UMAM: The Basics and Beyonds391879964.onlinehome.us/Joomla/images/PDFBank...UMAM: The Basics and...

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UMAM: The Basics and UMAM: The Basics and Beyond Beyond Gisele L. Colbert, E Sciences, Inc. Gisele L. Colbert, E Sciences, Inc. Penny Cople, BDA Penny Cople, BDA Julie M. Sullivan, PBS&J and Julie M. Sullivan, PBS&J and Julie M. Sullivan, PBS&J and Julie M. Sullivan, PBS&J and Mark Clark, Miller Legg Mark Clark, Miller Legg

Transcript of UMAM: The Basics and Beyonds391879964.onlinehome.us/Joomla/images/PDFBank...UMAM: The Basics and...

Page 1: UMAM: The Basics and Beyonds391879964.onlinehome.us/Joomla/images/PDFBank...UMAM: The Basics and Beyond Gisele L. Colbert, E Sciences, Inc. Penny Cople, BDA Julie M. Sullivan, PBS&J

UMAM: The Basics and UMAM: The Basics and BeyondBeyond

Gisele L. Colbert, E Sciences, Inc.Gisele L. Colbert, E Sciences, Inc.Penny Cople, BDAPenny Cople, BDA

Julie M. Sullivan, PBS&J andJulie M. Sullivan, PBS&J andJulie M. Sullivan, PBS&J andJulie M. Sullivan, PBS&J andMark Clark, Miller LeggMark Clark, Miller Legg

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Course OutlineCourse OutlineCourse OutlineCourse OutlineCourse OutlineCourse OutlineCourse OutlineCourse OutlineGisele Colbert: UMAM Basics: intro to rule, web Gisele Colbert: UMAM Basics: intro to rule, web references and basic “parts” and regulatoryreferences and basic “parts” and regulatoryGisele Colbert: UMAM Basics: intro to rule, web Gisele Colbert: UMAM Basics: intro to rule, web references and basic “parts” and regulatoryreferences and basic “parts” and regulatoryreferences, and basic parts and regulatory references, and basic parts and regulatory perspectiveperspectivePenny Cople: Part I details and value as a dataPenny Cople: Part I details and value as a data

references, and basic parts and regulatory references, and basic parts and regulatory perspectiveperspectivePenny Cople: Part I details and value as a dataPenny Cople: Part I details and value as a dataPenny Cople: Part I details and value as a data Penny Cople: Part I details and value as a data collection toolcollection toolJulie Sullivan: Part II details andJulie Sullivan: Part II details and calcscalcs, with, with

Penny Cople: Part I details and value as a data Penny Cople: Part I details and value as a data collection toolcollection toolJulie Sullivan: Part II details andJulie Sullivan: Part II details and calcscalcs, with, withJulie Sullivan: Part II details and Julie Sullivan: Part II details and calcscalcs, with , with specific examples and differences with COE specific examples and differences with COE application application vsvs StateState

Julie Sullivan: Part II details and Julie Sullivan: Part II details and calcscalcs, with , with specific examples and differences with COE specific examples and differences with COE application application vsvs StateStateGisele Colbert: UMAM for Gisele Colbert: UMAM for seagrassseagrass bedsbedsMark Clark: Challenges with implementing UMAMMark Clark: Challenges with implementing UMAMGisele Colbert: UMAM for Gisele Colbert: UMAM for seagrassseagrass bedsbedsMark Clark: Challenges with implementing UMAMMark Clark: Challenges with implementing UMAM

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UMAM B k dUMAM B k dUMAM B k dUMAM B k dUMAM BackgroundUMAM BackgroundUMAM BackgroundUMAM BackgroundFlorida’s Wetland Functional AssessmentFlorida’s Wetland Functional AssessmentFlorida’s Wetland Functional AssessmentFlorida’s Wetland Functional AssessmentFlorida s Wetland Functional Assessment Florida s Wetland Functional Assessment MethodMethodUUniformniform MMitigationitigation AAssessmentssessment MMethodethod

Florida s Wetland Functional Assessment Florida s Wetland Functional Assessment MethodMethodUUniformniform MMitigationitigation AAssessmentssessment MMethodethodUUniform niform MMitigation itigation AAssessment ssessment MMethodethodAuthorized by Authorized by Chapter 373.414(18), Chapter 373.414(18), F.S. F.S. andand FAC Rule 62FAC Rule 62 345345

UUniform niform MMitigation itigation AAssessment ssessment MMethodethodAuthorized by Authorized by Chapter 373.414(18), Chapter 373.414(18), F.S. F.S. andand FAC Rule 62FAC Rule 62 345345and and FAC Rule 62FAC Rule 62--345345Used by DEP, WMDs and Local Used by DEP, WMDs and Local G hG h ff

and and FAC Rule 62FAC Rule 62--345345Used by DEP, WMDs and Local Used by DEP, WMDs and Local G hG h ffGovernments to assess the Governments to assess the amountamount of of mitigation required to offset wetland mitigation required to offset wetland ii

Governments to assess the Governments to assess the amountamount of of mitigation required to offset wetland mitigation required to offset wetland iiimpacts.impacts.impacts.impacts.

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Web ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb Resources

h // d fl / / l d /h // d fl / / l d /h // d fl / / l d /h // d fl / / l d /http://www.dep.state.fl.us/water/wetlands/http://www.dep.state.fl.us/water/wetlands/mitigation/index.htmmitigation/index.htm

http://www.dep.state.fl.us/water/wetlands/http://www.dep.state.fl.us/water/wetlands/mitigation/index.htmmitigation/index.htm

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Web ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb Resources

http://www.dep.state.fl.us/water/wetlands/mitigation/umam.htmmitigation/umam.htm

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Wh t i UMAM d f ?Wh t i UMAM d f ?Wh t i UMAM d f ?Wh t i UMAM d f ?What is UMAM used for?What is UMAM used for?What is UMAM used for?What is UMAM used for?

UMAM is to:UMAM is to:–– determine the determine the amountamount of mitigation needed of mitigation needed UMAM is to:UMAM is to:–– determine the determine the amountamount of mitigation needed of mitigation needed gg

to offset adverse impacts and to award and to offset adverse impacts and to award and deduct mitigation bank credits deduct mitigation bank credits

ggto offset adverse impacts and to award and to offset adverse impacts and to award and deduct mitigation bank credits deduct mitigation bank credits

–– Find out Find out how muchhow much mitigation you need! mitigation you need! –– Find out Find out how muchhow much mitigation you need! mitigation you need!

