91 



CATEGORIZATION 



Classification and categorization are useful tools in ordering chaos. Wetland classification 

 generally represents groupings of wetlands on hydrologic, biologic and edaphic characteristics without 

 including value judgments. Categorization, however, implies grouping wetlands based on a value 

 regime. 



Value is determined by society and is not an inherent characteristic. Value has socio-economic 

 implications that co far beyond an assessment uf presence ur absence or even quantitative 

 measurements. Valuation is also a function of time in that society's values change, and therefore the 

 very same wetland could have a very different perceived value in the same society at a different point 

 in time. If valuation schemes are employed to categorize wetlands, evaluators must be able to estimate 

 future values, as well as adequately assess present values, of existing wetlands. Furthermore 

 evaluation of a wetland is inevitably relateo to time of year and age of system. Wetlands are dynamic 

 ecosystems undergoing seasonal and annual change as well as progressive change over time, as the 

 wetland system ages. Time, techniques and location of data collection can have substantial impact on 

 the result of a one-time evaluation. 



We recognize the importance of evaluation of natural resources as an important basis for land 

 use decision making. Regulatory agencies now engage in wetland assessment as they decide what level 

 of review is necessary when permits are filed. But the ba.sis for this decision is not clear, interpretable 

 or available to the permit applicant in advance. 



A method of evaluating wetlands to determine the appropriate category for each individual 

 wetland must be a key element of any categorization proposal, we are familiar with widely used 

 evaluation methods (technical assessment tool.s). We do not believe that any existing evaluation regime 

 is adeouate to measure the value of each function performed by the myriad of types of natural wetlands 

 in the U.S. Consequently, any attempt to evaluate and subseouentiy categorize natural wetlands with 

 existing methodologies would result in irretrievable harm to trie Nation's wetland and wildlife 

 resources. 



For the va.st majority of wetlands and even for most different types of wetland, we lack 

 quantitative information even on the biologic productivity, much less auequate, comparable information 

 on other important functional values. We are aware of tne potential aists of assessing the functions of 

 individual wetlands, however, it is also clear that careful and costly study of watersheds is a pre- 

 requisite to designing flood protection programs. Wetlands must be included in similarly 

 comprehensive watershed planning. Wetlands are providing important functions in maintaining water 

 quality, reducing flood damage and conserving biological diversity, and their management requires an 

 appropriate puhfic investment in data collection and ftinctional assessment. 



We are concerned that some categorization proposals would allow for valuation/categorization 

 by non-wetland professionals, i.e., developers or engineers. We do not believe that other disciplines 

 are competent to evaluate wetlands or wetland functional values and we disagree with these 

 approaches. 



The Committee is concerned that certain proposals for categorization do not distinguish among 

 several functions of wetlands, and lump values, such as fltKKl control and wildlife habitat that have 

 different biological and physical bases, into a few simple "value" classes. Schemes to put wetlands 

 into nation-wide value classes without providing for any process to distinguish between regional 

 differences are similarly suspect. In audition, some categorization proposals appear to have a strong 

 element of triage, i.e., if wetlands were assigned to high (Type A), medium (Type B) and low value 

 (Type C) categories, the Committee is concerned that wetlands in the low value category would receive 

 less protection than they currently are provided, allowing development and subsequent foss of "low 

 value" wetlands when in fact, their value is largely unknown. 



Finally, high priority must be given to funding research to develop improved techniques and 

 metliodologies to quantify the functional values of wetlands and effects of wetland alterations. This 

 research should develop an objective, quantitative, evaluation process that can be coupled with the 

 National Wetlands Inventory. Similar research is urgently needed to improve methoas tii create 

 compensatory wetlands that provide important wetland functions. 



