Wetland Alteration and Conservation: Planning Implications and Strategies

ions and simplifications of the "real world". 21 Furthermore, models are more useful in dealing with certain classes of information (i.e., those that lend themselves to quantification and mathematical formulation) than with others. We do not yet have the scientific capability to include in our models all of the natural history and lifecycle information about all the biological species of a given environment. Yet, these natural history details are what often determines the success or failure of a given species when stressed by habitat manipulations. Wetland conservation efforts will benefit greatly from improved ecosystem modeling capabilities. Models are, of course, no substitute for human input. Our public policies and research directives must be founded on the knowledge and judgement of experienced scientists and a concerned citizenry. Man alone can ask the relevant questions and interpret the data provided by the computer. Some wetland conservation issues for which additional research is

Wetlands and saturated soils are not only unremunerative, but if the area is considerable, they prove a source of enervation and disease to the section in which they exist. Although individuals may neglect swamp lands, or find their reclamation and drainage too expensive, the State cannot afford to be indifferent to their continuance, because they check production, limit population, and reduce the standard of vigor and health. Their value, too, when reclaimed, in an economic view will be greatly enhanced. 1 President of the American Public Health Association, 1876.
Wetlands are areas of great natural productivity, hydrological utility, and environmental diversity, providing natural flood control, improved water quality, recharge of aquifers, flow stabilization of streams and rivers, and habitat for fish and wildlife resources. Wetlands contribute to the productivity of agricultural resources of national interest. This piecemeal alteration and destruction of wetlands through draining, dredging, filling and other means has had an adverse cumulative impact on our natural resources and on the quality of human life.
President Carter, 1977 2 The contrasting views expressed in these passages reflect the profound change in attitude towards wetlands and the growing appreciation of the importance of wetlands to the ecological balance of the environment. Wetlands have traditionally been considered wastelands, sources of mosquitoes and impediments to development and travel. Alteration of these natural systems through filling and draining to create solid ground has long been accepted construction . 3 practice.
The long-term physical and ecological relationships between water, land and man's activities are now better understood. The value of wetlands and the hazards that accompany wetland alteration are now being recognized. Wetlands in their natura l state serve important functions, including purification of water bodies, flood storage and conveyance, fish and wildlife habitat and aquifer 4 recharge.
Coastal wetlands and those adjacent to major streams are often subject to serious flood and erosion hazard which may persist af ter draining and filling. 5 Today, the protection of wetlands is mo r e widely recognized as essential to restoring and maintaining water quality, preserving natural hydrologic cycles, providing wildlife habitat and enriching man's communities in general.
There is now a heightened awareness of the need to make conscious, informed choices about future modif ications of the natural environment. The crucial trade-offs involved in altering wetland systems are now being weighed more heavily in the decision-making process in many communities. The wetland setting provides a framework within which important land use decisions must be made so as to optimize conservation and development opportunities while minimizing adverse environmental impacts.
The growing recognition of the ecological and economic importance of wetlands in the last decade, combined with accelerated f lood losses and water pollution from wetland alteration, has prompted nearly one half of the states to adopt regulatory pro grams at the state and/or local levels to control coasta l and inland wetla nd use or to guide wetland use as a component of broader flood plain, coastal, scenic and wild river, shoreland and critical environmental 6 area programs.

Loss of the Resource Base
Over one half of the nation's original two hundred and fifteen (215) million acres of wetlands have been lost through various forms of direct habitat destruction, and over half the remaining wetlands 7 have been severely modified.
Construction activities continue to destroy wetland environments at an alarming rate. The primary types of construction activity that severely impact wetland systems include floodplain surfacing and draining, mining, impoundment, channel-8 ization, dredging, bank/shoreline construction and canalization.
Each type of construction activity produces an identifiable set of physical and chemical alterations of the wetland environment that may extend for many miles from the construction site, and which may persist for many years. In turn, each phy sical and chemical 9 modification induces a predictable set of biological effects.
The most important ecologically damaging effects of construction activities on wetlands, in order of importance, are direct habitat loss, addition of suspended solids and modification of water levels 10 and flow re gimes.
Major construction-related impacts also derive from altered water temperature, pH, nutrient levels, oxygen, carbon dioxide, hydrogen sulfide and certain pollutants such as heavy 1 d . · · d · ·a 11 meta s, ra ioactive isotopes an pest1c1 es.
Many aquatic species have been lost or severely restricted as a result of wetland alterations. Other species are currently in jeopardy. Every aquatic system consists of a vast array of physical and biological elements that interact in subtle ways. In order to reverse the destructive trend and provide a rational basis for environmental management, it is necessary to minimize these activities. As one astute observer noted "Today there may be higher 12 political priorities, but tomorrow may be too late".

Project Background
The basis for this study is a personal conviction that wetlands are valuable ecological systems and significant features of the landscape. Wetlands are valuable natural assets that simply cannot be discarded through ignorance, indifference, accident or design.
Environmental planning at the national and state level has focused on chemical water pollution and water quality standards. These regulations address only one aspect of wetland protection. In the absence of comprehensive wetland regulations that take into account the causes of wetland deterioration and patterns of response, construction activities will continue to eliminate and degrade our nation's wetlands.
My appreciation of wetlands led me to the realization that there is a general lack of awareness of the magnitude of wetland losses in this country and the immediate need for improved regulations to deal with incremental wetland losses at the community level. As a planner and a citizen, I cannot stand idley by and accept the loss of these valuable national assets.

Project Purpose and Scope
The purpose of this project is identify those construction activities that a re impacting wetlands on a large scale and consider their planning implications. Recognition of the values of wetlands has prompted many states to enact wetland protection regulations. Some of these regulations go so far as to require restoration of altered 13 wetlands.
In addition to the multitude of legal ramifications, si gnificant ecological questions remain unanswered as to the environmental impacts and success of these restoration efforts. Yet, even with these regulations "on the books", incremental losses of wetland habitat continues in every community.
The goals of the project are, therefore, to: 1. Assess the impacts of wetland alteration; and 2. Offer strategies for wetland conservation.
The objectives of this project are to: 1. Highli ght wetland values; 2. Identify construction activities that impact wetlands; 3. Review wetland alteration impacts and patterns of response; and 4. Discuss planning implications and recommendations for wetland conservation at the local level.

Synopsis of Chapters
Chapter I serves to introduce the topic and scope of the project. This chapter also highlights the changing attitudes toward wetlands and the need for comprehensive resource planning at the local level. Chapter II provides a discussion of wetland ecology with an emphasis on definition, classification, values and dynamics. The management implications for regulating wetlands in light of these dynamic natural processes are also discussed briefly in this chapter.
Chapter III describes conunon construction activities that impact wetland environments throughout the United States. The physical, chemical and biological impacts of these construction activities on wetlands are discussed in Chapter IV. Chapter V synthesizes the preceeding information on wetland alteration impacts and provides some recommendations for wetland conservation strategies.

FOOTNOTES
Chapter I (continued) 13. Recognition of the values of inland wetlands prompted the Rhode Island Legislature to enact legislation (RIGL SS 2-1-18 to 2-1-25) entitled "An Act Relating to Freshwater Wetlands" (1971) declaring: 2-1-19: It is the public policy of the State of Rhode Island and Providence Plantations to preserve the purity and integrity of the swamps, marshes and other freshwater wetlands of this State ... The health, welfare and general well-being of the populace and the protection of life and property require that the State restrict the use of wetlands and, therefore, in the exercise of the police powers such wetlands are to be regulated hereunder ...
2-1-24: Whenever any person, firm, industry •.. shall commence any activity set forth in Section 2-1-21 without first having obtained the approval of the director, the director may serve said person with written notice to cease said operation and/or order the removal of any such fill placed illegally on such wetlands and the wetlands restored to their original state insofar as possible ...

