Moving in Texas A Case Study in Cooperation. Keeping Wind Turbines. Inside The Wire

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1 News from SWCA Environmental Consultants Volume 12, No. 2, Summer 2012 Keeping Wind Turbines Moving in Texas A Case Study in Cooperation By Dustin Jones Does it surprise you that Texas has the country s largest installed wind power capacity more than 10 gigawatts? How did a state with deep roots in fossil fuel energy that supplies one-fifth of the nation s oil production, one-third of the nation s natural gas production, and a quarter of the nation s refining capacity become the Saudi Arabia of Wind? The road to becoming such a renewable energy powerhouse has had some Texas-sized twists and turns along the way. It started with an innovative and forward-thinking Texas Legislature, Public Utility Commission of Texas (PUC), and the Electric Reliability Council of Texas (ERCOT) the state s electric grid operator. In 1999, Texas had less than 200 megawatts of installed wind capacity. Despite wind assessment models ranking the state second nationally in potential capacity, there were no incentives for developers to harvest this valuable resource. Thus, the Texas Legislature enacted the pioneering Senate Bill 7 to restructure the state s electric industry and develop one of the nation s first Renewable Portfolio Standards mandating that electricity providers collectively generate 2,000 megawatts of additional renewable energy by This created the crucial Renewable Energy Credit program that made renewable energy production, especially wind energy, economically attractive. Under the program, utilities could sell, trade, or barter credits for megawatt-hours produced by renewable energy facilities for the values and benefits added above conventional power sources such as coal and natural gas. See Texas Power on page 4 Inside Cool Stuff Happening with GIS Final Wind Energy Guidelines Released Spotlight on Wind Energy Development & Construction Services A Market-Driven Solution to Preserving Wetlands

2 Vol. 12, No. 2 Final Wind Energy Guidelines Released: Where Do We Go From Here? Last year, in the article Tensions Mount Over New Wind Energy and Wildlife Conservation Guidelines from, we described the concerns of conservationists and developers about the U.S. Fish and Wildlife Service s efforts to revise their 2003 interim draft wind power guidelines. At the time it was not easy to find anyone who thought the draft guidelines were good for either wildlife or the wind industry. Most conservation groups insisted that the voluntary draft guidelines were insufficient to prevent significant impacts to wildlife, especially winged creatures like raptors, migratory birds, and bats. On the other side of the fence, the businesspeople building and operating wind farms were convinced that the industry was being unfairly singled out. They believed that it would only be a matter of time before the guidelines changed from voluntary to required, and the high cost of implementing the guidelines would simply shut down potential projects. In March 2012, the Service released the long-awaited Final Land- Based Wind Energy Guidelines. These final guidelines are intended to provide a structured, scientific process for addressing wildlife conservation concerns at all stages of land-based wind energy development. The final guidance demonstrates a shift away from the prescriptive philosophy of the 2003 guidance, toward a more flexible descriptive approach. The guidance is the culmination of a decade-long push by the Service to address concerns over wind turbine impacts to wildlife. The final guidelines ( resulted from a collaborative effort between the Service and numerous conservation organizations and industry stakeholders, including the National Audubon Society, Defenders of Wildlife, American Wind Energy Association (AWEA), consultants, attorneys, and other interested parties. The result still finds many wind-watchers split over the efficacy of the conservation measures and the financial burden these guidelines may place on wind energy developers. But at least now there is a path forward for wind energy developers and their supporters. A Summary of the Final Guidelines The guidelines are structured in five tiers, following the sequential order in which a typical project might evolve (i.e., landscape-level evaluation, project siting, pre- and post-construction surveys, and as-needed follow-up studies). At each tier there is a series of questions that By Steve Carothers and Melanie Gregory require detailed answers, as well as accompanying decision points. The Service intends this structure to encourage adaptive management and course correction (read: modify or abandon a project) throughout the process. Questions may be answered by mining publicly available information or desktop surveys, or, as is usually the case, they may require field studies such as habitat assessments, presence-absence surveys, and/or mortality monitoring. The process provides ample opportunities for developers