There's a local issue here in Maryland that involves the potential development of a mostly retired farm that has a few patches of pretty nice woods on it. Most field ecologists would describe it that way, certainly, with additional details about the declining health of some very large specimen trees, or the unstable nature of eroding streams on the property. Or even categories like "primary buffer" and "priority forest." These are all assessments based on "form," which in the environmental assessment world, lies somewhere between "appearance" and "function." And since one of the six classically defined functions of a natural place is "aesthetics and viewshed," and since observations like, "numerous infected nut-bearing trees" have direct ties to ecological function, let's not dismiss "environmental form."
The problem arises, as it has on this individual project, when passionate environmentalists and occasionally the odd "cubicle ecologist" decide to do their own assessment....one that's based on basic appearances. The eroding creek onsite is causing significant pollution problems downstream (a river defined as "biologically dead" for most of the summer), and yet these advocates have stated that the farm "keeps the watershed clean and healthy downstream." What? Another claim has been that the property should be saved because of its value to wildlife (note: no one from the environmental community has in any way proposed to purchase the property, they only seek to deny development rights to the landowners). The document proceeds to list the wildlife of concern: "Deer, frogs, and turtles." Here's the thing. I live in a 75 year old house inside City limits. We have deer, frogs, raccoons, foxes, rabbits, hawks, snakes, bald eagles, and even nesting herons. Hopefully these folks don't find out about my neighborhood, or they'll petition the City to force us to abandon it. It's also worth noting that the City intentionally annexed this property and zoned it for dense development for several years ago, with no complaint from the environmental community because there was no immediate threat.
So what really needs to be saved - protected - denied from development? It has to do with function. Why in the world would we battle to save (read: leave alone) a stream that is eating its own banks and shooting the polluted sediment right downstream into public fishing and crabbing waters? Why would we save (read; buy with tax dollars) a woodlot that is actually an old pasture that somebody forgot to mow too many years in a row, and so some trees of questionable to moderate value popped up? Is there seriously no higher priority resource anywhere in the area in need of saving?
So, what is ecological function? Function is an expression of the relationship between patterns, processes, and mechanisms that drive environmental form (and possibly environmental appearance).The notion of environmental preservation is - or should be - based on the notion of permanently protecting, usually via fee simple purchase or easement purchase, the highest-functioning at-risk habitats under consideration by the folks with the money.
What does "high functioning" mean? High functioning habitats are those whose biogeochemical interactions span across numerous temporal and spatial scales. Or, as some may put it, multiple feedback loops with very few "free radicals." Everything has value. Everything is used. Very little leaves the habitat. A recent study by US Fish and Wildlife Service found that functionally "clean" water in suburban areas is correlated with a drainage area less than 10% covered in impervious surface. Drainage areas covered 10-25% in pavement were "moderate functioning," and USFWS declared that most drainages over 25% impervious are biologically impaired. So before you claim that the water coursing through your favorite site is "clean and fresh," make sure, at minimum, that it drains less than 10% pavement.
Wednesday, July 31, 2013
Tuesday, February 26, 2013
What is Environmental Leadership?
Fundamental change is starting to occur within the realms of leadership within the environmental world. The change is based upon three premises - a transition of generations, a tiredness for protocol that never satisfied a scientific need and no longer satisfies political fancy, and an economy that demands accountability and direct results for startlingly tiny amounts of money. For those in the evening of their careers, it is certainly a dynamic time. I've been alarmed, however, that more senior environmental "leaders" don't feel positively about the "new generation" or about what is coming next. What follows will read to some as an ageist rant - it's anything but that. No, this is a rant about academic platitudes and literary happy hours. About 40 year old soap boxes that were never hurled through a window or burned in the street, but instead, kept on display as a monument to themselves.
What is leadership? There are two standard definitions, which both require examination for our purposes.
Leadership:
1. The action of leading
2. Having the position of a leader
The people who read this blog are smart people, and as a result, I shouldn't have to continue past that definition. You now know what I am preparing to say. But I'll say it anyway.
