COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT Committee on Mitigating Wetland Losses Board on Environmental Studies and Toxicology Water Science and Technology Board Division on Earth and Life Studies National Research Council NATIONAL ACADEMY PRESS Washington, D.C.

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT NATIONAL ACADEMY PRESS 2101 Constitution Avenue, N.W. Washington, D.C. 20418 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This project was supported by Cooperative Agreement No. C X 827828-01-0 between the National Academy of Sciences and the U.S. Environmental Protection Agency. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the view of the organizations or agencies that provided support for this project. Library of Congress Cataloging-in-Publication Data Compensating for wetland losses under the Clean Water Act/Committee on Mitigating Wetland Losses, Board on Environmental Studies and Toxicology, Water Science and Technology Board, Division on Earth and Life Studies, National Research Council. p. cm. Includes bibliographical references (p. ). ISBN 0-309-07432-0 (hardcover) 1. Wetlands—Law and legislation—United States. 2. Wetland conservation—Government policy—United States. 3. Wetland mitigation banking—United States. I. National Research Council (U.S.). Committee on Mitigating Wetland Losses. KF5624 C66 2001 346.7304'6918--dc21 2001004921 Compensating for Wetland Losses Under the Clean Water Act is available from the National Academy Press, 2101 Constitution Avenue, N.W., Box 285, Washington, DC 20055; (800) 624–6242 or (202) 334–3313 (in the Washington metropolitan area); Internet: http://www.nap.edu Copyright 2001 by the National Academy of Sciences. All rights reserved. Printed in the United States of America

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT THE NATIONAL ACADEMIES National Academy of Sciences National Academy of Engineering Institute of Medicine National Research Council The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Bruce M.Alberts is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Wm.A. Wulf is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Kenneth I.Shine is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy's purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Bruce M.Alberts and Dr. Wm.A.Wulf are chairman and vice chairman, respectively, of the National Research Council.

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT COMMITTEE ON MITIGATING WETLAND LOSSES JOY ZEDLER (Chair), University of Wisconsin, Madison, Wisconsin LEONARD SHABMAN (Vice Chair), Virginia Polytechnic Institute and State University, Blacksburg, Virginia VICTORIA ALVAREZ, California Department of Transportation, Sacramento, California ROBERT O.EVANS, North Carolina State University, Raleigh, North Carolina ROYAL C.GARDNER, Stetson University College of Law, St. Petersburg, Florida J.WHITFIELD GIBBONS, Savannah River Ecology Laboratory, Aiken, South Carolina JAMES WENDELL GILLIAM, North Carolina State University, Raleigh, North Carolina CAROL A.JOHNSTON, University of Minnesota, Duluth, Minnesota WILLIAM J.MITSCH, Ohio State University, Columbus, Ohio KAREN PRESTEGAARD, University of Maryland, College Park, Maryland ANN M.REDMOND, WilsonMiller, Inc., Tallahassee, Florida CHARLES SIMENSTAD, University of Washington, Seattle, Washington R.EUGENE TURNER, Louisiana State University, Baton Rouge, Louisiana FEDERAL LIAISONS JOHN GOODIN, U.S. Environmental Protection Agency LISA T.MORALES, U.S. Environmental Protection Agency JOHN F.STUDT, U.S. Army Corps of Engineers ROBERT BRUMBAUGH, U.S. Army Corps of Engineers, Institute for Water Resources BENJAMIN N.TUGGLE, U.S. Department of the Interior, Fish and Wildlife Service THOMAS BIGFORD, U.S. Department of Commerce, National Marine Fisheries Service KATHRYN CONANT, U.S. Department of Commerce, National Marine Fisheries Service SUSAN MARIE STEDMAN, U.S. Department of Commerce, National Marine Fisheries Service

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT Staff SUZANNE VAN DRUNICK, Study Director RUTH CROSSGROVE, Editor BARBARA O'HARE, Editor MIRSADA KARALIC-LONCAREVIC, Information Specialist LEAH PROBST, Senior Project Assistant JENNIFER SAUNDERS, Project Assistant JAMIE YOUNG, Research Associate

