Title: Status Report on the Assessment of Wetland Creation for Mitigation in the SJRWMD
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Title: Status Report on the Assessment of Wetland Creation for Mitigation in the SJRWMD
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Language: English
Publisher: Department of Resource Management SJRWMD
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Spatial Coverage: North America -- United States of America -- Florida
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Abstract: Status Report on the Assessment of Wetland Creation for Mitigation in the SJRWMD, Nov 11, 1992
General Note: Box 8, Folder 3 ( Vail Conference, 1993 - 1993 ), Item 16
Funding: Digitized by the Legal Technology Institute in the Levin College of Law at the University of Florida.
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Volume ID: VID00001
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Full Text

















STATUS REPORT ON THE ASSESSMENT OF


WETLAND CREATION FOR MITIGATION IN THE SJRWMD




Department of Resource Management
St. Johns River Water Management District
P. O. Box 1429
Palatka, Florida 32178




11 November 1992


/.32























TABLE OF CONTENTS


BACKGROUND .............................


METHODOLOGY ..........................


. . . . . . . 3


ASSESSMENT AND COMPLIANCE PARAMETERS .......................... 4

RESULTS
Permit conditions and project design ................................ 6
Site evaluation ................................................. 8
Corrective measures needed ....................................... 9
Success criteria ................................................. 10
Com pliance .................................................. 12
Related Assessment Information ....................................12


DISCUSSION AND CONCLUSIONS
Creation assessment .............
Compliance ....................
Future considerations ............


.............. 14
................17




















FIGURES


Figure 1. Frequency bar chart of creation sites by county.

Figure 2. Percentage bar chart of inspected creation sites by
county.

Figure 3. Percentage bar chart of creation site areas (acres).
Chart intervals are midpoints, except intervals 1
and 10 which include areas less than 0.5 and greater than 10.5
acres, respectively.

Figure 4. Percentage bar chart of site age (in months) at time of field
inspection. Chart intervals are midpoints.



APPENDICES

Appendix A Mitigation assessment and compliance data forms.


Case examples of wetland mitigation.


Appendix B








BACKGROUND

The District considers mitigation for wetland impacts under it's Management

and Storage of Surface Water rule (chapter 40C-4 F.A.C.), and also as part of the

Wetland Resource Management Program (chapter 17-312 F.A.C.), delegated from the

Department of Environmental Regulation to the District in October 1988. Between

December 1983 and August 1992, the District issued 6,690 Management and Storage

of Surface Water (MSSW) permits and 940 Wetland Resource Management (WRM)

permits. Mitigation for wetland impacts was required for 1,096 of these permits

including 871 MSSW permits (13% of all MSSW permits) and 225 WRM permits (24%

of all WRM permits). The distribution, by county, of permits issued with mitigation

is shown in Figure 1.

Wetland creation is one of the mitigation alternatives under both of these rules.

Other possible mitigation measures include wetland enhancement or restoration and

the preservation, by conservation easement or fee simple title transfer, of both

wetlands and uplands. Of the issued permits which entailed mitigation, the vast

majority involved wetland creation either as the sole mitigative measure or combined

with another mitigation alternative. Since "wetland creation" has been so prevalently

used as a method to off-set wetland impacts, the phase has often been erroneously

used interchangeably with the term "mitigation".

Wetland creation is basically the transformation by construction techniques of

uplands (as defined under the rules) to wetlands. Typically, the site is first graded to

the appropriate elevation, i.e., the elevation which will be inundated or saturated at








duration and frequency necessary to support the target vegetative community. The

site is then usually planted with the appropriate species.

While forested wetland creation typically requires planting, some herbaceous

creation efforts have employed natural re-colonization through the transfer of

wetland organic mulch as a supplement to or in lieu of plantings. The success of a

created wetland depends on a suite of factors including elevations for grading and

planting, soil preparation, viability of plant materials, planting techniques and

maintenance.

The extent and type of wetland creation required to offset adverse effects of a

specific project depend on an evaluation of the individual site. The ratios of created

to lost wetlands are generally greater for forested than herbaceous systems due to the

longer period required for replacement and the greater difficulty in creating forested

wetlands.

In 1988 the District staff initiated an evaluation of permitted wetland creation

sites. This wetland creation evaluation is on-going and is in addition to the District's

overall compliance program which has been in effect since the inception of the MSSW

Rule and delegation of the WRM Program. Staff has intensified this study during the

past two years.

