Wetland protection is just as high a priority
as the design of the pavement or the drainage. If the project
proceeds, the City should require an operation and maintenance plan to
be a part of the project. The project should not proceed unless
there is financing set aside to carry out that ongoing operation and
maintenance.
Long term stewardship is what makes or breaks all restoration
and mitigation projects. All you have to do is look at all the
wetland mitigations along 80-94 and see them all full of cattails,
Phragmites, and purple loosestrife to know what happens when there
isn't any stewardship. There should be a long term operation and
maintenance plan with the funding and expertise to carry it out.
Someone should look into what the Corps's present
policy is on requiring funding and planning for long term
management of mitigation land. The US Army Corps put out
a Technical Guidance on wetland mitigation that covers this
long-term management need after the National Research Council put out
their big report that was very critical of the success of wetland
mitigation so far because created wetlands are shoehorned in where
they are convenient to developers without regard for buffers and clean
water sources and no one is keeping them free of exotic species or
doing any other management. The Corps didn't even
require monitoring wetland mitigation past 5 years.
Anyway, there is documentation that can be accessed on this
issue. Not to brag, but I (Sandy) have a very nice wetland
mitigation on our property--with wet prairie, sedge meadow and
shallow pond edge--which shows the value of good
stewardship. You are welcome to come and see it.
One extremely important point that must be hammered home relates to
maintaining the existing and the enhanced wetlands that
are proposed to be a part of the project. The Park
Department does not have the knowledge, funds or staffing to properly
carry out this operation and maintenance work.