Savage_MMESThesis1994.pdf

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Part of An Evaluation of the Wetland Monitoring Program of the Washington Staet Department of Transportation

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TABLE OF CONTENTS
List of Tables and Figures ........................................................................................... vi
Acknowledgments ....................................................................................................... vii
1. Introduction ............................................................................................................. 1
2. Overview ..................................................................................................................5
2.1. Wetlands in Washington's Landscape .............................................. .5
2.2. Wetland Mitigation Within WSDOT ................................................. 6
3. WSDOT Wetland Monitoring Program ............................................................9
3.1 Current Methods ....................................................................................... 11
3.2 Evaluation of Current Methods ............................................................ 16
Overview ............................................................................................... 16
Problems with Current Methods ...................................................... 19
4. Developing Recommendations for the Monitoring Program .......................23
4.1. Interviews with Environmental Specialists within ........................ 24
U.S. Army Corps of Engineers .......................................................... 24
Environmental Protection Agency ..................................................27
U.S. Fish and Wildlife Service ..........................................................28
Washington State Department of Ecology ..................................... 29
King County Surface Water Management .....................................30
King County Environmental Division .......................................... .32
Washington State Department of Transportation ....................... 33
4.2. Review of Two EPA Studies of Monitoring
Methodology ...............................................................................................34
5. Recommendations .................................................................................................35
5.1. Methods ......................................................................................................36
5.2 Annual Monitoring Report ........................... :....................................... .46
Data Analysis and Discussion .......................................................... .47
Report Format ......................................................................................54
5.3 Promotion of In-House Use of Monitoring Data ............................... SS
Feedback Loop ....................................................................................... 56
Costs ........................................................................................................59
6. Conclusion ...............................................................................................................60
References Cited ........................................................................................................... 63

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Appendix A: History and Policy Leading to Compensatory
Mitigation ................................................................................................................ 68
Appendix B: WSDOT Process: Project Scoping, Design, and
Permitting ................................................................................................................ 75
Appendix C: Summary of Primary Regulations Pertaining to
Washington State's Wetlands ............................................................................ 79
Appendix D: WSDOT Guidelines for Wetland Mitigation Plans .................... 80
Appendix E: Current Parameters Used for Vegetation Sampling .................... 88

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LIST OF TABLES AND FIGURES
Figure 1. Baseline, transect, and sampling station placement .......................... 12
Figure 2. Line-intercept method .............................................................................. 13
Figure 3. Canopy coverage method ......................................................................... 13
Figure 4. Vegetation community summary data sheet. ..................................... 39
Figure 5. Recommended placement of baseline, transects, and
sample plots ............................................................................................................ 41
Table 1. Water Quality Criteria for Fish and Invertebrate
Production ...............................................................................................................53

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Acknowledgments

I would like to express my appreciation to the Washington State
Department of ~ransportation for providing access to the wetland
monitoring data and to my coworkers for their moral support of this
project. I thank the following individuals for their generous
contributions of both their time and expertise: Chris McAuliffe and
Muffy Walker (U.S. Army Corps of Engineers), Linda Storm
(Environmental Protection Agency), Joanne Stellini (U.S. Fish and
Wildlife Service), Tom Hruby (Washington State Department of
Ecology), Tina Miller (King County Surface Water Management), Klaus
Richter (King County Environmental Division), and Jean Mabry
(Washington State Department of Transportation); also to Rich Horner
and Sarah Cooke for their advice. My gratitude to coworkers Barb
Aberle and Mary Ossinger for their input over countless discussions of
the monitoring program and again to Mary for her excellent editing.
Finally, my very special thanks to my professor and reader, John
Perkins, for his unending patience and encouragement, and whose
belief in my ability to persevere will not be forgotten.

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1. Introduction

The very nature of the business conducted by the Washington
State Department of Transportation (WSDOT) entails direct contact,
and often direct conflict, with the environment. The state's ferry
system, railways, and road network fall under the direction of an
agency whose prime directive is ".... to provide safe, efficient,
dependable, and environmentally responsive transportation facilities
and services."l According to a Washington State Department of
Transportation (1990) report to the Washington State Legislature many
of Washington's highways are nearing or have reached vehicle
carrying capacity. Roads that were not intended to handle high volume
use are becoming overburdened, a fact that has created not only the
necessity for higher levels of maintenance, but an increasing demand
by the public for relief from traffic congestion (Washington State
Department of Transportation 1990). This relief from congestion is
often provided by road widening projects and new access roads linking
heavily traveled rural routes to major highways.

Most of Washington's roads were built long before wetlands' place
in the landscape garnered much acclaim and hence, little consequence
was placed on routing a road through wetland systems. WSDOT road
construction projects projected through the end of this decade involve
widening roads, adding passing lanes, adding bike paths, constructing
safer road shoulders, improving highway safety (e.g. straightening
1 WSDOT Mission Statement: "The mission of Washington's transportation system is to
provide safe, efficient, dependable, and environmentally responsive transportaion
facilities and services."

1

curves that no longer meet WSDOT standards), or adding access routes
to existing highways (Rettew 1994). The majority of these types of
projects entail using additional land on either side of the existing
roadways. Where road project and wetland meet, there is the potential
for negative impact to these environmentally sensitive areas.

Activities in wetlands are controlled by federal, state, and in
some instances, local regulations. WSDOT road projects that
involve the dredging or filling of a wetland will require federal
permits under Section 404 of the Clean Water Act2 and will
generally require compensatory mitigation under the terms of
the permit.3 This typically involves creating a replacement
wetland, or combining wetland creation with enhancement of a
degraded wetland, and monitoring the progress of the site.
Although compensatory mitigation cannot replace the original
wetland impacted by construction activities, it is intended to
balance the loss by creating a system that provides wetland
functions similar to those of the original wetland. At each
mitigation site the development of these functions must be
monitored, an activity that entails some level of sampling water,
soil, vegetation, and wildlife. Monitoring provides a systematic
means of tracking the development of the wetland over time,

2 Refers to the Federal Water Pollution Control Act of 1972, later amended as the Clean
Water Act of 1977 (33 USC 1344). Appendix A provides greater detail on Sec. 404.
3How compensatory mitigation came into being through the Amendments to the
Federal Water Pollution Control Act of 1972 and where wetland creation and
monitoring fall in the timeline of a WSDOT project are somewhat ancillary to the focus
of this paper. However, the legal and temporal aspects may provide a perspective on
what emphasis WSDOT places upon wetland mitigation and the monitoring program,
and are therefore included as Appendix A and B, respectively.

2

determines compliance with the goals and objectives set for the
site, and provides a critical source of feedback for future site
designs.

WSDOT began its wetland monitoring program in 1988 with six
created wetland mitigation sites. Several significant changes have
occurred in the six years since the inception of the program. Most
notable is that in this time period the number of mitigation sites have
almost tripled: in 1994 twenty mitigation sites will be monitored and
additional sites are likely for 1995. Another change is that the goals and
objectives outlined for the mitigation sites have evolved from broadbased, generically applied standards to directives tailored to the
individual wetland site. In addition, the criteria (standards of success)
set for achieving those goals have become more rigorous. Monitoring
costs for each site have also increased, rising by almost twenty-five
percent over the past two years. The estimated cost to monitor a
wetland site in 1994 is $5000.00. Total monitoring costs in 1994 for
twenty sites will approach $100,000.00. Over the five years of
monitoring expected for these sites WSDOT will have spent nearly 0.5
million dollars; an amount that will increase accordingly as more sites
are added. The combination of increased costs, higher standards for
mitigation site development, and the increase in the number of sites
monitored has made it necessary to assess the monitoring program for
efficiency and effectiveness.

This paper evaluates the WSDOT wetland monitoring program
with a focus on its three main components: the methodology, the

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annual monitoring report, and the in-house (WSDOT) use of the
monitoring results. The main objectives are to provide
recommendations for a more efficient monitoring methodology, to
better present the data in the annual monitoring report, and to
promote more effective use of the report within WSDOT.

Room for improvement was found in each area. With the
methodology, some changes to sampling design combined with
additional sampling methods will be necessary in order to meet the
more stringent requirements set forth in the goals and objectives for
the newer wetland sites. Instead of employing one monitoring strategy
for all mitigation sites, the rigor of the standards of success should
drive the level of monitoring necessary to meet the goals for an
individual site. The annual report represents the compilation of all
data generated in one monitoring season. In its present format the
report is difficult to follow. Minor changes would enable the reader to
more readily extract specific information for any site. Also, the annual
report is weakest in its analysis and recommendations section, which
would provide feedback critical to the long-term success of WSDOT
wetland mitigation. Finally, there needs to be better promotion of
internal use of the annual monitoring report. Many of the WSDOT
landscape architects and planners, those involved in the technical
design of the mitigation sites, are not familiar with the annual
monitoring report. The overall mitigation program loses its
effectiveness if the information generated from site monitoring is not
incorporated into future site design, and ultimately, furthering
knowledge of what makes a successful wetland mitigation site.

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2. Overview

2.1. Wetlands in Washington's Landscape

Often characterized as lands that are transitional between
terrestrial and aquatic ecosystems (Cowardin et al. 1979), wetlands have
been given several formal definitions. In general each definition
centers on three basic characteristics that separate wetlands from other
systems: 1) water is present at some time during the growing season, 2)
the soils are saturated to an extent that anaerobic (without oxygen)
conditions prevail, and 3) the predominant vegetation is adapted to
saturated conditions (Mitsch and Gosselink 1986, Cowardin et al. 1979).
Washington is host to a variety of wetland types from the alkaline
vernal pools and potholes in eastern Washington to the highly acidic
bogs and fens of northwestern Washington (Stevens and Vanbianchi
1993). Tidal marshes, forested riverine wetlands, sub-alpine wet
meadows, and isolated lowland pools are other wetland types, all
which have contributed to what has been estimated as 1.35 million
acres of wetlands, (approximately 3% of Washington's total area), at
pre-European settler times (Dahl 1990). Over the past two centuries
losses of these unique systems in Washington State have been
estimated to be between 31% (Dahl 1990) to greater than 50% (McMillan
1987) of their original area. Tidal wetlands have sustained the greatest
losses, estimated at greater than 80% destroyed (Stevens and
Vanbianchi 1993). Washington State is on par with the rest of the
nation in wetland losses; of an estimated 221 million wetlands in the

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conterminous United States at the turn of the 18th century, it is
estimated that 53% of the original acreage has been lost (Dahl 1990).

There is no one encompassing piece of legislation at either the
federal or state level (in Washington State) that has as its primary
function the regulation of wetlands (Washington State Department of
Ecology 1988). Instead, various laws and ordinances from federal to
local jurisdictions are used to regulate human activities in these
systems. Refer to Appendix C for a listing of the primary
laws/regulations pertaining Washington wetlands.

2.2. Wetland Mitigation Within WSDOT

For the purposes of this paper, the term "wetland mitigation"
refers to the compensation of wetland impacts through creating,
enhancing, or restoring wetlands. The terms restoration, enhancement,
and creation have often been used in different ways in different parts of
the country and within different state, county, and local jurisdictions
(Lewis 1990). As adopted from recommendations presented by Lewis
(1990) for standardizing wetland terminology, "created wetland" refers
to a wetland that has been constructed in an area that has not been a
wetland in recent times (100-200 years). "Wetland enhancement" refers
to human activities occurring in an existing wetland for the purpose of
increasing the overall value of the wetland; e.g., increasing wildlife
habitat value or water quality. This may include modifying the existing
contours of the wetland, reintroducing meanders to a stream that has
been straightened, or the addition of different species of wetland .

6

vegetation. "Wetland restoration" is the process of returning an area
that was once a wetland to its historical, or pre-disturbance condition.

All WSDOT projects involving wetland impacts follow guidelines
established by the National Environmental Protection Act of 1969
(NEP A) and the 1971 State Environmental Protection Act (SEP A - a
parallel to NEP A). The NEP A/SEP A process requires that a full
disclosure of environmental impacts be made for any project
involving federal/ state actions, that all adverse environmental
impacts resulting from a proposed project be evaluated, and that all
practicable alternatives to avoid the impact be considered (Washington
State Department of Ecology 1988). Although not specific to wetlands,
both NEP A and SEPA have adopted a sequential process of mitigation
(as supported by the Environmental Protection Agency- EPA),
authored by the Council on Environmental Quality in 1979. These
sequential steps, adapted by WSDOT and the Washington State
Department of Ecology (WSDOE/Ecology) in their Implementing
Agreement Concerning Wetlands Protection and Management
(WSDOT and WSDOE 1993), are as follows:4

1) A void impacts altogether by not taking a certain action or part of
an action;
4 A Memorandum of Understanding (MOU) was adopted between WSOOT and Ecology
in 1988 in an effort to facilitate the environmental review of WSDOT documents and
improve the coordination of activities surrounding permit application and processing.
In 1993 the two agencies developed a supplement to the MOU, the Implementing
Agreement between the Washington State Department of Transportation and the
Washington State Department of Ecology Concerning Wetlands Protection and
Management, specifically to address issues concerning wetland protection with regard
to WSDOT construction projects. The section in the Implementing Agreement that
addresses mitigation plans and site monitoring is given in Appendix D.

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2) Minimize impacts by limiting the degree or magnitude of the
action and its implementation;
3) Rectify impacts by repairing, rehabilitating, or restoring the
affected environment;
4) Reduce or eliminate impacts over time by preservation and
maintenance operations during the life of the action;
5) Compensate for impacts by replacing, enhancing, or providing
substitute wetland resources or environments;
6) Monitor the mitigation by systematic evaluation of the
development of a constructed wetland to determine success.