As a prime example - but one of very many on the scientific and political landscape - there's a certain "group of senior leaders" within the Chesapeake Bay watershed who think pretty highly of themselves and their CVs. They craft position papers for elected officials about once every 18 months, and true to the nature of such a group, they celebrate any success as a result of their input and leverage.....and deride any failure as the result of "corruption." Obviously I find that tactic a little childish but I tend to give them deference - good people trying to effect positive change. It has come to my attention that they also have a blog, which you can find here. Look again at those two definitions of "leadership," above, and peruse some of the most recent blog topics:
1. Complaining about a comprehensive plan revision after the comment period has been closed.
2. Bragging about their critical influence in the development of animal manure regulations, while simultaneously complaining that the resulting regulations are critically flawed and will not work.
3. Complaining about Perdue Chicken's disinformation campaign (that's truly what it was) associated with what most conservationists knew was an ill-advised dud of a lawsuit against Perdue Chicken. Now Perdue seeks $3 million in legal fees from the environmentalist plaintiffs....wonder if the Senior Leaders will help fundraise?
What consistently lacks in any of this is a road map to doing things differently. These "leaders," and so many thousands like them, still believe that their name or their organization's name gives them distinct political leverage (there's that second definition of "leadership" again) to have their voice heard above other voices - particularly, those singularly based in a motive for profit. They are wrong. They don't favor engagement or compromise. They simply tell stories of how good it all once was, how bad it currently is, and how much worse it could be, and hope that somehow, someone else will actually do the good work of conserving the world's air, soil, water, and biota. Increasingly, true political decision makers, as well as their anti-environment opponents, just shake their heads at best, and laugh at worst, as the platitude-holding "leaders" demand the same regulations they've been demanding for 30 years, with rapidly decreasing impact.
We - and I - don't need any more "senior environmental leaders" who are going to "tell us" how things are bad, fully lacking coherent, new ideas to make them better. Other than the passage of several (now) poorly enforced pollution laws over 40 years ago, their business plan of organizing and complaining has accomplished little. It is time, sirs and madams, for a new model.
We need leadership rooted in the "first definition." If I had my way, anyone touting themselves as a "leader" - let alone a "senior leader" - should be required to spend their time considering the following:
1. Teaching the next generations (two new generations are already in the field) about all of the science's (or the movement's) past failures and successes since 1969. What models are there? What pitfalls can be expected? How are opponents and antagonists created, emboldened, and eventually dissolved? What mistakes were made - were they inevitable? Were they necessary? How do we understand what that even means?
2. Having a high ranking government position and writing a book about environmental problems does not make you an environmental leader. It's great that you had some book tours, and you met two presidents. So what, if your life's work (cleanup of a river) remains totally incomplete? Consider writing a book that won't sell a million copies but will change lives - something like, "What the next generation must do to truly save the Bay." Or "How Your Home Must Save the Bay."
3. Stop complaining about problems that occur far after the point that they've exited your locus of control. A true leader is either connected enough to impact policy at its inception, or tactful enough to rally meaningful support at future decision points. STOP COMPLAINING ABOUT THINGS YOU DO NOT INTEND TO ACTUALLY EMBARK ON FIXING.
4. The 1970s model of environmental stewardship was essentially "My job is to bring awareness to the unwashed masses, and magically that will transform into a small army of activists that does not include me, who will then ensure that massive change occurs." Unfortunately, Eco Darth Vader, the last decade of behavioral environmental studies has shown that your generation's theory of creating engaged citizens absolutely DOES NOT WORK. We know the harm of tobacco, and we still smoke (I enjoy a Nicaraguan in a natural wrapper from time to time, myself). We know the harm of texting while driving, and we still do it. We know that we are strangling our own life support system (this planet), and yet, we don't stop. If you want to be a leader, now is the time to snap out of your 10, or 20, or 40 year slump and realize that you need to go out and build leaders, not just tell sad stories and threaten lawsuits from time to time.
When my generation (Generation X) retires in 30 years (60 years in the work force, no pension), our grown children will ask, "What did you do to make it better?" We know that will happen because we asked our parents (hippies turned venture capitalists) the same thing, and they've - by and large - never had an answer beyond, "We got the clean water act passed!" Those of you in that generation still have many years in front of you - make them the most impactful. Go out and recruit new scientists, new citizens, new activists. It's time to realize that a meaningful legacy will be carried out by those who respect and admire your actions to save life on earth, not just postulate about its hazards and woes over the course of a well-paid, pension-ensured career.
