Wetlands Restoration and Mitigation Policies: Reply MARGARET SELUK RACE University of California

Division of Agriculture and Natural Resources 2120 University Avenue

Berkeley, California 94720, USA

In evaluating the comments of Harvey and Jos- selyn, it is important to recognize the following points:

1) Their comments were made with the good for- tune of several years of additional hindsight over my original research effort. The terminology and defini- tions used in my article reflect a time when ideas were in flux and there were considerable differences among authors and coastal managers on what com- prised mitigation, marsh creation, and wetland resto- ration. Thus, some of their criticisms related to termi- nology and definitions are well taken.

At the time I undertook this research, the terms marsh creation and wetland restoration were loosely syn- onomous with vegetation establishment. Were I to write the article again today, I would undoubtedly be more precise in distinguishing between categories of projects. However, I doubt that such precision would dramatically alter my general recommendations and conclusions. I agree that "it is not necessary to recreate the same type of wetland that once existed at a site to count the site as restored." Likewise, it is appropriate to consider all types of wetlands (not just marsh per se) when planning for mitigation at a site.

My inclusion of experimental plantings and erosion control projects was done for good reasons--not be- cause I "apparently define experimental plantings as equivalent to restoration." In various written sources these projects were referred to as marsh or habitat es- tablishment projects, giving the impression that they were more substantial than experimental plots. In ad- dition, I sought to gather information on all types of past marsh establishment work that would help pro- vide indications of the state of the art. Obviously all these experimental plantings and plots generated valu- able researach information, as Harvey and Josselyn rightly note, and as experiments, they succeeded. An experiment can be successful even if it yields only neg- ative information. All agree that these experiments have generated considerable information, both posi- tive and negative, much of which has been incorpo- rated into planning for new restoration projects. How- ever, I still maintain that information from past exper- iments of limited on-site success (as opposed to

experimental success) can be misleading when in- cluded in published guidelines.

2) Much of the criticism by Harvey and Josselyn steins from a misrepresentation of my findings. They charge that my "major conclusion is that wetland resto- ration has been substantially unsuccessful in San Fran- cisco Bay." Careful reading of the article says nothing of the sort. The article was never intended as an ex- pos~ of successes and failures in San Francisco Bay. Rather, I argue that the collective record of all 'types of previous restoration and marsh creation projects sug- gests that the technology is still somewhat experi- mental and unpredictable and that the bartering of wetlands via mitigation and the permit process should be reanalyzed accordingly. By using a historical case study approach, the article provides a critique, not of individual successes and failures, but of the premature adoption of ideas into a policy-making process--one that has serious ramifications for wetlands throughout the country. After all, we must be certain that we es- tablish true wetland restorations in all their biological and physical potential, not just wet areas flushed by the tides.

3) My use of the terms evaluation and analysis in the abstract and title was unfortunately imprecise. As de- scribed in the methods section, the article should more accurately be called a detailed historical review of past projects in San Francisco Bay. For reasons outlined in the article, I intentionally chose not to conduct any "analysis" or "evaluation" using either standardized or other techniques. In the article, all reports of "success," "failure," or "longevity" of particular sites rest not on my "opinion" or "anecdotal reports" as Harvey and Josselyn allege, but on the raw data and results pre- sented in consultants' reports, literature records, or other written sources. The article purposely presented the actual, sometimes elusive, findings from many past projects, allowing readers to draw their own conclu- sions about the overall record.

As stated in the article, my own interpretation (as opposed to strict scientific evaluation) from these findings is that "it is debatable whether any sites in San Francisco Bay can be described as completed, active or successful restoration sites at present." As written, the statement refers to the past projects described in the article at the time it was written. Apparently, the de- bate still rages. I look forward to a time when addi- tional research and improvements in technology will make this statement totally inaccurate. Until then, 1 am willing to recognize that restoration attempts have

Environmental Management VoL 10, No. 5, pp. 571-572 �9 1986 Springer-Verlag New York Inc.

572 M.S. Race

greatly improved over the past decade, but I am not enthusiastic about judging success or completion by the fact that "none of the sites have reverted to non- wetland habitats."

It is fitting and proper that the debate continues over the success of past projects and the advisability of wetland restoration as a mitigation tool. The debate is far more than an academic exercise. At two recent wetlands conferences, I heard coastal managers voice concern over their inability to monitor mitigation projects after permits are issued. Their concerns were not about determining the "success" of mitigation projects, but, about whether projects were even begun. In a recent study in San Francisco Bay (Eliot 1985), a survey of 58 mitigation projects found that almost half had not even been started by the specified completion date in the permit. The issuance of a permit all but guarantees the loss of some existing wetland area. Un- fortunately, it does not always guarantee the establish- ment of a suitable wetland replacement, even when

mitigation by habitat restoration is a condition of the permit.

I think the differences of opinion between Harvey, Josselyn and myself can be explained, in part, by per- spective. I do not share the same degree of confidence as Harvey and Josselyn about the reliability or predict- ability of technology used to restore wetland areas. I am pleased we agree on the need for further research and discussion. If my article and Harvey and Josselyn's critique have further fueled the debate on this subject, then our efforts have been worthwhile. Regardless of the outcome of the debate, I am hopeful that the ulti- mate result will be better wetland management every- where.

Literature Cited

Eliot, W. 1985. Implementing mitigation policies in San Fran- cisco Bay: a critique. A report of the California Coastal Conservancy, Oakland, California.