and their consultants to negotiate projectspecific solutions to potential conflicts. Throughout the document the Service emphasizes frequent communication between developers and agencies. The Service indicates that their resource staff will usually respond to requests for assistance or information within 60 days. The guidelines also provide some flexibility. When necessary, developers and their consultants who believe their projects are relatively non-impacting are free to proceed through the construction stage without Service input. Compliance with the voluntary guidelines does not absolve developers of obligations under the various state and federal laws protecting wildlife, primarily the Migratory Bird Treaty Act (MBTA), the Bald and Golden Eagle Protection Act (BGEPA), and the Endangered Species Act (ESA). If it becomes apparent during the course of answering the questions posed by each tier of guidance that a project may impact, for example, bald or golden eagles or the Indiana bat, the developer may elect to seek take permits for those species through provisions of the BGEPA and ESA, respectively. A Tool for Risk Management So far the guidelines remain voluntary. Still, many state and local power siting boards solicit Service input on applications, suggesting that the siting boards will be the teeth behind the guidelines. At complex or high-risk project sites, the guidelines potentially represent a sizeable data-gathering and decision-making exercise. They require consideration of all species of concern, defined in the document to include federally listed species, federal candidates for listing, state-listed species, bald and golden eagles, the thousand-plus bird species covered by the MBTA, and any species that is determined to be possibly affected by the project. See Guidelines on Page 7 2

3 Summer 2012 Banking on the Future: A Market-Driven Solution to Preserving Wetlands By Matt Stahman, Catherine Mayhew and Megan Philips-Schaap Section 404 of the Clean Water Act requires a permit from the U.S. Army Corps of Engineers before dredged or fill material may be discharged into waters of the United States, including wetlands, as a result of development activities. This applies to both private and public projects anywhere in the country. Getting a permit from the Corps can be tricky because of the need to mitigate any impacts to those waters and wetlands. Mitigation under Section 404 requires replacement of lost aquatic functions and values as a result of development activity. That typically means compensating for a wetland impact with a created, restored, and/or preserved wetland somewhere else. This is no small endeavor and is best left to those who have a vested interest in the ultimate, long-term success of the mitigation project. Enter the Mitigation Banker Mitigation banking involves the replacement of wetlands in advance of Corps-permitted wetland impacts. The way it works is that an agency, company or individual enters into an agreement (referred to as the banking instrument ) with the Corps to complete a wetland mitigation project. That agency, company or individual the mitigation banker in turn receives ecological credits from the Corps that can then be used to offset future Corps-permitted wetland impacts. The mitigation banker may sell those credits to permittees who need them to offset their impacts. The price is dictated by supply and demand and can range from a few thousand to several hundred thousand dollars per credit. In addition to wetland acreage, the quality and ecological value of the mitigation project also help determine the number of credits assigned by the Corps. Investing in a Family Business SWCA s Houston office was approached by local landowner Suzanne Jamison, managing partner of Gin City Land Company, a familyowned business with interests in real estate and agriculture. Upon learning about mitigation banking, Jamison thought her property would be a good candidate. She had a vision of investing in her family s future while helping preserve their ties to the family land, which had been farmed for several generations. She came to the right place. SWCA staff in Houston have helped several clients establish mitigation banks and understand the mitigation banking process to compensate for losses of aquatic resources. Matt Stahman/SWCA Megan Philips-Schaap/SWCA The goal is a transformation of this agricultural field......into mature bottomland hardwood wetland forest like this one, a few decades from now. Preserving wetlands also restores habitat for wildlife like the great blue heron. The process is quite involved and not to be entered into lightly. It is very technical, requires a great deal of interaction with resource agency personnel, and takes a year or more to complete. However, a knowledgeable consultant can make the task easier, and the rewards can be significant. A Rewarding Possibility Monetarily, those rewards require being in the right place at the right time. Mitigation banks have limited service areas within which they can sell their