2-1-23:
In the event of a violation of Section 2-1-21 of the General Laws, the director shall have the power to order complete restoration.
We abuse land because we see it as a commodity belonging to us. When we see land as a community to which we belong, we may begin to use it with love and respect. 2. The substrate is predominantly undrained hydric soil**; 3. The substrate is non-soil and is saturated with water or covered by shallow water at some time during the growing 4 season each year.
In wetlands, the water table is at, near or above the land surface long enough each year to promote the formation of hydric (water-logged) soils and to support the growth of hydrophytes (plants capable of surviving in aquatic or water-lo gged soil conditions) as long as other environmental conditions are favorable. W etlands span a continuum of environments where terrestrial and aquatic inter grade.
The single f eature that all wetlands share is the presence of more soil moisture than is necessary to support the growth of most plants.
This excess of water creates severe physiological problems for all plants except hydrophytes which are adapted to life in water or in d 'l 5 saturate soi .
The upland limit of a wetland is designated by the followin g : 1. A change from predominantly hydrophytes to upland vegetation; 2. A change from predominantly hydric to nonhydric soils; and 3. A change from land that is flooded at some time to land ~ that is never flooded.
The lower limit of a coastal wetland coincides with the elevation of extreme low spring tide. At inland sites, a depth of two (2) meters below low water level or the deep water boundary of emergent aquatic vegetation, shrubs or trees that may grow beyond this depth is considered the lower limit of the wetland. 6 * Hydrophyte -Any plant growing in water or on a substrate that is at least periodically deficient in oxygen as a result of excessive water content.
** Hydric soil -Soil that is wet long enough to periodically produce anaerobic conditions (oxygen deficient), thereby influencing plant growth.
Wetlands are known by common names such as swamps, marshes, bogs, flats, sloughs, beaches and rock shores. Because these common names have different meanings in different parts of the country, the term "wetlands" is used to cover all transitional habitats that occur between upland and aquatic environments where the water table is at or near the surface of the land, or where the land is covered by shallow water up to six (6) feet deep.

Wetlands Classification Systems
The "National Wetlands Classification System" recognizes five (5) major wetland systems. These major systems are outlined in Table   II-1.   Table II The Lacustrine System has two (2) subsystems -Littoral and Limnetic. 7 The Palustrine system has no subsystem.
For planning purposes, Marine and Estuarine habitats include coastal wetlands, such as tidal marshes and mangrove swamps. The other three (3) major wetland categories describe freshwater systems, which account for ninety percent (90%) of the nation's wetlands. 8 Lacustrine wetlands are associated with lakes while Riverine wetlands are found along rivers and streams. The word Palustrine means marshy and includes wetlands commonly known as marshes, swamps and bogs.  Table II The Rock and Unconsolidated Bottom classes are flooded all or most of the time while the Rocky and Unconsolidated Shore classes are exposed most of the time. The class Streambed is restricted to channels and intermittant streams, and tidal channels that are dewatered at low tide. 12 The type and duration of flooding in tidal wetlands are further . d. f. 13 escri e y our water regime mo i iers.
These modifying terms are summarized in Table II-3.   Table II-3. "National Wetlands Classification System" water regime modifiers for tidal and nontidal wetlands WATER REGIME MODIFIERS TIDAL (4) Sub tidal Irregularly exposed

Regularly exposed
Irregularly flooded NONTIDAL (8) Permanently flooded  Table II-4. showing systems, sub-systems and classes is presented in Figure 1.
Wetland categories are further described in Appendix A.
In the glaciated Northeast, the most conunon freshwater wetland types are deep marshes, shallow marshes, meadows, shrub swamps, 17 wooded swamps, fens, bogs and open water.
These freshwater wetland classes and subclasses are listed in Table II-5     The flood-control effectiveness of any wetland depends on its size, hydrologic character and location in the drainage basin, as well as the size, hydrologic character, flooding characteristics and distribution of streams and rivers in the drainage basin. Flood control effectiveness is generally greatest during high-intensity, 20 short-duration storm events which generate the largest floods.
The importance of wetlands in flood storage can be appreciated when it is recognized that a wetland one (1) acre in size will hold 21 330,000 gallons of water if flooded to a depth of one foot.
Filling a wetland or channelizing an associated water course will negate the function of flood storage, causing increased flood heights on adjacent and upstream lands and increased velocities downstream.

Barriers to Waves and Erosion
Coastal and inland wetlands along lakes and streams reduce the impact of storm tides and waves by dissipating much of their energy before they reach upland areas. . Wetland

Water Supply
Wetlands have a valuable influence on the quantity of surface water that supplies large portions of the population with clean water for recreational, domestic and industrial uses. The low, flat surfaces of wetlands gather runoff from adjacent uplands and allow the water level to build up as they slowly release water to streams, thus reducing peak flood flows. After welands are flooded, they may recharge ground water aquifers for several weeks. In addition, wetland water storage augments the low flows of streams for an even

Recreation
Water bodies and related wetlands are not only essential to a community's environmental well-being, but they also provide valuable recreational and cultural amenities in the form of both water and non-water based leisure activities. There are many different recreation values associated with wetlands. Many of which are passive and inexpensive recreation activities that require little or no organization, equipment or development, and are spread out over a 28 large area rather than concentrated in a small area.

Wildlife Dynamics
As wetlands change from one successional stage to another, wildlife populations within these wetland communities change as well, for each species has particular habitat requirements that only 69 specific wetland types can satisfy.
During the last 10,000 years, the composition of wetland wildlife populations has fluctuated between primarily marsh species such as muskrats and waterfowl, and forest species such as deer and grouse. The current trend toward decreasing wetland diversity in the region suggests that wildlife 70 diversity is also decreasing.
In a region where prime habitat for waterfowl and other marsh wildlife is already scarce, further reductions in such habitat is likely to occur. The abundance of waterfowl, marsh birds, muskrats and many other species of wetland wildlife will gradually but steadily continue to decline in Rhode Island unless natural or manmade disturbances act to set wetland succession back to an earlier 71 stage.
As society continues to enjoy more leisure time, outdoor activities will remain popular forms of recreation. Wildlife is becoming an important source of enjoyment for non-consumptive uses, including bird watching, photography, hiking, canoeing, camping and education. Viewing a diversity of wildlife in their natural habitat is a meaningful experience for many people. As development in the 35 region continues, and the opportunity to hunt declines, emphasis on the management of non-game species will likely increase to reflect 72 societal needs and desires.