Staff has inspected 326 wetland creation sites as of August 1992 which

represent 265 permits that were issued between 1986 and 1992. Some permits entailed

construction of more than one creation site, therefore the inspection results will

always indicate a greater number of individual creation sites than permits involving








wetland creation.

The types of wetland creation inspected to date include freshwater herbaceous

(38%; 349 acres), freshwater forested (57.4%; 561 acres), saltwater herbaceous (3.4%;

46 acres) and saltwater forested (1.2%; 10 acres). A total of 966 acres of wetland

creation, or 25.6% of the total acres of wetland creation that were permitted through

September 1991, have been inspected to date (Figure 2). All of the permitted acreage

has not yet been constructed as construction has not commenced on many permitted

projects.

METHODOLOGY

Staff has developed a mitigation database which contains the assessment

information for the mitigation projects and acts as a recordkeeping tool. The first step

of current mitigation assessments is an administrative review to determine

requirements for, and compliance with, recording of legal documents, submission of

monitoring reports and as-built surveys etc. The administrative review is followed by

a site inspection to evaluate compliance with permit conditions and permitted plans

and other aspects of the site such as the "success" of the mitigation effort and

techniques employed in the construction. The content of the database has evolved

through this effort to include more detailed and relevant information. Information

from both steps is entered into the tracking portion of the database in order to

facilitate follow-up and monitor mitigation compliance.

The mitigation database is intended to eventually serve several goals: (1) to

provide an up-to-date summary of mitigation compliance actions and a framework








for effective enforcement; (2) to answer specific questions relating to design and

permitting of future wetland creation projects; and (3) to provide information

regarding long-term viability and wildlife values of mitigation efforts. Although the

database is designed to contain information for all types of mitigation, wetland

creation sites encompass the majority of those inspected to date.

ASSESSMENT AND COMPLIANCE PARAMETERS

Observations included the design criteria specified in the permit conditions

and plans, compliance information, corrective measures necessary, vegetation

survival, coverage, and characterization, and evaluation of the success and wildlife

value of the created wetland (see Appendix A).

The "compliance with permit conditions" category was a general determination

as to whether or not the creation site was built in accordance with the permitted plan

and met all of the conditions of the permit. Included in this determination were

administrative reporting requirements and site construction requirements.

Five categories of remedial measures which may be necessary were recorded.

These included regrading the site, replanting, stabilization, removal of exotics, and

controlling access.

The creation site was evaluated as to whether or not the success criteria

specified in the permit conditions and approved mitigation plan had been met.

Success criteria typically include a specified survival of plantings and percent

vegetative coverage. A final determination of success is generally made three to five

years after planting.








The District has included wildlife value and similarity evaluations in the

mitigation assessment in order to include information on those creation efforts which

may be a low priority for, or not require, corrective action because they are

functioning as viable wildlife habitat albeit perhaps of a type different than that

anticipated when the permit was issued and success criteria specified.

Wildlife value of the creation site was judged for its current value, potential

value, current similarity to the value intended in the permitting action, and the

long-term potential to provide wildlife value as intended in the permitting action.

Current wildlife value was ranked as low, medium or high based upon

observed or reasonably expected use of the site by fish and wildlife. Potential wildlife

value was similarly ranked in order to determine whether the value of sites was

likely to improve or decline as they matured and the surrounding landscape changed.

For the purposes of this assessment "potential" was a projection of about 20 years.

Current similarity to the intended value was an assessment of whether the site

provides the general type of habitat intended in the permitting action for example

"broad-leaved marsh with open water feeding pools", or "early successional

cypress/mixed hardwood forest". Potential similarity was an assessment of the

potential of the site to provide the type of habitat anticipated in the permit, i.e., are

the basic components (hydrology, grade, plantings and location) sufficient to allow

successional development into a functional wetland of the type intended in the

permit.

The wildlife value section has recently been revised to account for factors








external to the physical design, particularly those related to current and future

surrounding land use. The wildlife value and similarity also has recently been revised

from a three-point (high, medium, low) scale to a five-point scale to record more

precise information and improve the analysis. A staff training and evaluation

standardization effort is concurrently being implemented to verify the quality of the

wildlife evaluations. The information collected to date should be considered only as a

compilation of individual staff assessments until the sites are re-evaluated under the

new program.