Leadership: The action of leading
What is leadership? There are two standard definitions, which both require examination for our purposes.
Leadership:
1. The action of leading
2. Having the position of a leader
The people who read this blog are smart people, and as a result, I shouldn't have to continue past that definition. You now know what I am preparing to say. But I'll say it anyway.
As a prime example - but one of very many on the scientific and political landscape - there's a certain "group of senior leaders" within the Chesapeake Bay watershed who think pretty highly of themselves and their CVs. They craft position papers for elected officials about once every 18 months, and true to the nature of such a group, they celebrate any success as a result of their input and leverage.....and deride any failure as the result of "corruption." Obviously I find that tactic a little childish but I tend to give them deference - good people trying to effect positive change. It has come to my attention that they also have a blog, which you can find here. Look again at those two definitions of "leadership," above, and peruse some of the most recent blog topics:
1. Complaining about a comprehensive plan revision after the comment period has been closed.
2. Bragging about their critical influence in the development of animal manure regulations, while simultaneously complaining that the resulting regulations are critically flawed and will not work.
3. Complaining about Perdue Chicken's disinformation campaign (that's truly what it was) associated with what most conservationists knew was an ill-advised dud of a lawsuit against Perdue Chicken. Now Perdue seeks $3 million in legal fees from the environmentalist plaintiffs....wonder if the Senior Leaders will help fundraise?
What consistently lacks in any of this is a road map to doing things differently. These "leaders," and so many thousands like them, still believe that their name or their organization's name gives them distinct political leverage (there's that second definition of "leadership" again) to have their voice heard above other voices - particularly, those singularly based in a motive for profit. They are wrong. They don't favor engagement or compromise. They simply tell stories of how good it all once was, how bad it currently is, and how much worse it could be, and hope that somehow, someone else will actually do the good work of conserving the world's air, soil, water, and biota. Increasingly, true political decision makers, as well as their anti-environment opponents, just shake their heads at best, and laugh at worst, as the platitude-holding "leaders" demand the same regulations they've been demanding for 30 years, with rapidly decreasing impact.
We - and I - don't need any more "senior environmental leaders" who are going to "tell us" how things are bad, fully lacking coherent, new ideas to make them better. Other than the passage of several (now) poorly enforced pollution laws over 40 years ago, their business plan of organizing and complaining has accomplished little. It is time, sirs and madams, for a new model.
We need leadership rooted in the "first definition." If I had my way, anyone touting themselves as a "leader" - let alone a "senior leader" - should be required to spend their time considering the following:
1. Teaching the next generations (two new generations are already in the field) about all of the science's (or the movement's) past failures and successes since 1969. What models are there? What pitfalls can be expected? How are opponents and antagonists created, emboldened, and eventually dissolved? What mistakes were made - were they inevitable? Were they necessary? How do we understand what that even means?
2. Having a high ranking government position and writing a book about environmental problems does not make you an environmental leader. It's great that you had some book tours, and you met two presidents. So what, if your life's work (cleanup of a river) remains totally incomplete? Consider writing a book that won't sell a million copies but will change lives - something like, "What the next generation must do to truly save the Bay." Or "How Your Home Must Save the Bay."
3. Stop complaining about problems that occur far after the point that they've exited your locus of control. A true leader is either connected enough to impact policy at its inception, or tactful enough to rally meaningful support at future decision points. STOP COMPLAINING ABOUT THINGS YOU DO NOT INTEND TO ACTUALLY EMBARK ON FIXING.
4. The 1970s model of environmental stewardship was essentially "My job is to bring awareness to the unwashed masses, and magically that will transform into a small army of activists that does not include me, who will then ensure that massive change occurs." Unfortunately, Eco Darth Vader, the last decade of behavioral environmental studies has shown that your generation's theory of creating engaged citizens absolutely DOES NOT WORK. We know the harm of tobacco, and we still smoke (I enjoy a Nicaraguan in a natural wrapper from time to time, myself). We know the harm of texting while driving, and we still do it. We know that we are strangling our own life support system (this planet), and yet, we don't stop. If you want to be a leader, now is the time to snap out of your 10, or 20, or 40 year slump and realize that you need to go out and build leaders, not just tell sad stories and threaten lawsuits from time to time.