Management Implications
The relative abundance of wetland types and diversity of wetland plant and wildlife communities has undoubtedly fluctuated considerably since the formation of most of the region's wetlands.
Many of the wetland changes that have occurred in the past will continue to occur in the future. Wooded swamps will grow in acreage as a result of natural succession, and non-wooded wetlands will decline. Shallow marshes and meadows are easily altered and will likely suffer the greatest damage and destruction. Other wetlands Much of the urban growth experience in the United States over the past quarter century has consisted of people running away--from other people in the older cities, now even from the suburbs to the mountains and the seas. Now it is dawning on us that there is not really any place to run to . . . There is no hiding on two-acre lots. Wetland impacts vary with locale and from site to site. The "housekeeping" practices employed at the construction site will also significantly affect the magnitude of the alteration impacts. Sloppy 1 engineering practices will tend to magnify environmental impacts.
Wetlands may be impacted directly by construction that takes place within or at the margins of the wetland, or indirectly by construction activities on adjacent floodplains, banks and shores.
Numerous construction activities are associated with large development projects. For purposes of this report, these activities are grouped into ten (10) classes of activities as follows:

10.
Major construction activities; and 2 Site restoration and clean-up.
All ten classes of activities may not be required for all construction projects, particularly for small projects in ex isting built-up areas. In addition, the long-term impacts of the construetion project will depend on the nature, use and operation of the structure(s), and by other activities and developments which occur as a result of the initial construction project. 3 Construction activities can be grouped according to the types of wetland environments generally impacted by these activities. Construction activities associated with floodplains, banks and shores include: 1.

Pre-construction activities;
Construction involving impervious surfacing and earthwork; ipe ine construction.
In order to evaluate the actual and potential impacts of construction activities on wetlands, it is essential to outline the engineering aspects of various types of construction activities. A brief overview of the major construction activities and facilities associated with wetland environments is presented below.

Construction Activities Associated with
Floodplains, Banks and Shores

Pre-Construction Activities
The activities required prior to construction are similar for most projects. These activities involve the desi gn and initial on-

Construction Involving Impervious Surfacing and Earth Work
Activities that involve impervious surfacing and earth work include the construction of highways, roads, streets, driveways, airports, parking lots, playing fields, dikes, levees and earthen darns.
The activities and facilities that characterize impervious surfacing and earth work construction are listed in Table III Table III-3.  11  Table III Table III-4.  12  Table III

Construction of Drainage Structures
Drainage devices include a wide spectrum of structures ranging from small, corrugated metal culverts which discharge the drainage from a few acres, to large suspension bridges over major rivers. In general, most drainage structures can be divided into these two (2) classes --culverts and bridges.
Culverts are employed primarily to permit drainage through normally dry channels and streams with small flows. Culverts generally span less than fifty feet (50'). Bridges, on the other hand, are used to cross major waterways requiring spans of over fifty feet.
Bridge piers may be constructed using wet or dry construction techniques . The activities and facilities associated with the construetion of these two classes of drainage structures are presented in 13  Table III-5.   Table III- Table III-6.  14   Table III Table III-7. 15  Table III Table III-8. 16  Table III oat1ng rag 1ne.
In the floating dragline method, materials are excavated using a steam-shovel or grab operating from a barge. The excavated material is deposited as a spoil bank on one or both sides of the excavation.

River and Channel Modifications
River and channel modifications are carried out to stabilize the channel or to shorten the length of the river by cutting off meanders. In the latter case, the dry land excavation method is usually employed to create a broad, deep trench which almost connects with the river at either end. The end sections between the river and the trench are then blasted open to admit the river into the new channel. The old channel or oxbow may be filled or allow the remain 19 as a man-made or remnant oxbow.

Bridging in Wetlands
In wetland areas where the unstable material is quite deep or extensive, the most economical solution for linear construction such as highways or railways is to bridge the wetland. This bridging is accomplished by placing the bridge super-structure on pile bents and bent caps. The operation proceeds from the bank outward with pile 20 driving, pile caps and bridge super-structure placed consecutively.

Dredging and Placement of Dredge Spoils
Dredging refers to excavation in water. Dredging is employed to deepen channels, ports and harbors, and to provide fill materials for the construction of piers, docks, wharves, dams and underwater foun-  Table III-9.  24   Table III 25 The eroded length of beach may be artificially refilled.
The first method may employ the use of groynes which are wave and current-assisting installations placed perpendicular to the shoreline and extending both inshore and offshore. Groynes may be composed of short pilings, large quarry rocks or precast concrete blocks placed in a line. The length and spacing of groynes is a function of the rate and limit of littoral drift and the maximize 26 size of shore waves.
Intermediate barriers consist of revetments (retaining walls) placed parallel to the shoreline in a position half-way between high and low water. These structures reduce the beach slope shoreward and seaward. Off-shore barriers are commonly composed of rock mounds 27 placed parallel to shore that resemble breakwaters. Imported materials may also be used to stabilize shorelines from erosion. This material may come from borrow on uplands or from dredging operations. Table III- The alteration impacts of the ten classes of construction activities highlighted in this chapter are discussed in Chapter IV.
25. Ibid. 26. Ibid Small and unrelated decisions systematically foul the water, pollute the air, dam the rivers, subdivide the farms, fell the forests, fill the marshes, occupy the floodplains, and make accidental and whimsical growth emerge as the physical image of our state.   2. Impacts that occur during the period of stabilization followin g completion of the construction project; and 3. Long-term impacts and permanent changes brought about by the construction itself or by subsequent human use and environ- menta management resu ting ram t e constructe aci ity.

Physical and Chemical Impacts of Construction Activities on Wetlands
The physical and chemical impacts of construction activities on wetlands will be discussed in the same order that these activities were presented in Chapter III. The biological and ecolo gical impacts will be discussed in a separate section later in this chapter.

Impacts Associated with
Floodplains, Banks and Shores

Pre-Construction Activities
Pre-construction activities, such as survey ing and initial on-site lay-outs, involve the removal of some vegetation cover. This Petroleum products can enter water courses as spills from construction and/or maintenance equipment, and as runoff from highways. Large quantities of heavy metals, hydrocarbons, oil, grease, asbestos fibers from brake linings, and other materials can 14 enter wetlands from adjacent highways.
The major impacts of impervious surfacing and earth work on wetlands are summarized in Table IV-3. lS  Table IV Greatly increased stream sediment load due to erosion and runoff Greatly increased stream turbidity due to erosion and runoff Modified chemical composition of the water due to increased sedimentation, runoff, turbidity, leaching of soil nutrients, leaching of concrete and bituminous materials, cement plant operation, use and maintenance of construction activities, and road use following construction

MAJOR IMPACTS
The long-term impacts of these construction activities on wetlands will depend greatly on local circumstances. In general, however, the long-term impacts listed in Table IV

Impacts of Building Construction Activities
Building construction involves many of the impacts associated with impervious surfacing and earthwork concentrated in one location.
The construction of large buildings are generally accompanied by the construction of drainage ditches, storm sewers and parking lots.
Rapid surface runoff from these impervious surfaces will carry soil sediments, concrete leachings and oily compounds from the site to neighboring wetlands. The water level, turbidity, sediment load and chemical composition of the receiving water will be affected by this 20 runoff.
The long-term impacts of building construction activities are indicated in Table IV-6.  21  Table IV Table   IV-7. 25 wit any mining operation. For purposes of this report, these general impacts will be discussed in terms of their topographic, physical and chemical impacts on wetlands.
The  Table IV-8. 31  Table IV Habitat diversity is greatly reduced or eliminated.
The impacts associated with habitat destruction continue downstream many miles from the mining site. Many miles of streambeds and extensive estuarine areas may be affected. The physical impacts of mineral extraction on wetlands are presented in Table IV-9.  32   Table IV Table IV-10.  35   Table IV Table IV-14 highlights the general and immediate impacts of dredging on wetlands.