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B t b f b iB t b f b iB t b f b iB t b f b iBut…before you beginBut…before you beginBut…before you beginBut…before you begin

You must decide if mitigation is:You must decide if mitigation is:–– RequiredRequiredYou must decide if mitigation is:You must decide if mitigation is:–– RequiredRequiredqq–– AppropriateAppropriate

qq–– AppropriateAppropriate

UMAM will UMAM will NOTNOT do this!do this!UMAM will UMAM will NOTNOT do this!do this!

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Chapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62 345.100 345.100 Intent Intent and Scope and Scope Chapter 62Chapter 62 345.100 345.100 Intent Intent and Scope and Scope

UMAM isUMAM is NOTNOT::UMAM isUMAM is NOTNOT::UMAM is UMAM is NOTNOT::–– to determine the amount of net improvement for to determine the amount of net improvement for

water qualitywater quality

UMAM is UMAM is NOTNOT::–– to determine the amount of net improvement for to determine the amount of net improvement for

water qualitywater qualityq yq y–– to determine mitigation for mangrove trimming and to determine mitigation for mangrove trimming and

alteration as required and implemented in accordance alteration as required and implemented in accordance with Section 403 9332 F Swith Section 403 9332 F S

q yq y–– to determine mitigation for mangrove trimming and to determine mitigation for mangrove trimming and

alteration as required and implemented in accordance alteration as required and implemented in accordance with Section 403 9332 F Swith Section 403 9332 F Swith Section 403.9332, F.S.with Section 403.9332, F.S.

It does not assess whether the adverse impact It does not assess whether the adverse impact meets other criteria for issuance of a permit normeets other criteria for issuance of a permit nor

with Section 403.9332, F.S.with Section 403.9332, F.S.

It does not assess whether the adverse impact It does not assess whether the adverse impact meets other criteria for issuance of a permit normeets other criteria for issuance of a permit normeets other criteria for issuance of a permit, nor meets other criteria for issuance of a permit, nor the extent that such impacts may be approved.the extent that such impacts may be approved.meets other criteria for issuance of a permit, nor meets other criteria for issuance of a permit, nor the extent that such impacts may be approved.the extent that such impacts may be approved.

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Chapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62 345.100 345.100 Intent Intent and Scope and Scope Chapter 62Chapter 62 345.100 345.100 Intent Intent and Scope and Scope

UMAM is UMAM is NOTNOT::–– intended to supersede or replace existing intended to supersede or replace existing UMAM is UMAM is NOTNOT::–– intended to supersede or replace existing intended to supersede or replace existing p p gp p g

rules regarding rules regarding cumulative impactscumulative impacts, the , the prevention of secondary impactsprevention of secondary impacts, , reduction reduction

d li i ti f i td li i ti f i t t d t it d t i

p p gp p grules regarding rules regarding cumulative impactscumulative impacts, the , the prevention of secondary impactsprevention of secondary impacts, , reduction reduction

d li i ti f i td li i ti f i t t d t it d t iand elimination of impactsand elimination of impacts, or to determine , or to determine the the appropriatenessappropriateness of the type of mitigation of the type of mitigation proposedproposed

and elimination of impactsand elimination of impacts, or to determine , or to determine the the appropriatenessappropriateness of the type of mitigation of the type of mitigation proposedproposedproposed. proposed. proposed. proposed.

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Chapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62 345.100 345.100 Intent Intent and Scope (preand Scope (pre--UMAM)UMAM)Chapter 62Chapter 62 345.100 345.100 Intent Intent and Scope (preand Scope (pre--UMAM)UMAM)

Applications to modify a preApplications to modify a pre--UMAM permit UMAM permit shall be evaluated under the mitigation shall be evaluated under the mitigation Applications to modify a preApplications to modify a pre--UMAM permit UMAM permit shall be evaluated under the mitigation shall be evaluated under the mitigation assessment criteria used in the review of assessment criteria used in the review of that permit, unless:that permit, unless:assessment criteria used in the review of assessment criteria used in the review of that permit, unless:that permit, unless:–– the applicant elects to have the application the applicant elects to have the application

reviewed under UMAM or reviewed under UMAM or –– the applicant elects to have the application the applicant elects to have the application

reviewed under UMAM or reviewed under UMAM or –– the proposed modification is reasonably the proposed modification is reasonably

expected to lead to expected to lead to substantially differentsubstantially differentb i ll i db i ll i d

–– the proposed modification is reasonably the proposed modification is reasonably expected to lead to expected to lead to substantially differentsubstantially different

b i ll i db i ll i dor or substantially increasedsubstantially increased water resource water resource impactsimpactsor or substantially increasedsubstantially increased water resource water resource impactsimpacts

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UMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IProvides the Frame of Provides the Frame of ReferenceReferenceProvides the Frame of Provides the Frame of ReferenceReference

Site/Project Name Application Number Assessment Area Name or Number

Impact or Mitigation Site? Assessment Area Size

PART I – Qualitative Description(See Section 62-345.400, F.A.C.)

FLUCCs code Further classification (optional)ReferenceReferenceDefines community Defines community typetype

ReferenceReferenceDefines community Defines community typetype

Special Classification (i.e.OFW, AP, other local/state/federal designation of importance)Affected Waterbody (Class)Basin/Watershed Name/Number

Geographic relationship to and hydrologic connection with wetlands, other surface water, uplands

Assessment area descriptiontypetypeMost data compiled Most data compiled before going into thebefore going into the

typetypeMost data compiled Most data compiled before going into thebefore going into the Functions Mitigation for previous permit/other historic use

Significant nearby features Uniqueness (considering the relative rarity in relation to the regional landscape.)

before going into the before going into the fieldfieldWetland Field Guides Wetland Field Guides

before going into the before going into the fieldfieldWetland Field Guides Wetland Field Guides Observed Evidence of Wildlife Utilization (List species directly observed, or other signs such as tracks, droppings, casings, nests, etc.):

Anticipated Utilization by Listed Species (List species, their legal classification (E, T, SSC), type of use, and intensity of use of the assessment area)

Anticipated Wildlife Utilization Based on Literature Review (List of species that are representative of the assessment area and reasonably expected to be found )

for Anticipated for Anticipated Wildlife and listed Wildlife and listed for Anticipated for Anticipated Wildlife and listed Wildlife and listed

Additional relevant factors:

species species species species Assessment conducted by: Assessment date(s):

Form 62-345.900(1), F.A.C. [ effective date 02-04-2004 ]

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UMAM B i R lUMAM B i R lUMAM B i R lUMAM B i R lUMAM Basics: RuleUMAM Basics: RuleUMAM Basics: RuleUMAM Basics: RuleNative Community typeNative Community typeNative Community typeNative Community typeNative Community typeNative Community type–– Term used throughout Part I languageTerm used throughout Part I language

