EPA and the Corps have just published a proposed Compensatory Mitigation Rule in the Federal Register today (28 March 2006). There will be a 60-day comment period. The rule, a fact sheet and a Q & A sheet are available at
www.epa.gov/wetlandsmitigation/

Unfortunately the proposed mitigation rule is rife with administrative and philosophical positions, but bereft on suggestions for constructing or restoring quality wetlands. What we need to know is how to deal with water, plant and soil issues. What we get is platatudes regarding watershed context. Frankly how the **** can we not work in a watershed context. We get statements about mitigation banks and how they are more desireable than individual mitigation projects, but again what we should do to make them work ecologically is substantially missing. Maybe the problem with the rulemaking is the same problem as with the underlying National Research Council tome.

I am going to recommend to those few of us who will respond to this forum that we write our opinionns, good, bad, and ugly, and then we send our comments to appear on the public record.

I will start by asserting that the state of the art and therefore the rulemaking should assert that we define all proposed mitigation from a hydrologic, geologic, and morphologic context, and that we use this basis to quntitatively discuss the depth duration and timing of water over tme (produce a hydrograph).