na 1.4 1.2 1.7 0.7 2.1 1.4 1.4 3.5 0.0 na 1.0 x 0.77 0.78 0.79 0.60 0.73 0.73 0.74 0.75 0.80 0.64 0.53 0.72 UMAM na 0.10 0.10 0.16 0.14 0.14 0.11 0.11 0.18 0.09 na 0.10

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70 UMAM scores reflect current condition of th e assessment areas and do not indicate the beginning condition of the assessment area, nor the anticipated amount of ecological lift attributed to the mitigation plan, nor the overall status of the bank in accordance with the permitted plan. The degree of ecological improvement, or lift, in a bank determines the number of potential credits awarded and integrates changes from the beginning condition and the anticipated condition of the bank. Lift has been defined as the number of potential credits awarded per acre. Mean lift was 0.38 ( = 0.20), with a range from 0.05 (at R.G. Reserve, which had minor enhancement) to 0.88 (at Florida Wetla nds Bank, with mostly restoration). When Hole-in-the-Donut was included, the mean lift was slightly higher at 0.40 ( = 0.23), as Hole-inthe-Donut more closely resembles an in-lieu-fee bank, and has been awarded 1 credit per acre of restoration. Each data point on Figure 4-3 represents a we tland assessment area, with the UMAM score for the wetland assessment area on the y-axis (vertical) and lift or potential credits released for the entire mitigation bank on the xaxis (horizontal). No correlation was found between UMAM scores, lift, or potentia l credits released (Figure 4-3).

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71 (A) 0.0 0.2 0.4 0.6 0.8 1.0 0.00.20.40.60.81.0 Permitted Lift (credits/ac)UMAM (B) 0.0 0.2 0.4 0.6 0.8 1.0 020406080100 Potential Credit Released (%)UMAM <25% >=25, <50% >=50, <75% >75% Percent of Potential Credits Released Figure 4-3. Uniform Mitigation Assessment Me thod (UMAM) scores for the 58 assessment areas in relation to A) permit ted lift (credits/ac) in respectiv e bank and B) potential credits released (%) at respective bank.

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72 WRAP: Wetland Rapid Assessment Procedure The WRAP scale ranges from 0.001.00, with 1.00 representing the reference standard condition. WRAP has six scoring categories, each with scores ranging fr om 0.0-3.0, in 0.5 increments, and a score of 3.0 represents an intact wetland. For herbaceous wetland systems, the category of Wetland Canopy (O/S) is generally not scored; however, if the wetland assessment area had 20% or greater overstory and/or shrub canopy, a score was assigned (Miller an d Gunsalus 1999). This was the case at three of 18 wetland assessmen t areas with a wetland community type of 6410: Freshwater Marsh. A freshwater marsh at Boran Ranch, Phase I (Bora_MAR_1) received a 0.99, the highest WRAP score (Table 4-5). This wetland assessment area also r eceived the highest UMAM score of 0.93. At the other extreme, a hydric pine flatwoods at Corkscrew (Cork_FLA) received the lowest WRAP score of 0.47 (Table 4-5). No wetland assessment area receiv ed a 0.0 score in any of the six scoring categories. However, nine scores of 0.5 were assigne d for the categories of Wetland Canopy (O/S) (n = 2), Wetland Ground Cover (GC) (n = 3), Habitat Support/Buffer (n = 3), and Water Quality Input & Treatment (WQ) (n = 1). Thirty-two wetland assessment areas had WRAP scores greater than or equal to 0.75. Comparison of mean WRAP scores within FL UCCS wetland community types shows a wide variability in scores ranging from x = 0.57 ( = 0.18) for 6250 Hydric Pine Flatwoods (n = 4) to x = 0.82 ( = 0.13) for 6210 Cypress (n = 13) (Table 4-6). The highest va riability of WRAP scores within a wetland community type wa s for 6420 Saltwater Mars hes for two wetland assessment areas within Little Pine Island mitig ation bank; the same wetland assessment areas discussed earlier for UMAM. The scores ranged from 0.49 at the pre-restoration saltwater marsh (LPI_SLT_1) to 0.92 at the restor ed saltwater marsh (LPI_SLT_2). At the other extreme, the wetland community type with the smallest va riability in WRAP scores was 6120 Mangrove Swamps ( x = 0.74, = 0.02). Both of the 6120 Mangrove Swamps assessment areas at Bear Point (Bear_MAN) and CGW (CGW_MAN) scor ed 3.0 in the category of Wetland Canopy (O/S). However, total WRAP scores were lower than the optimal 1.00 score at these sites due to the influence of adjacent development, whic h generally provided p oor habitat support and buffers, limited wildlife utiliza tion, and adversely influenced we tland hydrology. As noted in the UMAM section above, assessment area scores reflect current condition at the time of site visits. No correlation was found between WRAP scores, lift, or potential credits released (Figure 4-4).

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73 Table 4-5. Wetland Rapid Assessment Pr ocedure (WRAP) scores for 58 wetland assessment areas. In addition to total WRAP score, sc ores are presented for each of the six WRAP scoring categories: Wildlife U tilization, Wetland Canopy, Wetland Ground Cover, Habitat Support/Buffer, Field Hydrology, and Water Quality Input & Treatment. Bank Name Site Code Wildlife Utilization (WU) Wetland Canopy (O/S) Wetland Ground Cover (GC) Habitat Support/Buffer Field Hydrology (HYD) WQ Input & Treatment (WQ) WRAP Barberville Barb_CYP 2.5 2.5 2.5 2.5 2.5 2.8 0.85 Barb_MAR 2.5 na 2.0 2.5 2.5 2.5 0.80 Bear Point Bear_MAN 2.5 3.0 na 2.5 2.0 1.3 0.75 Big Cypress BigC_FLA 1.5 1.0 0.5 1.4 2.0 2.5 0.49 BigC_MAR_1 2.0 2.0 2.0 2.4 3.0 3.0 0.80 BigC_MAR_2 2.0 2.5 2.0 2.1 2.5 3.0 0.78 Bluefield Ranch Blue_BOT 2.0 1.5 2.0 2.3 2.5 1.7 0.67 Blue_FLA 2.5 2.5 3.0 2.4 3.0 1.6 0.83 Blue_MAR 2.0 na 2.0 2.5 2.5 3.0 0.80 Boran Ranch, Phase I Bora_MAR_1 3.0 na 3.0 3.0 3.0 2.9 0.99 Bora_MAR_2 3.0 na 2.5 2.5 3.0 2.9 0.93 CGW CGW_MAN 2.0 3.0 3.0 1.5 2.0 1.5 0.72 Colbert-Cameron CoCa_FOR 2.5 2.0 2.5 2.5 3.0 3.0 0.86 CoCa_CYP_1 2.0 2.0 3.0 2.5 2.0 3.0 0.81 CoCa_CYP_2 2.5 2.5 2.5 2.5 3.0 3.0 0.89 Corkscrew Cork_FLA 1.5 na 0.5 1.6 2.0 1.5 0.47 East Central ECFl_FOR 2.0 2.0 0.5 2.0 2.0 3.0 0.64 ECFl_HAM 2.0 2.0 2.5 2.0 2.5 3.0 0.78 Everglades Mitigation Bank/Phase I Glad_MAR_1 2.5 na 3.0 1.6 2.5 2.1 0.78 Glad_MAR_2 2.5 3.0 2.5 2.0 2.0 2.4 0.80 Glad_SHR 3.0 2.5 3.0 2.5 2.5 3.0 0.92 Everglades Mitigation Bank/Phase II Glad_MAR_3 1.5 na 2.0 1.5 2.0 2.8 0.65 Florida Mitigation Bank FLMB_FOR 2.5 1.5 2.0 1.8 2.0 0.9 0.59 Florida Wetlandsbank FLWt_MAR_1 1.5 na 2.0 0.5 2.5 1.8 0.55 FLWt_MAR_2 1.5 na 1.5 0.5 2.5 1.8 0.52 Garcon Peninsula Garc_FLA 1.5 0.5 1.0 1.9 2.0 1.8 0.48 Graham Swamp Grhm_FOR 2.5 2.5 2.0 1.3 2.0 1.9 0.68 Hole in the Donut HID_MAR_1 3.0 na 3.0 2.6 3.0 2.5 0.94 HID_MAR_2 3.0 na 2.5 2.0 2.0 2.0 0.77 Lake Louisa and Green Swamp Loui_SHR 2.0 1.0 2.0 2.0 1.0 2.8 0.60 Lake Monroe Monr_CYP 3.0 2.0 3.0 2.5 2.0 3.0 0.86 Monr_MAR 2.0 na 2.0 2.0 3.0 2.5 0.77 Little Pine Island LPI_MAR 2.5 na 2.5 3.0 3.0 3.0 0.93 LPI_SLT_1 2.0 0.5 1.0 1.5 1.5 2.4 0.49 LPI_SLT_2 2.5 3.0 3.0 2.5 3.0 2.5 0.92

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74 Table 4-5. Continued. Bank Name Site Code Wildlife Utilization (WU) Wetland Canopy (O/S) Wetland Ground Cover (GC) Habitat Support/Buffer Field Hydrology (HYD) WQ Input & Treatment (WQ) WRAP Loblolly Mitigation Bank Lob_CYP_1 2.0 2.0 2.0 2.5 2.0 1.0 0.64 Lob_CYP_2 2.5 3.0 2.5 2.5 2.5 3.0 0.89 Loxahatchee Lox_ CYP 1.5 1.5 1.0 1.5 1.5 1.9 0.49 Lox_ FOR 1.5 2.0 2.0 0.5 2.0 1.3 0.52 Lox_SHR 1.5 2.5 2.5 1.0 2.0 1.4 0.60 Panther Island Pant_CYP_1 3.0 3.0 1.5 2.5 2.5 2.8 0.85 Pant_CYP_2 2.5 3.0 2.5 2.5 3.0 3.0 0.92 Pant_CYP_3 2.5 3.0 1.5 2.5 2.5 2.8 0.82 Pant_FOR 3.0 3.0 2.0 2.5 3.0 2.0 0.86 Reedy Creek Reed_BOT 2.0 1.5 1.5 2.1 2.0 2.2 0.63 Reed_FOR 2.0 2.0 2.0 1.5 3.0 0.5 0.61 R.G. Reserve RG_MAR 2.0 na 2.0 1.8 2.0 2.8 0.71 Split Oak SplO_CYP 3.0 3.0 2.5 3.0 3.0 3.0 0.97 SplO_MAR 2.0 na 2.0 2.4 1.5 3.0 0.73 Sundew Mitigation Bank Sun_FOR_1 2.0 2.0 1.5 2.0 2.5 1.6 0.65 Sun_FOR_2 2.0 2.0 3.0 2.0 2.5 1.6 0.73 TM-Econ TMEc_CYP_1 2.5 1.5 1.5 2.8 2.0 2.7 0.72 TMEc_CYP_2 3.0 3.0 2.5 3.0 2.5 2.9 0.93 Tosohatchee Toso_FOR 2.5 3.0 2.0 2.5 2.5 2.8 0.85 Toso_MAR 3.0 na 3.0 2.0 3.0 3.0 0.93 Toso_SHR 2.5 3.0 2.0 2.5 3.0 3.0 0.89 Tupelo Mitigation Bank Tup_FOR 2.5 2.0 2.5 2.3 1.5 2.1 0.70 Tup_PRA 1.5 1.5 1.5 2.2 1.5 2.5 0.59

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75 Table 4-6. Wetland Rapid Assessment Proce dure (WRAP) scores categorized by Florida Land Use, Cover and Forms Classification System (FLUCCS) wetland community type. Values for each wetland comm unity type include mean ( x ) and standard deviation ( ). WRAP Category 6181: Cabbage Palm Hammock 6210: Cypress 6410: Freshwater Marsh 6250: Hydric Pine Flatwoods 6120: Mangrove Swamps 6310 & 6460: Mixed Scrub Shrub Wetland 6170: Mixed Wetland Hardwood 6172: Mixed Wetland Hardwoods Mixed Shrubs 6420: Saltwater Marshes 6150: Stream and Lake Swamps (Bottomland) 6430: Wet Prairie 6300: Wetland Forested Mixed Sample size n 1 13 18 4 2 2 5 2 2 2 1 6 2.0 2.5 2.3 1.8 2.3 2.3 2.2 2.3 2.3 2.0 1.5 2.3 Wildlife Utilization (WU) na 0.5 0.5 0.5 0.4 0.4 0.4 1.1 0.4 0.0 na 0.4 2.0 2.5 2.5 1.3 3.0 2.0 2.3 2.5 1.8 1.5 1.5 2.1 Wetland Canopy (O/S) na 0.6 0.5 1.0 0.0 1.4 0.4 0.0 1.8 0.0 na 0.5 2.5 2.2 2.3 1.3 3.0 2.0 2.1 2.8 2.0 1.8 1.5 1.9 Wetland Ground Cover (GC) na 0.6 0.5 1.2 na 0.0 0.2 0.4 1.4 0.4 na 0.9 2.0 2.5 2.1 1.8 2.0 2.3 1.7 1.8 2.0 2.2 2.2 2.1 Habitat Support/Buffer na 0.4 0.7 0.4 0.7 0.4 0.9 1.1 0.7 0.1 na 0.3 2.5 2.4 2.5 2.3 2.0 2.0 2.5 2.3 2.3 2.3 1.5 2.3 Field Hydrology (HYD) na 0.5 0.5 0.5 0.0 1.4 0.5 0.4 1.1 0.4 na 0.5 3.0 2.7 2.6 1.9 1.4 2.9 1.9 2.2 2.5 2.0 2.5 1.9 WQ Input & Treatment (WQ) na 0.6 0.4 0.5 0.1 0.1 1.0 1.1 0.1 0.4 na 0.7 0.78 0.82 0.79 0.57 0.74 0.75 0.70 0.76 0.71 0.65 0.59 0.70 WRAP na 0.13 0.13 0.18 0.02 0.21 0.15 0.23 0.30 0.03 na 0.09 x x x x x x x

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76 (A) 0.0 0.2 0.4 0.6 0.8 1.0 0.00.20.40.60.81.0 Permitted Lift (credits/ac)WRAP (B) 0.0 0.2 0.4 0.6 0.8 1.0 020406080100 Potential Credit Released (%)WRAP <25% >=25, <50% >=50, <75% >75%Percent of Potential Credits Released Figure 4-4. Wetland Rapid Assessment Proc edure (WRAP) scores for the 58 assessment areas in relation to A) permitted lift (credits/ ac) in respective bank and B) potential credits released (%) at respective bank.

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77 HGM: Hydrogeomorphic Wetland Assessment Method The Hydrogeomorphic wetland assessment method ( HGM) was conducted at six flats wetlands in the Everglades and nine depressional wetlands in peninsular Florida. Flats wetlands in the Everglades HGM assessment for flats wetlands in the Everglades was divided into three subclasses of flats wetlands: marl, organic, and roc ky flats. These wetland subclasse s were distinguished based on geology, geomorphic setting, climate, soils, water source, hydrodynamics, and biota. A spatial distribution of flats wetlands in the Everglades was presented by Noble et al. (2002, see Figure 2, page 14). While the three subclasses were di stinguished primarily on soil differences and hydrology, they share similarities in wetland f unctions including unidirectional surface water flow, poorly drained soils, flat terrain, and surficial aquifer inte ractions (Noble et al. 2002). An overview of the variables used in HGM functiona l capacity index calculati ons and the functional capacity index scores for all three subclasses of fl ats wetlands in the Everglades is presented in Tables 4-7 and 4-8, respectively. Of the 12 vari ables described for func tional capacity index calculations in flats wetlands in the Everglad es, 10, 9, and 11 variables were used for marl, organic, and rocky flats wetlands respectively (Table 4-7). The two marl flats wetlands sampled were locate d in Everglades Mitigation Bank: Glad_MAR_1 in Phase I, where mitigation activities had been completed at the time of the site visit, and Glad_MAR_3 in Phase II, where no mitigation activ ities had been completed at the time of the site visit. For the marl flats wetlands in the restored wetland tract (G lad_MAR_1), 9 of the 10 variables achieved a perfect score of 1.00, wher e 1.00 reflects the reference standard condition. The only variable not receivi ng a perfect 1.00 was Emergent Macrophytic Vegetation Cover (MAC), with a score of 0.68. The marl flat s wetland in the non -restored wetland tract (Glad_MAR_3) also received high variable scores with 8 of 10 variables receiving 1.00. This wetland also received lower scores for MAC (0.40) and for Habitat Connections (CONNECT) (0.85). The two organic flats wetlands were both located within Flor ida Wetlandsbank. The variable scores for these wetlands were lower, with FLWt_MAR_1 receiving 3 (of 9) scores of 1.00 and FLWt_MAR_2 receiving 4 (of 9) scores of 1.00, where 1.00 reflec ts the reference standard condition. Both wetlands received scores of 0.00 for the variable Mi crotopographic Features (MICRO), as these wetlands had previously been rock plowed for farming and then were regraded as part of the restor ation plan to match the modele d hydrology. These wetlands also received scores less than 1.00 for Plant Spec ies Composition (COMP), Habitat Connections (CONNECT), Interior Core Area (CORE), and Wetland Tract Area (TRACT), as Florida Wetlandsbank was located in urban Broward C ounty with predominantly residential and transportation land uses in the supporting land scape. FLWt_MAR_1 also received a 0.90 score for Cover of Woody Vegetation (WOODY). The two rocky flats wetlands within Hole in th e Donut included the we tland re-graded in 1989 (HID_MAR_1) receiving 7 (of 11) scores of 1.00 and the wetland re-grade d in 2001 receiving 8 (of 11) scores of 1.00, where 1.00 reflects the reference standard condition. The younger

