Wetlands Search Comes Up Dry

Lily Palmer representing Coleman Engineering presents Phase 1 of the Wetlands Search to the Gogebic Economic Development Commission. The County has commissioned Coleman Engineering to search for suitable wetlands that could be placed into a County Wetlands Bank. The bank would be used to make it easier for developers to build in current restricted wetlands areas primarily along U.S. 2.

According to the report the county-wide search was conducted using GIS layers to sort out the parcels. According Ms. Palmer "Restoration of drained wetlands is the preferred mitigation banking method." "the sites revealed using the given GIS search parameters did not result in any significant restoration opportunities within Gogebic County."  The reports states that "The economic history of Gogebic County is not rooted in agriculture, therefore an effort at finding sites suitable for restoration of drained farmland have turned out to be largely unsuccessful."

 Ms. Palmer told the EDC members that "If the EDC was interested in pursuing a restoration based wetland mitigation bank, additional GIS site searches could be conducted to examine 10 acre and smaller agricultural lands. There may be smaller sites within the County that may offer feasible restoration opportunities. "


"Given that no suitable restoration sites were found within the County during Phase I of the project, an alternative is to attempt construction of a wetland mitigation bank based on creation of new wetlands. The created wetlands option is much more costly than traditional wetland restoration and would require close consultation with the MDEO to determine if it would even be a feasible to pursue. This scenario may not be the most cost effective for the EDC, particularly because there is no scheduled return on the investment "

One of the alternatives still available is to have the developers handle the mitigation themselves.

The Final Report for Phase 1 is reported below

Phase I Search for Potential Wetland Mitigation Sites in Gogebic County, Michigan September 24, 2008

BACKGROUND
According to the Michigan Department of Environmental Quality (MDEQ) Wetland Mitigation Banking Handbook, wetland mitigation banking is the creation or restoration of wetlands in order to provide mitigation credits that can be used to offset permitted wetland .Iosses. Mitigation banking benefits wetland resources by providing advance replacement for permitted wetland losses, consolidating small projects into larger, better-designed and managed units, and encouraging integration of wetland mitigation projects with watershed planning.

The ideal wetland mitigation bank will consist of wetland restoration. This process involves restoring formerly drained wetlands to their natural state through various methods which may include blocking existing drain tile or other ditches. Restoration returns a site to historical conditions and is typically less costly and more successful than wetland creation. Wetland creation means the physical and biological establishment of a wetland where a wetland did not formerly exist. Sites requiring complex design and construction strategy to achieve wetland functions should be avoided, thus restoration of historic wetlands should be the preferred banking method. Under certain circumstances, limited mitigation credit may be given for the preservation of existing wetlands which have exceptional public values. Using preservation of existing wetlands for mitigation, however results in an overall loss of wetlands. Therefore, mitigation credit is not typically offered for preservation of existing wetlands. In those situations where mitigation banks include preservation credits the wetlands must meet specific criteria. These criteria include exceptional physical or biological function essential to the preservation of the natural resources of the state or that the wetland is of an ecological type which is rare or endangered. In addition, the preserved wetland must be under threat of loss or degradation due to human activities and the preserved wetland must be protected by inclusion in the bank with specifications for management measures to protect its exceptional wetland functions. No more than 15 percent of the total wetland acreage in a mitigation bank may be preserved wetlands.
In addition, a wetland mitigation bank should be constructed with the overall intent of replacing those wetland functions which are unavoidably lost as a result of permitted activities within that watershed. Thus, the site should be situated in the watershed where wetland impact is likely to occur. The Gogebic County Economic Development Commission (EDC) has identified the U.S. Highway 2 corridor between the cities of Bessemer and Ironwood as a possible commercial development area where existing wetlands are seen as a hindrance to development. Attachment 5 shows the National Wetlands Inventory (NWI) overlay for the US Highway 2 corridor from Ironwood to Bessemer. The NWI map shows the potential wetland acreage along this corridor to be roughly 224 acres.

