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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT
ing a watershed approach for making advance decisions about all matters related to permitting and sequencing, the required compensation for fills in certain areas, and the location and type of compensation that would be required. In making this determination, both regulatory and nonregulatory programs are coordinated. The above quotation from EPA's Interagency Wetland Plan describes management-oriented wetland planning. The high cost and potential for legal and political disagreements suggest that such broad planning may be too ambitious to be implemented in many watersheds, as has proven to be the case in many instances (White and Shabman 1995). While some broad planning efforts have come to fruition (West Eugene, Oregon), others remain controversial years after their initiation (Hackensack Meadowlands, New Jersey).
Protection-oriented wetland planning has the single objective of discouraging wetland-damaging activities (avoidance) by defining and mapping wetlands by their ecological value in advance of any proposed wetland development project. Such planning may be completed under the advanced identification (ADID) process of the CWA or be part of a general land-use planning process (White and Shabman 1995). These plans would then be used to help define areas that should be avoided in the sequencing process.
Compensation wetland planning identifies watershed needs for types, functions, and general locations of wetlands in the landscape in order to establish restoration priorities for both regulatory and nonregulatory programs. However, the written plan will not include specific locations and designs for the restoration and creation sites. This type of planning might link projects undertaken through both regulatory and nonregulatory programs to secure some desired mosaic of wetlands in the landscape. Such a goal is served by the Southern California Wetland Recovery Project (see Box 8–1). North Carolina's developing statewide wetland restoration plan provides advance planning for choosing specific wetland projects (see Box 8–2 and Appendix B). The North Carolina program's formal plans are expected to guide investments in wetland restoration, although the plans do not identify specific sites. Such large, regional programs can combine the efforts of governmental and mitigation funds to achieve the broad goal of no net loss plus a net gain in wetland area and function.
The committee understands that even the more limited form of compensation planning for wetlands can be costly. Both the California and the North Carolina programs have a permanent staff and supporting resources. Such support will not be available in all areas. Therefore, watershed planning for wetlands will need to proceed without a formal written plan. Instead, reliance on the professional judgment of staff from multiple agencies can set watershed priorities and be the form of compensation wetland planning, given current agency time and resource limitations. At