Loss of half of the remaining habitat is being proposed. It is obvious that this will severely impact the remaining wildlife in the basin. The majority of the in-basin mitigation will be enhancement of existing wetlands. The in-basin mitigation plan confuses the terms when discussing the details of the mitigation plan. The term restoration means converting existing upland habitat back to wetland in areas that were historically wet.
Enhancement is, however, improving the functions of existing wetlands.
There will, therefore, be a net loss of wetland acreage because 18.28 acres of wetland will be lost and only 6.09 acres will be enhanced. The soils are almost always left intact although they are tilled. The proposal to restore ten acres of the Vacca farmland from prior converted wetland is therefore more of an enhancement throught replacement of hydrology and replanting plants than a restoration, and the mitigation ratio would be lower than that offered. The total mitigation credit for enhancing the Vacca farm should be only 33 percent of the total acreage proposed. Additionally the plan presented is lacking in sufficient detail to determine if the proposal is viable.