The U.S. Highway 2 corridor between Bessemer and Ironwood is comprised of the Montreal River watershed to the west and the Black River watershed to the east . Therefore, potential mitigation sites located within these watersheds should be prioritized. Again, mitigation banks should be designed to replace wetlands lost within the same watershed. Nearly all of the sites produced by GIS sorting during Phase I of this project are located within these watersheds. The watershed name is listed on each individual site data sheet.
GIS SITE SEARCH DESCRIPTION

Site search for a wetland mitigation bank was conducted within the boundaries of Gogebic County, Michigan.

Numerous site searches were conducted using Geographic Information System (GIS) layers to sort out possible mitigation sites. The site searches were implemented to locate 10-acre sites and 20-acre and greater potential wetland mitigation sites. The flow chart criteria utilized to determine these sites are included in Attachment 1.
The individual site searches are summarized in Table 1, below.

TABLE 1

ACREAGE

WOODED
(Acres)

OPEN LAND
(farmand & other)  (Acres)

TOTALS
10 Acre & Greater
County Lands
174

15

189

10 Acre & Greater - All
Inclusive Lands
5082

1773

6855

20 Acre & greater - All
Inclusive Lands

Included in
10 acre search

428

428

     

7472


In considering a wetland mitigation bank in Gogebic County, setbacks from local airports must  be considered. The FAA recommends a setback distance of 10,000 feet for hazardous wildlife attractants including wetland mitigation banks. The Federal Aviation Administration (FAA), the U.S. Air Force, The U.S. Army Corps of Engineers, the U. S. Environmental Protection Agency, The U.S. Fish and Wildlife Service, and the U.S. Department of Agricultural - Wildlife Services signed a Memorandum of Agreement in July 2003 to acknowledge their respective missions in protecting aviation from wildlife hazards. The FAA provided an Advisory Circular in August 2007 outlining specific setback requirements at airport facilities. The FAA requires that wetland mitigation projects that may attract hazardous wildlife (i.e. waterfowl, migratory birds, etc) be sited outside of the minimum separation criteria for the airport facility. The FAA criteria include land uses that cause movement of hazardous wildlife onto, into, or across the airport's approach or departure airspace or air operations area. The separation distances are based upon 1) aircraft flight patterns, 2) the altitude at which most strikes happen (78% occur under 1,000 feet and 90% occur under 3,000 feet above ground level) and 3) National Transportation Safety Board recommendations. For airports that serve turbine powered aircraft (such as Gogebic County Airport) the FAA requires a separation distance of 10,000 feet for any wetland mitigation site development. This separation distance for the Gogebic County Airport is shown in Figure 1 in Attachment 4. No sites within 10,000 feet of the airport were included in this report.

The 10-acre all inclusive (County and privately owned) agricultural and wooded lands GIS search resulted in 6,800 acres of land. To facilitate ground-truthing of individual sites and in keeping with the EDC's request, this massive acreage was trimmed down by narrowing the search to include only 10-acre County lands as the EDC had expressed that County owned lands are the desired location for a wetland mitigation bank. The 10-acre County owned lands with agricultural or wooded coverage turned up 13 sites ·encompassing 189 acres; 174 of these acres are wooded. Three sites comprising 43.5-acres (Sites 412, 414 and 415) were not accessible by vehicle. A fourth site of 20.5-acres (Site 280), lying immediately north of Extreme Tool in Wakefield Township was deemed likely be in conflict with the mission of this industrial park area nor was it accessible by vehicle, and, therefore, was not ground-truthed. Thus, the remaining 9 sites (125-acres) of County owned land were ground-truthed. A County-wide map showing individual site locations is included. The individual site specific data sheets are included.

The 20-acre and greater site search (County and privately owned) agricultural lands search resulted in 428 acres comprising 15 sites. All of this acreage was on private land (any County owned lands occurred within 10,000 feet of the Gogebic County Airport and were, by rule, eliminated). One 24-acre parcel (Site 1) was not accessible by vehicle. Thus, the remaining 404-acres of privately owned property (14 sites) were ground-truthed. Again a County-wide map showing individual site locations is included. The individual site specific data sheets are included.

 

FIELD CHECK OF GIS SITE SEARCH RESULTS

Field checking of the sites produced from the GIS searches described above was conducted in August and September, 2008. A brief description of the results of the field investigations in Gogebic County are provided in this section. The data sheets for each individual site are included in Attachment 3 and they provide additional data concerning the sites. One field team was deployed to check the sites identified in the site search. A standard methodology of site review and data gathering were utilized with the intent of attaining consistency in how sites were evaluated.