credits for impacts. These service areas are typically confined to discrete watersheds commonly delineated by U.S. Geological Survey hydrologic unit codes (HUCs). If a bank falls into the right HUC, say, in an area under significant development pressure that generates a need for wetland mitigation credits, and that bank is the only one in that HUC with credits for sale, then conditions can be ripe for a significant return on investment. Still, it can be risky business, but there are other benefits to mitigation banking besides financial gain. Those benefits may include reduced property taxes, as the Corps requires the property be restricted from any other use in perpetuity. Also, the intrinsic value of the land as open space, to be enjoyed by See Mitigation Banking on back page 3

4 Vol. 12, No. 2 Summer 2012 Texas Power from cover The Renewable Energy Credit program along with a federal Production Tax Credit program worked so well that in 2001 ERCOT had to curtail wind farms or its grid would overload. Curtailment in wind energy production meant shutting down turbines or entire wind farms, which in turn meant that wind farm owners could no longer earn money from the credits. When ERCOT compensated wind farm owners for their losses due to curtailment, wind project development was re-energized but transmission congestion remained. Another Bump in the Road Texas looked to solve transmission congestion in 2003 with House Bill 2548, which granted the PUC additional authority on transmission The CREZ process will move wind power energy from areas of abundant supply in West Texas and the Panhandle to areas of heavy demand in major metropolitan areas. construction, but it was not enough to prevent deadlock. Utilities needed power generating guarantees in order to build the necessary transmission lines, yet wind developers would not guarantee projects without adequate transmission lines in place. Wind energy development stalled once again. Even so, in 2005 Texas outpaced the goal of 2,000 megawatts, predominately with wind energy, and knew there was capacity for much more. So the issue of congestion was revisited during a special legislative session assembled to solve a school financing issue. Wind power development was eyed as a way to fund education if deadlock between wind developers and utilities could be resolved. The resolution was the landmark Senate Bill 20 that created the $7 billion Competitive Renewable Energy Zone (CREZ) process, the Public Utility Commission of Texas first of its kind in the nation at such a scale. The CREZ process gave the PUC the necessary authority to: Identify the geographic areas with the best conditions to develop wind power generation facilities. The PUC defined five zones throughout north and West Texas (see graphic at left). Designate transmission service providers to develop a network of new and upgraded transmission projects to move electricity from areas of abundant supply (primarily remote parts of West Texas and the Panhandle) to areas of heavy demand (Austin, Dallas-Fort Worth, and San Antonio). The transmission network will total 2,400 miles of new and 1,200 miles of upgraded transmission lines and more than 70 connection points. Ten transmission service providers were selected with a goal to have all transmission lines constructed by the end of Enhance the underlying stability of the state s electric grid and increase Texas s wind generation capacity to more than 18 gigawatts. More Potential Roadblocks The CREZ process, however, requires compliance with a host of federal, state, and local agency laws, among them the National Environmental Policy Act, Endangered Species Act, Bald and Golden Eagle Protection Act, Migratory Bird Treaty Act, Clean Water Act, Texas Pollutant Discharge Elimination System, National Historic Preservation Act, Antiquities Code of Texas, and PUC Substantive Rules. Two of the 10 transmission service providers the Lower Colorado River Authority Transmission Services Corporation (LCRA) and Cross Texas Transmission (CTT) hired SWCA to help them comply with those regulations. LCRA LCRA is a conservation and reclamation district that owns and operates a network of facilities totaling more than 4,400 miles of transmission lines and 330 substations. SWCA is working on two of LCRA s CREZ transmission lines the Twin Buttes to Big Hill line and the Big Hill to Kendall line that total 178 miles and span seven central Texas counties. Here, SWCA is helping LCRA acquire an incidental take permit under the Endangered Species Act for two endangered songbirds the golden-cheeked warbler and black-capped vireo that occur widely across the region where the CREZ projects are taking place. During this process, SWCA helped develop requisite habitat conservation plans, environmental assessments, and avoidance and minimization measures. CTT CTT is part of LS Power Group, a private power generation and transmission firm with a national presence. SWCA is providing consulting services for six CREZ transmission projects that total 240 miles and span