Correlation between the current and potential wildlife value, functional

similarity to the permit intent and various aspects of the design and construction is a

key element of the database design. Results will be reported when sufficient data are

available for statistical analysis.

RESULTS

Permit conditions and project design

Wetland creation plans submitted by the applicant were referenced by 87.1% of

the permits. The remaining 12.9% of the permits had conditions which committed the

permitted to create a specific type of wetland.

A planting scheme was submitted by the applicant with 71.4% of the permit

applications. The planting scheme is basically a plan detailing the species of plants,

the number of each species to be planted and the location on the site where each

species should be planted. The 28.6% of the permits that did not include specific

planting schemes fell into three additional categories: natural recruitment and








succession following grading and transfer of wetland organic topsoil (mulch),

specification of planting details by permit condition, and those projects which had no

details for planting either submitted with the application or required by permit

condition. The latter category primarily includes the earliest permitted creation

.projects.

Mitigation specific as-builts were required for 58.4% of the permits inspected

to date; as-builts have been received for 47.5% of these permits. A portion of those

that were not received were due to confusion between this requirement and the

as-builts which have been traditionally required to satisfy those aspects of a project's

construction that were designed by a Professional Engineer.

Success criteria (i.e., a specified survival and coverage of plantings within a

specified time period) were included by permit condition for 89.4% of the permits.

Maintenance procedures were specified for 60.1% of the permits. Exotic and

nuisance species control measures were specified for 80.1% of the permits.

Contingency plans were specified for 77.3% of the permits.

Monitoring reports were required for 84.6% of the permits; reports have been

submitted for 58.8% of the these permits. The level of information in the reports is

variable.

As partial mitigation, or to protect the wetland creation areas, conservation

easements or deed restrictions over the mitigation areas were required to be recorded

for 39.4% of the permits; proof of recording has been received for 58.1% of these

permits.


__








Site evaluation


Various features of the project site were evaluated to determine whether the

construction was in general accordance with the approved mitigation plan.

Correct wetland type is a rough determination as to whether or not the

mitigation effort successfully created the general type of the target wetland for

example, cypress dome, mixed hardwood floodplain, broad-leaved herbaceous marsh.

The type of wetland created was as intended by the plans and permit conditions for

95.7% of the herbaceous and 87.5% of the forested freshwater sites. All of the

saltwater sites were constructed as the type intended.

Size of the creation site was recorded as being correct for 90.2% of all sites,

including 90.1% of the herbaceous and 89.3% of the forested freshwater sites. All of

the saltwater sites inspected were considered to have been constructed to the correct

size. The majority of the creation sites are less than 1 acre, as can be seen in Figure 3.

Grading was considered correct for 78.0% of all sites, including 88.3% of the

herbaceous and 68.4% of the forested freshwater sites. All saltwater sites were

considered to have been graded correctly.

Correct species were used in the plantings for 84.4% of all sites which had

specific planting requirements. By category; correct species were used in 88.6% of the

herbaceous and 79.9% of the forested freshwater sites. Correct species were used in

all saltwater sites. In general, sites which were not indicated as having correct species

either lacked one or more of the species specified in the permit, or no planting had

been performed on the site (both cases would represent sites which were not in








compliance.)

Planting elevations were considered correct for 78.7% of all sites, including

86.4% of the herbaceous and 71.8% of the forested freshwater sites. All saltwater sites

were considered to have been planted at correct elevations. "Correct" here is an

opinion as to whether or not the plants were planted at the appropriate elevation to

promote their growth and continued survival, rather than a determination or

measurement as to whether they were planted at a specific elevation per the

permitted plans or conditions.

Sites were indicated as having been properly stabilized (i.e., having sufficient

natural or artificial cover such that erosion and sedimentation would be unlikely to

occur) for 82.2% of all sites, including 85.8% of the herbaceous and 88.9% of the

forested freshwater sites. One herbaceous saltwater site was not stabilized.

The requirement for mulch, hydrologic monitoring and plant inventories,

either as a permit condition or approved creation plan, was not recorded on the data

form until recently.

Corrective measures needed

Due to the design of an earlier version of the data forms we cannot determine

whether "considered necessary" for these categories means "needed to create a viable

wetland" or "needed to comply with the requirements of the issued permit".