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Table 4-7. Hydrogeomorphic wetland assessment method ( HGM) variable for flats wetlands in the Everglades. Combinations of these 12 variables were used to calculat e wetland function scores in Table 4-8 according to equati ons from Noble et al. (200 2). MARL FLATS: ORGANIC FLATS: ROCKY FLATS: Everglades Mitigation Bank Florid a Wetlandsbank Hole in the Donut Phase I Phase II Variable Code Glad_MAR_1 Glad_MAR_3 FLWt_MAR_1 FLWt_MAR_2 HID_MAR_1 HID_MAR_2 Plant Species Composition COMP 1.00 1.00 0.76 0.55 na na Habitat Connections CONNECT 1.00 0.85 0.10 0.10 1.00 1.00 Interior Core Area CORE 1.00 1.00 0.38 0.38 1.00 1.00 Invasive Vegetation INVASIVE 1.00 1.00 1.00 1.00 1.00 1.00 Emergent Macrophytic Vegetation Cover MAC 0.68 0.40 1.00 1.00 0.65 1.00 Microtopographic Features MICRO 1.00 1.00 0.00 0.00 0.00 0.00 Number of Native Wetland Species NATIVE na na na na 1.00 1.00 Periphyton Cover PERI 1.00 1.00 na na 0.73 1.00 Soil Thickness SOILTHICK na na na na 0.70 0.20 Surface Soil Texture SURTEX 1.00 1.00 1.00 1.00 1.00 0.70 Wetland Tract Area TRACT 1.00 1.00 0.03 0.03 1.00 1.00 Cover of Woody Vegetation WOODY 1.00 1.00 0.90 1.00 1.00 1.00

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Table 4-8. Hydrogeomorphic wetland assessment method (HGM) fu nctional capacity index sco res (Function) for six flats wetlands in the Everglades. Variables in Table 4-7 were used to calculate f unctional capacity index scores according to equations from Noble et al. (2002). MARL FLATS: ORGANIC FLATS: ROCKY FLATS: Everglades Mitigation Bank Florid a Wetlands Bank Hole in the Donut Phase I Phase II Function Glad_MAR_1 Glad_MAR_3 FLWt_MAR_1 FLWt_MAR_2 HID_MAR_1 HID_MAR_2 Surface and Subsurface Water Stor age 1.00 1.00 0. 63 0.67 0.64 0.48 Cycle Nutrients 0.95 0.90 0.69 0.64 0.65 0.68 Characteristic Plant Community 0.98 0.96 0.66 0.62 0.72 0.59 Wildlife Habitat 0.96 0.90 0.56 0.53 0.81 0.81

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80 wetland (HID_MAR_2), re-graded in 2001, receiv ed scores less than 1.00 for MICRO, Soil Thickness (SOILTHICK), and Soil Surface Texture (SURTEX). Whereas, the older rocky flats wetland (HID_MAR_1), re-graded in 1989, received scores less than 1.00 for MICRO, MAC, SOILTHICK, and Periphyton Cover (PERI). When the variables presented in Table 4-7 were used to calculate the f unctional capacity index scores for the flats wetlands (Table 4-8), tw o wetlands, both at Everglades Mitigation Bank, received the highest score of 1.00 for the Su rface and Subsurface Water Storage function at Phase I (Glad_MAR_1) and Phase II (Glad_MAR_3) wetlands. The remainder of the functional capacity index scores between 0.48 and 0.98. While HGM is not designed to provide one singl e overall score of wetland function, Story et al. (1998) suggest several ways HGM could be used while establishing a single value of function. For example, averaging the four functional capac ity index scores would result in a range of scores from 0.62 at Florida Wetlandsbank (FLWt_MAR_2) to 0.97 at Everglades Mitigation Bank Phase I (Glad_MAR_1). Depressional wetlands in peninsular Florida Nine wetlands belonging to both subclasses of de pressional wetlands in pe ninsular Florida were sampled (n = 6 herbaceous marsh depressional we tlands, n = 3 cypress domes). Noble et al. (2004) described the differences in these two su bclasses mainly on visual distinction based on woody vegetation and a longer hydroperiod for cypr ess domes. The depressional wetlands HGM model had 10 variables for herbaceous marsh de pressional wetlands and 12 variables for cypress domes. All nine depressional wetlands received the maximum score of 1.00 for the variable Upland Land Use (UPUSE) (Table 4-9). Further, eigh t of nine depressional wetlands received 1.00 scores for Surface Outlet (SUROUT) and Wetla nd Volume (WETVOL), as most of these wetlands had little to no excavation or disturba nce in their interior. The exceptions were the herbaceous marsh depressional wetlands at Split Oak (SplO_MAR, SUROUT = 0.78) and Barberville (Barb_MAR, WT EVOL = 0.92), respectively. Among the herbaceous marsh depressional we tlands, the wetland asse ssment area at Lake Monroe (Monr_MAR) received a 1.00 score for 9 (o f 10) variables and received a 0.98 score for the tenth variable (MAC). Similarly, the cypr ess dome at Lake Monroe received the highest number of 1.00 variable scores for 9 (of 12) va riables. The remainder of the wetland assessment areas received between three to seven scores of 1.00 for HGM variables. The herbaceous marsh depressional wetland at Split Oak (SplO_MAR) received the lowest number of 1.00 scores for variables with 3 (of 10). When the variables were used to calculate functi onal capacity index scores for herbaceous marsh depressional wetland functions, sc ores ranged from 0.53 for Characteristic Plant Community at Split Oak (SplO_MAR) to 1.00 for Surface Wate r Storage at three wetland assessment areas including Bluefield Ranch (Blue_MAR), Lake Monroe (Monr_MAR), and R.G. Reserve (RG_MAR), and Subsurface Water Storage at one wetland at Lake Monroe (Monr_MAR) (Table 4-10). When attempting to compress HGM functional capacity indices into a single value for

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Table 4-9. Hydrogeomorphic wetland assessment method (HGM) va riable for depressional wetl ands in peninsular Florida. Combinations of these 14 variables were used to calculate wetla nd function scores in Table 4-10 ac cording to equations from Nob le et al. (2004). Herbaceous Marsh Depressional Wetlands Cypress Domes Barberville Bluefield Ranch Boran Ranch, Phase I Lake Monroe R.G. Reserve Split Oak Lake Monroe Panther Island Reedy Creek Variable Code Barb_MAR Blue_MAR Bora_MAR_1 Monr_MAR RG_MAR SplO_MAR Monr_CYP Pant_CYP_1 Reed_FOR Cypress Canopy CANOPY na na na na na na 1.00 1.00 0.40 Change in Catchment Size CATCH 0.75 1.00 0.93 1.00 1.00 0.85 0.50 0.12 1.00 Herbaceous Plant Species Composition HCOMP 0.50 0.33 0.50 1.00 0.67 0.25 na na na Macrophytic Vegetation Cover MAC 0.95 1.00 0.95 0.98 0.50 0.87 na na na Understory Vegetation Biomass SSD na na na na na na 0.88 0.90 0.08 Subsurface Outlet SUBOUT 1.00 1.00 1.00 1.00 0.15 0.00 1.00 1.00 1.00 Surface Outlet SUROUT 1.00 1.00 1.00 1.00 1.00 0. 78 1.00 1.00 1.00 Surface Soil Texture SURTEX 1.00 0.90 1.00 1.00 1.00 1.00 1.00 1.00 0.70 Tree Basal Area TBA na na na na na na 0.20 0.37 1.00 Tree Species Composition TCOMP na na na na na na 1.00 0.90 0.20 Upland Land Use UPUSE 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 Wetland Proximity WETPROX 0.99 0.70 1.00 1.00 1.00 0.10 1.00 0.10 0.82 Wetland Volume WETVOL 0.92 1.00 1.00 1.00 1.00 1.00 1.00 1.00 1.00 Change in the Number of Wetland Zones ZONES 0.50 0.25 0.50 1.00 0.25 0.50 1.00 1.00 0.50

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Table 4-10. Hydrogeomorphic wetland assessment method (HGM) functional capacity index sc ores (Function) for nine depressional wetlands in peninsular Florida. Variables in Table 4-9 were used to calculate functional capacity index scores according to equations from Noble et al. (2004). Herbaceous Marsh Depressional Wetlands Cypress Domes Barberville Bluefield Ranch Boran Ranch, Phase I Lake Monroe R.G. Reserve Split Oak Lake Monroe Panther Island Reedy Creek Function Barb_MAR Blue_MAR Bora_MAR_1 Monr_MAR RG_MAR SplO_MAR Monr_CYP Pant_CYP_1 Reed_FOR Surface Water Storage 0.93 1.00 0.99 1.00 1.00 0.92 0.94 0.88 0.92 Subsurface Water Storage 0.94 0.98 0.98 1.00 0.79 0.71 0.88 0.78 0.93 Cycle Nutrients 0.96 0.97 0.98 0.99 0.83 0.92 0.79 0.78 0.75 Characteristic Plant Community 0.85 0.79 0.85 0.99 0.58 0.53 0.88 0.88 0.31 Wildlife Habitat 0.87 0.76 0.87 0.99 0.69 0.56 0.93 0.82 0.61

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83 herbaceous marsh depressional wetland functions there was a large range when considering the mean (0.73-0.99), the maximum (0.92-1.00), or the minimum (0.53-0.99). Selection of any of these methods has strong impact on the overall assessment of wetland condition. In general, cypress dome wetland assessment areas scored lower than the marsh assessment areas with an overall range from 0.31 for Characteristic Plant Community at Reedy Creek (Reed_FOR) to 0.94 for Surface Water Storage at Lake Monroe (Monr_CYP) (Table 4-10). Scores for the functional capacity index category of Cycle Nutrie nts had a narrow range for all three cypress domes, with scores of 0.75, 0.78, and 0.79, at Reedy Creek (Reed_FOR), Panther Island (Pant_CYP_1), and Lake Monroe (MONR_ CYP), respectively. Once more, for cypress domes, selecting a single valu e to describe HGM would presen t a large range in scores for wetland mean ( x = 0.70-0.88), maximum (max = 0.88-0.94) or minimum (min = 0.31-0.79) functional capacity index scores. FWCI: Florida Wetland Condition Index The Florida Wetland Condition Index (FWCI) is an index of biological integrity with similar community-specific metrics for depressional herbaceous wetlands (Lane et al. 2003), depressional forested wetlands (Reiss and Br own 2005a), and forested strand and floodplain wetlands (Reiss and Brown 2005b). All three wetland classes have a FWCI developed for the macrophyte assemblage. In addition, an FWCI fo r diatom and macroinvertebrate assemblages has been developed for depressional herbaceous a nd depressional forested wetlands. This study includes macrophyte FWCI assessments for si x depressional herbaceous wetlands, three depressional forested wetlands, and one forested strand wetland. As well, macroinvertebrate FWCI assessments were completed at two depressional herbaceous wetlands and two depressional forested wetlands. Macroinvertebrate samples were not collected at the remaining six depressional wetlands, as th ese wetland assessment areas did not have a minimum of 10 cm of standing water throughout a minimum of half the wetland area, which is the minimum requirement for application of the macroinvertebrate FWCI. Macrophyte FWCI The depressional herbaceous wetland macrophyte FW CI included five metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 3) Percent of species exotic to the state of Florida (Exotic); 4) Ratio of annual to perennial species (A:P Ratio); and 5) Mean Coefficient of Conservation score based on the Floristic Quality Assessment Index (Average CC; Cohen et al. 2004). Each metric wa s assigned a score of 0, 3, 7, or 10 with total possible FWCI scores ranging from 0-50, with 50 re presenting the reference standard condition. Metric scores included two 0 scores for the Sensitive metric at Boran Ranch, Phase I (Bora_MAR_1) and for the A:P Ratio metric at Lake Monroe (Monr_MAR) (Table 4-11). The most common metric score was 3 (n = 14), followed by 7 (n = 9). Five metric scores of 10 were assigned for Sensitive and for A: P Ratio at Barberville (Barb_MAR) and for Sensitive, Exotic, and Average CC at R.G. Reserve (RG_MAR). To tal FWCI scores ranged from 12 (of 50) at Boran Ranch, Phase I (Bora_MAR_1) to 41 (of 50) at Barberville (Barb_MAR) with a mean of 26 ( = 12), translating into 24-82% of reference standard condition ( x = 52%, = 24%).

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84 Table 4-11. Macrophyte Florida Wetland Condi tion Index (FWCI) me tric scores, total FWCI scores, and percent of reference condition for six depressional herbaceous wetlands. Wetland region from Lane (2000). Bank Name Barberville Bluefield Ranch Boran Ranch, Phase I Lake Monroe R.G. Reserve Split Oak Site Code Barb_MAR Blue_MAR Bora_MAR_1 Monr_MAR RG_MAR SplO_MAR Region Central Central Central Central South Central Sensitive 10 7 0 7 10 7 Tolerant 7 3 3 3 7 3 Exotic 7 3 3 3 10 7 A:P Ratio 10 7 3 0 3 3 Average CC 7 3 3 3 10 3 FWCI 41 23 12 16 40 23 out of 50 50 50 50 50 50 % of Reference Condition 82% 46% 24% 32% 80% 46% The depressional forested wetland FWCI included si x metrics: 1) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 2) Percent of sensitive indicator species as determined from a refe rence dataset (Sensitive ); 3) Percent of species exotic to the state of Florida (Exotic); 4) Floristic Quality Assessment Index score (FQAI Score); 5) Percent of species that are both native and perennial (Native Perennial); and 5) Percent of species that are either facultative wetland or obligate species (W etland Status). For the depressional forested wetlands scoring for individua l FWCI metrics was on a con tinuous scale from 0.0-10.0, with 10.0 representing the reference standard conditio n. FWCI metric scores had a mean of 5.5 ( = 3.2) with scores assigned at both extremes, with a 0.0 for the Sensitive me tric at Panther Island (Pant_CYP_1) and a 10.0 for the Tolerant metric at Lake Monroe (Monr_CYP) (Table 4-12). Total FWCI scores ranged from 12.8 (of 60) at Panther Island to 48.3 (of 60) at Lake Monroe ( x = 33.2, = 18.3), translating into 21-81% of the reference standard condition ( x = 55%, = 31%). Five metrics were included in the forested strand and floodplain FWCI: 1)Proportion of tolerant indicator species (Tolerant); 2) Proportion of sensitive indicator species (Sensitive); 3) Floristic Quality Assessment Index score (FQAI Score); 4) Proportion of specie s exotic to Florida (Exotic); and 5) Proporti on of species that are both native a nd perennial (Nativ e Perennial). Scoring for each metric was based on a conti nuous scale from 0.0-10.0, with 10.0 representing the reference standard condition. Only the wetland assessment area at TM-Econ (TMEc_CYP_2) was included in the forested strand and floodpl ain FWCI calculations, with a range of metric scores from 7.5 for the FQAI Score metric to 9.1 for the Sensitive metric ( x = 8.3, = 0.7) (Table 4-13). The total FWCI for the wetland asse ssment area (TMEc_CYP_2) was 41.7 (of 50), translating into 83% of the reference standard condition.