Unavoidable wetland impacts are addressed in a wetland
mitigation plan drawn up by a WSDOT biologist. In this document the
impacted wetlands are described, the terms for mitigating the wetland
impacts are proposed (which includes steps taken to avoid and
minimize impacts as well as wetland creation), the prospective
mitigation site is identified, and the basic design plans are given for the
wetland to be constructed. This includes grading plans (wetland
configuration and contours) and planting plans specifying species,
quantities, and placement of the vegetation to be planted on the site.
The mitigation plan also provides goals, objectives, and standards of
success (criteria by which to evaluate the progress of the created
wetland) for the site. Ideally the mitigation plan should dictate the
level of monitoring that takes place on the individual sites. WSDOT
projects that require mitigation in the form of wetland creation may
take less than one year or greater than ten to go from the scoping (preproject) phase, to the project design stage, through the permitting

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process, into the construction phase, and finally to the construction and
planting of the wetland mitigation site. A more detailed account of this
process is given in Appendix B.

3. WSDOT Wetland Monitoring Program

Wetland monitoring by WSDOT is defined as the process of
tracking the development of its created wetlands over time through
the systematic sampling of water, soil, vegetation, and wildlife. The
goal of the wetland monitoring program is to ensure mitigation
compliance as specified in the wetland mitigation plan, which has been
incorporated into the terms of the permits issued by federal, state, and
local regulatory agencies. To meet this goal WSDOT must show that its
created wetlands have obtained or are developing 1) wetland
characteristics of hydrology, hydric soils, and hydrophytic vegetation,
and 2) wetland functions of flood attenuation, sediment trapping,
water quality improvement, wildlife habitat, and food chain support.

Wetland mitigation sites are typically monitored for five years, a
length agreed upon between the United States Army Corps of
Engineers (Corps) and WSDOT, starting with the first growing season
after construction of the wetland has been completed and/ or the site
has been planted. Monitoring occurs over a four month period
beginning mid-May and continuing into early September. WSDOT
mitigation sites are mostly concentrated in the region west of the
Cascade Mountains, ranging from Whatcom County in the north to
Wahkiakum County in the south of the state, and are located in both

9

rural and urban settings. Mitigation sites are also located on the
Olympic Peninsula and east of the Cascades.

Monitoring results are compiled in an annual report that is
submitted to the Corps, EPA, U.S. Fish and Wildlife Service (USFWS),
Ecology, Washington Departments of Fisheries and Wildlife (WDFW)
and the Federal Highways Administration (FHWA). The report is also
sent to the environmental divisions of each WSDOT district.S Ideally,
the report should provide the regulating agencies with the information
necessary to determine permit compliance as well as important
feedback to WSDOT through data analysis and recommendations to be
incorporated into future mitigation site designs.

WSDOT mitigation projects that require monitoring are mostly
created wetlands, although a few of the more recent sites have
combined wetland creation with wetland enhancement. Monitoring of
a mitigation site encompasses the actual wetland and its surrounding
upland buffer (a non-wetland area that may be entirely replanted or be
a combination of replanted and existing vegetation). Current WSDOT
monitoring protocol is modified from methodology described in Guide

for Wetland Mitigation Project Monitoring (Horner and Raedeke 1989),
a document prepared specifically to help shape the WSDOT
monitoring program. As indicated in previous sections, data are
collected on parameters that are indicative of the success and
development of the constructed wetland. The techniques and methods

5 In addition to the headquarters office, WSDOT is divided into six regional districtseach district has a central office and various field stations.

10

currently used to monitor WSDOT wetland mitigation site, as adopted
from Horner and Raedeke (1989) and summarized from the WSDOT
1993 Monitoring Report (Savage and Olds 1994), are presented below.

3.1 Current Methods

Preparation of a new mitigation site involves setting a baseline
and transects, which are used to identify sampling stations for each of
the monitoring tasks (see Figure 1). The baseline is established in the
upland area and parallel to the wetland within each mitigation site.
Transect lines are set perpendicular to the baseline and extended into
the upland buffer beyond the opposite end of the wetland. During
monitoring a tape measure is stretched the length of the transect. This
provides reference points for the fixed stations from which all site
sampling occurs.

Assessing the development of the vegetation community in the
mitigation sites has been the focal point in the WSDOT monitoring
program. Two plant sampling methods, line-intercept (Canfield 1941),
and canopy coverage (Daubenmire 1959) are used to evaluate the
occurrence and influence of plants in the mitigation site. The lineintercept method is used for woody vegetation (trees and shrubs)
greater than one meter in height. All vegetation intercepting the tape
measure stretched along the transect line is identified and the length of
intercept is recorded (see Figure 2). The canopy coverage method
provides a means to assess the herbaceous layer, defined as all nonwoody vegetation and woody plants less than or equal to one meter in

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mitigation site boundary
wetland boundary
baseline
transect
bird station
invertebrate station
water station
soil station

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Figure 1. Baseline, transect, and sampling station placement.
(Modified from Horner and Raedeke 1989)

12

I

height. Rectangular plots measuring O.Sm2 are established at 3m or 6m
intervals (3m for transects less than or equal to 60m, and 6m for
transects longer than 60m) along the transects (see Figure 3). In each
plot all vegetation is identified. An estimate is made of the percent of
total area within the plot that is non-vegetated and of the percent cover
by each species of vegetation.

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25cm

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Transect

Figure 2. Line-intercept method.

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Figure 3. Canopy coverage method.

13

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The data from the line-intercept method are computed as percent
area cover. Data collected by the canopy coverage method are compiled
as cumulative vegetative cover (accounts for overlapping vegetation),
percent area cover by all species combined (ratio of vegetated to nonvegetated area), percent cover by individual species (a proportion of the
total vegetative cover), and species richness (the total number of
species sampled). The parameters used to report the results of
vegetation sampling are given in greater detail in Appendix E.

Bird surveys are the primary means used by WSDOT to quantify
wildlife use of a mitigation site. Three formal bird surveys are
conducted annually from permanent census stations at each of the
sites. The surveys take place between sunrise and noon, and are
scheduled from May through June. Biologists conduct the survey by
standing silently at a station for five minutes followed by five minutes
of recording all bird species detected by sight or sound within 30 meters
of the mitigation site. In addition to the surveys, any wildlife sign (e.g.
tracks, scat), and/or sightings are recorded throughout all site visits.
The bird surveys are conducted during optimal weather conditions,
(i.e. little to no precipitation, and light to no wind), to ensure good
visibility. The results are reported as species richness.

Benthic invertebrates (the larval form of aquatic insects residing
in the substrate) are sampled on or near established transects with a
standard Surber square-foot stream bottom sampler (net) in streams,
and with a tube (corer) sampler in ponds (Brooks and Hughes 1988,
Swanson 1978). Surber samples are taken mid-stream, and tube

14

samples are taken in standing water approximately one meter from the
shoreline. Invertebrate collection is conducted from mid-June to midJuly. Both Surber and tube samples are washed and filtered through a
0.5 mm sieve, then placed in a sample jar and preserved with alcohol
for later analysis. Invertebrates are classified to order, counted, and
then air dried for 3-5 minutes before being weighed. Data are reported
as total individuals counted, taxa richness (number of orders
identified), relative abundance (percent distribution of the taxa), and
average density.

Temperature, pH, and dissolved oxygen are water quality criteria
measured for each site. Measurements are made with electronic meters
and all sampling is done on or near an established transect. Sampling is
conducted at two or more locations, (near the inlet and outlet, if
applicable), with three samples taken at each location and the results
averaged. Water quality sampling is conducted during every site visit.
Results are reported as a high/low range of the averages. Staff gauges (a
post to which a measuring staff is attached) have been placed at some
sites. The gauge is read each site visit and provides a means for
monitoring changes in water level.

Soil samples are usually taken from each site during the first,
third and fifth years of monitoring. Soils are analyzed for organic
content and percent sand, silt, and clay. First year samples are taken
from the wetland and upland area and subsequent years' samples are
from the wetland area only. Soil cores are used to establish a baseline
from which to document changes in soil characteristics over time.

15

Samples are ideally taken to a depth of 32 centimeters. Soils are
characterized by hue, value, and chroma according to the Munsell soil
color chart (Munsell Color 1990). Each Munsell color notation for soil
matrix is given with the corresponding depth at which it occurred in
the core sample.

Mitigation sites are photographed annually from permanently
established photo monitoring stations as another means of
documenting changes to the plant community. All slides and prints are
on file at the WSDOT Headquarters in Olympia, Washington. During
all visits general site conditions are noted. Presence of litter, evidence
of vandalism or other signs of disturbance are recorded and WSDOT
Maintenance personnel are notified as appropriate.

3.2 Evaluation of Current Methods

Overview

Three major factors were taken into consideration in the
evaluation of the WSDOT monitoring program: 1) it is stated in the
Implementing Agreement (Washington State Department of
Transportation and Washington State Department of Ecology 1993) that
a monitoring program "... must include measures of vegetation,
hydrology, water quality, soils, and wildlife over time"; 2) WSDOT
monitors its created wetlands out of compliance with mitigation
requirements and to measure the success of the wetland in meeting the
goals set for the site; and 3) the high number of mitigation sites that

16

must be monitored within a relatively short amount of time (less than
five months) limits the complexity of sampling methodology that can
be undertaken.

The first factor is important in that it sets the basic sampling
parameters that must be included in the monitoring. Although the
current program does provide these measurements, the collection of
the data is not focused. Each task, whether sampling water quality or
estimating percent cover for vegetation, is seemingly isolated from the
next task. The lack of continuity is apparent in the annual report where
the data are reported yet very little analysis or discussion is offered to
integrate the results of each task.

This is reflected in the second factor: WSDOT monitoring is
motivated by the need to satisfy regulations, not research needs. The
current level of monitoring reflects what have typically been general
goals and broad-based objectives set in the mitigation plans developed
for each site. Although by 1991 WSDOT mitigation plans were
beginning to set more specific requirements for tracking the success of
its created wetlands, the advent of the Implementing Agreement in
1993 provided a standard for mitigation plans to follow in which goals
and objectives for the wetland mitigation site are more clearly defined.6
Objectives now identify specific actions to take that will show a wetland
6The 1993 Implementing Agreement between the Washington State Department of
Transportation and the Washington State Department of Ecology Concerning Wetlands
Protection and Management was drawn up as a supplement to the 1988 Memorandum of
Understanding between the two agencies. The Implementing Agreement specifically
adresses issues concerning wetland protection with regard to WSDOT construction
projects. Refer to Appendix D for the section that gives the guidelines for wetland
mitigation plans.

17

function is being provided by the mitigation site, and performance
standards have been added as a means to evaluate whether the
objectives have been attained.

To illustrate, the goals set for a wetland created in 1989 were to
encourage the revegetation of native species through planting, and to
create the wetland functions of flood storage, sediment trapping, food
chain support, and fish and wildlife habitat. Success was to be
determined by the attainment of 90% vegetative cover of the site by its
fifth year.7 In contrast, a mitigation plan developed for a created
wetland constructed in 1994 gives as its goals the "successful
duplication of a functioning stream system and creation of a
wetland/riparian zone to enhance stream values."8 The objectives are
to "create improved habitat structure to support and enhance fish use,
... [through] providing shelter, erosion control, and areas for spawning,"
and to "create a wetland/riparian zone along the creek that enhances
and protects stream values." The criteria given to meet these goals and
objectives require measurements of invertebrate and vegetative
production and documentation of the presence of in-stream habitat
structures. The measurements will provide a means by which to assess
whether the stream and surrounding riparian zone are providing food,
shelter, erosion control, and spawning habitat. The criteria further
specify distinct percent vegetative cover requirements for three

7 SR 167: South 180th Street to SR 405, Northbound HOV Lane, L-8612, Wetland
Mitigation Plan. Unpublished document prepared for Washington State Department of
Transportation, 1987; pp. 9. Olympia, Washington.
8 Barbara Aberle and Scott Clay-Poole. Wetland Mitigation Plan: 208th Street SE to
164th Street SE, SR 527. Unpublished document prepared for Washington State
Department of Transportation, July 1992; pp. 9. Olympia, Washington.

18

different vegetative zones, minimum number of vegetative species for
each zone, and the percent of overall vegetative cover for each zone
that must be comprised of native Washington species.

The third factor, an increased number of mitigation sites with
commensurate increases in workload, is creating a situation where a
limit is being reached as to what can be physically accomplished in one
season by the WSDOT biologists available to conduct the monitoring.
Time constraints, available work force, and monetary limits all
combine to affect the level of sampling that can occur.

Problems with Current Methods

The major problems center on how to revise the sampling
methodology for vegetation in a manner that will provide specific (and
separate) information on wetland and upland zones, yet not entail
significantly greater expenditures of time. Currently vegetation
sampling is the most time intensive task, requiring a minimum of one
day in the field to conduct the sampling and from an average of five to
more than eight additional hours devoted to identifying plants that
were not known in the field. Other problems include a lack of
standardization in number and location of samples collected (soil and
water), unavoidable bias in collection (invertebrates), or need for
additional sampling (wildlife). In all cases more emphasis on analysis
of the data and evaluation of results is needed in the annual report.
The following list highlights the major areas needing change in the

19

monitoring methods in order to satisfy the more stringent standards of
success now being applied to WSDOT mitigation sites.