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY GORDON ORIANS (Chair), University of Washington, Seattle, Washington JOHN DOULL (Vice Chair), University of Kansas Medical Center, Kansas City, Kansas DAVID ALLEN, University of Texas, Austin, Texas INGRID C.BURKE, Colorado State University, Fort Collins, Colorado THOMAS BURKE, Johns Hopkins University, Baltimore, Maryland GLEN R.CASS, Georgia Institute of Technology, Atlanta, Georgia WILLIAM L.CHAMEIDES, Georgia Institute of Technology, Atlanta, Georgia CHRISTOPHER B.FIELD, Carnegie Institute of Washington, Stanford, California JOHN GERHART, University of California, Berkeley, California J.PAUL GILMAN, Celera Genomics, Rockville, Maryland DANIEL S.GREENBAUM, Health Effects Institute, Cambridge, Massachusetts BRUCE D.HAMMOCK, University of California, Davis, California ROGENE HENDERSON, Lovelace Respiratory Research Institute, Albuquerque, New Mexico CAROL HENRY, American Chemistry Council, Arlington, Virginia ROBERT HUGGETT, Michigan State University, East Lansing, Michigan JAMES F.KITCHELL, University of Wisconsin, Madison, Wisconsin DANIEL KREWSKI, University of Ottawa, Ottawa, Ontario JAMES A.MacMAHON, Utah State University, Logan, Utah CHARLES O'MELIA, Johns Hopkins University, Baltimore, Maryland WILLEM F.PASSCHIER, Health Council of the Netherlands, The Hague ANN POWERS, Pace University School of Law, White Plains, New York KIRK SMITH, University of California, Berkeley, California TERRY F.YOSIE, American Chemistry Council, Arlington, Virginia Senior Staff JAMES J.REISA, Director DAVID J.POLICANSKY, Associate Director and Senior Program Director for Applied Ecology RAYMOND A.WASSEL, Senior Program Director for Environmental Sciences and Engineering KULBIR BAKSHI, Program Director for the Committee on Toxicology ROBERTA M.WEDGE, Program Director for Risk Analysis K.JOHN HOLMES, Senior Staff Officer

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT WATER SCIENCE AND TECHNOLOGY BOARD HENRY J.VAUX, JR. (Chair), University of California, Oakland, California RICHARD LUTHY (Vice Chair), Stanford University, Stanford, California RICHELLE ALLEN-KING, Washington State University, Pullman, Washington GREGORY B.BAECHER, University of Maryland, College Park, Maryland JOHN BRISCOE, The World Bank, Washington, D.C. EFI FOUFOULA-GEORGIOU, University of Minnesota, St. Paul, Minnesota STEVEN P.GLOSS, University of Wyoming, Laramie, Wyoming WILLIAM A.JURY, University of California, Riverside, California GARY S.LOGSDON, Black and Veatch, Cincinnati, Ohio DIANE M.McKNIGHT, University of Colorado, Boulder, Colorado JOHN W.MORRIS, J.W.Morris Ltd., Arlington, Virginia PHILIP A.PALMER, DuPont Engineering, Wilmington, Delaware REBECCA T.PARKIN, George Washington University, Washington, D.C. RUTHERFORD H.PLATT, University of Massachusetts, Amherst, Massachusetts JOAN B.ROSE, University of South Florida, St. Petersburg, Florida JERALD L.SCHNOOR, University of Iowa, Iowa City, Iowa RHODES TRUSSELL, Montgomery Watson, Pasadena, California Staff STEPHEN PARKER, Director LAURA J.EHLERS, Senior Staff Officer JEFFREY W.JACOBS, Senior Staff Officer MARK GIBSON, Staff Officer WILLIAM LOGAN, Staff Officer JEANNE AQUILINO, Administrative Associate PATRICIA JONES, Staff/Research Associate ANITA HALL, Administrative Assistant ELLEN DE GUZMAN, Senior Project Assistant ANIKE JOHNSON, Project Assistant