Cl ifi th D t t’ i i l i t tCl ifi th D t t’ i i l i t t

Native Community typeNative Community type–– Term used throughout Part I languageTerm used throughout Part I language

Cl ifi th D t t’ i i l i t tCl ifi th D t t’ i i l i t t–– Clarifies the Department’s original intentClarifies the Department’s original intent

Artificial/Altered SystemsArtificial/Altered Systems–– Clarifies the Department’s original intentClarifies the Department’s original intent

Artificial/Altered SystemsArtificial/Altered Systems–– For artificial systems, such as borrow pits, For artificial systems, such as borrow pits,

ditches and canals, and for altered systems, ditches and canals, and for altered systems, f t thf t th ti it t itti it t it

–– For artificial systems, such as borrow pits, For artificial systems, such as borrow pits, ditches and canals, and for altered systems, ditches and canals, and for altered systems,

f t thf t th ti it t itti it t itrefer to the refer to the native community type it native community type it most closely resemblesmost closely resembles. . refer to the refer to the native community type it native community type it most closely resemblesmost closely resembles. .

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UMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part IUMAM Basics: Part I

Found on DEP websiteFound on DEP websiteMore in depth community descriptions for the More in depth community descriptions for the FLUCCS native wetland habitat codesFLUCCS native wetland habitat codes

Found on DEP websiteFound on DEP websiteMore in depth community descriptions for the More in depth community descriptions for the FLUCCS native wetland habitat codesFLUCCS native wetland habitat codesFLUCCS native wetland habitat codesFLUCCS native wetland habitat codesDownload as individual word documentsDownload as individual word documentsFLUCCS native wetland habitat codesFLUCCS native wetland habitat codesDownload as individual word documentsDownload as individual word documents

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UMAM Basics: Part IIUMAM Basics: Part IIUMAM Basics: Part IIUMAM Basics: Part IIUMAM Basics: Part IIUMAM Basics: Part IIUMAM Basics: Part IIUMAM Basics: Part IIImpacts score current condition Impacts score current condition vsvs “with” proposed impact“with” proposed impactImpacts score current condition Impacts score current condition vsvs “with” proposed impact“with” proposed impact

PART II – Quantification of Assessment Area (impact or mitigation)(See Sections 62-345.500 and .600, F.A.C.)

Site/Project Name Application Number Assessment Area Name or Number

Impact or Mitigation Assessment date:Assessment conducted by:

Mitigation score current Mitigation score current condition “without” and “with” condition “without” and “with” mitigationmitigation

Mitigation score current Mitigation score current condition “without” and “with” condition “without” and “with” mitigationmitigation

Not Present (0)Moderate(7) Minimal (4)Scoring GuidanceThe scoring of each

indicator is based on what would be suitable for the

type of wetland or surface water assessed

Minimal level of support of wetland/surface water

functions

Optimal (10)

.500(6)(a) Location and Landscape Support

Condition is insufficient to provide wetland/surface

water functions

Condition is optimal and fully supports

wetland/surface water functions

Condition is less than optimal, but sufficient to

maintain most wetland/surface waterfunctions

Location & mitigationmitigationCreation the current = 0Creation the current = 0Preservation current = w/out Preservation current = w/out

mitigationmitigationCreation the current = 0Creation the current = 0Preservation current = w/out Preservation current = w/out

w/o pres orcurrent with

.500(6)(b)Water Environment (n/a for uplands)

Landscape

Water //condition (i.e. exempt activities condition (i.e. exempt activities for wetlands)for wetlands)Adj t t Ti L Ri kAdj t t Ti L Ri k

//condition (i.e. exempt activities condition (i.e. exempt activities for wetlands)for wetlands)Adj t t Ti L Ri kAdj t t Ti L Ri k

w/o pres orcurrent with

.500(6)(c)Community structure

EnvironmentCommunity Adjustments: Time Lag, Risk Adjustments: Time Lag, Risk

and Pand P--Factor Factor Calculating Functional Loss andCalculating Functional Loss and

Adjustments: Time Lag, Risk Adjustments: Time Lag, Risk and Pand P--Factor Factor Calculating Functional Loss andCalculating Functional Loss and

w/o pres orcurrent

current Preservation adjustment factor =

with

1. Vegetation and/or 2. Benthic Community

Score = sum of above scores/30 (if uplands, divide by 20)

For impact assessment areas

FL d lt

If preservation as mitigation,

Co u tyStructure

Calculating Functional Loss and Calculating Functional Loss and Functional GainFunctional GainCalculating Functional Loss and Calculating Functional Loss and Functional GainFunctional Gain

currentor w/o pres

Form 62-345.900(2), F.A.C. [effective date 02-04-2004]

Adjusted mitigation delta =

Delta = [with-current]

with

Time lag (t-factor) =

Risk factor =

If mitigation

FL = delta x acres =

For mitigation assessment areas

RFG = delta/(t-factor x risk) =

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Chapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62--345.100345.100 IntentIntentChapter 62Chapter 62 345.100 345.100 Intent Intent and Scope (Mitigation and Scope (Mitigation Chapter 62Chapter 62 345.100 345.100 Intent Intent and Scope (Mitigation and Scope (Mitigation Bank)Bank)Bank)Bank)

If using a nonIf using a non--UMAM mitigation bank, you UMAM mitigation bank, you must use the credit assessment methodmust use the credit assessment methodIf using a nonIf using a non--UMAM mitigation bank, you UMAM mitigation bank, you must use the credit assessment methodmust use the credit assessment methodmust use the credit assessment method, must use the credit assessment method, including any functional assessment including any functional assessment methodology that was in place when themethodology that was in place when the

must use the credit assessment method, must use the credit assessment method, including any functional assessment including any functional assessment methodology that was in place when themethodology that was in place when themethodology, that was in place when the methodology, that was in place when the bank was permitted. bank was permitted. methodology, that was in place when the methodology, that was in place when the bank was permitted. bank was permitted.

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Wh D Wh t?Wh D Wh t?Wh D Wh t?Wh D Wh t?Who Does What? Who Does What? Who Does What? Who Does What?