seven counties in the Panhandle. They include the Silverton to Tesla line, Gray to Tesla line, Gray to White Deer line, Silverton to Tesla Compensation, Gray Reactive Compensation, and Gray Substation. SWCA has provided multiple environmental services to CTT, including desktop assessments and support for Clean Water Act, Endangered Species Act, and PUC compliance; agency coordination and permitting; floodplain analyses; and Stormwater Pollution Prevention Plans. A dedicated, full-time environmental monitor is also present on-site through project completion. Project staff have surveyed and mapped aquatic and cultural resources as well as developed stormwater best management practices. Our endangered species experts have conducted habitat assessments and/or presence-absence surveys related to the lesser prairie-chicken, interior least tern, piping plover, Sprague s pipit, whooping crane, Texas kangaroo rat, Palo Duro mouse, and Texas horned lizard. These assessments continue throughout Challenges at the Project Level Transmission service providers have faced many challenges since being designated by the PUC, including the Certificate of Convenience and Necessity application and approval process, public review and comment, land acquisition, engineering and surveying, regulatory constraints and permits, material procurement, and construction logistics. For example, the Certificate of Convenience and Necessity process requires transmission service providers to supply a thorough review of a project s purpose and need, specific attributes, practicable alternative routes (including designation of a preferred route), and an assessment of how the project could affect the surrounding community and environment. The PUC s consideration of the application typically takes about one year, and Texas law requires an evaluation of the capability of existing services compared to the project, the need for additional service, the effect on any electric utility serving the area, community values, recreational and park areas, historical and aesthetic values, environmental integrity, and more. Despite complications along the way, these transmission projects have been moving forward thanks to a Texas-sized determination to make alternative energy work. Trailblazing Texas Deadlock on transmission problems is not unique to Texas. But while other states were still talking about resolution, Texas was doing it. And it has been a windfall, so to speak, for the state. It is advancing clean, renewable energy while providing economic, environmental, and human-health benefits (jobs, reduced dependence on fossil fuels, and school funding). The impact of renewable energy on Texas has also in turn strengthened the electric grid and reduced electricity rates. Because of the success of CREZ, the Texas model is spreading across the nation. It can be seen in California s Renewable Energy Transmission Initiative, the West Coast s Western Renewable Energy Zones, Minnesota s CapX2020 Project, and Colorado s Western Renewable Energy Zones initiative. Most importantly, the Texas CREZ process is more than just an example of ideal cooperation between governments, regulators, utilities, and industries. It is proof that projects of this scale are possible in years, not decades. For more information about the CREZ project or transmission services, contact Dustin Jones at [email protected]. BONUS MATERIALS The Texas horned lizard is a state special status species found in the area. Paul Sunby/SWCA Helicopter surveys were used to identify habitat for the lesser prairiechicken, a federal candidate for listing as an endangered species. Paul Sunby/SWCA 3D modeling viewshed analyses were prepared to estimate the visual impact that CREZ transmission lines would have on the landscape. Julie McGilvray/SWCA Several endangered species such as the golden-cheeked warbler inhabit the proposed transmission routes. Clint King/SWCA To see more images from our work on the CREZ project, scan the QR code above or visit You will need a QR code reader application on your smartphone to view the video. 4 5

5 Vol. 12, No. 2 Spotlight on Wind Energy Development & Construction Services SWCA has seen an increasing need for environmental consulting services related to development and construction in recent years, especially in the wind energy industry. Wire editor Christiana Ferris sat down to talk about environmental compliance during the wind energy project development and construction process with Jim Jones, a senior consultant and natural resources program director in SWCA s Austin office and the company s national power generation business line leader. : Why is an environmental consultant essential to wind construction projects? Jones: A quality environmental consultant can help the wind developer, project manager, construction manager, and operations manager reduce project risks and delays due to anything from site selection to constructability issues and regulatory compliance. : What laws and regulations come into play? Jones: Numerous federal, state and