Impacts of Stream Channelization
Stream channelization is undertaken primarily to (1)     The loss of fine sand also means that new dunes cannot form to 62 replace those lost by the construction activity.
The impacts of construction of breakwaters, sea walls and other shore protection systems are higlighted in Table IV-19.   Table IV-19. Impacts of breakwater, sea wall and shore protection system construction on coastal wetlands IMPACTS Interruption of long-shore currents and lateral transport of sand Accelerated beach erosion due to removal of sand from the nearshore continental shelf creating greater wave forces Alteration or destruction of "high beach" (dune) habitat due to removal of sand Alteration or destruction of lagoon habitat due to dune erosion 4 IMPACTS

Impacts of Piers, Wharves and Bulkheads
The construction of piers, wharves and bulkheads permanently eliminates productive inter-tidal and sub-tidal "water-edge" habitat.
Dredging to obtain fill for such structures destroys additional shallow or deepwater habitat. These structures tend to be vertical

Impacts of Offshore Mineral Extraction and Pipeline Construction
Offshore dredging for sand, gravel and shell destroys bottom habitat and eliminates protective cover. Dredging near shore removes protective barriers and accelerates beach erosion.
The problems of off shore drilling for petroleum and natural gas stern from water pollution hazards and the creation of "artificial" habitats. These hazards are particularly acute in extreme environments such as those in the Artie Ocean. Construction under artic conditions must, therefore, incorporate high construction standards, advanced safety devices, attention to good "housekeeping", . 65 an provi e or requent inspection an monitoring.

Biological Impacts of Construction Activities on Wetlands
Environmental modification seldom impacts only a single physical or chemical factor. These impacts generally fall into two (2) groups that are time-related. These two types of impacts are: 1. Primary impacts that occur immediately after the environmental modification; and 2. Secondary and tertiary impacts that occur later in time and often some distance from the site. 66 It is important to recognize that a given environmental impact may result from more than one wetland alteration activity. For example, the total sediment load in a river system may be the result of multiple construction activities along its length. It is also important to note that two or more factors, working in combination, may produce impacts that may not have been predicted based on an examination of the factors taken separately. In some instances, one factor tends to partically cancel another, while in other instances, the combined effect may be more severe than the simple sum of the two 67 acting separately.
The set of secondary and tertiary impacts resulting from the primary disturbances are referred to as a "factor train". The generalized response patterns to increased levels of environmental stress at the different organizational levels discussed above are summarized in Table IV  The floral and f aunal mixing associated with construction activities is slowly crowding out many native species, thereby, reducing the . d . d. .     As soon as society recognize s that it cannot maximize everything for everyone, it must begin to make choices. Should there be more people or more wealth, more wilderness or more automobiles, more food for the poor or more services for the rich? Establishing the societal answers to questions like these and translating those answers into policy 1s the essence of the political process.
Yet few people in any society even realize that such choices are being made everyday, much less ask themselves what their own choices would be. The equilibrium society will have to weigh the trade-offs engendered by a finite earth not only with considerations of present human values but also with consideration of future generations. In order to effectively conserve wetlands, it is essential to understand the causes of wetland deterioration and major patterns of response. The following sections highlight these "causes" and "effects".

Causes of Wetland Deterioration
The A serious ramification of construction in wetlands is a long-range reduction in productivity or diversity. Following construction, the wetland may appear to have recovered when, in fact, it now exists at a low-equilibrium, chronically-stressed state. This situation is undoubtedly the case for many of our nation's wetlands that have been subjected to floodplain devegetation or heavy siltation.
Another response pattern that is probably more common than is generally recognized is that of "delayed response". This may result from life history peculiarities, environmental idiosyncrasies, multiple construction projects, or a combination of these factors. 6 Pollution gradually added to wetland bottom sediments, for example, may suddenly be released by a dredging project or the impacts of a water diversion project may be magnified during a drought period.
11·8 Wetland response to alteration by construction activities may appear insignificant at first but have far-reaching ecological or economic impacts. This is the case when one species or set of species is substituted for another. 7 For example, commercially important species of fish or shellfish may be replaced by non-commercial species as a result of shifts in salinity or water quality.
It is also prudent to keep in mind that ecosystem response patterns are not mutually exclusive but can grade into one another. Science provides us with a reasonable degree of predictability of cummulative biological response to human manipulation. We need to make use of this predictability in our resource management activities. But we must not lose site of those elements of nature that, to-date, escape our sophisticated wetland management capability to understand.

Planning Assumptions
Although major gaps in our knowledge of wetland dynamics clearly exist, we do know a lot about the impacts of construction activities on these natural environments. We can use this information to actively pursue steps to reverse the nationwide trend of wetland deterioration and destruction through planning. We can summarize this knowledge in the form of "planning assumptions". I have divided these 'assumptions' into ecological assumptions and resource management assumptions.

Ecological Assumptions
Wetlands in their undistrubed state are ecologically-adapted to o environmenta impacts. We can therefore expect to see these impacts each time a similar type of project is proposed. When a number of similar projects are undertaken, certain wetland types may be jeopardized on the local, regional or even national scale.
Certain wetland species and habitats are particularly vulnerable an require protection i t ey are to survive. These include rare and endangered species, certain immobile and isolated species as well as highly vulnerable wetland types. Some wetland types are more vulnerable than others because of their location or as habitat for economically important or aesthetically valuable species. The most sensitive and "pressured" wetlands are not likely to survive intact without deliberate protective intervention.
These ecological assumptions are summarized in Table V-1 and used, along with my resource management assumptions, to develop some strategies and recommendations for wetland conservation. Human demands and pressures on our nation's wetlands will increase in the future. Wetlands will continue to be altered and destroyed by the construction activities that result from these socio-economic demands and growth pressures. Small wetlands in growing communities will remain those least appreciated and thus most affected by development.
The Despite the predictability of wetland impacts for a given type of construction activity, every project is a "site-specific" ecological experiment. Local circumstances, in combination with the large number of physical, chemical and biological variables involved, make impact prediction somewhat uncertain at best. Planners need to recognize this potential for uncertainty and advocate that a significant margin of environmental safety be incorporated into the permitting process.
Consideration should be given to requiring a built-in "control" for approved projects. This control should be a local wetland of comparable size and ecological type which can provide baseline data for comparison.
There is a need for ecological research on the response of wetlands to specific types of environmental manipulation. Systems analysis data on ecosystem structure and function will improve our ability to predict wetland impacts. There is also a need to develop a sophisticated technology for restoring degraded wetlands. Wetland restoration may help us regain those ecological values lost in the construction process and avoid destroying these values in future projects. In addition, further investigation of what constitutes an adequate "buffer" is needed to enhance wetland conservation. Every wetland modification project is an ecological experiment Present impact predictability is not adequate to fully assess sitespecific variability and unique conditions The predictability of alteration impacts can be enhanced through research on ecosystem structure and function, and on wetland responses to manipulation (CONTINUED) We can no longer accept incremental destruction of these valuable ecosystems, or ignore the problem altogether. Short-term and long-term steps can be taken to reduce wetland deterioration and preserve those wetlands most threatened by development and "progress".
Maintaining the quality of our nation's wetlands is one component of overall environmental protection. Wetland conservation cannot be separated from land use. Therefore, wetland conservation must be linked to a national program of environmental protection that extends from the uplands to the sea. We can work with the cycles of nature to preserve our environmental quality or be defeated by them. The followin g sections discuss some planning strategies, policy issues, research directives and specific reconnnendations for conserving wetlands at the connnuni ty level.