Vegetation:
1.

Current methods combine vegetation data for upland and wetland
zones; a different methodology is needed to characterize each
vegetation zone.

2.

A boundary must be established to distinguish between wetland
and upland zones; however, standard delineation methods which
require indicators of hydric soil, wetland vegetation, and
hydrology cannot be easily applied to newly constructed
mitigation sites. Soils may be entirely from another area or mixed
with existing soil, and wetland vegetation may or may not yet be
established.

3.

The number of sampling plots range from 45 to 80, averaging 65
plots per site; not only are the time costs high for this level of
sampling, but the degree of information yielded may be far greater
than is necessary. Number of plots needs to be reduced for greater
efficiency but equal effectiveness.

4.

Sample plots are 0.5 m 2 , which may be too small to avoid the
effects of vegetation clumping.

5.

There has been a lack of consistency on what constitutes bare
ground. An area of ground shaded by the canopy of a tree, yet

20

otherwise devoid of vegetation, has been interpreted as vegetated
or non-vegetated by different biologists conducting the
monitoring. Hence, the areal cover of vegetation reported for a
site, which is calculated by subtracting the total estimated percent
of bare ground from 100%, may show greater fluctuation from
year to year than is actually the case. A standard protocol is needed
for reporting bare ground.

6.

Inaccuracies in reporting the percent vegetative cover of a site may
be further compounded by the following:
a) total sampling area for a site is not calculated,
b) open water areas (loosely defined in WSDOT monitoring as
areas of non-vegetated water) that fall within a transect are
included in bare ground calculations,
c) transect length varies both within and between sites; there is
no standard protocol for how far back from the water's edge to
extend the transects.
Therefore two sites approximately the same size that have equal
areas of open water but different transect lengths may reflect vastly
different values for percent cover of vegetation. Standard protocol
is needed for each of the above.

7.

As-built grading and planting plans have not been considered in
the yearly analysis; as-built plans show the site as it was actually
constructed, giving the final grading and configuration of the
wetland, and the actual numbers and species of vegetation
planted. Many of the more recent mitigation plans are requiring

21

that the percent survival of planted species be reported; the final
planting list is necessary for these calculations.

Wildlife:
Current bird survey sampling methods are generating sufficient
data for analysis, however these surveys are the only formal
method used for assessing wildlife use of the site.

Invertebrates:
Current sampling methods are limited to sampling for preemergent aquatic invertebrates and presence (and quantity) or
absence of taxa are affected by seasonal timing of sampling. Both
factors may introduce bias resulting in an inaccurate
representation of taxa.

Soil:
Soil sampling for Munsell color characterization and organic
content analysis varies in the number of samples collected from
each site, where the sampling takes place, and how often sampling
occurs (i.e. annually, every other year, first and last year of
monitoring, etc.). A standard protocol should be adopted.

More recent mitigation plans have called for measuring sediment
accumulation within the created wetland, but do not specify
objectives; monitoring for sediment accumulation unrelated to a
specific objective may not provide useful information.

22

Water:
The number of water samples collected varies from site to site; a
standard protocol should be followed.

Staff gauges should be installed at all sites except those that are
tidal influenced. Currently measurements of water level
fluctuations are only taken during late spring and summer
months which is not adequate to provide an accurate picture of
site hydrology.

4. Developing Recommendations for the Monitoring Program

Federal, state, and local agencies are involved in various aspects of
issuing permits for WSDOT projects involving impacts to wetlands.
The annual monitoring report provides a primary means for the
agencies to evaluate whether the terms of the permits are being
satisfied. Environmental personnel in the U.S. Army Corps of
Engineers (Corps), Environmental Protection Agency (EPA), U.S. Fish
and Wildlife Service (USFWS), Washington State Department of
Ecology (Ecology), and King County Surface Water Management
(SWM) were interviewed for their input on current WSDOT
monitoring methods, the perceived problems with, and proposed
changes to, the methods, and the content and format of the annual
monitoring report. A WSDOT landscape architect involved in
mitigation site design was contacted specifically for input regarding the
content and format of the annual report.

23

In addition to the informational interviews conducted with the
above named agencies, two recent EPA studies on monitoring
methodology were examined for applicability to the WSDOT
monitoring program. Agency comments and a summary of the two
studies are given below.

4.1. Interviews with Environmental Specialists within
the Regulatory and Resource Agencies

U.S. Army Corps of Engineers9

McAuliffe and Walker (1994) suggest that newly constructed sites
should be left unplanted for at least one winter to assure that the water
depths are what were called for in the site design. Water levels should
then be staked at the time of site inspection. The wetland boundary on
newly constructed sites may be initially established based on the water
level present at that time. This point should be staked on each transect
line. Sample plots should then be differentiated by whether they fall
within the buffer, the wetland, or the edge where the two zones meet.
Each year should be analyzed as to the change in vegetation (and water
level) with relation to the original staking. This way perhaps some
correlation can be made between the success of the plantings and the
particular water level.

9 The Corps of Engineers is responsible for granting Section 10 (Federal River and
Harbor Act of 1899; 33 USC 401 § 10) and Section 404 (Ammendments to the Federal
Clean Water Act of 1977; 33 USC 1344) permits for construction activities in navigable
waters of the state and dredge and fill activities in all waters of the state, including
wetlands. Refer to Appendix A for more detail on the Corps' role in Section 10 and
Section 404.

24

McAuliffe suggests that sites should be considered for revegetation
through natural recruitment (i.e. not planting a site) only when there
is a wetland system nearby that has the type and quality of plants
desired in the newly created system. He cautions that high mortality of
some species may be due to WSDOT attempting to jump into a
successional stage that is out of sequence, that is, WSDOT is attempting
to create a mature vegetative community that bypasses the earliest
successional stages. He suggests that WSDOT avoid planting
understory species, (species that prefer shade during early growth), and
focus instead on establishing fast growing, early successional stage
species such as alder, cottonwood, and willow. Planting of the
understory may be phased in after the overstory has had a chance to
become established. McAuliffe believes that if WSDOT can successfully
establish hydrology on the site that "... the rest will follow."

McAuliffe and Walker suggest that more control is needed over
the top soil that is applied to the site. Soil brought in from other areas
may be a major source of invasive (undesirable) species. Water levels
should be checked seasonally, not just during the summer monitoring.
If the water level is monitored according to how it was initially staked

out, and monthly records are made of water level fluctuations by using
staff gauges, McAuliffe does not see the need for more detailed
hydrology measurements. Seasonal monitoring will provide
information that can then be related to the development of hydric soils
on the site. Combine this data with the results of Munsell soil color
designations to determine change in soil characteristics. Tests for
sand/silt/clay composition only need to be done at first and final

25

monitoring, and organic matter buildup can be monitored adequately
on site visits by manual measuring.

McAuliffe and Walker say the Corps would like the annual
reports (hence the data) to reflect the successional stages of the
vegetation over the five year monitoring period, specifically with
respect to which species are invading. This information could be
analyzed with respect to the degree of saturation on site. Regarding the
format of the annual report, the Corps would like to see the wetland
mitigation sites grouped according to geographic location.1 o Each
section should include all the data analysis and site specific
information (i.e. bird surveys, soil/water charts, etc.) for those
particular sites. The background, goals, objectives, and standards of
success (as stated in the mitigation plan) for each site should be clearly
stated in each annual report.

At the end of the final monitoring year, McAuliffe and Walker
would like to conduct the close-out evaluation of the site from two
angles: 1) if WSDOT didn't meet the objectives, is some level of
remedial action necessary? and 2) if WSDOT got something different
than what was planned, does it work? These will be taken into
consideration in the overall evaluation. McAuliffe states that from the
Corps' standpoint (as a regulatory agency) it doesn't do WSDOT any
good not to recognize what isn't working, especially since the Corps
will figure it out sooner or later. He mentions that it is important to

10Author's note: geographical grouping would be most readily accomplished by
grouping according to WSDOT District.

26

note that WSDOT is already ahead of the game because it does monitor
its mitigation sites and is consistent with turning in an annual report.
McAuliffe and Walker feel that it is more important that WSDOT
work towards achieving stability of hydrology within its created
wetlands than that it achieve a particular successional stage.

Environmental Protection Agencyll

Storm (1994) echoes the Corps by citing the importance of
separating vegetation sampling between the wetland and the upland
zones. Storm suggests that sampling be set in such a way that both the
wetland and the upland have permanent plots established, but that the
edge between the two have fluctuating plots. This will provide a means
by which to gauge changes in the vegetative edge of the wetland. Storm
agrees with the Corps that the wetland boundary should be staked
initially and change over time noted. Storm feels that the current level
of vegetation sampling is satisfactory. She believes that it is important
to identify species down to the 1% cover category and to state how
many species fall under 1% vegetative cover.

Storm comments that the regulating and resource agencies, and
WSDOT, seem institutionally stuck in trying to introduce out-of-step
succession of vegetative communities in an effort to beat out the
invasive, undesirable species. This is not to suggest that WSDOT
should discontinue planting overstory species; it is important to
11 EPA has the authority under Section 404(c) (Ammendrnents to the Federal Clean
Water Act of 1977; 33 USC 1344) to veto permits authorized by the Corps. Refer to
Appendix A for more detail on EPA's role in Section 404.

27

establish a canopy for various factors such as shading and/ or cover for
fish, invertebrates and other wildlife. One strategy to increase the
chances of survival of overstory species would be to plant larger trees
instead of seedlings. A point to consider is that WSDOT (and the other
agencies) must look at the limitations of developing wetlands in urban
environments. Storm recommends that the annual report should
reflect more of what has been learned- specifically, what worked and
what didn't. She suggests that when WSDOT changes its views
regarding wetland mitigation (i.e. places higher value on it) that it will
find it has better attainment of its goals and objectives for the
individual sites.

U.S. Fish and Wildlife Service12

Stellini (1994) suggests that more discussion be made of the area
beyond the boundary of the wetland. Specifically, the wetland buffer
and surrounding land uses, and the effect that these areas may have on
the functions of the wetland. She points out that there needs to be a
better accounting of area and dimensions of the site itself; the as-built
site should be surveyed. She suggests that water quality monitoring
(parameters) should be kept simple, that it is not realistic to try
otherwise due to the constraints on the time WSDOT is able to commit
to water quality monitoring. Stellini emphasizes that without
recommendations for on site manipulations or corrective actions to
12 Under the Fish and Wildlife Coordination Act of 1958, (33 USC 66.662), USFWS
(and the National Marine Fisheries Service) must be consulted regarding any federally
permitted projects (e.g. Sec. 404) that may have an impact on fish and other wildlife
species (Office of Technology Assessment 1984). Refer to Appendix C for the primary
regulations affecting WSDOT projects.

28

improve site functioning, or recommendations for future changes to
mitigation site planning and design, WSDOT will not progress in its
mitigation endeavors. More specifically, analysis that is not translated
into management action is useless, and is wasted effort on the part of
WSDOT.

Washington State Department of Ecology13

Hruby (1993) recommends conducting separate vegetation surveys
for wetland and upland zones, noting that this will yield information
critical to analyzing the development of the mitigation sites. He
suggests that the vegetation analysis should focus on the percent areal
cover of the site and that only those species registering over 5%
vegetative cover of the wetland or upland zones be included in the
species list. Also, each species should be listed individually by percent
areal cover (instead of as a proportion of the total cover) in order to get
a more accurate picture of the composition of total vegetative cover. He
suggests that the parameters of cumulative herbaceous cover and
percent of total herbaceous cover currently presented in the annual
report are not necessary, i.e. they do not aid in the level of analysis
currently applied. Hruby further suggests that too much detail is
currently applied to the vegetation surveys; specifically, that the
current resolution of sampling (high number of sample plots, and
identification of all species, even to under 1% cover) does not match
the resolution of the data collected for other monitoring tasks. Hruby
13Ecology is responsible for implementing various federal, state, and local regulations
regarding wetlands. Refer to Appendix C for the primary regulations affecting WSDOT
projects.

29

points out that because hydrology is a critical factor in establishing a
successful wetland, greater emphasis should be placed on monitoring
the site hydrology.

Hruby recommends conducting organic content analysis only in
the fifth (or final) year of monitoring, based on the assumption that
organic content would likely be less than 5% on a newly constructed
site. He suggests taking ten random samples from within the boundary
of the wetland and mixing them together before performing the
analysis. Hruby feels that bird surveys are significant and should be
continued. Also, that the addition of spring amphibian egg mass
surveys would provide greater depth to assessment of wildlife use of
the mitigation site. Analysis of invertebrate samples should focus more
on the identification of indicator species (species having the greatest
sensitivity to changes in their environment) than on the percent
distribution of the various taxa identified. Hruby notes that because
presence or absence of different invertebrate taxa is seasonally
dependent, sampling on or around the same date each year (which will
not necessarily correspond to the same time of season from year to
year) may be prone to error.

King County Surface Water Management14

Miller (1994) believes that surveying/recording as-built conditions
is key to tracking the performance of the wetland mitigation project.

14Local agencies share responsibility with Ecology for permits required under the State
Shoreline Management Act and the Floodplain Management Program; see Appendix C.

30

-

Miller asserts that collection of data that will not be used is a waste of
effort; monitoring should be tailored to the particular site. Specifically,
WSDOT should do what is necessary to meet the goals and objectives
set for the individual site.