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85 Table 4-12. Macrophyte Florida Wetland Condi tion Index (FWCI) me tric scores, total FWCI scores, and percent of reference condition for three depressional forested wetlands. Wetland region from Lane (2000). Bank Name Lake Monroe Panther Island Reedy Creek Site Code Monr_CYP Pant_CYP_1 Reed_FOR Region Central South Central Tolerant 10.0 3.5 9.8 Sensitive 6.6 0.0 1.5 Exotic 8.1 2.3 6.3 FQAI Score 8.9 0.5 4.6 Native Perennial 8.0 2.3 8.1 Wetland Status 6.7 4.3 8.2 FWCI 48.3 12.8 38.5 out of 60 60 60 % of Reference Condition 81% 21% 64% Table 4-13. Macrophyte Florida Wetland Condi tion Index (FWCI) me tric scores, total FWCI score, and percent of reference condition for a forested strand wetland within TMEcon Mitigation Bank. Wetland region from Lane (2000). Bank Name TM-Econ Site Code TMEc_CYP_1 Region Central Tolerant 7.9 Sensitive 9.1 FQAI Score 7.5 Exotic 8.2 Native Perennial 9.0 FWCI 41.7 out of 50 % of Reference Condition 83%

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86 Macroinvertebrate FWCI The depressional herbaceous wetland macroinverteb rate FWCI included five metrics: 1) Percent of sensitive indicator species as determined from a reference dataset (Sensitive); 2) Percent of tolerant indicator species as determined from a reference dataset (Tolerant); 3) Percent of macroinvertebrates in the pred ator functional feeding group (P redators); 4) Percent of macroinvertebrates in the order Odonata, which includes dragonflies and damselflies (Odonata); and 5) Percent of macroinvertebra tes in the subfamily Orthocladinae, a subfamily in the family Chironomidae (Orthocladinae). Scoring for the depressional herbaceous wetland macroinvertebrate FWCI assigned scores of 0, 3, 7, or 10 to each of the five metrics with total possible FWCI scores ranging from 0-50, with 50 re presenting the reference standard condition. Only two wetland assessment areas were sampled, with a majority of the metric scores (6 of 10) assigned scores of 10 (Table 4-14) One metric was scored a 0 fo r the Odonata metric at Boran Ranch, Phase I (Bora_MAR_1). The remaining th ree metric scores were 7 for the Tolerant metric at Barberville (Barb_MAR) and the Sens itive and Predators metrics at Boran Ranch, Phase I (Bora_MAR_1). Total FWCI scores were 34 (of 50) at Boran Ranch, Phase I (Bora_MAR_1) and 47 (of 50) at Barberville (B arb_MAR), reflecting 68% and 94% of reference standard condition, respectively. Six metrics were included in the depressiona l forested wetland macroinvertebrate FWCI: 1) Percent of sensitive indicator species as determ ined from a reference dataset (Sensitive); 2) Percent of tolerant indicator sp ecies as determined from a reference dataset (Tolerant); 3) Calculated score from the Flor ida Index (Florida Index; see Beck 1954, Barbour et al. 1996); 4) Percent of macroinvertebrates in the phylum Mollu sca, including snails and bivalves (Mollusca) 5) Percent of macroinvertebrates in the family Noteridae, the burrowing water beetles (Noteridae); and 6) Percent of macroinvertebrates in the scraper functional feeding group (Scrapers). Each metric was sc ored between 0-10, with 10 representing th e reference standard condition. Metric scores were summed for a final index ranging from 0-60, with 60 representing the reference standard condition. Two wetland assessment areas were assessed using the depressional forested wetland macroinvertebrate FW CI (Table 4-15). The lowest metric score was 0.0 for the Scrapers metric for the wetland as sessment area at Panther Island (Pant_CYP_1). This wetland assessment area also received a scor e of 0.1 for the Florida Index metric. Four of the metrics scored above 5.0, the midpoint of the scale, including the Tole rant metric (6.1) for the wetland assessment area at Panther Island (Pant_CYP_1) and the Tolerant (7.1), Florida Index (6.5), and Mollusca (5.2) metrics for the wetland assessment area at Reedy Creek (Reed_FOR). Total FWCI scores reflected less than 50% of the reference standard condition, with a 15.3 (of 60) at Panther Island (Pan t_CYP_1) and 27.1 (of 60) at Reedy Creek.

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87 Table 4-14. Macroinvertebrate Florida Wetla nd Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference co ndition for two depressional herbaceous wetlands. Wetland region from Lane (2000). Bank Name Barberville Boran Ranch, Phase I Site Code Barb_MAR Bora_MAR_1 Region (Lane 2000) Central Central Sensitive 10 7 Tolerant 7 10 Predators 10 7 Odonata 10 0 Orthocladinae 10 10 FWCI 47 34 out of 50 50 % of Reference Condition 94% 68% Table 4-15. Macroinvertebrate Florida Wetla nd Condition Index (FWCI) metric scores, total FWCI scores, and percent of reference condition for two depressional forested wetlands. Wetland region from Lane (2000). Bank Name Panther Island Reedy Creek Site Code Pant_CYP_1 Reed_FOR Region South Central Sensitive 2.7 3.5 Tolerant 6.1 7.1 Florida Index 0.1 6.5 Mollusca 3.8 5.2 Noteridae 2.6 1.9 Scrapers 0.0 2.9 FWCI 15.3 27.1 out of 60 60 % of Reference Condition 26% 45%

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88 LDI: Landscape Development Intensity Index Wetland scale LDI index scores were calculated for each of th e 58 wetland assessment areas. The mean wetland scale LDI index score was 3.17 ( = 4.89) with a median of 0.26 and a range from 0.00-16.65 (Table 4-16). The distribution of LDI index scores was non-normal (ShapiroWilk W = 0.7029, p < 0.01), with 16 wetland asse ssment areas with wetland scale LDI index scores of 0.00 and an additional 19 wetland scale LDI index scores less than 1.00. Nine wetland scale LDI index scores were greater than 10.00. Recall that the wetland scale LDI index was calculated as a potential score, as the surr ounding landscapes within the wetland mitigation bank may not yet be fully enhanced, restored, or created, although it is assume d that they will as a result of the permitted mitigation activities and after final success criteria have been met, and were accordingly assigned scores for natural lands. Bank scale LDI index scores were higher, with a mean bank scale LDI index score of 7.78 ( = 5.36), a median of 6.54, and a range from 0.00-18.22 (Tab le 4-16). Only Litt le Pine Island had a bank scale LDI index score of 0.00, with two additional mitigation banks (East Central and Graham Swamp) having bank scale LDI index scor es less than 1.00. Th e wetland assessment areas at East Central (ECFl_HAM and ECFl_FOR ) had wetland scale LDI index scores of 0.00 (compared to bank scale LDI index score of 0.32) ; whereas, Graham Swamp had a difference of 11.43 between the higher wetland scale LDI inde x (11.91) and lower bank scale LDI index (0.48), an indication that the s cale of delineation of land uses within the GIS interface has important implications for LDI cal culations (i.e., bank scale LDIs were calculated based on the WMD 2000 land use cover (LU00) where land use was delineated at a scale of 1:12,000; whereas wetland scale LDIs were calculated at a much finer grain, base d on hand delineation of land uses around the wetland assessment areas digi tally drawn on the digital orthopohoto quarter quads updated during the 2005 field vi sit). Eight banks had bank s cale LDI index scores greater than 10.00, with Florida Wetlandsbank having the hi ghest bank scale LDI index score of 18.22. A weak correlation was found between wetland scal e LDI index and bank s cale LDI index scores (r = 0.27, p < 0.05) (Figure 4-5). A large number of wetland assessment areas had wetland scale LDI scores of 0.00 (n = 16). Thes e sites were typically located in the interior portion of the wetland mitigation bank, or at least 100 m from the surrounding properties and therefore were buffered from surrounding land use activities by other areas within the mitigation bank boundaries. Consideration of potential wetland functional lift should incorporate both the wetland scale and bank scale LDI index, reflecti ng both the local and broad scale landscape support.

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89 Table 4-16. Landscape Developmen t Intensity (LDI) index scores. Wetland scale LDI index scores were based on hand delinea tion of land uses around the wetla nd assessment ar eas digitally drawn on the digital orthopohoto quarter quads upda ted during the 2005 field visit. Bank scale LDI index scores were based on delineation of land use within a 100 m zone around the wetland mitigation bank boundary using 2000 land use cover maps from the WMD (LU00). The mitigation bank outline was not available for Bora n Ranch Phase I (only Boran Ranch Phase II). Everglades Mitigation Bank has one bank scale LDI index, as the outline available was combined for Phases I and II. Year 2000 land use was not available for Garcon Peninsula. Bank Name Site Code Wetland Scale LDI Index Bank Scale LDI Index Barberville Barb_ CYP 0.10 9.39 Barb_ MAR 0.04 9.39 Bear Point Bear_MAN 6.92 6.59 Big Cypress BigC_FLA 1.74 4.63 BigC_MAR_1 5.87 4.63 BigC_MAR_2 0.00 4.63 Bluefield Ranch Blue_BOT 0.29 3.74 Blue_FLA 1.55 3.74 Blue_MAR 0.00 3.74 Boran Ranch, Phase I Bora_MAR_1 0.00 NC Bora_MAR_2 4.42 NC CGW CGW_MAN 0.16 9.85 Colbert-Cameron CoCa_ CYP_1 5.18 4.81 CoCa_CYP_2 0.00 4.81 CoCa_ FOR 0.00 4.81 Corkscrew Cork_FLA 0.00 6.01 East Central ECFl_HAM 0.00 0.32 ECFl_FOR 0.00 0.32 Everglades Mitigation Bank Glad_MAR_1 13.69 11.58 Phase I Glad_MAR_2 8.30 11.58 Glad_SHR 0.00 11.58 Everglades Mitigation Bank Phase II Glad_MAR_3 6.51 11.58 Florida Mitigation Bank FLMB_FOR 0.80 10.65 Florida Wetlandsbank FLWt_MAR_1 16.65 18.22 FLWt_MAR_2 13.00 18.22 Garcon Peninsula Garc_FLA 12.55 NC Graham Swamp Grhm_FOR 11.91 0.48 Hole in the Donut HID_MAR_1 7.45 3.70 HID_MAR_2 13.10 3.70 Lake Louisa and Green Swamp Loui_SHR 0.00 2.87

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90 Table 4-16. Continued. Bank Name Site Code Wetland Scale LDI Index Bank Scale LDI Index Lake Monroe Monr_CYP 0.05 10.46 Monr_MAR 0.01 10.46 Little Pine Island LPI_MAR 0.00 0.00 LPI_SLT_1 2.01 0.00 LPI_SLT_2 10.77 0.00 Loblolly Mitigation Bank Lob_CYP_1 1.00 10.86 Lob_CYP_2 0.28 10.86 Loxahatchee Lox_ CYP 15.72 17.03 Lox_ FOR 10.93 17.03 Lox_SHR 6.51 17.03 Panther Island Pant_CYP_1 0.22 9.90 Pant_CYP_2 0.02 9.90 Pant_CYP_3 0.01 9.90 Pant_FOR 0.00 9.90 Reedy Creek Reed_BOT 2.28 8.12 Reed_FOR 0.00 8.12 R.G. Reserve RG_MAR 0.01 6.48 Split Oak SplO_CYP 0.03 1.25 SplO_MAR 0.80 1.25 Sundew Mitigation Bank Sun_FOR_1 0.59 16.04 Sun_FOR_2 0.23 16.04 TM-Econ TMEc_CYP_1 1.26 17.84 TMEc_CYP_2 0.02 17.84 Tosohatchee Toso_FOR 0.00 5.43 Toso_ MAR 0.00 5.43 Toso_ SHR 0.00 5.43 Tupelo Mitigation Bank Tup_FOR 0.52 5.91 Tup_PRA 0.14 5.91 NC none calculated

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0 2 4 6 8 10 12 14 16 18 20LPI_MAR LPI_SLT_1 LPI_SLT_2 ECFl_HAM ECFl_FOR Grhm_FOR SplO_CYP SplO_MAR Loui_SHR HID_MAR_1 HID_MAR_2 Blue_BOT Blue_FLA Blue_MAR BigC_FLA BigC_MAR_1 BigC_MAR_2 CoCa_CYP_1 CoCa_CYP_2 CoCa_FOR Toso_FOR Toso_MAR Toso_SHR Tup_FOR Tup_PRA Cork_FLA RG_MAR Bear_MAN Reed_BOT Reed_FOR Barb_CYP Barb_MAR CGW_MAN Pant_CYP_1 Pant_CYP_2 Pant_CYP_3 Pant_FOR Monr_CYP Monr_MAR FLMB_FOR Lob_CYP_1 Lob_CYP_2 Glad_MAR_1 Glad_MAR_2 Glad_SHR Glad_MAR_3 Sun_FOR_1 Sun_FOR_2 Lox_ CYP Lox_ FOR Lox_SHR TMEc_CYP_1 TMEc_CYP_2 FLWt_MAR_1 FLWt_MAR_2Wetland Assessment Area (n=55)LDI Inde x Wetland Scale LDI Index Bank Scale LDI Index Figure 4-5. Wetland scale (light blue ba rs) and bank scale (dark green bars) Land scape Development Intensity (LDI) index scores for 55 wetland assessment areas (identified by site code).

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92 Comparison of Assessment Methods Comparisons were made between the five assessment methods used (UMAM, WRAP, HGM, FWCI, and LDI). Each assessment method was based on wetland condition using field observations, field sampling and m easurements, laboratory taxonomic id entification, and/or GIS. General comparison among UMAM, WRAP, and LDI we re most robust, with a sample size of 58 wetland assessment areas, while comparisons of HGM or FWCI (macrophyte and macroinvertebrate) with other assessment meth ods were more limited due to much smaller sample sizes (15, 10, and 4, respectively). Statis tical analyses were perf ormed using Analyse-It Software, Ltd., version 1.67 (1997-2003). UMAM and WRAP Half (n = 29) of the wetland assessment areas ha d UMAM scores greater than 0.75 (Table 4-3). Results were similar for WRAP assessments, as 31 of the wetland assessment areas (53%) had scores greater than 0.75 (Table 4-5). WRAP and UMAM scores for the 58 wetland assessment areas showed a strong positive correlation (Sp earman rank correlation r = 0.87, p < 0.01) (Figure 4-6). While it is not considered appropriate to compare scores for diffe rent wetland community types, UMAM and WRAP scores for each assessm ent area should be comparable to each other as a set, due to similarity in assessment me thod design and intent. Given the similar scoring criteria and scale, a wetland assessment area may be expected to achieve equal UMAM and WRAP scores. Comparison between UMAM and WRAP scores fo r the various wetland community types shows that there was no significant difference based on community types regarding whether the UMAM or WRAP score was higher (Figure 4-6) The difference between UMAM and WRAP scores at each wetland assessmen t area ranged from -0.15 to 0.18 (Figure 4-7), with two wetland assessment areas, a hydric pine flatwoods wetland assessment area at Bluefield Ranch (Blue_FLA; UMAM, WRAP = 0.83) and a fres hwater marsh at Boran Ranch, Phase I (BORA_MAR_2; UMAM, WRAP = 0.93), having no difference between UMAM and WRAP scores. Two freshwater marsh organic flats wetland assessment areas at Florida Wetlandsbank (FLWt_MAR_1 and FLWt_MAR_2) and a saltwate r marsh wetland assessment area at Little Pine Island (LPI_SLT_1) had the largest differe nce between UMAM and WRAP scores of 0.18 (FLWt_MAR_1 UMAM = 0.73, WRAP = 0.55; FLWt_MAR_2 UMAM = 0.70, WRAP 0.52; LPI_SLT_1 UMAM = 0.67, WRAP = 0.49). However, the mean difference between UMAM and WRAP scores was 0.00 ( = 0.08), suggesting that as a group, UMAM and WRAP scores were similar. A simple linear regression analysis performe d between UMAM and WRAP scores for the 58 wetland assessment areas showed a positive correlation (R2 = 0.72, p < 0.01, fitted regression line shown), a narrow 95% confid ence interval (middle dashed lines), and a wide prediction interval band (bold outer lines), suggesting the fitted regression line wa s not a good fit and that accurate or useful prediction of future UMAM scores are not possible based on WRAP scores (Figure 4-8). Use of a linear regression was possible due to the norma l distribution of the UMAM scores dataset (Shapiro-Wilk test) and apparent constant variance over the sampling range.

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0.0 0.2 0.4 0.6 0.8 1.0 0.00.20.40.60.81.0 WRAPUMAM 6181 Cabbage Palm Hammock 6210 Cypress 6410 Freshwater Marsh 6250 Hydric Pine Flatwoods 6120 Mangrove Swamps 6460 & 6310 Mixed Scrub Shrub 6170 Mixed Wetland Hardwood 6172 Mixed Wetland HardwoodShrubs 6420 Saltwater Marshes 6150 Stream and Lake Swamps (Bottomland) 6430 Wet Prairie 6300 Wetland Forested Mixed Figure 4-6. Uniform Miti gation Assessment Method (UMAM) and Wetlan d Rapid Assessment Procedure (WRAP) were positively correlated (Spearman rank correlation r = 0.87, p < 0.01). The line shown represents the 1:1 line.

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-0.20 -0.15 -0.10 -0.05 0.00 0.05 0.10 0.15 0.20Pant_CYP_1 BigC_MAR_1 Pant_CYP_2 Glad_SHR CGW_MAN CoCa_CYP_1 Grhm_FOR Barb_CYP Blue_MAR Tup_FOR CoCa_CYP_2 TMEc_CYP_2 LPI_MAR Toso_SHR Reed_BOT Bora_MAR_1 CoCa_FOR Tup_PRA BigC_MAR_2 Glad_MAR_3 Pant_CYP_3 SplO_CYP RG_MAR SplO_MAR Barb_MAR Toso_MAR Lob_CYP_2 BigC_FLA ECFl_HAM HID_MAR_1 Bora_MAR_2 Blue_FLA TMEc_CYP_1 LPI_SLT_2 Toso_FOR Sun_FOR_1 Glad_MAR_2 Blue_BOT Lob_CYP_1 Monr_MAR Cork_FLA Loui_SHR Monr_CYP Pant_FOR Sun_FOR_2 Glad_MAR_1 HID_MAR_2 ECFl_FOR Lox_SHR Lox_CYP Bear_MAN FLMB_FOR Garc_FLA Lox_FOR Reed_FOR FLWt_MAR_1 FLWt_MAR_2 LPI_SLT_1Wetland Assessment Areas (n=58)Difference UMAM WRAP Figure 4-7. The difference between Un iform Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas. Light colored bars (n = 30) show higher WRAP scores; dark colored bars (n = 26) show higher UMAM.