When an applicant proposes mitigation:When an applicant proposes mitigation:–– the applicant will be responsible for the applicant will be responsible for When an applicant proposes mitigation:When an applicant proposes mitigation:–– the applicant will be responsible for the applicant will be responsible for pp ppp p

submittingsubmitting the necessary supporting the necessary supporting information for the application of UMAM and information for the application of UMAM and

pp ppp psubmittingsubmitting the necessary supporting the necessary supporting information for the application of UMAM and information for the application of UMAM and

–– the reviewing agency will be responsible for the reviewing agency will be responsible for verifyingverifying this information and this information and applyingapplying this this

t th d t d t i th tt th d t d t i th t

–– the reviewing agency will be responsible for the reviewing agency will be responsible for verifyingverifying this information and this information and applyingapplying this this

t th d t d t i th tt th d t d t i th tassessment method to determine the amount assessment method to determine the amount of mitigation necessary to offset the of mitigation necessary to offset the proposed impactsproposed impacts

assessment method to determine the amount assessment method to determine the amount of mitigation necessary to offset the of mitigation necessary to offset the proposed impactsproposed impactsproposed impacts. proposed impacts. proposed impacts. proposed impacts.

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Chapter 62-345, Florida Administrative CodepUniform Mitigation Assessment Method

(UMAM)(UMAM)

Part I: Qualitative Characterizationa t Qua tat e C a acte at o

BDABDA

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Chapter 62-345.400 Qualitative Characterization Part I

Frame of Reference for TypeFrame of Reference for Type of Community and Functions

Being Evaluated

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part IIncludes information requested in 62-345.400(1)(a) through (i).Utilize best available resources, such as aerial photographs, topographic maps, GIS data, technical

bli ti d

CAN BE FILLED OUT IN OFFICE…

publications, and reasonable scientific judgment to describe the native community typenative community type subject to your assessment.

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part IIdentify Assessment Area

Assessment Area:All or part of a wetland orAll or part of a wetland or surface water impact site, or a mitigation site, that is sufficiently homogeneous in y gcharacter, impact, or mitigation benefits to be assessed as a single unit.

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part IFLUCFCS Code (i.e. Community Type)

Native

Further Classification

Type of Assessment AreaType of Assessment Area

Assessment Area Size

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part I

Basin/Watershed

Affected Waterbody (Class)

Special Classification (OFW, AP, other local/state/Federal d i ti f i t )designation of importance)

Geographic Relationship to d H d l i C tiand Hydrologic Connection

with Other Wetlands, Other Surface Waters, Uplands

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part IAssessment Area Description (Based on

Community Type) Native

Significant Nearby Features

Uniqueness

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part IFunctions Performed (i.e.,

C i T )N ti Community Type)

Mitigation for Previous P it/Oth Hi t i U

Native

Permit/Other Historic Use

Anticipated Wildlife Utilization (i e characteristicUtilization (i.e., characteristic of community type)

Anticipated Utilization by

native

Anticipated Utilization by Listed Species (i.e., characteristic of community type)

native

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part I

Observed Evidence of Wildlife Utilization

Any additional information needed to accurately characterizeaccurately characterize the ecological values of the assessment area and functions providedand functions provided

CAN BE FILLED OUT IN FIELD

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part I

BDABDABDABDA

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Qualitative Characterization Part IQualitative Characterization Part I

BDABDA

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Qualitative Characterization Part IQualitative Characterization Part INative Community Type Current Conditiony yp

BDABDA

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Chapter 62-345.500Assessment and Scoring – Part II

Frame of Reference for Type of Community and

Functions Being Evaluated

Utilize:

Evaluated

To Assess Functions and Values for:To Assess Functions and Values for:

Current ConditionWith Mitigation

ANDWith ImpactCurrent Condition or Without Preservation

BDABDA

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U if Miti tiUniform Mitigation Assessment Method (UMAM)Assessment Method (UMAM)

Part II: Quantitative AssessmentPart II: Quantitative Assessment

Julie Sullivan, M.S.

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UMAM MethodUMAM Method• UMAM is a two-part assessment methodUMAM is a two part assessment method• Part I is the biological assessment for

mitigation appropriatenessg pp p– Considers community type, uniqueness, size,

setting, wildlife, habitat classification• Part II is the scoring

– Compares impact site with project to impact site ith t j twithout project

– Compares mitigation site without mitigation and with mitigation g

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Part II AssessmentPart II Assessment

• This assessment is used to determine theThis assessment is used to determine the degree to which the assessment area provides the functions identified in Part Ip

• Determines the amount of function lost orDetermines the amount of function lost or gained by the project or mitigation

• Takes into account time lag, risk, and preservation adjustment factorspreservation adjustment factors

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Part II Assessment

• Three categories of indicators of wetlandThree categories of indicators of wetland function are scored individually on a whole number scale from zero to ten (0-10)number scale from zero to ten (0-10)

• The three categories are: g– location and landscape support– water environmentwater environment– community structure

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Part II AssessmentPart II Assessment

• Evaluation must be based upon availableEvaluation must be based upon available information including:• Aerial photos, topographic and GIS data and maps,• Site visits,• Scientific articles,• Journals,• Professional reports, and• Reasonable scientific judgment

• “With mitigation” or “with impact” scores based on “reasonably expected outcome”

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Mitigation DeterminationMitigation Determination

Upland mitigation areas are scored for• Upland mitigation areas are scored for location and community structure only

• Amount of mitigation required is determined by comparing the Functionaldetermined by comparing the Functional Loss due to the proposed impacts with the Relative Functional Gain value of thethe Relative Functional Gain value of the proposed mitigation

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Not Present (0)Moderate(7) Minimal (4)Scoring Guidance

.500(6)(a) Location and

Optimal (10)

Site/Project Name Application Number Assessment Area Name or NumberImpact or Mitigation Assessment date:Assessment conducted by:

Project XIMPACT

Wetland A40-XXXJune 2, 2008John Doe

w/o pres orcurrent

.500(6)(a) Location and Landscape Support

with

w/o pres orcurrent with

.500(6)(b)Water Environment (n/a for uplands)

.500(6)(c)Community structure

1. Vegetation and/or 2. Benthic Community

w/o pres orcurrent with

y

Score s m of abo e scores/30 For impact assessment areasIf preservation as mitigation

currentor w/o pres

Preservation adjustment factor =

Adjusted mitigation delta = with

Score = sum of above scores/30 (if uplands, divide by 20)

For impact assessment areas

FL = delta x acres =

If preservation as mitigation,

Delta = [with-current] Time lag (t-factor) =

Risk factor =

If mitigation For mitigation assessment areas

RFG = delta/(t-factor x risk) =

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Location and Landscape SupportLocation and Landscape Support• The value of functions provided by an p y

assessment area are influenced by the landscape position and its relationship with surrounding areaswith surrounding areas

