Rapid Wetland Functional Assessment: Its Role and Utility in the Regulatory Arena

Section 404 of the Clean Water Act (CWA) regulates the discharge of dredged or fill material, which is defined as a pollutant, into waters of the United States by requiring potential dischargers to obtain a permit for such activities. The Section 404(b)(1) Guidelines provide the substantive environmental criteria by which all dredge and fill permit applications arc reviewed. The Guidelines consist of 4 basic steps: 1) evaluation of practicable alternatives; 2) evaluation of relation of discharge to other environmental standards; 3) assessment of significant degradation to waters of the U.S.; and 4) assessment of appropriate steps to minimize impacts. Wetland functional assessment is important in steps 1, 3, and 4. The use of wetland functional assessment techniques has typically been hindered by lack of time and resources, among other technical concerns, by the resource agencies implementing the Section 404 program. Functional assessment is critical to the Section 404 program since most decisions revolve around an assessment of wetland functions. The Hydrogeomorphic Classification for Wetlands (Brinson, 1993) and the developing functional assessment procedure shows potential for being rapid and inexpensive, scientifically-based and replicable. It is based upon functional indicators which can be recognized in the field and can form the basis for functional indices. The utility of the HGM procedure is illustrated using an example from West Kentucky.