Many small projects can have more impact than one coherent big one.
The federal government does not require mitigation outside of the riparian corridor Part of the problem is that this may open up mitigation for only a few general permit impacts, but future administrations could expand it and require mitigation for all impacts When DEP is calculating total onsite impacts, they should not consider all adjacent properties owned by the same applicant as one site. In brownfields - wetland restored may be smaller than disturbance, but result may be a high quality wetland. DEP should be more flexible in these cases Particularly in brownfields with a no further action letter - impacted wetlands, but not hazardous Mitigation in planning area 5 is ok if balanced tighten in Planning Area 5, loosen in centers and Planning Area 1, etc. Otherwise, State Plan link is not o.k. The DEP needs to establish a hierarchy of mitigation for general permits But a simple one if any because mitigation for GPs must be quick and simple.