• The scoring should reflect how ideally• The scoring should reflect how ideally the assessment area is located and the functions and support the surrounding pp ghabitats allow the assessment area to provide

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Location and Landscape SupportLocation and Landscape Support

Score of 10 (optimal) Score of 7 (70% of ideal)Score of 10 (optimal)

– Optimal support for all wildlife in Part I

Score of 7 (70% of ideal)

– Optimal support for mostwildlife in Part 1in Part I

– N/E not in proximity– Wildlife access not limited

No adverse land uses

wildlife in Part 1 – Minimal N/E– Wildlife partially limited

Minimal adverse land uses– No adverse land uses– Downstream areas derive

critical benefits and could suffer severe impacts if altered

– Minimal adverse land uses– Downstream areas derive

significant benefits and could suffer substantial impacts ifsuffer severe impacts if altered

– Optimal protection of wetland functions (upland mitigation assessment)

suffer substantial impacts if altered

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Location and Landscape SupportLocation and Landscape Support

Score of 4 (40% of ideal) Score of 0 (no s pport)Score of 4 (40% of ideal)

– Minimal support for many

Score of 0 (no support)

– No support for wildlifeor no support for somewildlife in Part I

– N/E majority of cover

– N/E predominant– Wildlife precluded– Severe adverse land uses

– Wildlife access substantially limited

– Significant adverse land

– Severe adverse land uses– Downstream areas derive

negligible or no benefits and could suffer nog

uses– Downstream areas derive

minimal benefits and could

and could suffer noimpacts if altered

suffer adverse impacts if altered

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Not Present (0)Moderate(7) Minimal (4)Scoring Guidance

.500(6)(a) Location and

Optimal (10)

Site/Project Name Application Number Assessment Area Name or NumberImpact or Mitigation Assessment date:Assessment conducted by:

Project XIMPACT

Wetland A40-XXXJune 2, 2008John Doe

w/o pres orcurrent

.500(6)(a) Location and Landscape Support

with

8 0

Insert discussion including justification for score here.

w/o pres orcurrent with

.500(6)(b)Water Environment (n/a for uplands)

.500(6)(c)Community structure

1. Vegetation and/or 2. Benthic Community

w/o pres orcurrent with

y

Score s m of abo e scores/30 For impact assessment areasIf preservation as mitigation

currentor w/o pres

Preservation adjustment factor =

Adjusted mitigation delta = with

Score = sum of above scores/30 (if uplands, divide by 20)

For impact assessment areas

FL = delta x acres =

If preservation as mitigation,

Delta = [with-current] Time lag (t-factor) =

Risk factor =

If mitigation For mitigation assessment areas

RFG = delta/(t-factor x risk) =

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Water Environment• Hydrologic conditions within an

Water EnvironmentHydrologic conditions within an assessment area must be evaluated to determine the effect on fish and wildlife

• Includes parameters such as:– Water quantity q y– Timing, frequency, depth and duration of

inundation or saturation– Flow characteristics– Water quality

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Water EnvironmentScore of 10 (optimal) Score of 7 (70% of ideal)

– Water levels & flows appropriate– Water level indicators are distinct

and consistent– Soil moisture appropriate

– Water levels & flows slightly higher or lower than appropriate

– Water level indicators are not as distinct or consistentpp p

– Fire frequency/severity not atypical– All strata are appropriate– No hydrologic stress (vegetation)

Animal use as expected

– Soil drier than ideal with minimalsoil desiccation/subsidence

– Fire frequency/severity increased– Some strata are appropriate– Animal use as expected

– Plants tolerant of WQ degradation not present

– No observation of WQ degradationW t d th t

pp p– Increased vegetation mortality– Animal use decreased– Some plants tolerant of WQ

degradation present– Water depth, wave energy, currents, light penetration optimal

degradation present– Evidence of slight WQ degradation– Water depth, wave energy, currents,

light penetration generally sufficient

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Water EnvironmentScore of 4 (40%) Score of 0 (no value)

– Water levels & flows moderately higher or lower than appropriate

– Water level indicators are not distinct or consistent

– Water levels & flows show extreme deviation from appropriate

– Water level indicators are not present or inconsistent

– Soil with strong evidence of soil desiccation/subsidence

– Fire much increased– Most strata are inappropriate

– Soil with strong evidence of soil desiccation/subsidence

– Fire greatly increased– All strata are inappropriatepp p

– Significant vegetation mortality– Animal use greatly reduced– Many plants tolerant of WQ

degradation present

pp p– Highly significant vegetation

mortality– Animal use lacking– Mostly plants tolerant of WQdegradation present

– Evidence of moderate WQ degradation

– Water depth, wave energy, currents, light penetration not well suited

Mostly plants tolerant of WQ degradation present

– Evidence of significant WQ degradation

– Water depth wave energy currentslight penetration not well suited – Water depth, wave energy, currents, light penetration inappropriate

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Not Present (0)Moderate(7) Minimal (4)Scoring Guidance

.500(6)(a) Location and

Optimal (10)

Site/Project Name Application Number Assessment Area Name or NumberImpact or Mitigation Assessment date:Assessment conducted by:

Project XIMPACT

Wetland A40-XXXJune 2, 2008John Doe

w/o pres orcurrent

.500(6)(a) Location and Landscape Support

with

8 0

Insert discussion including justification for score here.

w/o pres orcurrent with

.500(6)(b)Water Environment (n/a for uplands)

Insert discussion including justification for score here.

.500(6)(c)Community structure

1. Vegetation and/or 2. Benthic Community

8 0

w/o pres orcurrent with

y

Score s m of abo e scores/30 For impact assessment areasIf preservation as mitigation

currentor w/o pres

Preservation adjustment factor =

Adjusted mitigation delta = with

Score = sum of above scores/30 (if uplands, divide by 20)

For impact assessment areas

FL = delta x acres =

If preservation as mitigation,

Delta = [with-current] Time lag (t-factor) =

Risk factor =

If mitigation For mitigation assessment areas

RFG = delta/(t-factor x risk) =

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Community Structure

• Divided into two categories:

Community Structure

Divided into two categories: – Vegetation and Structural Habitat

Benthic Habitat– Benthic Habitat

G• Generally assesses the presence, abundance, health, condition, appropriateness, and distribution of plant or benthic communities

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Community Structure:Vegetation and StructuralVegetation and Structural

Score of 10 (optimal) Score of 7 (70%)– All or nearly all plant cover/species

appropriate and desirable– N/E not present– Strong evidence of natural regeneration

– Majority plant cover/species appropriate and desirable

– N/E minimally present– Evidence of natural regeneration g g

and recruitment– Age and size distribution typical w/ no

deviation from normal mortality– Structural habitat optimal

gand recruitment

– Age/size distribution nearly typical, no permanent deviation

– Structural habitat slightly alteredp– Plant condition good– Land management optimal– Topo features present and normal

No siltation or algal growth (submerged)

g y– Plant condition generally good– Land management appropriate– Topo features less optimal

No siltation or algal growth– No siltation or algal growth (submerged)– Provides optimal support for associated

wetlands (upland mit.)