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95 y = 0.68x + 0.24 R2 = 0.72, p < 0.01 0.4 0.5 0.6 0.7 0.8 0.9 1.0 0.40.50.60.70.80.91.0 WRAPUMAM Figure 4-8. Linear regression between Un iform Mitigation Assessment Method (UMAM) and Wetland Rapid Assessment Procedure (WRAP) scores for 58 wetland assessment areas (R2 = 0.72, p < 0.01, fitted regression line shown). Middle dashed lines are 95% confidence interval and bold outer lines are prediction interval band. Given the similarities in the UMAM and WRAP scoring categories and application of the methods, correlations were expected among the many scoring categories for each method. In fact, of the 55 pair wise comparisons between UMAM and its three scoring categories (Location and Landscape Support, Water Environment, and Community Structure) and WRAP and its six scoring categories (Wildlife Utilization (WU), Wetland Canopy (O/S), Wetland Ground Cover (GC), Habitat Support/Buffer, Field Hydrology ( HYD), WQ Input & Treatment (WQ)), 52 pair wise comparisons were statis tically correlated (S pearman rank correlation r > 0.25, p < 0.05; Table 4-17). The three non-si gnificant comparisons were for WRAP WQ Input & Treatment (WQ) with UMAM Water Environment, WR AP Wetland Canopy (O/S), and WRAP Wetland Ground Cover (GC).

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96 UMAM, WRAP, and LDI The distribution of scores for both wetland s cale and bank scale LD I index were non-normal (Shapiro-Wilk W = 0.69; W = 0.94, respectiv ely, p < 0.01), therefore the Spearman rank correlation was used for comparisons, as this correlation does not rely on the assumption of normal distributions and it does no t anticipate a lin ear correlation among variables. Recall that the wetland scale LDI index was calculated as the potential for a wetland assessment area. That is, given successful restoration, creation, enhancement, or preservation in the adjacent landscape, the wetland scale LDI index value re flects the lowest potential wetland scale LDI index score and in turn the highest potenti al ecological integrity possible for a wetland assessment area once mitigation is complete and successful restoration of wetland function is achieved. Overall UMAM scores were not significantly correlated with wetland scale or bank scale LDI index scores (Table 4-17). However the UMAM scoring category Location and Landscape Support was significantly correlated with both the wetland scale LDI index (Spearman rank correlation r = -0.36, p < 0.01) (Figure 4-9A) and bank scale LDI index (r = -0.30, p < 0.05) (Figure 4-9B). Bardi et al. (2005) suggested usi ng a modified form of the LDI index scaled to match UMAM scoring, as a tool to assist in scoring UMAM. As the support landscape within mitigation banks undergoes further restoration a nd/or enhancement, th e correlation between UMAM Location and Landscape Support and wetla nd scale LDI index may strengthen. UMAM Water Environment and UMAM Community Structur e scoring categories we re not statistically significant with either wetland scal e or bank scale LDI index scores. Overall WRAP scores were sign ificantly correlated with wetl and scale LDI index scores (r = -0.36, p < 0.01) (Figure 4-10A), though not with bank scale LDI index scores. In addition, wetland scale LDI index scores we re significantly correlated with WRAP Habitat Support/Buffer (r = -0.39, p < 0.01) (Figure 410B), WRAP Field Hydrology (HYD) (r = -0.27, p < 0.05) (Figure 4-10C), and WRAP WQ Input & Treatmen t (WQ) (r = -0.49, p < 0.01) (Figure 4-10D). Bank scale LDI index scores were also correlated with WRAP WQ Input & Treatment (WQ) (r = -0.37, p < 0.01) (Figure 4-11). HGM and FWCI Comparisons between HGM and FW CI with the other three met hods (UMAM, WRAP, and LDI) were limited due to the relatively small sample size of HGM assessments (n = 15), macrophyte FWCI assessments (n = 10), and macroinverte brate FWCI assessments (n = 4), though some interesting trends were apparent with even this small dataset. One statistically significant correlation was found in the comparison of to tal WRAP score with HGM Wildlife Habitat (Spearman rank correlation r = 0.55, p < 0.05) (Table 4-18). This correlation used scores for all 15 HGM assessments, which included a mixture of flats wetlands in the Everglades and depressional wetlands in peninsul ar Florida. WRAP was originally designed for compliance assessment of wetlands in South Florida, includi ng Everglades and depre ssional wetlands in the southern portion of the Florid a peninsula. Two additional si gnificant correlations were found between WRAP scoring categories and HGM func tional capacity index scores: WRAP Field Hydrology (HYD) and HGM Subsurface Water St orage (r = 0.75, p < 0.05) and WRAP WQ

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Table 4-17. Pair wise comparisons among scoring categories and total scores for the Unifor m Mitigation Assessment Method (UMAM), Wetland Rapid Assessment Procedures (WRAP), wetla nd scale Landscape Development Intensity (LDI) index, and bank scale LDI index. All reported comparisons we re significant (p < 0.05). UMAM UMAM Location and Landscape Support UMAM Water Environment UMAM Community Structure WRAP WRAP Wildlife Utilization (WU) WRAP Wetland Canopy (O/S) WRAP Wetland Ground Cover (GC) WRAP Habitat Support/Buffer WRAP Field Hydrology (HYD) WRAP WQ Input & Treatment (WQ) Wetland Scale LDI Index UMAM Location and Landscape Support 0.77 x UMAM Water Environment 0.83 0.42 x UMAM Community Structure 0.85 0.47 0.67 x WRAP 0.87 0.73 0.65 0.74 x WRAP Wildlife Utilization (WU) 0.78 0.74 0.54 0.64 0.83 x WRAP Wetland Canopy (O/S) 0.69 0.33 0.61 0.80 0.76 0.63 x WRAP Wetland Ground Cover (GC) 0.66 0.46 0.49 0.71 0.68 0.55 0.48 x WRAP Habitat Support/Buffer 0.66 0.72 0.38 0.45 0.8 0.69 0.49 0.35 x WRAP Field Hydrology (HYD) 0.72 0.40 0.80 0.55 0.71 0.47 0.54 0.41 0.46 x WRAP WQ Input & Treatment (WQ) 0.41 0.50 NS 0.27 0.63 0.35 NS NS 0.54 0.31 x Wetland Scale LDI Index NS -0.36 NS NS -0.36 NS NS NS -0.39 -0.27 -0.49 x Bank Scale LDI Index NS -0.3 NS NS NS NS NS NS NS NS -0.37 0.27 Values reflect Spearman rank co rrelation coefficient (r value) NS Not significant

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98(A) (B) 0 2 4 6 8 10 048121620 Wetland Scale LDI IndexUMAM Location and Landscape Support 0 2 4 6 8 10 048121620 Bank Scale LDI IndexUMAM Location and Landscape Support .r = -0.36, p < 0.01 r = -0.30, p < 0.05 Figure 4-9. Correlations among Unifor m Mitigation Assessmen t Method (UMAM) Location and Landscape Support scoring ca tegory with A) wetland scale Landscape Development Intensity (LDI) index scores and B) bank scale LDI index scores.

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99(A)(B) (C)(D) 0.0 0.2 0.4 0.6 0.8 1.0 048121620 Wetland Scale LDI IndexWRAP .r = -0.36, p < 0.01 0 1 2 3 048121620 Wetland Scale LDI IndexWRAP Habitat Support/Buffer 0 1 2 3 048121620 Wetland Scale LDI IndexWRAP Field Hydrology (HYD) 0 1 2 3 048121620 Wetland Scale LDI IndexWRAP WQ Input & Treatment (WQ) .r = -0.27, p < 0.05 r = -0.39, p < 0.01 r = -0.49, p < 0.01 Figure 4-10. Wetland Rapid Assessment Pr ocedure (WRAP) correlations with wetland scale Landscape Development Intensity (LDI) index: A) Overall WRAP scores ; B) WRAP Habitat Support/Buffer scores; C) WRAP Fiel d Hydrology (HYD) scores ; and D) WRAP WQ Input & Treatment (WQ) scores.

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100 0 1 2 3 048121620 Bank Scale LDI IndexWRAP WQ Input & Treatment (WQ) .r = -0.37, p < 0.01 Figure 4-11. Bank scale Landscape Developmen t Intensity (LDI) index score correlations: A) Wetland Rapid Assessment Procedure (WRAP) WQ Input & Treatment (WQ) scores; and B) wetland scale LDI index scores.

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Table 4-18. Correlations among Uniform Mitigation Assessment Method (UMAM) and scoring categories, Wetland Rapid Assessment Procedure (WRAP) and scoring categories, wetland scale Landscape Development Intensity (LDI) index scores, bank scale LDI index scores, Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores, macrophyte Florida Wetland Condition Index (FWCI) scores, and macroinvertebrate FWCI scores. Only significant correlations (p < 0.05) are shown. HGM Subsurface Water Storage HGM Surface and Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat WRAP NS NS NS NS 0.55 WRAP Field Hydrology (HYD) 0.75NS NS NS NS WRAP WQ Input & Treatment (WQ) NS NS 0.53NS NS Wetland Scale LDI Index -0.72NS -0.56NS NS HGM Cycle Nutrients 0.71NS x x x HGM Characteristic Plant Community NS 0.81 NS x x HGM Wildlife Habitat NS NS 0.560.88x Values reflect Spearman rank co rrelation coefficient (r value) NS Not significant

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102 Input & Treatment (WQ) and HGM Cycle Nutrie nts (r = 0.53, p < 0.05). These same two HGM functional capacity index scores, HGM Subs urface Water Storage and HGM Cycle Nutrients were significantly correlated with wetland scale LDI index (r = -0.72, p < 0.05; r = -0.56, p < 0.05, respectively). Comparisons among the HGM functional capacity index scores revealed four significant correlations within HGM: HGM Subsurface Water Storage and HGM Cycle Nutrients (r = 0.71, p < 0.05), HGM Surface and Subsurface Water Storage and HGM Characteristic Plant Community (r = 0.81, p < 0.05), and HGM Wildlife Habitat with both HGM Cycle Nutrients (r = 0.56, p < 0.05) and HGM Characteristic Plant Community (r = 0.88, p < 0.01). Neither the macrophyte nor macroinvertebrate FWCI scores were significan tly correlated with UMAM and UMAM scoring catego ries, WRAP and WRAP scoring categories, wetland scale or bank scale LDI scores, HGM functio nal capacity index scores, or one another. Further, UMAM, UMAM scoring categories, and bank scale LDI i ndex were not significantly correlated with HGM functional capacity index scores. Each of the five assessment methods measured wetland condition as compared to the reference standard condition. As such, co mparisons have been made by sc aling each assessment score to represent the percent of the reference standard conditi on. UMAM, WRAP, macrophyte FWCI, macroinvertebrate FWCI, and wetland scale LDI (Table 4-19) and HGM variables (Table 4-20) scores presented as percent of reference standa rd condition provide a comp lex picture of wetland assessment, as shown in three examples below. The depressional forested wetland at Reedy Creek (Reed_FOR) scored 77% for UMAM, 61% for WRAP, 64% on macrophyte FWCI, and 45% on the macroinvertebrate FWCI (Table 4-19). This same wetland assessment area scored 31% of the reference standard condition for the HGM variable Characteristic Plant Community and 93% for the HGM variable Surface Water Storage variable (Table 4-20). The wetland scale LDI index was 0.00, suggesting that this wetland assessment area has the potential to provide fu ll wetland function in the future, based on complete restoration of surroundi ng lands within the bank. However, the bank scale LDI for Reedy Creek was 8.12, as the land surrounding th e bank hosts some human activities. The depressional marsh at Barberville (Barb_M AR) reflected 85-96% of the reference wetland condition for all of the HGM fu nctional capacity index scores Scores for the remaining assessment methods were more variable, fr om 77% for UMAM, 80% for WRAP, 82% for macrophyte FWCI, and 94% for macroinvertebrate FW CI. Another interest ing case was one of the organic flats marshes in Florida Wetlands bank (FLWt_MAR_1), which received a wetland scale LDI index of 16.65, yet received higher percentages of reference standard condition according to UMAM (73%), WRAP (55%), and HGM functional capacity index scores from 5669%. The variability in scoring percentages for th is wetland assessment area was large, and it is unclear which, if any, assessment method provided a more accurate picture of current wetland condition. A simple average am ong the assessment methods ( x = 0.64, = 0.07) offers an incomplete description of the current wetland condition.

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Table 4-19. Percent of reference standard conditions for Un iform Mitigation Assessment Met hod (UMAM), Wetland Rapid Assessment Procedure (WRAP), macrophyte Florida Wetland Condition Index (FWCI), and macroinvertebrate FWCI assessment methods for 16 wetland assessment areas. Mitigation Bank Site Code Wetland Type UMAM WRAP Macrophyte FWCI Macroinvertebrate FWCI Lake Monroe Monr_CYP Cypress 90% 86% 81% na Panther Island Pant_CYP_1 Cypress 70% 85% 21% 26% Reedy Creek Reed_FOR Cypress 77% 61% 64% 45% TM-Econ TMEc_CYP_1 Forested Strand 73% 72% 83% na Barberville Barb_MAR Marsh 77% 80% 82% 94% Bluefield Ranch Blue_MAR Marsh 73% 80% 46% na Boran Ranch, Phase I Bora_MAR_1 Marsh 93% 99% 24% 68% Lake Monroe Monr_MAR Marsh 80% 77% 32% na R.G. Reserve RG_MAR Marsh 67% 71% 80% na Split Oak SplO_MAR Marsh 70% 73% 46% na Everglades Mitigation Bank Phase I Glad_MAR_1 Marl Flats 83% 78% na na Everglades Mitigation Bank Phase II Glad_MAR_3 Marl Flats 60% 65% na na Florida Wetlandsbank FLWt_MAR_1 Organic Flats 73% 55% na na Florida Wetlandsbank FLWt_MAR_2 Organic Flats 70% 52% na na Hole in the Donut HID_MAR_1 Rocky Flats 93% 94% na na Hole in the Donut HID_MAR_2 Rocky Flats 83% 77% na na

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Table 4-20. Percent of reference standard conditions for Hydrogeomorphic wetland assessment method (HGM) functional capacity index scores for 15 wetland assessment areas. Mitigation Bank Site Code Wetland Type HGM Surface Water Storage HGM Subsurface Water Storage HGM Surface and Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat Lake Monroe Monr_CYP Cypress 94% 88% na 79% 88% 93% Panther Island Pant_CYP_1 Cypress 88% 78% na 78% 88% 82% Reedy Creek Reed_FOR Cypr ess 92% 93% na 75% 31% 61% Barberville Barb_MAR Marsh 93% 94% na 96% 85% 87% Bluefield Ranch Blue_MAR Marsh 100% 98% na 97% 79% 76% Boran Ranch, Phase I Bora_MAR_1 Marsh 99% 98% na 98% 85% 87% Lake Monroe Monr_MAR Marsh 100% 100% na 99% 99% 99% R.G. Reserve RG_MAR Marsh 100% 79% na 83% 58% 69% Split Oak SplO_MAR Marsh 92% 71% na 92% 53% 56% Everglades Mitigation Bank Phase I Glad_MAR_1 Marl Flats na na 100% 95% 98% 96% Everglades Mitigation Bank Phase II Glad_MAR_3 Marl Flats na na 100% 90% 96% 90% Florida Wetlandsbank FLWt_MAR_1 Organic Flats na na 63% 69% 66% 56% Florida Wetlandsbank FLWt_MAR_2 Organic Flats na na 67% 64% 62% 53% Hole in the Donut HID_MAR_1 Rocky Flats na na 64% 65% 72% 81% Hole in the Donut HID_MAR_2 Rocky Flats na na 48% 68% 59% 81%

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105 Further sampling and analysis with the detailed biological assessm ents methods is suggested, as this would provide for more robust comparisons among methods. However, inspection of the percentage of reference standard condition reflected in the 16 wetland assessment areas with HGM and/or FWCI assessments shows that few if any of these wetlands are providing maximum function according to the comparison to the refe rence standard condition (Figures 4-12, 4-13, 414). There was a general ( 10-20%) agreement in the range of sc ores for the majority of these assessment methods at each site, though no clear trend was apparent based on higher or lower representation of reference standard condition by assessment method or by potential credits released. For the six Everglades flats we tlands there was no clear trend between which assessment method presented the highest percent of reference condition as measured by UMAM, WRAP, or HGM (Figure 4-12). Similarly, for th e six depressional herbace ous wetlands, scores were variable, though scores for one of the HGM functional indices was often the highest assessment with the exception of the herbaceous marsh at Split Oak (SplO_MAR), where the WRAP score (0.97) was the highest measured a ssessment score (Figure 4-13). For the three forested depressional wetlands, HGM was also the highest assessment score, and for the forested strand wetland (where no HGM was conduc ted) the macrophyte FWCI was the highest assessment score (Figure 4-14).

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0% 20% 40% 60% 80% 100% Glad_MAR_3HID_MAR_1HID_MAR_2Glad_MAR_1FLWt_MAR_2FLWt_MAR_1Percent of Reference Condition UMAM WRAP HGM Surface and Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat10% 33% 33% 90% 99% 99% Potential Credits Released per Respective Bank Figure 4-12. Comparison among six Everg lades flats wetlands of UMAM (solid bars), WRAP (white bars), and HGM functional capacity indices (hatched bars).

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0% 20% 40% 60% 80% 100% RG_MARSplO_MARBlue_MARBarb_MARMonr_MARBora_MAR_1Percent of Reference Condition UMAM WRAP HGM Surface Water Storage HGM Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat Macrophyte FWCI Macroinvertebrate FWCI8% 43% 45% 64% 65% 92% Potential Credits Released per Respective Bank Figure 4-13. Comparison among six depre ssional herbaceous wetlands of UMAM (s olid bars), WRAP (white bars), HGM functional capacity indices (hatched bars), macrophyte FWCI, and macroinvertebrate FWCI (checkered bars).