local regulations affect project risk from site selection through operation of the facility. But perhaps the top environmental regulatory statute in the western United States determining whether a wind energy project gets developed is the Bald and Golden Eagle Protection Act. Addressing eagle issues very early during constraints analyses and preliminary site screening will help the client avoid spending too much money on preconstruction studies and project development until site-specific eagle use data are obtained. : Let s talk about when and how an environmental consultant is most useful during the different phases of wind energy development and start with site selection. Jones: The first thing we can help with is reviewing the wind prospect the potential area to be leased for a wind project. This review provides quick and relatively inexpensive high-level constraints evaluations for regulatory and resource issues. We can help a client avoid spending too much time and money on a prospect with too many environmental or cultural resource issues. Conversely, we can sometimes show that a prospect everyone assumes is too constrained can actually be permitted within a reasonable time and budget. At an initial site visit we can verify the potential constraints identified on the desktop and suggest cost effective ways to deal with those constraints. Fatal flaw evaluations, critical issues analyses, and site suitability assessments (per the U.S. Fish and Wildlife Service) can further establish the economic viability of the project. : What s next? Jones: During the initial development stage, scientific studies along with local knowledge and specialized expertise are key. At SWCA we use rigorous science to design and execute valid and cost-effective environmental studies and assessments. We specialize in studies of avian and bat use, as well as aquatic and cultural resources. Visual simulations, jurisdictional waters delineations, constructability reviews, and public outreach strategies are other services we commonly provide during this stage. And sometimes additional specific resource management plans must be put in place before permits will be issued. We ve designed Hazardous Materials Management Plans, Spill Prevention Control and Countermeasure Plans, Stormwater Pollution Prevention Plans, Environmental Compliance Management Plans, and Waste Management Plans, just to name a few. : Where does it go from there? Jones: The next phase is permitting. An effective environmental consultant will have strong wildlife agency relationships and can assist with agency coordination. Our close relationships with regulatory agencies and in-depth knowledge of the regulatory process allow us to prepare regulatory strategies that minimize the time needed to obtain project permits. While we typically focus on federal and state permits, we can be equally as effective with the local ones, and our geographically diverse offices provide that important local expertise. During final development, we also can provide worker environmental awareness programs and training. : So the permits are issued and construction begins. Is that the end of the story? Jones: No. In fact, this is the point where some projects go awry. Securing the necessary permits is only half the process; staying in compliance during construction is the other. Once construction has begun, an environmental consultant can provide regulatory guidance and work with the client to manage and resolve compliance issues. We provide environmental monitoring and reporting on a variety of natural and cultural resources. We also have had staff in the field during construction to answer questions and provide guidance for on-the-fly design changes, field-staking, and workarounds. And we can implement wetland mitigation efforts, conduct archaeological and paleontological artifact recovery, and train crew members on environmental awareness without taking them off the job site. Some clients have brought us in for salvage and relocation of sensitive species. The goal is to make sure that construction activities stay on track and within budget while at the same time meeting environmental permitting requirements. 6 Continued on next page

6 Summer 2012 Development Services from previous page : What about after the project has been built? Jones: In some cases environmental compliance issues remain after a project becomes operational, requiring ongoing monitoring and reporting (such as monitoring of mitigation activities), environmental audits, or damage assessments. Some clients bring us in for reclamation and restoration work, creating compensatory wetland mitigation plans, or developing so-called adaptive environmental management strategies. Adaptive management is especially relevant for wind projects to meet requirements under the Endangered Species Act, Migratory Bird Treaty Act, and Bald and Golden Eagle Protection Act because uncertainties exist for any given management plan. Having the flexibility to change the plan if necessary yields the best environmental