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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
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
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.
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
Web ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb ResourcesWeb Resources
http://www.dep.state.fl.us/water/wetlands/mitigation/umam.htmmitigation/umam.htm
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!
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!
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.
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.
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
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 ]
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. .
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
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) =
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.
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.
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
Chapter 62-345.400 Qualitative Characterization Part I
Frame of Reference for TypeFrame of Reference for Type of Community and Functions
Being Evaluated
BDABDA
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
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
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
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
Qualitative Characterization Part IQualitative Characterization Part IAssessment Area Description (Based on
Community Type) Native
Significant Nearby Features
Uniqueness
BDABDA
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
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
Qualitative Characterization Part IQualitative Characterization Part I
BDABDABDABDA
Qualitative Characterization Part IQualitative Characterization Part I
BDABDA
Qualitative Characterization Part IQualitative Characterization Part INative Community Type Current Conditiony yp
BDABDA
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
U if Miti tiUniform Mitigation Assessment Method (UMAM)Assessment Method (UMAM)
Part II: Quantitative AssessmentPart II: Quantitative Assessment
Julie Sullivan, M.S.
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
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
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
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”
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
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) =
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
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
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
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) =
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
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
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
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) =
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
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.)
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
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
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)
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.
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
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
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
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.
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
QUESTIONS?
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.
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
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
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.
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.
QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?QUESTIONS ?
Permitting and UMAM
Mark Clark, CEPSenior Biologist
Miller Legg
Permitting and UMAMm
ents
.es
.
g
UMAM Summary
g En
viro
nmom
mun
itie
• UMAM is a valuable tool in addressing direct impact (i.e., the existing UMAM wetland
Cre
atin
gpr
ovin
g C
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
Permitting and UMAMm
ents
.es
.
g
Secondary ImpactsAssessed when wetlands are proposed to remain onsite post-
g En
viro
nmom
mun
itie Assessed when wetlands are proposed to remain onsite, post-
project or offsite adjacent to impacted wetlands
The challenge is how to assess the impacts to those remaining
Cre
atin
gpr
ovin
g C
o The challenge is how to assess the impacts to those remaining wetlands within the project area
i l S i
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
Permitting and UMAMm
ents
.es
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g
Secondary ImpactsTh ti i h d th d i t b d
g En
viro
nmom
mun
itie The question is where does the secondary impact boundary
end?How are the applicant and agency to know when enough is
h?
Cre
atin
gpr
ovin
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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
Permitting and UMAMm
ents
.es
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g
Secondary ImpactsE l W tl d dj t t d ( k d d
g En
viro
nmom
mun
itie Example – Wetlands adjacent to a road (work proposed down
to the toe-of-slope):• Wetlands are located adjacent to the toe –of –slope and extend
beyond r/w
Cre
atin
gpr
ovin
g C
o beyond r/w• Where would the secondary impact zone end?
Imp
Permitting and UMAMm
ents
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Secondary Impacts
g En
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nmom
mun
itie
Is it appropriate to assume an additional 25’ extension of the direct impact footprint and use UMAM to calculate the
Cre
atin
gpr
ovin
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o additional wetland mitigation required?
• 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?
Permitting and UMAMm
ents
.es
.
g
Secondary Impacts
g En
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nmom
mun
itie
Is it appropriate to extend the potential secondary impact boundary beyond the direct impact footprint until there is a
Cre
atin
gpr
ovin
g C
o natural change in the UMAM existing condition score?
• 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?
Permitting and UMAMm
ents
.es
.
g
Secondary ImpactsR i iti th i l
g En
viro
nmom
mun
itie Revisiting the previous example:
• Wetlands are located adjacent to the toe –of –slope and extend beyond r/w to +/- Naples
• Again where would the secondary impact zone end?
Cre
atin
gpr
ovin
g C
o • Again, where would the secondary impact zone end?– Is it all considered a direct impact?– What is the value depreciation if not to “0”?– Is a % of the acreage entered into UMAM (a subjective
Imp % g ( j
determination)?
Permitting and UMAMm
ents
.es
.
g
Secondary Impacts
g En
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nmom
mun
itie
The secondary impact determination is not unique to UMAM (it was around with ratios and WRAP)
Cre
atin
gpr
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o
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?
Permitting and UMAMm
ents
.es
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UMAM and Mitigation
g En
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nmom
mun
itie
UMAM is not necessarily supportive of onsite mitigation because :
Cre
atin
gpr
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o
• 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
Permitting and UMAMm
ents
.es
.
g
UMAM and Mitigation
g En
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nmom
mun
itie
A regional/out-of-basin option can provide the opportunity to maximize all three UMAM criteria
Cre
atin
gpr
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g C
o
• 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
Permitting and UMAMm
ents
.es
.
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Conclusion
g En
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mun
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UMAM is an excellent tool to assess wetland functional values for direct impacts and objectively determine the
Cre
atin
gpr
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o amount of mitigation required to offset that impact
UMAM does not remove the subjectivity associated with the
Imp j y
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