serve those needs. A watershed approach means that mitigation decisions are made with a regional perspective, involve multiple agencies, citizens, scientists, and nonprofit organizations, and draw upon multiple funding sources (e.g., permittee-responsible, mitigation banks, and in-lieu fees). A watershed approach means that permitting decisions are integrated with other regulatory programs (e.g., storm-water management or habitat conservation) and nonregulatory programs (e.g., conservation easement programs).

The idealized watershed planning process, described in the 1993 Clinton Administration Wetland Plan (August 24, 1993) suggests far more formality than may be possible or required. The interagency plan states,

Typically, decisions affecting wetland[s] are made on a project-by-project, permit-by-permit basis. This often precludes the effective consideration of the cumulative effects of piecemeal wetland loss and degradation. It also hampers the ability of State, Tribal, regional, and local governments to integrate wetland conservation objectives into the planning, management, and regulatory tools they use to make decisions regarding development and other natural resource issues. This can often result in inconsistent and inefficient efforts among agencies at all levels of government, and frustration and confusion among the public.

In contrast, advance planning, particularly comprehensive planning conducted on a watershed basis, offers the opportunity to have strong participation by State, Tribal, and local governments and private citizens in designing and implementing specific solutions to the most pressing environmental problems of that watershed. Advance planning generally involves at least the identification, mapping, and preliminary assessment of relative wetland functions within the planning area. More comprehensive advance planning may identify wetlands that merit a high level of protection and others that may be considered for development, and may also incorporate wetland conservation into overall land use planning at the local level. Advance planning can provide greater predictability and certainty to property owners, developers, project planners, and local governments. (

Various efforts at structured wetland planning for watersheds have been attempted in many places (e.g., Minnesota, Tennessee, North Carolina, and Tampa Bay, Florida). A recent review of watershed planning for wetlands describes three approaches to wetland planning, where each approach relies on formal analytical processes and primary or secondary data for their execution (White and Shabman 1995). These planning approaches are characterized by the purpose to be served by the planning activity. Management-oriented wetland planning has the broadest objective. These plans are expected to replace case-by-case permitting by employ-

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