Miller emphasizes that survival of planted species cannot be
calculated without as-built planting plans. (The actual number and
species planted are often dependent on what is available from the
nursery at the time of planting, and hence may differ significantly from
the original plans.) Miller suggests using the following method to
estimate planted species survival in the first monitoring year. Divide
the site into quarters (encompassing roughly equal areas of vegetation)
and walk transects that encompass the length of the quarter. Sample a
minimum of 10%, or 100 plants total for each species, (twenty-five
plants per quarter if plants are evenly distributed in each area), and
record each plant encountered as live, dead, or stressed. Miller thinks
that if there is a high level of survival in the first year it will give a
good idea of survival after five years. She also feels that it is important
to keep track of the invasive and volunteer species. Miller
recommends that hydrology measurements using staff and crest gauge
be taken monthly throughout the year.

31

King County Environmental Division 15

Richter (1994) was consulted specifically for his expertise
concerning amphibians. WSDOT is considering designing some of its
wetland mitigation sites specifically to provide amphibian habitat. The
addition of amphibian spawn surveys to the monitoring program
would provide WSDOT with a means to document the success of this
endeavor.

Richter's research has shown him that amphibians are very
selective in where they spawn. He sees amphibians as the critical link
in a healthy wetland, citing that amphibians eat invertebrates, and fish,
mammals, and birds eat the amphibians. He has found that
Ambystoma gracile (Northwestern salamander) is a good indicator

species, meaning that if this amphibian is present, then the habitat
provided is of a quality that will support many other species.

Richter also states that hydrology is the driving force behind the
presence or absence of amphibians, seconded only by the presence of
vegetation of a specific stem diameter which will support amphibian
egg masses. Richter has found that breeding Northwestern
salamanders prefer water depths of 30 to 40 em., plant stem diameters
of 3 mm (e.g. a rush), and relatively stable water levels throughout the
embryonic stage.

15The King County Environmental Division is not linked to WSDOT as either a
regulatory or resource agency.

32

With reference to hydrology, Richter is somewhat adamant that
WSDOT wetlands cannot be everything, that it may not be reasonable
to expect stormwater capacity, wildlife and emergent vegetation all in
one wetland. He points out that because of the degree of water level
fluctuation, flood storage and sediment trapping functions with regard
to many WSDOT created wetlands (e.g., smaller, steep sided sites with
open water ponds) are diametrically opposed to wildlife habitat
function. WSDOT should decide which functions are most important
and then target those desired functions through the objectives for the
mitigation site.

Washington State Department of Transportation

Mabry (1994), a landscape architect for WSDOT, points out that the
"percent herbaceous species" figure in the annual monitoring report
means very little to her if she does not know the as-built conditions for
vegetation. She cannot know if a particular planted species is
succeeding without knowing how many were planted in the first place.
Mabry points out that although she specifies quantities and species in
the final plans, the contractor may need to make last minute
substitutions. Knowing the final contours and grading as well as postconstruction conditions of the mitigation site, (such as compacted soil
due to heavy equipment on site, or vegetation planted incorrectly), is
important to Mabry, as all are factors that can affect the success of the
site. With this information better conclusions may be made as to
whether site design, construction conditions, or plant selection are
affecting the success of the planted species.

33

4.2. Review of Two EPA Studies of Monitoring Methodology

Two of the more recent studies on wetland monitoring
methodology have been conducted by Kentula et al. (1992) and Magee
et al. (1993). The central strategy presented by Kentula et al (1992) is in
the comparison of created or restored wetlands to natural wetland
systems. Kentula et al. (1992) outlines three assessment levels for
monitoring: 1) the documentation of as-built conditions, 2) routine
assessments, and 3) comprehensive assessments. The latter two differ
in the level of the data acquired. Routine assessments entail visual
estimation of vegetative cover, surrounding land observations,
wildlife seen during the visit, and water depth taken from a staff gauge.
Comprehensive assessment involves a more intensive monitoring of
parameters and should not take place until the wetland has had a
chance to settle somewhat; specifically that the vegetation has had a
chance to become established and the substrate has stabilized (3-5 years
for emergent wetlands).

Among the recommendations presented in this study are that
comprehensive monitoring be done according to a standard protocol,
that sources of error should be acknowledged, and that the
methodology used be replicable for scientific defensibility. Kentula et al
(1992) suggest that basic information concerning the created wetland
include its position in the watershed; slopes, water depth, and total
area; and adjacent land use. One of the central points made in this
study is that the data generated from created wetlands, and its analysis,

34

should be used to evaluate and improve the design of current or future
projects.

The study conducted by Magee et al. (1993) provides a protocol by
which detailed characterizations can be made of natural, created, or
restored wetlands within an urban environment. Included are
methods for performing general site characterizations, establishing site
elevations, vegetation sampling, and soil and hydrologic
characterization. The methodology is designed to be carried out in a
single site visit by a crew of eight people. Data analysis focuses on
characterizing the study wetland and evaluating it in comparison to a
natural wetland.

The primary aspect of the Kentula et al. (1992) study incorporated into
the recommendations proposed in this paper is the message that an
underlying strategy is needed for any monitoring program; specifically,
that the data and data analysis generated from the various monitoring
tasks be applied to future wetland mitigation planning. The Magee et
al. (1993) study provided useful information regarding general site setup activities, site mapping, and baseline and transect placement.

5. Recommendations

The following recommendations for changes to the WSDOT wetland
monitoring program have been compiled from feedback on the
program given by regulatory and resource agencies, a review of two
recent EPA studies of wetland monitoring methodology, and the

35

author's observations from three years of conducting the WSDOT
monitoring program. These recommendations have been incorporated
into the existing methodology adopted from the Monitoring Guide
(Horner and Raedeke 1989).

Specific methodology proposed regarding transect number and spacing,
number of sampling stations and station location, number of sample
plots for vegetation and plot size, and number of soil and water
samples, was also developed through information garnered from the
above mentioned resources. The figures given are proposed with the
purpose of promoting standardization within the WSDOT monitoring
program, as well as providing a means by which to most efficiently
gather the level of data necessary to comply with permit and mitigation
plan requirements. It is expected that refinements may be made to the
proposed methodology after field testing; however, a systematic testing
of the methodology and a more in-depth comparison to existing
monitoring methods will be necessary to test validity.

5 .1. Methods

Pre-site visit preparation -critical to keeping track of the tasks required
for each site

1.

Each site should have a checklist of specific monitoring
requirements and the years in which they are to be conducted or
completed should be clearly stated. This sheet will provide the

36

tracking system for the individual site for the duration of its
monitoring.

2.

Monitoring folder for each site should include:
-final mitigation plan
-as-built grading and planting plans
-summary sheet listing goals, objectives, and standards of success
as designated in the mitigation plan
-aerial photographs (ideally 1st and then final year of monitoring)
-vicinity map and directions to the site

Site set-up

1.

Baseline
-baseline set parallel to flow or to the longest side of the wetland
and set 15-20 minto the upland from wetland perimeter (using
water's edge)
-baseline should extend at least 5 m beyond either end of wetland
perimeter

2.

Transects
-transects should be established at evenly spaced intervals
perpendicular to baseline
-transects should extend at least 15-20 m into the upland beyond
the wetland perimeter
-establish 5 transects for wetland under 5 acres
-8 transects for wetland between 5-10 acres

37

-add transects only as needed to adequately characterize wetland
for sites greater than 10 acres

2.

Wetland boundary
-mark wetland boundary (wooden stake) on established transects;
use vegetation and hydrology to determine boundary
-record changes (if any) in boundary each year of monitoring

3.

Mapping
-complete a summary vegetation community data sheet for each
site prior to beginning the vegetation surveys (see sample data
sheet, Figure 4); this information will supplement vegetation data
collected through the sample plot surveys
-data sheets should include:
-surrounding land use
-percent area covered by open water, and herbaceous, scrubshrub, and forested zones
-percent cover estimates for dominant vegetation (20% or greater
dominance of all species within each stratum)

-create a map for each new mitigation site; include:
baseline/transect locations and locations of bird, invertebrate,
soil, and water sample stations (this is done under current
monitoring program, see Figure 1, p. 12; refer to Figure 5, p. 41
for recommended change in placement of baseline, transects,
and vegetation sample plots)

38

Vegetation Community Summary Data Sheet (complete for entire site)
Date

Site Name

Observer_ _ _ _ _ __

%

Wetland

__%
= 100%
__ % vegetated
_%trees
_%shrubs
_% herbaceous

Upland

__ % open water
_% unvegetated
_% submerged aquatics

= 100%

= 100%

__ % vegetated
_%trees
_%shrubs
_% herbaceous

__ % unvegetated

= 100%

= 100%

__ % unvegetated

= 100%

Dominant Vegetation(% of total vegetation)

Dominant Vegetation

_%
_%
_%
_%

_%
_%
_%
_%

Make a rough sketch of site; show open water, wetland, and upland; indicate general location
of dominant wetland/upland communities. Note surrounding land use and/or give description
on back.
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Figure 4. Vegetation community summary data sheet.
Modified from Magee, eta!. (1993), and Homer and Raedeke (1989).

39

I

I

!

-use aerial photographs to make estimates of wetland area at
conclusion of final year of monitoring

Vegetation

1.

Continue using line-intercept method (Canfield 1941) to provide a
measure of woody vegetation greater than 1 meter

2.

Sample plots (see Figure 5 for recommended placement of
baseline, transect, and vegetation sample plots)
-increase sample plot size from 0.5 m2 rectangular quadrat plots to
1.0 m diameter circle plots to sample herbaceous vegetation
(including emergent vegetation) in wetland and upland areas;
increased plot size will help reduce affects of vegetation clumping
-15-30 plots within wetland are adequate to characterize vegetation
-locate plots tangent to transect line
-locate first wetland plot 1 min from staked wetland boundary,
transect length at that point is recorded; this becomes a permanent
plot
-successive plots are located at 3m intervals until open water
(non-vegetated) equals greater than 50% of the plot area
-the number of wetland plots will fluctuate over the duration of
the monitoring; tracking this will result in a better assessment of
how the wetland is developing I changing

40

Key:

- - - - mitigation site boundary
---..;....-... wetland boundary
• · · ~ ·• boundary between vegetation und open water

D-- ba~cline

r ---

- - - transect
0 wetland vegetation plots

upland vegetation plots

--- - --- ---

-

..._

Upland

-

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~

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lm diameter
circumference plot

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Upland

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Figure 5. Recommended placement of baseline, transects, and sample plots

41

-15 plots in upland are adequate to characterize herbaceous
vegetation community (more plots may be necessary for sites over
10 acres)
-alternate between 1 and 2 plots per transect per side so that each
transect will have a total of 3 upland plots sampled

3.

Assessing survival of planted species
-stem counts and visual estimation for planted emergents in the
first year, and visual estimation for subsequent years
-stem counts and visual estimation for shrubs and trees in all
years of monitoring

-use following method to conduct stem counts:
-divide the wetland into quarters
-walk each quarter in parallel transects lengthwise
-count 25 plants each planted species in each quarter
-record each planted species encountered as live, dead, or stressed
-percent survival for total species planted will be extrapolated
from these sub-samples

4.

Bare ground
-unvegetated areas will be recorded as bare ground regardless of
the presence or absence of tree canopy or the presence of water at
depths of 1m or less; however, note should be made if the plot is
located under a canopy cover greater than 1m in height (presence
or absence of water is automatically recorded)

42

5.

Open water
-open water will be defined as any area of standing water greater
than lm depth that is either devoid of vegetation or containing
only submerged aquatic vegetation.

Wildlife

1.

Bird surveys
-3-5 stations per site, or as many as necessary to observe maximum
area
-begin with 5 minute wait, followed by a 5 minute survey
-select stations where greatest area can be observed, yet observer is
as hidden as possible (this will be difficult on most new sites)
-provide more extensive evaluation of data in the annual report;
integrate results with those from the other sampling parameters

2.

Wildlife sign
-note wildlife sign on all visits
-relate sign to habitat and other sampling parameters

3.

Habitat structures
-record in first year, then any changes thereafter
-note root wads, stumps, downed trees, snags, rock piles and any
other structures, and locations
-relate to expected or observed wildlife in evaluation

43

4.

Amphibian spawn (egg mass) surveys -proposed addition to 1995
monitoring
-conduct surveys March-April
-walk perimeter of wetland; identify and measure egg mass,
describe structure on which eggs are attached, and record depth
from water surface and depth to substrate

Invertebrates

1.

Sampling
-maintain current collection methods: Surber net sampler for
streams, tube/ core sampler for ponds
-take 3 samples per wetland; combine samples prior to
identification
-if wetland has both stream and pond components, take one set of
3 samples in each area

2.

Identification
-take a sub-sample (1/2) of the combined sample
-identify to the taxonomic level of order
-more specific identification to family or genus level is not
necessary for the level of analysis that will be conducted, and
should only be done in response to specific goals stated in the
mitigation plan

44

Soils

1.

Assessing for hydric conditions
-take sample soil cores in years 1, 3, and 5
-3 cores at the wetland boundary on designated transect lines
-core to at least 30 em.
-use Munsell soil color classification to characterize soil; record
depth for each change in soil hue/value/ chroma
-record mottle color, percent of matrix
-note general texture of core- sand, silt, clay, etc.

2.

Soil texture analysis and organic content analysis (loss by ignition
method) in years 1 and 5
-3 cores from wetland -combine
-3 cores from upland -combine

3.