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0% 20% 40% 60% 80% 100% TMEc_CYP_1Reed_FORMonr_CYPPant_CYP_1Percent of Reference Condition UMAM WRAP HGM Surface Water Storage HGM Subsurface Water Storage HGM Cycle Nutrients HGM Characteristic Plant Community HGM Wildlife Habitat Macrophyte FWCI Macroinvertebrate FWCI15% 62% 65% 86% Potential Credits Released per Respective Bank Figure 4-14. Comparison among four foreste d wetlands of UMAM (solid bars), WRAP (white bars), HGM functional capacity indices (hatched bars), macrophyte FWCI, an d macroinvertebrate FWCI (checkered bars). HGM was not completed at TMEc_CYP_1, a forested strand wetland. The remaining three wetlands were depressional forested wetlands.

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109 Suggestions for Assessment Methods Our primary goal was to determine the current ecological integrity of the wetland resources within permitted wetland mitigation banks. While this research was not specifically designed to provide suggestions to further develop and refi ne the assessment methods, some comments and concerns have arisen after implementa tion of the different assessment methods. In general, UMAM Location and Landscape Suppor t could use further guidance regarding the spatial extent that should be identified and us ed in scoring this category. Questions that commonly arose in the field centered around the a ppropriate scale or exte nt to consider for wildlife conduits, downstream connectivity, a nd surrounding land uses. Some wetland assessment areas were situated in the interior of the wetland mitigation bank, while others were located adjacent to the boundary near roadways or other anthropogenic land us es. In the case of the former, consideration had to be given to the implications of developed lands outside of the mitigation bank boundaries and how these areas affected the connectivity of the wetland assessment area to areas appropriate to suppor t expected wildlife species, provide water buffering (both quality and quantity) supply native and exotic seed sources, etc. In the case of the latter, consideration had to be given to immediately adjacent land uses as well as available habitat within the wetland mitigation bank. UMAM Location and Landscape Support scores could be highly variable dependi ng on the spatial extent used. Suggestions and concerns for WRAP have not b een provided, as UMAM must now be used by state agencies for all regulatory decisi on making involving mitigation, including the determination of potential credits in mitigation banks in Florida. Both the HGM flats wetlands in the Everglades a nd depressional wetlands of peninsular Florida guidebooks have had limited field testing and applic ation within Florida. There are some areas where clarification would be appropriate for fu ture HGM assessments as well as some minor errors that were detected within the guid ebooks. Additional HGM guidebooks for more wetland community types would be beneficial. To ease the use of the guidebook, a reference sheet that explains what specific data need to be collected for each variable would be valuable. This study created its own reference sheet so that the guidebook did not need to go in the field and to ensure that important data were not accidentally overlo oked and not collected. Field data sheets were inconsistently referred to within the text of the HGM guidebook for de pressions making cross referencing confusing at times. Field data sheets could be reworked; it appears sometimes that they reflected data collection that may have be en included earlier on in the development of the guidebook but not the final method. Specifically sometimes too much data collection was required that was not later used as part of the analysis. This was especially true for the variable of tree basal area (TBA) and macrophytic vege tation cover (MAC) in the depressional guidebook. Identification of a species and recording its species name was not part of the analysis and was unnecessary to that degr ee of detail. The field sheet could also be made more user friendly by providing more space for recording data. Often notes were taken elsewhere or in the margins and it would have been useful on the fi eld sheet itself so that there was an obvious progression of data recorded and then final asse ssment. For example it would be appropriate for the COMP variable for vegetation dominance to have a space for recording what the species actually were along with th e percent dominance.

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110 Likewise, development and application of FWCI in Florida has been limited to three wetland community types, and expansion to include add itional wetland types and regions would improve application. Clearly the diatom and macroinve rtebrate FWCIs are limited by the need for a minimum of 10 cm of standing water. As th ese species assemblages depend on standing water for their existence, little coul d be done regarding the small sa mple size. Perhaps additional FWCIs for other community assemblages such as bi rds or herps could be developed to alleviate some of the need for a minimum level of standing water. The application of LDI to mitigation sites presents many challenges. Primarily, there is concern over how to appropriately assign non -renewable empower density values to lands that in the past have been used for human activities but currently are being restored to a reference community type. As such, wetland scale LDI calculations used in this study have been considered potential LDI, suggesting th e wetland condition a ttainable based on surrounding land use within the bank. Further, the differences betw een wetland scale and bank scale LDI scores raise a question as the most important or relevant scale to consider. In the end, perhaps an integration of both scales is the best indication of landscape support. Overall each assessment method has multiple strengths and weaknesses. It was useful to use all five of the assessment methods to evaluate wetland condition within the wetland mitigation banks.

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111 CHAPTER 5 PERMIT REVIEW AND ECOLOGICAL INTEGRITY: CASE STUDIES In an attempt to understand and evaluate the effectiveness of wetland mitigation banking in Florida, a review of permits and other relevant documents, site vi sits, and field assessments were conducted. The results indicated a disconnect between the determ ination of success or interim success criteria according to th e permit and the site condition assessed according to five methods. Mitigation bank permits refer to succe ss as meeting the minimal intended ecological condition and the specific criteria listed in the Mitigation Banking Instrument (MBI) or the permit as a result of the permitted restoration a nd enhancement activities (Story et al. 1998; Ch 62-342.750, F.A.C.). Permit success is not intende d to indicate that the functional capacity of a particular area (whether wetl and or upland, or whether re stored, enhanced, created, or preserved) has been achieved. Therefore, it has b een challenging to correlated success defined by permit review with field evaluations, whic h rely on a score of wetland function. Permits may also refer to interim success, or milestones, for incremental credit releases. Permit credit release (also called interim success) crit eria were often combin ations of recording a conservation easement, removal of exotic sp ecies vegetation, earth moving and grading, hydrologic enhancement in the form of ditch plugging or canal filling, site preparation and planting, removal of undesirable tree canopy species or woody ve getation, successful completion of a prescribed burn, monitoring and accompanyi ng reports, management, and preservation. While these are all worthy activities and necessary for restoration efforts, they do not in and of themselves equate to success defined as fully functioning wetland communities. Due to the vast difference among permit success criteria, credit release requirements, and application of fields assessment methods (spe cific to particular we tland community types), across the board generalizations are difficult. Case studies for three wetland mitigation banks will be presented, highlighting differences of permit success, as measured by permit and document review and compliance interviews as presented in Chapter 3, and functional success, as measured by field assessment methods as pres ented in Chapter 4. Case studies for East Central, Florida Wetlandsbank, and Sundew Mitigation Bank provi de an overview of permit and document review juxtaposed w ith field assessment results.

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112 Case Study: East Central East Central Florida Regional Mitigation Bank (East Central) a 385 ha (952 ac) wetland mitigation bank located in the northeast corner of Orange County in central Florida along the St. Johns River (S2-6, 8-11/T22S/R33E and S35/T21S /R33E) (Figure 5-1A), abuts approximately 23,472 ha (58,000 ac) of public lands and was reported to host seven state li sted threatened or endangered plant species and six state and/or fede rally listed wildlife species. It was permitted by SJRWMD in May 1997. Approximately 75-80% of the bank consisted of hydric hammock and floodplain swamp wetland, with pine or mi xed hardwood upland communities covering the remaining 20-25%. To date, all of the 286.3 potential credits have b een released. Original credit allocation was 121.4 credits (42.4%) for forest ed upland enhancement and management, 96.2 credits (33.6%) for forested wetland restora tion and enhancement, and 68.7 credits (24%) for forested wetland preservation. As of October 2006, a total of 176.1 credits (61.5%) have been sold. The forested communities on this property were logged primarily for bald-cypress (Taxodium distichum), oak (Quercus spp.), red maple (Acer rubrum), and sweetgum (Liquidambar styraciflua) in the 1940s, with additional l ogging activities in the past 60 yrs. In areas where the canopy has not recovered, the wetland community type was described as cabbage palm hammock. Cattle grazing was also historically prevalent on the property. The majority of credits (55.4%) were released for recordi ng a conservation easement, removing cattle, and constructing a fence along the western boundary to prevent cattle ac cess from adjoining properties (Table 5-1). Filli ng an existing canal system that impacted Christmas Creek and installing vegetation for stabilization accounted fo r 95.1 credits (33.2%). A dditional ditch filling to improve the hydrology of seven impacted isol ated wetlands was awarde d 1.1 credits (0.38%). Canal filling used existing spoil berm materials onsite, with four areas of the canal filled to match the adjacent grade and others filled only to the extent possible given existing on-site material, leaving some deeper pools along the hist oric canal footprint (F igure 5-1B). Areas restored to matching grade were planted with herbaceous vegetation for stabilization. An additional 26.4 credits (9.22%) were allocated fo r a prescribed burn of designated upland area where fire suppression had led to encroachment by hardwood species in an otherwise pine (Pinus sp.) dominated area. Detailed success criteri a were not found for the remaining 5.0 credits (1.7%) that were tied into success of planted areas, defined roughly with achieving and maintaining target hydrologic regimes based upon reve rsal of existing altera tions and less than 10% cover by nuisance and e xotic species of vegetation. Potential credit determination was establishe d through mitigation ratios by SJRWMD. The 121.4 forested upland enhancement and manageme nt credits were awarded based on a 2.1:1 credit ratio. Of the 96.2 credits for forested wetland restorat ion and enhancement, 50.9 credits were allocated for hydrologic enhancement with in the primary and s econdary zones along Christmas Creek canal and the isolated wetlands with credit ratios of 2.5:1, 5:1, and 6:1, respectively; 23.5 credits were allo cated for enhancement of Christ mas Creek with a credit ratio of 2.5:1; and 21.8 credits were allocated for we tland restoration using existing berms to fill canals to grade with a 1:1 credit ratio.

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113 (A) (B) Figure 5-1. Landscape location of East Central (green line) in northeast Orange County: A) along the St. Johns River and surrounding land use in 2004 and B) close-up of wetland assessment areas for field assessment methods. Images are digital orthographic quarter quads. Green line is East Central bank boundary; blue (ECFl_HAM) and orange (ECFl_FOR) lines are wetland assessment areas for field assessment methods.

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114 Table 5-1. Credit release schedule for East Central. Activity Credits% Credits Record conservation easement, remove cattle, construct fence along west boundary 158.755.4% Complete canal filling and install plants for stabilization 95.133.2% Perform restorative burn of designated upland area 26.49.2% Meet success criteria for planted areas 5.01.7% Complete ditch filling for seven isolated wetlands 1.10.4% Total Credits 286.3100% Two wetland assessment areas were selected with in East Central, ECFl_HAM a cabbage palm hammock (FLUCCS 6181 Cabbage Palm Hammock) and ECFl_FOR a mixed species forested wetland along a black water stream (FLUCCS 6300 Wetland Forested Mixed) (Figure 5-1B). ECFl_HAM surrounds a portion of the filled canal that has been planted with marsh vegetation for stabilization but will be allowed to naturally recruit shrub and tree species in the long term. The filled canal footprint was not included in the assessment area because it is not currently a recognized wetland community type. Historically the canal imp acted the surficia l aquifer in the forested areas and downstream wetlands within two zones according to the original permit, a primary impact zone within 76.2 m (250 ft) and a secondary im pact zone within 152.4 m (500 ft). Both zones were included within the we tland assessment area of ECFl_HAM. Total UMAM (0.77) and WRAP (0.78) scores for ECFl_HAM were similar (T able 5-2). UMAM category scores ranged from 6 for Community Structure to 9 for Location and Landscape Support. The lower Community Structure score was assigned based on the altered canopy composition from logging activities and the presen ce of some exotic and nuisance species of vegetation. WRAP scoring categories ranged from 2.0 for Wildlif e Utilization (WU), We tland Canopy (O/S), and Habitat Support/Buffer to 3.0 for WQ Input & Treatment (WQ). The second wetland assessment area, ECFl_FOR wa s located along the historic Christmas Creek floodplain in the forested wetland preservation ar ea. Christmas Creek runs through the wetland mitigation bank in a southwest/northeast direction, though the creek signature is difficult to detect on the 2004 digital orthogr aphic quarter quads (Figure 51). UMAM (0.70) and WRAP (0.64) scores were lower for ECFl_FOR (Table 52) mainly due to upstream disturbances, the constant input of the invasive ex otic species comm on water-hyacinth (Eichhornia crassipes) from the connection with the St. Johns River, improper zonation in the wetland ground cover, and altered canopy. All three UMAM scoring categ ories were assigned scores of 7. WRAP scoring categories ranged from 0.5 for Wetla nd Ground Cover (GC) to 3.0 for WQ Input & Treatment (WQ), with the remaining four scoring categories assigned a 2.0. While all of the potential credit has been released for East Central, it is clear from the wetland assessments conducted that full wetland function ha s not been achieved. It is unclear if the permitting process assumed full wetland function would be restored in determining mitigation

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115 Table 5-2. Wetland assessment scores for two wetland assessment areas (ECFl_HAM and ECFl_FOR) at East Central. Assessment methods include Uniform Mitigation Assessment Method (UMAM), three UMAM scoring catego ries, Wetland Rapid Assessment Procedure (WRAP), and six WRAP sc oring categories scores. ECFl_HAM ECFl_FOR UMAM 0.77 0.70 Location and Landscape Support 9 7 Water Environment 8 7 Community Structure 6 7 WRAP 0.78 0.64 Wildlife Utilization (WU) 2.0 2.0 Wetland Canopy (O/S) 2.0 2.0 Wetland Ground Cover (GC) 2.5 0.5 Habitat Support/Buffer 2.0 2.0 Field Hydrology (HYD) 2.5 2.0 WQ Input & Treatment (WQ) 3.0 3.0 ratios. If so, while success criteria designed for this project have been met, full wetland function has not been attained at this s ite as measured by these method. Of the entire credits allocated for East Central, only 1.7% (5.0 credits) were based on reaching success criteria for planted areas. A majority of credits, 89% ( 254.9 credits) were based on recording a conservation easement or construction activities (i.e., fence construction, canal fil ling, ditch filling). The remaining 8.8% (26.4 credits) were based on completion of a pres cribed burn in the uplands and meeting success criteria. While these activities were assumed to enhance the condition of wetland and upland communities, there was little control over m odification of credit release based on wetland function achieved from these activities.

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116 Case Study: Florida Wetlandsbank As the first wetland mitigation bank permitte d in Florida in 1995 by SFWMD, Florida Wetlandsbank provided an example of a bank that has been deemed successful according to permit success criteria. Current conditions of two ar eas assessed in 2005, 10 yrs after the state permit was issued, suggested that full wetland function has not been restored to date. Florida Wetlandsbank was located in western Br oward County (S11/T51S/R39E). Current land use surrounding the bank was predominantly re sidential with some light commercial development, roads, and small parcels of old-fi eld non-restored lands (F igure 5-2A). Before becoming a mitigation bank, this 170 ha (420 ac) site was an old-field with a large population of the Florida Exotic Pest Plant Council Category I invasive exotic punktree (Melaleuca quinquenervia), a species documented as causing ecological damage through invading and disrupting native communities (EPPC 2003). The historic land use from a 1970s land use cover map (file USGSLU, available at: http://www.fgdl .org/) characterized the site as herbaceous rangeland (FLUCCS 3100). In addition, the site was hydrologically impacted by land drainage and canals, including a canal bisecting the property along a NE-SW line (Figure 5-2B). The mitigation plan involved removing exotic sp ecies, scraping the site down to the limestone bedrock to facilitate wetland establishment, and installing water control structures. The site was graded to target elevations of community types present in the greater Everglades: cypress flats, open water, sawgrass marsh, wet prairie, tree islands and other native upland communities. Water levels were manipulated and controlled to keep the site hydrated for the extended 9-12 month annual period of inundation t ypical of natural organic flats wetlands in the Everglades (Noble et al. 2002). Berms surrounding the wetla nds and dividing some of the phases were planted with native upland vegetation. The wetlands were also either planted and/or allowed to naturally recruit with native vegetation. Planting at the bank included 1,317,433 plants, and some areas had to be planted several times beca use of poor success in plan t establishment. At least 129 native species were documented as recrui ting naturally on the bank. In addition, the site has three known protected archaeological sites. Success criteria for Florida Wetlandsbank include d hydrology, exotic spec ies cover, planted vegetation, and recruited vegetatio n (Table 5-3). For hydrologic re storation, the project goal was to maintain an average water level of 4.0 ft ( 0.25 ft) National Ge odetic Vertical Datum (NGVD) to maintain the desired inundation cond itions. The second success criteria was for 5% or less cover by exotic or undesirable species of vegetatio n throughout the bank, including both planted and non-planted areas. The remaini ng two success criteria concerned minimum survivorship and cover of desi rable species throughout the bank. The credit release schedule for this bank was 90 % activity oriented credi t: credit release awarded for recording the conser vation easement (15%), punkt ree removal (25%), site grading (40%), and planting and mulching (10%). The final 10% of credits were schedul ed for release after successful monitoring after the first (5%) and second (5%) year. To date, 367.37 of the potential 370 credits have been released and the bank has b een sold out. The final 2.63 credits were being held by the SFWMD until monitoring for the last restored phase was complete.

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117 (A) (B) Figure 5-2. Landscape location of Florida We tlandsbank (green line) in western Broward County and surrounding land use in A) 2004 and B) 1995. Images are digital orthographic quarter quads. Green lines are wetland mitigat ion bank boundaries with small county in-holding in southwest corner. Blue (FLWt_MAR_1) and orange (FLW t_MAR_2) lines are wetland assessment areas for field assessment methods.