Planning Strategies
The first step in conserving wetlands is to curtail the most environmentally destructive types of construction projects. "Growth management" is more than a popular planning term now. Many communities around the country recognize that 'growth and development' often brings with it reduced environmental quality. We are in an age when individual projects must be justified on their own merit in light of the social, 13 economic and environmental costs.
Connnunities and developers alike must consider alternative means of achieving desirable social goals and refrain from allowing those construction projects for which the environmental price is too high. The scarcer the wetland type (because of its biology or location), the more valuable it becomes to society as a means of preserving components of the living ecosystem for future generations. It is imperative that those projects that have the most serious environmental impacts be prohibited.
Balancing wetland conservation with appropriate development is the goal of resource planning. Some construction projects are necessary and desirable. For those projects that have been judged to be socially desirable, every effort should be made to ameliorate the impacts by requiring that the least-damaging construction methods be employed.
Consideration should be given to seasonal ecological patterns to minimize habitat modification at "critical" times. "Good housekeeping" methods should be required and monitored. Permits and contracts should specify quality control of environmental damage during all phases of the construction project. 14 Impact analysis efforts should address gaps in our technological capability to ameliorate the wetland impacts of future projects.

12.S
Wetland conservation has been accomplished largely as a result of broad pollution control standards adopted at the national and state levels. Enforcement of these standards has undoubtedly helped maintain the integrity of many aquatic systems in the United States. However, "water quality criteria" alone are not sufficient to prevent wetland deterioration and destruction. An additional set of criteria is 15 necessary to reduce problems resulting from construction activities.
Some of the problems that need to be addressed by these criteria are outlined in Table V-3.   Table V Postconstruction studies are useful not only to encourage "good housekeeping", but also as a means of assessing the accuracy of preconstruction impact prediction. The result of these studies can be used to make realistic predictions about the impacts of future projects on specific wetland types.
Some wetlands need special protection now. These are wetlands threatened because of their rarity or sensitivity to human activities, their size and location, or their desirability for incompatible uses.
Subject to the twin pressures of construction and pollution, these wetlands need to be protected from certain destruction. The establishment of wetland sanctuaries may be required if these wetlands are to survive. Wetlands that are candidates for special protection include those listed in Table V-4. Small streams, shallow ponds and marshes near urban developments (because of their small size, they are sensitive to modification and highly vulnerable to filling) Stream sections between bluffs (such areas may be the only stretches of swift water for miles and are especially amenable to damming) Certain floodplain types that are easily destroyed by levees, canals and drainage ditches Coastal marshes and swamps (especially those near expanding coastal communities) Estuaries that may be damaged directly or indirectly by development and the impacts of development upstream Remedial action is needed to restore some of our nation's degraded wetlands. Current technology provides the capablity to partially restore some wetlands and fully restore others. There is considerable room for the application of creative engineering and additional research on remedial measures. The more effort that is made to restore degraded wetlands, the more knowledge we will gain and be able to apply to future restoration efforts. At present, a number of measures can be undertaken 17 that have proven to be successful in restoring wetlands. Some of these measures are highlighted in Table V Researchers should continue to study wetland ecology, alteration impacts and mitigation methods and make their findings known. This information should serve as the basis for environmental protection and restoration policy that is technically sound and sensitive to regional and local environmental requirements. Failure to campaign for wetland conservation at the local, regional and national levels will lead to the further erosion of this important resource base and our overall environmental quality.
Public opinion influences public policy. As a nation, we are now more willing to accept the real costs of environmental protection. We can identify some important issues that need to be addressed by public policy and wetland research efforts. These policy issues and research directives are highlighted in the following sections.

12·9 Policy Issues
With increasing pressures on our nation's wetlands, the success of future conservation programs rests with improved scientific knowledge and public commitment to the long-range maintenance of environmental quality. Without such a commitment and adequate safeguards, human pressures will lead to further stress, genetic simplification, species extinction, habitat loss and ecosystem deterioration. The technology for environmental improvement is becoming more sophisticated daily.
Technological capability allows us to make choices. It is time to ask ourselves some meaningful questions about the future of our society.
Comprehensive planning begins with a clear definition of the desired future state or condition; i.e., goals to be accomplished. We must establish environmental goals and integrate these goals into our public policies. Citizens, planners, governmental representatives and technical specialists need to work together to identify the desired environmental condition, and the social and institutional framework required to monitor and maintain the environment in the desired state.
Such planning should be instituted now.
Maintaining environmental quality is an exercise in quality control. The pathway to our desired future is a narrow track balanced between society's demands, on the one hand, and ecological constraints 18 on the other.
In a political sense, maintaining environmental quality means retaining resource options for future generations. In a biological sense, it means perpetuating genetic diversity within functioning ecosystems. In an engineering sense, it is incorporating quality control into every construction project. In the absence of quality control, biology may reduce our political options. Extinct 13·0 species are non-renewable; they cannot be recycled, negotiated or compromised. We must, therefore, be concerned not only with the environmental quality balance, but also with environmental recovery.
Our environmental policies must emphasize protection of healthy ecosystems and improvement of degraded ones.
Planning for our desired environmental future requires that we change our traditional approach to the environment. We must place environmental goals above societal goals for the latter cannot be accomplished in the absence of a quality environment. The emphasis of our planning efforts must be on protecting vital ecological and genetic processes. In the past, we have based our wetland protection programs on setting water quality standards; i.e., permissible levels of environmental stress. Ultimately, wetland protection must be based on genetic and ecological requirements, not simply allowable limits of 19 ecosystem degradation.
Table V-6 summarizes these policy issues in the form of goals.
Planning efforts should focus on establishing specific goals and objectives for wetland conservation that address these issues.

POLICY GOALS
Require that "environmental impact statements" emphasize the critical biological issues and long-range ecosystem consequences Establish a nationwide system of wetland reserves in and near urban areas Establish wetland sanctuaries for rare and endangered species and habitats 7 GOALS

Research Directives
We must look to science to expand our knowledge of the requirements of the basic life support system and permissible impact levels that sustain healthy ecosystems. With this knowledge, we will be able to more accurately identify potential damage and acceptable environmental "boundary conditions" for individual construction projects.
The "environmental impact statement" (EIS) has proven to be a valuable mechanism for assessing potential environmental damange. At times, however, an EIS is more educated guesswork than scientific fact.
With refinement, the EIS can be a more accurate tool for determining project impacts. The basis for more sophisticated impact statements rests with expanding our knowledge of wetland "systems" and the ecological effects of disturbance. In other words, we need to understand more about the composition and function of wetlands and how they respond to specific types of human perturbation.
Research is needed on the ecology of wetland systems and how such concepts as "succession", "climax", "stability" and "chronic stress" relate and are affected by construction activities. Research on impact mitigation should also be a wetland conservation priority. These 13.2 studies should be conducted on a regional basis and include adequate controls. Research findings should be integrated into ecosystem analysis capability systems that can be used at different decisionmaking levels.
"Systems analysis models" are available for the simulation of many 20 physical, chemical and biological aspects of aquatic systems.
Modeling techniques are also available for treating many sociological Some wetland conservation issues for which additional research is needed are sununarized in Table V-7. Such ambitious research efforts require manpower and resources. This will require a strenthening of governmental, private and university facilities already in existence as well as the establishment of new ones. This presupposes that we have adopted a public policy that "a healthy environment is an absolute prerequisite of a healthy society". 22 Wetland response to specific types of perturbations in a regional setting with adequate controls "Impact mitigation" measures including adequate buffers Improved wetland restoration techniques Sophisticated ecosystem analysis capability systems Improved ecosystem models that include natural history details for all species in the subject environment Integrated ecological/socio-economic analysis capabilities for weighing the benefits and costs of a proposed project "Performance standards" for wetland construction projects

Local Initiatives
Strengthing efforts may involve a range of activities, and must be tailored to state requirements, the physical circumstances and preferences of the individual corrnnunity. Integrating wetland management with comprehensive planning efforts that consider the environmental, social and economic implications of land and water use is of ten the most successful way of conserving wetlands. Some examples of initiatives that a community can undertake to strengthen wetland conservation efforts at the local level are listed in Table V-8. 24 Table V Table V-10.  26 The burden should be on the developer to show compliance with the wetland policy.   carefully evaluated and efforts are made to require that development be located on upland areas. Furthermore, the requirement for larger lots tends to reduce the overall density of development so that less wetland will be disturbed. 28 Table V-11 gives an overview of wetland zoning.

