Restoration Systems wrote the U.S. Army Corps of Engineers Wilmington District last week asking the Corps to reissue the Dam Removal Guidance for Compensatory Mitigation. (You may ask why the U.S. Army regulates impacts to waters but that is a story for another blog). The Corps, as they are commonly known, rescinded the document in the fall of 2004 without any formal explanation.
We relied on the dam removal guidance to make possible our sales of mitigation from the Carbonton and Lowell Dam removal projects to the N.C. Ecosystem Enhancement Program. We consider these projects an ecological and economic success. The gains are much larger for the environment given that the mitigation is derived from river restoration, not creek repair, and the credit was sold for less than 12 of the typical cost to the state Ecosystem Enhancement Program. A win-win for the environment and the taxpayer. In addition, the method relies largely on low-impact passive restoration, not heavy equipment work, a stated goal of the Army Corps.
We would like to continue to remove dams that do not make sense. However, it is very difficult to make a sale of mitigation when the proper guidance documents are not available to give the customer confidence the mitigation method is viable and credit estimates are reliable. This is particularly true for large scale dam removal, a relatively new mitigation method.
From what we heard back at the Stream Restoration Conference, however, it does not look good. The Corps has not formerly responded yet (we will blog it when they do!) but the suggestion has been made that they will handle each matter “case-by-case”. They are the boss, and we appreciate the Corps reviewing these projects. Given the tight budgets and limited staff in the Wilmington District it is clearly a challenge to review projects. But we contend that guidance — not guess work — would better serve the mitigation system. The NCEEP should have some basis for judging the mitigation value of a project, just as Restoration Systems should have some basis for preparing a proposal.
We hope the Corps will consider issuing guidance to help move this innovative and productive form of compensatory mitigation forward. We will keep you updated on the process and, hopefully, progress.