Sediment accumulation
-clear objectives should be stated, e.g.: obtaining an ideal or target
accumulation rate (a function of water velocity); comparison of
rates between mitigation site and a reference site; establishing a
relationship between rate of sediment accumulation and some
other factor such as surrounding land use, or presence or absence
of vegetation in the wetland
-recommend not monitoring for sedimentation in absence of
specific goals/ objectives
-if measuring sediment accumulation is specified in the

mitigation plan as a requirement, follow methods outlined in

45

Horner and Raedeke (1989) for sediment trap construction and
placement within the wetland

Water

1.

Current methods provide basic measures of water quality
-continue to measure pH, temperature, and dissolved oxygen (DO)
each site visit
-record sampling times
-3 sample stations: in-flow and out-flow (where applicable), and
one location near mid-point of wetland; locate sampling stations
on or as near to a transect line as possible
-3 measurements at each station; results are averaged

2.

Monitor water level from staff gauges on a monthly basis
throughout the year

5.2 Annual Monitoring Report

In its ideal form the annual monitoring report should present the

results of the summer's monitoring, provide discussion as to whether
the goals and objectives for each mitigation site are being met, and give
an explanation of how this is occurring. In addition, the report should
provide recommendations for remedial or other necessary actions for a
particular site; e.g. replacement of dead or dying plants, or closing off an
access point for trespassers and/ or vandals, or placement of an
interpretive sign for a site in a highly urbanized area.

46

Currently the annual monitoring report presents the data with a
moderate level of analysis, but relatively little to no discussion of the
results. This may be due in part to a perception by WSDOT that
reporting the data shows that the monitoring has been carried out,
thereby fulfilling its obligations under the terms of the permits. A
complicated sampling regime is not necessary for WSDOT to show that
a created wetland is providing wildlife habitat, food chain support,
flood storage, or sediment trapping functions. What is needed is a
commitment to undertaking a discussion of the results.
Recommendations for additions and changes to the data analysis and
discussion sections of the annual report and to the report format are
presented in the following two sections.

Data Analysis and Discussion

Vegetation
1.

Report the total area sampled for the entire site as well as for the
individual vegetation zones (or as required in the mitigation
plan). Calculation is made by taking the total number of plots
sampled and multiplying by the area of a single plot. This figure
should then be related as a percent of the total area of the
mitigation site. Calculations of the percent vegetative cover for a
site will be more accurate when stated in terms of actual area
sampled rather than for the entire site.

2.

Percent vegetative cover of the herbaceous layer should be
calculated for the entire area sampled and for each zone, (wetland

47

and upland at minimum). As described in Appendix E, percent of
herbaceous vegetative cover for the area sampled is derived by
subtracting the total sampled percent of bare ground (unvegetated
area) from 100%.

3.

Discussion of percent vegetative cover for the herbaceous layer
should include percent cover by tree and shrub species for a better
characterization of the site; i.e. how much overlap is there in the
upland? In the wetland? Percent cover by wetland species should
be discussed in relation to presence of water, depth, and seasonal
fluctuation.

4.

"Percent of total herbaceous cover," as currently termed in the
annual report, could be more accurately renamed "relative
dominance" (Lewis 1990), which would reduce confusion between
this parameter and that of percent vegetative cover for the
herbaceous layer. Calculated for each species, relative dominance
is a measure of the abundance, or dominance of a species relative
to all other species present. Relative dominance is calculated by
dividing the mean percent areal cover of an individual species by
the total mean percent cover of all species.

5.

Relative frequency is a measure of the relative distribution of an
individual species over the sampling area. It is calculated by
dividing the frequency of an individual species (the number of
plots containing that species divided by the total number of plots)
by the sum of the frequencies of all species. Adding this parameter

48

to those already established in the annual report for evaluating
vegetation could over time provide valuable information on the
rate of spread of a planted species.

6.

Relative dominance and relative frequency of species should be
reported by vegetative zone. Over several years monitoring these
figures could be evaluated with hydrologic data (water depth,
duration, and fluctuation), or other factors such as type of soil
brought on site, or site design (contours, slope). This information
could be analyzed to help select planted species most likely to
survive under a particular set of conditions, or which planted
species can best withstand competition from invasive or
undesirable species.

7.

Species richness as reported in the annual report is the total
number of species encountered within the sample area. This
figure should be given for the wetland and upland areas and
change over time noted. Species richness combined with the other
parameters can be used to track invasive species and change in
diversity of vegetative communities over time.

Wildlife
1.

Bird surveys provide an efficient and effective means of assessing
a wetland's value as wildlife habitat (Council on Environmental
Quality 1972, Horner and Raedeke 1989). Current WSDOT
methods generate sufficient data for evaluating habitat value.
Discussion of birds should include possible relationships to habitat

49

structures (cavity dwellers), vegetation (availability of cover,
habitat diversity, availability of forage), invertebrates (insect eaters,
or bottom feeders), size of the wetland, amount of open water, and
surrounding land use (urban, rural). The discussion should also
mention those species positively identified as breeding on site (i.e.
observations of nests or nesting activities, adults carrying food,
presence of young) specific to either the wetland or upland areas.
These same factors can be used to make inferences about the site's
potential for providing habitat for other wildlife species.

2.

If amphibian egg mass surveys are to be added to the WSDOT

monitoring program, rough estimates of the adult population for
each species identified can be made from the number of egg
masses found (Richter and Wisseman 1990). Amphibians readily
absorb chemicals through their skin, hence the fact that they are in
constant contact with either water or soil makes them especially
sensitive monitors of their environment (Richter and Wisseman
1990). The presence or absence of amphibians can be related to the
relative stability of a wetland; in a study on amphibian
distributions in the Puget Sound area of Washington State,
Richter and Azous (1994) found that one of the limiting factors on
amphibian species richness was a high degree of water level
fluctuation. Discussion of amphibians in the annual report should
be tied into results of hydrologic monitoring.

50

Invertebrates
Invertebrate sampling is becoming more common as a means to
assess water quality (Rosenberg and Resh 1993, Resh and Jackson
1993) and the general health of riparian and other freshwater
systems (Richter and Wisseman 1990). Three taxa of aquatic
invertebrates are considered to be less tolerant of poor water
quality than other aquatic invertebrate taxa: the orders
Ephemeroptera (mayflies), Plecoptera (stoneflies), and Trichoptera
(caddisflies) (Resh and Jackson 1993, Reice and Wohlenberg 1993).
Analysis and discussion of invertebrate data should focus on the
distribution of these three taxa relative to that of Chironomidae
(midges, considered more tolerant of pollution), the rationale
being that a relatively even distribution of the taxa reflects a nonstressed habitat while an imbalance may indicate a stressed habitat
(Resh and Jackson 1993). Because this monitoring task is
particularly susceptible to a high degree of error as conducted
within the scope of the WSDOT monitoring program, analysis
should be kept to the simplest level: taxa richness and relative
distribution of taxa. Major sources of error include: seasonal
variations in abundance and distribution, sample size, method of
collection, and that different life stages of a single taxa can be easily
mistaken for different taxa (Rosenberg and Resh 1993, Resh and
Jackson 1993). Also, weight measurements should be
discontinued. Current methods used by WSDOT introduce too
much error for the measurements to be scientifically defensible or
usable in analysis.

51

Soil
1.

Organic content increases the water-holding capacity of a soil and
aids in retention of nutrients important for vegetative growth
(Horner and Raedeke 1989). Substrates rich in organic sediment
will support higher densities of fish and aquatic invertebrates
(Marble 1990). Medium textured soils are more conducive to seed
germination and plant rooting than are extremely fine textured
soils such as clay (Horner and Raedeke 1989). Because soil
characteristics are relatively slow to change, soil monitoring tasks
(organic content, texture analysis, and Munsell soil color
classification) should be conducted only in the first and final year
(typically the fifth year) of monitoring. Discussion in the final
monitoring year for a particular site should relate soil texture and
organic content analyses of the wetland soil to the development of
the wetland vegetative community and to invertebrate taxa
richness and abundance over the duration of the monitoring.

2.

Rate of sediment accumulation in a wetland is principally affected
by water velocity and residence time within the wetland (Marble
1990, Phibbs 1986). Marble (1990) cites the following factors which
would decrease water velocity, hence increase sediment
deposition: lack of outlet in the wetland, gentle gradient, shallow
water depth, dense wetland vegetation, and long duration of
seasonal flooding.

As mentioned in section 3.2 ("Problems with Current Methods"),
monitoring sediment accumulation without a clear objective may

52

not provide information that is particularly useful (Horner and
Raedeke 1989). If sedimentation can be inferred by other means
(i.e. wetland gradient, water depth, vegetation, etc.), it may not be
necessary to add an additional task to the WSDOT monitoring
program.

Water
Water temperature, pH, and DO content are fundamental water
quality characteristics that affect fish, invertebrate, and vegetation
productivity (Horner and Raedeke 1989, Marble 1990). Water
quality sampling results should be discussed with reference to the
parameters listed in Table 1.

Table 1. Water Quality Criteria for Fish and Invertebrate Production*

co
::::::13-14 co

EH

00

5.6-8.6

>7mg!L

Coldwater/salmonid fish feeding

::::::15 co

5.6-8.6

>6mg!L

Coldwater fish refuge and migration

::::::15 co

5.6-8.6

>5mg!L

5.6-8.6

~4mg/L

5.6-8.6

~4mg!L

TemE.

Objective
Coldwater/salmonid fish spawning
and rearing

20-25

Warm water fish production

co

<20C 0

Invertebrate Eroduction
*Modified from Horner and Raedeke (1989)

All discussion of monitoring results should clearly state potential
sources of error. For example, seasonal timing of sampling will affect
what data is collected in all monitoring tasks except perhaps soil
sampling. Although WSDOT attempts to conduct each task within

53

approximately the same time period each year of monitoring, it is no
assurance that the actual time of season for any given year will come at
the same time in subsequent years. Even changes in the time of day
sampling takes place may affect bird surveys and water quality
measurements.

Report Format

There are three main problem areas with the current arrangement
of the WSDOT annual monitoring report. One is that the mitigation
sites are listed in alphabetical order within the report rather than by
WSDOT District location. This makes it difficult for any one District to
readily access information specific to its wetland sites. Secondly, there is
confusion generated in that the names given the mitigation sites by the
WSDOT Headquarters biologists conducting the monitoring often
differ from how they are known by the District. For the monitoring
program, mitigation sites are typically named after their primary source
of hydrology, or nearest body of water, as in Palix River, Matriotti
Creek, and Ebey Slough. The Districts refer to the site by the particular
project name with which it is associated; hence, the names given for
the aforementioned sites are, respectively: State Route 504, Green River
to Coldwater Lake, and State Route 527, 208th to 164th SE. A third
problem is that tables and graphs are grouped separately from the
written text, which creates a situation where the reader is forced to flip
back and forth between the site discussion and the tables and graphs
section for relevant data.

54

A relatively simple reorganization of the report will contribute
greatly to its readability. Mitigation sites should be organized by District
and all tables, charts, and graphs should be presented along with their
associated site. Also, sites should be listed by both project and
monitoring program names, and each site should be started on a new
page. For the convenience of the Districts and the resource and
regulatory agencies evaluating the monitoring results, a summary of
the monitoring recommendations and/ or any problems needing action
should precede each District section.

5.3 Promotion of In-House Use of Monitoring Data

The prevailing theme from agency input and current literature on
monitoring programs is: provide discussion of monitoring results,
provide recommendations, and apply what is learned to future
mitigation site design. Kentula et al. (1992) note that although wetland
monitoring reports may be kept on file in state and federal agencies,
they are rarely used. Personal communications by the author with
several WSDOT landscape architects who design many of the WSDOT
mitigation sites showed that this may indeed hold true for WSDOT.
Lack of time, difficulty with the report layout, and being unaware of the
existence of the monitoring report are several of the reasons cited for
not utilizing information generated by the monitoring program.

Miller (1994) and Stellini (1994) point out that collection of data
that are not used, or analysis that does not get translated into
management decision, constitute wasted effort (and hence, money) for

55

WSDOT. This observation is underscored by the findings of Crabtree et
al. (1992) in their evaluation of seventeen Department of
Transportation (DOT) wetland mitigation sites in fourteen states.
Crabtree et al. (1992) found that certain designs of wetlands are a
recurring motif in DOT sites and that these designs inhibit the growth
of wetland vegetation; more specifically, that relatively steep slopes
(6:1) were common and often provided the limiting factor in the
successful development of emergent vegetation. The report points out
that "Most natural wetlands are nearly flat ... [a] basic characteristic
[which] makes possible the performance of typical wetland functions."

Crabtree et al. (1992) further state that causes of failure in
mitigation sites were most directly linked to "... shortcomings or
misconceptions in planning or design, or to failures of
implementation, but not to gaps in the wetland information base." The
WSDOT monitoring program is generating sufficient data- however, it
is up to the agency to close the feedback loop.

Feedback Loop

One of the primary sources of feedback are the as-built plans for a
mitigation site and the site conditions at the time of vegetation
planting. The plans include the final grading and shape of the wetland,
and the final number, species, and location of vegetation planted on
site. Site conditions include noting whether the soil has been
compacted, the degree and quality of topsoil, and whether antidesiccants have been used on the planted vegetation. This information

56

provides the foundation for evaluating the site's development over
time (Kentula et al. 1992, Mabry 1994) and should be included in the
monitoring report. As-built conditions may often vary from the
original design, and hence may significantly affect the performance of
the wetland (Kentula et al. 1992, Mabry 1994).