– No siltation or algal growth (submerged)

– Provides optimal support for associated wetlands (upland mit.)

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Community Structure:Vegetation and StructuralVegetation and Structural

Score of 4 (40%) Score of 0 (no value)– Majority plant cover/species

inappropriate or undesirable– N/E majority

Mi i l id f t l

– No plant cover/species appropriate or desirable

– N/E dominantN id f t l– Minimal evidence of natural

regeneration and recruitment– Age and size distribution atypical w/

permanent deviation from normal

– No evidence of natural regeneration and recruitment

– Age/size distribution not typical, high mortality p

– Structural habitat limited– Plant condition generally poor– Land management results in

lt ti

g y– Structural habitat not present– Plant condition very poor– Land management inappropriate

alterations– Topo features reduced from normal– Moderate siltation or algal growth

Provides moderate support for

– Topo features lacking– Significant siltation or algae– Provides no support for

associated wetlands– Provides moderate support for associated wetlands

associated wetlands

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Not Present (0)Moderate(7) Minimal (4)Scoring Guidance

.500(6)(a) Location and

Optimal (10)

Site/Project Name Application Number Assessment Area Name or NumberImpact or Mitigation Assessment date:Assessment conducted by:

Project XIMPACT

Wetland A40-XXXJune 2, 2008John Doe

w/o pres orcurrent

.500(6)(a) Location and Landscape Support

with

8 0

Insert discussion including justification for score here.

w/o pres orcurrent with

.500(6)(b)Water Environment (n/a for uplands)

Insert discussion including justification for score here.

.500(6)(c)Community structure

1. Vegetation and/or 2. Benthic Community

8 0

w/o pres orcurrent with

y

Score s m of abo e scores/30 For impact assessment areasIf preservation as mitigation

8 0

Insert discussion including justification for score here.

currentor w/o pres

Preservation adjustment factor =

Adjusted mitigation delta = with

Score = sum of above scores/30 (if uplands, divide by 20)

For impact assessment areas

FL = delta x acres =

If preservation as mitigation,

0.8 00.8(2ac)=1.6

Delta = [with-current] Time lag (t-factor) =

Risk factor =

If mitigation For mitigation assessment areas

RFG = delta/(t-factor x risk) = 0.8

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Calculate MitigationCalculate MitigationMitigation Determination Formulasg

For each impact assessment area:pFunctional Loss (FL) = Impact Delta x Impact

Acres

For each mitigation assessment area:R l i F i l G i (RFG) Mi i i D lRelative Functional Gain (RFG) = Mitigation Delta

(t-factor)(risk)

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Calculate MitigationCalculate Mitigation• When using a mitigation bank permitted underWhen using a mitigation bank permitted under

UMAM, the FL = # credits needed• When determining mitigation not using a bank, the g g g ,

FL/RFG for each assessment area is the amount of mitigation required. Total mitigation is sum of all area calculations.

• When using a bank not permitted under UMAM, h i i l h dyou must revert to the original assessment method

unless directed otherwise by the permitting agency.

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Not Present (0)Moderate(7) Minimal (4)Scoring Guidance

.500(6)(a) Location and

Optimal (10)

Site/Project Name Application Number Assessment Area Name or NumberImpact or Mitigation Assessment date:Assessment conducted by:

Project XMitigation

Wetland X40-XXXJune 2, 2008John Doe

w/o pres orcurrent

.500(6)(a) Location and Landscape Support

with

4 8

Insert discussion including justification for score here.

w/o pres orcurrent with

.500(6)(b)Water Environment (n/a for uplands)

Insert discussion including justification for score here.

.500(6)(c)Community structure

1. Vegetation and/or 2. Benthic Community

4 8

w/o pres orcurrent with

y

Score s m of abo e scores/30 For impact assessment areasIf preservation as mitigation

4 8

Insert discussion including justification for score here.

currentor w/o pres

Preservation adjustment factor =

Adjusted mitigation delta = with

Score = sum of above scores/30 (if uplands, divide by 20)

For impact assessment areas

FL = delta x acres =

If preservation as mitigation,

0.4 0.80.4(0.5) = 0.2

0.5

Delta = [with-current] Time lag (t-factor) =

Risk factor =

If mitigation For mitigation assessment areas

RFG = delta/(t-factor x risk) = 0.4 0.2 / (1*1) = 0.2

1

1

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Calculating MitigationImpact

AssessmentArea FL =

Credits neededArea FL =

example1

needed

1 2a.a.1a.a.2total

1.2 1.2

1.2

FL / RFG = Acres of Mitigation

examplea.a.1

Mitigation

1.2 0.2 6 acres

a.a.2total 6 acres

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UMAM and the ACOEUMAM and the ACOE

• To simplify and speed evaluation of ACOE• To simplify and speed evaluation of ACOE permits, the Jacksonville District implemented UMAM in the State of Florida on 8-1-2005UMAM in the State of Florida on 8-1-2005

• Provided a standardized procedure for i f ti id d b tl dassessing functions provided by wetlands

and Waters of the U.S., the reduction of those f nctions b a proposed impact and thefunctions by a proposed impact, and the amount of mitigation required to offset

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UMAM and the ACOEUMAM and the ACOE

• Consistent with the ACOE Regulatory• Consistent with the ACOE Regulatory Guidance Letter 02-2 the assessment methodology needed to provide a minimummethodology needed to provide a minimum one-to-one functional replacement for wetland losswetland loss

• After extended testing, partnering, reference sites and calibration the ACOE implementedsites, and calibration, the ACOE implemented UMAM with a few differences from the State methodologmethodology.

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UMAM and the ACOEUMAM and the ACOE

• Time Lag• Time Lag– 3% rate of return for the time lag factor

instead of the 7% rate used by the Stateinstead of the 7% rate used by the State• Preservation as mitigation

St t lib l– State more liberal• Upland Credit

– Must link upland preservation to the aquatic environment (i.e. buffer)

– No upland debit = no upland credit

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QUESTIONS?