When my generation (Generation X) retires in 30 years (60 years in the work force, no pension), our grown children will ask, "What did you do to make it better?" We know that will happen because we asked our parents (hippies turned venture capitalists) the same thing, and they've - by and large - never had an answer beyond, "We got the clean water act passed!" Those of you in that generation still have many years in front of you - make them the most impactful. Go out and recruit new scientists, new citizens, new activists. It's time to realize that a meaningful legacy will be carried out by those who respect and admire your actions to save life on earth, not just postulate about its hazards and woes over the course of a well-paid, pension-ensured career.
Leadership: The action of leading
Monday, February 4, 2013
Is the Use of Regionally Sourced Plant Material a Valid Requirement for Plants in a Climate Change Scenario?
Here in Maryland, as in many states, the assembly of a restoration planting plan often requires the explicit statement: "All plant material is to be sourced from (name physiographic province of the state) region of (name a term that describes five states including yours)." The idea, and it is a noble one, is to ensure that the New York Finger Lakes wetland you are building is populated by plant material that was not sourced from Washington state, which could cause a dilution of high quality genetics from the regionally appropriate plants. One of the first (academic or regulatory) problems of this rule is that it is only applied to live plant material, and not to conservation seed mixes, even though those seed mixes contain seeds for perennial native plants. Oops.
But there's a much larger problem with focusing on New York-bred plants for New York projects. Take a look below.
The vast majority of the country should experience a 5 to 7 degree increase in mean temperature. Now, mean temperatures are deceiving because it's actually the minimum temperatures that impact things like growing seasons, insect overwintering mortality, and seed viability. But let's ignore that, or, rather than ignoring it, let's take a look at the USDA growing season map, which is dictated by lowest temperatures, not mean temperatures.
You gardeners may recall that just a year ago, USDA revised its plant zone map based upon climate change data that is already rolling in. How might a 5 degree change in the next 40 years impact this map further? Well, let's look at Maryland, largely a Zone 7a state (0-5 degrees - we haven't seen temperatures that low in a decade). An increase of 5 to 7 degrees could place Maryland in Zone 8a, a solid subtropical coastal growing zone. That's a lot of change in a short amount of time. Maryland ecosystems could quite feasibly start acting like South Carolina ecosystems. Which brings us back to the topic of regional plant genetics.
If I'm planting an emergent wetland where even perennial plants will succumb after less than 10 years, it seems to make great sense to utilize the most locally native plant genetics possible. But what about planting an oak swamp? An alder thicket? An upland hickory forest stand? What about plants that quite conceivably could still be alive as the climate changes drastically over the next 40 years?
For long-lived plants used in forestry and restoration work, I propose abandoning the "regional plant genetics" preferences and requirements, and instead, for us to begin looking to our south to find strong genetics for plants that are tolerant of the stresses that climate change is likely to bring us - increased flooding, increased drought, unpredictability of precipitation, and warmer minimum temperatures. In Maryland, for example, the Shumard Red Oak exists in the wild in our southernmost county. Yet, it's never mentioned in conversations about forestry, forest habitat management, or habitat restoration because "It's Not Native." I think this is foolish, and currently there are 200 Shumard acorns from northern North Carolina now hardening in my basement refrigerator, to be used on habitat restoration sites.
"This is preposterous!" you might say. An alternate example with a different story ending is the Sugar Maple. Most foresters and landscape architects stopped planting sugar maples in the Mid-Atlantic in the early 2000s because the summer droughts were killing huge numbers of trees. Yet, our DNR Forestry Division still refers to Sugar Maple as a "Maryland Native Tree" - providing it to citizens to plant on their property!
Here's what's going on with the Sugar Maple:
The species is predicted to lose over 90% of its range. It's already happening. Why - as a professional community - can't we agree to change and accept new conditions around us?