The monitoring report can provide estimates of percent survival
of planted species in the first year. Monitoring can track the rate of
change through relative dominance and relative frequency analyses for
any given species over the five year span of monitoring, yielding
important clues as to the potential competitiveness and/ or rate of
propagation for that species. Information on dominance or rate of
increase by invasive vegetation may show some correlation with what
topsoil (source of, or if any) was spread on the site, or site hydrology.

Monitoring data should show, at the very least, what doesn't
work. For example, in the six years of WSDOT monitoring, there may
be enough data to show a positive correlation between low percent
cover by emergent wetland vegetation and degree of slope. Crabtree et
al. (1992) found that although slopes of 6:1 were common target slopes
for the emergent zone in DOT mitigation sites nationwide, they
consistently produced little more than a narrow ring of emergent
wetland vegetation.

If data analyses show that certain planted species consistently have

low to no survival, then WSDOT should cease planting those species
or switch strategies; e.g., stagger the timing of plantings by planting

57

shade loving vegetation after faster growing, sun-tolerant species have
had a chance to get established. If the data continue to reflect low
survival rate, yet the message from the resource or regulatory agencies
are to continue planting those species, then meetings should be held
between WSDOT and these agencies to discuss what are realistic goals.

To illustrate, in comparisons of vegetation composition between
created and natural wetlands in Oregon, Kentula et al. (1992) found that
54% to 81% of the species occurring were common to both groups.
However, only 0% to 7% of those occurring in created wetlands
correlated with the species planted for that wetland. According to
Kentula et al. (1992), this suggests that either the species planted were
inappropriate for the particular wetland or that the volunteer species
(naturally occurring) should be included in future site design planting
lists.

The monitoring report should be used to advise management of
potential or ongoing problems on a site. For example, monitoring can
usually pick up high mortality of planted species within the first
monitoring year. Most landscape contractors guarantee the survival of
their plantings for three years and must replace dead plants if they are
notified within that time period. However, if no action is taken by
WSDOT within the appropriate time frame, the agency may be saddled
with additional replanting costs in order to meet the percent vegetation
cover requirements specified in the mitigation plan. Hence, avoiding
unexpected additional costs should be a motivating factor for utilizing
information within the monitoring report.

58

Costs

The number of WSDOT mitigation sites requiring monitoring has
more than tripled in a span of six years, with the greatest increase in
sites occurring between 1993 and 1994 (from 13 sites to 20 sites).
Monitoring costs have risen by over $1000.00 per site over the past year:
cost in 1993 was approximately $3900.00 per site while the estimated
cost for 1994 is $5000.00 per site. Total monitoring costs for 20 sites in
1994 will approach $100,000.00. Over the five years of monitoring
expected for these sites WSDOT will spend nearly 0.5 million dollars;
an amount that will increase accordingly with additional sites.

With budget pressures increasing and environmental costs rising,
(whether directly or through more stringent regulations), WSDOT like
other agencies must be ever persistent in figuring ways to keep costs
down. McAuliffe (1994) of the U.S. Army Corps of Engineers
mentioned that if WSDOT could show its wetland mitigation sites to
be consistently successful, it may be possible to reduce the number of
years WSDOT is required to monitor each site. For example, three years
of monitoring instead of five, but staggered over a five year (or longer)
period, would be considered. At current annual monitoring costs,
dropping two years of monitoring translates to a 40% reduction in
monitoring costs per site. At very least, applying information generated
from the monitoring program to future wetland mitigation site design
will serve to establish WSDOT's credibility in this particular arena, as
well as make good economic sense.

59

6. Conclusion

Wetland creation, enhancement, and restoration will figure
prominently within WSDOT throughout the next decade. As the
state's population continues to grow, the commensurate increase in
highway congestion will intensify the call for WSDOT projects such as
road widening. Rural roads reaching traffic load capacity will spur
demands not only for additional vehicle lanes, but also for new access
roads to trunk routes. Although WSDOT is committed to minimizing
wetland impacts, the nature of these projects is such that, when
wetlands are involved, there oftentimes are few alternatives to impacts
through filling.

As the scientific community's understanding of wetlands
increases, and the role wetlands play in water quality, nutrient cycling,
flood attenuation, and wildlife habitat becomes m:ore widely accepted,
the call for WSDOT to be more sparing in its impacts to wetlands and
to be consistently successful in its endeavors to balance wetland losses
will become more persistent. This is already reflected in the more
stringent mitigation requirements requested by federal and state
agencies, and increasingly, local governments. These agencies will be
looking more closely at WSDOT to make sure that WSDOT's
compensatory mitigation efforts are successful. The annual monitoring
report will also come under greater scrutiny. With each year of data
collection, outside expectations rise for WSDOT to show that it is
applying what it has learned from monitoring, following its own

60

recommendations, and taking a pro-active stance in dealing with sites
that are not meeting the standards that have been set for them.

The recommendations presented in this paper are offered as a
means towards increasing the efficiency and effectiveness of the
current WSDOT monitoring program. Changes and additions proposed
for the methodology are targeted to meeting the newest WSDOT
mitigation requirements without adding more time demands to a
program that is already operating near capacity. Proposed
recommendations for changes to the annual monitoring report are
directed both at making the information more accessible to the reader
and underscoring the report's potential for use as a management tool.
Recommendations for promoting in-house WSDOT use are based on
current monitoring costs and WSDOT's need to establish credibility
with regulatory and resource agencies regarding wetland mitigation.

At the conclusion of the 1994 monitoring season WSDOT will
have accumulated seven years of monitoring data and will have a total
of eight mitigation sites that have completed five years of monitoring.
This accumulation of data should provide sufficient information with
which to make good assessments of what does and doesn't work for the
mitigation sites. At this point it may be useful for WSDOT and the
various agencies to meet to discuss future strategies for the monitoring
program. For example, the issues of trying to create later successional
stage wetlands, or battling the persistent problem of invasive species
encroachment and competitiveness should be evaluated in light of
what is realistic to expect of a created wetland in five years. Also, the

61

possibility of extending the length of the monitoring period, (e.g., from
five years to eight or ten years), but reducing the number of times
WSDOT has to conduct the monitoring per site should be considered
by WSDOT and the permitting agencies. In all cases, a good monitoring
program strategy will entail all agencies working in concert with each
other.

It is important that the WSDOT monitoring program remain

flexible; further refinements to the methodology may be necessary in
the future if (or as) mitigation requirements change. Time constraints
will become a limiting factor if the total number of sites monitored in
one season continue to increase. Potential budget restrictions may also
become a factor affecting the WSDOT monitoring program. To be the
most efficient and effective in monitoring its created wetland
mitigation sites, WSDOT should continue to work with federal, state,
and local agencies in an effort to establish common ground on the
expectations for and the focus of the monitoring program. There
should be a consensus on where the emphasis of monitoring is placed,
developed out of a realistic assessment of what can be achieved.
Ultimately, WSDOT must make a commitment to its own monitoring
program, recognizing that although the monitoring is motivated out of
the need to comply with permit terms, WSDOT has both an obligation
and a responsibility as a state agency to providing the best product
possible.

62

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March 04, 1994.
Richter, K.O. King County Environmental Division. Personal
interview. January 27, 1994.
Richter, K.O. and A.L. Azous. 1994. Amphibian Distribution and
Habitat Characteristics in Lower Puget Sound Wetlands: Biology
and Management- DRAFT. Puget Sound Wetlands and Stormwater
Management Research Program, Bellevue, Washington.
Richter, K.O. and R.W. Wisseman. 1990. Effects of Stormwater Runoff
on Wetland Zoology; pp. 144. Puget Sound Wetlands and
65

Stormwater Management Research Program, Seattle, Washington.
WSDOE Project No. G0089028.
Rosenberg, D.M. and V.H. Resh (eds.). 1993. Freshwater Biomonitoring
and Benthic Macroinvertebrates; 488 pp. Chapman and Hall, Inc.
New York.
Savage, M.S. and J.O. Olds. 1994. WSDOT Wetland Mitigation Sites:
1993 Monitoring Report. Unpublished document prepared for
Washington State Department of Transportation, March 1994; pp.
57. Olympia, Washington.
Stellini, J. U.S. Fish and Wildlife Service. Personal interview. January
24, 1994.
Stevens, M.L. and R. Vanbianchi. 1993. Restoring Wetlands in
Washington: A Guidebook for Wetland Restoration, Planning and
Implementation. WSDOE Publ. No. 93-17.
Storm, L. Environmental Protection Agency. Personal interview.
January 25, 1994.
Swanson, G.A. 1978. A water column sampler for invertebrates in
shallow wetlands. Journal of Wildlife Management 42:670-672.
United States General Accounting Office (GAO). 1988. Wetlands: The
Corps of Engineers' Administration of the Section 404 Program.
Resources, Community, and Economic Development Division,
Washington, DC.
Want, W.L. 1984. Federal wetlands law: the cases and the problems.
The Harvard Environmental Law Review Vol. 8, 1:1-54.
Washington State Department of Ecology (WSDOE). 1988. Wetlands
Regulation Guidebook. Publ. No. 88-5.
Washington State Department of Transportation (WSDOT). 1990.
Washington's Transportation Future: 1990 Report to the
Washington State Legislature, Transportation Policy Plan for
Washington State. Publ. TP-90-01.
Washington State Department of Transportation (WSDOT). 1992. The
Permitting Process at the Department of Transportation. Legislative
Transportation Committee. Briefing Paper #3.

66

Washington State Department of Transportation and Washington
State Department of Ecology. 1993. Implementing Agreement
between the Washington State Department of Transportation and
Washington State Department of Ecology Concerning Wetlands
Protection and Management. Olympia, Washington.

67

APPENDIX A

History and Policy Leading to Compensatory Wetland Mitigation

Historically, wetlands have been viewed primarily as wastelands
with little regard given them other than the practicality of converting
them to agricultural lands, an activity that continues to be the primary
cause of wetland losses (The Conservation Foundation 1988, Mitsch
and Gosselink 1986). The draining of wetlands for conversion to other
uses was routinely encouraged from early 1800s through the mid- to
latter part of this century (Mitsch and Gosselink 1986). In 1906 and
again in 1922, Congress directed the United States Department of
Agriculture to conduct surveys of wetlands for the express purpose of
identifying areas suitable for conversion to agricultural lands (Horwitz
1978, Mitsch and Gosselink 1986). Beginning in 1934 a few wetlands
gained protection through the mandatory sale of Migratory Bird
Hunting and Conservation Stamps (duck stamps) to waterfowl
hunters, the proceeds of which went towards the acquisition of
migratory bird habitat (Office of Technology Assessment 1984).
However, it wasn't until the early 1970s that wetlands gained any
specific recognition as a resource to be protected (The Conservation
Foundation 1988) or widespread acknowledgment as having beneficial
environmental functions.

The primary legislators of wetland protection have been the
Rivers and Harbors Act (RHA) of 1899 and the Amendments to the
Federal Water Pollution Control Act (FWPCA) of 1972, later amenqed

68

as the Clean Water Act (CWA) of 1977. Although recent years have
seen the inception of State programs and local ordinances that regulate
activities in sensitive areas, including wetlands, these two federal
statutes continue to be the first defense against impacts to wetland
areas.

Until the United States Army Corps of Engineers (Corps) revised
its permitting authority in 1968 to include consideration of
environmental factors, protection of wetlands under the RHA of 1899
was more happenstance than intent. Section 10 of the RHA gives the
Corps responsibility for the authorization (permitting) of all activities
that could obstruct or alter navigable waters of the United States
(Horwitz 1978, WSDOE 1988). The jurisdiction of the Corps was limited
by the definition of navigable waters: "... those waters that are subject to
the ebb and flow of the tide and/ or are presently used, or have been
used in the past, or may be susceptible for use to transport interstate or
foreign commerce," (Want 1984, 33 CFR §329.4 (1982)).

Navigable waters "subject to the ebb and flow of the tide" refers to
those areas within the mean high water mark of tidal zones and the
ordinary high water mark within freshwater zones (33 CFR §329.4
(1982)). Wetlands extending beyond these marks, or not connected to
navigable waters were not covered under the Corps' jurisdiction.
Pressure from environmentalists along with a general increase in
concern nationally over the limitations of wetland protection
influenced the Corps to revise its Section 10 permit regulations in 1968
to include environmental factors such as pollution, aesthetics,

69

conservation, ecology, and fish and wildlife in its consideration of
permit requests (Horwitz 1978/ Want 1984). Although not specifically
targeted as such, the revision did have the effect of extending
protection of wetlands somewhat; however, the jurisdiction of the
Corps was still bound by the definition of navigable waters. It was not
until the enactment of the Amendments to the FWPCA of 1972,
(hereafter referred to as the Clean Water Act, or CWA), which was
spurred in part by the continuing concern by environmentalists and
some federal agencies over the restrictive bounds to wetlands
protection (Want 1984), that the Corps authority was expanded to
include all waters of the United States, including wetlands (Horowitz
1978).

Congress directed both the Corps and the Environmental
Protection Agency (EPA) to develop the environmental guidelines for
Section 404 of the CWA (known as the Section 404 (b )(1) Guidelines, or
"the Guidelines"). The primary authority of the Corps encompasses
issuing permits and the enforcement of their conditions. The EPA is
responsible for enforcing compliance with the Guidelines regarding
unpermitted activities in wetlands. In addition it has the authority
under Section 404 (c) to veto permits authorized by the Corps. (United
States General Accounting Office -GAO 1988, Kruczynski 1990).

