TABLE 6–14 Ranking of Compliance for 30 Sites in San Francisco Bay That Were Issued Section 404 Permits

Permits (No.)

Compliance (%)

3

100

6

85 to 95

6

75 to 85

12

45 to 75

1

1 to 14

2

0

NOTE: DeWeese (1994) ranked sites (scale 1 to 10) to determine their ecological success rate.

one-third of that required. These subjective measures of equivalency suggest that compliance is much lower than expected.

The historical and national perspective of mitigation in the United States that has been presented comes from a wide range of studies, and we do not think that our review is a parochial or geographically restricted one. A summary of key data reviews is in Table 6–16. Between 70% and 76% of the mitigation required in the permits is implemented, and about 50% to 53% of the implemented mitigation projects did not meet the permit requirements. In addition, the estimate of functional equivalency of mitigation wetland was about 20% of that intended. These estimates (based on the mean or median value in the tables) suggest that there is a substantial net loss in wetland area from wetlands permitting program. In terms of the ecological equivalency of these wetlands, there is a low value of the wetlands actually built.

TABLE 6–15 Results from an Analysis of Compliance for 17 Mitigation Projects with Field Investigation in Western Washington

Condition

Number

Percent

Not verified as being in compliance

9

53

Out of compliance

5

29

Not functioning ecologically

11

65

In compliance with regulatory requirements

3

18

Monitoring done/required

9/17

53

Monitoring done when required

3

33

SOURCE: Storm and Stellini (1994).



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