So when you're considering a list of long-lived trees for a forestry, landscaping, or habitat restoration site, there's no need to stick to "the standards" for native plants in your area. Please plan ahead, and perhaps your innovation to prepare habitat for climate change will be noted as part of your legacy. It's certainly better than being known as "the idiot who planted all these dead sugar maples 40 years ago."
But there's a much larger problem with focusing on New York-bred plants for New York projects. Take a look below.
The vast majority of the country should experience a 5 to 7 degree increase in mean temperature. Now, mean temperatures are deceiving because it's actually the minimum temperatures that impact things like growing seasons, insect overwintering mortality, and seed viability. But let's ignore that, or, rather than ignoring it, let's take a look at the USDA growing season map, which is dictated by lowest temperatures, not mean temperatures.
You gardeners may recall that just a year ago, USDA revised its plant zone map based upon climate change data that is already rolling in. How might a 5 degree change in the next 40 years impact this map further? Well, let's look at Maryland, largely a Zone 7a state (0-5 degrees - we haven't seen temperatures that low in a decade). An increase of 5 to 7 degrees could place Maryland in Zone 8a, a solid subtropical coastal growing zone. That's a lot of change in a short amount of time. Maryland ecosystems could quite feasibly start acting like South Carolina ecosystems. Which brings us back to the topic of regional plant genetics.
If I'm planting an emergent wetland where even perennial plants will succumb after less than 10 years, it seems to make great sense to utilize the most locally native plant genetics possible. But what about planting an oak swamp? An alder thicket? An upland hickory forest stand? What about plants that quite conceivably could still be alive as the climate changes drastically over the next 40 years?
For long-lived plants used in forestry and restoration work, I propose abandoning the "regional plant genetics" preferences and requirements, and instead, for us to begin looking to our south to find strong genetics for plants that are tolerant of the stresses that climate change is likely to bring us - increased flooding, increased drought, unpredictability of precipitation, and warmer minimum temperatures. In Maryland, for example, the Shumard Red Oak exists in the wild in our southernmost county. Yet, it's never mentioned in conversations about forestry, forest habitat management, or habitat restoration because "It's Not Native." I think this is foolish, and currently there are 200 Shumard acorns from northern North Carolina now hardening in my basement refrigerator, to be used on habitat restoration sites.
"This is preposterous!" you might say. An alternate example with a different story ending is the Sugar Maple. Most foresters and landscape architects stopped planting sugar maples in the Mid-Atlantic in the early 2000s because the summer droughts were killing huge numbers of trees. Yet, our DNR Forestry Division still refers to Sugar Maple as a "Maryland Native Tree" - providing it to citizens to plant on their property!
Here's what's going on with the Sugar Maple:
The species is predicted to lose over 90% of its range. It's already happening. Why - as a professional community - can't we agree to change and accept new conditions around us?
So when you're considering a list of long-lived trees for a forestry, landscaping, or habitat restoration site, there's no need to stick to "the standards" for native plants in your area. Please plan ahead, and perhaps your innovation to prepare habitat for climate change will be noted as part of your legacy. It's certainly better than being known as "the idiot who planted all these dead sugar maples 40 years ago."
Monday, January 7, 2013
Your Consultant Is Not A Corps Certified Wetland Delineator
I frequently run across the CVs of high-level wetland professionals who each claim to be a "USACE Certified Wetland Delineator." Hmmm. That's all well and good - after all, the annals of wetland management and regulation are full of tales of both consultants and regulatory staff making egregious wetland boundary errors during wetland delineations - errors which impact everything from legitimate economic uses of land, to vital aquatic habitats that might be hard to recognize. There could - and should - be some way to make sure everyone in the field, including government employees, is competent to do this type of work. Here's the problem - there's no such program at the federal level. No such certification. No such thing as a "USACE Certified Wetland Delineator." From a 2007 mailer released by NC State University:
"The US Army Corps Wetland Delineator Certification Program (WDCP) was canceled in 2003 before implementation. The WDCP does not exist (emphasis added) and the Corps has no plans to resurrect it."
In 2011, a webpage from Rutgers University similarly stated,
"There is currently no official certification program offered through the ACOE."
