Competing With Natural Channel Design Crediting Paradigms: Review of Dam Removal as an Innovative Stream Mitigation Approach
Wes Newell
RES
Pittsboro, NC
Stream mitigation has been dominated over the last several decades by Rosgen-based fluvial geomorphology. Natural Channel Design (NCD) has been codified by many States through the development of rigid mitigation crediting methods. The NCD paradigm has limited innovative forms of stream mitigation, such as dam removal. When dam removal as an alternative for stream mitigation is prospected, the regulatory community does not know how to fit these projects into state-sanctioned, simplified crediting schemes. The inability to accommodate alternative stream mitigation approaches increases cost and causes prolonged delays relative to NCD, which further decreases economic viability. The economics and ecological impacts are discussed further in various publications, including Doyle et. Al. 2015 and Lave and Doyle 2020.
Standardized NCD stream crediting rigidly defines monitoring and success criteria required to produce mitigation credit. In addition, the standardized process defines the service area that can be utilized for a project based on the concept that 1st and 2nd-order NCD streams will dominate the industry. Indeed, Geographic Service Area (GSA) is quite different for dam removal and river restoration, with functional benefits extending to the Chesapeake Bay, the Gulf of Mexico, and the Sargasso Sea. The crediting and service area paradigms limit innovative stream mitigation approaches unless alternative proposals become more acceptable to Interagency Review Teams (IRTs).
The response to innovative pre-application prospectuses typically includes the following generic statement: “We acknowledge that the proposed Bank has the potential to provide ecological improvements but may not provide appropriate compensatory mitigation for activities authorized by Section 404 of the Clean Water Act. Some portions of the proposal may exceed the legal authority of these programs, which is not intended to be for environmental restoration. In addition, the proposed project does not meet State Laws (i.e., the paradigm) for Wetland and Stream Mitigation Banks”.
This statement alone almost guarantees that dam removal and river restoration will require years longer to permit, with increased cost relative to codified mitigation on headwater streams. The history of dam removals using 404 mitigation protocols will be reviewed, including quantitative functional assessments, alternative crediting methods, and past service area proposals in the southeastern U.S.
About Wes Newell
Wes Newell has been involved in dam removal, stream, and wetland mitigation since 1992, including 30+ years experience in funding acquisition, stakeholder negotiations, design, permitting, construction, repair, removal, and associated river restoration. Mr. Newell has been involved with over 25 dam removals, including 120,000+ linear feet of river restoration. During this period, Mr. Newell developed quantitative functional assessments and decision support models for dam removal, river restoration, and aquatic species mitigation in VA, S.C., and N.C. The models quantified the functional benefits generated by impoundment removal and river restoration, provided a mechanism to promote funding acquisition, and defended dam removal as a viable form of Section 404 mitigation. Mr. Newell converted the quantitative results of the VA model into a form compatible with the Virginia Unified Stream Methodology (USM). In addition, a mussel habitat restoration model was developed for Carolina Heelsplitter (Lasmigona Decorata) in S.C. to promote an alternative to the natural channel design paradigm dominating Section 404 mitigation in the Southeast. Mr. Newell currently serves as a senior manager for RES in North Carolina.