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT OTHER REPORTS OF THE BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY A Risk-Management Strategy for PCB-Contaminated Sediments (2001) Toxicological Effects of Methylmercury (2000) Strengthening Science at the U.S. Environmental Protection Agency: Research-Management and Peer-Review Practices (2000) Scientific Frontiers in Developmental Toxicology and Risk Assessment (2000) Modeling Mobile-Source Emissions (2000) Toxicological Risks of Selected Flame-Retardant Chemicals (2000) Copper in Drinking Water (2000) Ecological Indicators for the Nation (2000) Waste Incineration and Public Health (1999) Hormonally Active Agents in the Environment (1999) Research Priorities for Airborne Particulate Matter: I. Immediate Priorities and a Long-Range Research Portfolio (1998); II. Evaluating Research Progress and Updating the Portfolio (1999); III. Early Research Progress (2001) Ozone-Forming Potential of Reformulated Gasoline (1999) Risk-Based Waste Classification in California (1999) Arsenic in Drinking Water (1999) Brucellosis in the Greater Yellowstone Area (1998) The National Research Council's Committee on Toxicology: The First 50 Years (1997) Toxicologic Assessment of the Army's Zinc Cadmium Sulfide Dispersion Tests (1997) Carcinogens and Anticarcinogens in the Human Diet (1996) Upstream: Salmon and Society in the Pacific Northwest (1996) Science and the Endangered Species Act (1995) Wetlands: Characteristics and Boundaries (1995) Biologic Markers (5 reports, 1989–1995) Review of EPA's Environmental Monitoring and Assessment Program (3 reports, 1994 –1995) Science and Judgment in Risk Assessment (1994) Ranking Hazardous Waste Sites for Remedial Action (1994) Pesticides in the Diets of Infants and Children (1993) Issues in Risk Assessment (1993) Setting Priorities for Land Conservation (1993) Protecting Visibility in National Parks and Wilderness Areas (1993) Dolphins and the Tuna Industry (1992) Hazardous Materials on the Public Lands (1992)

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT Science and the National Parks (1992) Animals as Sentinels of Environmental Health Hazards (1991) Assessment of the U.S. Outer Continental Shelf Environmental Studies Program, Volumes I–IV (1991–1993) Human Exposure Assessment for Airborne Pollutants (1991) Monitoring Human Tissues for Toxic Substances (1991) Rethinking the Ozone Problem in Urban and Regional Air Pollution (1991) Decline of the Sea Turtles (1990) Copies of these reports may be ordered from the National Academy Press (800) 624–6242 (202) 334–3313 www.nap.edu

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT Acknowledgments Many individuals assisted the committee and National Research Council (NRC) staff in their task to create this report. We are especially grateful for the outstanding assistance provided by Lisa Morales, U.S. Environmental Protection Agency. We are also appreciative of the generous support provided by John Goodin, U.S. Environmental Protection Agency; John Studt, U.S. Army Corps of Engineers; Robert Brumbaugh, U.S. Army Corps of Engineers; Benjamin Tuggle, U.S. Fish and Wildlife Service; Thomas Bigford, National Marine Fisheries Service; Kathryn Conant, National Marine Fisheries Service; and Susan Marie Stedman, National Marine Fisheries Service. Field trips held in conjunction with committee meetings helped the committee better understand the complexities of mitigating wetland losses. We would like to express our appreciation to the following people, who assisted the committee and NRC staff during these field trips: Washington, DC Michael Bean, Environmental Defense Fund George Beston, Maryland Department of the Environment Denise Clearwater, Maryland Department of the Environment Timothy Searchinger, Environmental Defense Fund Julie Sibbing, National Audubon Society Orlando, Florida William Ainslie, U.S. Environmental Protection Agency William Barnard, Greater Orlando Aviation Authority Constance Bersok, Florida Department of Environmental Protection

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT was coherent. We all benefited greatly from the help of Jennifer Saunders, who followed Leah Probst as project assistant. Ruth Crossgrove, Mirsada Karalic-Loncarevic, and Barbara O'Hare helped with the many details that made the report ready for publication. Dr. David Policansky initiated the project, and we thank him for providing stimulating discussions. Dr. James Reisa's suggestions improved the Executive Summary. The committee members were exemplary in their dedication to this complicated task; without their expertise, hard work, and timely responses, completion of the project would not have been possible. Joy B.Zedler Chair, Committee on Mitigating Wetland Losses

