The net gain concept should be applied within a project context to ensure accountability and effectiveness of mitigation efforts. Lacks strong monitoring requirements and inventory protocols. The draft rule constantly makes reference to preserving ecological functions, adaptive management, and best available science to guide decision making. Monitoring and inventory protocols should be better articulated to ensure that they actually work. Allows for varying levels of enforcement.
All shorelines deserve the same level of strong regulation and enforcement.
Allows lower standards for urban areas. Aside from being without scientific merit, it is areas within urban growth boundaries that are at greatest risk from degradation. We need to save what we have left and do no harm to existing habitat if we hope to recover salmon.