As described above, in the 10-acre County land category a total of 9 sites were field checked. All of the sites were mostly wooded. None of the sites appeared to be candidates for wetland restoration as they did not appear to have been disturbed by humans or by human-made drainage structures, however some of the sites. may be candidates for wetland creation in a more conventional sense, as described in the Summary of Findings section, below. Typically, the MDEO prefers wetland mitigation banks be formed from restoration of historically drained or altered open, agricultural lands as opposed to through the harvesting of forestlands.

The 14 sites identified in the 20-acre and greater privately owned lands categories were ground­truthed. Unfortunately none of these sites appeared to be restorable wetland sites, however the sites with the most potential for wetland creation are described as follows:

Site 394 - This site is located near Saari Lane and Airport Road, north of the City of Ironwood. The western half of the site is an active horse pasture and the southwestern area may already be wetland, exhibiting that hydrology is near the ground surface. The possibility exists to expand the existing wetland area to the east by excavating the surrounding slopes.

Site 230 -This site is located northwest of the intersection of Pioneer Road and Van Buskirk Road, south of the City of Ironwood. The existing swale on the east side of the property is tied into regional drainage and blocking it may negatively affect neighboring properties. The center of the site is relatively high, thus the most feasible creation possibility lies around creating wetland hydrology around the perimeter of the site's high center. Significant earthwork would need to be undertaken to remove the site's high center and increase wetland creation acreage.

386 - This site is located north of the intersection of Airport and Norlund Roads. There may be some possibility to create a wetland by constructing a berm across the existing natural drainage through center of western portion of the farm field. There also appear to be ditches in the upland pastures immediately at the termination of the north end of Saari Lane.
 
SUMMARY OF FINDINGS
Restoration of drained wetlands is the preferred mitigation banking method. In summary, the sites revealed using the given GIS search parameters did not result in any significant restoration opportunities within Gogebic County. The economic history of Gogebic County is not rooted in agriculture, therefore an effort at finding sites suitable for restoration of drained farmland have turned out to be largely unsuccessful. If the EDC was interested in pursuing a restoration based wetland mitigation bank, additional GIS site searches could be conducted to examine 10 acre and smaller agricultural lands. There may be smaller sites within the County that may offer feasible restoration opportunities.
Given that no suitable restoration sites were found within the County during Phase I of the project, an alternative is to attempt construction of a wetland mitigation bank based on creation of new wetlands. The created wetlands option is much more costly than traditional wetland restoration and would require close consultation with the MDEO to determine if it would even be a feasible to pursue. This scenario may not be the most cost effective for the EDC, particularly because there is no scheduled return on the investment

Perhaps the most viable option for the EDC to consider would be utilizing the data gathered from Phase I of this process to provide potential developers with a "bank" or "selection" of upland sites on County' lands that could be developed into wetlands on an as-needed basis (this is more in line with "conventional" mitigation conducted on a site-by-site basis). Sufficient on­site work would need to be conducted on the high priority sites to ensure that they are feasible for creation of wetlands. This scenario would release the EDC from the financial burden of locating, creating and maintaining a wetland mitigation bank while still providing possible mitigation sites that developers could choose from to create wetlands to mitigate for permitted losses, at their own cost. In this scenario the EDC's focus would now shift towards locating sites suitable for wetland creation, likely on County owned lands. Timber harvest and sale or lease of the property to a developer could possibly offset costs incurred during this type of mitigation site selection process.

While this "bank" or "selection" of suitable mitigation sites approach is certainly less of a risk for the EDC, it would need to be balanced with the overall goals of the Commission. Under these circumstances, the developer would be provided with a suitable mitigation site on which to create wetlands at his/her cost, not a wetland mitigation bank where he/she could "cut a check" to mitigate for permitted wetland losses and then walk away.

Resources
MDEQ Wetland Mitigation Banking Handbook, September 2001.
Coleman Engineering Company CECJob No. 08050 EDC - Final Report
 

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