The goal of the CW A is "to restore and maintain the chemical,
physical, and biological integrity of the nation's waters" (33 USC 1344).
Section 404 of the Act, which regulates the discharge of dredged or fill
material into waters of the United States (40 CFR 230.1 (1980)) provides

70

the primary legislative means with which to control use of wetlands
(United States General Accounting Office 1988). In its definition of
waters of the United States, Section 404 of the CWA encompasses the
definition of navigable waters given in Section 10 of the RHA, as well
as inter- and intrastate waters (i.e. lakes, rivers, streams, mudflats,
sandflats, wetlands, sloughs, prairie potholes, wet meadows, playa
lakes, or natural ponds), and all wetlands adjacent to those waters as
described (40 CFR §230.3 (s)). Wetlands are defined in this section to
mean "those areas that are inundated or saturated by surface or ground
water at a frequency and duration sufficient to support, and that under
normal circumstances do support, a prevalence of vegetation typically
adapted for life in saturated soil conditions" (40 CFR §230.3 (t)).
Although both the CWA and the RHA involve regulating the
discharge of dredged and fill material, in addition to its greater
geographical scope Section 404 of the CWA differs from Section 10 of
the RHA in that the focus of the former concerns regulating water
pollution, while the latter regulates navigation (Want 1984).

With the initial passage of the CWA the Corps showed reluctance
to expand its jurisdiction to the new definition of waters of the United
States; more specifically, it did not interpret them to mean anything
different from the Corps' definition of navigable waters (Kruczynski
1990). The Corps was challenged on this point in the landmark case
NRDC v. Calloway (Want 1984, cites 392 F. Supp. 685 (D.D.C. 1975)) in

which the Corps was forced to expand its jurisdiction to include the
Section 404 definition. In revising its Sec. 404 Regulations, the Corps
included a public interest review which involved opening to agency

71

consultation any permit decision regarding activities in wetlands made
by the Corps (Want 1984, Kruczynski 1990). Agencies consulted
included the Soil Conservation Service (SCS) the National Marine
Fishery Service (NMFS), United States Fish and Wildlife Service
(USFWS), and various state agencies. As outlined in Kruczynski (1990),
the review process entitled the agencies to make recommendations
which would then be taken into consideration by the Corps before a
final decision was made on a Sec. 404 permit. Any agency disagreeing
with the final decision was able to elevate authority, (i.e. appeal the
decision), the threat of which was usually enough to cause the Corps to
reassess its stance on the permit in question. However, the process of
elevating authority was difficult and agencies began to opt for a return
of some environmental benefit by agreeing to the replacement of
impacted wetlands, or as it became known, compensatory mitigation.

The year 1981 ushered in a new presidential regime. One of the
first actions of the new president upon taking office was to establish the
Presidential Task Force on Regulatory Relief (Andrews 1984). Targeting
what were viewed as the regulatory excesses of the CWA, the Task
Force effectively gutted the power of the state and federal agencies, and
that of the EPA especially, by shortening the agency review period for
permits and by making it extremely difficult and time consuming
overall to pursue an appeal of a Corps decision (United States General
Accounting Office 1988, Kruczynski 1990). In view of their reduced
voice resulting from the regulatory relief measures, agencies found
that it was far easier to compromise on the conditions of a permit than
to appeal its legitimacy, and it was not long before mitigation came to

72

mean minimizing adverse impacts to wetlands, regardless of available
alternatives (United States General Accounting Office 1988, Kruczynski
1990). Although the reduced regulatory role of the Sec. 404(b)(1)
Guidelines was successfully challenged in 1984 by the National
Wildlife Federation (Kruczynski 1990), the stage had been set for
viewing mitigation as a means to obtain a permit for any project that
would have some impact on a wetland; it is here that compensatory
mitigation became firmly entrenched within Section 404 of the CWA.

In its report to the House of Representatives regarding the Corps'
administration of the Sec. 404 program, the United States General
Accounting Office (1988) established that there were differences
between the Corps and the EPA (and other resource agencies) in their
interpretation of the Sec. 404(b )(1) Guidelines. Specifically the GAO
finds that the resource agencies believe the Corps has greater range of
authority to protect wetlands than it chooses to exercise. Three major
areas of difference cited are: 1) the Corps tends to be more conservative
than the EPA or USFWS in its delineation of wetland boundaries (i.e.
the Corps applies more rigid standards); 2) the Corps tends to rely on
the applicant to determine whether any practicable alternatives exist to
an action or actions, and 3) the Corps usually considers each permit
individually, and finds it hard to develop criteria that would judge
cumulative environmental impacts, while the EPA finds that its
recommendations are often not followed with regard to cumulative
impacts. The EPA, in its interpretation of the Sec. 404(b )(1) Guidelines,
supports NEP A's sequential process of mitigating for environmental
impacts (Washintong State Department of Ecology 1988, Kruczynski

73

1990), maintaining that minimization of impacts through seeking
alternatives cannot be overridden by willingness to provide
compensatory mitigation (United States General Accounting Office
1988, Kruczynski 1990). The difference in interpretation is important in
that it is the Corps that authorizes Sec. 404 permitting of those WSDOT
projects affecting wetlands and hence sets the lead on the terms of
mitigation.

It is further pointed out in the United States General Accounting

Office (1988) report that basic differences exist regarding permitting
decisions by the Corps. Specifically, "... the resource agencies are charged
with protecting the resource without consideration of the other factors
that comprise the public interest, while the Corps must balance many
factors in the public interest in making decisions about permit
applications." I believe the Corps' stance underscores how WSDOT
views its responsibility towards wetland mitigation in the overall
picture of its transportation responsibilities. The priority of this agency
is to provide safe, efficient, and effective transportation for the public,
and mitigating for impacts to wetlands is simply one of the many parts
to a complicated puzzle.

74

APPENDIX B
WSDOT Process: Project Scoping, Design, and Permitting

Scoping is, as the name implies, the pre-project phase; it is
WSDOT's initial response to a current or projected transportation
need. In this stage a prospectus is developed that includes the basic
project design, a rough timeline for completion, and projected project
costs. What makes the scoping phase so critical is that, despite the fact
that the project planning is in its infancy, it is at this point that the
budget must be set and then approved for funding. The requirement
for funding approval at so early a date creates the potential for
problems later on, not the least of which is the unplanned, or
underplanned costs of environmental impacts. It is not uncommon for
mitigation costs to run as high as 18% of the total project budget
(Washington State Department of Transportation 1992) yet the scoping
phase does not currently involve a preliminary biology report, which
would bring to the agency's attention the potential for adverse impact
to environmentally sensitive areas. Recognizing that the lack of
incorporating a biological evaluation into the scoping process
contributes to the potential for delays and unforeseen costs later on in
the project, WSDOT is reassessing the scoping phase.

With approval of funding the project moves into the design
phase. This phase includes wetland inventories, permit application,
preparation of environmental impact statements, and the final design
report. It is also the stage at which federal, state, and local agencies
become involved in the project process. The following paragraphs.

75

summarize the path a typical WSDOT project involving wetland
mitigation must take to get to the "Ad" or, construction phase of the
project.

One of the earliest tasks during the design phase is to inventory
the proposed project site for wetlands. The wetland inventory is
considered in conjunction with the project proposal and the project
design is then modified to avoid or minimize wetland impacts to the
extent possible. An informal review of the project is conducted with all
resource agencies affected, typically: the Corps, Ecology, USFWS, and
Washington Department of Fisheries and Wildlife (WDFW). Project
design may be further modified, incorporating comments from the
reviewers.

When the project design is close to finalized, a biology report for
the project area is written and submitted to the resource agencies as
well as to the WSDOT district initiating the construction project
(WSDOT is divided into six districts statewide). This report discusses
the area in terms of impact to endangered plants or wildlife (if
applicable) and to wildlife (including fish) in general.
Recommendations are made for reducing impact to fish bearing
streams (if applicable) and to other wildlife. A wetland report is
developed concurrent with the biology report. The wetland report is a
formalization of the wetland inventory; all wetlands within the project
area are formally delineated and mapped, and wetland impacts are
described in detail.

76

Application for various permits is occurring throughout the
process of finalizing the project design. Typically these include Sec. 404
(Corps), Hydraulic Project Approval (WDFW), and any permits
required under the Shoreline Management Act. In addition, approval
must be sought under the Coastal Zone Management Act if the project
involves shorelines of the state (refer to Appendix C). When the
project design is finalized a wetland mitigation plan is written. The
mitigation plan is developed through a collaborative effort between
WSDOT biologists, landscape architects, hydrologists, and other
WSDOT specialists as needed. This document defines the wetland
functions that will be lost to impacts from project construction and
states how they will be replaced. The mitigation plan provides the
construction and planting plans for the wetland to be created, and the
goals, objectives, and the standards of success by which to evaluate the
wetland's development.

Once the final mitigation plan is delivered to the Corps, the Corps
makes a determination on the permit, publishes a public notice of the
preliminary decision and requests Sec. 401 Certification from Ecology.
Comments from the resource agencies and the public are solicited for
thirty days. The Sec. 404 permit application is approved upon
determination that all local permits have been approved, that the
project has met the requirements set under the CZMA (if applicable),
and that a Sec. 401 water quality certification has been issued. The
WSDOT road project may then proceed to the construction phase.

77

Construction of the wetland replacement project will be initiated
as fits the individual contractor's time table. The contractor has the
grading and planting plans for the site that were developed in the final
mitigation plan. Grading plans provide the configuration of the site
and its slope, and planting plans designate the specific species and
quantities of plants as well as where they are to be planted within and
surrounding the wetland. Soils and plant materials may be removed
from the impacted wetland and used in the created wetland. Wetland
monitoring commences with the first growing season after the
mitigation site has been planted. WSDOT mitigation sites are typically
monitored for five consecutive years.

78

APPENDIXC

Table 2. Summary of primary regulations pertaining to Washington State's
wetlands*
Regulation
Federal River and Harbor
Act - Section 10 -- 1899
33

usc 401

§ 10

Federal Clean Water Act Section 404-- 1972/1977
33

usc

1344

Reason for Permit or
Action
Permit required for
construction activity in
navigable waters of the state
Permit required for dredge and
fill activities in all waters of the
state, including wetlands.

Implementing Agency
U.S. Army Corps of
Engineers
U.S. Army Corps of
Engineers/ Environmental
Protection Agency

Federal Clean Water Act Section 401 -- 197211977
FWPCA § 401
RCW 90.48.260, WAC 173-225

Certification that water quality Washington State
standards have been met;
Department of Ecology
necessary before federal permit
approval

Federal Coastal Zone
1972
16 USC 1451, RCW 90.58

A notice that proposed activity Washington State
Department of Ecology
is consistent with state coastal
zone management plan;
necessary before federal permit
approval

Executive Order 119901977

All agencies
Established protection of
wetland and riparian systems as
an official policy of federal
government

National Environmental
Policy Act (NEPA) -- 1969

Federal process requiring full
disclosure of potential
environmental impacts

Usually the federal agency
issuing the permit

State Environmental
Protection Act (SEPA) -1971
RCW 43.21

State process requiring full
disclosure of potential
environmental impacts

Usually the local agency
issuing the permit,
certification, or other
approval

~anagementAct--

State Shoreline ~anagement Permit required ensuring that
Local
Act -- 1971
proposed activity complies with jurisdiction/Washington
RCW 90.58, RCW 36.70
local shoreline master plan
State Department of Ecology
State Hydraulic Code-1949 Hydraulic Project
Approval
RCW 75.20.100-140

Permit required for all activities Washington Department of
below the ordinary high water Fisheries/ Washington
Department of Wildlife
mark of waters of the state

Permit required ensuring that
Local jurisdictions with
State Flood Control Zone
Act-- 1935
proposed activity is consistent approved programs, or
with state or local floodplain
Washington State
Floodplain ~anagement
management program
Department of Ecology
Program, EO 11988
*Modified from Washington State Department of Ecology's Wetland Regulations Guidebook (1988)

79

APPENDIXD
Taken from the Implementing Agreement between the Washington State Department of Transportation and
the Washington State Department of Ecology Concerning Wetlands Protection and Management.

WSDOT Guidelines For Wetland Mitigation Plans
The Washington State Department of Transportation (WSDOT) has developed
these guidelines to provide format and contents requirements for wetland
mitigation plans (WMP) and reports. The guidelines apply in the preparation of
mitigation plans associated with regulatory agency permit requirements.
Agencies responsible for project review and permit certifications are developing
guidelines for wetland mitigation reports, plans, and monitoring. The Department
of Ecology, the U.S. Army Corps of Engineers (Corps), and the Environmental
Protection Agency mitigation plan guidelines were considered in the preparation of
these guidelines. WSDOT Wetland Mitigation Plan Guidelines are intended to meet
the requirements of each of these regulatory agencies.
If wetlands are encountered in a project, the following activities are normally
required: 1) a wetland report is prepared, identifying the location and value of
wetlands in ihe project vicinity; 2) alternatives that would reduce or eliminate
impacts to wetlands by changes in location or design of the project are analyzed; 3) a
mitigation ·site is selected that will satisfy requirements for acreage needed for
unavoidable wetland impacts; and 4) a wetland mitigation plan is written.

The Preliminary 'Wetland Mitigation Plan is prepared as the first action in the
process of developing a W:MP, followed by internal review and resource agency
review. The Final Wetland Mitigation Plan is provided to agencies as part of the
permit process. These guidelines explain the elements of mitigation plans and detail
the essential coordination required.
I.

