In her 1996 paper, Barbara Bedford mentioned that wetland mitigation policies are in effect landscape-level policies for managing and distributing wetlands. In a paper* soon to be published in the journal Wetlands Ecology and Management, Shari Clare of the University of Alberta (Canada) and her co-authors make this point further by investigating if and how the mitigation sequence of avoiding, reducing and finally offsetting or compensating is applied in the province of Alberta.
Through interviews with regulators, developers and actors of the wetland mitigation hierarchy they show that offsetting is systematically used to allow developers to get approval for their project. They argue that the requirement to avoid impacts is not well enforced in part because of:
the lack of guidelines on how to assess avoidance measures and alternatives while, in contrast, there are established guidelines for designing and sizing offsets)
the lack of a province-wide vision of where development could occur and where avoidance should be sought (i.e. land-use planning does not play its role)
the lack of recognized economic value of wetlands (i.e. their “use-value” is not taken into consideration in assessing equivalence)
the belief that wetland functions are easy to (re)create or restore (i.e. “techno-arrogance”).
To address these issues, the authors suggest watershed-based planning where wetlands are placed within a broader landscape context and alternative land-uses prioritized. This is consistent with the conclusions of Bedford (1996) who argued that project-centred regulation (i.e. command-and-control) is insufficient to reach the goal of no-net-loss of wetland functions. Shari Clare and her co-authors mention systematic conservation planning as one methodology for developing such watershed-level approaches. More generally, having a strategic vision for managing wetland resources at the provincial (or watershed level) is necessary for regulators to be proactive in the permitting process (rather than being reactive to developer requirements) and to effectively take into account cumulative effects (or many small impacts and wetland losses).
The authors also add that wetland functions need to be better “valued” and suggest that social and economic values be explicitly incorporated into the assessment process. They suggest using the concept of ecosystem services to this end but not necessarily through a monetary valuation exercise. This raises complex assessment and accounting issues but is probably an effective avenue for both the public and developers to acknowledge the purpose of wetland mitigation policies and the option of avoiding impacts.
Beyond the question of avoidance measures, the paper also gives some interesting (frightening?) insight into the design and sizing of offsets:
In Alberta, all of the government regulators we interviewed indicated that the most common metric used for comparability or equivalency between impacted and compensatory wetlands is area, with very little consideration given to wetland functions or services.
Having shown that the mitigation policy suffers from a lack of post-approval monitoring of offsets, the authors also argue for a stronger involvement of civil society in monitoring and control of offset actions: if public authorities are unable to follow-up on their decisions, then the easy solution is to get volunteers to do the work but perhaps that is too easy?
To conclude, the paper is a very interesting contribution to the argument that, beyond developing adequate methodologies for assessing the equivalence between losses and gains in the context of offsets, the proper implementation of the mitigation hierarchy requires public authorities to be proactive about the goals in terms of wetlands, biodiversity, ecosystems etc. Being proactive means that a strategy must be formulated to managing these “resources” beyond each individual project.
* Reference of the paper : Clare, S., Krogman, N., Foote, L; & Lemphers, N. (2011): Where is the avoidance in the implementation of wetland law and policy? Wetlands Ecology and Management, in press.
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