Subdivision Controls
Subdivision regulations are another regulatory tool for conserving wetlands in the community setting. Subdivision regulations are usually adopted on a community-wide basis and not solely for wetland protection.
These regulations typically require that subdividers prepare detailed "plat" maps which must be approved by the local planning board prior to division of lots for sale or construction of buildings. To be approved, plats must comply with all applicable zoning and land use regulations.

t-'
""" 0 Protec t wildlif e ha bitat, scenic bea uty, a nd provide f lood sto rage, we tl a nd rec rea tion opportu niti es by contro l of g radi ng , filling, dredging, tr ee-c utting , type and density of wetland uses, buffer area uses.
2. Pro t ec t public safety and preven t nuisances by prohibiting dangerous uses (e.g., chemical factories in flood haza rd areas), unreasonable increases in flood he ights due to floodway encroachments, threats to safety by location of quasi-public uses such as motels in flash-flood areas, water pollution from location of onsite waste disposal and solid waste disposa l in wet land ar eas.
3. Promote most suitable and eco no mic use of community lands as a who le by implem enting comprehensive land use plans allocating wetland a reas to use consistent with wet land values and haza rds.
4. Reduce the c ost of public facili ti es and assist in the implement a tion of facility plans for roads, sewe r, water, schools, e tc. by preventi ng or limit ing the type and density of development in wetland a reas.
2. Delineate floodway areas and prohibit new structural uses and land alterations that will individually or cumulatively increase flood heights or velocities beyond defined levels.
3. Establish flood protection elevations and protection standards for floodway and flood fringe areas and uses.
4. In some instances, abate existing wetland uses of a nuisance nature and require flood proofing with major alteration of flood fringe uses.   ""' N Purposes 1. Pr eve nt victimization and fr a ud du e to sa le of we tland fl ood haza rd, a nd pea ty soil a reas (structur a l bea ring c apac it y a nd onsite waste disposal limitati ons) to innocent purchaser.
2. Pro t ec t floodw a y a reas from enc roac hment by roads, buildings, e tc.
3. Insure that roads, sewers, water supply, and other subdivision services are located in areas above flood elevation, or protected against flooding.
4. Implement master and comprehensive plans including public facility components.
5. Insure that subdivider installs drainage facilities which are consi st e nt with community drainage system standards.

Drafting of Regulations
Often the most expensive and tim e-c onsuming step in the adoption of legally sound and rational regulations. A variety of data may be needed to (1) identify flood-. way and flood fringe limits; (2) establish regulatory protection elevations; (3) identify vegetation types; (4) identify soils. Not all data need be gathered at once. The ultimate data used for regulation will determine the rationality of the regulation. Two approaches are often combined: ,(1) initial data gathering to identify wetland limits gathered in advance of adoption of regulation; (2) case-by-case development of more specific data when building permit applications are submitted.
Detailed and geographically comprehensive planning is not legally required prior to adoption of most wetland regulations. Nevertheless, regulations must be rational and based upon sound data.
Planning is usually the responsibility of consultant or in-house land-use planners acting under the direction of a community planning commission.
Usually the responsibility of a consultant or resident land-use planner cooperating with a city attorney, planning commission, city council, etc. Often a "boiler plate" job with use of model ordinances or ordinances from another community.
Enabling acts usually make no mention of data needs; but data are essential for sound regulations. Available data will determine whether an interim "freeze" ordinance or other regulations are adopted.
Enabling acts often require adoption of a "comprehensive plan." This requirement has hot been strictly enforced by the courts. However, some measure of community-wide planning is essential if flood plain regulations are to assist in the allocation of lands throughout a community to their most appropriate uses. Community plans are important in floodway delineation.
Enabling acts generally require preparation of both a text and map. Drafting is often accomplished by the planning commission.

.Subdivision
Enabling acts make no mention of data needs, but sound data is essential for sound regulations. Protection elevations and floodway limits are desireable prior to adoption of regulations but may be determined on a caseby-case basis.
Some enabling acts require adoption of a "master plan" prior to adoption of subdivision regulations. Requirement has not been strictly enforced. Master plans showing proposed community public works are important if the subdivider is required to install sewer, water, roads and drainage facilities consistent with overall community needs. · Usually undertaken by the planning commission cooperating with the city or county council.

Zoning
Enabling acts require at least 1 hearing with public notice prior to adoption. Zoning map which determines where particular regulations will apply is often the most controversial subject at hearing.
Enabling acts specify that adoption is responsibility of city, county, village, town, or borough council.
Building permits (if required) are generally issued by the zoning administrator or conservation com mission. Enabling acts typically authorize the issuance of variances and special exceptions by the zoning board of adjustment which conducts fact-finding activities. Special-exception and specialpermit uses are widely used in wetland ordinance.

Subdivision
Enabling acts require hea ring with public notice.
Enabling acts usually specify that adoption is the responsibility of the city, county, village, town, or borough council. However, adoption may be the responsibility of the planning commission.
Enabling acts typically establish the planning commission as the "plat review" agency. Preliminary and final plat procedures and specifications are often defined in some detail. .._. .i::.

Commentary
Enabling acts establish fines and other penalties including jail sentences for violation of regulations. Local district attorney is responsible for initiating enforcement actions, enabling acts, and injunctions to prevent breach of regulations.
Enabling acts usually establish amendment procedures in some detail.

Zoning
Enabling acts specify penalties, but are varied.
Enabling act amendment procedures are often more complicated than initial adoption, particularly where landowners protest a change .

Subdivision
Enabling acts specify penalties, I.Jut are varied.
Enabling act amendment procedures are usually identical to procedures for initial adoption. These standards can be used to protect the wetland and adjacent buffer areas from development impacts that will harm the natural functions and values of the wetland system. Performance standards accomplish this by requiring that a proposed use meets certain standards that will insure against the use causing (or having the potential to cause) adverse impacts.   A community may wish to combine performance standards with more specific standards for land uses that threaten its wetlands. Using a combined approach, wetland regulations can provide added specificity while maintaining a basic performance standard orientation. Specific performance standards for protecting freshwater wetland functions are provided in Table V- The private sector has been highly successful in conserving wetlands at the local and regional levels. Wetland conservation efforts by the private sector can be divided into four (4) categories; namely:    Table V   Community with no planning or zoning wishing to optimize the tax base but with some concern for flood damages and wildlife.
Community with little undeveloped remaining land and need for industrial, commercial or residential sites. The Golet and Larson (1974) classification system for freshwater wetlands in the glaciated Northeast is based on the principle that vegetation is the most important factor determining the type and quality of wildlife habitat.
In classifying wetland habitat, they selected the life form or growth habit of vegetation, rather than species composition, as a primary descriptor. Deep marshes represent the most valuable all-purpose wildlife habitat. They are used for mating, nesting, feeding and brood-rearing during the breeding season, and for resting and feeding during migration.
These wetlands are attractive to diving ducks, dabbling ducks and geese.
They provide valuable feeding habitat for wading birds like herons, egrets and bitterns. Stands of emergents support muskrats and nesting bird species.
(3) Shallow marsh class. Shallow marshes are wetlands dominated by robust or marsh emergents, with an average water depth of less than 6 inches during the growing season. Surface water may be present throughout the year or absent during the late summer and normally dry periods.