Develop Preliminary Wetland Mitigation Plan
The Preliminary Wetland Mitigation Plan is a draft document Jar use in early
coordination with in-house and resource agency staff. In this document, the
project is described, the measures that will be taken to avoid wetlands and
reduce impacts are discussed, and the measures proposed to compensate for the
impacts are described.
Following are the elements of the Preliminary Wetland Mitigation Plan:
A. Description of the Project
Provide a brief outline of the project proposal, including the following site
information: ·
1.

Project name, short description, and location.

2.

Wetland information. Include who conducted the delineation (e.g.,
WSDOT biologist, consultant), which manual was used (1987 or 1989),
methodology (routine, intermediate, problem, or disturbed), date(s) field
(go)

D1

work was performed, data sheets used to establish the wetland boundary
and general findings.

B.

3.

Vicinity map. U.S. Geological Survey (USGS) Quadrangle (1:1200),
National Wetlands Inventory Map (NWI), or other will suffice. Range,
Township, and Section should be shown.

4.

A large scale site map (not smaller than 1:400) and aerial photo if
available.

Assessment of the Impacted Wetland
Description should be provided of the type and quantity of wetlands that
would be impacted. Address vegetation (including canopy structure,
indicator status, percent cover and wetland classes) hydrology (water depths,
average seasonal flows and/ or duration of saturation), soil characteristics,
and functions and values. Impacted wetlands should also be rated according
to the Department of Ecology's Washington State Wetlands Rating System,
and include a qualitative description of how the wetland functions in the
landscape.
This information is available in the Wetland Biology Report prepared for
the project.

C.

Evaluation of Mitigation Alternatives
The Preliminary Wetland Mitigation Plan should document all early
project design changes made to avoid and minimize impacts to wetlands.
This information is needed for both Preliminary and Final Wetland
Mitigation Plans and demonstrates to reviewing agencies that WSDOT has
avoided and minimized ·impacts to the extent practical. It should follow the
mitigation sequence adopted by WSDOT and show how the development of
the project design has:
1.

A voided the impact .altogether by not taking a certain action or part of
an action

2.

Minimized impacts by limiting the degree or magnitude of the action
and its implementation, using appropriate technology, or taking
affirmative steps to avoid or reduce impacts

3.

Rectified the impact by repairing, rehabilitating, or restoring the affected
environment

4.

Reduced or eliminated the impact over time by preservation and
maintenance operations during the life of the project

5.

Compensated for the impact by replacing, enhancing, or providing
substitute resources or .environments.

Mitigation steps should be tracked and recorded throughout the project
planning and design process. This information can then be incorporated

(~!)

D2

into the Final Wetland Mitigation Plan.
D. Mitigation Project Goals, Objectives, and Performance Standards
Goals are broad statements that define the intent or purpose of the proposal.
Objectives are the direct actions necessary to achieve a specific goal. These
should be measurable. Wetlands perform numerous important functions.
However, if an objective of the mitigation is to create a function it must be
one that can be accurately measured in the field, such as percent cover of
wetland vegetation. Water quality improvement is an example of wetland
function that is difficult to use as a measurable performance standard.
Performance standards are specific criteria used to evaluate whether the
goals and objectives have been met. These must be developed on a site-bysite basis. Performance standards should provide target criteria to be met
each year, or every other year, based on reasonably paced progress toward
measuring final success.
Describe the long-term goals of the mitigation project. Specifically, identify
objectives in the following terms:

E.

1.

Size and classification of wetlands to be created, restored, enhanced, or
preserved

2.

Functions and values to be created, restored, enhanced, or preserved

3.

Number of years it is likely to take for the long-term establishment of
the proposed functions and habitats

4.

The measurable performance standards that will be used to determine if
an objective has been met.

Description of the Proposed Wetland Mitigation Site
1.

Describe pre-construction conditions existing at the proposed site,
including vegetation, wildlife and wetlands. Provide a description of the
plant community, its cover, classes and structure, and make special note
of exotic species and other management concerns that may affect site
viability. Wetlands present at the mitigation site must be delineated,
assessed and their location indicated on the site map using the format
described for a Wetland Report.

2.

Explain how hydrology will be provided for the proposed wetland
mitigation, including expected seasonal water level fluctuations,
seasonal depth to groundwater, or surface water source and water
quality.

3.

Describe soil classification and series at the site and any soil testing that
has been done. Describe amenities that may be needed to improve the
soil conditions at the site.

4.

Describe how the planned mitigation will fit in the landscape. Discuss

(g-J)

D3

the location of the site in relation to its position in the watershed or
adjacent upland or wetland habitats or other water resources.
F.

Proposed Site Plans
Prepare a general grading and revegetation plan, including:
1.

The shape and contour of the mitigation project. Provide sufficient
information so that water depths, open water areas, boundary areas, and
other features can be visualized. Seasonal ground water and the sources
of hydrology for the site should be evident.

2.

A list of plants to be used and general planting plan to illustrate the
planting concept for the site. Reviewers need to know what species will
be planted, in what proportions, and their general locations.

3.

Information on the construction sequence and schedule.

4.

Steps to be used to minimize damage to surrounding buffers or
wetlands during site construction.

5.

Methods for controlling invasive species.

6.

A description and map of the plant communities which make up the
wetland buffer, if a buffer is included in the mitigation design.

H. Maintenance Plan
Describe planned maintenance activities including erosion control and
protection of plant materials from herbivores, repairing vandalism, and
other activities that may be required over time to ensure that the site
viability is maintained.
I.

Contingency Plan
A contingency plan is required and must outline the steps that will be taken
if performance standards are not met.

G. Mitigation Site Monitoring
A monitoring plan collects the data necessary to measure the success of the
mitigation in meeting goals and performance standards established for the
site. In the Preliminary Wetland Mitigation Plan, state that monitoring will
be conducted for a period of 5 years or longer, if necessary, and that an
annual report will be issued by WSDOT to the U.S. Army Corps of
Engineers, Department of Ecology, and other federal, state and local resource
agencies. A monitoring program must include measures of vegetation,
hydrology, water quality, soils, and wildlife over time. Headquarters Biology
conducts the actual monitoring and issues the WSDOT Wetland Mitigation
Monitoring Report, which is sent to regulatory agencies each year.

(83)

D4

II. Coordination
The Preliminary vVetland Mitigation Plan is intended to be reviewed internally
by WSDOT Districts, Headquarters Design, Maintenance, and Right of Way staff
before circulating to outside agencies. WSDOT District Environmental Managers
should coordinate the appropriate review within the District.
The outside agency review follows the internal review. Comments and
suggestions made to the Preliminary Wetland Mitigation Plan by outside
agencies should be considered in the preparation of the Final Wetland
Mitigation Plan.
III. Final Wetland Mitigation Plan

The Final Wetland Mitigation Plan is completed after the Preliminary Wetland
Mitigation Plan has been circulated to agencies. It incorporates comments from
agencies and the public (and comments from draft environmental documents, if
applicable). The Final Wetland Mitigation Plan is the document of record.
IV. As-Built Plans
Within a month of construction and planting completion, as-built plans should
be sent to the lead agency, including an as-built topographic survey, plant species
and quantities used, photographs of the site, and notes about any changes to the
original approved plan. Also list the contractor's responsibility concerning plant
replacement, fertilization and irrigation, protection from wildlife, and
contingency plan requirements.

( 'i!'l)

DS

Examples of Goals and Standards of Success
The following are examples of possible goals, objectives, and performance standards
that could be used in a mitigation report.
Example 1
Goals
The goal of this mitigation is to create 12 acres of wetland by converting
existing pasture land to a productive, functional native wetland system. The
wetland is intended to have the following functions: wildlife habitat, food
chain support, flood storage, water quality improvement, and sediment and
nutrient trapping.
The goal of the pond and emergent area is to provide food, open water, and
nesting habitat for waterfowl and shorebirds, and habitat and food for
aquatic-dependent and other species.
Objective# 1:
Creation of a wetland system that has vegetation structure and species
diversity similar to those found in natural wetland systems located in the
vicinity:
Performance Standards:
After 1 year:
We.t land has 35-50% survival of planted species. Recruitment of native
species is expected and should increase the overall areal coverage of
wetland plants.
After 3 years:
Wetland has 75% survival of facultative or wetter species, or is replaced
by a native, naturally colonizing plant community at 75% or greater
cover. At least 75% of the species are the same as those found at the
reference site.
After 5 years:
a.

Wetland has about 35-50% scrub/shrub.

b.

Wetland has about 25-35% emergent.

c.

Wetland has about 10-20% riparian.

d.

Shrub I scrub wetland is 90% native species.

~Note: In this example the wetland systems located in the vicinity are being used as reference
sites.

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D6

e.

Emergent wetland has about 75% native species.

f.

Emergent community must have at least 3 species with 20%
coverage each.
·

g.

Scrub/shrub community must have at least 2 species of 30% cover
each.

h. Wetland has 90% vegetative coverage by predominantly native
species.
1.

At least 80% of the wetland plant species are the same as those
found at the reference site.
·

Objective #2:
Provide wildlife support by increasing wildlife cover, forage availability, and
vegetative class interspersion. The open water area will provide
water I support for aquatic-dependent and other species.
Performance Standards:
After 3 years:
At least 3 wetland classes will be established (emergent, scrub-shrub,
open water).
After 5 years:
Wildlife cover and forage species should be established equal to
percentages listed for vegetative structural and species diversity. A
quantitative increase in species diversity should be observed, based on
visual estimates.
·
Example 2
Goals
The goal of the wetland mitigation project is to create a functional self
sustaining forested wetland linked with the adjacent ecosystems that
provides a continuous forested corridor along a side channel of the North
Fork of the Stillaguamish River. In general, the created wetland system is
expected to provide the following functions and values: fish and wildlife
habitat, food chain support, flood storage and attenuation, and sediment
and nutrient trapping.
Contour grading and vegetation establishment will alter the existing site
conditions from predominantly wet pasture to a forest/ scrubshrub I emergent wetland system. The resulting cpange in habitat structure
and increased complexity should result in habitat that can be utilized by
forest and wetland dependent wildlife species. Reestablishing a forested
connection with adjacent habitats will extend a wildlife corridor through
this area. The increase in edge habitat created between pasture land and

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D7

forested wetland will benefit species that utilize the ecozone between habitat
types.
Objectives/Performance Standards
Objective # 1
Upgrade wildlife habitat by the addition of proposed native species
plantings.
Objective # 2
Increase habitat complexity and diversity as compared to existing
agricultural land use by increasing vegetation structure and edge.
As the mitigation site vegetation matures, the conditions of the site will
change from a system dominated by pasture grass to a complex scrub-shrub
and forested wetland interspersed with the existing emergent wetland areas.
It is expected that this type of habitat would support forest and wetland
species. A wildlife corridor will be extended by completion of a forested link
with the adjacent wetland systems which are associated with the
Stillaguamish River.
Performance Standards
After 3 years:
a.

Woody vegetation will cover approximately 30% (±5%) of the site
with 112 trees and 1/2 scrub-shrub.

b.

Measurement of the cover of woody vegetation will be used as an
indicator of an increase in habitat structure and complexity. It is
expected that habitat structure will change from a single layer of
vegetation to multiple layers over time, as trees and shrubs mature.

After 5 years:
a.

Cover of trees will be 15%.

b.

Cover of scrub I shrub will be 50%.

c.

There will be at least 250 lineal feet of edge boundary between
scrub I shrub and tree species.

d.

The corridor to the Stillaguamish system will be 100' wide and show
no human disturbance.

(<'57}

DB

APPENDIXE
Current Parameters Used by WSDOT to Report the Results of Vegetation
Sampling

Data from the canopy cover method are used to generate the figures
for herbaceous canopy cover, percent vegetative cover, and percent of
total herbaceous cover. Data from the line intercept method are
represented as percent canopy cover.

1) Herbaceous canopy coverage is the percent areal cover within a

sample plot of all individuals of a single species in the herbaceous
layer. Coverage is assigned a coverage class number which
represents a percentage spread, i.e. 1=0-5%, 2=5-25%, 3=25-50%,
4=50-75%, 5=75-95%, and 6=95-100%. Mean canopy coverage is
calculated for each species by summing the midpoint values of all
the coverage classes recorded for that species and dividing by the
total number of plots. Mean canopy coverage for all species is
summed and reported as cumulative herbaceous cover. These
figures are used primarily to provide a three dimensional
characterization of the site and may exceed 100% because of
overlapping canopies of different species within a plot.

2) Percent vegetative cover reflects the proportion of ground covered
by the herbaceous layer relative to the proportion of bare ground.
This areal cover value is calculated by subtracting the mean
coverage of bare ground (the sum of the midpoint values divided
by total number of plots) from 100%.

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3) Plant species richness is the total number of species encountered
on a site using both line intercept and canopy cover methods.

4) Percent of tree and shrub canopy cover is reported as the percent
area cover of woody vegetation greater than one meter tall. The
percent canopy cover is calculated by summing the line intercept
lengths for an individual species and dividing by the total length
of all the transects sampled. The sum of percent cover for all trees
and shrubs on a site may exceed 100% due to layering of the
canopies of different species.

5) Percent of total herbaceous cover is the proportion of the
cumulative herbaceous cover (mean canopy coverage divided by
the cumulative herbaceous cover) provided by a single species, or
a group of species which could not be separated in the field. When
the percents of total herbaceous cover for all species are summed,
the total will equallOO%.

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