However, this clarification will be available for future evaluation. The results

presented here should be considered solely as staff opinions as to what is needed on

the site rather than as a summary for compliance purposes.








Maintenance, i.e., site stabilization, replanting, nuisance species removal, and

trash removal, was considered necessary, although not always required by permit

condition, for 44.6% of all sites including 41.7% of the herbaceous and 48.8% of the

forested freshwater sites. Maintenance was also necessary for two saltwater sites.

Maintenance was known to have been performed on 50.0% of all sites

including 59.4% of the herbaceous and 41.6% of the forested freshwater sites.

Replanting or supplemental planting was considered necessary for 42.4% of all

sites including 24.6% of the herbaceous and 58.1% of the forested freshwater sites.

One forested saltwater site needed replanting.

Regrading was considered necessary for 19.8% of all sites including 10.7% of

the herbaceous and 28.8% of the forested freshwater sites.

Nuisance species control was considered necessary for 39.9% of all sites

including 29.9% of the herbaceous and 48.9% of the forested freshwater sites. One

herbaceous and one forested saltwater site also required nuisance species control. The

type of exotic or nuisance species was not recorded, but cattails (Typha spp.) and

brazilian pepper (Schinus terebenthifolia) are major problem species on some sites. In

addition, invasion by upland species occurred on the drier sites affected by the

drought.

Success criteria

Success criteria are evaluated regularly, with a final determination usually

made at three to five years. The success criteria had been met for 27.1% of the

herbaceous and 8.8% of the forested of the freshwater creation sites which had been








established for the time frame specified in the success criteria. A cross-tabulation of

sites that failed to meet the permit success criteria with other variables in the

database indicates that the primary reason for low success rate is the need for

additional plantings (85.3% for forested sites). A need for maintenance appears to be

the secondary contributing variable. Two-thirds (66.7%) of the saltwater sites had met

the specified success criteria. Nearly one-half (48.5%) of the sites had, at the time of

inspection, not been established long enough to determine success. The distribution of

creation site age at the time of the inspection is shown in Figure 4.

The long term potential of the site to meet the success criteria both with and

without additional compliance action by the District was also evaluated. About half

(59%) of the sites were judged to be likely to meet the success criteria in the long

term without additional action; 83% of the sites were judged likely to meet the

success criteria with additional action by the District and the permitted. The cause of

the remaining 17% that are unlikely to meet the success criteria, even with action,

was not recorded, however it is likely that these sites fall into two categories: a) those

sites that are a functional wetland type different than that which was permitted and

for which District enforcement action would serve no purpose and b) those sites for

which the original design was inappropriate or for which the original design cannot

be implemented due to conflicting physical constraints of on-site construction or

other factors. The latter category of projects will require permit modification in

addition to other corrective actions.








Compliance

Compliance was evaluated at the permit level (i.e., for 265 permits) and also at

the site level (i.e. for 326 sites which represent the 265 permits). Two-thirds (63.7%) of

the permits inspected to date are not in compliance with all administrative

requirements and half (56.6%) of the sites are not in compliance with all construction

requirements. At the individual mitigation site level, compliance (i.e., meeting all

permit conditions applicable at the time of the inspection and constructing the site in

accordance with the approved plans) was 43.4% for all sites including 57.5% for the

herbaceous and 31.7% for the forested freshwater sites. Compliance for saltwater sites

was 61.5%

It is important to note that the percentage of projects in compliance is greater

than the percentage of projects meeting the success criteria because the success

criteria determination is made after a three or five year period of time. Until that time

period is met the success criteria condition is not a part of the compliance

determination.

As of August 1991, enforcement letters had been mailed to 48.6% of permit

holders with known compliance violations. Most of the remaining permittees have

been contacted by telephone. A follow-up field visit was scheduled for 50.7% of the

permits to inspect site progress.

Related Assessment Information

Data were recorded for several factors that are not part of the permitting

process or requirements. These data will be used in future studies to evaluate other








factors contributing to wetland creation success.

Siting contiguous to an existing wetland was 54.6% for all sites, and

substantially more common for forested (70.0%) than herbaceous (27.4%) wetland

creation. Use of the site as a stormwater treatment area was more common for

herbaceous (71.4%) than forested (36.0%) creation. Permitting the use of created

wetlands for stormwater treatment was more common in the earlier issued permits.

