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with peril. This is especially true for smaller wetlands and unique types with isolated distributions. 

 Furthermore, the interrelationships of wetland units within a geograpnic area and their 

 interdenendencies on associated terrestrial environments, make evaluations of replacement difficult at 

 best. However, certain types of wetland have been restored, enhanced and/or created for many years. 

 Wc have a considerable body of knowledge on restoration, enhancement, creation and management of 

 marshes - especially the Prairie Potholes and other midwesiern marshes. Similar though less extensive 

 information is available for freshwater marshes in the interior valley of California, the Intermountain 

 West and coastal marshes along the Atlantic and Gulf coasts. Some information is available for 

 northern bogs, less for Coastal Plain bogs and very little for high elevation bogs. Our information on 

 forested wetlands, especially the great river swamps of the Southeast is rudimentary at best and it's 

 almost non-existent for unique systems such as pocosins, vernal pools, riparian bands, Carolina Bays, 

 etc. 



Similarly, our information base on wetland functional values varies considerably. We have the 

 ability to accomplish certain life support functions - notably waterfowl, wetland mammal, fish and 

 timber production but only limited information on the ho.st of other biological products deriving from 

 wetlands. Very few investigations have explored the hydrologic buffering functions and results have 

 been multi-directional. The water quality improvement function has received considerable attention 

 within the last few years but much of the information has derived from deliberately constructed 

 wetlands and extrapolation to natural wetlands is largely unknown. Consequently, our ability to 

 replace fiinctional values, with a few exceptions, is limited because of our poor understanding of these 

 functions. We do not believe that the state of the art for functional values is adequate to enable us to 

 replace these functions in most newly created wetlands. 



Unfortunately, existing information is often not used in restoration, enhancement and creation 

 projects Failure of many projects lies with the lack of, or improper application of, existing 

 Knowledge. In most cases, problems are caused in application not by tne science. Too few developers 

 employ experienced biologists in the design, construction and operation of wetland projects and 

 subsequent failures are predictable. 



Since compensatory mitigation projects that attempted to create new wetlands have had widely 

 varying success rates and because opportunities for wetland restoration or enhancement are finite, 

 regulatory agencies should require natural wetland restoration or enhancement for mitigation rather 

 than creation of new wetland Our emphasis on restoring former or prior-existing wetland is pragmatic 

 in that, in many cases, restoration of damaged or degraded wetland is much more likely to succeed 

 than attempts to create a wetland in a formerly terrestrial environment. Quite simply, the residual 

 hydrology, edaphic and biological components in the previous wetland make it possible to restore the 

 wetland simply by removing or modifying the factors causing degradation. 



In situations where restoration or enhancement are not feasible, mitigation in the form of 

 created wetland may be acceptable if. 



1) documentation is available on the success of projects creating similar types of 



wetland in that region; or, 



2) the permittee provides funding for research on similar natural wetlands in the region 



that would identify means by which the form and function of the impacted 

 wetland could be duplicated in a newly created wetland; and, 



3) the permittee insures that development of the new wetland is conducted under the 



direction of competent biologists employing current information or information 

 obtained from studies on the model natural wetland; and 



4) the permittee agrees to provide for long-term monitoring to insure the new wetland 



is functional and self-perpetuating. 



Although various acencies and individual offices i)f these agencies have developed replacement 

 acreage requirements, the Committee is reluctant to delve into that morass. Suffice it to say, that 

 replacement of functions for an individual wetland could easily require replacement at ratios greater 

 than 1:1 depending upon the functions and the time period during which tne replacement is expected to 

 be accomplished. 



