Improving the Success of Wetland Mitigation Banking: Lessons Learned in Monitoring and Compliance

Wetlands that are lost to development are not effectively compensated by the current wetland mitigation banking regulatory program due to inadequate monitoring and compliance. Based on a critical investigation of two wetland mitigation banks in Colorado described herein, recommendations are given to improve the effectiveness of the wetland mitigation banking program. The recommendations to improve mitigation banking are to specify and follow comprehensive monitoring and reporting plans, develop solid contingency and adaptive management plans, utilize specially developed checklists and templates, and impose enforcement when compliance is not met. Implementing these recommendations will assist regulators and bankers in achieving more effective wetland mitigation and will help the United States reach its no net loss of wetlands goal.

The Creation of a Legal Ordinance and Program Manual for the Purpose of Illicit Discharge Detection and Elimination

Illegal dumping and improper disposal of pollutants in urban areas can contribute significant pollutant loads to the municipal separate storm sewer system (MS4) and natural environments. Illicit discharges to the MS4 can pose a significant risk to human and environmental health. The Clean Water Act requires that municipalities implement a legal mechanism and plan to detect and eliminate illicit discharges to the MS4. The methodology for program creation included the analysis of other municipal illicit discharge programs, review of state and federal guidance publications, and the review of illicit discharge case-studies. This paper describes a systematic approach applied to the creation and implementation of a legal ordinance and program manual designed for the purpose of illicit discharge detection and elimination (IDDE).