Floating-leaved plants and submergents are usually present in open areas.
Duckweek is often abundant in quiet water. Submergents are primarily shallow water species like coontail, bladde rwort and waterweed. Cover plants occupy more than 50 percent, and often more than 90 percent, of the mars h area. Shallow marshes constitute th e most valuable muskrat habitat.
Sea sonally flooded flats refer to extensive river flood plains where flooding to a depth of 12 inches or more occurs annually during late fall, winter and spring. In most years, spring floods subside by early June, leaving the ground exposed.
During the summer, the soil is saturated with a few inches of surface water occurring locally. Dominant vegetation is usually emergent, but shrubs and scattered trees may be present. and early spring. During the growing season, the soil is saturated and the surface is exposed, except in shallow depressions and drainage ditches.
Meadows occur most commonly on agricultural lands where periodic grazing and mowing keeps shrubs from establishing.
Wet meadows provide stopping places for migrating dabbling ducks, herons and shorebirds. In the summer, this wetland class supoorts muskrats and birds like redwings and song sparrows which feed or nest among the emergents. Wildlife value is limited also because there is seldom much shallow water in bogs. Since the edge of the bog mat is often floating, the shoreline is bordered by deep water where emergent cover plants cannot grow. The ringneck duck is one of the few waterfowl species that regularly inhabits bogs. Being a diver, it can obtain submergent food plants unavailable to dabblers. Warblers, flycatchers and other songbirds are found in the high shrub and tree zones in the bog class.
Water shrews, jumping mice and muskrats are often present but other species are limited since food is scarse and cover is unsuitable.
~-1-18. DECLARATION OF INTENT.-Wherea!.i ; recognized that swamps, marshes and other fresh er wetlands as herein defined act as · buffer zones :i.bsorption areas for fiood waters, and Thercas, ail flood plains for all rivers, streams and ~r water courses are certain to be overflowed with er periodically in spite of all reasonable efforts to vent such occurrences, and iThereas, flood waters overfiowing into marshes, .mps and other fresh water wetlands are not only ased more slowly downstream thus reducing the iage they may cause, but such flood waters tend to absorbed into the ground water supply through .mps, marshes, a.nd other fresh water wetlands thus her reducing the fiood hazard and recharging the 1 ground water resource, and hereas swamps, marshes, and other fresh water ands are among the most valuable of all wildlife itats and are high value recreational areas as well, wildlife and recreation are widely recognized as tial to the health, welfare, and general well befng he general populace, and /hereas swamps, marshes, and other fresh water ands are increasingly threatened by random and uently undesirable projects for drainage, excav.a. , filling, encroachnient or other form of disturbor destruction and are currently inadequately pro ed from such random and undesirable projects, and hereas, the protection of swamps, marshes, and r fresh_ water wetlands from random, unneces. ,, and/or undesirable drainage, excavation, filling, oachment, or any other form of disturbance or dection is recognized as being in the best public inst ar;_d essential to the health, welfare, .and general being of the general populace and essential to protection of property and life during times of or other disaster affecting water levels or water ly, the ref ore, the provisions of the following sec. S are intended to preserve and regulate the use uch swamps, marshlands and wetlands.
-1-19. PUBLIC POLICY ON SW AMPS, MARSH-AND FRESH WATER WETLANDS.-It is the lie policy of the State of Rhode Island and Provie Plantations to preserve the purity and integrity he swamps, marshes, and other fresh water wets of this state. The health, welfare, and general being of the populace and the protection of life property require that the state restrict the uses of ands and, therefore, in the exercise of the police er such wetl.ands are to be regulated hereunder.
The term 'Director' as used in this chapter shall r.e. fer to the director of the department of natural resources, The term 'Flood plain' as used in this chapter shall be that land area adjacent to a river or !.itream or other body of flowing water which is, on the average, likely to be covered with flood waters once every 50 years.
The term 'Fresh water wetlands' as used in this chapter shall include, but not be limited to, marshes; swamps; bogs; rivers; river and stream flood plains and banks; areas subject to flooding or storm fiowage; areas where ground water, flowing or standing surface water or ice provide a significant part of the supporting substrate for a plant community for a significant pa.rt of the year; emergent and submergent plant communities in water bodies; and that portion of any bank which touches any inland waters.
The term 'Swamp' as used in this chapter shall be place not less than 3 acres in extent where ground ater shall be near or at the surface of the ground for significant part of the growing season or runoff ater from surface drainage shall collect frequently nd/or where a vegetational community shall be made p of a significant portion of one or more of, but not imited to nor necessarily including all of, the followng: red maple (Acer rubrum), elm (Ulmus ameri-:ana), black spruce (Picea mariana), white cedar chama.ecyparis thyoides), ashes (Fraxinus), poison umac (Rhus vernix), larch (Larix laricina), spicesh (Lindera benzoin), alders (Alnus), skunk cabge (Symplocarpus foetidus), hellebore (Veratrum iride), hemlock (Thuja canadensis), sphagnums sphagnum), azaleas (Rhododendron), black alder nex verticillata), white alder (Clethra alnifolia), arsh marigold (Caltha palustris), blueberries (Vacinium), button bush ( Cephalanthus occidentalis), wilow (Salicaceae), water willow (Decodon verticillaus), tupelo (Nyssa sylvatica), laurels (Kalmia). "2-1-21. APPROVAL OF DIRECTOR.-No person, .rm, industry, company, corporation, city, town, muniipal or state agency, fire district, club, non-profit gency, or other individual or group, may excavate; ra.in; fill; place trash, garbage, sewage, highway runff, drainage ditch effiuents, earth, rock, bo1Tow, gravl, sand, clay, peat, or other materials or effluents .pon; divert -water .flows into ;or out of; dike; dam, . ivert; change; add to or take from or otherwise alter b.e character of any fresh water wetland as herein dened without first obtaining the approval of the dictor of the department of natural resources. Such pproval will · be denied if in the opinion of the director ranting of such approval would not be in the best ublic interest. Such approval shall not be granted nless ·the city council of a city or the town council f a town within whose borders the project lies shall so approve. Appeal from such denial may be made > the superior court.
"2-1-22. PROCEDURE FOR APPROVAL BY DI-ECTOR.-Application for approval of such a project • the director of natur al resources shall be ma.de in a form to be prescribed by the director and provided by the director upon request. Upon receipt of the completed application accompanied by plans and drawings of the proposed project, such plans and drawings to be prepared by a certified registered engineer to J. scale of not less than one inch to one hundred feet, the director will notify all land owners whose properties abut tho area of the proposed project and he will also notify the town council, the conservation commission, the planning board, the zoning board, and any other tndividual5 and agencies in any towns within whose borders the project lies who may have reason in the opinion of the director to be concerned with th~ proposal. The director may also establish a mailing list of' alt interested persons and agencies who may wish to be notified of all such applications. If the director receives any objection to the project within 45 days of the mailing of the notice of application from his office, such objection to be in writing, the director shall then schedule a public hearing in an appropriate place as convenient as reasonably possible to the site of the proposed project. He shall inform by registered mail all objectors of the date, time, place, and subject of the hearing to be held. He shall further publish notice of the time, place, date, and subject of the hearing in one local Rhode Island newspaper circulated in the area of the project and one statewide Rhode Island newspaper, such notices to appear once per week for at least three consecutive weeks prior to the week during which the hearing is scheduled. The director shall establish a reasonable fee to cover the costs of the above investigations, notifications and publications, and hearing and the applicant shall be liable for such fee.
If no public hearing is required, or following a public hearing, the director shall make his decision en the application and shall notify the applicant by registered mail of this decision within a period of 6 weeks. If a public hearing was held, any persons who objected to the project in writing during the 45 day period provided for such objections shall be notified of the director's decision by first class mail.
In the event of a decision in favor of granting an application the director shall issue a permit for the applicant to proceed with the project. Sucl: permits shall be valid for a period of one year from the date of issue and shall expire at the end of that time unless renewed. An extension of the identical original permit may be granted upon written request to ;;he director by the original permit holder or his legal agent at least 90 days prior to the expiration date of the original permit. The director may require new he arin gs if, in his judgment, the original intent of the permit is red or extended by the renewal or if the ii.pplicant failed to abide by the terms of the original permit ny way. The request for renewal of a permit shall ow the same form and procedure as the original lication except that the director shall Lave the. on of not holding a. hearing if . the original intent he permit is not altered or extended in any signifit way.
-1-23. VIOLATIONS.-In the event of a. violaof section 2-1-21 of the general laws, the director natural resources shall have the power to order plete restoration of the fresh water w~tland are~ olved by the person or a.gent responsible · for the lation. If such responsible person or a.gent does complete such restoration within a. reasonable . time owing the order of the director of the depa.rtment atural· resources, the director shall have the a.uity to. order the work done by an agent of his Osing a.nd the person or agent resp-0nsible for the inal violation shall be held liable for the cost of the re3toration. Such viola.tor shall be liable for a fine of up to $1,000. for each such violation.