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118 Table 5-3. Success criteria for Florida Wetlandsbank. Category Criteria Hydrology Water levels demonstrate an average water elevation of 4.0 ft NGVD or within an acceptable deviation of 0.25 ft Exotic cover No more than 5% of both plan ted and unplanted areas will support exotic or undesirable plant species Desirable vegetation, planted 80% survival of each planted specie s after 2 years with persistence of another 3 years after the da te of time zero for each phase Desirable vegetation, recruited 80% cover for volunteer vegetation areas without planting after 2 years persistence for another 3 year s after the date of time zero for each phase Information from Bank Permit Staff Report Monitoring Plan E xhibit 29 and Special Conditions. Two years after the state permit was issued, Le w Lautin, Chief Executive Officer and Partner WetlandsbankTM, Inc., testified before the H ouse of Representatives, Subcommittee on Water Resources and Environment Committee on Transportation and Infrastructure, that As of December 1, 1997, our Pembroke Pines mitigation bank has completely restored almost 350 acres to fully functioning wetlands that have been monitored and approved by federal, state and local regulatory agencies. In my written report, you will find information that supports this success through the elimination of exotic plants, the reest ablishment of hydrology and the planting and growth of a variety of pl ants and trees that now thrive at th e site and provide critical habitat for diverse wildlife speci es that now make their home in this mitigation bank within a mile of the historic Florida Everglades (pg. 3). The permit and supporting documentation appear to assume full wetla nd function would be restored to this site once the success criteria have been met. However, according to the field UMAM, WRAP, and HGM assessment results from this study, this bank has achieved 52-73% of the reference wetland condition (Table 5-4) Assessment scores ranged between 0.52 (for WRAP at FLWt_MAR_2) to 0.73 (for UMAM at FLWt_MAR_1). The difference between the expected full return of wetland function following restoration and the measured level of wetland function was predominantly based on the suburban location and the effect of that location on wildlife, water, and related functions. It is not clear that the consideration of location was included in the original credit assessment. Thus there is a potential for loss of wetland function for impact projects that relied on this bank as mitigation providing full function as defined by current assessment methods. The wetland assessment area in Phase 1 (FLWt_MAR_1), which was restored approximately 3.5 yrs earlier than the wetland assessment area in Phase 29 (FLWt_MAR_2), had slightly higher scores for UMAM, WRAP, and HGM functional ca pacity index scores, except HGM Surface and Subsurface Water Storage (Table 5-4). Perh aps assessing the wetland function of similar wetland types restored over time using similar restoration techniques (i.e., a chronosequence design) would provide a reasonabl e estimate of time lag factors associated with restoration activities for specific wetland community types. However, fi nding a large enough sample size for any statistical vigor seems unlikely due to vast differences in site specific conditions.

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119 Table 5-4. Wetland assessment scores for two wetland assessment areas (FLWt_MAR_1 and FLWt_MAR_2) at Florida Wetlandsbank. Assessment methods include Uniform Mitigation Assessment Method (UMAM), three UMAM scoring categories, Wetland Rapid Assessment Procedure (WRAP), six WRAP sc oring categories, Hydrogeomorphic wetland assessment method (HGM), and four HGM functional capacity index scores. FLWt_MAR_1 FLWt_MAR_2 UMAM 0.73 0.70 Location and Landscape Support 4 4 Water Environment 9 9 Community Structure 9 8 WRAP 0.55 0.52 Wildlife Utilization (WU) 1.5 1.5 Wetland Canopy (O/S)* na na Wetland Ground Cover (GC) 2.0 1.5 Habitat Support/Buffer 0.5 0.5 Field Hydrology (HYD) 2.5 2.5 WQ Input & Treatment (WQ) 1.8 1.8 HGM Surface and Subsurface Water Storage 0.63 0.67 Cycle Nutrients 0.69 0.64 Characteristic Plant Community 0.66 0.62 Wildlife Habitat 0.56 0.53 *WRAP Wetland Canopy (O/S) was not scored for these wetland assessment areas because they did meet the minimum requirement of 20% cover by overstory /shrub canopy (Miller and Gunsalus 1999). In the case of Florida Wetland sbank and other banks located in highly develope d landscapes, the location and associated landscape support will al ways be a limiting factor in achieving full wetland function. For example, UMAM Lo cation and Landscape Support score was 4 and WRAP Habitat Support/Buffer score was 0.5 for both wetland assessment ar eas indicating that habitats outside the wetland assessment area prov ide support for generalist species, but typically fail to provide support for many wetland specialists and wildlife species that have larger home ranges than the bank can provide or that need a mosaic of habitats to complete their life cycles. Both assessment areas had the same scores fo r HGM variables that defined accessibility to wildlife for dispersal and migr ation (TRACT; 0.03 out of 1.00), interior core habitat and vulnerability to fragmentation (CORE; 0.38 out of 1.00), and habitat connectivity (CONNECT; 0.10 out of 1.00). Reasons for low landscape and connectivity scores included: substantial barriers for terrestrial species to reach the greater Everglades system to the west from roadways, canals, and urban structures (Fi gure 5-3); nearby urban areas provi ded a constant seed source for exotic species of vegetation, including the in vasive exotic punktree; and alteration of the hydrologic discharge from the property. Whereas, hi storically this area w ould have contributed to the regional water budget with sheet flow st yle drainage, now the down stream areas receive a point source outflow into a SFWMD canal, which drai ns to the east rather than into the greater Everglades system south and west. Florida We tlandsbank was thought to act as a water purifier

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120 for the SFWMD canal water, a gain of local wetland function by tr eating urban run off, but that water is no longer part of the greater Everglades system, a loss of regional wetland function. The HGM assessment also gave all organic flats wi th rock plowing a 0.00 variable score (MICRO) because of the loss of water storage capacity. Even if restoration activities (i.e., grading) can account for recreating some micr otopographic relief, the drop in elevation associated with scraping the site down to the be drock can never regain the same storage capacity (Noble et al. 2002). Lew Lautin, in his testimony before the House of Representatives, went on to state that . when circumstances favor mitigation banking, it has proven to be a viable and successful alternative that ensures a true no net loss of wetland functional values (pg. 4). It is true that the wetland resources at Florida Wetlandsbank are ra re for urban Broward County and that the aesthetic and recreational resources provided are a positiv e contribution to the area. However, in regards to wetland function, ther e has been a net loss when assumptions of full functional restoration are perpetuated. For example, while local water treatment and nutrient cycling has been restored, contribution to th e regional water cycle has not. In addition, wildlife species found within the wetland boundaries that can carryout their life cycles with in narrow strips of upland or that can fly over urban developmen t can succeed within the bank; however, ground limited species and those needing larger areas will not succeed. This is not to say that the wetland function has not been enhanced at the bank, but simply that it was not restored to full function.

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121 Case Study: Sundew Mitigation Bank Located in the southeastern corner of Clay County (S26,27,34,35/T7S/R26E), Sundew Mitigation Bank encompasses 851.7 ha (2,104.6 ac) Over half of the site (57%) was characterized as wetland (488.7 ha), with just under 6% of the wetland area (or 28.6 ha) considered largely unaltered by s ilvicultural activities. Only approximately 1.5 ha, less than 1% of the uplands, of native-like forest (scrubby flatwoods) remains, according to the Individual Environmental Resource Permit Technical Sta ff Report (Staff Report) dated August 7, 2001. This property was used for turp entine production in the early 1900s By the 1940s, the entire property, including most interior wetlands, was clear cut, root raked, and bedded. A 1970s land use cover map (file USGSLU, available at: http://www.fgdl.org/ ) showed a majority of the property as FLUCCS code 4200 Upland Hardwood Forests with a strand of 6100 Wetland Hardwood Forests. The apparent shift from pine dominance (for turpentine and harvest) to hardwood species dominance was most likely a re sult of rapid hardwood re-growth following extensive pine harvest, suggestin g the site was harvested again in the late 1960s or early 1970s. Silvicultural practices were active up until the property became a bank. Digital orthographic quarter quads from 1995 show that the middle section of the property had recently been harvested (Figure 5-3A), with the remaining ar eas harvested before the 1999 digital orthographic quarter quads were flown (Figure 5-3B). The Staff Report states that a majority of the upland areas host six-year-old slash pine (Pinus elliottii) planted on 0.9-1.5 m (3-5 ft) centers in 2001. The rows of young pine can be seen in the 200 4 digital orthographic quarter quads (Figure 53C). Mitigation activities at Sundew Mitigation Bank included ending silvicultural activities, eliminating most bedding, restoring water leve ls and patterns, enha ncing native forest communities through planting, creating small herb aceous wetlands, and implementing prescribed fire. While the permit was issued August 7, 2001, lit tle had been completed four years later. The only recent activity that was noted was some clear cutting. The ground was impacted with rutting by machinery and woody debris. Hydrologic alterations draining the site were still in place. Sundew Mitigation Banks permit allowed 698.3 potential credits, as stated in Exhibit 3 of the Staff Report (Table 5-5). As of October 2006, 194.2 credits had been released, representing just under 28% of the total potential credits. Th e federal Mitigation Banking Instrument (MBI) suggested 930.9 total credits were available. It was unclear from either the MBI or the state permit why the credit determination was different fo r the state and federal agencies. The credit release schedule in the SJRWMD permit was also set up somewhat differently than the federal MBI. The federal permit had more detail and di fferent success criteria and credit release. Federal documents were not acquired for all ba nks, and the federal MB I success criteria for Sundew Mitigation Bank were included here as an example of the differences between state and federal requirements. Note that this was one example, and all state and federal permits do not share the same similarities and differences. One of the primary differences between the state credit release schedule (Table 5-5) and the federal credit release schedule (Table 5-6) was th e large difference between the percent of credits

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(A) (B) (C) Figure 5-3. Landscape location of Sundew Mitigation Bank (green line) in Clay Co unty and surrounding land use in A) 1995, B) 1999, and C) 2004. Images are digital orthographic quarter quads. Green line is wetland mitigation bank boundary; blue (Sun_FOR_1) and orange (Sun_FOR_2) lines are wetla nd assessment areas for field assessment methods.

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123 Table 5-5. State permit credit release schedule for Sundew Mi tigation Bank from SJRWMD technical report. Activity Credit Release Percent Release Conservation easement 139.66 20% Cut planted pines 69.83 10% Harrow the bedding 69.83 10% Complete hydrologic enhancement construction 69.83 10% Complete tree plantings 34.92 5% Document hydrologic enhancement (with minimum 3 years monitoring) 34.92 5% Document tree assemblage and densities met After 1 year monitoring indicates success 27.93 4% After 2 year monitoring indicates success 27.93 4% After 3 year monitoring indicates success 27.93 4% After 4 year monitoring indicates success 27.93 4% After 5 year monitoring indicates success 27.93 4% Final success achieved with mini mum 5 years monitoring* 139.66 20% Total 698.30 100% 100% of created wetland credits will be released only after a minimum of 3 years of monitoring indicates successful establishment awarded for mechanized or phys ical activities versus credits awarded for monitoring and demonstration of success. For example, 45% of the credits aw arded through the state credit release schedule came from monitoring and docum entation of meeting permit specified success criteria; whereas only 11% of th e credits awarded through the fe deral credit re lease schedule came from monitoring and documentation of success. In fact, the state credit release schedule allocated 20% of the credits for reaching final success after a minimum 5 yr monitoring period. The federal credit release schedule, however, pl aced emphasis on construction based activities on the assumption that removing undesirable species (i.e., slash pine), removing silvicultural bedding, and removing unnatural drai nage features would lead to full restoration of wetland function. The implementation of such activities resulting in restoration of full wetland function remains untested. Two wetland assessment areas (Sun_FOR_1 a nd Sun_FOR_2) were selected for field assessments within Phase 1 at Sundew Mitigatio n Bank (Figure 5-3), both characterized as 6300 Wetland Forested Mixed wetland communities (SJRWMD 2000 land use cover map). The first wetland assessment area (Sun_FOR_1) included one area with a fairly closed canopy and one area with a more open canopy due to past harves ting with extensive evidence of recent hog rooting. Because these areas did not have distinct boundaries and they clearly comprised one contiguous wetland, these areas were scored as one wetland assessment area. The second assessment area (Sun_FOR_2) was characterized as floodplain forest though the strip of remaining floodplain vegetation had been greatly re duced due to past silvicultural encroachment into the wetland. There were occasional cypress (Taxodium spp.) in the canopy with some large

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124 Table 5-6. Federal permit credit release sche dule from the Mitigation Bank Instrument for Sundew Mitigation Bank. Activity Percent Release Place conservation easement 15% Eliminate planted pines per plan 15% Eliminate and Cross-cut bedding Year one 10% Year two 5% Year three 5% Eliminate unnatural drainage structures and washouts 10% Supplemental canopy tree planting Year one 6% Year two 5% Year three 5% Year four 5% Year five 8% Demonstrate Improved Wetland Hydrology Year one 2% Year two 2% Year three 2% Demonstrate <5% exotic nuisance plant cover Year one 1% Year two 1% Year three 1% Year four 1% Year five 1% Completion and Success of Created Herbaceous Wetlands 100% loblolly bay (Gordonia lasianthus) throughout, though much of the cypress had likely been harvested in the past. No evidence of cypr ess regeneration was found. Water flowed in a distinct channel through the cen ter of this assessment area, di rectly connecting it to other wetlands throughout the bank a nd draining to the south. Assessment score ranged from 0.65 to 0.77, with Sun_FOR_1 having UMAM and WRAP scores of 0.67 and 0.65 and Sun_FOR_2 having UMAM and WRAP scores of 0.77 and 0.73, respectively (Table 5-7). State credit allocati on was based on mitigation ratios; however federal credit allocation was based on M-WRAP calculati ons with scoring worksheets available. All with-bank scenarios in the federal MBI for we tland polygons predicted a score of 3.0 for each M-WRAP scoring category and th erefore an overall 1.00 M-WR AP score after restoration, enhancement, or creation activities were comp leted. M-WRAP scores for current (pre-bank) conditions from federal documentation at th is bank ranged from 0.56-0.83, which encompassed the range of scores for the two wetland asse ssment areas in this study (Sun_FOR_1 and

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125 Table 5-7. Wetland assessment scores for two wetland assessment areas (Sun_FOR_1 and Sun_FOR_2) at Sundew Mitigation Bank. Assessment methods include Uniform Mitigation Assessment Method (UMAM) with its three scoring categorie s and Wetland Rapid Assessment Procedure (WRAP) with its six scoring categories. Sun_FOR_1 Sun_FOR_2 UMAM 0.67 0.77 Location and Landscape Support 6 7 Water Environment 8 9 Community Structure 6 7 WRAP 0.65 0.73 Wildlife Utilization (WU) 2.0 2.0 Wetland Canopy (O/S) 2.0 2.0 Wetland Ground Cover (GC) 1.5 3.0 Habitat Support/Buffer 2.0 2.0 Field Hydrology (HYD) 2.5 2.5 WQ Input & Treatment (WQ) 1.6 1.6 Sun_FOR_2). While specific condi tions within the wetlands can be expected to improve with the implementation of mitigation activities such as improved community structure and hydrologic conditions, it is uncertain that full functi on could ever be attained at this location. The disruption of neighboring lands to the southw est through mining activit ies (Figure 5-4B, C) will influence site hydrology, species exchange, a nd wildlife habitat suppor t. Additionally, the proximity of US-17, a busy highway to the northeast, acts as a wildlife barrier between the bank and Bayard Conservation Area. As well, the occurrence of residentia l areas along the eastern boundary and the abundance of silvic ultural activities in the vicin ity suggest that the landscape will never provide all of the benefits and connections necessary for full wetland function. Further, without-bank scenarios in the MBI used to calculate the delta for credit determination seemed overly depressed. For example, in one polygon (e.g., W-1) the Ve getation Overstory (an M-WRAP category analogous to WRAP Wetland Ca nopy) scored 0.0 under the assumption that all cypress would be harveste d. Also, Adjacent Upland Buffer (analogous to WRAP Habitat Support/Buffer) received a score of 0.0. While it might be possible to completely eliminate both the vegetative structure of the wetland and th e surrounding lands, current regulations regarding urban development would require some compensa tion for such loss, and these scores seem inappropriate for without-bank scenarios. Ov erall, the prospects of Sundew Mitigation Bank ever achieving full wetland function, documente d through perfect WRAP or M-WRAP scores, seems unlikely, and a net loss of wetland function likely.