Soils information was submitted with 44.6% of the permits. Mulch was known to

have been used in a minority of both herbaceous (19.0%) and forested (28.8%) sites,

although actual use was probably higher.

More than one-half (54.1%) of the creation sites had wildlife value similar to

that anticipated at the same point in time by the permit action. The current wildlife

value was considered at least moderate for 58.4% of the herbaceous and 37.1% of the

forested freshwater sites. The potential for the sites to achieve, without enforcement

action, wildlife values similar to that anticipated by the permit action was considered

moderate or high for 80.2% of the herbaceous and 63.8% of the forested freshwater

sites, 75.0% of the saltwater sites, and 59.3% of all creation sites.

Hydrological problems external to the permitted design, such as drought, can

contribute to lowered achievement of success criteria and wildlife values, particularly

in the short term. Hydrological problems were noted for 21.4% of the herbaceous and

38.9% of the forested freshwater sites. The difference between herbaceous and

forested sites is likely due to the more narrow range of hydrologic tolerance of the

planted woody species, particularly the more transitional species.








DISCUSSION

Creation assessment

The wildlife results suggest that freshwater wetland creation is a viable

mitigation option. Recent additions to the mitigation assessment parameters, which

will allow a comparison of success rates depending upon siting of the mitigation

areas, are expected to indicate that location is a key factor in long-term success.

Additional emphasis on the appropriate siting during the permit review and project

planning process would likely increase the overall effectiveness of mitigation efforts.

As anticipated, saltwater creation sites appear inherently more successful than

freshwater sites, and forested freshwater creation appears more difficult than

herbaceous creation. The contrast between freshwater and saltwater systems may be

attributed to data available in the design of the system. Saltwater system design is

based upon established and recorded tidal ranges usually from gaging stations in the

immediate area. The design grade of freshwater systems is usually based on adjacent

wetland grades without extensive knowledge of existing hydroperiods. Only

occasionally have fresh water levels been recorded over sufficient time that design

can be based on historic data.

The data also indicates a difference between forested and herbaceous systems

in the correctness of grading. It is likely that design of forested system grading and

hydrology should include more detailed evaluation of the pre- and post-development

drainage basins (a water budget) and the duration, frequency and seasonality of

inundation. For certain types of forested systems, particularly the more transitional








areas, a number of other factors such as physical and chemical soil properties and

mycorrhizal relationships, are probably as critical as hydrology in determining

long-term success.

Drought conditions over much of the District often made a field determination

of correctness of grade difficult for freshwater systems particularly when there was

not an adjacent natural wetland for comparison. It should also be noted that the

"correct" hydroperiod of created freshwater systems can be difficult to determine

during a one-day site inspection as most freshwater system water levels fluctuate

seasonally and following storm events. During a field inspection in saltwater systems,

the evidence of tide fluctuations is readily observable and "correct grading" is a more

direct determination.

Correct planting elevation is often, but not always, a function of grading. In

some instances, drought conditions again contributed to difficulty determining

whether the plants were planted at the correct elevation. For this parameter the

remaining sites that were not indicated as having correct planting elevations either

had species clearly planted at elevations which would not support their continued

survival and growth or the reviewer was unable to determine if the plants were

planted at the correct elevations.

Requiring mitigation as-builts and planting inventories as standard permit

conditions will improve the evaluation process. Results of an earlier mitigation

assessment indicated the need for submittal of a mitigation specific as-built survey in

order to determine whether the size, grading and planting elevations were in








accordance with the permitted design. This requirement has been included on most

permits issued since 1989. In the absence of an as-built survey, observations of

correctness of grading and size, were not measurements, but rather estimates. In the

case of grading, the estimate was largely based upon whether the hydrology was

correct. If the hydrology appeared correct the assumption was made that the grading

was correct.

Mitigation planning and permitting requires a regional perspective to ensure

that cumulative and secondary impacts to an ecosystem will be capable of being

offset in the long term. There are instances where regional mitigation efforts

(mitigation banks) between a number of parties can be effectively used to ensure a

greater likelihood of long-term success and to address secondary and cumulative

impacts. The evaluation of a banking proposal should be based on the same criteria

as other mitigation proposals.