Appendix D POTENTIAL ENVIRONMENTAL IMPACTS OF HYDROELECTRIC POWER PROJECTS
Hydropower development projects may be major, or minor, multi-purpose, conventional "run of river", or pumped storage, and they may involve almost any kind of environmental impact. Every aquatic system consists of a vast array of physical and biological elements which interact in subtle and often unrecognized ways.
Each type of hydro development activity is attended by an identifiable set of physical and chemical alterations in the aquatic environment which may extend for many miles from the site and may persist for many years. In turn, each type of physical and chemical modification has been shown to induce a derived set of biological effects, many of which are predictable in general if not specific detail.
The most significant environmentally damaging effect of hydro development activities are direct habitat loss, addition of suspended solids and modification of water levels and flow regimes.
Major construction related impacts also derive from altered water temperatures, pH, nutrient levels, and certain pollutants such as heavy metals present in discharges or in dredged materials.
In order to provide the basis for rational environmental management, it is necessary to identify the potentially destructive activities and to analyze their specific effects upon the natural environments and the native biological corrmunities of river ecosystems.
Carmonly Observed Impacts: A hydroelectric dam and reservoir may have the same range of impacts as any other dam and reservoir. Important wildlife habitat may be flooded; passage up and downstream for highly valued migratory fish may be blocked and their habitat inundated, etc. A long, deep reservoir behind a high dam on an important anadromous fish-spawning stream presents the ultimate challenge to fisheries conservation measures in the need for and design of fish passage and propagation facilities.
A similar dam flooding a broad or extensive valley serving as critical winter range for migratory birds and marrmals is similarly an ultimate challenge to wildlife resources conservation measures with a need for the development of habitat replacement and other mitigation measures.
Overall impacts of these kinds vary in size and significance according to the specific situation.

Alteration of Streamflows:
Diversion and regulation of streamflow will cause other adverse impacts which can only be mitigated by dedication of minimum flow releases to the stream below the dam, re-regulation or other control of peaking flows, scheduling flows to meet critical fish maintenance or fish harvest needs, installation and proper operation of multi-level outlets for temperature and other water quality maintenance, etc. In some of the older hydroelectric projects wi th deep-water release structures , low dissolved ox ygen problems may be encountered with release of oxygen-deficient, hypol imnial waters. This, in turn, reduces the streams' capacity to handle organic pollutants.

Reservoir Pool Level Fluctuations:
As with other reservoir projects, reservoir pool level fluctuations and drawdown may be of concern in relation to biomass production, fish spawning, turbidity control, and recreational use. Usually the maintenance of a minimum fish conservation pool is not a problem because power production requires maintenance of that pool in order to operate efficiently.

Sediment and Turbidity:
Environmental protection measures must be taken during the construction phase to prevent undue sediment and turbidity in the stream through run-off from disturbed lands, and to prevent unnecessary destruction of scenic, natural, historic, and other cultural values.

Obstructions to Migration of Wildlife:
On some constructed projects, open conduits may present problems to migratory animals especially where the flow is rapid and deep.
Deer and other animals may be lost in important number if provisions are not made for excluding them or providing escape devices for them. Suitable engineering measures should be taken to prevent interruption of migration routes.
Transmission line rights-of-way may adversely affect fauna. Direct removal of habitat, blockage of normal daily or migratory routes, creation of corridors along which some species may move and extend their range, and by creation of new habitat resulting in change in species composition of the local fauna are some possible effects of creation of a new right-of-way. Additional impacts such as bird electrocution and bird collision with the structures may occur.

Recreational Facilities:
Public use of reservoirs for recreational purposes may adversely affect terrestrial habitat in areas inmediately adjacent to campgrounds, roadways, and other public access areas. Habitat may be removed or altered for public use facilities; increased use of the area by people may alter use of that habitat by some vertebrate species.
Beneficial impacts may also result from the creation of fishing and other recreational facilities on the reservoir as well as creation of desirable wildlife habitat along transmission line or conduit rights-of-way.

RESOURCE SYSTEM OR ATIRIBUTE AFFECTED Aquatic Biota
Appendix D (continued) POTENTIAL HYDROPCMER DEVELOPMENT IMPAC1'S1 IMPACT CAUSED BY: 1. Changes in downstream and/or r eservoir water quality due to: a. b. c. d.
temporary pollution from construction activities pollution associated with operation and maintenance gas supersaturation below dam flooding of land, causin~ leaching, organic matter decay, and toxin releases higher temperatures and less Oz in still waters* silt trapping in reservoir, causing higher nutrient levels in reservoir, lower turbidity and nutrient levels downstream* reservoir stratification* power plant intakes in reservoir hypolimnion, or at level of particular activity changed season thermal re~ime--slow to warm in spring, slow to cool in fall.
2. Changes in downstream flows with consequent effects on spawning, migration, and other behavior patterns due to: a. increased evapo-transpiration from reservoir* b. reservoir filling* c. increased loss to ground water accretion from . * reservoir d. flow management for power production.
* Denotes those impacts that occur only whe n a new dam i s constructed or the he i ght of an old dam is increased.