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127 CHAPTER 6 DISCUSSION When this proposal was drafted in 2004, only 34 Florida wetland mitigation banks had been permitted. By October 2006, that number had increas ed to 45 permitted banks in Florida. As a result of this rapid increase in banking in Florida, this study ha d the opportunity to identify the current ecological function provided by permitted wetland mitigation banks across a broad spectrum of activity, from those sites where mitiga tion activities had not yet occurred to those banks deemed successful. The following sections describe overall conc lusions drawn from permit and documentation review and from field assessments. First, we present eight recommendations to improve permits and mitigation plans. Second, we discuss consider ations for basing success criteria on indicators of ecological integrity. Third, we present a brief discussion on project limitations and future research direction, followed by concluding remarks. Permit Review Generalizations regarding permits were difficult considering the vast di fferences in wetland community types, regional variations in exotic and nuisance species of ve getation present, varied expectations of wildlife use, di fferent anticipated fire regimes based on community type, assorted methods of potential credit determination, and differences among overseeing agencies (Florida Department of Environmental Protection, FDEP ; South Florida Water Management District, SFWMD; Southwest Florida Water Management District, SWFWMD; or St Johns Water Management District, SJRWMD). All of these factors contributed to somewhat unique permit requirements for each wetland mitigation bank. One consideration regarding wetland mitigation banks was the lack of any centralized oversight structure that followed the mitigation bank from initial permit ap plication review through final credit release, combined state and federal regulations and over sight, and warehoused important documentation such as permits, credit releas e requests, monitoring reports, and any other additional correspondence and proceedings relating to banks. The management of banks by four separate agencies within the state and the time la g between state and federal processing appeared to confuse and delay the process of permitting Florida banks. In contrast, having multiple agencies responsible for permitting did not overloa d one single agency with all permit requests, though it did increase the differences among ba nk permits within the state. Sharing all documentation in a transparent, accessible, cent ralized, digital fashion from pre-permit through final success would facilitate compliance tracking and auditing. Eight recommendations for improving permits a nd/or mitigation plans were developed from review of permits and documentation at 29 Florida mitigation banks. These included: 1. Define natural communities and associated reference standard conditions; 2. Emphasize groundcover restoration; 3. Monitor plant and animal community structure, not just presence or cover of exotic or nuisance species; 4. Establish and implement fire management plans; 5. Identify sustainability of m itigation within the landscape;

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128 6. Allocate a higher percent of credits for achievi ng success criteria a nd a lower percent of credits for task completion; 7. Encourage better coordination and standardiz ation among state and federal agencies and between bank managers and agency personnel; and, 8. Increase compliance responsibilit ies of the regulatory agencies. These suggestions are intended to facilitate improvement in th e ecological condition of wetland and upland communities within banks permitted in the future. Natural Communities Chapter 373.4135, F.S. states Mitigation banks and offsite regional mitigation should emphasize the restoration and enhancement of degraded ecosystems and the preservation of uplands and wetlands as intact ecosystems rather than alteration of landscapes to create wetlands. This is best accomplished through restoration of ecological communities that were historically present. The Society for Ecological Restor ation International (SER) defines ecological restoration as the process of assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed (SER 2004, pg. 3). Th e Environmental Resource Permitting Basis of Review defines restoration as converting back to a historic condition those wetlands, surface waters, or uplands which currently exist as a land form which differs from the historic condition (SJRWMD BOR 2.0(vv)). Both th e SER and SJRWMD defi nitions point to a need to understand the historic condition or a recove red condition of the intended comm unity. Therefore, defining the targeted ecological community or reference standa rd condition is imperative in mitigation banks. While some mitigation plans for banks clearly de fine the targeted natural community type and restoration goals, many more do not. Language commonly encountered in permits suggests that mitigation areas would resemble a particular co mmunity type, but rarely were explanations given as to how this resemblance would be dete rmined. In fact, sometimes the resemblance would be based on similar percent cover by a singl e species. While ecological statistics can be quite complicated, some simpler functional a ssessment tools are available to provide a quantitative comparison of community structure, such as indices of biotic integrity (i.e., Florida Wetland Condition Index, FWCI), or functional assessment techniques (i.e., Hydrogeomorphic approach to assessing wetland func tion, HGM). Further, in a re view of restoration projects described in the first 11 volumes of the journa l Restoration Ecology, Ruiz-Jaen and Aide (2005) mention group comparisons (i.e., ANOVA, ttest), ordination (i.e., DCA), and linear comparisons as the three common st atistical methods for evaluating restoration success. Surely some quantitative means of evaluating similarity to a reference standard community could be incorporated into permit success criteria. Ecosystems are inherently variable as they or ganize around constant change s in driving energies (i.e., sunlight, rainfall, etc.) and natural disturbances (i.e., wind storms, hurricanes, fire, etc.). Defining the target reference st andard condition and having a refe rence database and/or nearby field sites for comparison are crucial to understa nding the expected range of variability for a community type. In many instances having bot h would be ideal, as a reference database provides representative conditions across the region or state and lo cal field sites provide for an understanding of current local variation. Unfortuna tely, a state-wide reference database does not exist, though restoration planning, monitoring, an d assessment would benefit from such a tool.

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129 Florida banks are not alone in their lack of cl early defined target natu ral communities. In a nationwide study on wetland mitigation, the Environm ental Law Institute (ELI 2002) found that a clear and uniform definition of wetland type was rarely included in bank permits and documents, despite indication within the documents suggesting a standard wetland classification systems would be used, typically that of Coward in et al. (1979). Further, Ruiz-Jaen and Aide (2005) noted that existing laws in the United Stat es do not require restora tion success as defined by comparison to reference standard communities, and that given financial concerns, such as increased costs for monitoring reference sites as we ll as restoration sites, it is unlikely that such comparisons to reference sites will be required fo r future restoration efforts. While the Uniform Mitigation Assessment Method (UMAM), which is now the required assessment method for determining potential credits at wetland mitigat ion banks, does require the assessor to describe the wetland assessment area by FLUCCS code or other classification scheme, functions, and anticipated common and listed wildlife utilizat ion, it does not require field comparison to a reference standard community. Perhaps the Fl orida Natural Areas Inventory (FNAI) Guide to the Natural Communities of Florid a (1990) would be a more useful classification for managers planning restoration activities th an FLUCCS codes, as FNAI provi des a detailed description of each of Floridas native communities. In addition to defining a reference standard c ondition for a community type, baseline conditions should be established. Moore et al. (1999) state that the need fo r restoration acti vities and the evaluation of restoration success are based on diffe rences between current and reference standard condition. While some permits did establish the current condition of the environmental resources for the determination of preservation cr edit release (credits available for preservation credit release can be calculated as the differe nce between the current condition scores minus the without bank scenario, Story et al. 1998), this depended on the met hod used to calculate potential credits. The baseline condition should be calculated for all communities within banks. This is particularly important if a bank falls out of complia nce and the baseline wetland function has been diminished. Such was the case for at least one bank that stalled restoration activities, fell out of compliance, and thus had more work to attain permit success criteria due to the delayed activities and the growth of both exotic and nui sance species that expanded during an extended period of inactivity leading to a se t back in restoration progress. Groundcover Restoration Restoration of different commun ity types requires more than replacement of canopy structure alone. While the canopy no doubt influences a great deal about the community (e.g., microclimate, Breshears et al. 1998; air turbulence, Patton et al. 2003; etc.), there is more to restoring natural communities than simply planting or growing trees. However, most restoration plans rely on natural processes alone to esta blish non-canopy vegetation (Clewell 1999). In a study of Florida Everglades marsh restoration, Sm ith et al. (2002) support that active vegetation management must be used along with hydrologic re storation in order to restore the herbaceous vegetation to the target re ference standard condition. Beyond plantings, Mitsch and Wilson (1996) suggest that allowing nature to participate in the wetland community design through multiple-seeding, multiple-transplanting, and allowing genetic material to enter through hydrologically c onnected systems is an appropriate means of

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130 vegetative restoration. In a restoration site in south Florida, David (1999) suggested that colonization of a restored marsh by pickerelweed (Pontederia cordata) occurred due to the hydrologic connectivity of the restored site with a drainage ditch that hosted pickerelweed. For restoration at wetland mitigation banks, it may be important to include connectivity to off-site wetlands and uplands, not just for hydrologic rest oration but to increase the inflow of genetic vegetation material as well. In restoring flatwood ecosystems, many of the banks have success cr iteria tied to survivorship of planted pine trees, but relatively few in clude specific success criteria for groundcover composition in these areas. However, gro undcover plays an importa nt role in these communities, particularly for carrying fire and providing food and nesting materials for wildlife. When wet flatwoods have had groundcover or hydrologic disturbance, overall community recovery is poor (FNAI 1990), suggesting the im portance of actively restoring the groundcover in such communities. An important part of achieving success in groundcover restoration includes adequate site preparati on prior to planting, seeding or allowing natural regeneration to occur. Perhaps in such communities success crit eria should be more cl osely tied to groundcover composition similarity to the target reference st andard condition in add ition to or instead of survivorship of planted tree species. Community Structure An apparent oversight in many mitigation plans is the lack of consideration of target community structure for both flora and fauna. Some permits require a minimum percent cover of a desirable species or percent plant cover that resemble s a reference standard community and limit the percent cover by exotic and/or nuisance species. Ten of the 29 permits reviewed in this study had wildlife requirements for determination of success, and seven of these included qualitative wildlife monitoring. Restoration of wetland a nd upland communities should focus on the target wildlife community structure as we ll as the vegetative community structure. It is not enough to believe that if you create a sim ilar vegetative structure, the w ildlife will come back. Instead, attention should also be given to establishment a nd maintenance of desired wildlife communities. Further, it is recognized that currently many available assessment methods clearly aim to measure community structure, with the assump tion that restoring community structure will equate to returning community function. However, a simple list of speci es occurrence does not provide an adequate means of assessing ecosystem function (Mitsch and Wilson 1996). Ten years ago Mitsch and Wilson (1996) recognized the need for linking structural measures such as species diversity, productivity, or cover, with impor tant ecosystem functions such as wildlife use, nutrient cycling, or organic matter accumulation. Studi es have noted that the return of the water storage or water quality functions at restoration sites does not always equate to targeted community structure or wildlife habitat f unctions (e.g., Brown and Veneman 2003, McKenna 2003, Zampella and Laidig 2003) Further, McPherson and DeSt efano (2003) suggest that a quantitative, objective description may be required to assess the effectiveness of management activities on community structure. Establishing community structure targets through applic ation of functional a ssessment tools that provide a quantitative comparison of community structure, such as indices of biotic integrity

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131 (i.e., Florida Wetland Condition Index, FWCI), or functional assessment techniques (i.e., Hydrogeomorphic approach to a ssessing wetland function, HGM), may improve the structural component of wetland mitigation banks. The underlying support for using biological indicators is that organisms have an intricate relationship with their environment, which reflects current and cumulative ecosystem conditions (Karr 1981). Biol ogical indicators reflect chemical exposure and also integrate changes in the community compos ition of the ecosystem (from physical, chemical, and biological changes) (Adams 2002). Currently the FWCI is only available for three wetland community types (i.e., depressional herbaceous, de pressional forested, a nd forested strand and floodplain wetlands) and three community assemblages (i.e., diatoms, macrophytes, and macroinvertebrates) for Florida wetlands. Sim ilarly, indices of biotic integrity should be developed for other species assemblages, as has been the case in other states for fish (Schulz et al. 1999), birds (OConnell et al. 1998), and amphibians (Micacchion 2002). Developing bioassessment tools based on additional community assemblages (e.g., bird, amphibians, etc.) and for additional wetland types (e .g., cabbage palm hammock, Ever glades flats, etc.) for the state of Florida would help provide means to qu antitatively compare community structure. In fact, biological assessment data for multiple community assemblages will provide a more complete picture of ecosystem condition (Reiss and Brown 2005a). Application of the HGM approach is also limite d by method development and field testing, as currently guidebooks are available for a limited set of wetland community types in Florida: 1. Flats wetlands in the Ev erglades (Noble et al. 2002); 2. Wet pine flats on mineral so ils in the Atlantic and Gulf Co astal Plains (Reinhardt et al. 2002), which includes far northeastern Florid a but excludes penins ular Florida, though the authors suggest the same m odel may be applicable to peni nsular Florida with limited modification; 3. Low-gradient, blackwater riverine wetlands in peninsular Florida (Uranowski et al. 2003); 4. Depressional wetlands in peni nsular Florida (N oble et al. 2004). Increased field testing, developing guide books for other wetland community types, and expanding the geographic regions of Florida represented by HGM models would provide further tools for quantitative comparis ons of community structure. Fire Management Fire management is crucial to successful mainte nance of many of Floridas natural communities, ranging from high-frequency fires in prairies, flatwoods, and sha llow marshes, to longer fire return interval in sw amps and hardwood forests (FNAI 1990). Yet detailed fire management plans were often not included in permits and associated documenta tion. Even wh en prescribed fire was indicated for achieving successful ecosy stem restoration, many barriers arose to prevent implementation of prescribed fire management plans. Management s hould be proactive and aggressive in conducting prescribed fires. Wh ile weather conditions ar e not always ideal for conducting prescribed fires, certain ly some day within the appropria te fire season interval should become available within a reasonable time fram e to keep fire management based mitigation activities on track. Managers should be ready to act when appropriate weather and field conditions arise. Historic Florida fire regimes ha ve been altered for over a hundred years, when human activities began to fragment the Florida landscape and pr omote activities to supp ress and extinguish any

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132 natural fires that did occur. However, re storation of groundcover in many communities is dependent on frequent lightning season fires, and successful restoratio n may be unattainable without fire management that mi mics the natural regime to the extent practical. Some banks suggest prescribed fire as a management t ool only after the canopy species have become established (5-10 yrs after planting) yet prescribed fire should be c onsidered as a restoration tool sooner to help promote the groundcover that can then support and sustai n a fire. The early establishment of appropriate pyr ophytic groundcover that includes fi ne fuels capable of carrying prescribed fire is an important consideration. Successful implementation of prescribed fire and community response to this management tool sh ould be required by m itigation bank permits and linked to credit release in fire-dependent communities. Sustainability and Landscape Position The location of compensatory mitigation sites con tinues to be an important consideration. The state of Florida has been cross ditched and drained since human settlement began, and as such, an ideal landscape setting probably does not exist wi thin the state. Having realistic goals as to the potential function of a wetland mitigation ba nk should be a priority for assessing with mitigation bank scenarios. A bank surrounded by human development land uses or in areas that are likely to support human development activities in the near future s hould not receive perfect landscape scores for with mitigation scenarios. Consideration of potential wetland functional lift should incorporate a landscape perspective, whic h could include application of available tools such as both the wetland scale and bank scale LDI index, reflecting both the local and broad scale landscape support. The relatively rece ntly adopted UMAM does consider location and landscape support in its scoring. Finding a significantly large tract of land on which to locate a ba nk in Florida, or the United States, may be impossible, as Forman (2000) su ggests that approximately 20% of the land area within the United States has experienced direct ecological effects from the public road system. This 20% figure is expected to rise in the future, suggesting that roadways will continue to act as a major influence on the community structure and wildlife habitat suitabili ty for Florida wetland mitigation banks. While the Criteria for Esta blishing a Mitigation Bank (62-342.400 (1) (f), F.A.C.) states that the wetland mitigation ba nk should be adjacent to lands which will not adversely affect the perpetual viability of the Mitigation Bank due to unsuitable land uses or conditions (pg. 538), this criteria may be overlooked when deciding to approve the location of a proposed wetland mitigation bank. For example, mitigation banks adjacent to or bisected by highways is a concern, as highways act as significant barriers for wildlife. In a study on the mortality of amphibians, reptiles, and other wildlife along a two-lane pa ved causeway, Ashley and Robinson (1996) found over 32,000 individuals died in two two-year periods along the road. In another study from Boston, Massachusetts, researchers found the impacts of a major four-lane road extended at least 100 m and perhaps more than 1 km for some effects (Forman and Deblinger 2000). Further examples of the significant impacts roads play in disturbing wildlife include the mortality of herpetofauna along US-27 in Lake Jackson, Florida (Aresc o 2005), which are a co mmonly overlooked though major biotic component of freshw ater wetlands (Gibbons 2003). In addition, rarely have female Florida panthers (Felis concolor coryi) been found to cross major ro ads or use underpasses, so

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133 their habitat is still essentially fragmented by roads even where underpasses have been constructed (Maehr 1988, as cited by the Florid a Fish and Wildlife Conservation Commission at http://myfwc.com/panther). These studies sugge st that roadways and conservation areas should be well separated, and yet many of the Florid a banks are bordered by busy roadways (e.g., Barberville is bordered to the south by SR-40; Ev erglades Mitigation Bank/Phase I is bordered to the east by Card Sound Rd. a nd the west by US-1 ; etc.) or bisected by busy roads (e.g., Tosohatchee is bisected by the Beach-Line High way SR-528; Little Pine Island is bisected by SR-78; etc.). In addition, a recently permitte d bank, Wekiva River, has been targeted as a potential area to be impacted by a futu re highway serving the Orlando area. A further concern regarding landscape support is the presence of tall transmission towers on or near bank property that may occur within avian f light paths. A few banks (e.g., Panther Island) are situated adjacent to such towers, and species attracted to the mitigation site may be endangered by neighboring structur es. For example, in a study on bird mortality in central Florida, Taylor (1973) found hundreds of black-t hroated blue and Cape May warblers were killed in a six week period in September and October at the WDBO-WFTV TV Tower, in the autumns of 1969-1972. In a more recent study by Crawford and Engstrom (2001), a total of 44,007 individuals of 186 species were collected at the WCTV television to wer in north Florida, and over 94% of the total number of individuals were Neotropical migrants. The study spanned a 29-yr period, one of the longest of its kind. Th ey found that towers approximately 94 m or lower may not pose as great a threat to avian mortality as caused by towers 200 m or greater. Clearly the position of banks in urban lo cations, near highways, or adjace nt to transmission towers will have unintended consequen ces for mobile species. Further, McAllister et al. (2000) suggest that the landscape location at a regional scale that would maximize the functional gain from wetland restora tion is frequently ignored. While the primary focus of that study was the function of flood attenuati on, certainly this is true of other functions. In the end, all restoration, mitigation, and c onservation areas must contend with human development activities. Conve rsely, a recent study on the demographics of Florida banks suggested that the locati on of banks in more rural areas redistributes wetland resources and the associated ecosystem services away from urban areas and thus removes some of the services afforded by these systems (Ruhl and Salzman 2006). Locating banks within developed urban areas may improve the distribution of certain ecosystem services acro ss the landscape (e.g., flood attenuation), but it will not improve the total potential function that could be attained on a site. Wetland mitigation in general must be consider ed a trade-off between temporal and spatial ecosystem function, and th e bottom line comes back to a rea listic expectation of attainable function in the calculated with mitigation bank scenario. That is, when a bank is adjacent to developed lands, the location and landscape functi onal component should ne ver be expected to achieve a perfect score. Similarl y, when a bank is located in an area spatially distant from the impact site, some local loss of wetland function s hould be anticipated and offset as appropriate through other components of wetland regulation, such as floodplain compensation and surface water treatment and attenuation. A national study by Brown and Lant (1999) found that the spatial location of banks was ofte n in downstream or coastal locat ions, so that replacement may not be providing equal function as from the we tlands lost in the upper watershed. Significant loss in wetland function from moving mitigation wetlands towards the bottom of a watershed may be manifest in loss of flood control (O gawa and Male 1986 as cited by Brown and Lant

