95 



2) landscape interchanges and interactions; 



3) inventory; 



4) classiflcation and categorization; and, 



5) wetland restoration/creation methods. 



are critical to recovering financial losses to society caused by previous costly subsidies supponing 

 drainage/conversion programs. 



MITIGATION 



Despite society's desire to protect remaining wetland resources through positive efforts to 

 avoid and minimize wetland impacts (the sequencing rules), ceruin types of developments, such 85 

 water-related projects, are impossible without detrimentally impacting on-site wetlands. Therefore, 

 protective regulations include a third category requiring compensatory mitigation of wetland impacts m 

 cases where wetlands will ineviubly be impacted if the proposed development is anproved Under 

 current philosophies, compensatory mitigation must occur only after avoidance and mmimization of 

 impacts have been attempted. In its simplest form, compensatory mitigation allows the regulatory 

 agency to say yes to development with a series of requirements. In that sense, mitigation is a tool that 

 expands the regulators role from a simple yes or no to one of negoiiaied development. However, it is 

 important to maintain our perspective. Mitigation banking is only applicable within the prescribed 

 wetland regulatory process; at present non-regulatory wetlands (those built for other than mitieation 

 purposes) account Um 99% of all man-made wetland restoration and creation. Mitigation is NOT the 

 cure to the wetland loss problem. It is only one tool, in a bag of tools, that we have to protect/manage 

 the nations wetland resources. 



Due to the broad scope and many interpretations of the term, the Committee defines 



mltlgatiun as: replacement of the form and function of the wetland that will be 

 delrimentully Impacted. 



This definition deliberately excludes the conceni of minimizing harm from mitigation, though the latter 

 often is included. We have deliberately avoiding specifying locations, acreages, creation, restoration, 

 enhancement, etc. in an effort to simplify the definition because we recognize that full replacement may 

 be accomplished through a variety of means. Since our charge is to evaluate impacts of mitigation 

 banks on wildlife and wetlands, we chose to restrict the definition and limit our discussion to the 

 concept. 



Our inclusion of function within the above definition is important since we believe that current 

 mitigation is largely based on replacement of wetland form, i.e., the physical components of the 

 impacted wetland. However, replacement of the major components may or may not replace the 

 wetland functions depending upon the specific functions, the wetland form and spatial and temporal 

 locations. However, given thai definition, we must then examine the viability of the basic aporoach to 

 replacement. Since mitigation assumes that the form and functions of the wetland can be replaced, a 

 review of wetland functions may be useful. 



Important functional values deriving to human societies from natural wetlands include: 



ground-water recharge, ground-water discharge, floodwater alteration, sediment 

 stabilization, sediment/toxicant retention, nutrient removal/transformation, production 

 export, aquatic and wildlife diversity/abundance, storm buffering, recreation and 

 uniqueness/heritage (Adamus, et al i991). 



This list may be grouped into four major categories: 

 n life support' 

 2) hydrologic buffering; 



water quality improvements, and, 



historical/cultural significance. 



I] 