So, now that we can verify that there are, in fact, no Corps-certified delineators, let's back up a bit. In 1992, the Corps announced the formation of the Wetland Delineator Certification Program (WDCP). Meetings between the regulated and regulatory community produced an important bridge concept - that both regulatory staff and for-profit consultants should be certified prior to making legal determinations (or recommendations) on wetland boundaries. In the halls of Congress, as well as in the headquarters of the US Army Corps of Engineers - this made perfect sense. That's what produced the first failure.
A select group of Corps, USDA, and USFWS wetland experts worked quickly to develop the certification program - one that would include both written and field testing. As the mythology goes (I wasn't in the room, and trust me, this is not well documented), upon seeing drafts of the exam, Corps regulatory managers began to increasingly voice concerns that their staff may not have the basic wetland delineation training or professional experience necessary to pass the two-part exam that was being prepared at that moment by the Corps' wetland experts. Then (this part we know to be true), magically, without notifying the "regulated community" (infrastructure agencies, developers, etc), the portion of the WDCP that required certification of Corps field staff was quietly eliminated. Suddenly, this new grand plan - one that arose from massive wetland delineation failures on the part of permit applicants as well as regulatory staff - only sought to scrutinize and certify permit applicants - not government staff. Of course, this is problematic at its most basic level because Corps field staff wield an enormous amount of legal authority over wetland boundaries, and whether avoidance, minimization, and mitigation approaches are appropriate. If the "mythology" is true, then, to concede that their staff was not competent to represent the agency was a major blunder.
The ranks of private sector supporters of the WDCP shrank very quickly, but the process went on anyway. The end result was a "provisional certification" that would be awarded, and perhaps revisited if - not when - the WDCP became a formal, nationwide program. Several hundred consultants took the exam and nearly half of them passed the written portion. Nearly all who passed the written portion also passed the field portion of the exam. These several hundred men and women - most of them now age 45-55, were awarded the title "Provisional Certified Wetland Delineator."
Side note: for those of you unfamiliar with the legal moniker of "provisional," I'll provide an example. If you apply for a hunting license and lack a piece of required information, like the ID# on your hunter safety card, then the state will issue you a "provisional" license. It's "provisional" because it requires additional steps to take place for you to actually garner the title of "licensed hunter." Basically, "you are certified...PROVIDED THAT..(insert requirements for future action). " Back to our story...
At the time, the "Provisional" delineation title was granted because the program was not official, and had not passed "official rule making," a critical part of any time of federal award, certification, or regulation. The "provisional" status of those professionals who passed the two-part exam was intended to be immediately (say, within three years) rolled into the nationwide WDCP in 1997, at the very latest. But although the Corps proposed its final recommendations for the WDCP to Congress in 1995, the program languished until the Corps officially eliminated the WDCP in 2003. Most telling, perhaps is the Corps' final report to Congress in 1998, which reports the following: "Government Levels Affected: None." That only is important if your title related to that Congressional action is "provisional" - in which case, your status is now nil.
Finally, adding insult to injury for the then-young professionals who jumped through the hoops of the written application, the written test, and the field test (all administered by agency staff who would never have to take the test) have to suffer through the knowledge that the Corps of Engineers does not maintain a list of their names. Why? I don't have a good answer for that.
I'm sorry, ladies and gentlemen. If an agency certified you provisionally as a wetland delineator 20 years ago, in a test/demonstration program that was never offered throughout the agency's jurisdiction, a program that was never funded, never fully approved by Congress, then you actually cannot be a "Corps Certified Wetland Delineator." Then, if they never converted your provisional status to "full certified" in those 20 years, and on top of that, they do not maintain a list of you and your cohorts who successfully completed your exam, then you, my friends, are unfortunately not "Corps Certified Wetland Delineators." You are, of course, a "Formerly Provisionally Certified Wetland Delineator, 1992-1997, Expired" which is not AT ALL the same thing as a "Corps Certified Wetland Delineator."
I'm not blaming you - please don't think I am. I'm blaming the Corps, who let this die on the vine, and your certification with it.
"The US Army Corps Wetland Delineator Certification Program (WDCP) was canceled in 2003 before implementation. The WDCP does not exist (emphasis added) and the Corps has no plans to resurrect it."
