1. Wetland restoration and creation trajectories do not suggest equivalency with reference sites within the commonly used 5-year monitoring period.

  2. The literature and testimony provided to the committee indicate that the national goal of “no net loss” for permitted wetland conversions is not being met.

  3. The gap between what is required and what is realized is not precisely known; however, the evidence strongly suggests that the required compensatory mitigation called for by wetland permits to date will not be realized.

  4. Permit follow-up is sparse or too infrequent, and a higher post-monitoring rate will increase permit compliance rates. Compliance monitoring is commonly known to be nonexistent after 5 years. Better documentation and monitoring will increase compliance rates.

  5. The sparse compliance monitoring is a direct consequence of its designation as a “below-the-line” policy standard. Raising compliance monitoring to “above the line” will greatly enhance mitigation success. Chapter 8 further discusses mitigation compliance issues; specifically, recommendations 4 and 6 in that chapter addresses concerns outlined here.


The committee makes the following recommendations relative to future mitigation compliance to ensure that the nation has an accurate reporting of wetland losses and gains:

  1. The wetland area and functions lost and regained over time should be tracked in a national database. This database may or may not be the Corps Regulatory Analysis and Management System (RAMS) database.

  2. The Corps should expand and improve the quality-assurance measures for data entry in the RAMS database.

  3. Mitigation goals must be clear and those goals carefully specified in terms of measurable performance standards in order to improve mitigation effectiveness. Performance standards in permits should reflect mitigation goals and be written in such a way that ecological viability can be measured and the impacted functions replaced.

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