results. And at least one year of post-construction avian and bat fatality studies is recommended per the U.S. Fish and Wildlife Service s Final Land-Based Wind Energy Guidelines released in March : Are there differences in permitting requirements whether a project is on public or private land? Jones: The types of permits necessary do not vary significantly on private versus public lands. The biggest difference is the extent of studies that are required. On private land, natural and cultural resource surveys do not have to be conducted on 100% of the property and federal and state permitting can sometimes be avoided or greatly reduced through creative facility design. The Endangered Species Act and Migratory Bird Treaty Act both still apply on private land, but the client has the option of doing as much or as little investigation and documentation as they are comfortable with. Also, National Environmental Policy Act documentation is generally not required on private land unless a permit is necessary under the Clean Air Act, Clean Water Act Section 404, etc. : What sets us apart from other environmental consulting firms? Jones: The biggest thing that sets us apart is that when we identify constraints, we don t just point out the problem. We offer solutions and alternatives that often are informed by our heavy emphasis on science and our 30-year working knowledge of project design and construction. Many consulting firms have environmental practitioners on staff who simply read the regulations and follow the rules as they understand them. At SWCA, we understand the science behind the rules and can help our clients meet the intent of the regulations through a variety of methods at every stage of the construction process. : Give me an example of a time when we went beyond just pointing out the constraints. Jones: We were recently involved with a proposed wind farm expansion that was on a very fast track during the micro-siting stage. The client needed to lay out the wind farm to avoid all wetlands. After delineating the wetlands within the project area, SWCA wetland scientists accompanied the client s electrical engineer and his team to the site to help route the project around those wetlands. The entire layout of the facility was completed over a three-day period with on-the-fly modifications by our team. The client was impressed that our work didn t end with handing them a map of the constraints but rather included helping them site around those constraints in the field. The client told us, This was phenomenal. I never have had a consultant work with us like this before. Guidelines from page 2 With pre- and post-construction surveys potentially stretching over multiple years, compliance at a high-risk site could pose a challenge for project budgets and schedules. However, coordination with the Service and early siting decisions can pare down the number of species of concern carried through each tier of analysis. Developers who make an honest effort at compliance and document their data-gathering and decision-making processes significantly minimize their risk. While developers who follow the guidelines are offered no specific legal protection for violations, such violations will not be a priority for our law enforcement efforts according to Service Director Daniel Ashe. By following the guidelines, a developer also can demonstrate to lenders and project backers that the threat of a shutdown during construction or operation is minimized. However, if an endangered species is taken without a permit, developers are still open to citizen lawsuits via the ESA, and as always, an unpermitted take of an eagle or a federally listed species constitutes a violation of the ESA and the BGEPA. Can Projects Still Move Ahead? We are seeing a number of projects moving forward and on schedule. One wind project in central Oregon, currently in compliance with the guidelines, is also in the process of receiving the first golden eagle take permit through the BGEPA, even though the Draft Environmental Assessment for the permit reveals some onerous mitigation requirements for the take of 1-2 golden eagles. It has been estimated that eagle conservation and mitigation costs will be as high as $700,000 to $1,000,000 for the first five years of operation for the 104-megawatt project. For this reason AWEA is concerned that the Service is requiring mitigation that is not commensurate with the long-term impacts to eagle populations. Anti-wind groups disagree with allowing any mortality and the environmental community remains split, with many calling for more stringent rules (as opposed to voluntary guidelines) and a formal permitting process. The Service has stated that they chose to keep the guidelines voluntary because any process leading to a Serviceissued permit constitutes a federal action subject to review under the National Environmental Policy Act, adding another layer of public involvement, data collection and analysis, and a statutory timeline. However, the Service is assisting wind industry applicants and