In 2011, a webpage from Rutgers University similarly stated,
"There is currently no official certification program offered through the ACOE."
So, now that we can verify that there are, in fact, no Corps-certified delineators, let's back up a bit. In 1992, the Corps announced the formation of the Wetland Delineator Certification Program (WDCP). Meetings between the regulated and regulatory community produced an important bridge concept - that both regulatory staff and for-profit consultants should be certified prior to making legal determinations (or recommendations) on wetland boundaries. In the halls of Congress, as well as in the headquarters of the US Army Corps of Engineers - this made perfect sense. That's what produced the first failure.
A select group of Corps, USDA, and USFWS wetland experts worked quickly to develop the certification program - one that would include both written and field testing. As the mythology goes (I wasn't in the room, and trust me, this is not well documented), upon seeing drafts of the exam, Corps regulatory managers began to increasingly voice concerns that their staff may not have the basic wetland delineation training or professional experience necessary to pass the two-part exam that was being prepared at that moment by the Corps' wetland experts. Then (this part we know to be true), magically, without notifying the "regulated community" (infrastructure agencies, developers, etc), the portion of the WDCP that required certification of Corps field staff was quietly eliminated. Suddenly, this new grand plan - one that arose from massive wetland delineation failures on the part of permit applicants as well as regulatory staff - only sought to scrutinize and certify permit applicants - not government staff. Of course, this is problematic at its most basic level because Corps field staff wield an enormous amount of legal authority over wetland boundaries, and whether avoidance, minimization, and mitigation approaches are appropriate. If the "mythology" is true, then, to concede that their staff was not competent to represent the agency was a major blunder.
The ranks of private sector supporters of the WDCP shrank very quickly, but the process went on anyway. The end result was a "provisional certification" that would be awarded, and perhaps revisited if - not when - the WDCP became a formal, nationwide program. Several hundred consultants took the exam and nearly half of them passed the written portion. Nearly all who passed the written portion also passed the field portion of the exam. These several hundred men and women - most of them now age 45-55, were awarded the title "Provisional Certified Wetland Delineator."
Side note: for those of you unfamiliar with the legal moniker of "provisional," I'll provide an example. If you apply for a hunting license and lack a piece of required information, like the ID# on your hunter safety card, then the state will issue you a "provisional" license. It's "provisional" because it requires additional steps to take place for you to actually garner the title of "licensed hunter." Basically, "you are certified...PROVIDED THAT..(insert requirements for future action). " Back to our story...
At the time, the "Provisional" delineation title was granted because the program was not official, and had not passed "official rule making," a critical part of any time of federal award, certification, or regulation. The "provisional" status of those professionals who passed the two-part exam was intended to be immediately (say, within three years) rolled into the nationwide WDCP in 1997, at the very latest. But although the Corps proposed its final recommendations for the WDCP to Congress in 1995, the program languished until the Corps officially eliminated the WDCP in 2003. Most telling, perhaps is the Corps' final report to Congress in 1998, which reports the following: "Government Levels Affected: None." That only is important if your title related to that Congressional action is "provisional" - in which case, your status is now nil.
Finally, adding insult to injury for the then-young professionals who jumped through the hoops of the written application, the written test, and the field test (all administered by agency staff who would never have to take the test) have to suffer through the knowledge that the Corps of Engineers does not maintain a list of their names. Why? I don't have a good answer for that.
I'm sorry, ladies and gentlemen. If an agency certified you provisionally as a wetland delineator 20 years ago, in a test/demonstration program that was never offered throughout the agency's jurisdiction, a program that was never funded, never fully approved by Congress, then you actually cannot be a "Corps Certified Wetland Delineator." Then, if they never converted your provisional status to "full certified" in those 20 years, and on top of that, they do not maintain a list of you and your cohorts who successfully completed your exam, then you, my friends, are unfortunately not "Corps Certified Wetland Delineators." You are, of course, a "Formerly Provisionally Certified Wetland Delineator, 1992-1997, Expired" which is not AT ALL the same thing as a "Corps Certified Wetland Delineator."
I'm not blaming you - please don't think I am. I'm blaming the Corps, who let this die on the vine, and your certification with it.
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