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT Contents     EXECUTIVE SUMMARY   1  1   INTRODUCTION   11      Important Terms,   13      No Net Loss and the Section 404 Program,   16      The Committee's Task,   20  2   OUTCOMES OF WETLAND RESTORATION AND CREATION   22      Introduction,   22      Five Wetland Functions,   27      Factors That Contribute to the Performance of Mitigation Sites,   35      Recommendations,   45  3   WATERSHED SETTING   46      Watershed Organization and Landscape Function,   46      Wetland Function and Position in the Watershed,   47      Watershed-Scale Patterns of Wetland Losses,   57      A Watershed Template for Wetland Restoration and Conservation,   58      Conclusions,   59      Recommendations,   59

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT  4   WETLAND PERMITTING: HISTORY AND OVERVIEW   60      Evolution of Compensatory Mitigation Requirements in the CWA Section 404 Program,   60      General Mitigation Requirements,   61      General Corps Mitigation Requirements,   63      CWA Section 404 Mitigation Requirements,   64      Mitigation Banking,   67      In-Lieu Fees,   69      The Clean Water Act and the Goal of No Net Loss,   70      Section 404 Permit Process,   73      Inspection and Enforcement,   80  5   COMPENSATORY MITIGATION MECHANISMS UNDER SECTION 404   82      Location of the Compensatory Mitigation Action,   83      Legal Responsibility for the Mitigation,   86      Relationship of Mitigation Actions to Permitted Activities (Timing),   88      The MBRT Process,   91      Stewardship Requirements,   91      A Taxonomy,   92      Recommendation,   93  6   MITIGATION COMPLIANCE   94      Mitigation Planning,   95      Mitigation Design Standards,   97      Project Implementation,   101      Compliance with Permit Conditions,   103      Mitigation Ratios,   108      Monitoring of Mitigation Projects,   110      Monitoring Duration,   112      The Compliance Record,   113      Conclusions,   121      Recommendations,   122  7   TECHNICAL APPROACHES TOWARD ACHIEVING NO NET LOSS   123      Operational Guidelines for Creating or Restoring Wetlands That Are Ecologically Self-Sustaining,   123      Wetland Functional Assessment,   128      The Floristic Approach,   129

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT      Habitat Evaluation Procedures and the Hydrogeomorphic Approach,   131      HGM as a Functional Assessment Procedure,   132      Recommendations,   136  8   INSTITUTIONAL REFORMS FOR ENHANCING COMPENSATORY MITIGATION   138      Introduction,   138      A Watershed-Based Approach to Compensatory Mitigation,   140      Improvements in Permittee-Responsible Mitigation,   149      Expectations for the Regulatory Agency,   154      Third-Party Mitigation,   160      Support for Increased State Responsibilities,   165      Recommendations,   166     REFERENCES   169     APPENDIXES       A  Survey of Studies: Comparison of Mitigation and Natural Wetlands   189     B  Case Studies   199      Everglades National Park,   199      Coyote Creek Mitigation Site,   201      North Carolina Wetland Restoration Program,   208     C  Analyses of Soil, Plant, and Animal Communities for Mitigation Sites Compared With Reference Sites   211     D  California Department of Fish and Game, South Coast Region; Guidelines for Wetland Mitigation   217     E  Examples of Performance Standards for Wetland Creation and Restoration in Section 404 Permits and an Approach to Developing Performance Standards   219     F  Memorandum for Commanders, Major Subordinate Commands, and District Commands, April 8, 1999   234

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT     G  Army Corps of Engineers Standard Operating Procedures for the Regulatory Program   239     H  Selected Attributes of 40 Common Wetland Functional Assessment Procedures   285     I  Function, Factors, and Values Considered in Section 404 Permit Reviews   292     J  Biographical Sketches of Committee Members   294     GLOSSARY   299     INDEX   305

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT Tables and Figures FIGURES  FIGURE 1–1   Area of wetland impacts permitted, mitigation required by the permit, and the anticipated gain in wetland area as a result of permits issued by the U.S. Army Corps of Engineers regulatory program from 1993 to 2000,   19  FIGURE 2–1   Percent plant cover on created or restored coastal wetlands on the Atlantic and Gulf of Mexico (GOM) coasts,   41  FIGURE 2–2   Long-term data for salt marshes constructed in San Diego Bay,   43  FIGURE 3–1   Comparison between observed and DRAINMOD (hydrological model) simulated water-table depths for a wetland restoration site in Craven County, N.C., 1996,   55  FIGURE 4–1   Mitigation sequencing,   66  FIGURE 4–2   Section 404 of the CWA permit process flow chart,   75  FIGURE 4–3   Approach to the nationwide permit process,   77  FIGURE 4–4   U.S. Army Corps of Engineers enforcement chart for inspection and noncompliance,   81