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Using UMAM for SeagrassUsing UMAM for SeagrassUsing UMAM for SeagrassUsing UMAM for SeagrassUsing UMAM for SeagrassUsing UMAM for SeagrassUsing UMAM for SeagrassUsing UMAM for SeagrassKey PointsKey PointsSeagrass surveys can be conducted from June 1Seagrass surveys can be conducted from June 1Key PointsKey PointsSeagrass surveys can be conducted from June 1Seagrass surveys can be conducted from June 1Seagrass surveys can be conducted from June 1 Seagrass surveys can be conducted from June 1 through September 30. If possible best to through September 30. If possible best to conduct in “peak season” Julyconduct in “peak season” July –– August.August.

Seagrass surveys can be conducted from June 1 Seagrass surveys can be conducted from June 1 through September 30. If possible best to through September 30. If possible best to conduct in “peak season” Julyconduct in “peak season” July –– August.August.conduct in peak season July conduct in peak season July August.August.Ephemeral Systems Ephemeral Systems –– seagrass bed locations seagrass bed locations change over time. Best to conduct surveys overchange over time. Best to conduct surveys over

conduct in peak season July conduct in peak season July August.August.Ephemeral Systems Ephemeral Systems –– seagrass bed locations seagrass bed locations change over time. Best to conduct surveys overchange over time. Best to conduct surveys overchange over time. Best to conduct surveys over change over time. Best to conduct surveys over multiple years.multiple years.Seagrass tends to grow at depths of 6” to 10’ Seagrass tends to grow at depths of 6” to 10’

change over time. Best to conduct surveys over change over time. Best to conduct surveys over multiple years.multiple years.Seagrass tends to grow at depths of 6” to 10’ Seagrass tends to grow at depths of 6” to 10’ g g pg g pwhere there is good light penetration, sandy where there is good light penetration, sandy substrate and protection from strong tidal substrate and protection from strong tidal

g g pg g pwhere there is good light penetration, sandy where there is good light penetration, sandy substrate and protection from strong tidal substrate and protection from strong tidal activity.activity.activity.activity.

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Location and LandscapeLocation and Landscape SeagrassSeagrassLocation and LandscapeLocation and Landscape SeagrassSeagrassLocation and Landscape Location and Landscape -- SeagrassSeagrassLocation and Landscape Location and Landscape -- SeagrassSeagrassIs the site in an Aquatic Preserve or Outstanding Is the site in an Aquatic Preserve or Outstanding Is the site in an Aquatic Preserve or Outstanding Is the site in an Aquatic Preserve or Outstanding Florida WaterFlorida WaterProximity to tidal and freshwater inputs (outfalls).Proximity to tidal and freshwater inputs (outfalls).Florida WaterFlorida WaterProximity to tidal and freshwater inputs (outfalls).Proximity to tidal and freshwater inputs (outfalls).Is the site protected from wave action by Is the site protected from wave action by mangroves or riprap or naturally isolated, such as mangroves or riprap or naturally isolated, such as Is the site protected from wave action by Is the site protected from wave action by mangroves or riprap or naturally isolated, such as mangroves or riprap or naturally isolated, such as a cove.a cove.Access to wildlife to eat, spawn, etc.Access to wildlife to eat, spawn, etc.a cove.a cove.Access to wildlife to eat, spawn, etc.Access to wildlife to eat, spawn, etc.Surrounding development and boat usage in the Surrounding development and boat usage in the areaareaSurrounding development and boat usage in the Surrounding development and boat usage in the areaarea

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Water EnvironmentWater Environment SeagrassSeagrassWater EnvironmentWater Environment SeagrassSeagrassWater Environment Water Environment -- SeagrassSeagrassWater Environment Water Environment -- SeagrassSeagrassIdeal Ideal –– Tidal area with flushing channel that Tidal area with flushing channel that

i t t d h d li ht t tii t t d h d li ht t tiIdeal Ideal –– Tidal area with flushing channel that Tidal area with flushing channel that

i t t d h d li ht t tii t t d h d li ht t tiis protected, has good light penetration is protected, has good light penetration and clarity with no pollution sourcesand clarity with no pollution sourcesis protected, has good light penetration is protected, has good light penetration and clarity with no pollution sourcesand clarity with no pollution sourcesProximity to stormwater, runoff or other Proximity to stormwater, runoff or other freshwater inputsfreshwater inputsProximity to stormwater, runoff or other Proximity to stormwater, runoff or other freshwater inputsfreshwater inputsTurbidity, light penetration, sediment loadTurbidity, light penetration, sediment loadHigh tidal currents or calm watersHigh tidal currents or calm watersTurbidity, light penetration, sediment loadTurbidity, light penetration, sediment loadHigh tidal currents or calm watersHigh tidal currents or calm watersHigh tidal currents or calm waters. High tidal currents or calm waters. Proximity to pollution sources and boat Proximity to pollution sources and boat traffictraffic

High tidal currents or calm waters. High tidal currents or calm waters. Proximity to pollution sources and boat Proximity to pollution sources and boat traffictraffictraffictraffictraffictraffic

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Community StructureCommunity Structure -- SeagrassSeagrassCommunity StructureCommunity Structure -- SeagrassSeagrassCommunity Structure Community Structure -- SeagrassSeagrassCommunity Structure Community Structure -- SeagrassSeagrassSeagrass is vegetation, not benthic Seagrass is vegetation, not benthic Seagrass is vegetation, not benthic Seagrass is vegetation, not benthic Size of the seagrass bed or potential growing Size of the seagrass bed or potential growing area. Ephemeral system, so agency may claim area. Ephemeral system, so agency may claim n e l ge th n nti ip ted b ed on hi ton e l ge th n nti ip ted b ed on hi to

Size of the seagrass bed or potential growing Size of the seagrass bed or potential growing area. Ephemeral system, so agency may claim area. Ephemeral system, so agency may claim n e l ge th n nti ip ted b ed on hi ton e l ge th n nti ip ted b ed on hi toan area larger than anticipated based on history an area larger than anticipated based on history

of growing area and not what is observed in of growing area and not what is observed in one growing seasonone growing season

an area larger than anticipated based on history an area larger than anticipated based on history of growing area and not what is observed in of growing area and not what is observed in one growing seasonone growing seasonone growing season. one growing season. Density of the seagrass Density of the seagrass –– This is species This is species specific. Ex.specific. Ex. HalophilaHalophila seagrass beds areseagrass beds are

one growing season. one growing season. Density of the seagrass Density of the seagrass –– This is species This is species specific. Ex.specific. Ex. HalophilaHalophila seagrass beds areseagrass beds arespecific. Ex. specific. Ex. HalophilaHalophila seagrass beds are seagrass beds are typically spares and dynamic in nature, so these typically spares and dynamic in nature, so these features should not count against the features should not count against the

specific. Ex. specific. Ex. HalophilaHalophila seagrass beds are seagrass beds are typically spares and dynamic in nature, so these typically spares and dynamic in nature, so these features should not count against the features should not count against the community structure.community structure.community structure.community structure.

