93 



Natural wetlands are an ephemeral component of the landscape that largely result from 

 geiilogical incidents and to a lesser extent, from biological and human activities. Specific location, 

 type and size of every wetland is dependent on a series of geophysical phenomena that created and 

 maintain suitable hyorological and edaphic conditions at that site, Conse<)ueml^, attempts to preserve 

 every wetland or even to require on-site replacement are in fact attempts to maintain the status quo 

 disregarding the series of unintentional events that created and mainuin a wetland on that specific site_ 

 This philosophy is inherent in rigid application of in-kind, on-site restoration/creation requirements of 

 the COE/EPA MOA on mitigation signed in January 1990. In contrast, a strategic, landscape 

 approach might well identify more suitable locations for certain types and sizes or even different types 

 and sizes to enhance one or more of the functional values to society. 



Unfortunately, fear of change has obscured serious consideration of arguments for strategic, 

 landscape planning for wetland management that might increase the values of wetland through 

 judicious location. It also has inhibited restoration of wetlands to their orielnal form and f""ction 

 especially in the aia.stal regions where freshwater marshes have become saltwater marshes aner the 

 intra-coastal and associated canals permitted extensive salt water intrusion. For example, in Texaco s 

 Bessy Height's field near Port Arthur, Texas, cypress stumps are still prominent in a saltwater marsh 

 but tne regulatory process discourages efforts to restore the original freshwater marshes. Required 

 permitting contravenes the goal of restoring freshwater wetlands on sites where those wetlands 

 previously existed despite the fact that salt water intrusion resulted from man-induced and not natural 

 changes. Rigid attempts to maintain the status quo totally disregard historical conditions and man- 

 induced changes, as well as the ever changing, dynamic nature of all wetlands. 



Wetlands interactions and interdependencies in a watershed negate management approaches 

 based on evaluating potential impacts to discrete wetland units. Current site specific approaches, 

 especially regulatory measures, to wetland resources management are inadequate to conserve or restore 

 the Nation's wetland and wildlife resources Natural wetlands are interdependent and interact with 

 terrestrial components of the landscape and with other wetlands, especially within a watershed or biotic 

 region, such that meaningful management must incorporate a landscape, watershed or biotic region 

 approach. Because of these strong interactions and interdependencies. it is not possible to evaluate, 

 assess or categorize a wetland unit in isolation from other components in the watershed or biotic 

 region Wetlands management must also include temporal factors since age/successional stage as well 

 as geographical location, strongly influences both form and function of wetland resources. For 

 example, small isolated wetlands strategically located throughout a watershed may have considerably 

 more value in terms of flood amelioration and water Quality improvement than a single, larce wetland 

 at one position, even though it may be situated at the lower end of the watershed. Relatively, narrow 

 bands of riparian vegetation may have inordinate importance as travel lanes for some species of 

 wildlife. Conseouently, wetland resource management must include the context of the surroundings on 

 a watershed, landscape or biogeographical unit basis. 



In rea)gni2inE the complex of hydrologic, biologic, and edaphic components and processes that 

 wmbine to create ana maintain viable wetland eaisystems, the Committee recommends that 

 management efforts and programs employ multi-disciplinary and system analysis approaches to insure 

 adequate representation and evaluation of all aspects of wetland ecosystems. Managers must also 

 incorporate cumulative/multiple impact assessments to wetland resources (and other natural resources) 

 within a hydrological or biogeographical unit since loss or damage to a sinele wetland could have 

 serious repercussions to the functional values from remaining wetlands (and other resources) within the 

 hydro/bio/geographical unit. 



Because of the wide distribution and permeating impacts on world-wide public health safety 

 and welfare, wetland management must also adopt an international approach in developing a basic 

 philosophy to reverse the loss of additional wetlands and instead, encourage restoration and 

 replacement of previously lost wetlands throughout the world. 



The Committee believes that wetlands protective legislation should incorporate a 

 philosophy that bases permit decisions on whether or not we can afford to lose a wetland, not whether 

 or not the wetlands can be replaced. This is an extension and endorsement of the current philosophy 

 ("the sequencing rules") of: 



1) encouraging wetland restoration whenever and wherever feasible and practical; 



2) avoiding further loss or degradation of the Nation's wetland resources; 