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT  FIGURE 6–1   Water-table position and duration of root zone saturation for wetland site that satisfies the jurisdictional hydrology criteria (5% of growing season) as compared with wetland site that satisfies the criteria (12% of the growing season),   105  FIGURE 6–2   Year-to-year variations in water-table depth and duration of root zone saturation for a wetland site that satisfies jurisdictional hydrology criteria at least 5% of the growing season,   106  FIGURE 6–3   Year-to-year variation of the longest period that wetland hydrological criteria satisfied. Results obtained from long-term simulation modeling using DRAINMOD,   107  FIGURE B–1   Conceptual model of factors facilitating the invasion of Schinus terebinthifolius,   200 TABLES TABLES  TABLE 1–1   Wetland Losses Due to Agricultural and Nonagricultural Causes,   17  TABLE 1–2   Percent Loss by Cause and Acres Lost,   18  TABLE 2–1   Summary of Results from Study of a Created Salt Marsh Constructed as a Mitigation Site in North Carolina (1991),   42  TABLE 2–2   Time Toward Equivalency for Soil, Plant, and Animal Components in Wetland Restoration Projects Compared with That of Natural Reference Wetlands,   42  TABLE 4–1   Listing of Current Nationwide Permits,   78  TABLE 5–1   Taxonomy of Compensatory Mitigation Mechanisms,   84  TABLE 6–1   Required Mitigation as Restoration, Creation, and Enhancement for Permits Issued under Permitting Programs,   96  TABLE 6–2   Review of Corps Permits Issued Nationwide,   98  TABLE 6–3   Mitigation Initiated for Permits Requiring Mitigation,   102  TABLE 6–4   Parameters Measured in 110 Compensatory Wetland Mitigation Projects in California from 1988 to 1995,   107  TABLE 6–5   Mitigation Ratios Required and the Actual Ratios Met, Based on Post-Construction Evaluation (assumes complete compliance in meeting permit conditions),   109

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT  TABLE 6–6   Mitigation Ratios (Area Basis) and Achievement Rates (%) for Different Wetland Types in Southern California,   110  TABLE 6–7   Frequency of Monitoring for Permits That Required Mitigation,   111  TABLE 6–8   Permit Requirements and Compliance for Five Replacement Wetlands Investigated in Ohio,   114  TABLE 6–9   Index of Functional Equivalency for Four Constructed Salt Marshes in Relationship to Natural Sites in Paradise Creek, Southern California,   115  TABLE 6–10   Ecological Parameters in Paired Replacement and Reference Wetlands in Massachusetts,   116  TABLE 6–11   Comparison of the Percentage of Permits Meeting Their Requirements and Percentage of Those Permits Meeting Various Tests of Ecological Functionality or Viability,   117  TABLE 6–12   Compliance (Based on Permit Number) for When the Mitigation Plan Was Fully Implemented,   118  TABLE 6–13   Compliance (Area Basis) for Mitigation That Was Attempted Based on Field Inspection or Monitoring Reports,   119  TABLE 6–14   Ranking of Compliance for 30 Sites in San Francisco Bay That Were Issued Section 404 Permits,   120  TABLE 6–15   Results from an Analysis of Compliance for 17 Mitigation Projects with Field Investigation in Western Washington,   120  TABLE 6–16   Summary of Data from Previous Tables on Wetland Permit Implementation, Compliance, Ecological Success, and Monitoring Frequency,   121  TABLE A–1   Survey of Studies: Comparison of Mitigated and Natural Wetlands,   190  TABLE C–1   Analysis of Soil, Plant, and Animal Communities for Mitigation Sites Compared With Reference Sites,   212  TABLE E–1   Summary of Performance Standards from Selected Section 404 Permits Requiring Compensatory Mitigation,   222  TABLE H–1   Selected Attributes of 40 Common Wetland Functional Assessment Procedures,   286

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COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT COMPENSATING FOR WETLAND LOSSES UNDER THE CLEAN WATER ACT

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