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iiiiCommunity Structure Community Structure -- SeagrassSeagrassCommunity Structure Community Structure -- SeagrassSeagrass

Use by wildlife (spawning, nesting habitatUse by wildlife (spawning, nesting habitat))Use by wildlife (spawning, nesting habitatUse by wildlife (spawning, nesting habitat))

Is Is algae algae present or other aquatic vegetation that is present or other aquatic vegetation that is tolerant of freshwater. tolerant of freshwater. Some algae, such as Caulerpa is Some algae, such as Caulerpa is Is Is algae algae present or other aquatic vegetation that is present or other aquatic vegetation that is tolerant of freshwater. tolerant of freshwater. Some algae, such as Caulerpa is Some algae, such as Caulerpa is similar to having similar to having Brazilian pepper in a wetlandBrazilian pepper in a wetland..

Is there a mangrove shoreline to complete lifecycle andIs there a mangrove shoreline to complete lifecycle and

similar to having similar to having Brazilian pepper in a wetlandBrazilian pepper in a wetland..

Is there a mangrove shoreline to complete lifecycle andIs there a mangrove shoreline to complete lifecycle andIs there a mangrove shoreline to complete lifecycle and Is there a mangrove shoreline to complete lifecycle and attract fish and wildlife.attract fish and wildlife.Is there a mangrove shoreline to complete lifecycle and Is there a mangrove shoreline to complete lifecycle and attract fish and wildlife.attract fish and wildlife.

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QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?

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Permitting and UMAM

Mark Clark, CEPSenior Biologist

Miller Legg

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UMAM Summary

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• UMAM is a valuable tool in addressing direct impact (i.e., the existing UMAM wetland

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o impact (i.e., the existing UMAM wetland functional value is reduced to “0”, with project)

Imp • As previously discussed, UMAM is used to assess the functional value of the existing impacted wetland and objectively calculate theimpacted wetland and objectively calculate the appropriate mitigation

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Secondary ImpactsAssessed when wetlands are proposed to remain onsite post-

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project or offsite adjacent to impacted wetlands

The challenge is how to assess the impacts to those remaining

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Imp • Typical Scenarios:

– Access road crossing the center of a wetland– Road widening where wetlands exist adjacent to and

beyond the project footprint

• The secondary impact would begin at the edge of the direct impact

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Secondary ImpactsTh ti i h d th d i t b d

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end?How are the applicant and agency to know when enough is

h?

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o enough?• For some guidance, the SFWMD Basis of Review states that a

15’ minimum width, 25’ average width upland buffer separating the wetland from adjacent upland activities is sufficient to avoid

Imp the wetland from adjacent upland activities is sufficient to avoid adverse secondary impacts

– This scenario works if there are no wetlands remaining adjacent to or surrounding the impact area, or there is sufficient uplands to construct a buffer next to a remaining wetland

– To construct an upland buffer within remaining wetlands adjacent– To construct an upland buffer within remaining wetlands adjacent to an impact area only increases direct wetland impacts/mitigation and isn’t really consistent with wetland impact avoidance and minimization

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Secondary ImpactsE l W tl d dj t t d ( k d d

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to the toe-of-slope):• Wetlands are located adjacent to the toe –of –slope and extend

beyond r/w

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o beyond r/w• Where would the secondary impact zone end?

Imp

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Secondary Impacts

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Is it appropriate to assume an additional 25’ extension of the direct impact footprint and use UMAM to calculate the

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• Pro – Defined zone that fits well with the existing assessment

Imp and mitigation calculation methodology (but not really allowed anymore)

C I h i l f d i l b i• Con- Is the potential for secondary impacts truly being accounted for in such a small zone

R li h i di h ll b d 25’ i• Reality: the agencies are expanding the zone well beyond 25’ in practice (zone can extend beyond 500’, for example); but how is this number determined?

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Is it appropriate to extend the potential secondary impact boundary beyond the direct impact footprint until there is a

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• Pro – Provides an indication of the potential area of impact

Imp (which could extend several hundred feet beyond the direct impact)

• Con – How is the area of secondary impact and corresponding mitigation quantified using UMAM?

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Secondary ImpactsR i iti th i l

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• Wetlands are located adjacent to the toe –of –slope and extend beyond r/w to +/- Naples

• Again where would the secondary impact zone end?

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Imp % g ( j

determination)?

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Secondary Impacts

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The secondary impact determination is not unique to UMAM (it was around with ratios and WRAP)

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The subjective determination of secondary impacts is not resolved by the objective calculation of UMAM

Imp y j

In fact, the amount of mitigation required to address direct and secondary impacts can increase significantly dependingand secondary impacts can increase significantly depending upon the acreage of impact entered into UMAM

Is onsite mitigation off site mitigation or some combinationIs onsite mitigation, off-site mitigation, or some combination of the two appropriate?

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UMAM and Mitigation

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UMAM is not necessarily supportive of onsite mitigation because :

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• The Location and Landscape score does not change much with the installation of onsite mitigation

• Onsite mitigation plans require incorporation of habitat diversity for

Imp Onsite mitigation plans require incorporation of habitat diversity for permit approval (increases time lag and risk)

• Both of these require additional mitigation acreage to balance impacts

• The greater acreage does not change the reality that “bigger” doesn’t necessarily mean “better” (remember, the Location and Landscape or time lag and risk scores did not get “better” with size)

• The above issues are still pertinent once secondary impacts are included; as secondary impacts result in a greater mitigation acreage requirement

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UMAM and Mitigation

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A regional/out-of-basin option can provide the opportunity to maximize all three UMAM criteria

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• To propose mitigation outside the impact basin requires a cumulative impact analysis

Imp

• This has to be supported by parties who have geo-political interests as well as biological (otherwise, double or triple g ( , pmitigation can result). This isn’t a UMAM issue, yet still exists

Depending on the project type (linear projects, for example), locating a suitable mitigation site can be challenging

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Conclusion

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UMAM is an excellent tool to assess wetland functional values for direct impacts and objectively determine the

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UMAM does not remove the subjectivity associated with the

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secondary impact determination and mitigation

For long-term planning studies, addressing secondary impactsFor long term planning studies, addressing secondary impacts is critical as land acquisition, funding, and/or credit reservations are determined during that phase, prior to permit application submittal