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134 1999) and change in water quality benefits (P eterjohn and Correll 1984), which should be taken into consideration when defining the mitigation bank service area. Credits for Achieving Success Criteria When reviewing bank permits and supporting docum entation, it became clear that much of the credit release was tied directly into completion of specific tasks such as grading, ditch plugging, or canal filling. Because the concept behind comp ensatory mitigation is to prevent no net loss of wetland function and the function attributed to ba nks is meant to be in place prior to impacts (Federal Guidance for the Establishment, Use and Operation of Mitigation Banks 1995), more credits should be tied into demonstration of ac hieving function and less into task completion. Early credit release is probably necessary to maintain the economic incentive of establishing and operating a bank, and limited initial credit re lease based on acquisitio n of a conservation easement and demonstrating financial assurance seems justified. However, continued credit release based on completion of activities that do not necessarily equate to demonstrated improvement of function should be avoided. Cr edit release criteria should be explicit and measurable, and demonstration of trending toward s success should be the most important factor in further credit release. Mits ch and Wilson (1996) argued a decade ago that efforts to determine wetland restoration or creation succe ss are flawed due to a lack of application of sound wetland science and the weight of schedule-driven cons truction activities, and yet many of the success criteria of permits were focused on task completion. Both the FDEP and WMD rules on mitigation banking state that a mitigation bank permit must include the success criteria by which the mitig ation bank will be evaluated. (12.4.9(a)3, SJRWMD Applicants Handbook; Ch. 62-342.750(1)(c), F.A.C.) The FDEP rule goes on to state that Success means when a Mitigation Bank m eets the success criteria provided in Section 62-312.350, F.A.C., and in the Mitigation Bank Permit. Section 62-312.350, F.A.C. deems mitigation successful if three conditions are met: 1. All applicable water quality standards must be met. The state of Florida does not currently have water quality standards that specifically address wetland water quality, however the general state water quality stan dards established in Chapter 62-302 Surface Water Quality Standards, F.A.C. apply. Ra rely did bank permits require water quality monitoring, and in the few permits that did mention water quality, generally it was in regard to monitoring turbidity during construction activities. 2. The mitigation project must have sufficien t hydrology to sustain it. This was sometimes identified in permits as having a specified acreage of jurisdictional wetland, pursuant to Section 373.421, F.S. It seems intuitive that success of wetland restoration, enhancement, preservation, and particular ly creation projects should be deemed successful only if they can be clearly identifie d as jurisdictional wetlands, though not all bank permits specified this condition. In a study of compensatory wetland mitigation throughout the United States, ELI (2002) found that nationwide just over half of wetland mitigation banks with explicit performance standards include hydrologic criteria. 3. For mitigation success, the project must meet permit specific success criteria. Generally this was the main condition identified to determine success for banks. As noted above, particularly in the discussions of natu ral communities, groundcover, and community

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135 structure, many permits do not state the intended target community, establish a reference standard condition, or c onsider groundcover and other community components in the determination of success. Another controversy surrounding th e awarding of potential cred its deals with the types of mitigation and the communities receiving credit s including creation and preservation of wetlands and preservation of upland areas. Genera lly the greatest amount of potential credits is awarded for wetland creation as it represents the greatest potential lift, despite the low success rate of attaining wetla nd function with such endeavors (Sto lt et al. 2000, ELI 2002) In addition, there is some loss of upland f unction in areas converted to we tland, and the redistribution of wetlands across the landscape should be consider ed. However, state rules require that no credits awarded for freshwater wetland creation shall be released until the success criteria included in the mitigation bank permit are met (12.4.5(c), SJRWMD App licants Handbook; Ch. 62-342.470(3), FAC), thereby addressing the qu estion of success rate for creation. The Federal Guidance for the Establishment, Use and Operation of Mitigation Banks (1995) states that preservation shoul d only be used under exceptional circumst ances, yet Section 373.4135, F.S. states that Mitigation banks shoul d emphasize the restoration and enhancement of degraded ecosystems and the preservation of uplands and wetlands as intact ecosystems. Preservation acreage made up a major component in some Florida banks. A similar disconnect was found regarding awarding credits to upland areas. While many studies suggest the importance of uplands in bufferi ng wetland and aquati c ecosystems, providing support habitat for valuable wildlife species, a nd protecting the functional integrity of these systems (i.e., Brown et al. 1990, JEA 1999), pres ervation or enhancement of upland ecosystems alone do not increase total acreage of wetland in the landscape. However, the state directs mitigation banks to include both uplands and wetlands in banks as intact ecosystems (Section 373.4135, F.S.). Coordination and Standardization among Agencies In a study of compensatory wetland mitigation across the United States, ELI (2002) suggested that differences among permits and supporting docum ents make comparisons difficult. This is true not only between fe deral and state documents, but also among documents from the four state agencies that permit Florida mitigation banks : FDEP, SFWMD, SWFWMD and SJRWMD. In fact, simply tracking down documentation for each bank proved difficult in many instances. A new internet-based tracking system for United States Army Corps of Engineer (Corps) to monitor banks, called the Regional Internet Bank Information Tracking System (RIBITS), should provide a warehouse for bank documentation at the federal level. The RIBITS interface will allow Corps staff and the general public to track the status of banks, track credit release and credit debits, see compliance reports, and ema il information requests. A similar electronic database for tracking and storing bank permits at the state level would be useful. However, suggestions for centralized databases have been made in the past (e.g., Ke ntula et al. 1992) with little recent progress.

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136 Similarly, having a standard format for permits i ssued by state agencies would enable quick and efficient comparison among the state banks. This would also ensure that important information has not been overlooked. While the Mitigation Bank Review Team (MBRT) established through the Joint State/Federal Mitigati on Bank Review Team Process for Florida (Story et al. 1998) provides a forum for state and federal agencies to work together on bank reviews, the MBRT and recommended procedures are not binding on any of the agencies. In a few instances, the state and federal permits diverged in important points which leaves conf usion over key issues, such as the number of potential credits. Regulatory Agency Compliance Responsibilities While time and costs are no doubt limiting factors in the availability of agency personnel to conduct frequent and thorough site visits, increasi ng agency oversight and interactions with bank managers should enhance overall compliance and achievement of final success. Frequent inspection should provide motivation for bank ma nagers to maintain and improve ecosystem function between site visits. At a minimum, no agency should release credits without a bank inspection of sufficient detail to confirm that monitoring reports correctly document site condition and that required rel ease criteria have been met. Site visits are important to help understand th e unique characteristics of each bank. In some instances, the quality and detail provided in a mo nitoring report does not re flect the quality of on the ground efforts. Wetland ecolog ical condition and progress of restoration efforts are highly dependant on the knowledge and experience of the land manager and the interaction of the bank manager with the respective regulatory agen cy. FDEP, SJRWMD, SFWMD, and SWFWMD all operate somewhat differently regarding permit and compliance for banks. It appears that typically for FDEP the same individual is re sponsible for permit review and following up with compliance. However for SFWMD different indi viduals are responsible for each stage of the bank, so that once a permit has been approved the responsibility of compliance is shifted to someone who was not involved in the initial permit pr ocess. The benefit of this procedure is the additional oversight provided by a new individual. However, the down side is that the compliance office has no permit review experien ce with the bank manager, the mitigation plan, or the property. Ecological Integrity Before compensatory wetland mitigation is consid ered, state and federal regulations propose that first wetland impacts are avoided and second that unavoidable wetland impacts are minimized. Remaining wetland impacts are then mitigated w ith the intention of replacing lost wetland function and achieving the often proclaimed no net loss of wetland function. The impetus for wetland protection comes from protecting the physic al, biological, and chemical integrity of our Nations waters, particularly in matters of human health and economic concerns (e.g., coastal fisheries, navigation). Defining ecological integrity of a delineated wetland or water body can be done in a number of different ways, each reachi ng a somewhat different conclusion depending on what was measured and how it was quantified. There is currently no single scientifically agreed upon best method to assess the ecologi cal integrity of an ecosystem. However,

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137 developing a repeatable and objective measure of eco logical integrity that is easy to implement and unambiguous would be ideal. The variability in the wetland community types w ithin the 29 banks included in this study plus the fact that anywhere from one single wetland community type to multiple different wetland community types existed at each bank made a simple calculation of ecological integrity impracticable. In fact, most assessment method s developed to measure ecological integrity are wetland community specific (e.g., HGM, FWCI) or are simply not meant to be used as a comparison against other wetland community t ypes (e.g., WRAP, UMAM), in part due to the different ecosystem services and functions prov ided by each different wetland community type (Chapter 62-345.300, F.A.C.). Even if these issu es could be overcome, one may expect many banks would achieve similar, average scores due to the dampening effect that would come into play when scores for different community types within a bank were averaged. The number of potential mitigation credits is rel ative to that [ecological value] obtained by successfully creating one acre of wetland (Ch 62-342.470(2), F.S.). Wetland assessment areas in this study located in banks that had achieved final permit success criteria and had all potential credits released did not receive the highest po ssible scores for the field assessment methods, suggesting full wetland function had not been a ttained, as measured by these methods. Some banks near busy highways, receiving polluted wa ter (e.g., receiving water from a canal that receives urban stormwater runoff), or adjacent to high intensity human development activities (e.g., high-density single family residential), were assumed to have the potential to provide full wetland function. However, the landscape of Florida has become more urban and Florida has one of the highest rates of conversion of rural to urban land use (Reynolds 2001). Realistic withmitigation scenarios should be of primary importance for determining potential credits for a bank. This draws into question whether the same wetland functions are being restored within banks as are being lost at impact sites. Unfortunately, this study was lim ited to wetland assessment areas within banks, and we cannot comment specifically on what functions have been lost due to permitted wetland impacts. We can, however, focus on our understanding of the differences between the community structure and functional a ssessment scores of wetland assessment areas within banks and reference wetlands. In a stud y of the effectiveness of compensatory wetland mitigation in Massachusetts, Brown and Veneman (2001) found that while all projects were in compliance, plant community structure at mitiga tion wetlands was not similar to the wetlands that had been impacted, leading to a loss of wildli fe habitat and utilization functions. Even when water quality and sediment control functions we re replaced, there was still a calculated net loss of wetland function (Brown and Veneman 2001). Few studies have attempted to link community structure with function, though many assessment methods are based on the idea (e.g., VIBI, Mack et al. 2000; FWCI, Lane et al. 2003, Reiss and Brown 2005a). While community structure is c onsidered relatively easy to measure, direct measures of wetland functions are either not available or are more difficult and more time intensive. Further, there is some concern th at when restoring a single wetland function or a limited number of wetland functions, dissimilarities in community structure may still occur. A study in New York by McKenna (2003) found simila r rates of production and respiration, which

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138 are wetland functions, at a restored wetland a nd reference wetland. However, the community structure was not similar between these wetlands, and McKenna ( 2000) suggested that different foodweb pathways resulted. This is an important consideration for any form of mitigation. For example, simply restoring or enhancing hydro logic connectivity or we tland volume for flood attenuation may never result in a fully func tioning wetland consider ing all other potential wetland functions. Designing miti gation to address on ly a subset of all possible wetland functions provided by a certain wetland type coul d easily translate into a net loss of some wetland function if mitigation assumed equal impr ovement or replacement of all functions was attainable. While methods are not currently available to answer the questions about how and which functions should be restored, th ere are methods available for de termining ecological integrity. Perhaps HGM best addresses the various wetlan d functions by arriving at functional capacity index scores for each function separately. From an ecological perspective, separate accounting of each lost function may be the best means of accounting. However, from a regulatory perspective, accounting separately for each lost wetland function could further complicate the process. That does not mean this is not the best approach, but perhaps not the most realistic. One of the driving principles of ecosystem re storation lies in the concept of determining a reference standard community type. This concep t is similarly applied in the determination of ecological integrity, as community structure is compared to that of a reference standard community in order to assess ecological integrity. All of the field assessment methods used in this study were developed with regard to reference standard ecological communities. Some measures of wetland function can be calculated through rapid as sessment methods and best professional judgment (e.g., WRAP, UMAM), measures of community struct ure (e.g., FWCI), or measures of community variables (e.g., HGM). Use of the more detailed assessment methods (e.g., FWCI, HGM) may provide a clearer picture of wetland function through measures of community structure and/ or abiotic variables. Limitations to Study It is important to note that we are unable to comment specifically on the advantages of mitigation banking for maintaining no net loss of wetla nd function as compared to other methods of mitigation (e.g., on-site mitigation, in-lieu fee, etc. ). In addition, we are unable to definitively suggest there is a calculated no net loss of wetland function, as we did not compare wetlands on impact sites to wetlands in banks. This is an important avenue to be explored. What we can say is that, when permits assume that the with -bank scenario attains full wetland function and success criteria are established based on assumed attainment of full wetland function, any wetland (or upland) community in a bank that falls short of full wetland function represents a potential net loss of wetland function. Future Research Direction Two primary avenues for future research have b een identified through this study. First, further development of wetland assessment methods (e .g., FWCI, HGM) for additional Florida regions and wetland community types should be a prior ity in order to further accounting of wetland

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139 function. Second, further studies should focus on what wetland functions are being lost in wetland impact sites in relation to the mitigation provided. When this project began, the FWCI was consider ed to be one of the primary detailed assessment methods that would be used to assess wetland assessment areas within banks. However, once site visits and field sampling began, it became a pparent that the applica tion of the FWCI would be limited by wetland community type, as the FWCI has only been developed for depressional herbaceous wetlands (Lane et al. 2003), depre ssional forested wetla nds (Reiss and Brown 2005a), and forested strand and floodplain wetl ands (Reiss and Brown 2005b). Further, while separate FWCIs have been developed for diatom, macrophyte, and macroinvertebrate assemblages, site conditions during the samp ling period (May 2005-September 2006) prevented collection of diatom and macroinvertebrate samples at most sites. The general lack of correlati on among the rapid field assessme nt methods (e.g., WRAP, UMAM) with the more detailed field assessment met hods (e.g., HGM, FWCI) may be attributable to the small sample size or the variability in wetland comm unity type. It is unlik ely that there was truly no correlation among these methods, as the refe rence database used to develop the FWCI showed significant correlations among LDI, WRAP, and FWCI (R eiss and Brown 2007, in press). Although HGM and FWCI methods were more time consuming and labor intensive, further development and testing of field based biological assessment met hods and application of these tools for monitoring and assessment of rest oration, creation, enhancem ent, and preservation effectiveness for wetlands within mitigation ba nks could strengthen the foundation for a basis of calculating wetland function. In addition, undertaking a detailed study that meas ures the ecological integrity of wetlands lost from impacts compared to that gained from atta inment of permit success criteria at banks should be considered. No true calcula tion of net wetland function can be considered after-the-fact at wetland impact sites. Such a st udy would require a long time fram e, addressing initial wetland condition at the bank, wetland condition at the bank at the time of incremental credit releases, wetland condition at the bank following final release of credits after meeting permit success criteria, and assessments at each wetland impact project prior to impact that purchased credits from the bank, using the same assessment method or set of a ssessment methods throughout the study. While such a study may sound massive and unfeasible, it is seemingly the only way to truly account for functional gains or losses from compensatory mitigation and to calculate net loss. Conclusion Return of full wetland function may be an im possible goal given current and future human development activities across the Florida lands cape. A more realistic outlook on mitigation outcomes would probably reduce the amount of potenti al credits allocated fo r a particular site. Some may argue that this would reduce the econom ic incentive of mitigation banking. However, economic evaluation is beyond the scope of this study and existing state wetland regulatory rules.

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140 One of the purported benefits of wetland mitigation banks is that mitigation is in place prior to wetland impacts, which is an improvement over on-site mitigation that allows for the impact of one wetland resource prior to the enhancement or creation of another. However, for mitigation banks, it is unclear how much wetland function is act ually provided at the time of credit releases. Initial credit releases are based on recording of conservation easement, often with no additional mitigation activities or site improvements, such that there may be a temporary loss associated with this practice. Overall, most of the wetland