granting permits as needed. In fact, they recently published a proposed rule to extend the maximum permit duration for eagle incidental take permits from five to 30 years, specifically to facilitate renewable energy development. This action clearly demonstrates their willingness to accommodate the needs of wind energy developers. SWCA is helping several clients with projects in all tiers of the development process, from finding low-impact sites, to working with agencies in developing mitigation and minimization measures, and monitoring construction and post-construction impacts. Our experience indicates that even when species of concern are likely to occur on or near a site, mindful and informed micrositing of turbines and transmission lines can reduce the probability of impacts so that a project may be able to move forward without a formal permit. Sound science and creative solutions are often required, but with proper analysis, coordination with the Service, and a liberal dose of entrepreneurial fortitude, projects can and will move forward, some with take permits, and some without. For more information on wind energy development services, contact Jim Jones at [email protected]. For more information on the USFWS Wind Energy Guidelines, contact Melanie Gregory at [email protected]. 7

7 Sound Science. Creative Solutions. is published by SWCA, Incorporated. POSTMASTER: Send address changes to SWCA Environmental Consultants, 3033 North Central Ave., Suite 145, Phoenix, AZ To be added to our mailing list, or for editorial comments or questions, call ; us at com; or write to SWCA Environmental Consultants, 3033 North Central Ave., Suite 145, Phoenix, AZ Please visit us on the web at STEVEN W. CAROTHERS...Founder JOHN THOMAS...President CHRISTIANA FERRIS...Editor / Contributing Writer MICHELLE WEIGMAN...Graphic Designer / Illustrator Visit Us On Mitigation Banking from page 3 future generations, can provide a substantial rationale for the project. In the case of Gin City, that was one of the primary reasons for the project. Jamison s family felt it was important to set aside a portion of their land as an ecological preserve. Being the daughter of a farmer, Jamison says, I grew up with a constant connection to the land around me and a feeling of permanence in a changing world. It is deeply gratifying to be finally in a position to give back some of what we have taken from the land. We are excited to be able to live on the edge of the raucous wild beauty that this project will become. Thanks to SWCA s coordination with the Corps and help completing the extensive paperwork required, the Gin City Mitigation Bank is scheduled to be fully approved by the end of In addition, Houston staff coordinated the efforts of a specialty engineering firm to complete the hydrology analysis and restoration planning. SWCA also helped Jamison contract experts to conduct the restoration work that will begin this fall, as well as companies that will plant the first trees. Finally, SWCA will provide long-term monitoring on the site to ensure compliance with the terms of the mitigation banking instrument. A Win-Win Project The Gin City Mitigation Bank project is ideal in many ways. First, because the proposed restoration of 500 acres of bottomland hardwood wetland forest occurs in a relatively small HUC, with no overlapping primary service areas from other local mitigation banks, there is a real need for a bank at this location. This restoration also will help reestablish a forested riparian zone along Cedar Bayou in eastern Harris County, benefitting wildlife species (especially waterfowl) that use this region. Finally, there is demand. Gin City and Cedar Bayou are just miles away from one of the country s largest petrochemical hubs, Mont Belvieu. Wetland impacts associated with pipeline projects and facility expansions are common, driving a need for mitigation that has yet to be very well satisfied. Once this project is finished, it will be a win-win for multiple stakeholders. The Corps wins by establishing a mitigation bank in an area of high permit activity, cutting down on permit turnaround time and lessening staff workload. Industry permittees win by getting a no-risk solution to their mitigation needs, allowing them to get their development permits faster so they can start their projects sooner. Jamison and her family win by deriving a new revenue stream from their family land and preserving it for future generations to enjoy. And last but not least, we all win by realizing the benefits of 500 acres of forested wetland restoration. Those benefits include enhanced water quality in Cedar Bayou (a real plus for downstream Galveston Bay), floodwater retention protecting downstream homes and businesses, restored habitat for multiple wildlife species, and more than 200,000 new trees that will improve air quality and remove carbon dioxide from the atmosphere. You just can t get a better deal than that. For more information on the Gin City project or mitigation banking, contact Matt Stahman at [email protected].