Wildlife value results should be considered preliminary at this time. It is

anticipated that the evaluations, although subjective, can be useful for comparing the

actual and potential result of the creation effort with that anticipated at realistic time

frames during the permit review process. It is recognized that the current

quantitatively based success criteria do not allow for the assessment of the variability

inherent in natural systems, nor do they allow for a broader functional assessment

based professional ecological judgement. Further assessment will likely also lead to

an acknowledgement that wetland acreage comparisons (lost vs. created) are not a

representative measures of the impact of a project or of the effectiveness of a








regulatory program.

Wetland creation is a relatively new science. Some of the early creation efforts

which were "successful" were due mostly to luck and natural ecological succession.

Many sites were not "successful" resulting in the conclusion that creation does not

work. It is unfortunate that the nature of a regulatory program requires a short-term

assessment of impacts and compensatory mitigation. This has caused the cost of

creation to increase in an effort to accelerate natural succession and quickly reach a

point at which the permitted can be released from responsibility for the creation

effort. Additional research is needed to evaluate the ecological succession of

man-made systems. With proper planning and reasonable expectations this can occur

as a part of the regulatory process.

Long-term assessment of creation will likely show that if properly designed

and implemented it can be used in combination with other mitigation alternatives

and a responsible site plan to effectively offset many of the adverse effects of impacts

to wetlands. Mitigation, like other permitted systems, requires a long term

commitment from both the permitted and the District.

Compliance

The percentage of projects that are in compliance is higher than previously

reported by other agencies who have assessed their mitigation program. The higher

compliance rates within our District are thought to be directly related to a higher

level of staffing which allows for more oversight and assistance. Administrative

compliance is expected to improve as a result of the recently implemented permit








condition tracking aspects of the mitigation database. Prompt site follow-up will

identify problems early rather than late in the monitoring time frame, minimizing

compliance cost and effort for both the District and permitted.

When a project is not in compliance, there is usually a combination of

administrative and site problems. Noncompliance with permit conditions ranges from

late submittal of a monitoring report to improper site construction and planting. The

degree of enforcement action required to achieve compliance will, therefore, vary

considerably among permits. In addition, there is a range of effort associated with

enforcement, depending on the severity of the compliance problem. Many permits

require relatively minor administrative action such as a reminder phone call of a

past-due monitoring report. Other permitted projects have more serious problems

that require follow-up, such as site stabilization, exotic or nuisance species removal,

or replanting. Some will require substantial action such as construction or re-design

of the mitigation site.

Two-thirds (63.7%) of the 265 permits requiring mitigation reviewed to date

are not in compliance with all administrative requirements and half (56.6%) are not in

compliance with site construction requirements. Although these figures indicate that

wetland creation will require additional effort, it should also be noted that the rate of

non-compliance for mitigation projects is not substantially different than for other

types of projects which the District regulates.

Less than 20% of the projects inspected to date have met the success criteria

specified in the permit. More than half (59.3%) of wetland creation sites, however,








demonstrate the potential to succeed as functioning wetlands with at least moderate

wildlife value without enforcement action. This discrepancy suggests the need for a

review of the success criteria placed on mitigation permits. Some possible

modifications include a requirement for an "interim" determination of the likelihood

of success and also a re-evaluation of the density requirements for plantings.

Future considerations

The mitigation database provides the opportunity to develop statistical

answers to questions as the number and age of projects increases. Answers to the

following and other questions will have a large effect on mitigation compliance and

success, and on the cost of wetland mitigation to permittees and the District.

1) What is the effectiveness of early post-construction follow-up of the creation

site? Mitigation projects are now added to the database tracking system as they are

permitted and receive early follow-up, whereas the follow-up was later for many

older projects. A comparison of these two groups of projects can provide the required

answer.

2) What are the critical design factors contributing to long-term success of

wetland creation sites? A cross tabulation of design factors and "success" measures

can provide an answer.

3) What is the efficiency of added effort in increasing the compliance of

projects? The number of field visits and compliance actions are entered into the

database. A numerical tabulation of these efforts can be cross tabulated with "success"

measures.








4) What are the likely improvements to mitigation in the review and

permitting process? Wetland creation designs that demonstrate lower probability of

long-term success or other problems can be discouraged during the review process or

more thoroughly conditioned in the permitting step.

The database will provide an essential design element in an unbiased

comparison of wetland creation and restoration and enhancement banking. The

database is currently tracking these other forms of mitigation as well as preservation

of wetlands and uplands. Planned future reports will continue to assess wetland

creation in addition to other mitigation alternatives.




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